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What is FACTA?o WCMC has an identity theft prevention program in accordance with the Federal Trade Commission and the Fair and Accurate Credit Transactions Act (FACTA).o Identity Theft refers to fraud that involves stealing money or getting other benefits by pretending to be someone else.o WCMC promotes integrity in the information collected from their patients and families.o This applies to staff who work with patients and their protected health information ("PHI") for treatment, payment, or operations.
FACTA Red Flagso A Red Flag is a pattern, practice, or specific activity that indicates the possible existence of identity thefto The following are just a few examples among many: • Presentation of suspicious or altered documents • Presentation of a social security number that matches one submitted by another patient or differs from one submitted on a prior visit. • Patient provides information in the medical consultation that is inconsistent with the medical history • Repeated failure or refusal to provide identifying information
Red Flagso Presentation of personal identifying information that is associated with known fraud activityo Inability to verify insurance informationo Family members or friends reveal suspicious information to WCMC staff, such as calling the patient by a different nameo Mail sent to the patient is repeatedly returned as undeliverable despite ongoing transactionso Notices from patients, victims of identity theft, law enforcement, or other persons regarding possible identity theft in connection with patient
Red Flagso All WCMC staff who register/schedule patients will take reasonable action to identify/detect relevant red flags by collecting: • patients name • gender • date of birth • address • identification number from the patient or parent/guardian
Red Flagso WCMC staff will also verify and compare the information provided by the patient or parent/guardian with the information contained in its database to confirm identity.o Identity Authentication: For all patients, new or established, WCMC staff shall verify the identity of the patient or patients parent or guardian, by requesting to view a photo identification of the patient or patients parent or guardian, along with their insurance card, or by other reasonable means.
Red Flagso All WCMC staff members are responsible for notifying their direct supervisor immediately of any circumstance that arises with a patient or patients family that creates doubt or suspicion regarding the integrity and accuracy of the information provided by the patient.o Responses to Red Flags: • Notify the manager or supervisor of the situation who will contact the Compliance Officer or the Administrative Representative on– call. • If the staff member wishes to remain anonymous, he/she may report the incident to the Compliance Hotline at 380-4670
Red Flagso The Compliance Officer will then respond to the detection of a Red Flag by conducting an investigation. The response may include: • Contacting the patient • Notifying law enforcement • Consideration of EMTALA obligation • Correcting the medical record • Correcting the account to ensure accuracy • Changing passwords or security codes • Determining that no action is warranted under the circumstances.