Discovery variance · Leak precedence · Materiality delta · SEC filing delay · Filing span — no leak-site claim in this cluster; no SEC 8-K in this cluster; needs two dated filings.
Regulatory clocksHIPAA✓ HHS notifiedFull clock table in Litigation Timeline
HHS OCRConfirmedLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedmoderate sensitivity
Affected (total reported)
812
Data types
3
PHI · Health (basic) · Identity (basic)
Jurisdictions
1
MI
Linked filings
1
all HHS OCR
Timeline
Earliest sighting first · deep chronology in Litigation Timeline
Upper Peninsula Health Plan reported to HHS on 2019-11-25 a Hacking/IT Incident affecting 812 individuals. Breached information located on Email. The case was consolidated into an existing compliance review concerning Magellan Healthcare, the business associate responsible for the breach.
Affected (this filing): 812
HHS notified
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.