Uptime Report Research · Enforcement Ledger

HIPAA Enforcement Tracker: Every OCR Penalty and Settlement, 2016 to 2026

HIPAA enforcement by the HHS Office for Civil Rights reached a record 25 actions in 2025, and 17 of those 25 were announced as ransomware, hacking, phishing, or Security Rule cases. Penalties are also getting smaller: the median verified amount fell from $1,600,000 in 2016 to 2019 to $240,000 in 2024 to 2026, a decline of 85%.

Every amount checked against the HHS source document · Ledger last checked October 2026

162OCR resolution agreements and civil money penalties listed since July 2008
25actions in 2025, the most of any year
85%lower median amount, 2024-2026 vs 2016-2019
14actions naming ransomware since the first on 2023-10-31

OCR enforcement actions per year (bars) and median amount (below)122016$2,200k102017$2,300k82018$999k112019$1,600k152020$160k102021$70k72022$301k142023$80k152024$250k252025$225k62026$450k2026 through September 17. Medians use verified amounts only. Source: HHS OCR resolution agreements and civil money penalties list.

How has HIPAA enforcement changed?

OCR now brings more cases with smaller amounts. Between 2016 and 2019, the median verified HIPAA settlement or penalty was $1,600,000 (n=39). Between 2024 and 2026, it was $240,000 (n=37). Total dollars collected peaked in 2018 at $25,635,400, the year of the $16 million Anthem settlement, while 2025 produced the most actions on record with $8,580,316 in verified amounts.

Part of the volume increase comes from OCR initiatives that target specific obligations at scale, first patient right of access and, more recently, ransomware and Security Rule cases. These initiatives produce many smaller resolutions rather than a few large ones.

Is ransomware driving HIPAA enforcement?

Increasingly, by OCR’s own announcements. The first enforcement action with “ransomware” in its HHS title was announced on 2023-10-31. Since then, 14 actions have named ransomware. In 2025, 17 of 25 actions were announced as ransomware, hacking, phishing, or Security Rule cases.

Why this matters for providers and their IT partners. We were able to read the full resolution documents for three of the ransomware actions (October 2023, May 2025, and July 2026). All three cite the HIPAA Security Rule risk analysis requirement. For an MSP serving healthcare, a documented, current risk analysis is the control the public record points to most directly. This is an observation from the public record, not legal advice.

Year-by-year summary

Year Actions With verified amount Total verified Median Security-named
2016 12 10 $21,919,600 $2,200,000 1
2017 10 10 $17,250,418 $2,300,000 0
2018 8 8 $25,635,400 $999,000 0
2019 11 11 $15,285,000 $1,600,000 0
2020 15 14 $13,418,400 $160,000 2
2021 10 9 $5,650,000 $70,000 1
2022 7 4 $1,218,640 $300,640 1
2023 14 13 $2,966,500 $80,000 3
2024 15 11 $8,723,265 $250,000 8
2025 25 20 $8,580,316 $225,000 17
2026 6 6 $2,007,250 $450,000 2

“Security-named” counts actions whose HHS title names ransomware, phishing, hacking, cybersecurity, malware, a malicious insider, or the Security Rule. Older HHS titles named causes less consistently, so this column is not comparable across the full period.

The ledger: every action since January 2024

Each entry links to the HHS source document. Rows with a red edge were announced as security cases.

