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Red Flag Rule Training for the Medical Practice
Management Team
© Chery F. Kendrick & Kendrick Technical Services
What Is The Red Flag Rule?How Does It Apply to the Medical Practice?Now What Do We Do?
Presented by:Dr. Chery F. Kendrick
Kendrick Technical Serviceswww.DocChery.com
865-405-4255
© Chery F. Kendrick & Kendrick Technical Services
Define the Red Flag Rule Identify who must comply and why Identify risks for and ways to prevent,
detect or minimize the effects of identity theft
Discuss a compliance program to address risks and respond to flags
This Presentation Will:
© Chery F. Kendrick & Kendrick Technical Services
Identifies Risk Factors Discusses Protective Measures Discusses Fraud Alerts Presents Simplified RFR Form Packages
© Chery F. Kendrick & Kendrick Technical Services
How Does It Do That?
What is the Red Flag Rule?
The Red Flag Rule is a relatively new rule developed by the FTC (Federal Trade Commission) to help prevent identify theft and credit card fraud
© Chery F. Kendrick & Kendrick Technical Services
Could this apply to you? YES!The FTC ruled medical practitioners must comply
The Red Flag Rule
© Chery F. Kendrick & Kendrick Technical Services
If you are cash only …
… and all patients pay in full at time of service, you likely will not have any Red Flag Rule issues.
However , if you extend credit, bill patients, set up payment plans, or file insurance claims the RFR does apply to your practice.
© Chery F. Kendrick & Kendrick Technical Services
We are considered creditors when we allow patients to pay over time or accept credit applications on their behalf, for example, through CareCredit or through their insurance.
Thus, we must have a program to address the risk of identity theft, and train employees.
Applicability to the Medical Practice
© Chery F. Kendrick & Kendrick Technical Services
It’s not HIPAA- the RFR protects financial information not medical info
Specifically for protection of consumers (that would be our patients) from identity theft
HIPAA policies can overlap with the RFR in terms of identity protection (such as Social Security Numbers)
Isn’t This The HIPAA Rule??No, this is a cat of different stripes
© Chery F. Kendrick & Kendrick Technical Services
So, let’s get started
© Chery F. Kendrick & Kendrick Technical Services
How? What? Who? Designate a Privacy Officer, (for example, your Safety
Officer or Practice Manager) Determine potential risks in
your front office, billing and record keeping procedures (use checklist)
Have a written protocol on file
(use RFR policy)
© Chery F. Kendrick & Kendrick Technical Services
Protecting the practice and its patient’s information is everyone’s concern from the front desk to the exam rooms to treatment areas and labs. All areas ,all personnel need to be made aware.
The Red Flag Rule also requires that we notify all suppliers, tech support,
cleaning crew, et al that their adherence to the Red Flag Rule compliance program is required
Get everyone involved
© Chery F. Kendrick & Kendrick Technical Services
That’s where I come in
◦ As a regulatory specialist I understand your time constraints and “one more government regulation” to follow
◦ I have developed the tools you need◦ RFR policy◦ RFR Checklist◦ RFR Training Programs◦ It’s that simple
This could get overwhelming
© Chery F. Kendrick & Kendrick Technical Services
Go over the risk assessment checklist (next slide)
Read the RFR policy Set up training for management
and all employees Send notification to vendors and
suppliers Review policy and training
annually
How do we proceed?
© Chery F. Kendrick & Kendrick Technical Services
Risk Assessment Checklist
Has the clinic ever had a case of identity theft?
How do you protect patient’s personal information when transmitting payments or dealing with outside service providers such as insurance companies or pharmacies?
© Chery F. Kendrick & Kendrick Technical Services
Potential cracks in protection
New Patient forms – what personal information do you collect?
DL#? SS#? Credit Card#?
When a patient calls for refill of meds, how is that billed? Account info accessed? How is file and info protected?
Secondary vendors: what information do they receive about patient?
Do vendors have own RFR protocol?© Chery F. Kendrick & Kendrick Technical Services
Clinic Training
All employees should be trained on the RFR compliance policy
As with all training there should be an annual review
New employees should have RFR training
© Chery F. Kendrick & Kendrick Technical Services
Don’t Forget Staff Protection
Employee recordsSSNMedical informationChecking acct info for direct depositsPayroll information
Clinic Information Medical license numbers Credit card numbers Bank records
© Chery F. Kendrick & Kendrick Technical Services
Beware of what you put in the trash un-shredded. Thieves use contents of trash containers to steal identities.
Shred all messages or notes with information about personal records such as addresses, and billing info.
Don’t forget electronic media: shred discs , clear out files before disposing of computer.
The Importance of Shredding
© Chery F. Kendrick & Kendrick Technical Services
Now you have a plan in place to stop identity theft
© Chery F. Kendrick & Kendrick Technical Services
On completing your Red Flag Rule training Main Points: 1) Guard personal information collected 2) Be careful with credit applications 3) Be vigilant and report suspicious activity 4) Review Red Flag Rule Protocol 5) Train new employees on Red Flag Rule
Congratulations!
© Chery F. Kendrick & Kendrick Technical Services
Call “Doc Chery”Dr. Chery F. Kendrick Regulatory Specialist
Kendrick Technical Services865-405-4255
DocChery@charter.netwww.KendrickTechServices.com
Questions?
© Chery F. Kendrick & Kendrick Technical Services
Dr. Chery F. Kendrick Regulatory Specialist
865-405-4255Chery@KendrickTechServices.com
www.KendrickTechServices.com
Kendrick Technical Services
© Chery F. Kendrick & Kendrick Technical Services
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