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International Center for Chiropractic Office Managers |
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A Leader in Chiropractic Office Management Training |
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Red Flag: Identity Theft Prevention Manual Compliance date postponed to June 1, 2010 |
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The 35 page Electronic Version only: $79.00
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Dear Doctors and Chiropractic Office Managers,
I am concerned, again. I get many emails daily with questions concerning practice and HIPAA. But recently, of course, the emails are focusing on Red Flag Rules and the FTC Requirement to have an Identity Theft Prevention Program in place in our offices by August 1, 2009. FTC POSTPONED COMPLIANCE AGAIN TO JUNE 1, 2010.
These rulings are not new, but it seems that most of us, including me, were taken back by the fact that WE had to do it. I worked for several weeks putting together a manual because so many doctors have done nothing. I do not have it up on my website yet but Several state associations are going to co-sponsor my manual in an effort to get the information out as quickly as possible.
LINKS: http://www.ftc.gov/bcp/edu/pubs/business/idtheft/bus23.pdf http://www.nacubo.org/documents/business_topics/Guidelines%20to%20FTC%20Red%20Flag%20APP.pdf http://ftc.gov/opa/2009/04/redflagsrule.shtm This is what is required of you in the simplest of terms.
My goal is to support you in establishing and implementing your Identity Theft Prevention Program into your current office procedures in the easiest way possible. This should not be a difficult endeavor and does not need to be time consuming. It just MUST be done. How many of you have actually have had an issue with identity theft? In our chiropractic offices we have identified two main risks and would most likely show-up as suspicious documents on the first visit.
1) Someone who may try to steal an identity to use an insurance card 2) Someone who is trying to steal and identity to use a credit card
This publication is about keeping it simple and giving you everything you need to become compliant. Chiropractors do not fall victim to Identify theft issues often. We are considered “low risk” because we get to know our patients. Therefore, implementation should be relatively easy. Even though Identity theft is rare in chiropractic offices, times are changing and as health care providers (creditors) we are required by law to have in place an Identity Theft Prevention Program.
First, you must determine if you are required to comply with Red Flag rules and establish an Identity Theft Prevention Program. Are you considered a “creditor” under the FTC ruling?
It is simple: Do you allow patients to pay their accounts over time (ever)? Do you accept assignment from third party payers? Do you allow patients to pay their co-pay overtime? Do you allow cash patients to pay over time. Do you do any direct patient billing? Do you accept credit card payments? YES, then you are required to have your Identity Theft Program established for your office effective August 1, 2009. Any form of theft of personal identifying information to obtain medical goods and services is covered under the Red Flag rule.
Are you strictly cash each visit or prepay? Do you NOT accept credit card payments? No Exceptions, Ever? No, then you are not required to have your Identity Theft Program established and quit reading now and go adjust more patients. (Accepting credit cards does not make you a “creditor” under the Red Flag rules Medical Identity Theft, but identity theft prevention for credit card acceptance is required under other Red Flag rules.)
Second, since you answered YES, this is what you need to do:
Put together an Identity Theft Prevention Program in your office by August 1, 2009 or purchase my manual read it thoroughly and all appropriate links. Designate and announce an oversight employee (I strongly suggest you use your HIPAA Privacy Official) Set Training and Testing Schedule Complete training and have all policies and procedures in place by August 1, 2009
I have kept this as inexpensive as I can to get it out to as many D.C.’s as possible within the next 30 days. I try not to use “TIPs” as a forum to advertise or market, but you cannot get this cheaper or easier and you must do put this in place within the next 30 days.
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Contact Us: 18867 Circle Lane N Southgate, MI 48195
Phone: 313.330.0199 Fax: 801.306.8030 Email: edie@ICCOM.org |
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FTC’s Red Flag Rules: Identity Theft Prevention
COMPLIANCE deadline June 1, 2010 House has Passed an amendment to the FTC’s Red Flags Rule which Might exempt you from the compliance requirement. Stay tuned |