Medical Payment Products and Health Care Pricing Practices Draw CFPB Attention
The Consumer Financial Protection Bureau ("CFPB"), Department of Health and Human Services ("HHS"), and United States Treasury have issued an interagency Request for Information ("RFI") focused on the offering and provision of financing to consumers for health care procedures and services. The RFI signals a renewed focus on, and potential scrutiny of, the practices of health care providers, lenders, and credit card issuers, as well as those who own or control such health care providers, including private equity investors and other asset managers. This White Paper discusses the RFI and its potential implications for health care providers and those involved in financing health care services. In addition, the White Paper identifies steps to consider taking in anticipation of the CFPB conducting inquiries into the use of medical payment products and collecting related debt. And it highlights the real possibility that the CFPB may attempt to stretch the scope of its regulatory authority by using the RFI and any follow-on investigations as a basis to broadly scrutinize the underlying pricing practices used by health care providers.
