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2 Issues Affecting Early Out Healthcare Collections in a Shifting Federal Landscape

2 Issues Affecting Early Out Healthcare Collections in a Shifting Federal Landscape

Between the passage of the Affordable Care Act and the creation of the Consumer Financial Protection Bureau (CFPB), healthcare providers have faced many regulatory changes in the last decade. There are two other major changes on the horizon that will have a significant impact on early out healthcare collections:

When you can report a past-account to the Credit Bureau Report

The three major credit reporting agencies have set a 180-day waiting period before a medical debt can be reported on a consumer’s credit report. This change took place on September 15, 2017. This is meant to give the insurance companies and other third-party payers time to process the claims without hurting the consumer’s credit.

The only problem with this new rule is that it was never clarified when the 180 days begins. Is it when the patient is first admitted? Is it from the time they are discharged or when the medical services are completed? Or is it when the consumer first receives the bill in the mail? While this may ultimately be defined in the courts, it would be in your best interest to have a consistent and conservative policy in place now regarding your credit reporting timeline.

New Texas requirement for notice of mediation.

Texas passed a law that went into effect September 1, 2017 that requires servicers of medical accounts to provide notice that mediation is available for some eligible accounts. In most cases, it will only apply to out-of-networks charges more than $500. The law also requires that a disclosure must accompany these charges that reads:


“You may be able to reduce some of your out-of-pocket costs for an out-of-network medical or health care claim that is eligible for mediation by contacting the Texas Department of Insurance at [website] and [phone number].”


The problem lies in determining which accounts are eligible for this disclosure. Sending it to all patients could result in a higher number of requests for mediation; sending it to too few could result in legal action. The disclosure isn’t required on bills incurred on or before January 1, 2018, so you have a few months to sort out a consistent process with your accounts receivable team.

At CBE Companies, we specialize in helping healthcare providers recoup the revenue lost through past-due bills. For top-notch early out and bad debt collection services, contact us today to talk about creating a custom plan for your business.

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