CFPB to Revoke Guidance Prohibiting Debt Collectors from Collecting Medical Debts Not Owed

April 14, 2025 — Press Release

CFPB’s 2024 Guidance Sought to Prevent Deceptive and Unfair Medical Debt Collections

BOSTON – Sick or injured people may be more likely to be confronted by debt collectors attempting to collect medical bills they do not owe in the near future. Despite significant research about the problems caused by medical debt, the Consumer Financial Protection Bureau (CFPB) announced in a court filing on Friday that it was planning to abandon its recent guidance to debt collectors about how deceptive and unfair collection of medical debt may violate the federal Fair Debt Collection Practices Act (FDCPA).

“Instead of ensuring that debt collectors comply with the law, the CFPB is ready to walk away from guidance protecting consumers from the collection of medical debts that are not owed,” said April Kuehnhoff, senior attorney at the National Consumer Law Center.

The CFPB’s guidance – issued just six months ago – reminds debt collectors of their strict liability under the Fair Debt Collection Practices Act (FDCPA) if they: 

• collect on medical debts not owed, 
• collect for medical services not received, or 
• lack documentation of the alleged medical debt. 

It also clarifies when a debt is “in default” in order to address efforts by some medical debt collectors to avoid FDCPA liability. 

Ongoing Efforts to Defend the Medical Credit Reporting Rule

The guidance on collection of medical debts is separate from the CFPB regulation removing medical debt from credit reports, which is also under attack. NCLC opposes efforts in the U.S. House and Senate to repeal the regulation, and NCLC is also seeking to defend the regulation in court by asking judges to allow NCLC’s clients to intervene in two lawsuits challenging the regulation.

“Debt collectors and credit bureaus want to keep ruining the credit reports of 15 million people by continuing to report medical debt on them,” said Chi Chi Wu, senior attorney at the National Consumer Law Center. “Many of these medical debts are inaccurate or disputed, but credit reporting puts pressure on them to pay the bills to avoid damaging their credit scores.  We will fight in Congress and in the courts to preserve this rule.”

Related Resources

• NCLC Press Release, Consumers and Groups File for Right to Defend Rule Removing Medical Debt from the Credit Reports of 15M People (Feb. 13, 2025).
• NCLC Take Action, Tell Congress: Medical Debt Must Get Off Credit Reports – Support CFPB Rule (Jan. 15, 2025).
• NCLC Press Release, CFPB Rule Removes Medical Debts from Credit Reports (Jan. 7, 2025).
• Debt Collection Practices (Regulation F);  Deceptive and Unfair Collection of Medical Debt, 89 Fed. Reg. 80715 (Oct. 4, 2024).
• NCLC Press Release, White House Efforts Will Reduce Medical Debt, Protect Consumers from Harmful Debt Collection (Oct. 1, 2024).