Health Care Providers: Don't Miss the Red Flags [August 2008]

By Rebecca L. Williams RN, JD and Brent R. Eller

The Federal Trade Commission (FTC) recently issued a reminder of the upcoming Nov. 1, 2008, compliance deadline for implementing identity theft prevention programs pursuant to the identity theft red flag rules (“Red Flag Rules”).

Many health care providers have been unaware of the Red Flag Rules or have been uncertain of the applicability of these requirements. Providers in general should be aware of the Red Flag Rules, should revisit their existing privacy and security compliance programs to ensure that the requirements of the Red Flag Rules have been addressed, and should take other actions to bring themselves into compliance with applicable requirements. It would be prudent for those health care providers that have not done so already to seek legal advice with respect to applicability and appropriate compliance with the Red Flag Rules.

Ongoing Obligations Regarding Risk Analysis and Risk Management under the HIPAA Security Rule [Apr. 2008]

By Rachel E. Dobrow Stone, and Rebecca L. Williams

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