Breach filing
ArchivedMemorial Hermann Health System, reporting on behalf of Memorial Hermann Health System Employee Group Health Plan: 12,061 individuals, Jul 2016.
Memorial Hermann Health System, reporting on behalf of Memorial Hermann Health System Employee Group Health Plan reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 20 July 2016. The filing records the organisation as a health plan in Texas and lists 12,061 individuals affected, which makes it the 207th largest of the 633 Texas filings on the register and the 76th largest of the 328 filings submitted nationally in 2016. Among the 23 Texas filings made in 2016 it ranks 7th.
Individuals affected
12,061
As reported to HHS
Modelled cost (IBM 2025)
$1.93M
Method shown, not disclosed
Rank in TX
207th
of 633 Texas filings
Rank in 2016
76th
of 328 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
- Health Plan
- Individuals affected
- 12,061
- Breach submission date
- 20 July 2016
- Submission year
- 2016
- Type of breach
- Unauthorized Access/Disclosure
- Location of breached information
- Paper/Films
- Business associate present
- No
- State
- Texas (TX)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Texas by size
- 207th of 633
- Rank in 2016 nationally
- 76th of 328
- Texas median filing
- 4,055 individuals
- Register id (derived)
- TX-20160720-memorial-hermann-health-system-reporting
Section F.2 / In context
Where this filing sits in Texas and in 2016
OCR classifies the incident as unauthorized access or disclosure, with the breached information held in paper records or films. Unauthorized Access/Disclosure is the type recorded on 155 of the 633 Texas filings (24%) and on 40% of all filings submitted in 2016. Paper/Films appears on 10% of Texas filings.
No business associate is recorded on the filing; 27% of Texas filings do involve one. At 12,061 individuals the breach is 3.0 times the Texas median filing of 4,055 and 3.0 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.
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 12,061 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 $1.93M; the 2026 edition's $192 gives $2.32M. Both are modelled estimates with the method shown, not costs disclosed by Memorial Hermann Health System, reporting on behalf of Memorial Hermann Health System Employee Group Health Plan. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.3 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), Memorial Hermann Health System, reported that between December 12, 2015, and May 23, 2016, Memorial Hermann Health Solutions, the plan administrator for the Memorial Hermann Health System Employee Group Health Plan, impermissibly disclosed the protected health information (PHI) of 12,061 plan members to the CE's primary care physicians (PCP). The disclosure included plan members' names, addresses, dates of birth, telephone numbers and member identification. The plan members did not have an existing relationship with the PCP at the time of the disclosure, and therefore the disclosure was not for treatment purposes. The error occurred while implementing a new process in 2014, which was not effectively communicated to the leadership of the Health Plan. The CE met with the new leadership of the Health Plan to ensure the plan complies with its obligations to control data flow and to ensure the plan's appropriate use of shared data. Following the incident, the CE provided evidence it notified affected individuals, the media, and posted substitute notification on its website.
Section F.5 / Modelled cost
12,061 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$1.93M
12,061 x $160
IBM 2026 customer PII, $192 per record
$2.32M
12,061 x $192
Method: individuals affected, as reported by Memorial Hermann Health System, reporting on behalf of Memorial Hermann Health System Employee Group Health Plan 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 2016, topped up from other years where 2016 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Integrity Transitional Hospital | Healthcare Provider | 29,514 | 14 Oct 2016 | |||
| Northstar Healthcare Acquisitions LLC | Healthcare Provider | 19,898 | 28 Apr 2016 | |||
| Preventice Services, LLC | Healthcare Provider | 6,800 | 7 Dec 2016 | |||
| North Texas Heart Center, P.A. | Healthcare Provider | 4,210 | 21 Nov 2016 |
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 5517.
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.