Are You Adhering to the Red Flag Rules?

Implement your identify theft protection program today New Federal Trade Commission (FTC) rules effective May 1, 2009, make it more important than ever for health care providers to establish identity theft protection programs. The FTC’s “Red Flag Rules” require health care providers who are considered creditors to implement programs that are designed to prevent, detect, and mitigate identity theft in connection with the opening and maintaining of accounts. There is some question as to what makes a health care provider a creditor. Formally, a health care provider is a creditor if it regularly accepts deferred payment for goods and services, and offers accounts for which there is a reasonably foreseeable risk of identity theft (such as accounts that permit delayed payments or multiple transactions). However, it appears likely that ordinary billing and collection practices—such as billing a patient some time after services are rendered instead of at the point of service—make health care providers subject to the Red Flag Rules. Although the new rules do require some effort on the part of health care providers, they don’t have to be a burden. We can help you develop an identify theft protection program that will ensure you are adhering the Red Flag Rules. Please contact us for more information.