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Given the regulated, litigious environment in which we operate, confidentiality is a company priority.  We continually review procedures to ensure compliance with our industry regulations [the Fair Debt Collection Practice Act (FDCPA)], and more recently, our clients regulations (Health Insurance Portability and Accountability Act (HIPAA).  This section details aggressive efforts to ensure compliance.




All procedures were reviewed in light of Protected Health Information (PHI).  For your convenience, listed below, and in the pages that follow, is a summary of our protective efforts. 


·         Policies and procedures that address the handling, use, disclosure and control of patients’ protected health information have been written.  These procedures address:



Confidentiality statements      Improper disclosure of PHI

Disclosure of PHI                   Accounting for PHI disclosure

Computer security                   Protecting downloads

Employee termination             Sub-contractors

Facsimile usage                       Destruction of PHI

E-Mail usage                           Compliant/Grievance channels


·         On-going employee awareness programs are in place to educate the work force on written HIPAA policies and procedures.

·         HIPAA compliant sub-contractor (business associate) agreements are drafted.

·         Complaint and grievance procedures that are available to patients are written and understood by employees.

·         We continue to participate in seminars, conferences, and meetings with various trade associations.




Internal guidance is provided via an FDCPA sign-off program.  This program encompasses reading material sponsored through the American Collectors Association.  In addition, training programs allow for the observance of experienced collectors, telephone monitoring technology, and throughout employment, very close supervision located within each collection area.

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