Medical Debt and Your Credit Report: The 2026 Rules

Most of what you'll read online says a federal rule wiped medical bills off consumer credit reports. That rule was struck down on July 11, 2025, before a single account came off because of it.

The rule was real. The Consumer Financial Protection Bureau finalized it on January 7, 2025, and it would have barred consumer reporting agencies from including medical debt in reports sold to lenders. Then the U.S. District Court for the Eastern District of Texas vacated it in Cornerstone Credit Union League v. CFPB. The Bureau's own rule page now carries the vacatur notice at the top and describes the materials as reference only.

So the honest answer to "what are the 2026 rules" is that they're a stack of three different things, and only one of them is law. Knowing which is which tells you what you can dispute, what you can only ask for, and what could quietly change next year.

What changed, and when?

The sequence matters more than any single date, because the two things people most often confuse sit two years apart.

1. Mar 2022

   The three bureaus announce a voluntary policy change

   Equifax, Experian, and TransUnion jointly commit to dropping paid medical collections, extending the wait before an unpaid one appears, and excluding small balances.

2. Jul 1, 2022

   Paid medical collections stop being reported

   The one-year wait before an unpaid medical collection can appear also takes effect, up from six months.

3. Jan 2023

   VantageScore 3.0 and 4.0 stop using medical collection data

   A scoring-model change, separate from what the bureaus report.

4. Apr 11, 2023

   Medical collections under $500 come off

   Any medical collection with an initial reported balance under $500 is removed from U.S. consumer reports.

5. Jan 7, 2025

   The CFPB finalizes its medical debt rule

   It would have barred medical debt from consumer reports used for credit decisions. Industry groups sue the same day.

6. Jul 11, 2025

   A federal court vacates the rule

   The Eastern District of Texas holds it exceeded the CFPB's authority under the FCRA. It never took effect.

CFPB final rule page (July 2025); joint bureau announcements (March 2022, April 2023); VantageScore (August 2022).

The court's reasoning is worth a paragraph, because it explains why a replacement rule isn't around the corner. Per the CFPB's own notice on the rule page, the court held that the rule "exceeded the Bureau's statutory authority and was contrary to the Fair Credit Reporting Act (FCRA) because the rule purported to prohibit the furnishing and consideration of coded medical debt information." The FCRA expressly permits those activities, so long as what's reported doesn't identify the provider or let anyone infer the nature of the care. A regulation banning what the statute allows couldn't stand. The court also rejected the idea that the Bureau could set the contents of a consumer report by reference to state law, which turns out to matter later in this article.

Two things follow. The Bureau can't simply reissue the same rule, because the defect was statutory rather than procedural. And nothing about the vacatur disturbed the bureau policies that had already been running for years, which is what most people are actually experiencing when they notice a medical collection missing from their report.

Which of these rules is actually law?

This is the distinction the whole subject turns on. Three different mechanisms are doing the work, and they fail in three different ways.

The rule	What kind of rule it is	How it could change
Coded medical debt may appear in a consumer report	Federal statute (FCRA § 1681b(g), § 1681c(a)(6))	Only an act of Congress
Paid medical collections aren't reported	Voluntary bureau policy, since July 1, 2022	The bureaus can reverse it with an announcement
Unpaid medical collections wait one year	Voluntary bureau policy, since July 1, 2022	Same — no rulemaking required
Medical collections under $500 aren't reported	Voluntary bureau policy, since April 11, 2023	Same — no rulemaking required
VantageScore 3.0 and 4.0 ignore medical collections	Scoring model design, since January 2023	The model publisher's decision
Medical debt barred from consumer reports	Vacated federal rule	Not in force at all

• The ruleCoded medical debt may appear in a consumer report

  What kind of rule it is

  Federal statute (FCRA § 1681b(g), § 1681c(a)(6))

  How it could change

  Only an act of Congress

• The rulePaid medical collections aren't reported

  What kind of rule it is

  Voluntary bureau policy, since July 1, 2022

  How it could change

  The bureaus can reverse it with an announcement

• The ruleUnpaid medical collections wait one year

  What kind of rule it is

  Voluntary bureau policy, since July 1, 2022

  How it could change

  Same — no rulemaking required

• The ruleMedical collections under $500 aren't reported

  What kind of rule it is

  Voluntary bureau policy, since April 11, 2023

  How it could change

  Same — no rulemaking required

• The ruleVantageScore 3.0 and 4.0 ignore medical collections

  What kind of rule it is

  Scoring model design, since January 2023

  How it could change

  The model publisher's decision

• The ruleMedical debt barred from consumer reports

  What kind of rule it is

  Vacated federal rule

  How it could change

  Not in force at all

CFPB, Cornell LII, joint bureau announcements, VantageScore.

The middle three rows are doing most of the practical work in your life right now, and they're the least durable. A joint announcement from Equifax, Experian, and TransUnion created them in March 2022, and another announcement could unwind them. That's not a prediction. It's what "voluntary" means, and it's the reason to know which row you're relying on.

