Breach filing
ArchivedGuidehouse: 91,331 individuals, Jul 2021.
Guidehouse reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 15 July 2021. The filing records the organisation as a business associate in Virginia and lists 91,331 individuals affected, which makes it the 17th largest of the 157 Virginia filings on the register and the 89th largest of the 715 filings submitted nationally in 2021. Among the 15 Virginia filings made in 2021 it ranks 1st.
Individuals affected
91,331
As reported to HHS
Modelled cost (IBM 2025)
$14.6M
Method shown, not disclosed
Rank in VA
17th
of 157 Virginia filings
Rank in 2021
89th
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
- Business Associate
- Individuals affected
- 91,331
- Breach submission date
- 15 July 2021
- Submission year
- 2021
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Virginia (VA)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Virginia by size
- 17th of 157
- Rank in 2021 nationally
- 89th of 715
- Virginia median filing
- 4,441 individuals
- Register id (derived)
- VA-20210715-guidehouse
Section F.2 / In context
Where this filing sits in Virginia and in 2021
OCR classifies the incident as a hacking or IT incident, with the breached information held in a network server. Hacking/IT Incident is the type recorded on 99 of the 157 Virginia filings (63%) and on 76% of all filings submitted in 2021. Network Server is the most common location in the state, appearing on 53% of Virginia filings.
A business associate is recorded as present on the filing, as it is on 39% of Virginia filings. At 91,331 individuals the breach is 21 times the Virginia median filing of 4,441 and 23 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.
Virginia's breach notification statute (Va. Code 18.2-186.6) requires notice to affected residents without unreasonable delay. Its attorney general threshold: all breaches (concurrent with individual notice). 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 91,331 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 $14.6M; the 2026 edition's $192 gives $17.5M. Both are modelled estimates with the method shown, not costs disclosed by Guidehouse. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 2.6 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), Guidehouse, reported that its secure file transfer device experienced a cyber-attack that affected the protected health information (PHI) of approximately 91,331 individuals. The PHI involved included, names, dates of birth, diagnoses/conditions, and claims information. The CE notified HHS, affected individuals, and the media. In response to the breach, the CE applied a critical patch shortly after the cyber-attack which mitigated the vulnerability. Additionally, the CE discontinued use of the file transfer device and transitioned to another network.
Section F.5 / Modelled cost
91,331 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$14.6M
91,331 x $160
IBM 2026 customer PII, $192 per record
$17.5M
91,331 x $192
Method: individuals affected, as reported by Guidehouse 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
Virginia statute and the HIPAA rule
State notification statute
Virginia: Va. Code 18.2-186.6
- Notice to individuals
- Without unreasonable delay
- Attorney general threshold
- All breaches (concurrent with individual notice) (Concurrent with individual notification)
- Private right of action
- Limited: Individuals may recover direct economic damages (no non-economic damages)
- Penalty
- AG may impose civil penalties up to $150,000 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
Virginia filings closest in size
Neighbours by size rank among Virginia 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 |
|---|---|---|---|---|---|---|
| Tycon Medical Systems, Inc. | Healthcare Provider | 112,847 | 30 Dec 2024 | |||
| Defense Health Agency | Health Plan | 96,271 | 12 Mar 2026 | |||
| Democracy Data & Communications, LLC ( | Business Associate | 83,000 | 8 Dec 2009 | |||
| Sentara Healthcare | Healthcare Provider | 72,121 | 19 Nov 2021 | |||
| AllyAlign Health, Inc. | Health Plan | 33,932 | 26 Feb 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 3053.
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.