Debt Collection & Recovery Software

How to Remain Compliant with Colorado Medical Debt Collection Laws in 2025

Published on:
November 17, 2025

Medical debt continues to challenge collection agencies nationwide. 12% of U.S. adults borrowed money to pay medical bills. In total, Americans took on $74 billion in healthcare-related debt over a single year. As balances grow, Colorado has responded with stricter laws to protect patients and ensure fair collection practices.

For agencies, these regulations mean more than just compliance checklists. They reshape outreach, documentation, and recovery strategies. This guide explains Colorado’s medical debt collection laws and how to avoid a penalty in 2025.

Quick glance:

  • Colorado has strengthened its medical debt collection laws, introducing measures such as a 3% annual interest cap, exceptions to credit reporting, and mandatory itemized billing statements to protect patients from aggressive collection practices.
  • SB23-093 and HB23-1126 define the state’s current regulatory framework, setting clear standards for healthcare providers, debt collectors, and credit agencies involved in medical debt recovery.
  • Compliance expectations for collection agencies have expanded, requiring accurate documentation, transparent communication, and adherence to HIPAA and state-specific disclosure rules.
  • National credit reporting policies are changing, with major credit bureaus scaling back or reconsidering the inclusion of medical debt data, signaling tighter oversight ahead.
  • Agencies that build patient-centric, legally aligned workflows today will be better equipped to manage risks, maintain consumer trust, and adapt to further medical debt reforms.

Legal Foundation: What the Law Says

Colorado’s tightening of medical debt laws stems from the growing crisis of unpaid healthcare bills that have long burdened residents. 11% of Coloradans had medical debt in collections, placing the state among those most affected by medical-related financial stress.

Lawmakers responded with two key pieces of legislation designed to promote transparency, fairness, and accountability in the medical debt collection process.

1. Senate Bill 23-093: Fairness in Medical Debt Collection

Introduced in the Colorado Senate and enacted in May 2023, SB23-093 focuses on improving billing transparency and curbing predatory collection practices. It applies to healthcare providers, collection agencies, and debt buyers.

Key provisions include:

  • 3% annual interest cap on medical debt, replacing higher previous limits.
  • Itemized statement requirement before initiating any collection action.
  • Payment plan transparency, requiring clear terms and timelines.
  • Prohibition on collection activity during pending insurance or billing appeals.
  • Disclosure obligations to ensure consumers understand their rights before payment demands.

2. House Bill 23-1126: Limits on Medical Debt Credit Reporting

Introduced in the Colorado House and enacted in August 2023, HB23-1126 targets how medical debt is reported to credit bureaus. Its goal is to prevent credit harm from debts that may be inaccurate, disputed, or recently incurred.

Key provisions include:

  • Prohibition on reporting most medical debt to credit agencies before the waiting time period has passed from initial billing.
  • Notice requirements for consumers before any debt is reported.
  • Applicability extends to healthcare providers, collection agencies, and credit reporting companies.
  • Enhanced consumer protections for those settling or disputing medical bills.

Together, these laws redefine what compliance means for collection agencies in Colorado. They emphasize transparency, accurate reporting, and ethical recovery practices.

These are standards that agencies must now uphold to avoid costly violations. But how do these new laws translate into day-to-day compliance for debt collection agencies? The next section explores exactly that.

Suggested Read: Medical Debt Collection and Healthcare Services

Compliance Requirements for Debt Collection Agencies

The new Colorado medical debt laws redefine consumer protections. Compliance now goes beyond courteous communication or timely disclosures. It requires proactive alignment of your billing, reporting, and record-keeping practices with all legal expectations set out in SB23-093 and HB23-1126.

Below are the core compliance areas you must address to remain fully aligned with the state’s framework.

1. Interest Rate Compliance

Under SB23-093, you cannot charge more than 3% annual interest on any medical debt. This rule aims to prevent inflated repayment burdens on consumers.

Your responsibilities to remain compliant include:

  • Updating your internal systems to cap medical debt interest at 3% automatically.
  • Reviewing historical accounts to ensure retroactive compliance where applicable.
  • Training your collectors to communicate the reduced interest rate clearly during recovery discussions.

2. Itemized Statement Before Collection

Before you initiate any collection activity, you must provide consumers with a detailed, itemized statement that lists every charge and adjustment. This ensures full transparency and reduces disputes.

You can begin by:

  • Confirming receipt of itemized statements from providers before proceeding.
  • Verifying that statements include service dates, charges, insurance payments, and remaining balances.
  • Keeping proof of delivery for audit or complaint resolution purposes.

3. Prohibition During Insurance or Billing Appeals

Collection activity is prohibited while an insurance or billing appeal is pending. Acting prematurely could lead to legal penalties and consumer complaints.

Collection agencies need to:

  • Establish a verification process with providers to confirm no active appeals exist.
  • Place disputed accounts on administrative hold until appeals are resolved.
  • Document each verification step for compliance tracking.

