-patches bryan, rn, bsn, cdonltc, mha, nha chief executive clinical officer greystone healthcare...
TRANSCRIPT
-Patches Bryan, RN, BSN, CDONLTC, MHA, NHAChief Executive Clinical Officer
Greystone Healthcare Management
Identity Theftin Long Term Care
Facilities (NHs & ALFs)
Introduction
One of the most predominant problems in LTC/ALF
settings is lost, misplaced and or stolen items.
We have interventions in place for such things.
But what about “IDENTITY THEFT”? What do you
have in place for this – if it should happen in your
workplace setting? Do you even know what it is or
how it can happen?
Well I do, and it was an experience I will never
forget! First, lets discuss the facts…
It’s Curtains for this Identity-Theft Scam
Here’s how the story went …
The husband of one of the residents received a call from Sears, regarding a purchase for a washer/dryer. Police were notified at the suggestion of the department store.
It's not exactly the Hollywood ending for this mastermind of an
identity-theft criminal exploit.
It’s Curtains for this Identity-Theft Scam
Corporate office was notified and internal investigation began.
Facility personnel were asked to identify an individual in a photograph taken from a surveillance camera
Detective presented a list of names and asked if any were current or former residents
It’s Curtains for this Identity-Theft Scam
Abuse Hotline called
Adverse Incident Report completed
It’s Curtains for this Identity-Theft Scam
Employee was suspended Employee was suspended pending results of pending results of
internal investigation.internal investigation.
Support organizations sought for guidance.
It’s Curtains for this Identity-Theft Scam
Letter to families was prepared
Sample letter to families:
July 31, 2009
Dear Family,
As Administrator of [Facility Name], I am writing you this letter to notify you that one of
our residents have been identified as a victim of identity theft. This was brought to our
attention by the resident. I want to assure you that I am working closely with the police
department and the Credit Card Company to bring this matter to a definitive close. Our
residents’ privacy is a matter I take very seriously and will do everything I personally can
to assist local law enforcement as they bring the responsible party to justice. It is
strongly suggested that everyone check their bank account and credit report for any
unauthorized activity. This can be done at http://annualcreditreport.com which allows
you to receive at no cost an annual credit report from all three major credit reporting
companies. If you have any further questions, please contact me at XXX-XXX-XXXX.
Sincerely,
Administrator
It’s Curtains for this Identity-Theft Scam
Statement to the media was prepared
Sample Media Comment …
“[Facility Name] had suspended the staff member once we were notified by the police of the allegations. Now that authorities have pressed charges, the employee will be terminated and reported to their respective professional agencies in keeping with our policy on these matters. We have been and will continue to be in full cooperation with authorities on this matter.”
It’s Curtains for this Identity-Theft Scam
Town Hall meetings with the staff were
held as well as educational training
on identity theft.
It’s Curtains for this Identity-Theft Scam
Victim’s husband was continuously Victim’s husband was continuously informed throughout investigation.informed throughout investigation.
It’s Curtains for this Identity-Theft Scam
Police discovered the suspect was a Police discovered the suspect was a part of a group targeting LTC part of a group targeting LTC
facilitiesfacilities
Theft amounted to > $100,000 between Theft amounted to > $100,000 between Sears, JC Penney’s, and Rooms to Go.Sears, JC Penney’s, and Rooms to Go.
It’s Curtains for this Identity-Theft Scam
Employee X was arrested, dashing her bid for Hollywood stardom
PRACTICAL SUGGESTIONS
TO PREVENT LOSS AND THEFT IN LONG TERM CARE FACILITIES
Before Admission Complete a full inventory of all personal items and file
this inventory in the facility office. Keep a copy for your records.
Mark clothing and personal items with resident’s name (not just initials) using permanent markers or tags.
Engrave expensive items such as television sets with name and number. Dentists are also able to engrave dentures in this manner.
Check Homeowner’s insurance to see if coverage can be extended to cover property during a nursing home stay. Certain valuable items, such as prosthesis, may be insured separately.