The practical test: if a bureau is doing something the FCRA requires, you can dispute a violation and eventually sue over it. If a bureau is doing something it announced it would do, your remedy is a dispute and, failing that, a complaint. Both are worth filing. They just aren't the same instrument.

What the FCRA has always said about medical information

Long before any of this, the Fair Credit Reporting Act carved medical data out for special handling, and those provisions are untouched by the vacatur.

The parenthetical is the whole ballgame. Section 1681c(a)(6) permits a report to carry medical account information as long as it's coded so a lender can't infer the provider or what you were treated for. That's why a medical collection on your report shows up as a generic furnisher code and a balance rather than the name of an oncology practice. A lender sees that you owe a collection agency $1,400. It does not see why.

That coding requirement is real protection, and it's the reason the vacated rule failed. Congress had already decided how medical information gets handled, and it chose coding over exclusion.

What the bureaus actually do with a medical collection today

Take an unpaid hospital bill and follow it through. Four gates decide whether it reaches your report at all.

• Has it been a full year since the service?

  The three bureaus wait one year from the date of service before an unpaid medical collection can appear, up from six months before July 2022. Before that, unpaid medical bills were generally furnished after 60 to 120 days.

• Was the initial reported balance $500 or more?

  Anything under $500 is excluded outright, and the test is the balance as first reported, not what's owed today after fees.

• Is it still unpaid?

  Paid medical collections are excluded regardless of when they were paid or how long they sat unpaid first.

• Is it within seven years plus 180 days of first delinquency?

  Medical collections follow the same FCRA reporting clock as every other collection.

CFPB consumer guidance (May 2023); joint bureau announcements (March 2022, April 2023).

Miss any one of those and the tradeline shouldn't be there. Clear all four and it can be reported, and from that point it behaves like any other collection, including on the seven-year reporting clock and the date-of-first-delinquency rule that governs when it has to come off. The full route a bill takes from a provider's billing office to a collection agency is covered in what happens when medical bills go to collections.

The $500 test trips people up in one specific way. It runs on the balance as first reported by the collection agency, not the amount you owe today and not the amount the hospital originally billed. A $480 collection that grew past $500 through interest or fees is still an under-$500 collection for reporting purposes. A $2,300 hospital bill that a collector partly wrote down to $460 is not, because $2,300 is what was first reported.

How much did that threshold actually clear away? The CFPB's Office of Research estimated that 22.8 million people would have at least one medical collection removed, about 73% of everyone carrying a medical collection as of December 2022. The same April 2023 analysis found that half of those people would still have at least one medical collection left afterward. The change was enormous and partial at the same time, which is why "medical debt doesn't count anymore" is such a common and costly misreading.

Do medical collections still hurt your credit score?

Yes, when they're reported, and how much depends entirely on which model the lender pulls.

FICO 8 remains the workhorse in most consumer lending, and it treats a reported medical collection like any other collection. FICO 9 and the FICO 10 suite changed that. myFICO's own documentation says unpaid medical collections over $500 "are considered, but have less impact on the score within FICO Score 9 and the FICO Score 10 suite compared to older FICO Score versions," and that collections reported as paid in full are disregarded entirely by those versions.

VantageScore went furthest. In August 2022 it announced that neither VantageScore 3.0 nor 4.0 would continue to use medical debt collection data "regardless of the amount owed or the age of the collection," with implementation landing at the end of January 2023. It estimated affected consumers would see increases of as much as 20 points. That's a model estimate for a population, not a forecast for your file.

None of this is something you control. You can't choose which model a lender pulls, which is why how much a collection actually drops your score is a range rather than a number, and why two people with the same medical collection can see very different results. What you can control is whether an item that shouldn't be reported is sitting there anyway, which is the single highest-yield thing to check. The broader menu of what genuinely takes a collection off a report is in the guide to removing collections.

How does a medical bill become a collection in the first place?

Medical billing runs on a looser clock than credit card debt, and the loose parts are where you have room to act.

A card issuer's timeline is mechanical: miss a payment, get reported at 30 days, get charged off at around 180. A provider has no such schedule. Hospitals and physician groups bill in cycles, wait on insurance, rebill, and send statements for months. Before the 2022 policy change, unpaid medical bills were generally furnished to the credit bureaus after 60 to 120 days. Now the bureaus won't display one until a year has passed, which gives you a genuinely long window.

Nonprofit hospitals carry a further constraint, and it's one almost nobody mentions. Under IRS section 501(r)(6), reporting adverse information about you to a credit agency is an "extraordinary collection action." Before taking one, a tax-exempt hospital facility has to make reasonable efforts to determine whether you qualify for its financial assistance policy, notify you about that policy, and refrain from the collection action for at least 120 days from the first post-discharge billing statement. Financial assistance applications stay open through a 240-day application period.

Read that together with the bureaus' one-year wait and the picture changes. Between the hospital's 120-day floor, the 240-day application window, and the year before anything can be displayed, a nonprofit hospital bill has a long runway before it can touch your credit at all. If such a bill went to collections and nobody ever handed you a financial assistance policy, that's worth raising directly with the hospital's billing office, and hospital charity care and how to qualify for it covers what those policies typically require and how far up the income scale they usually reach.

