Maryland Issues Guidance On Medical Debt Laws

The guidance is an overview of three laws with changes for debt collectors and credit reporting agencies in effect Oct. 1.

New guidance from the Maryland Office of Financial Regulation summarizes three medical debt collection laws that took effect this month.

“Together, the bills amend the manner through which medical debt is collected and reported to collection agencies,” the guidance (PDF) states. “Collection agencies and consumer reporting agencies should take note of the relevant changes in the law and ensure they comply with them.”

The laws include:

• Fair Medical Debt Reporting Act (HB 1020) Maryland Gov.

Wes Moore approved HB 1020 in April. The law places new limits on reporting medical debts to consumer reporting agencies, information they can include on credit reports and information a lender can consider in loan decisions. “This prohibits providers of medical services, devices, or products from disclosing any medical debt information to a consumer reporting agency,” the guidance states. “Further, consumer reporting agencies may not create, furnish, or maintain a report that contains any adverse information an agency knows — or should know —relates to medical debt.” Any agreements between health care providers and a debt collector are required to include a clause prohibiting the disclosure of medical debt information to a consumer reporting agency.

• Medical Debt — Complaints for Money Judgement and Real Property Liens (HB 428)

The money judgment and liens law (PDF) requires debt collectors seeking to obtain a money judgment for medical debt to include the consumer’s primary residence address and that the money judgment is for medical debt in the complaint. Debt collectors are prohibited from using money judgments to place a lien on a consumer’s primary residence. Medical debt is defined as “a debt owed by a consumer to a person [or their agent] whose primary business is providing medical services, products, or devices.” The law clarifies that the definition of “medical debt” excludes charges on a general-purpose credit card. “However, if a credit card was specifically opened only to pay for medical expenses, then any debt on that card would be considered medical debt.” The Maryland District Court has updated judgment forms to facilitate these changes.

• Hospitals — Financial Assistance and Collection of Debts (HB 268)

Overall, HB 268 (PDF) “maintains a three-year statute of limitations on medical debt regardless of whether the contract between the hospital and consumer lists the debt as a contract under seal.” Hospitals are required to notify consumers of available financial assistance and provide a 240-day application period. During that time, hospitals may not conduct collection efforts for the medical debt. They are also prohibited from collecting on medical debts under $500 and reporting debts to a credit reporting agency. Hospitals may not charge interest to consumers who are eligible for free or reduced-cost care.

Questions on the guidance may be directed to Assistant Commissioner Clifford Charland at (410) 230-6167 or clifford.charland@maryland.gov.

Additional information on Maryland’s medical debt requirements may be found in the following ACA SearchPoint documents available to members:

Medical debt legislative proposals are expected to be considered in several states in the remainder of 2025 and in 2026.

For more state compliance updates, members are invited to register and join the weekly ACA Huddle at 11 a.m. CDT on Wednesdays.

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