Today's blog is a guest post by Dorrie J. Seyfried, Vice President of Risk Management Services, IPMG. Dorrie discusses the rising financial and identity theft risks to nursing home residents, when they can amount to abuse, and what you can do about it. If you do run into a theft that involves patient information, remember to analyze it from a HIPAA standpoint, too.
Theft and Financial Exploitation
Identity theft and financial exploitation in various forms is becoming more widespread within the nursing home community.
Blank checks have been stolen and then fraudulently filled out; credit cards have been stolen and used; credit card limits have been fraudulently increased followed by multiple ATM cash withdrawals; social security numbers have been accessed from paper-version and EMR face sheets to fraudulently apply for credit cards, etc. Skilled nursing and assisted living facility residents have been affected.
In order to protect your residents and facility, please review the below recommendations and re-evaluate your current practices:
- Evaluate availability of protected information, i.e. social security numbers. Is the full SSN really necessary on electronic face sheets? Are there other alternatives that provide another layer of protection? If paper face sheets are maintained on the units, the full social security number should definitely NOT be included.
- Communicate with residents and families upon admission and regularly thereafter regarding the potential risks of having bank checks, credit cards, social security cards, driver licenses and other financial information unsecured in resident rooms/apartments. There risks are real!
- Include identity theft and financial exploitation in Abuse in services with staff.
- Revise the ‘belongings inventory’ process upon admission. Many facilities document ‘black purse’ or ‘brown wallet’ without pursuing the contents. With resident/family permission, examine the contents for i.e. bank checks, bank account information, credit cards, social security cards, drivers licenses, house keys, etc. Please consider having the Social Worker conduct this portion of the belongings inventory process. (If the resident/family does not give permission to examine the purse or wallet, the Social Worker should document same.) If these items are present, it is an opportunity to discuss risks and encourage that these items be kept at home. If the resident/family insists upon maintaining these items onsite, then they should be encouraged to store them safely in i.e. the Business Office. If the resident/family insists upon maintaining these items within their room/apartment, then make lockable storage available within their room/apartment, i.e. lockable drawer/cabinet, lock-box that is adhered within the closet, drawer, etc.
- If theft and/or identity theft and/or financial exploitation is suspected, follow Abuse Reporting procedures, i.e. initial report within several hours of discovery ad final report within 5 business days. Depending upon the circumstances a the investigation unfolds, updates may be indicated.
- Actions to be taken:
- Contact the police immediately.
- Assist the resident/family with contacting banks, credit card companies, etc., in order to stop payments on checks, stop credit cards, etc.
- Conduct internal investigation, i.e. where did the resident keep these items within their room? When is the last time these items were seen, last check number used? Were staff aware that resident had these items and where they routinely stores within the room? Beyond this basic information, it is more likely that the facility will play a supportive role to the police investigation.
- Assist police with the investigation as requested, i.e., identity facility and/or agency staff who have been assigned to the resident and/or unit, etc., attendance irregularities, abrupt resignations or job abandonment, et al. Each case will be somewhat different.
- Suggest to resident/families to request Fraud Alerts with credit bureaus; contact Social Security Administration regarding potential identity theft, etc.
Skilled and assisted living facilities have been identified by the unscrupulous as easy pickings for identify theft and financial exploitation, but with a few changes to our routine practices we can protect our residents!
Should you have any questions, please do not hesitate to reach out to Dorrie at: Dorrie.Seyfried@ipmg.com