Breach filing
ArchivedConfluence Health: 33,821 individuals, Jul 2018.
Confluence Health reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 27 July 2018. The filing records the organisation as a healthcare provider in Washington and lists 33,821 individuals affected, which makes it the 31st largest of the 185 Washington filings on the register and the 49th largest of the 369 filings submitted nationally in 2018. Among the 7 Washington filings made in 2018 it ranks 1st.
Individuals affected
33,821
As reported to HHS
Modelled cost (IBM 2025)
$5.41M
Method shown, not disclosed
Rank in WA
31st
of 185 Washington filings
Rank in 2018
49th
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
- Healthcare Provider
- Individuals affected
- 33,821
- Breach submission date
- 27 July 2018
- Submission year
- 2018
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- No
- State
- Washington (WA)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Washington by size
- 31st of 185
- Rank in 2018 nationally
- 49th of 369
- Washington median filing
- 3,950 individuals
- Register id (derived)
- WA-20180727-confluence-health
Section F.2 / In context
Where this filing sits in Washington 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 117 of the 185 Washington filings (63%) and on 45% of all filings submitted in 2018. Email appears on 22% of Washington filings.
No business associate is recorded on the filing; 21% of Washington filings do involve one. At 33,821 individuals the breach is 8.6 times the Washington median filing of 3,950 and 8.5 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.
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 33,821 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 $5.41M; the 2026 edition's $192 gives $6.49M. Both are modelled estimates with the method shown, not costs disclosed by Confluence Health. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 1.0 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.
A Confluence Health employee received and responded to a phishing email on March 29, 2018. An unauthorized entity accessed the employee's email account from a Nigerian internet address on March 30, 2018, and again on May 28, 2018, sent phishing emails to multiple recipients, and entered a setting to automatically delete all sent emails. The employee's email account contained protected health information (PHI), including approximately 32,821 patients' names and treatment information. The covered entity (CE) provided breach notification to HHS, affected individuals, and the media and also provided substitute notice. Following the breach, the CE disabled the compromised email account, blocked certain internet addresses, and required a password reset of all its computer network accounts. Additionally, the CE created alert notifications for access to accounts, enabled anti-phishing protections for its email system, heightened its reviews of network activity, implemented multi-factor authentication, and disabled certain types of access from outside its network. OCR provided technical assistance regarding the CE's security management process.
Section F.5 / Modelled cost
33,821 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$5.41M
33,821 x $160
IBM 2026 customer PII, $192 per record
$6.49M
33,821 x $192
Method: individuals affected, as reported by Confluence Health 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 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 |
|---|---|---|---|---|---|---|
| Whitman County Public Hospital District No. 3 | Healthcare Provider | 63,453 | 11 Apr 2025 | |||
| Behavioral Health ResourcesOpen | Healthcare Provider | 49,213 | 17 Jan 2025 | |||
| Premera Blue Cross | Health Plan | 33,212 | 8 Aug 2023 | |||
| Southwest Washington Regional Surgery Center, LLC | Healthcare Provider | 2,393 | 6 Nov 2018 | |||
| West Sound Treatment Center | Healthcare Provider | 2,300 | 11 Oct 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 4780.
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.