Breach filing
ArchivedLegacy Community Health Services: 228,009 individuals, Sep 2020.
Legacy Community Health Services reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 25 September 2020. The filing records the organisation as a healthcare provider in Texas and lists 228,009 individuals affected, which makes it the 39th largest of the 633 Texas filings on the register and the 36th largest of the 663 filings submitted nationally in 2020. Among the 44 Texas filings made in 2020 it ranks 2nd.
Individuals affected
228,009
As reported to HHS
Modelled cost (IBM 2025)
$36.5M
Upper bound, method shown
Rank in TX
39th
of 633 Texas filings
Rank in 2020
36th
of 663 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
- 228,009
- Breach submission date
- 25 September 2020
- Submission year
- 2020
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- No
- State
- Texas (TX)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Texas by size
- 39th of 633
- Rank in 2020 nationally
- 36th of 663
- Texas median filing
- 4,055 individuals
- Register id (derived)
- TX-20200925-legacy-community-health-services
Section F.2 / In context
Where this filing sits in Texas and in 2020
OCR classifies the incident as a hacking or IT incident, with the breached information held in email. Hacking/IT Incident is the type recorded on 360 of the 633 Texas filings (57%) and on 69% of all filings submitted in 2020. Email appears on 23% of Texas filings.
No business associate is recorded on the filing; 27% of Texas filings do involve one. At 228,009 individuals the breach is 56 times the Texas median filing of 4,055 and 57 times the national median of 4,000 across all 7,884 filings. It is one of 801 filings of 100,000 or more individuals.
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.
Texas's breach notification statute (Tex. Bus. & Com. Code 521.053) requires notice to affected residents without unreasonable delay, no later than the 60th day after determining a breach occurred. Its attorney general threshold: 250 or more Texas residents. 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 228,009 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 $36.5M; the 2026 edition's $192 gives $43.8M. Both are modelled estimates with the method shown, not costs disclosed by Legacy Community Health Services. Because the filing is above the roughly 100,000-record range in which the per-record figure is reliable, the result is an upper bound, not an estimate: fixed costs are spread across far more records at this scale.
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), Legacy Community Health Services, reported that an employee was the victim of an email phishing scheme that affected the electronic protected health information (ePHI) of 228,009 patients. The ePHI involved included names, dates of birth, Social Security numbers, diagnoses, medications prescribed, and lab results. The CE notified HHS, affected individuals, and the media. As a result of the breach, the CE retrained its workforce members on the proper methods of identifying and responding to fraudulent email communications.
Section F.5 / Modelled cost
228,009 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$36.5M
228,009 x $160
IBM 2026 customer PII, $192 per record
$43.8M
228,009 x $192
Method: individuals affected, as reported by Legacy Community Health Services 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
Texas statute and the HIPAA rule
State notification statute
Texas: Tex. Bus. & Com. Code 521.053
- Notice to individuals
- Without unreasonable delay, no later than the 60th day after determining a breach occurred
- Attorney general threshold
- 250 or more Texas residents (No later than the 30th day after determining a breach occurred)
- Private right of action
- Limited: Indirect recovery via the Deceptive Trade Practices Act (up to treble economic damages for knowing violations)
- Penalty
- $2,000-$50,000 per violation; additional up to $100 per individual per day, capped at $250,000 per breach
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
Texas filings closest in size
Neighbours by size rank among Texas filings in 2020, topped up from other years where 2020 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Benefit Recovery Specialists, Inc. | Business Associate | 447,354 | 26 Jun 2020 | |||
| Allergy and Asthma Clinic of Fort Worth | Healthcare Provider | 69,777 | 16 Jul 2020 | |||
| Affordacare Urgent Care Clinics | Healthcare Provider | 57,411 | 31 Mar 2020 |
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 3670.
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.