Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing WI-20251107-marshfield-clinic-health-systemHHS OCR Breach Register, Wisconsin

Breach filing

Under investigation

Marshfield Clinic Health System: 35,952 individuals, Nov 2025.

Marshfield Clinic Health System reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 7 November 2025. The filing records the organisation as a healthcare provider in Wisconsin and lists 35,952 individuals affected, which makes it the 25th largest of the 126 Wisconsin filings on the register and the 179th largest of the 798 filings submitted nationally in 2025. Among the 17 Wisconsin filings made in 2025 it ranks 3rd.

Individuals affected

35,952

As reported to HHS

Modelled cost (IBM 2025)

$5.75M

Method shown, not disclosed

Rank in WI

25th

of 126 Wisconsin filings

Rank in 2025

179th

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
35,952
Breach submission date
7 November 2025
Submission year
2025
Type of breach
Hacking/IT Incident
Location of breached information
Email
Business associate present
No
Portal status
listed by HHS OCR under Cases Currently Under Investigation
Rank in Wisconsin by size
25th of 126
Rank in 2025 nationally
179th of 798
Wisconsin median filing
3,657 individuals
Register id (derived)
WI-20251107-marshfield-clinic-health-system

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 email. Hacking/IT Incident is the type recorded on 83 of the 126 Wisconsin filings (66%) and on 81% of all filings submitted in 2025. Email appears on 33% of Wisconsin filings.

No business associate is recorded on the filing; 31% of Wisconsin filings do involve one. At 35,952 individuals the breach is 9.8 times the Wisconsin median filing of 3,657 and 9.0 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 35,952 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 $5.75M; the 2026 edition's $192 gives $6.90M. Both are modelled estimates with the method shown, not costs disclosed by Marshfield Clinic Health System. 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.5 / Modelled cost

35,952 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Modelled

IBM 2025 customer PII, $160 per record

$5.75M

35,952 x $160

IBM 2026 customer PII, $192 per record

$6.90M

35,952 x $192

Method: individuals affected, as reported by Marshfield Clinic Health System 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 entityTypeIndividualsSubmitted
Bell Ambulance, Inc.OpenHealthcare Provider237,83014 Apr 2025
Morton Drug CompanyOpenHealthcare Provider40,05110 Nov 2025
Dove HealthcareHealthcare Provider16,25518 Mar 2025
Clement ManorOpenHealthcare Provider16,04625 Jun 2025

Index / Companion schedules

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 359.

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.