Terms Unconditional

EHR & Health Data Systems · Health Clearinghouse · Regulatory action + Private litigation + Data breach

Change Healthcare (Optum / UnitedHealth Group)

Headline

The largest health-data breach on record in the US.

Not independently verified. Verification status: Unverified - heuristic first draft. Publish state: draft unverified.

The largest health-data breach on record in the US. In February 2024 a ransomware group got into Change Healthcare, the claims clearinghouse that a huge share of US doctors, pharmacies and insurers route bills and eligibility checks through. They got in with stolen credentials through a remote-access (Citrix) portal that, by UnitedHealth's CEO's own testimony, did not have multi-factor authentication. UnitedHealth paid a $22 million ransom. The final count reported to HHS's Office for Civil Rights was about 192.7 million people (July 31, 2025), and UnitedHealth said it couldn't fully de-duplicate that number. HHS OCR has open investigations of both Change Healthcare and UnitedHealth Group, with no findings published yet. Nebraska's Attorney General became the first state to sue, in December 2024. A judge denied the companies' motion to dismiss in November 2025, so that case is going forward. Roughly 50 private class actions are consolidated in federal court in Minnesota (MDL No. 3108). No settlement had been announced as of mid-2026. Most people whose data was taken never chose to do business with Change Healthcare. Their doctor, pharmacy or insurer sent their records through it.

  • SeveritySeverity 5 of 5, not independently verified. The largest health-data breach on record in the US.
  • Evidence tierUnassigned
  • Claims confirmedNo sourced claims yet
  • Last verified2026-10-15

Primary source. www.hhs.gov/hipaa/for-professionals/special-topics/change-healthcare-cybersecurity-incident-frequently-asked-questions/ — Unverified - heuristic first draft.

Last verified 24 days agoverified 24 days ago0180 days
Freshness. Last verified 24 days ago (2026-10-15); stale after 180 days.

Terms

Arbitration

None. There is no consumer contract, because patients have no direct agreement with Change Healthcare. The website privacy notice says continued use of the Sites or Services 'constitutes your consent' to notice changes.

Data sharing

Acts as a HIPAA business associate for providers and payers. Its own privacy notice says its handling of protected health information 'is guided by HIPAA and the terms of a business associate agreement' and isn't described in the public notice. Claims, eligibility, pharmacy and payment transactions for a very large share of US patients flow through it. Data reported as exposed in the breach included medical, personal and financial information (Nebraska AG). The website privacy notice also lists collecting 'inferences' and data from data brokers, credit agencies and social networks about website and service users, which is separate from patient PHI.

Who holds your data. Data chain: Change Healthcare (Optum / UnitedHealth Group), then Optum, a subsidiary of UnitedHealth Group. The privacy notice says 'Change Healthcare is now a part of Optum.' (parent), then EHR vendor layer. See cross-cutting finding 16: THE EHR LAYER — THE COMPANY HOLDING YOUR CHART IS ONE YOU NEVER SIGNED WITH.

Fees and billing

Not a consumer-billing relationship. The provider-side MDL track alleges harm from delayed or denied reimbursement during the claims-processing outage, which is a downstream cost to small medical practices.

Contacts

Privacy contact. privacy@optum.com

Legal notice. Privacy mail: Optum Privacy Office, MN101-E013, 11000 Optum Circle, Eden Prairie, MN 55344 (per Change Healthcare privacy notice). UnitedHealth Group Incorporated, a Delaware corporation, lists principal executive offices at 1 Health Drive, Eden Prairie, MN 55344 and 655 New York Avenue NW, Washington, DC 20001 (FY2025 Form 10-K cover, filed Mar. 2, 2026). For service of process, confirm the Delaware registered agent via the Delaware Division of Corporations (not checked this pass).

Mailing address. Not recorded.

Written channel present
Paper trail: written. Written channel present.

Evidence

No claims have been itemized for this row yet.