PRACTICAL SUGGESTIONS
After Admission Remember to include clothing worn on the day of
admission on the inventory. Mark any new belongings brought to the home and
enter them on the inventory sheet. If an item is discharged or sent home with someone
for safekeeping, have it taken off the inventory. Communicate with family and friends to reduce
misunderstandings about possessions brought to or removed from the home.
Keep cash and small valuables which are not needed constantly and other valuables in a locked drawer or a safe.
Report every loss to the designated staff member, in writing (via Grievance Report)
PRACTICAL SUGGESTIONS
After Admission Provide a small container to hold dentures,
eyeglasses, hearing aids, convenient to both residents and nurse’s aides. Have staff check this box each shift and sign their name.
Use transparent trash liners and use personal mesh laundry bags for small items.
Consider extending homeowner’s policy to cover residents’ personal possessions in the nursing facility, or to buy special insurance on therapeutic devices (hearing aids, dentures, eye glasses).
Involve residents and families through the resident and family councils.
PRACTICAL SUGGESTIONS
After the Fact Note: Item(s) are often misplaced: check the
resident’s room with his/her help/permission; check with employees, and other residents and family. Check the facility’s Lost and Found.
Have staff check other resident rooms or clothing for the missing item(s).
Fill out a missing item report and give a copy to the staff/resident/family.
Facilities may assign one staff person to handle all “missing items”.
PRACTICAL SUGGESTIONS
After the Fact Call the police (this is what each of us would do in
our own home. It acts as a good preventative for the future).
If an employee is guilty of theft, facilities need to discharge and prosecute the employee immediately.
If the facility is responsible for lost items, ask for reimbursement or replacement of the item. File insurance claim for lost or stolen item(s).
If not satisfied, a claim can be filed in Small Claims Court.
Thank you !
-Peggy RigsbyDirector of Government ServicesFlorida Health Care Association
Identity Theftin Long Term Care
Facilities (NHs & ALFs)
History of Identity Theft and Federal Law
Identity Theft & Assumption Deterrence Act of 1998
Strengthened criminal laws regarding identity theft
Recognized that the real victim is the person whose identity was stolen
Identity Theft Penalty Enhancement Act of 2004Increases criminal penalties
Fair and Accurate Credit Transactions Act of 2003Creditors and identity theft
False Identification Laws
False Identification Crime Control Act of 1982Penalties for producing/possessing false
documents
Internet False Identification Act of 2000Closed loophole to include computer
aided crimes
Privacy Act of 1971Controlling Government’s Access
Driver’s Protection Act of 1994Limited DMV information
Health Insurance Portability and Accountability Act of 1996
Protection of health care records
Gramm-Leach-Bliley Act of 1999Protected sale of consumer financial
information
Social Security Confidentiality Act of 2000Prohibited certain displays of SSN
Privacy and Personal Data Laws
Federal Credit Laws
Fair Credit Reporting ActCollection and dissemination of
consumer credit information
Truth in Lending Act$50 limit on fraud charges
Electronic Fund Transfer ActFramework for EFTs
Fair Credit Billing ActResolution of billing errors
President Bush Task Force on Identity Theft
May 2006
Attorney General/Federal Trade Commission
Law Enforcement, Education, Government Safeguards
Strategic Plan
Who Governs What?
U. S. Department of Justice Federal Trade Commission Department of the Treasury Department of Health and Human Services Federal Reserve Securities & Exchange Commission Social Security Administration Comptroller of the Currency Secret Service U.S. Postal Inspection Federal Deposit Insurance Corporation
Identity Theft and State Law
Find your state statute
State Attorney General
Other relevant state agencies
www.idtheftcenter.org provides multi-state information
Red Flag Rules
History
Components
ImplementationPolicyEffective date
Karen L. GoldsmithGOLDSMITH & GROUT, P.A.
