Numerous changes and proposed rules regarding medical debt and credit reporting have been created, codified, or blocked over the past few years. You may have heard that medical debts in small amounts are no longer reported on credit reports, or that all medical debt has been wiped from reports. It can be difficult to figure out what the rules really are, and those in healthcare and medicine have been asking us: What actually changed? How does this work going forward?

The short answer: it depends. Rules differ across state lines, and federal regulations have been in flux this year. It’s vital for healthcare providers, ambulance services, EMS providers, and their billing partners to understand this ever-changing landscape.

Timeline of changes:

• In January 2022, the No Surprises Act was enacted to address unexpected medical bills that occur from emergencies. The goal of this law is to protect patients by making costs clearer, prohibiting balance billing, and other changes.
• In March 2022, the three major credit bureaus—Equifax, Experian, and TransUnion —announced that they would no longer be including paid medical debts, medical debts less than a year old, and medical debt under $500 on consumer credit reports. It’s estimated that this affected roughly half of consumers with medical debt on their credit reports.
• In January of this year, the Consumer Financial Protection Bureau (CFPB) finalized a rule that would have removed most medical debt from credit reports and prohibited lenders from making credit decisions based on medical debt. This rule was expected to go into effect in March, however, this was prevented by a lawsuit challenging it.
• In July, the rule was blocked by a federal judge in Texas, and the CFPB agreed to vacate the rule. This means that the rule will no longer go into effect.

Although medical debt as a whole has not been removed from credit reports, some states have more restrictions than others when it comes to consumer protections. As of June 2025, 11 states have enacted laws restricting, or even banning, the reporting of medical debt to consumer reporting agencies.

What does this mean for patients?

As stated, it’s complicated. Any ambulance or other unpaid medical bills may show up on their credit report, but they may not. Patients are less likely to see these bills on their credit report if their bills are small, if they are paid off quickly, or if the patient received care in a state with stricter consumer protections. Larger medical debts in collections that go unpaid for more than a year can still affect a patient’s credit score, but credit scoring models like FICO 9, FICO 10, and VantageScore 4.0 weigh them less heavily than other types of debt.

What does this mean for healthcare institutions and medical companies?

Companies that rely on debt collection agencies need to be aware of how the agency they work with operates, and what they can do as a company to help the collections process go smoothly. Here some things to keep in mind:

• Accuracy is key. The record of the bill itself is important, but so are patient identifiers like date of birth and insurance history. Missing information can result in errors, compliance issues, and potentially cause the debt to be unreportable.
• Know your collector’s policies. Some agencies continue reporting debts above $500, while others no longer report medical collections at all. Ask direct questions about thresholds, timing, and dispute procedures.
• Stay informed of your state’s policies. Given the difference in consumer protections across different states, it’s important to stay abreast of your state’s rules and regulations. If you operate in multiple states, don’t assume that they have the same standards.
• Communicate well with patients. The easiest way to get payment on a balance is to do it before it reaches collections in the first place. To do this, give your patients transparency on their billing statements, multiple payment plan options to choose from, and access to financial assistance programs to help them settle their balance quickly and easily.

The bottom line

Medical debt reporting has gone through some drastic changes over the past few years, but it hasn’t gone away completely. Though many debts were removed in 2022-2023, the rule that would’ve eliminated them all has been blocked for the time being. Whether or not a bill affects a patient’s credit report depends on how large the debt is, what the collector’s policies are, and where the patient lives.

The best way to ensure that your company is settling patient balances within regulations is to work with a collection agency that is compassionate with patients and compliant with state laws. Protect your company and community and set both up for success by prioritizing clear communication, compliance, and accuracy in collections.

As every creditor knows, there comes a point in some collection efforts when traditional methods aren’t enough. But when is the right time to stop collection activity and consider legal action?

Pursuing a judgement is not a decision to be taken lightly, it requires a careful, strategic approach. Here is what you need to know before heading down the legal path.

What Does Legal Action Really Mean in Collections?

Legal action typically involves hiring a lawyer and filing a lawsuit to obtain a judgement, a court order that formally recognizes a debt. Once obtained, this judgement can be enforced through methods such as:

• Wage garnishment
• Bank levies
• Property liens

However, not all debts are worth litigating, and not all debtors are collectible—even with a judgement in hand.