A medical collection appeared. What now?

Verify the bill before you verify anything about the credit reporting. Medical bills carry error rates that credit card statements simply don't, and paying a bill you didn't owe is the expensive way to fix a credit report.

Start by requesting an itemized bill from the provider and matching it against the explanation of benefits from your insurer. Duplicate charges, services you didn't receive, and claims the insurer should have paid are the common three. If the account is already with a collection agency, sending a debt validation request puts the burden on the collector to produce documentation before it keeps collecting.

One category is worth checking specifically. The No Surprises Act, effective January 1, 2022, limits surprise bills for emergency services from an out-of-network provider or facility, and for supplemental care such as radiology or anesthesiology delivered by out-of-network providers at an in-network facility. If you're uninsured or paying for care yourself, you're entitled to a good faith estimate before scheduled care, and the CFPB says you can dispute a bill that exceeds that estimate by $400 or more within 120 days. Ground ambulance rides sit outside the federal protection, which catches people out every year. If a bill looks like it should have been covered, the CMS No Surprises Help Desk takes complaints, and so does the CFPB.

If the bill is valid and simply more than you can pay, the negotiation lever is real: providers and hospital billing offices discount, and negotiating a hospital bill before and after it reaches collections walks through what to ask for at each stage. Once it's with a third-party agency, it behaves like any other collection account, which puts it inside the ordinary settlement negotiation playbook and the what-happens-next map for accounts in collections.

If the item shouldn't be reported at all, dispute it. The CFPB puts it plainly: if you find a medical collection under $500, a paid medical collection, a collection less than a year old, or errors on your report, you can dispute that information with the credit reporting company. Filing a credit report dispute that actually gets investigated covers the mechanics, and the medical-specific detail to lead with is the initial reported balance, since the $500 test runs on that figure rather than the current one.

Pull all three reports before you start. Each bureau applies its policy separately and receives data from different furnishers, so an item can be correctly absent from two reports and wrongly present on the third. Reading a credit report tradeline by tradeline is how you find the one that's out of step. Asking a collector to delete an accurate paid item is a different and much weaker play, covered in whether pay-for-delete still works.

Do state medical debt laws protect you?

A number of states have passed their own laws going further than bureau policy, banning medical debt from consumer reports outright rather than only below a threshold. Virginia's is the cleanest to read: Va. Code § 59.1-444.4 bars medical facilities, licensed practitioners, emergency medical services agencies, and any collection entity working a medical debt from reporting it to a consumer reporting agency at all.

States shown in blue have enacted statutes restricting medical debt on consumer reports.

Statutes verified individually: Cal. Civ. Code § 1785.13 (SB 1061, 2024); Colo. HB23-1126; Minn. Stat. § 332C.03; N.J. P.L. 2024 c.61; N.Y. Gen. Bus. Law §§ 380-a, 380-j (S4907A, 2023); R.I. Gen. Laws ch. 6-60; Va. Code § 59.1-444.4. Other states have passed similar laws.

Now the complication, and it's a live one. The FCRA contains a preemption provision, 15 U.S.C. § 1681t(b)(1)(E), covering state laws on "the subject matter regulated under section 1681c of this title, relating to information contained in consumer reports," with a carve-out only for state laws already in effect on September 30, 1996. Whether that provision knocks out a modern state medical debt reporting ban is exactly what's being fought over.

A federal court has now struck one of these laws down. On August 10, 2026, Judge Robert Pitman of the Western District of Texas ruled in Consumer Data Industry Association v. State of Texas that § 1681t(b)(1)(E) expressly preempts Texas Business & Commerce Code § 20.05(a)(5), and permanently enjoined the state from enforcing it. The Texas statute was a narrow one, covering only out-of-network emergency and facility-based balances owed by insured patients, which is why it isn't on the map above.

Two things about that ruling matter more than the headline. The court refused to go as far as the industry asked: it declined to hold that § 1681t(b)(1)(E) wipes out any state law touching information in consumer reports, limiting itself to subject matter § 1681c actually regulates. And it openly split with the First Circuit, which in Consumer Data Industry Association v. Frey, 26 F.4th 1 (1st Cir. 2022), read the same provision narrowly enough to let Maine's medical debt reporting law stand. A district court in Texas doesn't bind a bureau operating in Virginia or California. It does tell you which way the wind is blowing.

Where Felix fits

Felix negotiates with creditors and collectors on accounts you enroll, including medical accounts that have gone to a collection agency. Every letter is drafted for you, sent in your own name from your own return address, and mailed only after you read and sign it. Nothing goes out without your signature.

What Felix does not do is remove accurate information from a credit report, and no one honestly can. If your issue is that a medical collection under $500 or a paid one is showing anyway, that's a dispute you file yourself with each bureau, free, and the process is short. If your issue is a real balance you can't pay, negotiating it down is the lane Felix works in, and creditors are never obliged to accept an offer.

Checking eligibility uses a soft credit pull, which doesn't affect your score. Pricing is a flat subscription rather than a percentage of whatever gets forgiven, the FAQ answers what happens at each stage, and the privacy policy sets out what happens to your credit data and how long it's kept.