John Phalen and Nancy Vickroy on Privacy & Confidentiality – Building a Secure Platform for Growth

*The information contained in this presentation is not intended as and in no way constitutes legal or compliance advice.  Please consult your General Counsel or Compliance Officer.

Healthcare Critical Business Issues

According to a TransUnion webinar asking re; Patient Safety Primary Concern, 12/12/08, n=42, What is your biggest identity theft concern? Medical safety 55%, Uncollectible patient debt 29%, Operational inefficiencies 10%, Patient dissatisfaction 7%

Red Flag Regulations

Proposed by financial regulatory bodies and the FTC
‘Final rule’ addendum to FACT Act, modifies sections 114, 315

    Released on October 16, 2007; applies to:

  • All “users” of consumer reports (address discrepancy requirements)
  • Financial institutions and “creditors” (identity theft prevention program requirements)

Supplement including 26 examples of red flags

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Identity Theft Prevention Program

Identify Red Flags

  • Chose Red Flags that make sense in your environment
  • Identify departments that interact with individuals with covered accounts
  • Determine types of information gathered and how it is verified

Detect Red Flags

  • Develop procedures to detect Red Flags during life of account – pre-registration, registration, financial counseling, billing and collections
  • Implement identity verification at every step
  • Incorporate automated solutions to verify and authenticate identity information such as name, address and SSN

Respond to Red Flags

  • Responses will vary depending on risk of triggered Red Flag
  • Train staff in policies, procedures and responses to ensure consistent patient experience
  • Develop procedures for triggered Red Flag accounts for exception handling

Evaluate the program

  • Periodically evaluate for effectiveness and modify as needed
  • Track down known incidents of identity theft that occurred despite the program and monitor trends
  • Use data to make meaningful modifications over time

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