R ed F lag R ule Training for the Medical Industry © Chery F. Kendrick & Kendrick Technical Services

Red Flag Rule Training for the

Medical Industry

© Chery F. Kendrick & Kendrick Technical Services

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


Does this apply to you? YES! The FTC ruled that members of the medical team must comply.

The Red Flag Rule


• It’s not HIPAA- the RFR protects financial information not medical info

• Specifically for protection of consumers (that would be our clients) 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


So, let’s get started


Risk Assessment Checklist

• Your Practice Manager has created a “Risk Assessment Checklist”

• Let’s work through the checklist


Potential Red Flags

• Gathering information on forms that extend credit for veterinary care.

• Client information for pet health insurance forms.

• Accepting credit card payments by phone or mail on written-in forms.

• Accepting credit card payments at the front desk upon checkout.


Potential Red Flags Continued

• Accepting checks and obtaining personal info, such as SSN and driver’s license number.

• Forms completed by clients for veterinary service.


Steps to Take

• Don’t leave files on counters where public has access

• Keep file cabinets secured


More Steps to Take

• Take private information by phone out of public’s earshot


Computer Access

• Secure client information by

logging in/out before leaving terminal

Protect Your Password!!


Credit Card Safety

• Match name on credit card to driver’s license or other form of picture ID

• Hand credit card back directly to the client you received it from

• Do NOT lay credit cards down on desk or counter


Checks

• Match name on check to driver’s license or other form of picture ID

• Immediately secure checks in locked drawer

• When you are preparing deposit slips

do so in private© 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


Inspections

• Inspections would be conducted by a federal inspector with the FTC

• Front desk should be trained to follow the same inspection protocol as with any other government inspector

• Verification of inspector’s identity is rule #1• Verification is made by calling: 877-FTC-HELP

(877-382-4357)


Inspection Process

• Inspectors will want to see the following:• Training program and training records • RFR Protocol• RFR Checklist• RFR Vendor notification • May interview employees• Will give exit briefing


Fines

• NO inspector collects fines so any mention of money should in itself be a “Red Flag” that this is NOT a legitimate FTC inspector and you should immediately call the FTC

• Follow up report will be mailed to you summarizing findings and notifying you of any potential fines for missing documents or training


Investigations

• Red Flags Rule Investigations are separate. • They are initiated by consumer fraud complaint

which usually involves identity theft• Your business may be investigated if the

consumer conducted business with you and listed you as potential source of identify theft

• Investigator will review documents including how you handled that clients personal information


Resolution

• An investigation is NOT an accusation, But a fact finding process to determine where the identity breach may have occurred

• If however it is determined that the breach occurred at your practice which allowed the identify theft to occur then you may be held civilly liable

• Criminal liability is reserved for the actual thief


• Remain calm, answer only questions asked• Notify practice owner, regulatory consultant

and practice attorneys • Do Not allow documents to leave the practice• Allow the professions (consultants and

attorneys) to take over for you

Tips for Inspections and Investigations


Likelihood of Inspections

• It is unlikely there will be inspections however we are still required to have a program in place and train our team

• The protection of information is critical to all of us

• Stay calm, know you are trying your best to stay compliant and safeguard vital information


1) Guard personal information collected2) Carefully handle credit cards3) Secure personal checks4) Log in/out of computers5) Guard passwords

Summary


Now you have completed your training

to help stop identity theft


Call “Doc Chery”Dr. Chery F. Kendrick

Veterinarian & Regulatory SpecialistKendrick Technical Services

[email protected]

www.KendrickTechServices.com

Questions?


mailto:[email protected]

http://www.kendricktechservices.com/

Dr. Chery F. KendrickVeterinary Regulatory Specialist

865-405-4255Chery@KendrickTechServices.comwww.KendrickTechServices.com

Kendrick Technical Services


mailto:[email protected]

http://www.kendricktechservices.com/

Documents

R ed F lag R ule Training for the Medical Industry © Chery F. Kendrick & Kendrick Technical Services