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HHS OCRState AGConfirmed15 filings · 9 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 15 filings

Comprehensive Health Services — April 2020 breach

Clustered 15 filings across 9 jurisdictions · filing window Jan 20, 2022 → Mar 16, 2022 (dated filings only). View entity profile → Other incidents for this victim →

⚠ 2 cross-filing discrepancies →Merge100%

Determination

Confirmed

Members

15 filings

States

9

Affected · reported

106,752

First → last dated filing

Jan 20, 2022 → Mar 16, 2022

Merge confidence

100%

incident inc_273e49e86bda474b · merged by deterministic · confidence 100%

Confirmed breach. Merged as one breach: 15 regulatory filings. The filings describe unauthorized access. Intrusion Apr 9, 2020–Oct 22, 2020, discovered Sep 30, 2020. 106,752 individuals reported across the linked filings. Data reported: Government ID, Identity (basic), PII, and 3 more. Notifications rolled out on a 55-day schedule across 13 dated filings beginning Jan 20, 2022. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Discovery variance
399days

Range of discovered_at dates across filings

Filing span
55days

Time between earliest and latest filing

Not recorded for this incident

Leak precedence · Materiality delta · SEC filing delay — no leak-site claim in this cluster; no SEC 8-K in this cluster.

Regulatory clocksWashington✗ WA AG >90dOregon✗ OR AG >45dMaine⏱ ME AG >30d · 503dMassachusetts✓ MA credit monitoring dueHIPAA✓ HHS notifiedFull clock table in Litigation Timeline

Sensitive data

identity_government

Incident timeline

Apr 9, 2020breach begins
Sep 30, 2020discovered · members disagree
Jan 20, 2022first dated filing
Mar 16, 2022most recent dated filing

Dashed segments are unestablished, not zero — they fill in as filings merge into this incident. Filings without a recorded filing day, or recorded as filed before the breach they report began, are not placed on this rail.

Member cascade — every filing about this breach

  1. JAN 1IL AGIL AG noticefiling day not on record · no count stated—
  2. JAN 1IL AGIL AG noticefiling day not on record · no count stated—
  3. JAN 20NH AGNH AG noticefirst filing · 1 NH residentsday 0
  4. JAN 20MA AGMA AG notice1,533 MA residentsday 0
  5. FEB 15ME AGME AG noticestates nationwide total 94,449+26d
  6. FEB 15MT AGMT AG notice335 MT residents+26d
  7. FEB 15WA AGWA AG notice2,785 WA residents+26d
  8. FEB 15NH AGNH AG notice427 NH residents+26d
  9. FEB 15HHS OCRHHS OCR noticestates nationwide total 106,752+26d
  10. FEB 15CA AGCA AG noticeno count stated+26d
  11. FEB 15OR AGOR AG noticestates nationwide total 94,449+26d
  12. MAR 15NH AGNH AG notice428 NH residents+54d
  13. MAR 16OR AGOR AG noticestates nationwide total 95,297+55d
  14. MAR 16ME AGME AG noticestates nationwide total 95,297+55d
  15. MAR 16CA AGCA AG noticemost recent · no count stated+55d
  16. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Apr 9, 2020 – Oct 22, 2020
ME AG
Discovered
Sep 30, 2020IL AG + NH AG + ME AG +2Nov 3, 2021MT AG + CA AGfilings disagree on discovery
Data types
Employment · Financial account · Health (basic) · Identity (basic) · Government ID · PII
NH AG + ME AG + MT AG +4
Attack vector
Unauthorized Access
NH AG

Each fact cites the member filing that establishes it; when filings conflict, every value shows with its source.

Count reconciliation

per-state reported counts

Nationwide (stated in a filing)

106,752

Sum of filed state slices

5,683· 5.3% of stated

95% of the stated total lives in states whose filings carry no count — the dashed share shrinks as filings land.

US106,752
WA2,785
MA1,533
ME602
NH428
MT335

State AGs report only their own residents; teal bars show each state's reported slice. The gray US row is the nationwide total reported in a linked filing.

Evidence ladder — rungs this incident occupies

Leak-site claim

No leak-site claim on record for this incident.

Press / market report

No press coverage linked yet.

State AG / regulator filing15 members

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

SEC 8-K / victim statement

No SEC filing or victim statement yet.

Merge provenance

Method
deterministic
Confidence
1.00 · above the 0.85 auto-merge floor
Reviewed
operator-reviewed Oct 22, 2026 · at least one link edge was human-adjudicated
Audit
Every link edge records its method, confidence and model + prompt versions (100% is the strongest edge).

Merges are reversible — a wrong link can be detached with its audit trail intact. How merging works.

Filing velocity

Spread

55 days

Cadence

~1 / 4.6d

vs. multi-state median

9.2× slower

About this clustering

DisclosureLens links filings into incidents through layered matchers: deterministic rules (same source document, multistate filings of one breach, tight-window same-victim pairs), a weighted-similarity scorer for cross-source candidates, and an operator review queue for everything uncertain. Each link records its own method and confidence — shown per filing in the timeline below. The system defaults to NOT merging when uncertain, because a false merge (collapsing two unrelated breaches) is more harmful than a false split (showing related filings separately); uncertain pairs route to human review instead of auto-merging. This page states only what the linked filings agree on; each filing's own account stays on its own record, linked from the timeline below.

The weekly clock on records like this one

The Disclosure Clock is a weekly briefing on what landed in the disclosure record, and the gap between the criminals' post and the regulator's filing — measured on the whole record, with the method shown.

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