IANAL but it doesn't seem that the way they define a breach (https://www.hhs.gov/hipaa/for-professionals/breach-notification/index.html https://www.hhs.gov/hipa

IANAL but it doesn't seem that the way they define a breach (https://www.hhs.gov/hipaa/for-professionals/breach-notification/index.html https://www.hhs.gov/hipaa/for-professionals/breach-notificat...) includes issues that provably haven't been exploited.