What You Can’t Collect Through Legal Action

One of the most important limitations to understand: retirement funds like IRA’s and 401(k)s are protected from garnishment. So, if a debtor’s only assets are retirement accounts, legal action may not result in recovery.

Also, judgements don’t last forever. They can expire, typically in 7-20 years depending on the state, although many can be renewed. This makes timing and follow-through essential.

Is This Judgement Worth Pursuing?

Before moving forward with litigation, consider the following factors:

• Debtor’s Age: Is the debtor nearing retirement? Are they likely to have income in the future?
• Current Employment: Are they working, or do they have a steady income?
• Earning Potential: Even if unemployed, do they have career history, education or skills that suggest future earnings?
• Asset Ownership: Do they own property or valuable assets that a lien could attach to?
• State Laws: Garnishment limits and judgement renewal terms vary widely. Make sure you know what’s enforceable in your jurisdiction.
• Insurance: Does the debtor have applicable insurance that could cover part or all of the balance owed?

Pre-Litigation Vetting is Key

This is where strong collaboration between your collection agency and legal counsel comes into play. Pre-litigation vetting ensures:

• You don’t waste time and money on uncollectible debt
• All relevant account and consumer information is reviewed
• The strategy is in line with local laws

Empathy Still Matters

Legal action doesn’t mean throwing compassion out the window. In fact, empathy is one of the most valuable skills a collection attorney can have. Understanding a debtor’s circumstances can lead to more productive conversations – and often better settlement outcomes.

Sometimes, simply obtaining the judgment creates the pressure needed to incentivize a resolution. It becomes a bargaining tool rather than a battle.

What’s the Recovery Rate in Litigation?

On average, the recovery rate for accounts that go through litigation hovers around 25%. Although this is not a substantial amount, it may make sense for high-balance accounts or situations where the debtor is clearly collectible.

Factors That Impact Recovery Rates:

• Type of Debt: Medical and education debt may differ in collectability from credit card or commercial debt
• State Laws: Wage garnishment limits, exemption laws and duration vary by state
• Debtor Profile: Employed debtors with attachable wages or assets are more collectible
• Amount of the Debt: Higher balance accounts often justify legal action and are more likely to be pursued more aggressively.
• Legal Strategy & Follow Up: Attorneys who actively enforce judgements (ex. Garnishments, liens) often recover more.
• Insurance: In certain cases–especially involving accidents, property damage or services rendered—and insurance policy may be available to cover some or all of the debt. If insurance coverage applies, it can significantly improve the chance of recovery, especially if the debtor is otherwise uncollectable.

The Bottom Line

Litigation can be costly and slow. If you are considering legal action, partner with an experienced collections attorney who can:

• Vet the debt thoroughly
• Advise on state specific laws
• Approach debtors with the right mix of firmness and empathy

Litigation should always be the last resort—but when done correctly it can be a powerful one.

The passage of the Big Beautiful Bill (BBB) is ushering in a new era for billing and collections across the medical and education sectors. With sweeping reforms aimed at protecting consumers, organizations that service, manage, or recover debt must now adapt to a much stricter regulatory environment.

As a Massachusetts-based third-party collection agency specializing in medical and educational debt, FFR, Inc. is ready to help our clients navigate the changing landscape with compliance, compassion, and confidence.

What the BBB Means for Medical Providers

Healthcare providers—including EMS companies, hospitals, and specialty practices—are now required to take additional steps before unpaid balances can be referred to collections.

Key changes include:

• Mandatory cost transparency: Providers must give clear, itemized estimates before non-emergency services.
• Extended grace periods: A 120-day waiting period is now required before referring medical debt to collections.
• Enhanced outreach: Providers must attempt to contact patients’ multiple times and offer payment plan options before sending accounts out for recovery.
• Credit reporting limitations: Certain types of medical debt may no longer be reported to credit bureaus.

These changes directly affect revenue cycle timing—and increase the importance of working with a collection partner who understands both compliance and patient sensitivity.

Private Education Debt: New Rules, New Responsibilities

Unlike federal student loans, private education debt is typically owed directly to schools—like career training programs, trade schools, and tuition-driven institutions. The BBB brings several key changes that now affect how this debt can be recovered.

