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.
- Severity
- Evidence tierUnassigned
- Claims confirmed
- 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.
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.
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.
Evidence
No claims have been itemized for this row yet.
Sources
| Source | Claim | Tier | Status | Quote |
|---|---|---|---|---|
| Regulator (HHS OCR) · 2025-08-13 www.hhs.gov/hipaa/for-professionals/special-topics/change-healthcare-cybersecurity-incident-frequently-asked-questions/ | whole row | Unassigned | confirmed | “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 row | Unassigned | confirmed | “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 row | Unassigned | confirmed | “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 row | Unassigned | confirmed | “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 row | Unassigned | confirmed | “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 row | Unassigned | confirmed | “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 row | Unassigned | confirmed | “no agreement has been announced” Quote basis: not recorded. |
| Company privacy notice · 2023-12 changehealthcare.com/privacy-notice | whole row | Unassigned | confirmed | “Change Healthcare is now a part of Optum.” Quote basis: not recorded. |
Source vault
Link status: Candidate - not yet fetched
| Document | Last fetch | |
|---|---|---|
| Privacy policy https://changehealthcare.com/privacy-notice | Not fetched yet | NOT 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 yet | NOT 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
| Action | Amount | Link |
|---|---|---|
| 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:
| Provision | Type | Source |
|---|---|---|
| Applicability Threshold Minn. Stat. § 325O.03 | threshold | source |
| Right to Question Profiling Decisions — Most Explicit in Any US State Minn. Stat. § 325O.05 | hard | source |
| Right to List of SPECIFIC Third Parties Minn. Stat. § 325O.05, subd. 1(h) | hard | source |
| Universal Opt-Out Mechanism Required Minn. Stat. § 325O.05, subd. 3 | hard | source |
| Enforcement — AG; 30-Day Cure for Entities with Documented Programs Minn. Stat. § 325O.10 | hard | source |