DisclosureLens
FEDERALUnknownLow

Consociate Health

bd_2425fd9dda860c81 · schema v1 · pii pii-v1

Severity

Low

Discovered

—

Filed

Dec 18, 2025

To disclose

—

Affected

Not disclosed

Linked

3 filings

Confidence

90%
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. The business associate failed to conduct a thorough risk analysis. Consociate agreed to pay $225,000 and implement a Corrective Action Plan including risk analysis, risk management, policy updates, and workforce training.

Incident timeline — partial

? — ?

Breach window unknown

Dec 18, 2025

Filed

—

Corroborated · see linked filings

Compliance clocks stay unassessable until a breach filing is linked. This record is the regulator's action, not a breach notice. Dashed segments fill in automatically when corroboration arrives.

This filing is one of 3 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (2) · sorted by filing gap

Filing propagation · 3 filings · 2 states

View merged incident ↗
HHS OCRNov 3 · first
Indiana State AGNov 3 · first
HHS OCR enforcement+1506d · this page

Pattern: first filing Nov 3 (IL), last Dec 18 — a 1506-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

Evidence ladder

Leak-site claim

Attacker assertion only. Establishes: claim date, group, alleged victim.

Press / market report

Unlocks: incident narrative, operational impact. Still no compliance clock.

State AG / regulator filingThis record

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

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.