2. 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.
3. FACTA Red Flags
o A Red Flag is a pattern, practice, or specific activity that
indicates the possible existence of identity theft
o 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
4. Red Flags
o Presentation of personal identifying information that is associated with known
fraud activity
o Inability to verify insurance information
o Family members or friends reveal suspicious information to WCMC staff, such
as calling the patient by a different name
o Mail sent to the patient is repeatedly returned as undeliverable despite ongoing
transactions
o Notices from patients, victims of identity theft, law enforcement, or other
persons regarding possible identity theft in connection with patient
5. Red Flags
o All WCMC staff who register/schedule patients will
take reasonable action to identify/detect relevant red
flags by collecting:
• patient's name
• gender
• date of birth
• address
• identification number from the patient or
parent/guardian
6. Red Flags
o 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 patient's parent or guardian, by requesting to
view a photo identification of the patient or patient's
parent or guardian, along with their insurance card, or by
other reasonable means.
7. Red Flags
o All WCMC staff members are responsible for notifying their direct
supervisor immediately of any circumstance that arises with a patient or
patient's 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
8. Red Flags
o 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.
