Thus, so long as the use of debt collectors is consistent with the regulatory requirements (such as, providers obtain the proper
consents, the disclosure is of the minimum amount of information
necessary to collect the debt, the provider or health
plan enter into a business associate agreement with the debt collector, etc.), relying upon debt collectors to obtain reimbursement for the provision of health care would not be prohibited by the regulation.
Requiring that
consent process between an individual and a health
plan or clearinghouse, when no such unique relationship exists, we believe is not
necessary.