Collector - March 2018 - 36

HEALTHCARE

Understanding the Credit Reporting Landscape
Requirements are stricter for debt collection agencies that include credit reporting in
their collections process. Here's what you need to know.
By Katy Zillmer

T

he current credit reporting
landscape is complicated-
especially when it comes to
medical debt.
Increased regulatory requirements,
outside of the Fair Credit Reporting
Act and Health Insurance Portability
and Accountability Act, add to that
complication-but ultimately agencies have
the opportunity to decide what works best
for them and their clients.
It's important to evaluate that decision
on a regular basis based on feedback from
clients and taking into account risks on the
compliance front.

HOW IT STARTED
The FCRA and HIPAA include various
credit reporting requirements agencies
must comply with, in addition to standards

36

from individual consumer reporting
agencies (CRAs). The laws also permit the
reporting of medical information to CRAs,
with some restrictions.
Regulations increased as a result of a
2015 settlement agreement with multiple
state attorneys general, and the three major
nationwide CRAs-Experian, Equifax,
and TransUnion-launched the National
Consumer Assistance Plan (NCAP), which
took effect in September 2017.
Debt collection agencies or their clients
generally have a period of seven years to
report medical accounts, unless state law
provides for a different time period. The
seven-year reporting period begins to run
180 days after the date of delinquency.
The NCAP includes more requirements
when it comes to the date of delinquency.
For example, the date of first delinquency

with the original creditor needs to be
determined by the provider and furnisher
based on the underlying financial
agreements and the creditor's policies for
when an account becomes delinquent.
The 180-day reporting requirement after
the date of delinquency is one of many
factors that influence agencies' and clients'
choice to engage in credit reporting.
"The new rules are not difficult to comply
with; however, in general there's been a trend
over the past couple of years where medical
debt has been in the spotlight from a creditor
standpoint and a regulatory standpoint," said
Donna Nicholson Stief, executive director of
the Credit Bureau of Lancaster County Inc.
ACA International members report
that since the 2017 NCAP requirements
took effect-and even before that-credit
reporting, especially medical debt, has been

ACAINTERNATIONAL.ORG


http://www.ACAINTERNATIONAL.ORG

Table of Contents for the Digital Edition of Collector - March 2018

From the Editor
Industry News
Best Practices
FYI
Collection Tips
Enriching the Diversity Conversation
A New Take on Skiptracing
Collecting From Different Generations
Calendar
Honor Roll
Are You an ACA Professional Collection Specialist?
Understanding the Credit Reporting Landscape
An Inside Look at ACA’s Judicial Advocacy Efforts
Break It Down
ACA Files Amicus Brief with Court of Appeals in Case Combatting TCPA Abuse
Compliance
ACA SearchPoint
Last Word
Collector - March 2018 - Cover1
Collector - March 2018 - Cover2
Collector - March 2018 - 1
Collector - March 2018 - 2
Collector - March 2018 - 3
Collector - March 2018 - From the Editor
Collector - March 2018 - 5
Collector - March 2018 - Industry News
Collector - March 2018 - 7
Collector - March 2018 - 8
Collector - March 2018 - 9
Collector - March 2018 - Best Practices
Collector - March 2018 - 11
Collector - March 2018 - FYI
Collector - March 2018 - 13
Collector - March 2018 - Collection Tips
Collector - March 2018 - 15
Collector - March 2018 - Enriching the Diversity Conversation
Collector - March 2018 - 17
Collector - March 2018 - 18
Collector - March 2018 - 19
Collector - March 2018 - 20
Collector - March 2018 - 21
Collector - March 2018 - 22
Collector - March 2018 - 23
Collector - March 2018 - A New Take on Skiptracing
Collector - March 2018 - 25
Collector - March 2018 - 26
Collector - March 2018 - 27
Collector - March 2018 - Collecting From Different Generations
Collector - March 2018 - 29
Collector - March 2018 - 30
Collector - March 2018 - 31
Collector - March 2018 - Calendar
Collector - March 2018 - Honor Roll
Collector - March 2018 - Are You an ACA Professional Collection Specialist?
Collector - March 2018 - 35
Collector - March 2018 - Understanding the Credit Reporting Landscape
Collector - March 2018 - 37
Collector - March 2018 - An Inside Look at ACA’s Judicial Advocacy Efforts
Collector - March 2018 - 39
Collector - March 2018 - Break It Down
Collector - March 2018 - 41
Collector - March 2018 - ACA Files Amicus Brief with Court of Appeals in Case Combatting TCPA Abuse
Collector - March 2018 - 43
Collector - March 2018 - Compliance
Collector - March 2018 - 45
Collector - March 2018 - ACA SearchPoint
Collector - March 2018 - 47
Collector - March 2018 - Last Word
Collector - March 2018 - Cover3
Collector - March 2018 - Cover4
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