The CFPB and other federal agencies’ inquiry explores financial challenges of medical payment products as well as associated debt collection and credit reporting practices.
09/13/2023 10:20 P.M.
2 minute read
ACA International filed comments this week in response to the Consumer Financial Protection Bureau’s latest public inquiry, which focuses on medical payment products.
The request for information from the bureau, in partnership with the U.S. Department of Health and Human Services and the U.S. Department of the Treasury, focuses on the prevalence of medical payment products, patient experiences and the impact of incentives for providers to offer the products.
The federal agencies’ request for comment will help them understand “harms and financial challenges raised by specialty medical payment products,” according to a news release from the bureau.
It also focuses on debt collection and credit reporting practices of the companies that originate and service these products.
ACA noted in the comments (PDF) how the CFPB’s efforts in this area lack meaningful conversations in the health care or debt collection markets.
“The CFPB has not engaged in meaningful conversations with stakeholders in the health care or debt collection markets beyond the targeted collection of anecdotal information from select groups,” said ACA CEO Scott Purcell in the comments. “A good example of this is the recent July 11, 2023, CFPB hearing on medical billing and collections, where this RFI was discussed. The hearing included no medical providers or hospitals and instead included only a sounding board of government employees and consumer advocacy groups.”
As an overarching matter, ACA does not believe the CFPB should take any actions related to limiting options for health care providers without robust and data-driven research proving that they will not harm the ability to access medical services or the ability to offer and be compensated for medical care provided.
“ACA members serving medical providers support their work in a variety of ways, including by stepping into their shoes to collect owed debt and, in less common instances, by buying assets or litigating to enforce contractual obligations,” Purcell said.
ACA concluded the comments noting that it is unclear that the CFPB has the authority to regulate medical providers in many of the ways it contemplates in the request for information, various press releases and statements to Congress.
“Accordingly, ACA continues to remind the CFPB that Congress can make major changes to the U.S. medical system if, through their elected officials, consumers ask them to do so,” Purcell said. “However, the CFPB should not on its own make arbitrary judgments in areas of questionable jurisdiction.”
For more updates on ACA’s advocacy, members are invited to join the ACA Huddle every Wednesday at 11 a.m. central.