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Red Flags Rule

The programs must provide for the identification, detection and response to patterns, practices or specific activities (“red flags”) that could indicate identity theft.

To the surprise of many, the FTC has taken the position that this program also applies to many health care providers, including physicians.

Information is listed below and this page will be updated as the data approaches. Be sure to check back here for current information on the Red Flags Rule.

Rules, Guidance & Summaries

The “Red Flags” Rule: Are You Complying with New Requirements for Fighting Identity Theft?

FTC Article - The “Red Flags” Rule: What Health Care Providers Need to Know About Complying with New Requirements for Fighting Identity Theft

Frequently Asked Questions:
Identity Theft Red Flags and Address Discrepancies

FTC announces extension to the Red Flags rule deadline

Get ready for federal ‘Red Flag Rules’ that take effect May 1 (March 16, 2009)

FTC issues six-month delay for Red Flags rule (November 3, 2008)

FTC requires identity theft compliance program (October 20, 2008)

FTC Business Alert
(June 2008)

Red Flag Rules
(Nov. 9, 2007)

Look for more ISMA Reports articles soon


AMA letter to the FTC (Sept. 30, 2008)

FTC response to the AMA (Feb. 4, 2009)

AMA letter to the FTC (Feb 23, 2009)

AMA: Physicians File Lawsuit on FTC's Red Flags Rule (May 21, 2010)

Compliance Tools

Do-It-Yourself Program for Businesses at Low Risk For Identity Theft

Red Flags rule guide prepared by the FTC

ISMA Teleseminar presented by Krieg DeVault LLP (March 25, 2009) - archived seminar and materials available for purchase here

American Health Lawyers Association Red Flag Compliance for Healthcare Providers: Protecting Ourselves and Our Patients from Identity Theft and Red Flag Rules Resource Guide – available for purchase here

AMA guidance material to help physicians comply with the Red Flags Rule

The following Indianapolis-based law firms have prepared turnkey and sample policies and plans for physicians which are available for purchase:

Baker & Daniels LLP – Contact Meghan Freeman at 317-569-4851

Krieg DeVault LLP – Contact Susan Ziel at 317-238-6244


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