FTC delays enforcement of the Red Flags Rules until August 1, 2009


The Federal Trade Commission (“FTC”) has delayed the enforcement date of the Red Flags Rules until August 1, 2009.

Last summer, the FTC announced that it would consider health care providers to be creditors when they accept insurance and bill patients after services are provided for any amounts that insurance does not pay; or if the health care providers regularly allow patients to set up payment plans after services have been performed. The FTC originally planned to begin enforcement of the Red Flag Rules on November 1, 2008, but due to concerns expressed by MGMA and others in the health care industry, the enforcement date was postponed until May 1, 2009.

As a result of continued advocacy efforts, the FTC announced on April 30, 2009, it will further delay enforcement until August 1, 2009 in order to give creditors and financial institutions additional time to develop and implement written identity theft prevention programs. The FTC also announced that it will soon release a template to assist entities with a low risk of identity theft in complying with the Red Flag Rules.


© 2009 Parsonage Vandenack Williams LLC

  For more information, contact info@pvwlaw.com

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