CFPB’s Annual Report on Medical Debt: A Need for Caution 

The Consumer Financial Protection Bureau (CFPB) recently released its annual report to Congress on the Fair Debt Collection Practices Act (FDCPA), with a significant focus on medical debt collection and consumer complaints tied to health care providers’ financial assistance programs. However, concerns have been raised about the accuracy of some claims, which rely solely on reports from the CFPB’s Consumer Complaint Database. 

Concerns Over Medical Debt Reporting 

The CFPB’s report highlights issues with the accuracy of medical debt reporting on consumer credit reports, often using the rate of disputes as an indicator of errors. However, disputes may reflect broader challenges related to medical debt rather than a widespread issue of inaccuracies. Moreover, the reliance on the Consumer Complaint Database has been questioned, as the database contains duplicate and unverified entries. A single consumer complaint, without further verification, should not be viewed as indicative of a broader systemic problem.  

Using this unverified data as the foundation for large-scale regulatory changes raises concerns. Instead, such data should serve as a prompt for further research and investigation into potential issues. 

The Role of Debt Collectors in Resolving Medical Debt 

Debt collectors play a critical role in helping patients resolve their medical debt by working with hospitals and health care providers. This collaboration assists patients in managing their financial obligations, while also contributing to the efficient operation of the health care system’s revenue cycle. 

The Importance of Better Data and Research 

The CFPB’s report also addresses general trends in the debt collection industry, with a focus on medical debt credit reporting. However, there is a need for more current and comprehensive data to fully assess the impact of recent changes in medical debt credit reporting. Relying heavily on isolated complaints without contextualization may lead to misguided regulations that do not reflect the realities of medical debt collection. 

Consumer Complaint Analysis 

In 2023, the CFPB received around 109,900 debt collection complaints, with 69,000 forwarded to companies for review. Approximately 7,400 of these complaints—11%—were related to attempts to collect medical bills. The CFPB reports that fewer than 0.1% of the complaints remained unresolved with either the consumer or the bureau as of March 2024. 

Companies responded to 97% of the debt collection complaints forwarded to them, demonstrating a high level of industry responsiveness. 

Looking Ahead 

As the CFPB continues to propose new rules and issue reports on the debt collection industry, it is essential that data be properly contextualized, and conclusions be based on verified and comprehensive research. This approach will ensure that future regulations accurately reflect the complexities of medical debt collection and credit reporting, protecting both consumers and businesses alike. 

Author:  Jennifer Evancic

Jennifer.Evancic@ResourceManagement.com

Jennifer Evancic is a third-party auditor valued by creditors and large organizations for her knowledge in call monitoring within the collections industry. With meticulous attention to detail and a firm grasp of regulatory requirements, she ensures compliance with clients’ criteria and state and federal regulations.

Jennifer audits collections calls, ensuring they meet client-specific criteria and comply with regulations, providing valuable insights and maintaining industry standards.

Beyond her auditing responsibilities, Jennifer takes the lead in organizing and facilitating monthly call calibrations. These sessions serve as a collaborative forum where clients and their vendors come together to discuss call monitoring results and address any findings or areas for improvement. Jennifer’s guidance fosters open communication and ensures alignment between clients and vendors, driving continuous improvement in collections practices.

Jennifer stays up-to-date with compliance and industry best practices by participating regularly in peer meetings, regulatory updates and industry webinars. This keeps her informed about emerging issues and ensures she remains a knowledgeable leader in collections compliance.

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