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.

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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