Breach filing
ArchivedFOREFRONT DERMATOLOGY, SC: 45,580 individuals, Oct 2022.
FOREFRONT DERMATOLOGY, SC reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 20 October 2022. The filing records the organisation as a healthcare provider in Wisconsin and lists 45,580 individuals affected, which makes it the 20th largest of the 126 Wisconsin filings on the register and the 166th largest of the 718 filings submitted nationally in 2022. Among the 15 Wisconsin filings made in 2022 it ranks 6th.
Individuals affected
45,580
As reported to HHS
Modelled cost (IBM 2025)
$7.29M
Method shown, not disclosed
Rank in WI
20th
of 126 Wisconsin filings
Rank in 2022
166th
of 718 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
- 45,580
- Breach submission date
- 20 October 2022
- Submission year
- 2022
- Type of breach
- Theft
- Location of breached information
- Other Portable Electronic Device
- Business associate present
- Yes
- State
- Wisconsin (WI)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Wisconsin by size
- 20th of 126
- Rank in 2022 nationally
- 166th of 718
- Wisconsin median filing
- 3,657 individuals
- Register id (derived)
- WI-20221020-forefront-dermatology-sc
Section F.2 / In context
Where this filing sits in Wisconsin and in 2022
OCR classifies the incident as theft, with the breached information held in another portable electronic device. Theft is the type recorded on 13 of the 126 Wisconsin filings (10%) and on 3% of all filings submitted in 2022. Other Portable Electronic Device appears on 5% of Wisconsin filings.
A business associate is recorded as present on the filing, as it is on 31% of Wisconsin filings. At 45,580 individuals the breach is 12 times the Wisconsin median filing of 3,657 and 11 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.
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 45,580 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 $7.29M; the 2026 edition's $192 gives $8.75M. Both are modelled estimates with the method shown, not costs disclosed by FOREFRONT DERMATOLOGY, SC. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 1.3 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), Forefront Dermatology, reported that an employee sold decommissioned electronic devices that contained the protected health information (PHI) of 45,580 individuals. The PHI involved included names, dates of birth, phone numbers, addresses, diagnoses, and other treatment information. The CE notified HHS, affected individuals, the media, and provided substitute notice. In response to the breach, the CE sanctioned the responsible employee as well as others and implemented additional technical safeguards.
Section F.5 / Modelled cost
45,580 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$7.29M
45,580 x $160
IBM 2026 customer PII, $192 per record
$8.75M
45,580 x $192
Method: individuals affected, as reported by FOREFRONT DERMATOLOGY, SC 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 2022, topped up from other years where 2022 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Common Ground Healthcare Cooperative | Health Plan | 133,714 | 12 Aug 2022 | |||
| Southwest Health Center | Healthcare Provider | 46,142 | 5 Jul 2022 | |||
| Rock County Human Services Department | Healthcare Provider | 25,610 | 12 Aug 2022 | |||
| Wisconsin Department of Health Services | Health Plan | 12,358 | 7 Oct 2022 |
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 2157.
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.