ACA members dissect itemization date requirements and working with health care clients in final ACA Huddle on part two of the CFPB’s debt collection rule. Editor’s note: This article is available for members only.
1/15/2021 16:30
Medical debt adds another layer of compliance with the Consumer Financial Protection Bureau’s final debt collection rule, which ACA International members Pam Kirchner, CEO of BCA Financial Services Inc., and Shawn Gretz, president of Americollect, reviewed in a presentation concluding the ACA Huddle CFPB Rule Series Friday.
In the presentation, “Itemization of Medical Debt, Creditors and Medical Providers,” Gretz and Kirchner reviewed the itemization date definition and rules. They explained that once you pick an itemization date, stick with it.
In other words, while the medical debt compliance requirements are complicated, a good rule of thumb is to be consistent.
Here are a few pointers on the definition of the itemization date that is the best fit for medical debt, according to Section 1000.34 of the rule on notice of validation debts.
The definition of the itemization date means any one of the following five reference dates for which a debt collector can ascertain the amount of the debt:
- The last statement date, which is the date of the last periodic statement or written account statement or invoice provided to the consumer by a creditor;
- The charge-off-date, which is the date the debt was charged off;
- The last payment date, which is the date the last payment was applied to the debt;
- The transaction date, which is the date of the transaction that gave rise to the debt; or
- The judgment date, which is the date of the final court judgment that determines the amount of the debt owed by the consumer.
Gretz and Kirchner also reviewed best practices for the itemization of multiple debts and how to make it understandable for the patient.
They detailed what information to include on the validation notice for the consumer including the itemization date, the amount of the debt owed on the itemization date and the amount of the debt owed at the time the notice is sent.
When it comes to medical debt, it’s also important to consider how to handle disputes if multiple debts are included in a single validation notice, balance increases due to late charges, payment reversals and debit adjustments, and addition of interest after an account is placed with a collector.
Remember, once you pick an itemization date option, stick with it when communicating with the consumer.
Learn more from the medical debt presentation on ACA’s CFPB Rule Series website (part two) which will be available by early next week. Recordings and presentations for each ACA Huddle on the rule are also available on the website.
ACA’s panel of experts continues to review the comprehensive rule and will be providing detailed analysis and compliance resources through articles, member alerts and additional webinars.
Thank you to the sponsors of part two of the daily ACA Huddle CFPB Rule Series, Neustar and Ontario Systems.
The weekly ACA Huddle, sponsored by Connect International, will resume at 11 a.m. CST Jan. 20, with a discussion on the Paycheck Protection Program and the significant expansion of the employee retention credit with principals from CliftonLarsonAllen LLP Jennifer E. Rohen and Jack Rybicki. Click here to complete a one-time registration for the weekly ACA Huddle.
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