Court Vacates CFPB Medical Debt Rule: Key Takeaways for Providers
Earlier this month, the United States District Court for the Eastern District of Texas approved a consent judgment vacating the Consumer Financial Protection Bureau’s (CFPB) Medical Debt Rule. T he decision holds that the CFPB exceeded its authority under the Fair Credit Reporting Act (FCRA) and violated the Administrative Procedure Act (APA) when enacting the Rule . This development has significant implications for healthcare providers and other entities involved in the reporting and use of medical debt information. Background: The Medical Debt Rule and FCRA The FCRA, permits Credit Reporting Agencies (CRAs) to report medical debt information—provided it is coded to protect patient privacy—i.e., it does not disclose the patient’s health condition or procedure. Continuing with its efforts to prioritize medical debt rulemaking, the CFPB’s Medical Debt Rule, finalized in January 2025, sought to prohibit CRAs from including any medical debt information in con...