The Center for Capital Markets Competitiveness (“CCMC”) appreciates the opportunity to submit comments regarding the Request for Information regarding medical payment products (the “RFI”).
Medical care providers play an important role in Americans’ lives, allowing them to live longer and better than ever before. Congress and relevant regulators have taken numerous policy actions to make this medical care more accessible and affordable. These actions include the creation of Medicaid and Medicare, the establishment of health insurance exchanges, and establishing protections for Americans when they seek care in an emergency room.
Practically speaking, financial services companies play an important role for Americans seeking healthcare, since they provide payment options to consumers making use of medical care when it is not paid for by insurance. However, we note as a threshold matter that there are significant limitations on the scope of payment providers’ role in the context of medical care. These limitations also result in a corresponding limitation in the authority of the CFPB and inform the scope of our comments today in two primary ways.
