For decades, federal agencies were the place to focus day-to-day attention to stay abreast of the biggest security and compliance changes within our industry. Federal legislative challenges have forced a major shift to the states following the federal agency shakeups in Q1 of 2025. So far this year, state lawmakers across 38 states introduced 123 bills that included significant changes to medical debt collection. To date, only 14 of those bills have gone through the entire legislative process to become law, but it is important to note that many of those legislators have already announced plans to come back in the next session with similar bill introductions.
States Picking Up Where Feds Left Off
Credit reporting is a perfect example of where the CFPB’s work has ceased, for now, and the states have picked up to run with the torch. Currently, there are a total of 17 states that prohibit reporting and all agencies within the Meduit structure have appropriate blocks in place. Those states are: California, Colorado, Connecticut, Delaware, District of Columbia, Florida, Illinois, Maine, Maryland, Minnesota, New Jersey, New York, Oregon, Rhode Island, Vermont, Virginia, and Washington.
Another area that is expected to transition to the states more and more will be auditing, assessment fees, and additional reporting requirements. There have already been increases in entity on-site audits from states looking to cover the perceived gap in entity level reviews from the drawback of federal agencies, such as the CFPB. California, for example, has drastically increased its entity examinations, which the entity has to cover all costs for completion. Also, the state has issued large assessment invoices for those conducting collection business within its borders.
Early Warning Systems: Be Prepared
Meduit’s Compliance team closely monitors federal and state-level legislative movement from the introduction of each bill, proposed rule, and issued guidance through final determinations and internal implementation when passed. We also take an active advocacy role within the industry through our ACA association partner and other industry leaders and associations by providing review, data, insights, and in-person meetings to support challenges of introduced items. Compliance team members will be visiting Washington DC at the beginning of December to participate in federal level meetings organized by the ACA for their large, Group50, association members.
While Meduit is monitoring all of these changes, and will keep our clients updated with those that affect our services, it will be imperative to make plans to review your state level requirement compliance and ensure there is an assigned department with the responsibility of monitoring potential and finalized changes. Consider a statutory review of the legislation within the state and sign up to get news of potential new bills and changes. Taking an internal look now will prepare you for the state review later.