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Red Flag Compliance for Medical Practices June 9, 2009

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In this presentation, we'll learn more about the Red Flag Rules, and how Red Flag Compliance can be a worthwhile first step toward information security that can benefit a medical practice.

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Page 1: idBUSINESS for Physicians

Red Flag Compliance for Medical PracticesJune 9, 2009

Page 2: idBUSINESS for Physicians

Our goals today

Page 3: idBUSINESS for Physicians

Our goals today

‣ To give you the WHAT…

Page 4: idBUSINESS for Physicians

Our goals today

‣ To give you the WHAT…

‣ The FTC’s Red Flag Rules

Page 5: idBUSINESS for Physicians

Our goals today

‣ To give you the WHAT…

‣ The FTC’s Red Flag Rules

‣ ...review the HOW…

Page 6: idBUSINESS for Physicians

Our goals today

‣ To give you the WHAT…

‣ The FTC’s Red Flag Rules

‣ ...review the HOW…

‣ demo the idBUSINESS Red Flag Compliance Module

Page 7: idBUSINESS for Physicians

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

Page 8: idBUSINESS for Physicians

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

Page 9: idBUSINESS for Physicians

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

Page 10: idBUSINESS for Physicians

What this means

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What this means

‣ Medical identity theft is on the rise

‣ Costs $192 per record to restore

‣ Often an inside job

‣ Organized crime is involved

Page 12: idBUSINESS for Physicians

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

Page 13: idBUSINESS for Physicians

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

Page 14: idBUSINESS for Physicians

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

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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.

Page 16: idBUSINESS for Physicians

The Red Flag Rules

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The Red Flag Rules

‣ Sections 114 & 315 of the Fair and Accurate Credit Transactions Act

Page 18: idBUSINESS for Physicians

The Red Flag Rules

‣ Sections 114 & 315 of the Fair and Accurate Credit Transactions Act

‣ Applies to you if:

Page 19: idBUSINESS for Physicians

The Red Flag Rules

‣ Sections 114 & 315 of the Fair and Accurate Credit Transactions Act

‣ Applies to you if:

‣ you hold “covered accounts”

Page 20: idBUSINESS for Physicians

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”

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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.

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Red Flag REQUIREMENTS

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Red Flag REQUIREMENTS1. A Written Information Security Program

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Red Flag REQUIREMENTS1. A Written Information Security Program

2. Controls to prevent and mitigate the risks associated with identity theft

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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

Page 26: idBUSINESS for Physicians

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

Page 27: idBUSINESS for Physicians

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

Page 28: idBUSINESS for Physicians

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

Page 29: idBUSINESS for Physicians

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

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“What happens if I don’t comply?”• Noncompliance carries several penalties

– Civil Liability

– Class-Action Lawsuits

– Federal Fines

– State Fines

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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

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The Red Flag Compliance Module

‣ Secure online interface

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The Red Flag Compliance Module

‣ Learning tools available as text or video webinar

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The Red Flag Compliance Module

‣ Risk Assessment tool provides ranking of your company in 12 key focus areas

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The Red Flag Compliance Module

‣ Customizable checklist of 26 Red Flags to meet requirements of FACT Act

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The Red Flag Compliance Module

‣ Employee training automated & easy, integrates automatically with your compliance report

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The Red Flag Compliance Module

‣ Ability to evaluate supplier compliance practices using our proprietary Vendor Integrity Assessment

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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

Page 39: idBUSINESS for Physicians

“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

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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

Page 41: idBUSINESS for Physicians

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

Page 42: idBUSINESS for Physicians

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