Purpose: To provide procedures for Registration and Business Office staff to detect identity theft, and when to update the patient’s account accordingly, when ID theft is detected.

Scope: Patient Financial Services Director, HIM Director, Chief Financial Officer and the Chief Quality Officer in her role as Compliance Officer.

Responsibility: The Patient Financial Services Director will be responsible for implementing this policy.

Policy: It is the policy of Kingfisher Regional Hospital to protect the identity of all patients without the interruption of service, and to ensure the Patient Financial Services staff understands how to detect and prevent identity theft in connection with the operations performed in the PFS Department. The PFS staff should be trained and know what steps to take if identity theft is determined. This policy is intended to be the minimum standard requirement.

Procedure:

  1. Obtaining Patient Information
  1. All registration areas should obtain the patient’s driver’s license or another form of picture ID. The registration department should scan copies of the picture ID (e.g., driver’s license, military identification card, passport, etc). If the patient does not have a photo ID, ask for two (2) forms of a non - photo ID (birth certificate, social security card, school ID, ext.). If the patient is under the age of eighteen (18) or if the patient is unable due to their condition to produce identification, the responsible party’s ID should be requested.
  1. Emergency Care – There will be no delay in providing service. Providing identification is not a condition for obtaining emergency care. The process of confirming patient identity must never delay the provision of an appropriate medical screening examination or necessary stabilizing treatment for emergency medical conditions.

Policy Title: Red Flag Rule Page 2 of 6

  1. Refusal to Provide or Lack of Identification – No one will be refused care because they do not have acceptable identification with them. Patients will be asked to bring appropriate documents to their next visit.
  1. The registration clerk should look at the photo ID to make sure it is the person presenting for services. Does the ID look official? Has the ID been altered from the original ID? Compare the scanned photo ID to the photo ID presented at service. If an identity discrepancy/issue arises contact the Patient Financial Services Director or designee. The PFS Director or designee should contact the Chief Quality Officer in her role as Compliance Officer if identity theft is suspected and complete the Alleged Identity Theft Communication form (Attachment A).
  1. Compare the signature on the consent form to the signature on the driver’s license or other ID. If they do not match notify the PFS Director or designee. PFS Director or designee should complete the Alleged Identity Theft Communication form (Attachment A) and notify the Chief Quality Officer in her role as Compliance Officerif it is determined ID theft may exist.

NOTE: After registration, if an employee reasonably believes identity theft has occurred or may be occurring, immediately notify the PFS Director or designee who will then contact the Chief Quality Officer in her role as Compliance Officer.

  1. Patient Misidentification

If it is determined that patient misidentification, but not identity theft, has occurred

(Example: when a patient gives his or her real name, but the incorrect medical record number is assigned and the medical information of two patients is subsequently intermingled), the facility should take the following steps:

  1. If the registration clerk realizes they have chosen the wrong history number and the patient’s registration is not complete they should exit out of the account and start the registration process over.
  1. If the registration clerk realizes they have chosen the wrong history and the patient’s registration has been completed but the patient has not left the registration’s desk, the following steps should be completed:

Policy Title: Red Flag Rule Page 3 of 6

  1. The registration clerk should notify the PFS Director immediately.
  1. The PFS Director should correct the medical record number assigned to the patient’s account if possible before letting the patient continue for service. This would not include emergency room patients.
  1. Any documents printed and signed would need to be reprinted and signed again to reflect the correct history number.
  1. If the registration clerk realizes they have chosen the wrong history number and the patient’s registration has been completed and the patient has left the registration clerk’s desk, the registration clerk should notify the PFS Director immediately. The PFS Director will notify the HIM Director.
  1. Notification – At any point other than the above, when patient misidentification occurs, the employee discovering the misidentification immediately notifies the PFS Director who will notify the HIM Director. All identifying copies of the patient should be given to the PFS Director along with an explanation of the misidentification.
  1. If the incident occurs on a weekend, reporting may need to occur the next business day. A copy of the patient’s photo ID, face sheet, insurance cards, and insurance eligibility transactions should be given to the PFS Director along with an explanation of the misidentification.
  1. The PFS Director and HIM Director will verify that all demographic and insurance information has been updated to ensure all information is correct.
  1. If the account cannot be corrected before the bill is dropped, the account should be put on a Bill Hold status.
  1. Once the charges have been placed on the correct account and all information is correct in HIM, the PFS Director will release the bill from Bill Hold status.

