The cards are viable products if they’re used in appropriate circumstances and patients understand their choices for meeting their out-of-pocket obligation.
The federal request for information signals heightened scrutiny on the issuance of credit cards in healthcare settings.
The Consumer Financial Protection Bureau, Department of Health and Human Services and Department of the Treasury sent out an RFI in July to gain stakeholder feedback on whether the widespread availability of medical payment products such as credit cards drives medical debt.
“In particular, the agencies seek comment on whether these products may allow healthcare providers to operate outside of a broad range of patient and consumer protections,” the RFI states.
“The agencies also seek comment on whether these products may contribute to healthcare cost inflation, displace hospitals’ provision of financial assistance, lead patients to pay inaccurate or inflated medical bills, increase the amount patients must pay due to financing costs, or otherwise harm patients’ mental, physical and financial well-being, including through downstream credit reporting and debt collection practices.”
HFMA is working on a written response to the RFI. In an interview, HFMA’s Rick Gundling, FHFMA, CMA, senior vice president for content and professional practice guidance, said medical credit cards can be useful for patients with certain financial needs. The cards should be evaluated among the various financial options that are pertinent to a particular patient, including the hospital’s financial assistance policy.
“It’s not ideal for everything and everybody, but there are instances and different consumers [for whom] it does make sense,” Gundling said.
In a scenario involving cosmetic surgery, Gundling said as an example, a patient with means could obtain a credit card, pay off the balance in a year or so and avoid prematurely withdrawing money from a CD account.
In that case, “it’s just a financing tool to help me bridge time,” he said.
An expanded scope of utilization
The RFI states that one credit card vendor’s customer base grew from 4.4 million to 11.7 million between 2013 and 2023, while its number of provider partners rose from 177,000 to 250,000.
Such increases might stem from apparent changes in the function of medical credit cards, said Tom Policelli, CEO of Health Payment Systems (HPS) and of PayMedix, an HPS affiliate that has processed more than $5 billion in medical payments for hospitals and physician practices.
“In-network services that were covered by the insurance plan never had any external financing associated with [them],” he said. “The hospital or provider group would just either get paid or not get paid, or they kind of handled it themselves. But [for] the out-of-network or uncovered services, credit cards have been used for decades. And that hasn’t been alarming to regulators or anybody else.”
As credit cards increasingly are applied to more urgent healthcare situations, Policelli said, the risk increases of practices such as cherry-picking customers based on their ability to pay. That’s a concern raised in the RFI, as are the questions of whether the cards drive higher-priced in-network care and skew financial incentives for providers.
“I look at this as a very serious move, especially because it’s by three agencies,” he said. “This doesn’t happen very often, at least in my experience.”
Policelli said stakeholders should be prepared for some type of regulatory action to result from the RFI, which also asks questions about the practice of offering installment loans.
“My experience [with] the HHS side is that when they put out questions like this, it’s a strong indication of where they’re going,” he said. “I would expect — absent universal responses against them in the questioning — that they will head in this direction.”
Read the Full Interview on HFMA.org
