Red Flag Rule Enforcement Delayed
The Federal Trade Commission (FTC) announced on April 30th that it would - again - delay enforcement of the Red Flag Rules. These rules require creditors - which include ambulance services and other health care providers - to implement an Identify Theft Prevention Program. Though the rules became effective on November 1, 2008, the FTC has now twice delayed enforcement of those rules. The first FTC delay extended the enforcement deadline to May 1, 2009; the second extension, issued on the eve of the enforcement deadline, now extends it again until August 1, 2009. This reprieve gives ambulance services more time to comply with these regulations, including the implementation of written identity theft prevention policies, and to train their staff accordingly.
PWW has published a comprehensive Red Flag Rules Survival Kit. As you've come to expect with all of PWW's publications, this "how to" manual is practical and easy to understand, and contains the model documents you need - in Word format - to quickly and easily implement your own Identity Theft Prevention Program and get into compliance with the Red Flag Rules.
CLICK HERE to go to PWW's Red Flag Rule Resource Page.
OIG Approves Reciprocal Waiver of Copayments
On April 30, 2009 the OIG issued Advisory Opinion 09-03 regarding the practice of municipal ambulance services reciprocally waiving copayments for residents of neighboring jurisdictions. The OIG has already issued multiple, previous Advisory Opinions allowing municipal ambulance providers to waive copayments for residents within their own jurisdictions by treating revenues from local taxes as payment of copayments and deductibles. In the new Advisory Opinion 09-03, the OIG goes one step further and states that it would allow neighboring municipal ambulance providers who cover each others' areas on a backup or "mutual aid" basis to waive cost-sharing obligations of individuals in neighboring jurisdictions under certain circumstances.
CLICK HERE to go to PWW's Compliance Resource Page, where you can obtain more analysis and download a copy of Advisory Opinion 09-03 for review.
