Winter 2009/2010 - Promise Healthcare

LEGAL & COMPLIANCE MATTERS
In 2008, the Federal Trade Commission’s “Red
Flag and Address Discrepancy Rule,” more
commonly known as the “Red Flag Rule,” went
into effect. The rule was written with financial
institutions and creditors in mind, however, it
also applies to health care providers who bill for
services.
The purpose of the Red Flag Rule is to protect
consumers through the detection, prevention,
and mitigation of identity theft.
A “Red Flag” is defined as a pattern, practice,
or specific activity that could indicate identity
theft. Some of the most obvious and most
frequently encountered are:
- a complaint or question from a patient, based
on the patient’s receipt of:
• a bill for another individual,
• a bill for a product or service the patient
denies receiving,
• a bill from a health care provider the
patient has never seen, or
Medical Identity Theft
? DID YOU KNOW
• an Explanation of Benefits or other notice
for health services never received.
- records showing medical treatment inconsistent
with a physical examination or medical
history as reported by the patient, such as
discrepancies in age, race, and other physical
descriptions,( i.e., an “amputee” who has miraculously
regrown a limb.)
- a patient whose friends and family consistently
call him/her by a name other than what is in
his/her medical records, or who does not answer
to the name in the medical record.
As providers of health care, we must be alert to
such “red flags” in order to protect our patients
from Medical Identity Theft. It can cause erroneous
information to be entered in an individual’s
records such as the wrong blood type, a lack
of allergies, or an inaccurate medical history.
Policies and procedures related to Identity Theft
and the Red Flag Rule were recently issued to
all facilities. Employees should become aware of
and familiar with these policies.
We should also be alert to our own red flags. If
you receive a bill for a product or service you
never received, or any of the other items listed
above, notify the authorities immediately as you
may be a victim of Medical Identity Theft.
New Corporate Director of Pharmacy
Nish Patel, PharmD, BBA
Nish Patel brings 14 years of pharmacy experience in retail and acute care hospital settings to his
new position as Corporate Director of Pharmacy. For the past four years, he has served as the
Director of Pharmacy at Promise Hospital of San Antonio, ensuring compliance with patient care
quality standards and implementing clinical programs to promote appropriate use of medications.
His previous leadership roles include Clinical Coordinator/Manager for multiple hospitals within
the Baptist Health System and the Methodist Healthcare System in San Antonio, where he managed
formularies and implemented protocols and guidelines for improving care and reducing cost.
Nish earned his Doctor of Pharmacy and a Bachelors of Business Administration from the
University of Texas at Austin. He has published over a dozen abstracts on drug therapies and has
presented his findings at national and state pharmacy conferences. Nish also served as a Director
of an accredited Pharmacy Practice Residency program and he continues to be a practitionerfaculty
member with the University of Texas at Austin. His dedication to pharmacy earned him a
distinguished award from the Texas Society of Health-System Pharmacists for his achievements in
his first five years of practice.
Nish has lived in San Antonio for over 25 years with Mona, his wife of 15 years, and their two
children, Anaya (7 years old) and Arianna (4 years old). When not working, he likes to cycle,
travel and spend time with his family working on creative projects.
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