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Although medical groups are readying themselves to challenge the application of the Federal Trade Commission’s Red Flags Rule to health care providers, the feasibility of such a challenge is not guaranteed. So apart from being required to do so by the FTC, your practice should put into practice a Red Flag compliance program that helps to detect and prevent identity theft as it’s a best practice.

According to Duane Abbey, who recently gave an audio conference, the incremental procedures through which you have to go are not that burdensome. This is in fact an add-on to your already successful compliance program. Here are four things you need to comply with the Red Flags Rule, barring any reprieve:

• First, you need to brush up on 7 compliance principles. These should be familiar to health care providers as they’re based on the soon to be amended US Sentencing Guidelines, which form the basis for all corporate compliance programs at the federal level.

• Second, develop a written plan. With any compliance issue there must be written documentations, policies and procedures.

• Next, you need to train the personnel who have access to covered accounts. These training and education must be provided both initially and then on an on-going basis.

• That apart, you need to develop organizational infrastructure to implement and administer the program. This step may be the most labor-intensive because it’ll be new. Abbey also suggested developing an annual report on activities, problems and changes pertaining to your identity theft program.

Review any past experiences, over the last 5 to 10 years, your facility or practice might have had with identity theft issues. Specifically look at whether you got paid or not, or whether you had to adjust medical records regarding any such issues, he suggested.