The new CFPB medical-debt rule and what is left on your report

On January 7, 2025, the Consumer Financial Protection Bureau issued a final rule that prohibits consumer reporting agencies from including most medical debt in the credit reports lenders use for underwriting. The rule covers an estimated $49 billion of medical collections held by roughly 15 million Americans. The catch is that medical debt has been getting peeled off credit reports in pieces since 2022 by the bureaus themselves, the rule was challenged in court within weeks of being announced, and the actual question for someone whose file got cleaned is whether their score actually moved. Often it did. Sometimes it did not. Here is what the rule does, what it does not touch, and how to handle the medical collection that is still sitting on your report.

What changed on January 7, 2025

The CFPB's final rule is titled the Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information. It does three things.

It prohibits the three nationwide consumer reporting agencies (Equifax, Experian, TransUnion) from including most medical debt in the credit reports they sell to lenders for underwriting credit cards, auto loans, mortgages, and other consumer credit.

It bans creditors from using medical information to make underwriting decisions, with limited exceptions for medical loans where the debtor is the patient (medical credit cards) and where the medical information is the basis for the loan.

It distinguishes between medical bills from a provider (which are not collections on the report) and medical collections accounts (the third-party agency tradelines that used to drag scores down).

The rule was set to take effect 60 days after publication in the Federal Register. The actual effective date got tangled in court, which is the next thing to know.

Where the rule stands in court

Two trade groups, ACA International and the Cornerstone Credit Union League, filed suit in the US District Court for the Eastern District of Texas within days of the rule being published. The plaintiffs argued the CFPB exceeded its statutory authority under the Fair Credit Reporting Act and that the rule conflicts with the FCRA's existing framework for medical debt reporting.

A preliminary injunction was entered in early 2025, holding off enforcement while the case proceeds. The bureaus' voluntary policies (the ones from 2022 to 2023) stayed in place during the stay. Whether the rule eventually takes effect as written, gets modified, or gets struck down depends on how the litigation moves and whether the rule survives review in the Fifth Circuit.

For people checking their reports in 2026, that means the situation is layered. The CFPB rule may or may not be enforceable today. The bureaus' own policies are clearly in effect and are removing the most common kinds of medical collections regardless of what the court says.

What the bureaus already did, before the CFPB stepped in

This is the part that most articles skip. The bureaus did most of the heavy lifting before the CFPB final rule was issued.

In July 2022, Equifax, Experian, and TransUnion stopped reporting paid medical collection accounts at all. If you settled an old medical bill that had landed at a collection agency, the tradeline came off.

In the same window, the bureaus extended the grace period before unpaid medical collections show up. The window moved from 180 days (which had been the Consumer Data Industry Association standard since 2017) to one year. Translation: you have a full year from the date of first delinquency before a medical collection can land on your report.

Then in April 2023, the three bureaus stopped reporting medical collections under $500 entirely. That single change removed an estimated 70 percent of medical-collection tradelines from US credit reports.

Add it together and most medical debt was already off most reports before the CFPB rule was finalized. That is why scores did not jump as much as some headline coverage suggested when the rule was announced. There was less debt left to remove. Our longer explainer on medical debt and credit scores lays out the bureau timeline in more detail.

What removing a medical collection actually does to a score

Two cases.

Case one: your file was thin and the medical collection was the only major derogatory on it. Removing it can move a FICO 8 score 40 to 90 points. That is the meaningful end of the range.

Case two: your file is thicker, you have a 30-day late from a credit card last year, and the medical collection is one of several derogatories. Removing it can move the score 10 to 25 points. The other derogatories are still hurting you.

FICO 9 and VantageScore 4.0 already weight medical collections less heavily than other collections (FICO 9, released in 2014, was the first model to deemphasize medical collections, and lenders adopted it slowly). FICO 8 still treats them the same as any other collection. The score most lenders pull is still FICO 8, which is why bureau cleanups produced visible score lifts.

Most medical collections came off most US credit reports between 2022 and 2023, before the CFPB rule was final. The CFPB rule mostly seals what the bureaus had already done.

How to dispute a medical collection that is still on your file

1. Pull your three reports at AnnualCreditReport.com (the weekly free-access program was extended through at least 2026). Note the collection agency name, account number, original creditor (the provider or hospital), date of first delinquency, and balance.
2. Verify the date of first delinquency. The clock for the bureau's one-year grace runs from this date, not from the date the bill was sent to collections. If the collection is less than a year past first delinquency, file a bureau dispute on those grounds.
3. Send a written dispute through each bureau's online portal. Include the dispute reason (under $500, less than a year old, paid in full, or factual error). The bureau has 30 days under FCRA section 611 to investigate and respond.
4. If the collection was paid, request deletion under the post-2022 bureau policy that prohibits reporting paid medical collections. Attach proof of payment.
5. If the dispute is rejected, escalate. File a complaint at consumerfinance.gov. The CFPB forwards complaints to the bureaus and the bureaus respond.

What the rule does not touch

Three categories of medical credit are still fully in play on your report.

Medical credit cards (CareCredit, Wells Fargo Health Advantage, Synchrony) are regular credit cards. Late payments report. Balances report. The CFPB rule explicitly carves them out because they are consumer-credit products that happen to be used for medical bills, not medical-debt tradelines.

In-network bills you are paying late, but that have not yet been sent to collections, do not appear on your credit report at all. They appear in your bank's records and the provider's accounts-receivable file. The bureaus only see them when a third-party collection agency takes them on, which is the point at which the new grace and threshold rules engage.

Old paid medical collections that came off when the bureaus changed their policies in 2022 to 2023 may still show up briefly on credit-monitoring screenshots from before that date. They are not on your current credit report. If a credit-monitoring app is still flagging one, the cache has not refreshed.

Two more reads worth your time on the way out:

• A walk-through of what a 500 score actually looks like to a lender covers what removing a single derogatory can and cannot do for a low score.
• Our breakdown of why payment history is 35 percent of your FICO score explains why a collection tradeline, medical or otherwise, hurts as much as it does even when the underlying debt was small.