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Red Flag Compliance for Medical PracticesJune 9, 2009
Our goals today
Our goals today
‣ To give you the WHAT…
Our goals today
‣ To give you the WHAT…
‣ The FTC’s Red Flag Rules
Our goals today
‣ To give you the WHAT…
‣ The FTC’s Red Flag Rules
‣ ...review the HOW…
Our goals today
‣ To give you the WHAT…
‣ The FTC’s Red Flag Rules
‣ ...review the HOW…
‣ demo the idBUSINESS Red Flag Compliance Module
Our goals today
‣ To give you the WHAT…
‣ The FTC’s Red Flag Rules
‣ ...review the HOW…
‣ demo the idBUSINESS Red Flag Compliance Module
‣ but also give you the WHY
Our goals today
‣ To give you the WHAT…
‣ The FTC’s Red Flag Rules
‣ ...review the HOW…
‣ demo the idBUSINESS Red Flag Compliance Module
‣ but also give you the WHY
‣ Why information security should be a part of your practice
An issue of PATIENT CARE
“The possibility for medical identity theft gives rises to a duty to monitor for the
potential that patients may be victims. The prudent provider will also monitor employee
and vendor access to patient data.”
- World Privacy Forum, 9/24/08
What this means
What this means
‣ Medical identity theft is on the rise
‣ Costs $192 per record to restore
‣ Often an inside job
‣ Organized crime is involved
What this means
‣ Medical identity theft is on the rise
‣ Costs $192 per record to restore
‣ Often an inside job
‣ Organized crime is involved
‣ Doctor’s offices are unique
‣ Reliance on office manager to run operations
‣ No line between your brand and your name
The Opportunity
‣ There is a unique opportunity to grow a practice by leveraging strong information security policy and sharing it with patients
‣ Build trust with patients
‣ Strengthen employee relationships
‣ Tighten operations with vendors
The facts
• Since 2/15/05, over 251,000,000 Americans have had identities or other personal information compromised
40%
60%
Business has suffered breachBusiness has yet to incur a breach
30%
70%
Thief is employee or knows employeeThief is unknown
The facts
The average breach and its impact on customer confidence is growing.
Source: Ponemon Institute, 2008.
58% of customers willlose confidence in your business after a breach.
31% of your customers will immediately cease doing business with you following a breach.
The Red Flag Rules
The Red Flag Rules
‣ Sections 114 & 315 of the Fair and Accurate Credit Transactions Act
The Red Flag Rules
‣ Sections 114 & 315 of the Fair and Accurate Credit Transactions Act
‣ Applies to you if:
The Red Flag Rules
‣ Sections 114 & 315 of the Fair and Accurate Credit Transactions Act
‣ Applies to you if:
‣ you hold “covered accounts”
The Red Flag Rules
‣ Sections 114 & 315 of the Fair and Accurate Credit Transactions Act
‣ Applies to you if:
‣ you hold “covered accounts”
‣ your customer records present a “reasonably foreseeable risk of identity theft”
Why are physiciansCOVERED ENTITIES?‣ Accepting insurance
‣ Deferral of 100% of payment, you collect enough patient data to collect the remainder that insurance does not pay.
‣ Reasonably foreseeable risk
‣ Your patient files are a treasure trove
‣ Each record worth between $80-300 each*
* Source: Black Market Identity Auction attended by Net Reaction mole, 2008.
Red Flag REQUIREMENTS
Red Flag REQUIREMENTS1. A Written Information Security Program
Red Flag REQUIREMENTS1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with identity theft
Red Flag REQUIREMENTS1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with identity theft
3. Must be administered by a board of directors or a member of senior management
Red Flag REQUIREMENTS1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with identity theft
3. Must be administered by a board of directors or a member of senior management
4. Must deliver compliance report on at least an annual basis
Red Flag REQUIREMENTS1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with identity theft
3. Must be administered by a board of directors or a member of senior management
4. Must deliver compliance report on at least an annual basis
5. Must contain mechanism to train employees
Red Flag REQUIREMENTS1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with identity theft
3. Must be administered by a board of directors or a member of senior management
4. Must deliver compliance report on at least an annual basis
5. Must contain mechanism to train employees
6. Must contain an incident response capability
Red Flag REQUIREMENTS1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with identity theft
3. Must be administered by a board of directors or a member of senior management
4. Must deliver compliance report on at least an annual basis
5. Must contain mechanism to train employees
6. Must contain an incident response capability7. Must ensure that vendors and suppliers are also compliant
“What happens if I don’t comply?”• Noncompliance carries several penalties
– Civil Liability
– Class-Action Lawsuits
– Federal Fines
– State Fines
The solution
‣ The idBUSINESS Red Flag Compliance Module‣ Built on real-world forensic fieldwork‣ Includes tools & benefits that actively involve
employees in your compliance efforts
‣ Transitions information security from a compliance issue into a competitive advantage
The Red Flag Compliance Module
‣ Secure online interface
The Red Flag Compliance Module
‣ Learning tools available as text or video webinar
The Red Flag Compliance Module
‣ Risk Assessment tool provides ranking of your company in 12 key focus areas
The Red Flag Compliance Module
‣ Customizable checklist of 26 Red Flags to meet requirements of FACT Act
The Red Flag Compliance Module
‣ Employee training automated & easy, integrates automatically with your compliance report
The Red Flag Compliance Module
‣ Ability to evaluate supplier compliance practices using our proprietary Vendor Integrity Assessment
The Red Flag Compliance Module
‣ Access individual identity recovery protection using FraudStop and Restore from ID Experts
‣ Available as employee benefit, cafeteria-style add-on, customer blanket, or new revenue stream
‣ In the event of a breach, one-click access to best-in-breed data breach services and forensic services
“Can’t I do this myself?”
• A self-written policy meets the letter of the law, but leaves gaps:
– No vendor integrity assessment
– No employee training, just signature line
– No mitigation of damages in the event of an incident• Who will you call when you have a question?
• No context of how Red Flag Policy fits into your business
–What’s worth doing is worth doing right.
–Missing an opportunity to GROW your practice
So I’m compliant...
‣ NOW WHAT?
‣ Don’t let it sit on a shelf
‣ Talk to your employees
‣ Talk to your patients
‣ Use your policy as a practice-building tool
A final word‣ “I understand the mindset of other practices, and that it is easy to minimize identity
theft as a business threat or a patient care issue. It is low on their list of priorities, which
is unfortunate because if and when a patient data breach occurs, we are by law
responsible. I personally would recommend acting with a sense of urgency to become
compliant with the FTC ‘Red Flag Rules’ both to avoid penalty and to protect your
patients from a life-wrenching identity theft experience. You’ll be protecting yourself as
well, and as a result, will sleep better at night.”
Dr. Miles Collett, DDS
Thank you!
‣ To learn more, please visit idBUSINESS.com
‣ Discounts are available for medical associations
‣ Check with your association or call idBUSINESS Distributor Joe Nollet, 951-928-4438
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