As part of your facility's or practice's compliance with the FTCs Red Flag Rules, which are slated to take effect in June 2010, you need to come up with a list of "red flags" that represent risk factors for identity theft in health care.
Duane Abbey, whose recent audio conference, "Achieve Red Flag Compliance," gave medical professionals a hold on this new federal compliance requirement said, "To do this, use a risk assessment process, review prior experiences, and investigate the Federal Register.
First, assess these common risk factors of health care for identity theft: the types of accounts that have been established by the patients with you; verification of patient's identity by the insurance company; and the steps you take when opening an account for a patient.
Review prior experiences that your facility or practice might have had regarding identity theft issues. Look at the details whether you got paid or not, or if you had to make any adjustments in medical records regarding such issues.
Abbey cited few examples related to issues that could be red flags for identity thefts, from the Federal Register Supplement A to Appendix J:
* Alerts, warnings or notifications from a consumer reporting agency
* Suspicious personal identifying information and documents
* Suspicious activity related to, the covered account
* Notice from customers, law enforcement authorities, victims of identity theft or others.
* Mail sent to your patient is returned repeatedly as undeliverable, even though transactions continue to take place on his or her account
Abbey also provided some examples of red flags specific to healthcare providers:
* Thoroughly check insurance documents compared to drivers licenses and your records for address differences
* Check for mismatch between the individual and his photograph.
* Ensure that the address mentioned is true and it exists.
* Make sure you have a working and existing telephone number for patients.
* Check for medical record inconsistencies: sometimes there may be differences between the records you maintained and what the patients reports.
* Make sure that the patients have a legitimate insurance card.
* If your patient claims that he received a notice of an insurance payment for services that were not provided to him. Pay attention to it.
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