Red Flags Rule
Enforcement Begins May 1, 2009
As you know, the Red Flags Rule was adopted by the FTC and federal financial regulatory agencies in an effort to reduce the ongoing problem of identity theft. The Red Flags Rule is sweeping in its applicability to all businesses that provide services and receive payment for those services at a later date. The FTC has confirmed in a letter to the American Medical Association that the Red Flags Rule does apply to healthcare providers.
Originally, the FTC was going to begin enforcing the Red Flags Rule on November 1, 2008. In response to multiple inquiries and confusion over the applicability of the Red Flags Rule, however, the FTC suspended enforcement of the Rule until May 1, 2009. With less than a month until the FTC begins enforcing the Red Flags Rule, healthcare providers are well advised to take action now so that they will be in compliance by May 1st.
To be in compliance with the Red Flags Rule by May 1, 2009, your practice should
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Appoint a Red Flags Manager;
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Conduct a Risk Assessment;
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Create a Red Flags Program;
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Obtain Board approval of the Program; and
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Train appropriate personnel.
We offer a full array of services to help bring your practice into compliance with the Red Flags Rule and would be happy to assist you in any way. Please feel free to contact Steve Gravely, Paige Fitzgerald, or Erin Whaley to discuss how we can help you create a Red Flags Program.