Court Rules
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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"

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