Medical Debt and Reg F: Communication, Communication, Communication

Health Care Reports

How collection agencies can work with their clients  on Reg F compliance.

11/4/2021 9:00

As accounts receivable management (ARM) industry professionals make final preparations for Reg F compliance before Nov. 30, there are long-term takeaways to remember when it comes to health care collections and communication with clients and consumers.

In the ACA International 2021 Fall Forum session Managing Client Communications—Reg F Communication for Dummies, speakers Jack Brown III, president Gulf Coast Collection Bureau of Tim Haag, president of State Collection Service Inc., and Courtney Reynaud, president of Creditors Bureau USA, discussed tips and suggestions on how to communicate what creditors need to know about Reg F and its impact on their revenue cycle.

For Reynaud, it started with email communications with clients when Reg F was released and engaging with them on the front end to determine their needs and expectations.

For many, the last year has been about drilling down into the itemization date and helping clients navigate challenges with Reg F, such as the application of consent requirements to enable the debt collector to communicate with the consumer via text, email, and social media platforms. Brown said one of the key takeaways is that you can never overcommunicate with your clients.

The speakers found that communication opens you to opportunities to learn about clients’ other preferences and questions.

It’s also a good reminder to review those expectations regarding Reg F during your next compliance audit with your clients.

Reg F and Multiple Medical Accounts

In the second health care session at Fall Forum Thursday, speakers reviewed how to work with multiple medical accounts from the same provider and remain compliant with Reg F.

Richard Perr, co-managing partner at Kaufman Dolowich Voluck, Roger Weiss, IFCCE, president of CACi, and Colin Winkler, ACA’s corporate counsel, hosted the standing-room-only panel session to outline how medical debt is different from other types of debt—especially because consumers often don’t purposefully incur the bill resulting in the debt.

Medical debt bills may even have a smaller balance than other forms of consumer debt but come with more challenges to collect under state and federal laws.

The consumer may be facing economic challenges and their ability to pay is based on their other finances.

Looking ahead, the panel told attendees to be mindful of the date they include on letters and postmark dates as Nov. 30 approaches. If a consumer receives communications that are not compliant with Reg F that were sent or postmarked before the rule took effect Nov. 30, it could prompt legal challenges for an agency.

The discussion also covered how to list accounts from multiple creditors in one letter, call frequency, and reminders on itemization date requirements.

For agency clients, they may mostly want to know that consistency is key with the itemization date under Reg F. It can be the last statement date, charge-off date, last payment date, transaction date or judgment date, as long as the debt collector is consistent.

Remaining sessions on health care during Fall Forum included Partnering with Your Health Care Clients for Compliance with Regulation F and The Future of Health Care Collections—How Technology is Going to Change the Game.

Thank you to our 2021 Fall Forum sponsors: Prodigal, BaltoProvana, Payscout, Solutions by TextBeam Software, Maurice Wutscher, VoApps DirectDrop Voicemail, Recovery Management Solutions and Debt$Net Collection Software.

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