Consociate Health
bd_2425fd9dda860c81 · schema v1 · pii pii-v1
Full breach record for Consociate Health →Regulator's decision — not a breach notification
This record is a regulator's decision, not the organisation's own breach notice. Breach-notification fields (discovery date, notification clock) are structurally absent — what this source establishes is the outcome and the provisions the decision cites.
HHS OCR settled with Consociate, Inc. (d/b/a Consociate Health) regarding a 2021 ransomware attack resulting from a phishing compromise. HHS' investigation indicated that Consociate failed to conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of the electronic protected health information (ePHI) that it holds. Consociate agreed to pay $225,000 and implement a Corrective Action Plan including risk analysis, risk management, policy updates, and workforce training.
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Incident timeline — partial
? — ?
Breach window unknown
Dec 18, 2025
Filed
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Corroborated · see linked filings
This record is the regulator's action, not a breach notice; its own dates cannot anchor compliance clocks. See the linked filings.
Linked disclosures
Why this link?Regulatory filings (2) · sorted by filing gap
- HHS OCRbd_794617d03bc22d2b2021-11-03 · +1506dCandidate
- Indiana State AGbd_cf95d933561376d22021-11-03 · +1506dVerified
Filing propagation · 2 filings · 2 states
View merged incident ↗Evidence ladder
Attacker assertion only. Establishes: claim date, group, alleged victim.
Unlocks: incident narrative, operational impact. Still no compliance clock.
Unlocks: discovery date, data types, affected count, compliance clock.
Unlocks: materiality, stated response, full audit trail. Ceiling removed.
Source ceiling
- instrument + outcome
- amount as filed (USD)
- CFR provisions
- the breach it recites
- discovery date
- notification clock
The dates the agreement recites belong to the underlying breach, years earlier, and are kept as evidence of WHICH breach rather than as this record’s timeline.