MGMA responds to medical debt proposed rule (August 12, 2024)

August 12, 2024 

Rohit Chopra
Director
Consumer Financial Protection Bureau
1700 G Street, NW
Washington, DC 20552

Re: Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V, RIN 3170-AA54)

Dear Director Chopra:

On behalf of our member medical group practices, the Medical Group Management Association (MGMA) thanks you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information, published in the Federal Register on June 18, 2024. MGMA recognizes CFPB’s efforts to mitigate the negative effects rising healthcare costs have on patients and the U.S. healthcare system, and remains committed to providing high quality, cost-effective, and timely patient care.

With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical group practices ranging from small private medical practices to large national health systems, representing more than 350,000 physicians. MGMA’s diverse membership uniquely situates us to offer the following feedback.

While we recognize the significant burden medical debt places on many Americans and the need for sustainable solutions, we hope the CFPB understands that its proposal incentivizes payment not to be rendered for clinical services provided by physician practices. As opposed to inpatient and facility settings, rarely do the professional fees charged in an ambulatory setting directly result in medical bankruptcy. Yet the CFPB proposal appears comfortable promulgating a blanket approach to shifting patient medical debt resulting from the U.S. healthcare system's shortcomings onto all providers. The inability to adequately address longstanding healthcare reform problems has resulted in numerous federal agencies and Congress heaping administrative burden onto medical groups, all the while cutting federal Medicare payments. Medical groups face yet another proposed 2.8% reduction to Medicare physician payments for 2025 while 92% have reported increased operating costs and struggle to remain financially viable. Hindering medical groups’ ability to be paid for their services only exacerbates these burdens and threatens patient access to care.

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