The FTC has now delayed the enforcement date of the Red Flags Rule until December 31, 2010 while Congress considers legislation that would affect the scope of entities covered by the Rule.
The FTC suspended enforcement of the Red Flags Rule to give covered entities time to establish appropriate policies and procedures for dealing with the problem of identity theft. Because hospitals provide services to patients and regularly permit them to pay over time or to make multiple payments or transactions through an established account, it is presumed that health care entities will be considered a “creditor” that maintains “covered accounts” under the FTC's interpretations.
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