Breach filing
ArchivedCommunity Health Plan of Washington: 381,504 individuals, Dec 2016.
Community Health Plan of Washington reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 21 December 2016. The filing records the organisation as a health plan in Washington and lists 381,504 individuals affected, which makes it the 11th largest of the 185 Washington filings on the register and the 10th largest of the 328 filings submitted nationally in 2016. Among the 12 Washington filings made in 2016 it ranks 1st.
Individuals affected
381,504
As reported to HHS
Modelled cost (IBM 2025)
$61.0M
Upper bound, method shown
Rank in WA
11th
of 185 Washington filings
Rank in 2016
10th
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
- 381,504
- Breach submission date
- 21 December 2016
- Submission year
- 2016
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server, Other
- Business associate present
- No
- State
- Washington (WA)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Washington by size
- 11th of 185
- Rank in 2016 nationally
- 10th of 328
- Washington median filing
- 3,950 individuals
- Register id (derived)
- WA-20161221-community-health-plan-of-washington
Section F.2 / In context
Where this filing sits in Washington and in 2016
OCR classifies the incident as a hacking or IT incident, with the breached information held in a network server and another location. Hacking/IT Incident is the type recorded on 117 of the 185 Washington filings (63%) and on 35% of all filings submitted in 2016. Network Server appears on 48% of Washington filings.
No business associate is recorded on the filing; 21% of Washington filings do involve one. At 381,504 individuals the breach is 97 times the Washington median filing of 3,950 and 95 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.
Washington's breach notification statute (RCW 19.255.010) requires notice to affected residents no later than 30 days after discovery. Its attorney general threshold: more than 500 Washington 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 381,504 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 $61.0M; the 2026 edition's $192 gives $73.2M. Both are modelled estimates with the method shown, not costs disclosed by Community Health Plan of Washington. 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.
Transactions Application Group, Inc., a business associate (BA) for the covered entity (CE), Community Health Plan of Washington, failed to properly secure a port on a computer network server used for transferring electronic files (a File Transfer Protocol (FTP) server), resulting in an incident of unauthorized access to electronic protected health information (ePHI) maintained at the BA. The breach affected 381,504 individuals and included individuals' names, addresses, dates of birth, social security numbers, and certain coding information related to health care claims. The CE provided breach notification to the affected parties, the media, and HHS, and offered one year of free credit and identity theft monitoring. The CE also implemented additional technical safeguards. OCR obtained assurances that the CE implemented the corrective actions listed above .
Section F.5 / Modelled cost
381,504 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$61.0M
381,504 x $160
IBM 2026 customer PII, $192 per record
$73.2M
381,504 x $192
Method: individuals affected, as reported by Community Health Plan of Washington 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
Washington statute and the HIPAA rule
State notification statute
Washington: RCW 19.255.010
- Notice to individuals
- No later than 30 days after discovery
- Attorney general threshold
- More than 500 Washington residents (Within the same 30-day window)
- Private right of action
- Yes: Civil lawsuits under the Consumer Protection Act; actual damages plus up to $1,000 punitive for willful violations
- Penalty
- Consumers may recover damages, costs, and attorney fees; AG may seek penalties and injunctive relief
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
Washington filings closest in size
Neighbours by size rank among Washington 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 |
|---|---|---|---|---|---|---|
| Rebound Orthopedics & Neurosurgery | Healthcare Provider | 426,536 | 10 Apr 2024 | |||
| Columbia Surgical Specialist of Spokane | Healthcare Provider | 400,000 | 18 Feb 2019 | |||
| Northwest Radiologists, Inc./Mount Baker ImagingOpen | Healthcare Provider | 362,713 | 28 Oct 2025 | |||
| Washington State Health Care Authority (HCA) | Health Plan | 91,187 | 9 Feb 2016 | |||
| Franciscan Health, Highline Medical Center | Healthcare Provider | 18,399 | 1 Sep 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 5365.
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.