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Health Care Providers and the Red Flag Regulations |
August 15, 2009
Previously published by Health Care Law Note (Smith Moore Leatherwood) on October 2008
On the surface, the Red Flag regulations appear to be unrelated to the health care industry. It is widely recognized, however, that health care providers likely fall within the regulations¿ broad definition of ¿creditor¿ and have patient accounts that would fall within the broad scope of ¿covered accounts.¿ A health care provider is a ¿creditor¿ under the Red Flag regulations if it ¿regularly extends, renews, or continues credit¿ or arranges for
the same, and ¿credit¿ simply means any deferral of payment. A ¿covered account¿ means any account made ¿primarily for personal, family, or household purposes that involves or is designed to permit multiple payments or transactions¿ and ¿any other account . . . for which there is a reasonably foreseeable risk . . . from identity theft.¿
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The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance. |
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