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State Healthcare Group Files Comment Opposing Proposed Collection Rule

A trade group representing Florida community health centers has filed a comment with the Consumer Financial Protection Bureau, expressing concern that the proposed debt collection rule “could result in a negative impact on healthcare patients of limited financial resources, advanced age, and/or limited English proficiency.”

A copy of the comment can be accessed by clicking here.

The Florida Association of Community Health Centers represents healthcare providers, many of whom treat individuals with no insurance or who are covered by Medicaid. The proposed collection rule includes several provisions that could have a “potentially unintended impact” on those individuals.

Allowing up to seven calls per week per debt could “jeopardize” the employment status of individuals with outstanding medical debts, the group said in its comment. Likening private debt collection to a service provided by the federal government, the group said that allowing so many phone calls “would be counter-productive and contrary to those implemented by federal agencies such as the Internal Revenue Service (IRS) and the Social Security Administration (SSA), which convey important information in writing and by (certified) mail.”

The association also expressed concerns that collectors should not be excused from providing “linguistically appropriate communication” to individuals, considering that English might not be their first language.

“The proposed changes to FDCPA fail to ensure the receipt and comprehension of the message by the debtor or properly describe the next procedural steps,” the group said in its comment.

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