Surprise! Almost no one noticed the No Surprises Act (Act) buried as it was in a 3000-page omnibus spending bill. But it is in effect now. The Consumer Financial Protection Bureau (CFPB) immediately put out a bulletin stating they plan to enforce it. And suddenly, the medical collections industry is in turmoil.
It's a mistake to think the CFPB Bulletin only matters for medical debt covered by the Act. There are implications and lessons here for the entire industry.
The Act was aimed at healthcare billing practices; it created rules for certain types of medical bills and the amounts which can be charged to patients. Although it was not aimed at debt collectors and did not explicitly intertwine with the Fair Debt Collection Practices Act (FDCPA) or Fair Credit Reporting Act (FCRA), the CFPB has stated in no uncertain terms that if a debt collector attempts to collect a debt prohibited by the Act they may face liability under the FDCPA and FCRA. In other words, if a health care provider makes a mistake at the beginning of the billing process, the CFPB expects the debt collector to know that and refrain from collecting the debt.
View this content by subscribing
Please register to unlock this content
I already have an account. Log in
