By Katy Zillmer
healthcare
CRAs Agree to Policy Overhaul
Three consumer reporting agencies announce changes to medical debt reporting
Three of the major U.S. consumer reporting agencies, Equifax, TransUnion and
Experian, recently announced a new
National Consumer Assistance Plan,
which includes changes to reporting
consumers’ medical debts. The plan
became effective in the state of New
York on March 8 after cooperative
discussions and a settlement agreement
between the agencies and New York
Attorney General Eric Schneiderman. It
will eventually be implemented
nationwide, according to the attorney
general’s office.
The Plan
The new plan for the CRAs aims to
enhance their ability to collect complete
and accurate consumer information and
will provide consumers more
transparency and a better experience
interacting with credit bureaus about
their consumer credit reports.
ACA International, as part of a
Medical Debt Collection Task Force led
by the Healthcare Financial
Management Association, contributed to
developing best practices, released just
over a year ago, to help make paying
medical bills an easier and fairer
proposition for consumers. The best
practices for healthcare providers and
their business partners include following
up with CRAs when a consumer’s
account is resolved.
The National Consumer Assistance
Plan announced by Equifax, Experian
and TransUnion also includes following
up with CRAs, and focuses on
enhancements in two primary areas:
consumer interaction with national
CRAs and data accuracy and quality.
180 Days
The settlement agreement between
the New York attorney general and the
CRAs that likely resulted in the National
Consumer Assistance Plan states, “CRAs
shall prevent the reporting and display of
medical debt identified and furnished by
collection furnishers when the date of
the first delinquency is less than 180
days prior to the date that the account is
reporting to the CRAs.”
This means medical debts won’t be
reported until after a 180-day waiting
period from the date of delinquency.
Date of delinquency, as defined in the
Fair Credit Reporting Act, is “the month
and year of the commencement of the
delinquency on the account that
immediately preceded collection activity,
charge to provide or loss, or similar
action.”
This date needs to be determined by
the provider and furnisher based on the
underlying financial agreements and the
creditor’s policies for when an account
becomes “delinquent.”
Typically, the date of delinquency will
precede the date of placement with the
agency.
The 180-day waiting period for
reporting medical debts in the agreement
will allow insurance
payments to be applied,
according to the New York
attorney general. The
CRAs will also remove
previously reported
medical collections that
have been or are being paid
by insurance from
consumers’ credit reports.
Debt collection
agencies whose healthcare
provider clients request
that they report
consumers’ accounts to the three CRAs
also rely on them to follow up when the
account is paid.
Implementation
Implementation of the requirements
will occur over three years and 90 days
from the March 8 effective date and
includes three phases.
Requirements for medical debt
collections, including the delay of
sending accounts to CRAs and removing
paid medical bills from consumers’ credit
reports, are included in phase three.
CRAs have until the completion date to
meet those requirements.
CRAs have within six months from the
effective date to complete phase one and
18 months from the effective date to
complete phase two of the
implementation plan.
As more details on the agreement
emerge, it’s important for agencies
working in healthcare collections and
their healthcare provider clients to
communicate about their expectations
and plans going forward.cm
Katy Zillmer is a communications
specialist for ACA International.