3. Medical collection removals
The reasons for the removal of any information from a consumer’s credit report are varied and
not listed in the credit report. Medical collections are rarely visible on a report for the full seven
years that the Fair Credit Reporting Act permits, even though few are ever marked as paid. Less
than twenty percent of unpaid medical collections remain on consumer credit reports for longer
than four years.
14
The lack of persistence of the accounts on reports may be partially driven by a
failure of collectors to continue furnishing updated information. Additionally, the consumer
reporting companies have a requirement that medical collections should be removed from credit
reports after six months without updated furnishing, implemented in September 2017.
15
Another factor contributing to the lack of persistence may be consumer disputes of medical
collections. Medical collections are often reported by third-party collection companies who may
not be easily able to verify the legitimacy of the debt.
16
Individual experiences differ across a
large number of small furnishers, as the top four medical collection furnishers reported only
14.7 percent of the medical collections that were reported in the first quarter of 2022.
17
The Fair
Debt Collection Practices Act requires debt collection furnishers to investigate disputes and
provide individuals with verification of the debt.
18
If debt collection furnishers find that the
disputed debt is inaccurate or cannot be verified in response to a consumer dispute, the
furnisher is required to request that the consumer reporting company delete or modify the
furnished information about the debt. Additionally, there is some evidence that collection
14
Nathe, Lucas and Ryan Sandler, “Paid and Low-Balance Medical Collections on Consumer Credit
Reports,” Consumer Financial Protection Bureau Consumer Credit Trends, July 2022,
https://www.consumerfinance.gov/data-research/research-reports/paid-and-low-balance-medical-
collections-on-consumer-credit-reports.
15
Andrews, Michelle, “Credit Agencies to Ease Up on Medical Debt Reporting,” National Public Radio,
July 2017, https://www.npr.org/sections/health-shots/2017/07/11/536501809/credit-agencies-to-ease-
up-on-medical-debt-reporting; Nathe, Lucas and Ryan Sandler, “Paid and Low-Balance Medical
Collections on Consumer Credit Reports,” Consumer Financial Protection Bureau Consumer Credit
Trends, July 2022, https://www.consumerfinance.gov/data-research/research-reports/paid-and-low-
balance-medical-collections-on-consumer-credit-reports/.
16
Consumer Financial Protection Bureau, “Medical Debt Buren in the United States”, February 2022,
https://files.consumerfinance.gov/f/documents/cfpb_medical-debt-burden-in-the-united-
states_report_2022-03.pdf.
17
Consumer Financial Protection Bureau, “Market Snapshot: An Update on Third-Party Debt Collections
Tradelines Reporting,” February 2023, https://files.consumerfinance.gov/f/documents/cfpb_market-
snapshot-third-party-debt-collections-tradelines-reporting_2023-02.pdf.
18
Consumer Financial Protection Bureau, “What is a debt collection validation notice?” November 2021,
https://www.consumerfinance.gov/ask-cfpb/what-is-a-debt-collection-validation-notice-en-2109/.
CONSUMER CREDIT AND THE REMOVAL OF MEDICAL COLLECTIONS FROM CREDIT REPORTS 7