C. Consumer Disputes Care Received at Hospital

If a consumer contacts the Business Office to report that they have received a statement or letter in the mail and states that they did not receive these hospital services, the facility shall take the following steps:

Policy Title: Red Flag Rule Page 4 of 6

  1. The PFS Director will ask the consumer to bring their drivers license and all pertinent information to the facility regarding the account in dispute.
  1. The PFS Director will ask for proof of identification i.e., photo ID or two non photo IDs.
  1. The PFS Director or designee will review the claim with the patient to determine which date of service is in question.
  1. The PFS Director will contact the Facility Compliance Officer to inform him/her a misidentification or possible identity theft has occurred. The PFS Director will also complete the Alleged Identity Theft Communication form (Attachment A).
  1. If the PFS Director and the Facility Compliance Officer determine the claim was a case of misidentification, the following steps will need to be followed:
  1. The Business Office designee will remove the charges from the incorrect patient’s account.
  1. A new account number will be created using the correct patient’s history number. If the history number does not exist, one should be created.
  1. All charges will be placed on the correct patient’s account number.
  1. If the claim has been paid, an adjusted claim should be filed and all money should be returned to the insurance company. The incorrect patient’s account will also need to have any payments and contractuals reversed from their account.
  1. The corrected patient’s account will need to be billed when all charges have been applied to the account.
  1. If the PFS Director and Chief Quality Officer in her role as Compliance Officer determine the claim was due to identity theft, the following steps will need to be followed to correct the victims Master Patient Index and account information.

Policy Title: Red Flag Rule Page 5 of 6

  1. Once it is determined which date or dates of services should not be on the victims account, the PFS Director or designee will remove all charges for that date or dates of service from the incorrect account.
  2. An adjusted claim should be sent to the insurance company.
  3. All payments and contractuals should be reversed from the patient’s account once the insurance company has recouped their payments/contractuals.
  4. Notes should be added to this account explaining why charges and payments/contractuals were removed from the account.

b.The PFS Director will create a new account and a new medical record number for the individual who misrepresented him/herself to the facility and will collaborate with the HIM Director to ensure proper record keeping. If there is more than one date of service, an account will be created for each date of service. The same medical record would be used.

  1. If the name of the person who committed identity theft is known, that name and all other information will be entered correctly when creating the new medical record and account number.
  2. If the name of the person who committed identity theft is not known, the victim’s first name should be entered during the registration process along with IDTHEFT as the last name. This will help alert the registrar if the patient using the wrong identity returns to the hospital for services and tries to use the same name again.
  3. The patient’s address should be the hospital’s address.
  4. The insurance company will be Self Pay.
  5. The guarantor will be IDTHEFT (First name of Victim) i.e., IDTHEFT MARY. This will match the patient’s name once the name is changed in step vi.
  6. Once the registration is complete with a new medical record number, the patient’s name should be changed in the patient’s demographics to IDTHEFT (First name of Victim) i.e., IDTHEFT MARY. This process may be different depending on the patient accounting system.
  7. Changing the name to IDTHEFT (First name of Victim) will flag the account with the previous name or alias name. If the victims name is used again, the IDTHEFT (First Name of Victim) will be displayed. Each patient accounting system may display this differently.

Policy Title: Red Flag Rule Page 6 of 6

  1. When the patient (victim) whose identity has been used presents back to the hospital, the patient’s ID should be reviewed closely. Review the address and birth date and any other information before proceeding with the registration.
  1. The PFS Director or designee will enter the charges to the new account number. If there are charges for more than one date of service the charges will need to be input on separate accounts.
  1. The bill should be produced and the collector assignment should be changed to BOM Hold collector. This would allow the account to stay with the PFS Director and not move to other financial classes or to outside collection agencies. This process may vary by the patient accounting system used by the hospital.
  1. If the patient (ID thief) is never identified and the hospital makes the determination to write off the total charges, the transaction code for Administrative Adjustment should be used. This code will vary by patient accounting system.

D. Consumer Disputes Care Received at Hospital and the Account is in Bad Debt

If a consumer contacts theBusiness Office to report that they have received a statement or letter in the mail and states they did not receive these hospital services and the account is in bad debt, the facility will take the necessary steps above (Consumer Disputes Care Received at Hospital). If it is determined that the patients identity was stolen, the following steps should be taken:

  1. The PFS Director will notify the Chief Quality Officer.
  2. The hospital will recall the account from the collection agency.
  3. The account will need to be reinstated into Accounts Receivable.
  4. The account will need to be written off to an Administrative Adjustment.