Many healthcare organizations are not aware that they will come under Federal Trade Commission (FTC) authority as a result of identity theft rules that were once thought to only apply financial institutions and other lenders.
The so-called “Red Flag” rules require any organization – including non-profits and government agencies not traditionally subject to FTC jurisdiction -- that does not require payment at the time it provides service to establish and maintain a program to spot and address possible ID theft.
This interpretation by the FTC has surprised healthcare organizations and many others, who thought that the regulations under the Fair and Accurate Credit Transactions Act -- a law aimed at financial institutions, credit reporting agencies and others who provide financing for products or services – did not apply to healthcare providers.
In recent weeks, the FTC has signaled that the law’s requirements now apply to anyone business or organization that that does not get paid in full in advance or at the time of a purchase or service.
That means most healthcare organizations as well as nonprofits and government agencies are subject to the requirements.
With a Nov. 1 deadline to have a compliance plan in place, healthcare organizations must take action now.
To assist healthcare organizations meet these new mandates, Melamedia, LLC, publishers of Health Information Privacy/Security Alert sponsored: Healthcare Compliance with the FTC Red Flag Rules Participants are briefed on
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WHO SHOULD LISTEN |
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THE FACULTY |
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Robert Gellman, JD, a is privacy and information policy consultant in Washington, DC, and co-author of Red Flag and Address Discrepancy Requirements: Suggestions for Health Care Providers, produced by the World Privacy Forum. He served as a member of the National Committee on Vital and Health Statistics (NCVHS) from 1996-200. From 1977 to 1994, he served as a staff member and Chief Counsel of the House Government Operations’ Subcommittee on Information, where he was responsible for the panel’s information policy activities, hearings, oversight, legislation, and reports on general privacy matters, Freedom of Information Act, Privacy Act of 1974, health privacy, collection and dissemination of electronic data and security classification.
Gerald “Jud” DeLoss, JD is vice chair of the American Health Lawyers Association’s Health Information & Technology Practice Group and a principal at Gray Plant Mooty, where his practice focuses on representing medical providers in Health Information Technology (HIT), HIPAA, medical staff credentialing, fraud and abuse, transactions, and regulatory compliance |
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CONTINUING EDUCATION CREDITS |
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CD ORDERING |
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Download the form at
www.melamedia.com/10_30_order.form.pdf |
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| TRACK HIPAA ENFORCEMENT FOR FREE | |||||||
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Health Information
Privacy/Security Alert offers
free updates on HHS's efforts to enforce the HIPAA privacy and security
regulations. The statistics include privacy complaints lodged with the
Office for Civil Rights and security and transaction complaints lodged
with CMS Office for Electronic Health Standards and Services. CLICK HERE To receive the HIPAA Enforcement Statistics Update Service |
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