P.O. Box 2011Winter Park, Florida 32790
(407) [email protected]
Identity Theftin Long Term Care
Facilities (NHs & ALFs)
IDEAS FOR PREVENTION OF IDENTITY THEFT
Mail control
One or two people should process mail
Will know what resident normally gets mail
Change in amount of mail may indicate diversion
That person should be above suspicion – not the newest minimum wage employee
Do not drop mail off if resident not in room or not competent to understand maintaining mail safety
Consider a mailbox system for those residents alert and able to get around building
ENLIST THE RESIDENT
Education is key
Assist with shredding and explain importance
Give the alert resident a place to keep mail that is important – like a small lockbox
Ask alert residents to let you know if other residents’ mail is left lying around
If resident wants to keep a checkbook on the premises ask them to allow you to keep it in the business office under lock and key but make it accessible 24 hours a day
What about lockers for this type of material?
ENLIST THE FAMILY
Work out a system with families of residents who are not aware to hold their mail in a safe place until the family is there or to permit a specified individual on staff to open what appears to be “junk” mail
A mailbox for these residents is helpful
Lockbox in the room where mail can be slipped in is helpful
Alert families not to leave sensitive financial information in the resident’s room
Advise families not to discuss sensitive matters in a place where they may be overheard – will require you to provide a convenient place for such discussions
FAMILIES AND ALERT RESIDENTS (as well as those not so alert):
If the resident has a cellphone encourage them to check the bill monthly, even if they have unlimited minutes – unusual calls should be investigated
Resident should have a list of bills, bank statements, etc and when they are expected so that someone can verify that mail is not being diverted – keep the list in a safe place so it does not become a tool for an identity thief
Suggest someone verify all charges and payments
Suggest someone regularly balance the checking account or other bank accounts
Suggest someone check accounts online from time to time – clever thieves will use card between cutoff times
Extra checks and credit cards should be kept in a safe place
Have a secure place for outgoing mail, not the CNA’s pocket or receptionist desk
If a credit card expires or is no longer needed have a system in place to dispose of that card through a shredder in the presence of the resident or family
DUMPSTER DIVINGis a thief’s dream activity!!!!!
SHRED EVERYTHING WITH IDENTITY INFORMATION ON IT.
DEALING WITH YOUR STAFF
Let them know you are watching and theft will be handled harshly
Remind them of the concerns you share with residents and families
Remind them of their roles
Enforce policies regarding privacy
They must be your eyes and ears – anonymous hotlines may be helpful
THE COMPUTER AGE
Baby Boomers are going to demand more computer time. Protecting their identity is critical, but difficult
Each resident should have a password and change them frequently – residents who may be confused or forgetful might need a staff person to get them online
Protect the resident’s password from staff who are not cleared to assist residents – staff often is the identity thief
Have the computers residents use protected with a firewall or other method
Tweeting and having a blog can give sensitive information to potential thieves – while your residents may want to participate in these activities, be sure they understand the dangers – if a resident who uses the computer regularly starts getting an inordinate amount of mail or visitors keep your eyes and ears open – give that resident a refresher course
OTHER IDEAS
Inventories are more important than ever
Discourage keeping valuables and important papers at facility or locked away
If a resident gives mail or other information to other than a family member, discuss with resident or family, if appropriate
Keep the residents and family members advised of any problems – regularly report to family or resident’s council
Let staff know that if there is any suspicion of theft the police will be called
Have strict employee policies and enforce them – no room for interpretation
Background screening may be necessary
Keep social security numbers off facesheets or other places with access by employees
Be mindful of what your volunteers are permitted to do
So you thwart all attempts to prevent identity theft – don’t forget the most simple – stealing wallets, passports, purses, etc.
IF YOUR IDENTITY IS STOLEN
Contact your credit card companies immediately and check for misuse and ask for a new account number - by phone and follow up with letter.
FILE A POLICE REPORT
Will go to the 3 credit reporting agencies
Will limit your liability to an extent
May stop collection efforts
File an identity theft claim with the FTC- get form online or call the hotline 1-877-ID-THEFT.
