Mid-Atlantic Health Law TOPICS

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Did You Know? Winter 2009

FTC Red Flags Rule Enforcement Postponed to June 1, 2010: Did you know that the Federal Trade Commission delayed enforcement of the Identity Theft Red Flags Rule from November 1, 2009 to June 1, 2010? The FTC granted the delay on October 30, 2009, after Congress requested a stay of enforcement. This stay of enforcement was granted because of proposed legislation that, if it becomes law, would exempt certain health care providers from complying with the Red Flags Rule.

DMEPOS Surety Bond: Did you know that the Centers for Medicare and Medicaid Services (CMS) now requires certain Durable Medical Equipment, Prosthetics and Orthotics (DMEPOS) suppliers to obtain a $50,000 surety bond? Effective Oct. 1, 2009, DMEPOS suppliers must obtain and submit to the National Supplier Clearinghouse a $50,000 surety bond for each National Provider Identifier used by the DMEPOS supplier. Certain DMEPOS suppliers, including (i) government owned suppliers, (ii) private practice orthotic and prosthetic suppliers that are solely owned by persons who provide such orthotics and prosthetics, (iii) certain physicians and non-physician practitioners who provide DMEPOS items to their patients as part of their professional service, and (iv) physical and occupational therapists that are solely owned by such therapists and who provide such DMEPOS items to their patients as part of their professional service, are exempt from the bonding requirement.







Rosen, Barry F.


Health Care