Lessons learned

OCR closes each investigation with a narrative: what happened and what the entity changed. Each resolved case is filed under the control domain it teaches, with a program action and the exam domains it touches, in the same chapters as the analytics.

What this means for you

Workforce training is the corrective action OCR records most often: 2,590 resolved cases of 6,578 (39%), while 34% name no specific change.

The control resolved cases teach most is Business associate oversight (31%): Hold vendors to a signed BAA, a security assessment scaled to the data they hold, and a contractual breach-notice window shorter than the rule's 60 days.

Lessons that apply to you

Set your entity type and the breach type you most want to prevent, and this shows how many resolved cases match and what organizations like yours changed afterward.

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Lessons by the numbers

All 6,578 resolved OCR cases with a narrative, submitted 2009 to 2026. These figures do not change with the filters below. Click a control-domain bar to open that domain's chapter.

6,578
Resolved cases with a lesson
Submitted 2009 to 2026
56%
Name a specific change
3,697 of 6,578; 34% name only general safeguards, 10% state no corrective action
39%
Most common corrective action
Workforce training: 2,590 cases
362
Median days to closure
53 cases observed closing since Sep 23, 2026

Control failure mix

Resolved cases by the control domain they teach, of 6,578

Each case is filed under one domain, first match wins.

Control failure mix by year of submission

Share of each year's resolved cases, five largest domains

  • Business associate oversight
  • Email and phishing defense
  • Device and media encryption
  • Ransomware resilience and recovery
  • Paper records and disposal
  • All other domains
Years with at least 30 resolved cases.

Most common corrective actions

Resolved cases naming each action type, of 6,578

A case naming several actions counts under each.

Corrective actions by year of submission

Share of each year's resolved cases naming the five most common actions

Lines do not stack: one case can name several actions.

Every corrective action type

Corrective action types in resolved OCR cases
Workforce training2,59039%51%32%-18 pts
Safeguards not specified2,22034%14%46%+31 pts
Policies and procedures1,24919%41%6%-35 pts
Workforce sanctions6059%15%5%-10 pts
Risk analysis and management4327%16%1%-15 pts
Encryption4256%17%0%-16 pts
Email security3936%5%7%+2 pts
Physical security and disposal3195%10%2%-9 pts
Business associate agreements and vendors2854%8%2%-6 pts
Access controls and passwords2614%8%2%-6 pts
Audits and monitoring2153%7%1%-6 pts
Patching and system hardening1262%5%0%-4 pts
Multi-factor authentication911%2%1%-1 pts

Time to resolution

Median days from submission to closure, 53 cases Signals observed closing

By year of submission

By breach type

Median days to closure by breach type
Hacking/IT Incident32491 days
Unauthorized Access/Disclosure20107 days
Theft1834 daysFewer than 5 cases
Measured only for cases Signals saw move from under investigation to the archive, since Sep 23, 2026.

Chapter 2

Attack surface

Where does breached information sit, and which breach types go with which systems?

Read the analytics chapter

2,853 lessons in this chapterOne complete example below, the rest by title. Search, filters and every lesson in full come with a subscription.

District of Columbia, Department of Health Care FinanceMD · Health Plan · 399,086 individuals · submitted Sep 3, 2026
Unauthorized Access/DisclosureElectronic Medical Record

What changed afterward

  • In its mitigation efforts, the CE implemented additional technical controls to prevent a reoccurrence.

Program action

Enforce least privilege, MFA for remote and privileged access, and proactive EHR access audits.

HIPAA §164.312(a)(1), 164.312(d), 164.308(a)(4)

CISSP 5CISA 5

Full OCR narrative

The covered entity (CE), District of Columbia, Department of Health Care Finance, reported that a vulnerability in its website resulted in hidden protected health information (PHI) for two reports on its website could be accessed by individuals without authorization. According to the breach report, the breach affected approximately 399,086 individuals. The PHI involved dates of birth and other identifiers. The CE notified HHS, the media, and the affected individuals. In its mitigation efforts, the CE implemented additional technical controls to prevent a reoccurrence. OCR provided technical assistance to the CE regarding the HIPAA Rules and received evidence substantiating the CE’s notifications.

More lessons in this chapter (titles only)

and 2,844 more in this chapter

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Read all 6,589 lessons in full

Each resolved OCR case with what the organization changed afterward, the program action it points to and the HIPAA citation, filed by control domain in the same chapters as the analytics.
  • What changed afterward: corrective actions pulled from OCR's narrative
  • A program action and HIPAA citation for every lesson
  • CISSP, CISM and CISA exam-domain tags
  • Search the narratives; filter by breach type, entity type and location

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