As of June 15, 2016 your medical collection agency’s credit bureau requirements changed, and soon your practice’s will too.
In March of 2015 the nation’s three leading credit reporting agencies (CRAs) – Equifax, Experian, and TransUnion – entered into an agreement with the New York Attorney General’s office. The National Consumer Assistance Plan was designed to enhance the bureaus’ ability to collect complete and accurate information, and to provide consumers with more transparency and better resolution processes.
While the plan originated in New York as a result of an investigation into the consistent complaints filed by that state’s residents regarding erroneous reports, identity theft, and fraud, the bureaus have since entered into cooperative agreements with the Attorneys General of more than 30 states across the country. The result is changes to credit reporting practices that will affect collection agencies and data furnishers, include healthcare organizations, alike. For an in-depth discussion of these changes, watch our Credit Reporting Compliance Update webinar on demand.
What are some of the changes made by the National Consumer Assistance Plan?
Timeline for Action
When the National Consumer Assistance Plan was signed, a three-year timeline for implementation was created to allow the bureaus, and all agencies and data furnishers, time to comply. The first deadlines impacting collection agencies and debt buyers were effective as of June 15, 2016. These data reporting requirements included:
- Reporting the name of the Original Creditor and Creditor Classification Code for each account or item reported
- Can no longer report debt that did not arise from a consumer contract or agreement to pay, including (but not limited to) certain fines and fees, tickets, and other assessments
Additionally, as of September 1, 2016, agencies must begin reporting a full file monthly including accounts that are open, that are paid in the last 90 days, or that require deletion or correction. This is to avoid potential deletion of data by the CRA’s.
What does this mean for your healthcare organization? These new initiatives mean more work by medical collection agencies on your behalf to ensure that your patients’ data is being properly reported. They may require additional information from you on each file to ensure they are reporting all required information in a timely manner. Developing a good relationship with regular communication will become more important than ever in the wake of these new changes. Read our coverage of the announcement and the plan from March 2015 here.
The next round of requirements to become effective will have a much larger impact on the healthcare industry. As of September 15, 2017 the following initiatives will take effect:
- Collection agencies can no longer report medical debt collection accounts less than 180 days old. This waiting period is meant to provide additional time to resolve delinquencies resulting from disputes or delays on the part of third-party payers. While this will benefit the volume of patients who are unfairly or unknowingly reported as a result of discrepancies with their insurance companies, it also means accounts must age six months before your practice can take recourse via credit reporting. Because the cost of collections only increases over time, your practice must make even more efforts to collect at the time of service.
- All accounts that are being paid or have been paid in full by insurance companies must be reported for deletion. This new requirement aims at rectifying any negative reports resulting from payment delays or disputes from third-party payers. Once the debt has been paid by the insurance company it will be removed entirely from the report. This is unlike other paid accounts that can remain on the consumer’s credit report for several years.
New Requirements for your Practice
The new changes taking affect do not only apply to collection agencies. A new minimum standard has been established to expand the CRA’s capabilities to match credit data to the file of the appropriate consumer. This new minimum standard will apply to accounts reported with a date opened after September 15, 2017 in order to be accepted for processing.
Furnishers will be required to provide the following information for all reported accounts or items:
- Full name (First, Middle Name or Initial if available, Last Name and Suffix)
- Full social security number (if not available, a full date of birth will be required)
- Date of birth
This means more diligent reporting requirements for both your practice and your medical collection agency. Our third-party medical collections team currently requires a date of birth for all files to be reported, and we suggest this as a best practice, as well as adhering to other practice information requests from your agency in order to provide a complete file. If the bureaus do intend to closely police these new rules then the result will be reduced reporting ability, so getting into the practice of providing complete information now could help make the transition easier.
Each of the bureaus has a contact available for questions relating to the new requirements under the National Consumer Assistance Plan:
- Equifax: DataOperation@Equifax.com
- Experian: DataReporting@Experian.com
- TransUnion: TUDAS@TransUnion.com
For more information on recent credit reporting regulation changes, and your rights & responsibilities as a creditor, download our free Guide to Reporting Medical Debt
Written by Ali Bechtel, Digital Marketing Manager
Source: All data for this article was from an internal communication to AR Logix as a medical debt collection agency by email@example.com
This information is not intended to be legal advice and may not be used as legal advice. Legal advice must be tailored to the specific circumstances of each case. Every effort has been made to assure this information is up-to-date as of the date of publication. It is not intended to be a full and exhaustive explanation of the law in any area, nor should it be used to replace the advice of your own legal counsel.