Date Action (HHS title) Amount Evidence
2026-09-17 Ambry Genetics to Pay $700,000 After Phishing Attack Exposed 225,000 Patients’ Health Data $700,000 Verified in agreement text
2026-08-27 HHS’ Office for Civil Rights Settles HIPAA Right of Access Investigation with Azul Vision, Inc. $50,000 Verified in agreement text
2026-07-29 HHS’ Office for Civil Rights Settles Ransomware Investigation with Healthcare System $552,250 Verified in agreement text
2026-05-20 Spencer Gifts LLC Resolution Agreement $450,000 Verified in agreement text
2026-03-05 HHS’ Office for Civil Rights Settles HIPAA Investigation of MMG Fusion, LLC Breach $10,000 Verified in agreement text
2026-01-22 SG Health Plan Resolution Agreement and Corrective Action Plan $245,000 Verified in agreement text
2025-12-18 Consociate, Inc. Resolution Agreement and Corrective Action Plan $225,000 Verified in agreement text
2025-12-05 Assured Imaging Resolution Agreement and Corrective Action Plan $375,000 Verified in agreement text
2025-08-28 Regional Women’s Health Group, LLC Resolution Agreement and Corrective Action Plan $320,000 Verified in agreement text
2025-08-18 HHS’ Office for Civil Rights Settles HIPAA Ransomware Security Rule Investigation with BST & Co. CPAs, LLP $175,000 Verified in agreement text
2025-07-23 HHS’ Office for Civil Rights Settles HIPAA Ransomware Investigation with Syracuse ASC $250,000 Verified in agreement text
2025-07-07 HHS’ Office for Civil Rights Settles HIPAA Privacy and Security Rule Investigation with a Behavioral Health Provider Not quantified Not quantified (no amount in source text)
2025-06-06 Top of the World Ranch Treatment Center, LLC Resolution Agreement $103,000 Verified in agreement text
2025-05-30 HHS Office for Civil Rights Settles HIPAA Ransomware Cybersecurity Investigation with Comstar, LLC $75,000 Verified in agreement text
2025-05-28 HHS Office for Civil Rights Settles HIPAA Security Rule Investigation with a Florida Health Care Provider $800,000 Verified in agreement text
2025-05-15 HHS Office for Civil Rights Settles HIPAA Cybersecurity Investigation with Vision Upright MRI $25,000 Verified in agreement text
2025-04-30 Concentra Settlement Agreement $112,500 Verified in agreement text
2025-04-25 HHS Office for Civil Rights Settles HIPAA Ransomware Cybersecurity Investigation with Neurology Practice $25,000 Verified in agreement text
2025-04-23 HHS Office for Civil Rights Settles Phishing Attack Breach with Health Care Network for $600,000 $600,000 Verified in agreement text
2025-04-22 Cadia Rehabilitation Resolution Agreement $182,000 Verified in agreement text
2025-04-17 HHS Office for Civil Rights Settles HIPAA Ransomware Cybersecurity Investigation with Public Hospital $25,000 Verified in agreement text
2025-04-04 HHS Office for Civil Rights Settles HIPAA Security Rule Investigation with Northeast Radiology $350,000 Verified in agreement text
2025-03-21 HHS’ Office for Civil Rights Settles HIPAA Security Rule Investigation with Health Fitness Corporation $227,816 Verified in agreement text
2025-03-06 HHS Office for Civil Rights Imposes a $200,000 Penalty Against Oregon Health & Science University for Failure to Provide Timely Access to Patient Records $200,000 Verified in agreement text
2025-02-20 HHS Office for Civil Rights Imposes a $1,500,000 Civil Money Penalty Against Warby Parker in HIPAA Cybersecurity Hacking Investigation $1,500,000 Verified in agreement text
2025-01-15 HHS Office for Civil Rights Settles HIPAA Ransomware Cybersecurity Investigation for $10,000 $10,000 Verified in agreement text
2025-01-15 HHS Office for Civil Rights Settles HIPAA Case Against Memorial Healthcare System Over Patient Access to Records Not quantified Not quantified (source archived)
2025-01-14 HHS Office for Civil Rights Settles HIPAA Phishing Cybersecurity Investigation with Solara Medical Supplies, LLC for $3,000,000 $3,000,000 Stated in HHS headline
2025-01-08 HHS Office for Civil Rights Settles HIPAA Security Rule Investigation with USR Holdings, LLC Concerning the Deletion of Electronic Protected Health Information Not quantified Not quantified (source archived)
2025-01-07 HHS Office for Civil Rights Settles 9th Ransomware Investigation with Virtual Private Network Solutions Not quantified Not quantified (source archived)
2025-01-07 HHS Office for Civil Rights Settles 8th Ransomware Investigation with Elgon Information Systems Not quantified Not quantified (source archived)
2024-12-10 HHS Office for Civil Rights Settles with Health Care Clearinghouse, Inmediata Health Group, Over HIPAA Impermissible Disclosure Not quantified Not quantified (source archived)
2024-12-05 HHS Office for Civil Rights Imposes a $548,265 Penalty Against Children’s Hospital Colorado for HIPAA Privacy and Security Rules Violations $548,265 Stated in HHS headline
2024-12-03 HHS Office for Civil Rights Imposes a $1.19 Million Penalty Against Gulf Coast Pain Consultants for HIPAA Security Rule Violations $1,190,000 Stated in HHS headline
2024-11-26 HHS Office for Civil Rights Settles with Holy Redeemer Family Medicine Over Disclosure of Patient’s Protected Health Information, Including Reproductive Health Information Not quantified Not quantified (source archived)
2024-11-19 HHS Office for Civil Rights Imposes a $100,000 Penalty Against Mental Health Center for Failure to Provide Timely Access to Patient Records $100,000 Verified in agreement text
2024-10-31 HHS Office for Civil Rights Settles HIPAA Ransomware Cybersecurity Investigation for $90,000 $90,000 Verified in agreement text
2024-10-31 HHS Office for Civil Rights Settles Ransomware Cybersecurity Investigation for $500,000 $500,000 Verified in agreement text
2024-10-17 HHS Office for Civil Rights Imposes a $70,000 Civil Monetary Penalty Against Gums Dental Care for Failure to Provide Timely Access to Patient Records $70,000 Verified in agreement text
2024-10-03 HHS Office for Civil Rights Imposes a $240,000 Civil Monetary Penalty Against Providence Medical Institute in HIPAA Ransomware Cybersecurity Investigation $240,000 Verified in agreement text
2024-09-26 HHS Office for Civil Rights Settles Ransomware Cybersecurity Investigation under HIPAA Security Rule for $250,000 $250,000 Verified in agreement text
2024-07-01 HHS Office for Civil Rights Settles HIPAA Security Rule Failures for $950,000 $950,000 Stated in HHS headline
2024-04-01 HHS OCR Imposes a CMP on NJ Nursing Facility for Failing to Provide Timely Access to Patient Records Not quantified Not quantified (source shows proposed amount only)
2024-03-29 HHS’ OCR Settles HIPAA Investigation with Phoenix Healthcare $35,000 Verified in agreement text
2024-03-05 HHS OCR Work with Hospital to Improve Access to Kosher Electronic Devices Use for Virtual Patient Visitation Non-monetary Verified in agreement text
2024-02-06 HHS’ Office for Civil Rights Settles Malicious Insider Cybersecurity Investigation for $4.75 Million $4,750,000 Verified in agreement text

The full ledger back to 2008 is in the downloadable dataset below.

