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SettlementMedium RiskMultistate

CT and MA AGs Settle with Comstar for $515K Over Patient Data Breach

Comstar, LLCJanuary 28, 2026Connecticut Attorney General

Penalty Amount

$515,000

Consumers Affected

349,255

Summary

Comstar, LLC, an ambulance billing vendor, suffered a data breach in March 2022 that exposed sensitive patient information, including Social Security numbers and medical records, of over 349,000 residents in Connecticut and Massachusetts. The settlement requires Comstar to pay $515,000 and implement enhanced security measures such as phishing protection and annual security assessments.

Remedy

Comstar must pay $515,000 and implement security measures including phishing protection software, vulnerability management program, multi-factor authentication, and conduct annual security assessments for three years with reports to the Connecticut and Massachusetts Attorneys General.

Monetary PenaltyCompliance ProgramAudit RequirementReporting Requirements

Contract Impact

In-house legal teams should review vendor agreements, data processing agreements, and Business Associate Agreements (BAAs) with entities like Comstar that handle sensitive patient data. Key clauses to scrutinize include data security standards, breach notification requirements, HIPAA compliance obligations, audit rights, and indemnification provisions. Given the settlement, contracts should be updated to mandate specific security measures such as phishing protection and annual security assessments, ensure prompt breach notification in line with state and federal laws, and include robust indemnification clauses to cover potential liabilities from data breaches involving protected health information.

Contract Search Terms

HIPAA compliancedata security standardsbreach notification protocolencryption requirementsannual security assessmentsphishing protection measuresprotected health information (PHI) handlingvendor indemnification for data breachesaudit rights for securitydata retention and disposal

Laws Cited

Connecticut and Massachusetts security and consumer protection lawsHealth Insurance Portability and Accountability Act (HIPAA)

Violation Types

Entity Details

Entity

Comstar, LLC

Also known as: Comstar

Industry

Healthcare

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"Comstar, LLC"
Fine Amount
"$515,000"
Laws Cited
"Health Insurance Portability and Accountability Act (HIPAA)"
Laws Cited
"Connecticut and Massachusetts security and consumer protection laws"
Violation Types
"data breach"
Violation Types
"failing to implement basic, necessary security measures"

Related Enforcement Actions

MA

Comstar, LLC

$515K

Massachusetts Attorney General secured a $515,000 settlement with Comstar, LLC for a March 2022 data breach that exposed sensitive patient information of over 326,000 Massachusetts residents. Comstar violated Massachusetts Data Security regulations and HIPAA by failing to maintain adequate security measures. The settlement includes monetary payment and mandated security improvements.

CT

Frontier Communications Parent Inc.

$625K

Connecticut reached a $625,000 settlement with Frontier Communications Parent Inc. over an April 2024 breach in which compromised employee and vendor credentials were used to access internal systems and exfiltrate unencrypted personal information of 58,841 Connecticut residents. The settlement requires Frontier to strengthen its security program, implement specific safeguards and training, and obtain an independent third-party assessment.

CT

Boston Children’s Health Physicians and XTIUM

$2.6M

Connecticut and New York found that Boston Children’s Health Physicians and its security vendor, XTIUM, failed to use reasonable safeguards, resulting in hackers accessing sensitive personal, medical, and employee information. The companies agreed to pay penalties totaling $2.64 million and implement enhanced cybersecurity measures.

CT

Character Technologies, Inc.

Connecticut joined a coalition of state attorneys general filing a notice in Character Technologies, Inc.’s bankruptcy proceedings, raising concerns about the company’s safety and privacy practices and the sensitive information it holds. The states seek protections for children and consumers if the company’s business or assets are sold or transferred; the filing does not impose a fine or other remedy.

CT

Connecticut public utilities

Attorney General William Tong and Consumer Counsel Claire Coleman petitioned PURA to review how Connecticut public utilities use artificial intelligence, citing potential data privacy and cybersecurity risks, algorithmic errors, and misleading outputs. The petition asks PURA to examine utility AI systems, safeguards, vendors, and data security practices; it does not report a finding of violation or an imposed penalty.

CT

RZ Smoke, Inc.

$2.0M

Connecticut Attorney General William Tong announced a settlement with RZ Smoke, Inc. over allegations that it distributed and sold high-potency cannabis products without a state license. The stipulated judgment is $2 million, with $375,000 payable to the State and $1.6 million suspended to ensure compliance; the company is barred from specified cannabis activities in Connecticut unless licensed.