Progress Notes Issue 33: Red Flags Rule
NP Business Tip: Red Flags Rule The Federal Trade Commission has put together a Red Flags Rule for businesses, and it DOES apply to us. It requires you to have a written Identify Theft Prevention Program in place. According to the FTC, "Health care providers may be subject to the Rule if they are "creditors." Although you may not think of your practice as a "creditor" in the traditional sense of a bank or mortgage company, the law defines "creditor" to include any entity that regularly defers payments for goods or services or arranges for the extension of credit. For example, you are a creditor if you regularly bill patients after the completion of services, including for the remainder of medical fees not reimbursed by insurance. Similarly, health care providers who regularly allow patients to set up payment plans after services have been rendered are creditors under the Rule. Health care providers are also considered creditors if they help patients get credit from other sources -- for example, if they distribute and process applications for credit accounts tailored to the health care industry." Fortunately the government has made this relatively easy for all of us. Their website gives you templates to create our won Identify Theft Prevention Program. Visit http://www.ftc.gov/redflagsrule to learn more. You may want to read the article that is specific to the Health Care Provider for further information about why you need to comply with this rule.
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