In a letter dated April 15, 2026, CFPB General Counsel Seth Frotman urged Massachusetts Senator John J. Cronin and Representative John J. Lawn Jr. to pass HD. 3503 and SD. 1878. Frotman told the lawmakers the legislation "would cement important protections against medical bill credit reporting into Massachusetts law."

The endorsement follows the CFPB’s own federal regulation finalized on January 7, 2025, which bans medical bills from credit reports used by lenders and prohibits lenders from using medical information in lending decisions. Frotman noted that the federal rule has already been challenged in two lawsuits filed in Texas.

The bureau’s core argument is that medical debt is a poor proxy for creditworthiness and a vehicle for coercion. Frotman wrote that medical debt "is categorically different from most types of consumer tradelines that typically appear on consumer reports," citing bureau research showing it is less predictive of future credit performance.

According to the letter, 66 percent of consumers who report problems paying medical bills acquired their debt because of a one-time or short-term expense arising from an acute medical need. The CFPB also pointed to the prevalence of billing errors, noting that the most common consumer complaints allege the debt was already paid, does not belong to the consumer, or is otherwise incorrect.

Frotman described a recurring pattern in which consumers discover erroneous medical collection items only when applying for a mortgage or car loan. They then face a choice between, as he wrote, "a protracted fight to address the inaccuracy, often while recovering from serious illness, or to pay it without ample time to review, which is not an option for many."

Addressing preemption directly, the letter noted that the FCRA and FDCPA both provide narrow preemption of state law. The CFPB issued an interpretive rule in 2022 confirming that state laws prohibiting furnishers from reporting medical debt would generally not be preempted.

Industry challenges to similar state laws have failed: the First Circuit rejected a preemption challenge to Maine's Medical Debt Reporting Act in Consumer Data Industry Association v. Frey in February 2022, and the Ninth Circuit denied a challenge to Nevada Senate Bill 248 in Aargon Agency, Inc. v. O'Laughlin in June 2023.

Colorado and New York passed comparable legislation in 2023. The CFPB noted that major national consumer reporting companies announced in March 2023 that they would stop reporting some—but not all—medical bills. VantageScore eliminated all medical collection data from one of its scoring models in August 2022, stating it expected the impact on model performance "to be minimal for a large segment of the population."

Frotman closed by framing state action as integral to the bureau's broader consumer protection strategy. "States have long been valued and critical partners in establishing and fortifying protections for consumers," he wrote, offering continued collaboration on the Massachusetts bills.