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Tag: Red Flags Rule

The Red Flags Rule

HalamkaYou may have seen the recent headlines “FTC delays Red Flags Rule
implementation until August 2009”. What is the Red Flags Rule and how
does it relate to healthcare?

The FTC has a great website that it explains it all in detail.

Basically,
the FTC requires most clinical offices, hospitals, and other health
care providers to develop a written program to spot the warning signs
of identity theft – “red flags”  If a patient’s name on a photo ID and on their insurance card do not match, that’s a red flag. If a patient visited last week as John Smith but today is Fred Jones, that’s a red flag. If patient seems to travel from provider to provider seeking numerous expensive treatments, that’s a red flag.

The
law was initially designed to cover creditors and it seems odd for
healthcare providers to be considered creditors. The FTC defines a
creditor as anyone who enables the customer to carry a balance after
services are rendered. Unless a clinician asks for payment upfront (all
balances not covered by insurance), the clinician is a creditor.

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