Discovery variance · Leak precedence · Materiality delta · SEC filing delay — no leak-site claim in this cluster; no SEC 8-K in this cluster; needs two dated filings.
Regulatory clocksVermont⏱ VT AG >14 bdayHIPAA✓ HHS notifiedFull clock table in Litigation Timeline
HHS OCRState AGConfirmedLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedmoderate sensitivity
Affected (total reported)
2,740
Data types
2
PHI · Health (basic)
Jurisdictions
2
MI VT
Linked filings
2
HHS OCR · State AG
Timeline
Earliest sighting first · deep chronology in Litigation Timeline
Trinity Health (MI), a Business Associate, reported to HHS OCR on 2026-03-13 an Unauthorized Access/Disclosure breach affecting 2,740 individuals. Breached information was located on Electronic Medical Records. A business associate was present.
Trinity Health notified Vermont AG of a potential unauthorized disclosure of patient health information via HIE partner Health Gorilla on Jan 13, 2026. Data may include clinical details, demographics, insurance info, and driver's license numbers. Trinity Health suspended the involved companies from the HIE and is offering 12 months of credit monitoring.
VT AG >14 bday
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. Filing summaries shown in the timeline are AI-generated extracts — verify each against its linked source.