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
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Does this apply to you? YES! The FTC ruled that members of the medical team must comply.
The Red Flag Rule
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• 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
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So, let’s get started
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Risk Assessment Checklist
• Your Practice Manager has created a “Risk Assessment Checklist”
• Let’s work through the checklist
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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.
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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.
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Steps to Take
• Don’t leave files on counters where public has access
• Keep file cabinets secured
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More Steps to Take
• Take private information by phone out of public’s earshot
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Computer Access
• Secure client information by
logging in/out before leaving terminal
Protect Your Password!!
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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
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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
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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)
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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
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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
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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
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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
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• 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
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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
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1) Guard personal information collected2) Carefully handle credit cards3) Secure personal checks4) Log in/out of computers5) Guard passwords
Summary
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Now you have completed your training
to help stop identity theft
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Call “Doc Chery”Dr. Chery F. Kendrick
Veterinarian & Regulatory SpecialistKendrick Technical Services
www.KendrickTechServices.com
Questions?
© Chery F. Kendrick & Kendrick Technical Services
Dr. Chery F. KendrickVeterinary Regulatory Specialist
865-405-4255Chery@KendrickTechServices.comwww.KendrickTechServices.com
Kendrick Technical Services
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