Question What do we need to incorporate into the handbook to comply with the red flag rule?
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Dentist and medical practitioners were successfully removed from the Red Flag Rule legislation.
Update 01/22/11: Note that if your business accepts Credit Cards or creates payment plans that it is still a very good idea to train your employees on identity theft. Teaching them to red flag instances where they suspect theft or fraudulent use of a credit card is still a good idea. As the employer you are still responsible for verifying who is giving you payment.
This is a rather stupid, yet harmless rule that currently is NOT being enforced by the Federal Trade Commission against physicians/dentists. It is officially “on hold” until December 31, 2010, to allow Congress to address certain amendments to the rule which may include an exclusion of physicians/dentists with 20 or less employees. I know you are all getting lots of sales stuff and compliance program offers. I do believe that you will need to address the red flag rule on some level once legislation is complete, but at this time, it is a non issue. Read more on the redflags on FTC’s own webpage.
Note: If you are a member of The ADA, they also has a pretty good sample policy you can implement for free.
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This information is Human Resource Guidance and is not intended to be legal advice