How Does a Dental Office Comply with the Red Flag Rule as Currently Written?
If a dental office is a creditor with at least one covered account, the office must adopt a written policy and procedures designed to (1) Identify Red Flags relevant to the dental practice; (2) Explain how Red Flags will be detected; (3) Respond to Red Flag incidents that are detected; and (4) Establish procedures to administer the program as well as ensure that the program is reviewed and updated periodically. While each written identity theft prevention program should contain the four fundamental elements listed above, the FTC has indicated that one size does not fit all and that dentists are free to create a program which best suits their practices. ADA Offers Assistance to Dentists on Compliance The ADA has worked diligently to persuade the FTC to exclude dentists from the Red Flag Rules. The ADA believes that the rules were never intended to apply to dental practices, because identity theft has never been a serious problem in dental offices. The ADA believes that the rule would ha
