Breach filing
ArchivedVirginia Premier Health Plan (VPHP): 25,513 individuals, Jan 2014.
Virginia Premier Health Plan (VPHP) reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 10 January 2014. The filing records the organisation as a business associate in Virginia and lists 25,513 individuals affected, which makes it the 33rd largest of the 157 Virginia filings on the register and the 47th largest of the 314 filings submitted nationally in 2014. Among the 8 Virginia filings made in 2014 it ranks 2nd.
Individuals affected
25,513
As reported to HHS
Modelled cost (IBM 2025)
$4.08M
Method shown, not disclosed
Rank in VA
33rd
of 157 Virginia filings
Rank in 2014
47th
of 314 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
- 25,513
- Breach submission date
- 10 January 2014
- Submission year
- 2014
- Type of breach
- Theft
- Location of breached information
- Paper/Films
- Business associate present
- Yes
- State
- Virginia (VA)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Virginia by size
- 33rd of 157
- Rank in 2014 nationally
- 47th of 314
- Virginia median filing
- 4,441 individuals
- Register id (derived)
- VA-20140110-virginia-premier-health-plan-vphp
Section F.2 / In context
Where this filing sits in Virginia and in 2014
OCR classifies the incident as theft, with the breached information held in paper records or films. Theft is the type recorded on 19 of the 157 Virginia filings (12%) and on 41% of all filings submitted in 2014. Paper/Films appears on 8% of Virginia filings.
A business associate is recorded as present on the filing, as it is on 39% of Virginia filings. At 25,513 individuals the breach is 5.7 times the Virginia median filing of 4,441 and 6.4 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 25,513 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 $4.08M; the 2026 edition's $192 gives $4.90M. Both are modelled estimates with the method shown, not costs disclosed by Virginia Premier Health Plan (VPHP). For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.7 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.
Virginia Premier Health Plan, a business associate (BA) of the covered entity (CE), Virginia Department of Medical Assistance Services (VA-DMAS), mailed incorrect postcards to Virginia Medicaid members. The breach included 13,357 postcards that were mailed to the wrong address and 12,156 postcards that contained incorrect services information. The information did not include social security numbers or financial information. The BA provided breach notification to HHS, the media, and to affected individuals in English and Spanish. Following this breach, the BA improved safeguards by retraining employees on safeguards for protected health information, updating procedures for mailings, and implementing additional quality control checks. OCR obtained assurances that the BA implemented the corrective action listed above.
Section F.5 / Modelled cost
25,513 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$4.08M
25,513 x $160
IBM 2026 customer PII, $192 per record
$4.90M
25,513 x $192
Method: individuals affected, as reported by Virginia Premier Health Plan (VPHP) 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 2014, topped up from other years where 2014 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Amerigroup Texas, Inc. | Business Associate | 75,026 | 10 Apr 2014 | |||
| NOVA Chiropractic & Rehab Center | Healthcare Provider | 5,534 | 27 Mar 2014 | |||
| Sentara Healthcare | Healthcare Provider | 3,861 | 16 Jan 2014 |
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 6254.
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.