I know, you've heard this one before, but the Red Flags Rule deadline is currently set for August 1. This means you have less than a month to finish putting your plan together. As I have said before, for home health and hospice compliance won't be that difficult. The FTC has even acknowledged that for providers who routinely see their clients, compliance with the Red Flags Rule should be relatively simple. See here. (Note, I said relatively simple, not simple.)
With the deadline approaching, I thought you would appreciate this story. It is a story about the wrinkles that hospitals are discovering as they implement their Red Flags Rule policies and procedures. The story is interesting for two reasons, one the case of a red flag that led the hospital to identify a patient who actually thought he was someone else. The patient was using his cousin's name, not to take advantage of his cousin's insurance, but because he thought he was his cousin. The hospital learned of it when the cousin called to complain about a bill. The point is that this is another example of how a Red Flag might indicate something other than identity theft.
The other interesting point in the article is the discussion of whether a home health agency or other post-acute care provider can assume the hospital has properly identified the patient. In my opinion, you cannot make that assumption. Not surprisingly, the person interviewed in the article drew the same conclusion. They then discuss what options they have for identifying patients.
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