
Medical Identity Theft Prevention Compliance
Click Here for information on the Red Flag Compliance Package
developed by HCCS to help your practice!
The Federal Trade Commission issued an announcement that the deadline to implement the Red Flag requirements pertaining to identity theft has been delayed for six months utnil May 1, 2009. The deadline was extended to August 1, 2009. As of July 29, 2009, The Federal Trade Commission extended the Red Flag requirements to November 1, 2009. On October 30,2009, the Federal Trade Commission again extended the deadline to June 1, 2010. At the request of several Members of Congress, the Federal Trade Commission is further delaying enforcement of the “Red Flags” Rule through
December 31, 2010.
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The Red Flag Rules are a result of the Fair and Accurate Credit Transaction Act (FACTA) and focus on the prevention of identity theft. |
Originally intended for financial institutions and creditors, the Red Flag Rules become applicable to healthcare entities because they are considered creditors. The Federal Trade Commission (FTC) is the enforcement agency.
A Red Flag means a pattern, practice, or specific activity that indicates the possible existence of identity theft. The Red Flag Rules state that healthcare entities must establish reasonable policies and procedures for implementing the identity theft guidelines.
In order to accomplish this, a healthcare entity must develop a written program to detect, prevent, and mitigate identity theft in connection with the opening of an account or any existing account. The written program must address four main points:
1. Identify relevant Red Flags for the covered accounts and incorporate those Red Flags into the Program;
2. Detect Red Flags that have been incorporated into the program;
3. Respond appropriately to any Red Flags that are detected to prevent and mitigate identity theft; and
4. Ensure the Program is updated periodically to reflect changes in risks to customers or to the safety and soundness of the financial institution or creditor from identity theft.
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