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RED FLAG Deadline December 2010
If you offer credit in certain circumstances to clients or patients, you must comply with the FTC "Red Flag" Identity program by December 2010. We have a compliance program to help you get your internal program up and running. Does my practice need to comply with the Red Flags Rule? Medical identity theft, particularly involving insider access to data, is expressly addressed in the Red Flags Guidelines and directs Providers to monitor all circumstances to prevent and mitigate patient identity theft. Although many of the Red Flags Rule provisions apply to banks, credit unions, transportation dealerships, and other institutions, health care providers have obligations under the Red Flags Rule based on the Rule’s definition of “Creditor”:
ü any entity which regularly extends (offers), renews, or continues credit; ü any entity which regularly arranges for the extension, renewal, or continuation of credit; or ü any assignee of an original creditor which participates in the decision to extend, renew, or continue credit. Essentially, if a health care provider offers credit to a patient by establishing an account that permits multiple payments, the Provider becomes a “creditor” offering a “covered account”, and is subject to the Red Flags Rule. What is the Red Flags Rule? The Red Flags Rule requires many businesses and organizations to implement a written Identity Theft Prevention Program designed to detect the warning signs – or "red flags" – of identity theft in their day-to-day operations. What do we need to do? Develop a policy and procedures to detect, deter and mitigate possible identity theft. Call 678-570-5422 for assistance.
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