The Consumer Financial Protection Bureau (CFPB) has taken bold steps to curb the impact of medical debt on consumers, including efforts to eliminate medical debt from credit reports and crack down on abusive billing practices. As the political landscape shifts, the future of these protections grows increasingly uncertain. This change creates risk for self-insured health plans, employers and employees alike.

This growing uncertainty highlights a broader truth. Regulatory protections often change while the burden of unfair medical billing continues. This is where aequum plays a vital role.

The CFPB’s Shifting Role in Medical Debt Oversight

In early 2025, the CFPB finalized a rule to prohibit the inclusion of medical debt on consumer credit reports — a significant move aimed at protecting patients from long-term credit damage due to billing errors or unaffordable charges. Yet just weeks later, under a new administration, the agency halted operations. Rule enforcement was paused, the CFPB headquarters shut down and pending litigation has delayed the rule’s implementation until at least June 2025.

The pause leaves patients and employers in a vulnerable position, especially as recent CFPB advisories have exposed ongoing illegal practices in medical debt collection, including:

• Double billing for services already covered by insurance.
• Collecting amounts that exceed legal caps.
• Pursuing unverified or inflated charges.
• Misleading consumers about their rights to dispute debts.

The Bigger Picture: Medical Debt Is a Crisis Even for the Insured

While political battles dominate headlines, the real cost of medical debt is borne by working families — many of whom already have insurance. According to research from the Kaiser Family Foundation (KFF):

• 20 million adults in the U.S. owe medical debt, totaling at least $220 billion
• 14 million people owe more than $1,000 and 3 million owe over $10,000
• Medical debt affects 1 in 12 adults, even among those with full-year insurance coverage
• Black Americans, people with disabilities, rural residents and low- and middle-income households are disproportionately affected
• High deductibles and denied claims drive up out-of-pocket costs — even for people with private insurance

This reality makes one thing clear. Whether or not medical debt shows up on a credit report, its financial and emotional toll is widespread and growing.

Why This Matters to Employers and Health Plans

As the future of the CFPB remains uncertain, the responsibility to protect plan members increasingly falls on the shoulders of employers and plan sponsors. In the absence of strong and consistent regulatory enforcement, the risks grow more serious and immediate.

Billing errors may go unchallenged, slipping through the cracks and resulting in unnecessary costs. Employees could suffer damage to their credit due to unresolved or inaccurate charges. With federal protections paused or potentially rolled back, employers may face new compliance challenges that are harder to anticipate or manage. At the same time, aggressive billing practices by outsourced revenue cycle firms are likely to increase disputes, creating more administrative strain and financial exposure.

In this environment, proactive oversight is not just advisable—it’s essential.

How aequum Supports Health Plans Amid Regulatory Uncertainty

As federal oversight remains uncertain, aequum provides the legal and strategic support needed to protect health plans and their members from the consequences of unchecked medical billing practices.

Regardless of the direction policy takes in Washington, aequum helps employers stay in control of their healthcare costs and compliance. aequum’s services include:

Legal Advocacy for Billing Disputes
aequum’s team provides legal support to plan members facing inflated, duplicate or inaccurate medical charges. They work directly with providers to resolve billing disputes efficiently, including issues related to out-of-network services and balance billing.

Overpayment Recovery
aequum works with employers to identify and recover overpayments to healthcare providers, helping protect plan resources and strengthen long-term financial stability.

Compliance and Monitoring
aequum monitors state-level regulatory changes to help employers stay compliant as laws evolve, reducing risk and keeping health plans aligned with current legal requirements.

Credit Reporting Defense
When employees are affected by inaccurate or excessive medical charges on their credit reports, aequum steps in to correct the records and help prevent long-term financial harm.

Data Transparency and Reporting
Using a proprietary platform, aequum delivers actionable insights into claim disputes, settlements and financial impact. This allows employers to make smarter, data-informed decisions that strengthen plan performance and accountability.

Moving Forward: A Proactive Approach Is Essential

The CFPB’s role may be uncertain and regulatory protections may shift but the medical debt crisis is very real — and it won’t solve itself.

Now more than ever, employers and self-insured health plans need to take an active role by working with experienced advocates who understand the complexities of medical billing, credit reporting and legal safeguards.

aequum is here to help your organization protect its health plan and its people—guarding against excessive charges, hidden debt risks and regulatory blind spots. In times of uncertain enforcement, proactive protection is not optional—it’s essential.

Contact us today to learn how aequum can help your organization stay protected from rising medical debt risks, reduce exposure to unfair billing practices and keep your health plan financially secure.