Here’s what private institutions need to know:

• Mandatory outreach before collections: Schools must show documented efforts to communicate with students and offer payment plans before referring delinquent accounts.
• Grace periods now required: The BBB mandates a 90–120 day waiting period (depending on the state) before debt can be sent to collections, giving students more time to resolve unpaid balances.
• Collection limits for small-balance accounts: Some private education debts under a certain dollar amount may no longer be eligible for external collection activity.
• Increased documentation: Institutions must now maintain clear billing histories and provide full account records to support any debt that is referred to a collection agency.

At FFR, we work directly with private institutions to ensure all placement policies, documentation standards, and outreach protocols are aligned with the new federal law.

FFR, Inc.’s Commitment

At FFR, Inc., we’ve always believed that compliance and compassion go hand in hand. Our collectors are ACA-accredited, our processes are fully transparent, and we customize our outreach to align with both the spirit and letter of the law.

Now more than ever, your institution needs a recovery partner who:

• Understands the regulatory changes
• Protects your brand reputation
• Maximizes recoveries without sacrificing integrity

Whether you’re a medical provider or educational institution, we’re here to support you in this new chapter.

The No Suprises Act is a federal law that took effect on January 1,2022, designed to protect patients from unexpected medical bills caused by unknowingly receiving care from out-of-network providers. These unexpected charges, known as “surprise bills,” typically occur during emergency visits or when services like anesthesia, radiology or pathology are performed by out of network specialists—despite the patient seeking care at an in-network facility.

The law applies to most private health insurance plans, including employer-sponsored plans and those purchased on the Affordable Care Act (ACA) market. It limits how and when out-of-network providers can bill patients, shifting the financial burden off patients and onto payers and providers.

At FFR, we stay fully informed of these regulations, so our healthcare clients remain compliant—and their patients are treated fairly and compassionately throughout the recovery process.

At FFR, we stay fully informed of these regulations, so our healthcare clients remain compliant—and their patients are treated fairly and compassionately throughout the recovery process.

How Patients Are Protected

Under the No Suprises Act, patients with private insurance are protected from many forms of surprise billing. Government programs like Medicare and Medicaid are already protected by existing laws.

For some situations, patients only owe their in-network cost sharing amounts—like copays or deductibles. Providers are prohibited from balance billing which means they cannot charge patients for the difference between what the provider charges and what the insured patient pays.

Key Protections include:

1. Emergency Services

Patients receiving emergency care at a hospital or freestanding ER can only be charge in-network rates—even if the provider or facility is not in-network. These protections also cover post-stabilization care (which used to be a major source of surprise billing.

2. Non-Emergency Services at In-Network Facilities

If a patient receives scheduled care at an in-network hospital or center, they cannot be billed out-of-network rates by any supporting providers (ex: anesthesiologists or diagnostic labs) unless they are given clear notice and consent to receive out-of-network care.

3. Air Ambulance Services

Out of network air ambulance services must now be billed at in-network cost (Note: Ground ambulance services are still regulated by state laws and not yet covered under the No Suprises Act.)

Uninsured or Self-Pay Patients

For patients who are uninsured or choosing to pay out of pocket, the law includes a new requirement called the Good Faith Estimate (GFE).

This ensures that patients receive a written estimate of costs prior to receiving non-emergency services. The GFE must include:

• Total expected charges from all involved providers/facilities
• An estimate before services are rendered
• A way for patients to compare prices and avoid financial surprises

Price transparency helps patients make informed choices—and it helps providers and collection agencies like FFR, work from a position of clarity and trust.

What does this mean for Providers and Insurance Companies?

The No Suprises Act introduces a new dispute resolution process for billing discrepancies between providers and insurance companies. If a patient receives a bill more than $400 above their Good Faith Estimate, they can dispute the charges within 120 days.

Providers are also responsible for:

• Notifying patients of their rights under the Act
• Getting written consent for out-of-network care (non-emergency cases)

At FFR, we collaborate with providers to ensure that all collection efforts are complaint with current regulations and patients’ rights.

Why It Matters for Billing and Recovery

The No Surprises Act is a turning point for the healthcare revenue cycle. By cutting down surprise bills and making costs clearer, it helps build more trust between patients, providers and insurers.

As a third-party collection agency with 30+ years of experience, FFR understands how essential that trust is. That is why we:

• Stay current on evolving billing regulations and compliance
• Tailor our collection strategies to support both patient understanding and client reimbursement.
• Collet with compassion and professionalism, every step of the way.

