Red Flags Manual For Healthcare

April 26th, 2009

What is a Red Flags Program? Under the Red Flags regulations, creditors must develop a written program that identifies and detects warning signs (”red flags”) of identity theft within their organizations. Some of these red flags may include unusual activity in a patient account, suspicious activity within a patient’s medical record, documents provided for identification that appear to have been altered, etc.

Healthcare providers (for profit, non-profit, or governmental agencies) have obligations under the rule. Insider access to patient data is included in the Red Flag Rules Guidelines. Healthcare entities have a responsibility to monitor and oversee employee access to data. 

The folks over at Vantagepoint Healthcare Advisors (www.vantagepointconsult.com) have put together a great manual to help you take care of the problem.  See the Red Flags Manual.

Plan Ahead

March 8th, 2008

If you still haven’t ordered your tamper resistant Rx Pads, you probably should do so this week.

Normal turn times are about a week, plus shipping, so time is running out.

Moreover, many plants are expected to run out of stock during the week before 4/1/08.

PLAN AHEAD!

Be Prepared. Order early.

February 9th, 2008

If history is an indicator, the week before April 1, 2008 will be a busy one for printers, print brokers and paper manufacturers that deal with tamper-resistant prescriptions.

Last September, before the rule was extended, manufacturers were overwhelmed with last minute orders prompting back orders.

For example, typically Doctor Stuff has a turn around of about 5 business days plus shipping time. Starting March 15, we expect to have an 8 day turn time and are trying to put some measures into place to help existing customers meet the compliance date.

The bottom line is to order early to make sure that you have them in time.

NCPDP to Docs: Get Moving!

February 6th, 2008

From DrugTopics.com,

“With only two months left before Medicaid prescriptions must be written on tamper-resistant Rx pads, the National Council for Prescription Drug Programs (NCPDP) has issued some new resources (see below) pharmacists can use to prepare for this change. The resources include a model letter for prescribers that states may use as a template. The letter reminds prescribers that:

  • Medicaid Rxs are required to have at least one tamper-resistant feature by April 1.
  • Medicaid Rxs must have a minimum of one feature from each of three categories of tamper-resistant features by Oct. 1.
  • they should start ordering the new prescription pads promptly, since orders may take up to four weeks to process

In addition, NCPDP considered all the tamper-resistant features in the three categories and came out with its findings on which features it favors, because they are less costly and easy to implement, and which ones are harder to implement. NCPDP urges prescribers to implement all the security features by April 1, instead of phasing in some by April 1, and then adding new ones by Oct. 1. The latter approach would be wasteful of paper and pads, it explained.”

New Resources mentioned above:

Draft Letter to Prescribers (Word Document)

Draft Letter to Prescribers (pdf)

Final Letter to Prescribers (pdf)

Medicaid’s Tamper-Resistant Prescription Requirements FAQs

January 9th, 2008

See the FAQ’s from CMS.

Tamper-Resistant Prescriptions Delayed until April 1, 2008

September 30th, 2007

From CMS:

On Saturday, September 29, 2007, President Bush signed the “Extenders Law,” delaying the implementation date for all paper Medicaid prescriptions to be written on tamper-resistant paper. Under the new law, as of April 1, 2008, all written Medicaid prescriptions must be on tamper-resistant prescription pads.

CMS’ guidance on the tamper-resistant law, set forth in an August 17, 2007 State Medicaid Director letter, contains two phases. For the first, a prescription must contain at least one of the three tamper-resistant characteristics in order to be considered “tamper resistant.” For the second, prescriptions must contain all three characteristics.

The two-phased approach is still in effect. At least one of the three tamper-resistant characteristics is required on April 1, 2008. All three characteristics are required on October 1, 2008.

Tamper Resistant Prescription Delayed

September 29th, 2007

In response to strong concerns from physicians, pharmacists, and others, Congress delayed the regulation mandating the use of tamper-proof prescriptions for Medicaid patients for six months. If President Bush signs the legislation as expected, the new deadline is March 1, 2008.

Physicians and pharmacists contended that they weren’t given enough time to obtain the new prescription pads, and manufacturers said they were getting so many orders that they could not keep up with the demand.

Suppliers Running Short on Stock

September 24th, 2007

It seems that providers are realizing that they need to be prepared by next week.  But it seems that they may have problems complying.

Because of the demand, several of the largest manufacturers of tamper-resistant security paper for prescriptions are out of stock.

These manufacturers supply local, regional and national printers with this paper and the back order will cause delays for many to implement.

When I called to order some blank stock for some of my customers, Paris Business Forms, for example, told me that they were on a 2-3 week backorder. They have dedicated extra shifts to the problem, but they can’t satisfy the demand.

State Medicaid Directors Urge Delay

September 19th, 2007

From the National Association of State Medicaid Directors

Medicaid Directors Seek More Time

State Medicaid Director Letter (SMD)

August 20th, 2007

Actual Letter