Washington, DC Today, the Consumer Financial Protection Bureau (CFPB), the U.S. Department of Health and Human Services (HHS), and the U.S. Department of the Treasury (Treasury) launched an investigation into high-cost, specialty financial products, such as medical credit cards and installment loans, that are paid to patients as a way to pay for routine medical care and which Lead to increased health care costs and medical debt. Today’s request for information is based on CFPB’s research on medical payment products, billing, and medical collections, as well as other actions taken by CFPB and federal agencies for medical debt relief and collection practices. The three agencies are seeking information about the prevalence of these products, patients’ experiences with them, and incentives for healthcare providers to offer these high-cost products to patients, which may include avoiding the insurance claims process and financial assistance programs. The CFPB will use public input as it studies ways to address patient harms caused by these specialized financial products.
“Financial companies are partnering with healthcare players to push products that can drive patients deeper into debt,” said CFPB Director Rohit Chopra. “We are opening a public inquiry to better understand how these practices affect patients in our country.”
“This inquiry builds on the department’s work to protect patients from unfair billing practices, lower costs, and increase transparency in our healthcare system,” said HHS Secretary Xavier Becerra. “Hearing directly from patients about their experiences will help shape policies that can prevent families from taking on medical debt.”
“The Treasury Department is proud to partner with agencies across the Biden administration to eliminate these often abusive practices that take advantage of patients in times of vulnerability. We look forward to receiving stakeholder input so we can better protect patients and consumers,” said Deputy Treasury Secretary Wally Adeyou. .
Medical payment products were previously used primarily to pay for care not traditionally covered by health insurance plans, such as dental and vision care, fertility services, and plastic surgery. However, medical payment products are now also used to pay for a broader range of services, including emergency room visits and primary and specialty care. Even when Medicare can be covered by insurance or financial assistance, these products may be offered by healthcare providers to patients who then pass patient billing and collection management to financial services firms. CFPB research highlighted that health care providers may be discouraged from explaining legally mandated financial assistance programs or interest-free payment options before offering these products to patients. These products can also burden patients with inflated deferred interest or creditor lawsuits.
Given the current complexities of financial assistance programs and insurance plans, health care providers can experience difficulties when trying to receive payment for care. These challenges may encourage them to suggest that patients and families finance their care through specialized credit products. While these products may ease administrative burdens for healthcare providers, they do so by shifting burdens onto patients.
The RFI will help agencies better understand the consumer harms and financial challenges posed by specialty medical payment products. The RFI will provide the consumer’s voice in the agencies’ next steps about these products; For a CFPB, it includes the procedures for credit creation, debt collection, and the credit reporting practices of the financial companies that create and serve these products. Specifically, agencies ask for information about:
- Specialized Medical Payment Products Market. Agencies are interested in data and feedback on the benefits and fee costs of these products, as well as in understanding the marketing, application, and approval processes. The CFPB is also interested in trends in the use of medical payment products, including total consumer debt owed on medical credit cards, medical installment loans, and other medical payment products. The data will help agencies better understand how these products are used, the scope of their use, and who controls their use.
- Patient experiences and downstream consequences. The agencies want to know more about the risks of these products, and whether consumers fully understand the risks. Risks of paying medical bills using a medical payment product may include loss of the ability to negotiate medical bills, aggressive debt collection practices, lawsuits, and loss of credit report protection.
- Billing issues and financial assistance. The agencies want to know more about how credit cards and medical loans may exacerbate existing problems with health care billing and collections. For example, uninsured and out-of-network patients are often charged rates higher than those negotiated by in-network insurance companies for the same medical services. Medical payment products may enable providers to continue to charge high rates to uninsured or self-pay patients who would otherwise not be able to pay.
- Health care provider incentives. Agencies want to know more about incentives for healthcare providers to promote medical payment products, as well as how those incentives affect the promotion of these products by providers of care to patients. In some cases, this may include a share of the proceeds from these products. Other medical payment product issuers offer lower administration or processing fees to providers who register large numbers of patients – incentivizing medical providers to enroll as many of their patients as possible.
The CFPB encourages comments and statements from the public and all interested stakeholders. Comments must be received within 60 days of the request for publication of the information in the Federal Register.
Read today Interagency request for information about medical payment products.
Customers may submit complaints about financial products or services by visiting the CFPB website or by calling (855) 411-CFPB (2372).
The Consumer Financial Protection Bureau (CFPB) is the 21st century agency that helps consumer finance markets function by making rules more effective, by applying those rules consistently and fairly, and by enabling consumers to have more control over their economic lives. For more information visit www.consumerfinance.gov.