Red Flag Rules Effective November 1, 2008  
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Red Flag Rules Effective November 1, 2008

www.identitytheftdaily.com

NACHC has received inquiries as to whether the so-called “Red Flag” rules issued by the Federal Trade Commission (FTC) apply to health centers. The Red Flag rules require covered entities to implement anti-identity theft measures. The rules apply to any institution, including a health care provider, that is a “creditor” and maintains “covered accounts” as those terms are defined in the rules. Covered entities must implement an identity theft prevention program by November 1, 2008. This Alert is intended to outline key features of the Red Flag rules. Whether an individual health center is covered by the Red Flag rules depends entirely on its specific billing and collection practices. Accordingly, health centers should review the Red Flag rules to determine if they are covered and, if so, the actions required to comply with them.

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