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HHS OCRState AGConfirmed10 filings · 4 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 10 filings

Benefit Plan Administrators, Inc. — September 2021 breach

Clustered 10 filings across 4 jurisdictions · filing window Jan 1, 2022 → Jul 25, 2022. View entity profile → Other incidents for this victim →

✓ affected count, data types, discovery date agreeMerge100%

Determination

Confirmed

Members

10 filings

States

4

Affected · reported

2,846

First → last filing

Jan 1, 2022 → Jul 25, 2022

Merge confidence

100%

incident inc_817164ce27b24a65 · merged by deterministic · confidence 100%

Confirmed breach. Merged as one breach: 10 regulatory filings. The filings describe unauthorized access. Intrusion Sep 13, 2021, discovered Sep 13, 2021 — the first regulatory filing landed 110 days later. 2,846 individuals reported across the linked filings. Data reported: Government ID, PHI, Health (basic), and 1 more. Notifications rolled out on a 205-day schedule across 10 filings beginning Jan 1, 2022. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Notification delay
110days

Discovered → first regulatory filing

Discovery variance
0days

Range of discovered_at dates across filings

Filing span
205days

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 clocksHIPAA✓ HHS notifiedSouth Carolina✓ SC CRA notice dueFull clock table in Litigation Timeline

Sensitive data

identity_government

Incident timeline

Sep 13, 2021breach begins
Sep 13, 2021discovered
notification delay · 110 days
Jan 1, 2022first filing
Jul 25, 2022most recent filing

Dashed segments are unestablished, not zero — they fill in as filings merge into this incident.

Member cascade — every filing about this breach

  1. JAN 1IL AGIL AG noticefirst filing · no count statedday 0
  2. JUN 27HHS OCRHHS OCR noticestates nationwide total 735+177d
  3. JUN 27HHS OCRHHS OCR noticestates nationwide total 1,267+177d
  4. JUN 27NH AGNH AG notice5 NH residents+177d
  5. JUN 29SC AGSC AG notice2,841 SC residents+179d
  6. JUN 29HHS OCRHHS OCR noticestates nationwide total 1,145+179d
  7. JUN 30HHS OCRHHS OCR noticestates nationwide total 628+180d
  8. JUL 8HHS OCRHHS OCR noticestates nationwide total 878+188d
  9. JUL 8HHS OCRHHS OCR noticestates nationwide total 1,089+188d
  10. JUL 25HHS OCRHHS OCR noticemost recent · states nationwide total 1,457+205d
  11. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Sep 13, 2021
NH AG
Discovered
Sep 13, 2021
IL AG + NH AG + SC AG
Data types
Health (basic) · Identity (basic) · Government ID · PHI
HHS OCR + NH AG + SC AG
Attack vector
Unauthorized Access
HHS OCR

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

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 filing10 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
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

205 days

Cadence

~1 / 22.8d

vs. multi-state median

22.8× 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

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