Continuing its attack on the $220 billion worth of medical debt owed by Americans and the impact it can have on their lives, the Consumer Financial Protection Bureau recently issued guidance to medical debt collectors in the form of an advisory opinion. The opinion warned them that their debt collection activities may constitute unlawful practices under the Fair Debt Collection Practices Act and its implementing Regulation F.

The advisory opinion highlights debt collection practices that may cause the collection of legally invalid debts, including amounts already paid by health insurance, amounts that should be covered by workers’ compensation or other programs, or amounts that result from “upcoding” by health care providers. The opinion also warns debt collectors against misrepresenting the status of medical debt, including misleading consumers into believing that amounts demanded are fully settled when their payment obligations may be uncertain.