Sources

SourceClaimTierStatusQuote
Regulator (HHS OCR) · 2025-08-13
www.hhs.gov/hipaa/for-professionals/special-topics/change-healthcare-cybersecurity-incident-frequently-asked-questions/
whole rowUnassignedconfirmed“approximately 192.7 million individuals impacted”
Quote basis: not recorded.
Trade press · 2025-08-06
healthcareitnews.com/news/new-numbers-change-healthcare-data-breach-193-million-affected
whole rowUnassignedconfirmed“complete deduplication was not feasible.”
Quote basis: not recorded.
News (quoting written congressional testimony) · 2024-04-30
www.theregister.com/2024/04/30/unitedhealth_ceo_ransom/
whole rowUnassignedconfirmed“The portal did not have multi-factor authentication.”
Quote basis: not recorded.
News · 2024-12-16
nebraskaexaminer.com/2024/12/16/ag-sues-change-healthcare-two-other-companies-after-data-breach-hits-at-least-575000-nebraskans/
whole rowUnassignedconfirmed“Once that information is on the dark web, which it is, you can't put it back in.”
Quote basis: not recorded.
State AG press release · 2025-11-13
ago.nebraska.gov/sites/default/files/doc/News%20Release%2011-13-25.pdf
whole rowUnassignedconfirmed“Nearly half of Nebraskans had their most sensitive information exposed because of this breach.”
Quote basis: not recorded.
Law firm client alert · 2024-09-19
garfunkelwild.com/insights/update-on-change-healthcare-class-action-litigation/
whole rowUnassignedconfirmed“In re: Change Healthcare, Inc. Customer Data Security Breach Litigation”
Quote basis: not recorded.
Legal news aggregator (secondary) · 2026-07-28
openclassactions.com/lawsuits/data-breaches/change-healthcare-data-breach-class-action-lawsuit.php
whole rowUnassignedconfirmed“no agreement has been announced”
Quote basis: not recorded.
Company privacy notice · 2023-12
changehealthcare.com/privacy-notice
whole rowUnassignedconfirmed“Change Healthcare is now a part of Optum.”
Quote basis: not recorded.

Source vault

Link status: Candidate - not yet fetched

DocumentLast fetchPDF
Privacy policy
https://changehealthcare.com/privacy-notice
Not fetched yetNOT CONFIRMED
Terms of service
https://www.optum.com/en/terms-of-use.html (changehealthcare.com now redirects to Optum; these are the Optum Terms of Use linked from the redirected site)
Not fetched yetNOT CONFIRMED
Website
https://changehealthcare.com
Not fetched yet—
Primary source
https://www.hhs.gov/hipaa/for-professionals/special-topics/change-healthcare-cybersecurity-incident-frequently-asked-questions/
Verification: Unverified - heuristic first draft
Not fetched yet—

Enforcement

ActionAmountLink
HHS OCR investigation of Change Healthcare / UnitedHealth Group (open; no resolution published)
HHS Office for Civil Rights (OCR), 2024
OCR Change Healthcare Cybersecurity Incident FAQs (updated as of Mar. 14, 2025; content last reviewed Aug. 13, 2025)
—proposed
State of Nebraska ex rel. Hilgers v. Change Healthcare (Change Healthcare breach; MTD overruled Nov. 2025)
Nebraska Attorney General, 2024
No. CI 24-4356 (Lancaster Cnty. Dist. Ct., filed Dec. 16, 2024); Order on Motion to Dismiss (Nov. 10, 2025) (motion overruled)
—proposed

Links are proposed matches, not yet reviewed.

State statute

Headquarters on file: MN. Provisions of MCDPA-MN on file:

ProvisionTypeSource
Applicability Threshold
Minn. Stat. § 325O.03
thresholdsource
Right to Question Profiling Decisions — Most Explicit in Any US State
Minn. Stat. § 325O.05
hardsource
Right to List of SPECIFIC Third Parties
Minn. Stat. § 325O.05, subd. 1(h)
hardsource
Universal Opt-Out Mechanism Required
Minn. Stat. § 325O.05, subd. 3
hardsource
Enforcement — AG; 30-Day Cure for Entities with Documented Programs
Minn. Stat. § 325O.10
hardsource