Frequently asked questions

How many HIPAA enforcement actions were there in 2025?

25, the highest annual count on the HHS OCR resolution agreements and civil money penalties list.

What is the average HIPAA penalty?

The median verified amount for 2024 to 2026 was $240,000. Medians are more representative than averages because a few large settlements skew the mean.

What is the largest HIPAA settlement?

Anthem’s $16 million settlement in October 2018, after what HHS described as the largest health data breach in history, which exposed the electronic protected health information of almost 79 million people.

Does OCR penalize ransomware victims?

OCR has resolved 14 investigations naming ransomware since October 2023. In the three ransomware resolution documents we could read in full, OCR cited the Security Rule risk analysis requirement rather than the attack itself.

How often does OCR announce enforcement actions?

Irregularly; 2025 averaged about two a month.

Where does this data come from?

The HHS Office for Civil Rights list of resolution agreements and civil money penalties, and the agreement documents linked from it.

Why are some amounts “not quantified”?

Some source pages have moved to an archive service, some are scanned images, and some announcements bundle several cases. We report an amount only when it appears in an HHS source we could read.

Is this legal advice?

No. It is a record of public enforcement data.

Methodology

Source. HHS Office for Civil Rights, “Resolution Agreements and Civil Money Penalties” list, retrieved October 2026, and each linked agreement or press release. 162 enforcement entries were extracted after removing one regulatory fact sheet and one duplicate listing of the same Montefiore settlement.

Amounts. An amount is recorded only if it appears in an HHS headline or in the binding text of the linked document (“Resolution Amount”, “Settlement Amount”, or “agreed to pay”). Proposed penalties later reduced or settled were replaced with the final amount. Amounts not found in a readable HHS source are marked “not quantified”.

Not quantified since 2024 (8): 2025-07-07 HHS’ Office for Civil Rights Settles HIPAA Privacy and Security Rule I; 2025-01-15 HHS Office for Civil Rights Settles HIPAA Case Against Memorial Health; 2025-01-08 HHS Office for Civil Rights Settles HIPAA Security Rule Investigation ; 2025-01-07 HHS Office for Civil Rights Settles 9th Ransomware Investigation with ; 2025-01-07 HHS Office for Civil Rights Settles 8th Ransomware Investigation with ; 2024-12-10 HHS Office for Civil Rights Settles with Health Care Clearinghouse, In; 2024-11-26 HHS Office for Civil Rights Settles with Holy Redeemer Family Medicine; 2024-04-01 HHS OCR Imposes a CMP on NJ Nursing Facility for Failing to Provide Ti.

Limitations. The list covers formal resolutions and penalties only; most OCR investigations close with technical assistance and do not appear. Medians exclude unquantified actions. Headline-based categories understate security cases in earlier years.

Update cadence. This ledger is rechecked when OCR announces new actions. Last checked October 2026.

Cite as:The Uptime Report. "HIPAA Enforcement Tracker: Every OCR Penalty and Settlement, 2016 to 2026." October 2026. https://theuptimereport.com/hipaa-enforcement-tracker-2026/

Download the data. hipaa-enforcement-actions-2008-2026.csv (CSV). Licensed under CC BY 4.0: free to reuse with attribution to The Uptime Report.

References

  1. HHS OCR, Resolution Agreements and Civil Money Penalties. Accessed October 2026.
  2. HHS OCR, Anthem resolution agreement. Accessed October 2026.
  3. HHS, The HIPAA Security Rule. Accessed October 2026.
  4. Individual agreement documents, linked in the ledger above. Accessed October 2026.

Research library

More original data reports from The Uptime Report. Every report includes its methodology and a free CSV download. Browse all research

Threats and breaches

Infrastructure and uptime

Regulation and disclosure

Workforce and pay

MSP market and spending

Comments

5 responses to “HIPAA Enforcement Tracker: Every OCR Penalty and Settlement, 2016 to 2026”

  1. […] HIPAA Enforcement TrackerEvery OCR penalty and settlement […]

  2. […] HIPAA Enforcement TrackerEvery OCR penalty and settlement […]

  3. […] HIPAA Enforcement TrackerEvery OCR penalty and settlement […]

  4. […] HIPAA Enforcement TrackerEvery OCR penalty and settlement […]

  5. […] HIPAA Enforcement TrackerEvery OCR penalty and settlement […]

Leave a Reply

Your email address will not be published. Required fields are marked *