The comments period regarding the Consumer Financial Protection Bureau’s proposed rule that would prohibit creditors from using medical debts when determining whether a consumer is eligible for credit closed last week, but there are a lot of comments to pore through. To provide insight into the tone of the comments being filed, AccountsRecovery.net is sharing some of those comments here. To date, 1,076 comments have been filed and are available to be viewed. Here is a summary of some of the complaints that have been submitted. Click on the arrow next to a summary to read the full comment. In some browsers, there is no arrow next to the summary. In that case, just click on the text to view the entire comment.
In addition to the regulatory changes that have already been proposed, the County urges consideration of an additional rule prohibiting the furnishing to a credit reporting agency, and the reporting by a credit reporting agency, of debt arising from third-party medical financial services. The County is concerned that allowing the continued reporting of debt sourced from these products, specifically medical credit cards and medical installment loans with high interest rates and deferred interest promotions, will incentivize medical providers to promote these payment options for non-elective and emergency medical services. The issue with including these products is that it is difficult to separate loans for elective medical services, which reflect the debtor’s creditworthiness, from loans for non-elective services, which are often taken out of necessity and under duress. We recommend restricting reporting of any debt arising from these products unless the medical provider and consumer both attest to the elective nature of the service. This would transfer the responsibility to the medical and financial industries to clearly delineate between necessary and elective medical care, and only report debt from the latter when reporting to a credit agency. Furthermore, the County recommends that the aim should be to restrict the prevalent industry practice of reporting medical debt in all its forms to credit reporting agencies because this broader approach ensures that all forms of potentially inaccurate and unfair medical debt reporting are addressed, providing comprehensive protection for consumers.
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LA County Public Health Department 👍
Medical Group Management Association 👎🏻
Medical practices offer payment plans, sliding fee programs, and charity care to ensure patients can have access to physicians despite these systemic shortfalls. However, many groups report these services are increasingly difficult to provide or that they lack the resources to provide these flexibilities whatsoever. For those that outsource debt collection practices, this proposed regulation is likely to represent another impediment to their ability to collect payment for clinical services rendered, impacting their ability to pay staff, cover overhead costs, and ultimately provide care for their communities.
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H&R Accounts 👎🏻
It is irresponsible to lead consumers to believe that nothing within their medical services world will change and there will not be negative impacts to them from the implementation of this bill. Most hospitals and health systems operate on extremely low margins, and even a 2-3% reduction in payments could be the difference between being able to provide services or having to close their doors or stop providing services that are losing money.
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Kimberly Scaccia, Vice President of Revenue Cycle at Mercyhealth Systems 👎🏻
The current proposed rule stands to impact over sixty million dollars in our receivable operations, which directly affects our financial model and would therefore negatively impact the patients we are here to serve. … Unfortunately, by passing this ruling as writien, the CFPB will eliminate the only option that healthcare providers have in pursuing amounts owed that otherwise would result in litigation. Litigation is an unpleasant process for all involved, it is expensive and the resulting wage garnishments would further drive-up administrative healthcare costs in this country.
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Susan G. Komen 👍
Komen strongly support the CFPB’s proposed rule prohibiting creditors from obtaining and using
information on an individual’s medical debt when making credit determinations. This proposal protects
consumers’ sensitive medical information and stops people from being unfairly penalized in the credit
market for having medical debt which can often be unavoidable for patients … Komen recommends that CFPB broaden the definition of medical information to include debt accrued on medical financing instruments such as medical credit cards. Last year, Komen joined other patient organizations in responding to the CFPB’s Request for Information Regarding Medical Payment Products, highlighting the multiple harms of these forms of financing medical care, including high interest rates and significant transaction fees. We look forward to future rulemaking on medical financing instruments and recommend that, at a minimum, the medical information definition be expanded to include debts carried on these cards.
Click here to read the full comment letter.
