Limiting Medical Payment Options Won’t Deter Costs but Will Reduce Access to Services

September 11, 2023

The Consumer Bankers Association and the Bank Policy Institute (“the Associations”) addressed misconceptions surrounding medical payment products in a letter today to the Consumer Financial Protection Bureau, the Department of Health and Human Services and the U.S. Treasury Department (“the Agencies”). The Agencies issued a request for information in July that wrongly asserts that “medical payment products” — a term the Agencies do not define — are responsible for the high cost and disfavored practices of healthcare service providers, hospitals and insurance companies.

“Many consumers do not have access to sufficient funds to pay the full cost of a particular healthcare service using liquid funds,” the Associations wrote. “Having different options to pay for medical care, each with different terms and features, provides consumers with the ability to select a payment product that best suits his or her individual needs and finances.”

The Agencies only briefly acknowledge this benefit in the RFI, stating “[i]n some cases, medical payment products may allow patients to access care they would otherwise have to forgo,” but fail to further examine these benefits and instead attempt to blame the availability of payment options for the Agencies’ broader criticisms of the U.S. healthcare system.

Put simply, limiting medical payment options will harm consumers, not help. The Associations point out the following in their letter:

  • The availability of different means of payment expands consumers’ access to health care. Many consumers do not have cash on hand to cover major medical expenses, especially if unexpected or unanticipated, and having a variety of ways to pay makes these services accessible for consumers in different financial circumstances.
  • The RFI wrongly attributes the high cost of health care and harmful practices of healthcare providers, hospitals, and insurance companies to the availability of “medical payment products.” Suggesting that banks and card providers are responsible for rising healthcare costs is incorrect and not grounded in evidence.

The Associations believe that the issues the Agencies are concerned about regarding high healthcare costs are best addressed by Congress, state legislatures, insurance and other appropriate regulators rather than placing limits on payment options available to consumers for healthcare services.

To access a copy of the letter, please click here.