Credit Bureau Q & A for Reporting Medical Debts under New Rules (July 1, 2022)

1. If an account has been reported already because it has met the current 180 days requirement, but has not reached 365 days since the first delinquency date, how should we report those accounts? Should they have a DA to remove them and then be reported again once the 365 days are met? Is this change only for newly reported accounts?
   
   Equifax Response:  Yes, the accounts should be deleted and this applies to all accounts.
   
   TransUnion Response:  If an account has been reported already, continue to report the paid medical collection with a status code 62. The CRAs will then remove the paid medical collection effective 07/01/2022.
   
   Experian Response:  All Medical Debt Collections data furnished after July 1, 2022, cannot be reported until they are at least 365 days past the Date of First Delinquency. We will also be removing any Medical Debt Collection Account that does not meet these criteria from our database on July 1, 2022.
   
   
2. These two actions ensure that we address both the existing data on file as well as prevent new tradelines meeting this condition from being added to our database. We are enhancing discard 45 to change the DOFD from 180 days to 365 days. This change applies to both historical medical collections and those that may be reported going forward.
   
   Should we not keep the System of Record up-to-date with what the Consumer's Credit Report shows? I can see where you do not show it reported, but the agency may tell the consumer it has been reported.
   
   Equifax Response:  If something is not showing on a consumer's credit file, please reach out to that bureau with an inquiry.
   
   TransUnion Response:  Please reach out to that bureau with an inquiry.
   
   Experian Response:  Did not get a returned response.
   
   
3. For the minimum balance of $500.00. If an account was first reported with a balance above $500.00 and the consumer pays the balance down under $500.00, can that account still be reported? For example, if an account is reported as $1,000.00, the consumer starts to pay this down monthly, and over the course of time the debt will be less than $500.00. Does the minimum balance still apply to not reporting? If so, do we need to DA that account once it hits below $500.00?
   
   Equifax Response:  The minimum collection amount, not the balance amount must be $500 or above all other collection amounts $499 and lower must be deleted.
   
   TransUnion Response:  If an account is less than $500 after meeting monthly payments; do not report Medical Debt collection accounts (as defined by Creditor Classification Code 02) under a predefined minimum threshold (will be at least $500 and published later this year) effective 3/30/2023.
   
   Experian Response:  Do not report Medical Debt collection accounts (as defined by Creditor Classification Code 02) that are less than $500.
   
   
4. So, you are saying if an account was first reported with a $1,000.00 balance and the consumer pays it down under $500.00, we should stop reporting that and DA the account?
   
   Equifax Response:  The predefined minimum threshold will be at least $500 and published later this year effective 3/30/2023.
   
   TransUnion Response:  The predefined minimum threshold will be at least $500 and published later this year effective 3/30/2023.
   
   Experian Response:  I asked the same question just worded it a little differently. I understand that we do not report accounts under $500.00. But if an account is reported as $1000.00, the consumer starts to pay this down monthly, and over the course of time, the debt will be less than $500.00. Does this still apply to not reporting? If so, do we need to DA that account once it hits below $500.00? The trade will stay. The rule looks at the original credit.
   
   
5. If we were to DA an account due to missing one or more of the new requirements when they go into effect, how does that affect the re-reporting of said account when it qualifies?
   
   Example: Account was reported after 180 days from DOFD, data furnisher decides to DA and removes the tradeline from the consumer's credit report. Then after 365 days, they want to report this account again.
   
   **The basis of this question is to make sure that there are not any unintended consequences for submitting a DA and then re-reporting an account later. Data furnishers are going to want the system of record to match what the consumer's report is showing. So, I can see where we may be sending mass DA's and then re-reporting at a later time.
   
   Equifax Response:  Deleting the accounts and then re-reporting at the appropriate time is acceptable. 
   
   TransUnion Response:  Accounts were reported after 180 from DOFD and in regards to unintended consequences for submitting a DA and then re-reporting at a later date. TU will build in a way to scrub all data that doesn't meet the requirements effective 07/01/2022.
   
    (This question was only asked to TransUnion due to the previous response.) Again, I see the same issue happening here as #1, where the Consumer's Credit Report is reflecting something different than what the data furnishers and the system of record show. Do the bureaus not see this being a problem and causing more confusion to both the consumer and data furnishers?
   
   **If you have a consumer where the credit report is reflecting something different than what the data furnisher and the system of record show. Please reach out to that bureau with an inquiry.
   
   Experian Response:  An account that was previously deleted or closed cannot be reopened or used to report again, a new tradeline needs to be established.