Policies and Procedures to Identify Possible Identity Theft

GASTROENTEROLOGY CONSULTANTS-REGIONAL SURGICENTER-VALLEY ANESTHESIA, LLC-VALLEY LABORATORIES, LLC-MIDWEST CLINCICAL RESEARCH

• The following policies and procedures, if adopted by your practice, may help protect your patients by minimizing the potential of identity theft:
• As a “creditor” under the Fair and Accurate Credit Transactions Act of 2003 (FACT ACT), our practice will conduct and annual risk assessment to ensure the practice activities are conduced in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of identity theft in connection with the opening of a covered account or any existing account.
• Upon scheduling an appointment on the telephone, patients will be advised to bring both their insurance card and government issued picture ID to be copied when they come in for their appointment.
• To verify the identity of new patients, the practice will request and copy the patient’s insurance card and government identification card with picture upon check in. The copy of the patient’s ID will be kept in the patient’s record.
• To verify the identity of existing patients, the practice will compare the likeness of the patient that is kept in the medical record with the patient when they check in.
• Telephone or written requests for changes in a patient’s address will be verified by calling the existing phone number on file and requesting the verification of the number on the patient’s government ID.
• If there is a discrepancy between the patient that presents for services and the likeness of the patient in the medical record, the practice will notify the local law enforcement agency immediately.
• Under no circumstances will the personal patient information be given to anyone over the phone or in writing without the explicit permission from the patient whose identity has been verified.
• Any warning from the consumer reporting agencies, suspicious documents, suspicious personal information or notice from the patient they have experienced identity theft will be disseminated to the staff and flagged in the patients chart.
• The practice policies related to identity theft will be reviewed and updated at least annually, or more often as needed, to address any changes in risk.
• The management and oversight of the program to identify possible identity theft will be the responsibility of the practice manager/ administrator.
• New employee orientation will include instruction on the practice policies and procedures on identifying and reporting potential identity theft.
• The practice will conduct annual training sessions for all physicians and staff on government policies affecting the practice, including identifying and reporting potential identity theft.

To inform patients of our efforts to minimize the potential of identity theft, the practice will post the following sign in the reception areas:
TO OUR PATIENTS:
In accordance with the Federal Trade Commission requirements, effective May 1, 2009, our practice complies with the RED FLAG RULE that is intended to PROTECT YOU AGAINST IDENTITY THEFT.
We are required to ask our patients to prove their identity by showing a photo ID and by answering certain questions that only you or a family member would know when contact us by phone. We appreciate your cooperation with our efforts to protect your identity and comply with the federal regulations.