RED FLAG RULES IN HEALTH CARE

Red Flag Rules Leave Health Care Industry Wondering

The health care industry has been waiting for resolution of the question: Do the Federal Trade Commission’s Identity Theft Red Flag Rules apply to health care providers? With the May 1st compliance deadline looming, health care providers need to know. The answer seems to depend on whom you ask. The Federal Trade Commission (“FTC”) and the American Medical Association (“AMA”) have been in discussions regarding this point for the last several months.* Most recently, in a February 4th letter to the AMA, the FTC reiterated its earlier position stating that the Red Flag Rules apply to health care providers who regularly defer payment for medical services. In a February 23rd letter responding to the FTC, the AMA “strongly objected” to the FTC’s interpretation and alleged that the FTC failed to comply with the Administrative Procedures Act (“APA”) since it did not explain in advance its rules’ application to health care providers nor provide the public with notice and opportunity to comment. In summary, the AMA asked the FTC to either withdraw its interpretation or conduct a new rulemaking procedure that complies with the APA.
The Identity Theft Red Flag Rules require covered entities to implement a program to detect and respond appropriately to signs of identity theft. For a health care provider, this would mean, as an example, detecting situations in which a patient may be attempting to obtain medical services using another person’s identity and medical insurance policy. Since the FTC’s position on this issue has been firm, unless and until the AMA obtains a stay on enforcement of the rules, medical care providers should gear up for compliance. According to the FTC, for many providers of medical care, compliance may not be too burdensome since their programs need only be scaled to the level of risk of identity theft faced by their patients. So if the risk is low, the identity theft program can be streamlined commensurate with such risk. As examples, a health care provider could implement a program that includes, among other things:

Checking patients’ photo IDs when medical services are sought
Responding appropriately when notified by a consumer or law enforcement agency that the consumer’s identity has been misused
Isolating suspect medical records from the victim’s medical records
Suspending collection efforts against the medical identity theft victim relating to services provided to the unauthorized individual
(Posted from privacy law blog)

MN HEALTH CARE ASSOCIATIONS

Minnesota Health Care Associations (a partial list)
Life Science Alley: www.lifesciencealley.org
MN Chapter, American College of Healthcare Executives: http://minnesota.ache.org
Minnesota Hospital Association (MHA): www.mnhospitals.org
Minnesota Medical Association (MMA): www.mmaonline.net
Minnesota Medical Group Management Association (MMGMA): www.mmgma.org
Minnesota Organization for Leaders in Nursing (MOLN): www.moln.org
Minnesota Chapter, Healthcare Financial Management Association: www.mnhfma.org
Minnesota Council of Health Plans: www.mnhealthplans.org
Care Providers of MN (Long-term care trade association): www.careproviders.org
Aging Services of MN (formerly Minnesota Health and Housing Alliance): www.mhha.com
Women’s Health Leadership Trust: www.whltrust.org
National Health Care Management Associations (a partial list)
American College of Healthcare Executives (ACHE): www.ache.org
American College of Physician Executive (ACPE): www.acpe.org
American Hospital Association (AHA): www.aha.org
American Medical Group Association (AMGA): www.amga.org
Medical Group Management Association (MGMA): www.mgma.com
Strategic Business Associations with Health Care Membership (a partial list)
The Collaborative: www.collaborative.net
Association for Strategic Planning - Minnesota: www.strategyplus.org/chapters/Minnesota.php
MAP for non-profits: Will match you with volunteer management consultant and/or Board service opportunities in local non-profit organizations: www.mapfornonprofits.org

HEALTH CARE CONSULTING FIRMS

Consulting organizations with health care practices (a partial list): In addition to career information, these organizations’ websites often have insightful research reports and publications regarding the health care industry.

Accenture: http://www.accenture.com/
Deloitte & Touche: http://www.deloitte.com/
Ernst & Young: http://www.ey.com/
Grant Thornton: http://www.grantthornton.com/
KPMG: http://www.us.kpmg.com/
Kurt Salmon Associates (KSA): http://www.kurtsalmon.com/
LarsonAllen: http://www.larsonallen.com/
McKinsey & Company: http://www.mckinsey.com/
Price Waterhouse Coopers: http://www.pwc.com/
RSM McGladrey: http://www.rsmmcgladrey.com/
Stockamp & Associates: http://www.stockamp.com/
VHA: http://www.vha.com/
Wellspring Healthcare: http://www.wellspring-healthcare.com/
Wipfli: http://www.wipfli.com/
Compirion Healthcare Solutions: www.compirion.com

JOB SEARCH TIPS

Job Search Tips Provided at the University of St. Thomas MBA in Health Care Workshop
April 9, 2009

Networking

Over 80% of jobs are secured utilizing a ‘networking’ process
Set up ‘networking groups’

Best ‘network’ is to know someone within the company – to promote your application
Be careful what you put on social networks such as ‘facebook’ – employers look at these networks

“Informational interviews” are good to expand your network – ask for a 15 minute interview
Be honest why you want the informational interview – must be passionate that you want to spend a lifetime in heath care.

Resumes

Resumes are computer scanned – must have key words in resume that uses words in ‘qualifications’ section of job announcement

Customize cover letter to the organization on job with key words (research the diversity of the company)

NEVER state “I don’t have experience.” Use life skills that allow you to transfer to the position – community service, educational goals, volunteer opportunities. HR spends 30 seconds looking at a ‘story’ you need to tell – you must stand out. HR spends 15 seconds reviewing a resume.

Identify top 3 skills; identify ‘significant results;’ identify you are comfortable with change; you are comfortable with new technologies; and believe in data driven processes. You a leader who can assemble quality teams and motivate teams

Track your progress – follow-up every week; track sending thank you notes (HR does remember thank you notes).

Some people create charts for their resume to identify skill level they possess for job qualifications (that will catch attention!).

Equally important, always have a current resume ready; have others review; and create and identify your significant results and your desire for continuous learning.

Persevere – never give up- work 10 minutes longer than your competitor – and you will be successful. Going after a job is very hard work. Be positive, positive, positive.