Red Flags No Longer Applicable to Healthcare Practices
Passed in the House and Senate and awaiting signature by the President, the Red Flag Program Clarification Act of 2010 limits the definition of “creditor” to include only those that use consumer reports, furnish information to consumer reporting agencies or advance funds to a person. Importantly, the definition does not include one who advances funds for expenses incidental to a service. Thus, health care providers and entities are no longer required to comply with the Red Flags Rule mandate of adopting identity theft programs.
For more information, please contact Abby Pendleton, Esq. and Jessica L. Gustafson, Esq. at (248) 996-8510 or (212) 734-0128 or visit the Compliance specialty page on the HLP website.