September 13, 2023 – Washington, D.C. – ACA International (“ACA”) has responded to the Consumer Financial Protection Bureau (“CFPB”) Request for Information (“RFI”), made in partnership with the Centers for Medicare and Medicaid Services (“CMS”) and the U.S. Department of the Treasury, on medical payment products.
ACA outlined concerns about the CFPB’s haphazard approach to seeking to regulate issues outside of its jurisdiction and congressional authority.
“The CFPB has not engaged in meaningful conversations with stakeholders in the health care or debt collection markets beyond the targeted collection of anecdotal information from select groups,” said ACA CEO Scott Purcell. “A good example of this is the recent July 11, 2023, CFPB hearing on Medical Billing and Collections, where this RFI was discussed. The hearing included no medical providers or hospitals, and instead included mostly a sounding board of government employees and consumer advocacy groups.”
As an overarching matter, ACA does not believe the CFPB should take any actions related to limiting options for health care providers without robust and data-driven research proving that they will not harm the ability to access medical services or the ability to offer and be compensated for medical care provided.
ACA represents approximately 1,700 members, including credit grantors, third-party collection agencies, asset buyers, attorneys, and vendor affiliates, in an industry that employs more than 125,000 people worldwide. Most ACA member debt collection agencies are small businesses.
The accounts receivable management (“ARM”) industry is instrumental in keeping America’s credit-based economy functioning with access to credit at the lowest possible cost, thereby protecting one of the safety nets of the most vulnerable consumers in society from unplanned expenses. For example, in 2018, the ARM industry returned over $90 billion to creditors for goods and services they had provided to their customers. And in turn, the ARM industry’s collections benefit all consumers by lowering the costs of goods and services— especially when rising prices are impacting consumers’ quality of life throughout the country.
Read ACA’s complete comments on the RFI here.
ACA is the largest membership organization in the accounts receivable management industry. Founded in 1939, ACA brings together third-party collection agencies, law firms, asset buying companies, creditors and vendor affiliates representing industry professionals. ACA produces a wide variety of products, services and publications, including educational and compliance-related information; and articulates the value of the accounts receivable management industry to businesses, policymakers and consumers. www.acainternational.org.