Looking Ahead: Updates and Compliance

The No Surprises Act is currently in effect, but its details are still evolving. Challenges remain and new guidance keeps coming. Providers, insurers and partners, like FFR need to stay flexible and informed as regulations develop.

At FFR. We’re committed to:

• Helping clients understand and adapt to changing billing practices
• Ensuring all collections are handled with full legal and ethical compliance
• Supporting patient communication with transparency and compassion

Let’s work together to build  a healthcare system where billing makes sense, expectations are clear and patients are aways treated with respect.

Who Is Responsible for a Minor’s Medical Bills? A Guide for EMS and Private Practice Providers

Understanding who is legally responsible for a child’s medical bills is critical for providers like EMS services and private medical practices. Whether you’re treating a child after an emergency or seeing a minor for routine care, knowing the rules around billing and collections helps ensure compliance and protects your bottom line.

So, who is responsible for paying when a minor receives medical treatment—and what happens if the bill goes unpaid?

Minors Cannot Be Held Financially Liable

Here’s the key legal principle: Minors cannot legally enter into binding financial contracts, which means they cannot be held responsible for their own medical debt. If a child under 18 receives care, the financial responsibility falls on their parent or legal guardian.

What If the Parents Are Divorced or Separated?

When parents are divorced, determining which parent is financially responsible can get tricky. Typically:

• The parent with court-ordered responsibility for medical expenses is liable.
• If one parent carries health insurance, that parent is often expected to cover the bill.
• In some cases, both parents may share responsibility based on a divorce agreement or court order.

As a provider, you are not expected to enforce custody agreements—but having accurate intake information and insurance verification is key to billing the correct responsible party.

What Happens If the Bill Goes Unpaid?

If a medical bill for a minor goes unpaid, some providers wonder if they can collect once the patient turns 18. The answer is no—you cannot transfer medical debt to the child once they reach adulthood. Since the minor was never legally responsible in the first place, they cannot be held accountable later.

This is an important point to understand for both billing departments and collections partners.

Best Practices for EMS and Private Practices

To avoid confusion and maintain compliance:

Always verify the responsible party during intake or after an EMS run. Get complete parent/guardian information when treating minors.
Include insurance verification for the parent or guardian—not the minor.
Work with a collection partner who understands these legal nuances and follows all FDCPA regulations.
Do not send bills to patients who were minors at the time of service, even if they are now over 18.

In Summary

• Minors are not legally responsible for medical bills.
• Parents or legal guardians are the responsible parties.
• Debt cannot be transferred to the child once they become an adult.
• Following proper intake and billing procedures helps ensure compliance and improves your chances of recovery.

Need help collecting unpaid balances while staying compliant? FFR, Inc. specializes in third-party collections for EMS providers and private medical practices. Our compassionate and compliant approach protects your patients—and your reputation.

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A mental model is a simple way to think about the world.

The most useful mental models are broadly applicable—they help identify patterns across different areas of life to create clarity and spark action. Here’s one I can’t stop thinking about:

The hidden debts of life.

When you take on a financial debt, you get:

• Short-term benefit (the cash)
• Long-term burden (the repayment with interest)

As it turns out, this general tradeoff—taking a short-term benefit but incurring a long-term burden—can be seen in a variety of contexts beyond the financial.

When you avoid a hard conversation, you’re taking on a relationship debt. You get the short-term benefit of the pain avoided, but you incur the long-term burden of the problem that has been brushed under the rug. Time doesn’t heal anything when it comes to relationships. Minor issues become major issues over time.

When you skip your workouts or eat processed junk, you’re taking on a physical debt. You get the short-term benefit of the pleasure of relaxation and sugar, but you incur the long-term burden of the compounded health impact of these decisions.

When you procrastinate on your important work, you’re taking on a professional debt. You get the short-term benefit of the focus avoidance, but you incur the long-term burden of the last minute panic, regret, and missed opportunities.

All of these things are hidden debts of life—they may create some short-term benefit, but they will have to be repaid with interest at a date in the future.

There’s no such thing as a free lunch. The bill eventually comes due.

In your finances, as well as your life:

Choose your debts wisely.

Sahil Bloom