April 21, 2015


April 20, 2015

Red Flags Rule Delayed Again, Now Effective June 1, 2010

The Federal Trade Commission (“FTC”) has again delayed enforcement of the Red Flags Rule, this time at the request of members of Congress. The press release can be found here. In addition, some politicians have not given up the fight to exempt certain small business, including small medical practices, from complying with the FTC's Identity Theft Prevention Plan mandate. Rep. Adler of New Jersey introduced a bill that has already passed the house (H.R. 3763) that would amend the Fair Credit Reporting Act to provide for an exclusion for certain businesses including a healthcare practice with twenty (20) or fewer employees. Stay tuned to see if this exemption passes the Senate.

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About this Author


Stacey A. Borowicz is a member of the Corporate Department. Stacey counsels healthcare clients on business transactions, formations, mergers, acquisitions and employment-related transactions. Her experience includes handling matters involving fraud and abuse, Stark, anti-kickback and false claims. Stacey drafts compliance plans and performs antitrust, fraud and abuse, anti-self referral law, Medicare coding and billing compliance, HIPAA, and corporate compliance analyses. She regularly represents physician practices, ambulatory surgery centers, imaging centers and other physician-...