The Consumer Financial Protection Bureau (CFPB) recently issued an advisory opinion regarding 12 CFR Part 1006 – Debt Collection Practices (Regulation F). This advisory highlights the responsibility of debt collectors to comply with the Fair Debt Collection Practices Act (FDCPA) and reinforces the prohibitions on:
- False, deceptive, or misleading representations in connection with medical debt collections
- Unfair or unconscionable means to collect or attempt to collect medical debts
- Processes that result in duplicate billing
Given these enhanced compliance expectations, it is critical that healthcare providers and outsourced revenue cycle management (RCM) partners—like Revenue Enterprises—adhere to these regulations to avoid potential liability stemming from inaccurate or invalid medical debts.
To ensure collection efforts are both accurate and effective with your RCM partners, it is significantly important that facilities:
- Provide the most current and accurate balance information for collections and patient statements to ensure that only valid debts are pursued and patients receive accurate communications.
- Before assigning accounts to your RCM partner, verify that insurance carriers have been properly billed and that their remittances and adjustments are accurately posted to patient account balances.
- Schedule regular delivery of inventory files to facilitate consistent reconciliation and ensure that RCM records align with your EHR system(s), eliminating discrepancies that could lead to compliance issues.
At Revenue Enterprises, we are deeply committed to compliance and consumer protection. As your trusted partner, we uphold these values in all our actions. We:
- Prevent duplicate billing with automated processes to identify and eliminate duplicate accounts before billing.
- Comply with all legal recovery regulations, ensuring legal fees are fair, customary, and disclosed to patients. We also confirm that client Consent Forms include language informing patients of their responsibility for legal fees incurred during collections.
- Bill only for balances assigned by our clients, maintaining transparency and integrity at every step of the process.
- Clearly communicate consumer rights through patient statements and our payment portal, including information about financial assistance programs and how patients can dispute balances.
Should you have any questions or require further information, please do not hesitate to contact us!