Breach filing
ArchivedSummit Behavioral Healthcare: 70,822 individuals, Feb 2021.
Summit Behavioral Healthcare reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 26 February 2021. The filing records the organisation as a healthcare provider in Tennessee and lists 70,822 individuals affected, which makes it the 33rd largest of the 196 Tennessee filings on the register and the 106th largest of the 715 filings submitted nationally in 2021. Among the 14 Tennessee filings made in 2021 it ranks 2nd.
Individuals affected
70,822
As reported to HHS
Modelled cost (IBM 2025)
$11.3M
Method shown, not disclosed
Rank in TN
33rd
of 196 Tennessee filings
Rank in 2021
106th
of 715 filings nationally
Section F.1 / The filing
As posted by HHS OCR
Every value below is the portal's own field for this filing, plus its rank within the register.
- Covered entity type
- Healthcare Provider
- Individuals affected
- 70,822
- Breach submission date
- 26 February 2021
- Submission year
- 2021
- Type of breach
- Unauthorized Access/Disclosure
- Location of breached information
- Business associate present
- No
- State
- Tennessee (TN)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Tennessee by size
- 33rd of 196
- Rank in 2021 nationally
- 106th of 715
- Tennessee median filing
- 3,371 individuals
- Register id (derived)
- TN-20210226-summit-behavioral-healthcare
Section F.2 / In context
Where this filing sits in Tennessee and in 2021
OCR classifies the incident as unauthorized access or disclosure, with the breached information held in email. Unauthorized Access/Disclosure is the type recorded on 35 of the 196 Tennessee filings (18%) and on 18% of all filings submitted in 2021. Email appears on 24% of Tennessee filings.
No business associate is recorded on the filing; 36% of Tennessee filings do involve one. At 70,822 individuals the breach is 21 times the Tennessee median filing of 3,371 and 18 times the national median of 4,000 across all 7,884 filings. It sits in the 10,000 to 99,999 band, which holds 1,938 filings.
As of 28 August 2026 the case is listed in the HHS OCR breach portal archive. OCR's closing summary of the case is reproduced in full below.
Tennessee's breach notification statute (Tenn. Code Ann. 47-18-2107) requires notice to affected residents immediately, but no later than 45 days from discovery or notification. Its attorney general threshold: no mandatory AG notification for private-sector breaches. The HIPAA Breach Notification Rule ran alongside it: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery, which is the clock that put this filing on the portal.
Multiplying 70,822 individuals by IBM's $160 customer-PII cost per record (Cost of a Data Breach 2025, the figure the site's calculator uses) gives a modelled $11.3M; the 2026 edition's $192 gives $13.6M. Both are modelled estimates with the method shown, not costs disclosed by Summit Behavioral Healthcare. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 2.0 times the sector average.
Section F.3 / OCR closing summary
The portal's archived description, in full
Written by the Office for Civil Rights when the case was closed and reproduced verbatim from the HHS export.
The covered entity (CE), Summit Behavioral Healthcare, reported that an employee impermissibly emailed the electronic protected health information (ePHI) of 70,822 individuals to his personal email account. The CE notified HHS, affected individuals, and the media. In its mitigation efforts, the CE implemented additional administrative, technical, and security safeguards to better protect its PHI.
Section F.5 / Modelled cost
70,822 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$11.3M
70,822 x $160
IBM 2026 customer PII, $192 per record
$13.6M
70,822 x $192
Method: individuals affected, as reported by Summit Behavioral Healthcare to HHS, multiplied by IBM's customer-PII cost per record (Cost of a Data Breach 2025 Figure 6 and the 2026 edition). No cost has been disclosed by the entity for this filing; the figure is a planning estimate, not a fact about the breach. IBM's per-record figures come from mid-volume breaches and IBM cautions against applying them to breaches involving millions of records; the site's per-record page explains where the multiplication holds and where it breaks down.
Context: IBM's average cost of a healthcare breach is $6.64M in the 2026 report ($7.42M in 2025); the global average across all sectors was $4.44M in 2025.
Cost per record: method and limits / Healthcare breach cost, IBM 2026
Section F.6 / Notification clock
Tennessee statute and the HIPAA rule
State notification statute
Tennessee: Tenn. Code Ann. 47-18-2107
- Notice to individuals
- Immediately, but no later than 45 days from discovery or notification
- Attorney general threshold
- No mandatory AG notification for private-sector breaches
- Private right of action
- Yes: Affected customers may sue to recover damages and obtain injunctive relief
- Penalty
- AG may pursue civil penalties, injunctive relief, and restitution; class actions restricted
The HIPAA Breach Notification Rule runs alongside the state statute: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery.
Section F.7 / Peer filings
Tennessee filings closest in size
Neighbours by size rank among Tennessee filings in 2021, topped up from other years where 2021 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| QRS, Inc. | Business Associate | 430,334 | 22 Oct 2021 | |||
| Haven Behavioral Healthcare | Business Associate | 21,714 | 23 Mar 2021 | |||
| Cancer Care Center | Healthcare Provider | 17,809 | 9 Jun 2021 |
Index / Companion schedules
13 HHS breach register
→Hub: every filing, by state, year and entity.
04 Biggest breaches
→Mega-breaches with primary-source cost figures.
Industry / Healthcare
→IBM 2026: $6.64M average, 13 years at #1.
Regulation / HIPAA penalties
→OCR enforcement tiers and the 60-day rule.
11 50-state laws
→Deadline, AG threshold and penalties per state.
Cost / Per record
→Where the per-record model is reliable.
Provenance
Source: U.S. Department of Health and Human Services, Office for Civil Rights, Breach Portal (breaches affecting 500 or more individuals), retrieved 2026-08-28. Public domain. Individuals affected and dates as reported by the covered entity.
Portal: ocrportal.hhs.gov breach report. Statutory basis: HITECH Act section 13402(e)(4): the Secretary must post a list of breaches of unsecured protected health information affecting 500 or more individuals. Breaches affecting fewer than 500 individuals are reported to OCR annually and are not posted, so they are not on this register. Status wording follows the portal's two tabs ("Cases Currently Under Investigation" and "Archive") as of 28 August 2026; a filing moves to the archive when OCR closes the case. Modelled costs on this site are a method applied to the reported count, using IBM Cost of a Data Breach per-record figures, and are never a cost disclosed by the entity. This row: hhs-breach-archive__2026-08-28.csv, export row 3376.
Corrections: if you represent a listed entity and the portal row has been amended, email [email protected] with the portal entry and we will re-pull the export.