1. R ed F lag R ule Training for the Medical Industry © Chery F. Kendrick & Kendrick Technical Services

2. What is the Red Flag Rule? The Red Flag Rule is a relatively new rule developed by the FTC (Federal Trade Commission) to help prevent identify theft and credit card fraud © Chery F. Kendrick & Kendrick Technical Services

3. Does this apply to you? YES! The FTC ruled that members of the medical team must comply. The Red Flag Rule © Chery F. Kendrick & Kendrick Technical Services

4. It’s not HIPAA- the RFR protects financial information not medical info Specifically for protection of consumers (that would be our clients) from identity theft HIPAA policies can overlap with the RFR in terms of identity protection (such as Social Security Numbers) Isn’t This The HIPAA Rule?? No, this is a cat of different stripes © Chery F. Kendrick & Kendrick Technical Services

5. So, let’s get started © Chery F. Kendrick & Kendrick Technical Services

6. Risk Assessment Checklist Your Practice Manager has created a “Risk Assessment Checklist” Let’s work through the checklist © Chery F. Kendrick & Kendrick Technical Services

7. Potential Red Flags Gathering information on forms that extend credit for veterinary care. Client information for pet health insurance forms. Accepting credit card payments by phone or mail on written-in forms. Accepting credit card payments at the front desk upon checkout. © Chery F. Kendrick & Kendrick Technical Services

8. Potential Red Flags Continued Accepting checks and obtaining personal info, such as SSN and driver’s license number. Forms completed by clients for veterinary service. © Chery F. Kendrick & Kendrick Technical Services

9. Steps to Take Don’t leave files on counters where public has access Keep file cabinets secured © Chery F. Kendrick & Kendrick Technical Services

10. More Steps to Take Take private information by phone out of public’s earshot © Chery F. Kendrick & Kendrick Technical Services

11. Computer Access Secure client information by logging in/out before leaving terminal Protect Your Password!! © Chery F. Kendrick & Kendrick Technical Services

12. Credit Card Safety Match name on credit card to driver’s license or other form of picture ID Hand credit card back directly to the client you received it from Do NOT lay credit cards down on desk or counter © Chery F. Kendrick & Kendrick Technical Services

13. Checks Match name on check to driver’s license or other form of picture ID Immediately secure checks in locked drawer When you are preparing deposit slips do so in private © Chery F. Kendrick & Kendrick Technical Services

14. Beware of what you put in the trash un-shredded. Thieves use contents of trash containers to steal identities. Shred all messages or notes with information about personal records such as addresses, and billing info. Don’t forget electronic media: shred discs, clear out files before disposing of computer. The Importance of Shredding © Chery F. Kendrick & Kendrick Technical Services

15. Inspections Inspections would be conducted by a federal inspector with the FTC Front desk should be trained to follow the same inspection protocol as with any other government inspector Verification of inspector’s identity is rule #1 Verification is made by calling: 877-FTC-HELP (877-382-4357) © Chery F. Kendrick & Kendrick Technical Services

16. Inspection Process Inspectors will want to see the following: Training program and training records RFR Protocol RFR Checklist RFR Vendor notification May interview employees Will give exit briefing © Chery F. Kendrick & Kendrick Technical Services

17. Fines NO inspector collects fines so any mention of money should in itself be a “Red Flag” that this is NOT a legitimate FTC inspector and you should immediately call the FTC Follow up report will be mailed to you summarizing findings and notifying you of any potential fines for missing documents or training © Chery F. Kendrick & Kendrick Technical Services

18. Investigations Red Flags Rule Investigations are separate. They are initiated by consumer fraud complaint which usually involves identity theft Your business may be investigated if the consumer conducted business with you and listed you as potential source of identify theft Investigator will review documents including how you handled that clients personal information © Chery F. Kendrick & Kendrick Technical Services

19. Resolution An investigation is NOT an accusation, But a fact finding process to determine where the identity breach may have occurred If however it is determined that the breach occurred at your practice which allowed the identify theft to occur then you may be held civilly liable Criminal liability is reserved for the actual thief © Chery F. Kendrick & Kendrick Technical Services

20. Remain calm, answer only questions asked Notify practice owner, regulatory consultant and practice attorneys Do Not allow documents to leave the practice Allow the professions (consultants and attorneys) to take over for you Tips for Inspections and Investigations © Chery F. Kendrick & Kendrick Technical Services

21. Likelihood of Inspections It is unlikely there will be inspections however we are still required to have a program in place and train our team The protection of information is critical to all of us Stay calm, know you are trying your best to stay compliant and safeguard vital information © Chery F. Kendrick & Kendrick Technical Services

22. 1) Guard personal information collected 2) Carefully handle credit cards 3) Secure personal checks 4) Log in/out of computers 5) Guard passwords Summary © Chery F. Kendrick & Kendrick Technical Services

23. Now you have completed your training to help stop identity theft © Chery F. Kendrick & Kendrick Technical Services

24. Call “Doc Chery” Dr. Chery F. Kendrick Veterinarian & Regulatory Specialist Kendrick Technical Services 865-405-4255 DocChery@charter.net www.KendrickTechServices.com Questions? © Chery F. Kendrick & Kendrick Technical Services

25. Dr. Chery F. Kendrick Veterinary Regulatory Specialist 865-405-4255 Chery@KendrickTechServices.com www.KendrickTechServices.com Kendrick Technical Services © Chery F. Kendrick & Kendrick Technical Services