Breach filing
ArchivedHealthEquity, Inc.: 165,800 individuals, Nov 2018.
HealthEquity, Inc. reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 17 November 2018. The filing records the organisation as a business associate in Utah and lists 165,800 individuals affected, which makes it the 5th largest of the 68 Utah filings on the register and the 19th largest of the 369 filings submitted nationally in 2018. Among the 5 Utah filings made in 2018 it ranks 1st.
Individuals affected
165,800
As reported to HHS
Modelled cost (IBM 2025)
$26.5M
Upper bound, method shown
Rank in UT
5th
of 68 Utah filings
Rank in 2018
19th
of 369 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
- Business Associate
- Individuals affected
- 165,800
- Breach submission date
- 17 November 2018
- Submission year
- 2018
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- Yes
- State
- Utah (UT)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Utah by size
- 5th of 68
- Rank in 2018 nationally
- 19th of 369
- Utah median filing
- 5,381 individuals
- Register id (derived)
- UT-20181117-healthequity
Section F.2 / In context
Where this filing sits in Utah and in 2018
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 51 of the 68 Utah filings (75%) and on 45% of all filings submitted in 2018. Email appears on 21% of Utah filings.
A business associate is recorded as present on the filing, as it is on 34% of Utah filings. At 165,800 individuals the breach is 31 times the Utah median filing of 5,381 and 41 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.
Utah's breach notification statute (Utah Code 13-44-202) requires notice to affected residents in the most expedient time possible, without unreasonable delay. Its attorney general threshold: 500 or more Utah residents (AG and Utah Cyber Center). 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 165,800 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 $26.5M; the 2026 edition's $192 gives $31.8M. Both are modelled estimates with the method shown, not costs disclosed by HealthEquity, Inc.. 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.
HealthEquity, the covered entity (CE), reported that several employees were the victims of an email phishing attack. The breached accounts contained the protected health information (PHI) of 165,800 individuals. The PHI involved included names and Social Security numbers. HealthEquity conducted a forensic analysis and notified HHS, affected individuals, and the media. As a result of this breach, the CE implemented additional administrative, technical, and security safeguards and trained its staff on the proper methods for identifying fraudulent email communications. OCR provided technical assistance on how HealthEquity could better protect its PHI and reduce the amount of sensitive data vulnerable to attack. OCR obtained assurances that the CE implemented the aforementioned corrective actions.
Section F.5 / Modelled cost
165,800 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$26.5M
165,800 x $160
IBM 2026 customer PII, $192 per record
$31.8M
165,800 x $192
Method: individuals affected, as reported by HealthEquity, Inc. 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
Utah statute and the HIPAA rule
State notification statute
Utah: Utah Code 13-44-202
Protection of Personal Information Act
- Notice to individuals
- In the most expedient time possible, without unreasonable delay
- Attorney general threshold
- 500 or more Utah residents (AG and Utah Cyber Center) (Without unreasonable delay)
- Private right of action
- No: No PROA; only the Attorney General can enforce
- Penalty
- Up to $2,500 per consumer, capped at $100,000 aggregate for related violations
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
Utah filings closest in size
Neighbours by size rank among Utah filings in 2018, topped up from other years where 2018 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Utah Imaging Associates, Inc. | Healthcare Provider | 582,170 | 3 Nov 2021 | |||
| Premier Family Medical | Healthcare Provider | 320,000 | 7 Sep 2019 | |||
| Utah Pathology Services, Inc. | Healthcare Provider | 148,594 | 28 Aug 2020 | |||
| HealthEquity, Inc. | Business Associate | 16,000 | 12 Jun 2018 | |||
| Rocky Mountain Women's Health Center, Inc. | Healthcare Provider | 1,123 | 25 Jan 2018 |
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 4670.
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.