"The Federal Trade Commission has declared that on May 1, 2009, businesses, including dental offices, are to begin complying with the "Red Flags Rule" contained in new federal regulations designed to deter identity theft.

To prepare our Members for these potentially onerous regulations, the ADA has created a compliance guide for the Rule, including sample policies and procedures for identify theft detection and response. The Guide provides a step-by-step plan to help you prepare and implement the requirements of the Rule. The sample policy and procedures that are included with it can save your dental practice many hours, as well as the legal fees that would probably otherwise be necessary to meet the FTC requirements."

The ADA estimates that compliance may cost up to $600 per office.  You may not be effected if you have all patients pay in full at time of treatment. Care Credit type programs would not count.

Here are the FREE forms to get compliant:
Sample Identity Theft Detection and Response Policy (DOC)
Guide for Compliance with the New Red Flags Rule (PDF)