Breach filing
Under investigationClement Manor: 16,046 individuals, Jun 2025.
Clement Manor reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 25 June 2025. The filing records the organisation as a healthcare provider in Wisconsin and lists 16,046 individuals affected, which makes it the 33rd largest of the 126 Wisconsin filings on the register and the 262nd largest of the 798 filings submitted nationally in 2025. Among the 17 Wisconsin filings made in 2025 it ranks 5th.
Individuals affected
16,046
As reported to HHS
Modelled cost (IBM 2025)
$2.57M
Method shown, not disclosed
Rank in WI
33rd
of 126 Wisconsin filings
Rank in 2025
262nd
of 798 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
- 16,046
- Breach submission date
- 25 June 2025
- Submission year
- 2025
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- No
- State
- Wisconsin (WI)
- Portal status
- listed by HHS OCR under Cases Currently Under Investigation
- Rank in Wisconsin by size
- 33rd of 126
- Rank in 2025 nationally
- 262nd of 798
- Wisconsin median filing
- 3,657 individuals
- Register id (derived)
- WI-20250625-clement-manor
Section F.2 / In context
Where this filing sits in Wisconsin and in 2025
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 83 of the 126 Wisconsin filings (66%) and on 81% of all filings submitted in 2025. Network Server appears on 40% of Wisconsin filings.
No business associate is recorded on the filing; 31% of Wisconsin filings do involve one. At 16,046 individuals the breach is 4.4 times the Wisconsin median filing of 3,657 and 4.0 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 by HHS OCR under Cases Currently Under Investigation. OCR has not published a closing summary, so this page is limited to the fields on the filing itself; the archive entry that follows a closed investigation usually adds a short account of what was exposed and what the entity did afterwards.
Wisconsin's breach notification statute (Wis. Stat. 134.98) requires notice to affected residents within 45 days after learning of the unauthorized acquisition. Its attorney general threshold: no AG notification requirement. 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 16,046 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 $2.57M; the 2026 edition's $192 gives $3.08M. Both are modelled estimates with the method shown, not costs disclosed by Clement Manor. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.5 times the sector average.
Section F.5 / Modelled cost
16,046 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$2.57M
16,046 x $160
IBM 2026 customer PII, $192 per record
$3.08M
16,046 x $192
Method: individuals affected, as reported by Clement Manor 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
Wisconsin statute and the HIPAA rule
State notification statute
Wisconsin: Wis. Stat. 134.98
- Notice to individuals
- Within 45 days after learning of the unauthorized acquisition
- Attorney general threshold
- No AG notification requirement
- Private right of action
- No: No PROA under the statute; failure to notify may support separate negligence claims
- Penalty
- Civil forfeitures up to $10,000 per violation, enforced by the AG and DATCP
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
Wisconsin filings closest in size
Neighbours by size rank among Wisconsin filings in 2025, topped up from other years where 2025 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Marshfield Clinic Health SystemOpen | Healthcare Provider | 35,952 | 7 Nov 2025 | |||
| Dove Healthcare | Healthcare Provider | 16,255 | 18 Mar 2025 | |||
| Radiology Chartered | Healthcare Provider | 12,656 | 16 May 2025 | |||
| Assisted Living Pharmacy Service, LLCOpen | Healthcare Provider | 5,590 | 25 Aug 2025 |
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-under-investigation__2026-08-28.csv, export row 501.
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.