PLACE A FRAUD ALERT ON YOUR CREDIT REPORTS
Equifax: 1-800-525-6285; www.equifax.com; P.O. Box 740241, Atlanta, GA 30374-0241
Experian: 1-888-EXPERIAN; www.experian.com; P.O. Box 9532, Allen, TX 75013
Transunion: 1-800-680-7289; www.transunion.com; Fraud Victim Assistance Division, P.O. Box 6790, Fullerton, CA 92834-6790
Will permit you to get free credit report
May request only last four digits of your ss number are on report
Can be temporary (up to 90 days) or extended (7 years) – does not keep thieves from using existing accounts but may prevent them opening new accounts that require credit check
Check your credit report for unusual activity and follow up on it –
do not put your entire social security
number on your letter – credit companies do
make errors!!!!
IDENTITY THEFTEDUCATIONAL CHECKLIST FOR RESIDENTS AND FAMILIES
_____ Familiarize residents and families with ways in which identity may be stolen_____ Explain facility’s policies and
procedures for handling mail_____ Discuss privately with each resident and/or family member how they want to handle their incoming mail_____ Explain procedures for outgoing mail_____ Ask residents how they want you to handle their “junk” mail_____ Discuss with residents who wish to use computers (either own or
facility’s) importance of password and protecting it. Emphasize need to protect data if the computer is kept by the resident_____ Instruct those residents on proper procedures in using computers and supply them with a reminder list of steps to take_____ Assure residents that while you
believe that staff is honest and trustworthy; you have
designated certain individuals to handle mail and computer time and give them a list
_____ Stress the importance of leaving valuables at home and keeping
an accurate inventory on file with the facility_____ Explain shredding system and how best for residents to utilize it_____ Remind residents of cell phone theft and to keep cell phones with them at all times_____ Remind residents and families that they should watch out for one
another_____ Remind residents and families about using a private place to discuss
financial matters_____ If resident has left a home vacant remind family to check to be sure mail has been properly forwarded by the post office_____ Alert resident and families for the need to check all bills and bank
statements regularly (on computer if appropriate)_____ Remind residents that volunteers may not be honest so be careful
what is shared with them
Identity Theft IQ TestAre You at Risk for Identity Theft? Test Your "Identity Quotient"
___I receive several offers of pre-approved credit every week. (5 points)
___Add 5 points if you do not shred them (cross-cut shredder preferred) before putting them in the trash.
___I carry my Social Security card in my wallet. (10 points)
___I use a computer and do not have up-to-date anti-virus, anti-spyware, and firewall protection. (10 points)
___I do not believe someone would break into my house to steal my personal information. (10 points)
___I have not ordered a copy of my credit reports for at least 2 years. (20 points)
___I use an unlocked, open box at work or at my home to drop off my outgoing mail. (10 points)
___I do not have a P.O. Box or a locked, secured mailbox. (5 points)
___I carry my military ID in my wallet at all times. (It displays my SSN.) (10 points)
___I do not shred my banking and credit information, using a cross-cut “confetti” shredder, when I throw it in the trash. (10 points)
___I throw away old credit and debit cards without shredding or cutting them up. (5 points)
___I use an ATM machine and do not examine it for signs of tampering. (5 points)
___I provide my Social Security number (SSN) whenever asked, without asking why it is needed and how it will be safeguarded. (10 points)
___Add 5 points if you provide it orally without checking to see who might be listening nearby.
___I respond to unsolicited email messages that appear to be from my bank or credit card company. (10 points)
___I leave my purse or wallet in my car. (10 points)___I have my driver's license number and/or SSN
printed on my personal checks. (10 points) ___I carry my Medicare card in my wallet at all
times. (It displays my SSN.) (10 points) ___I do not believe that people would root around in
my trash looking for credit or financial information or for documents containing my SSN. (10 points)
___I do not verify that all financial (credit card, debit card, checking) statements are accurate monthly. (10 points)
Each one of these questions represents a possible avenue for an identity thief.
Understanding Your Score:100 + points - Recent surveys* indicate that 8-9 million people are victims of ID theft each year. You are at high risk. We recommend you purchase a cross-cut paper shredder, become more security-
aware in document handling, and start to question why people need your personal data. 50-99 points - Your odds of being victimized are about average. 0-49 points – Congratulations. You have a high “IQ.” Keep up the good
work and don’t let your guard down now.