Comments on: When Red Flags Rise

By: M. Feist

M. Feist — Tue, 18 Aug 2009 21:26:39 +0000

Since the OCC, Federal Reserve Board, FDIC, OTS, NCUA and Federal Trade Commission passed the RED FLAG Rule January 1, 2008 I find it interesting that President Obama is the blame for this.

By: Wayne Warriner DVM

Wayne Warriner DVM — Wed, 29 Apr 2009 03:11:01 +0000

I concur with Noel (comment #3) No way do I have time to spend an hour in the middle of the work day for something that commenter #1 apparently thought was less than useful. If it was anywhere nearly as confusing as the FTC web pages, I sympathize. Wake up AVMA!
This all looks like another make work Obama “stimulus” “shovel ready” make the bureaucracy bigger and more intrusive program to me. Since we don’t take photo ID’s or social security numbers from our “creditors” and they can’t steal our identity from our monthly statements the only place in our business that I can see anybody possibly stealing identity is if we had a dishonest employee who copied down credit card numbers or checking account numbers and tried to do something with that, but since “cash or credit card only” businesses are exempt from the “Red Flag” that is a non-sequiter as the same opportunity would exist in a cash business as in a ceditor business.
Just more government bull crap.

By: AVMA@Work

AVMA@Work — Tue, 28 Apr 2009 12:57:35 +0000

The AVMA identity theft information page does link to the FTC’s general guidance for health care providers at http://www.ftc.gov/bcp/edu/pubs/articles/art11.shtm. The rule requires a practice or business to assess the type of information it receives, steps it can take to mitigate risk, and training of staff. That analysis varies so greatly from practice to practice that it’s difficult to come up with one set of uniform guidelines that are more specific than the FTC guidance. Nevertheless, we are continuing to search for useful material that we can share with members.

By: AVMA@Work

AVMA@Work — Tue, 28 Apr 2009 12:38:47 +0000

We appreciate your feedback about the identity theft webinar you attended on April 22nd. We are disappointed that you did not find the program beneficial. The presenter has asked for feedback to help him improve the presentation, and I will share your concerns with him.

The webinar was designed to provide background and general information for veterinarians who don’t have knowledge of this rule and its application. We can see how individuals who have studied the FTC materials and have more familiarity with the topic would not find it as useful as other attendees. By the way, the online programs can be purchased separately without attending any of the webinars.

As the May 1st date approached for implementation of this rule, we conducted an environmental scan but were unable to identify guidance specifically tailored for veterinarians. This particular consultant, who has considerable identity theft credentials and who works closely with the Florida VMA, offered to customize training for veterinarians at a reasonable cost.

Let me be clear — the AVMA is receiving no financial consideration from this arrangement. Our goal is simply to provide veterinary practices with some training options since it would appear that many members will be impacted.

There are certainly other attorneys and consultants who can provide advice to veterinarians in this area.

Another option is to review the FTC information and create your own ID theft program by identifying the private info that comes into the practice and what steps can be taken to mitigate the risk. Be sure to document these polices, train your staff and ask your vendors to protect the information you send to them.

Meanwhile, we continue to try to provide as much guidance as we can to veterinary practices dealing with the Red Flags Rule and are making updates to our Red Flags Rule page at http://www.avma.org/issues/FTC_red_flags_rule.asp whenever we have new information.

Again, thank you for giving us your input.

Adrian Hochstadt, JD
Asst. Dir., State Legislative and Regulatory Affairs, AVMA

By: David S. Rosene, DVM

David S. Rosene, DVM — Sat, 25 Apr 2009 12:24:18 +0000

We attended the webinar on April 22, and found it to be virtually useless. Instead of providing us with guidelines on how to implement a Red Flag compliance program, the presentation was mainly a rehashing of material available in the material from the federal government. The webinar ended with an offer of “only $199″ per veterinary clinic to provide “how to” information on putting a program into place in our practice. In other words, the webinar was basically an infomercial for the company making the presentation. It would have been truly valuable too the membership to provide actual guidance for implementation in a timely fashion, rather than wasting valuable time listening to an extended sales pitch. Hopefully the AVMA can find someone to meet our needs in this area ASAP and develop a more useful nuts and bolts presentation. Thank you.

By: Noel Heacock, DVM

Noel Heacock, DVM — Sat, 25 Apr 2009 10:03:09 +0000

With the new “Red Flag Rule” regulation put out by the FTC regarding Identity Theft – being enforced May 9th, 2009.
My comments:
1- We (I) do not give private credit to our clients (we are not creditors or a bank)
2- We (I) are a pay for service same day service is given business
3- Pay by cash, credit card, or check only.
4- Even though the FTC states creditors that extend credit and exclude those businesses that are pay for service the day service is given…. they will have a way to control our life any way so we (each individual business) is supposed to develop our own “identity theft prevention manual” to show how “we” are protecting the public from identity theft. You know “make it impossible to function as a business rule”.
5- We are not stupid and make every effort not to give out personal information to anyone not entitled to it, but now with the “big hand over our head” makes one not want to speak to anyone or provide information to anyone without an attorney present. The “let’s make it impossible to communicate and function rule”, which can actually be life threatening if you need information fast to save a life and can’t get it because another veterinarian won’t release information without a “consent form” being signed by the owner(s), guardians, friends dog left in the house when she/he left, etc. etc.
6- Now the AVMA want to help, sending me a letter stating I can get the information from a Webinar on April 28 and 30th in an hour presentation during the busiest time of my productive day at the busiest time of the year when I am supposed to effectively “close” and pay for a program which will help me develop a “personalized business manual” to show the government how I plan to protect my clients privacy.

Why not just provide general guidlelines info sheet we can copy and paste on one page to help us comply ?