Orthopedic Tip of
RED FLAG RULE – WRITTEN PROGRAM TO DETECT, PREVENT, AND MITIGATE IDENTITY THEFT
According to the US Federal Trade Commission: “Medical Providers are creditors under the Red Flag Rule. Your business or organization is a “creditor” if you regularly:
- Extend, renew, or continue credit;
- Arrange for someone else to extend, renew, or continue credit, or
- Are the assignee of a creditor who is involved in the decision to extend, renew, or continue credit.
Under the RULE, “credit” means an arrangement by which you defer payment of debts or accept deferred payments for the purchase of property or services. In other words, payment is made after the product was sold or the service was rendered. “Even if you are a non-profit or government agency, you still may be a creditor if you accept deferred payments for goods or services.”
Go on-line to read about stories about identify theft: www.dhhs.gov/healthit/privacy/theft.html
The RED FLAG RULE doesn’t tell you specifically what your red flags program must look like. In some respects, that would be too easy ! Instead, it give you flexibility to implement a program that best suits your business or organization, as long as it meets the RULE’S requirements. Your starting point for developing a program is the GUIDELINES issued with the RED FLAGS RULE, available at www.ftc.gov/os/fedreg/2007/november/071109redflags.pdf. (The Guidelines are on pages # 63773 – 63774 of this document).
If you have questions about how you as a health care provider can comply with the RULE, you can e-mail RedFlags@ftc.gov for more information.
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