4. Credit Reporting Restrictions (HB23-1126)

Under Colorado law, you may not report medical debt to credit bureaus at all. House Bill 23-1126 prohibits consumer reporting agencies from including medical debt information in consumer credit reports, except in very limited cases involving high-value credit transactions.

To remain compliant, you should:

  • Remove all automated workflows that send medical debt data to credit bureaus.
  • Ensure your staff and vendors understand that medical debt cannot be reported under Colorado law.
  • Update your consumer communication templates to reflect the current rule and avoid implying that medical debt will appear on a credit report.

5. Notice and Disclosure Obligations

Transparency is central to compliance. You must notify consumers of their rights and provide clear information about the status of their debt.

Your responsibilities include:

  • Including statutory disclosures in all written communications.
  • Maintaining templates that reflect updated Colorado-specific language.
  • Training collectors to explain these notices verbally and in writing.

6. Record-Keeping and Audit Readiness

Both SB23-093 and HB23-1126 assume that you can prove compliance through proper documentation. Failure to maintain records could be treated as noncompliance.

Do not miss out on:

  • Retaining copies of itemized statements, communications, and proof of notice for a defined retention period.
  • Using digital compliance logs to track every collection milestone.
  • Preparing for random audits or consumer complaints by ensuring quick data access.

Modern compliance demands more than manual oversight—and this is where Tratta optimizes your process. Its automated compliance workflows track state-specific regulations, such as Colorado’s interest caps and credit-reporting delays, and alert your team before any action risks noncompliance.

With centralized audit logs and real-time rule updates, Tratta helps your agency stay compliant while focusing on recovery performance. Learn more by scheduling a demo today.

Colorado’s legislative updates are part of a broader movement reshaping how medical debt is managed across the United States. To understand where this trend is heading next, the following section explores broader national coverage of medical debt statutes.

Suggested Read: Understanding Medical Debt Collection and FDCPA Regulations

National Shift in Medical Debt Reporting Standards

When the three major credit reporting agencies—Equifax, Experian, and TransUnion—announced in 2023 that they would stop reporting paid medical collection debt and remove debts under $500, it was seen as a major step toward consumer fairness.

But things have changed since then. The national framework for medical debt reporting has continued to change, and as a collection agency, you must take stock of the following developments shaping your compliance strategy in 2025:

  • Federal Action and Its Reversal (2025)
  • The Consumer Financial Protection Bureau (CFPB) finalized a rule in early 2025 that banned medical debt from consumer credit reports entirely. However, by July 2025, a federal court vacated the rule, leaving the industry in limbo and returning control to individual states.
  • Colorado’s Continued Leadership
  • Colorado remains ahead of the curve. HB23-1126 already restricts credit reporting of medical debt and requires extended waiting periods before any data can be shared. In 2024, state regulators issued additional guidance reinforcing data accuracy obligations for collectors handling health-related debts.
  • HIPAA Considerations
  • Compliance now intersects with HIPAA privacy protections, especially when sharing consumer health-related financial information with third parties. Any data breach or unauthorized disclosure tied to medical billing information can trigger both state and federal penalties.
  • Credit Industry Realignment
  • With national reporting agencies continuing to self-restrict medical debt data and financial institutions reevaluating how they assess creditworthiness, collectors must anticipate greater scrutiny on data integrity and documentation at every stage of the recovery process.

These laws have made it necessary for debt collection agencies to be more cautious than ever—because the risks of getting it wrong can be severe. The next section explores the operational risks and penalties for creditors.

Suggested Read: Healthcare & Medical Debt Collection Software

Penalties for Creditors for Violating Colorado Laws

Violations of SB23-093 or HB23-1126 can trigger administrative action, civil liability, and severe reputational damage. As a collection agency, even unintentional errors, such as reporting too early, applying the wrong interest rate, or failing to provide itemized documentation, can lead to fines or litigation.

This is a breakdown of what is at stake under the state’s enforcement framework.

  • Civil Penalties under the Colorado Fair Debt Collection Practices Act (CFDCPA)
  • Violations can result in fines per incident and exposure to consumer lawsuits for damages and attorneys’ fees. Repeat or willful violations may invite action from the Colorado Attorney General’s Office, compounding liability.
  • Enforcement by the Colorado Attorney General (SB23-093)
  • The Attorney General can investigate, issue subpoenas, and impose administrative penalties for noncompliance with billing or disclosure requirements. Agencies that continue collection during an active billing appeal or exceed the 3% interest cap risk enforcement proceedings.
  • HIPAA-Related Violations
  • Disclosing or mishandling consumer medical information during collection can violate HIPAA privacy rules, leading to civil and criminal penalties, depending on the level of negligence.
  • Licensing and Reputational Impact
  • Noncompliance can affect your collection agency license in Colorado, as regulatory bodies may review violations during renewal or complaint reviews. Additionally, public enforcement actions can harm your standing with clients and healthcare providers.

Colorado’s enforcement climate leaves little room for procedural lapses. To avoid costly penalties and maintain trust, agencies must move from reactive compliance to proactive governance. The next section outlines best practices to help you stay legally aligned.

Suggested Read: How to Write a Medical Settlement Proposal Letter

Best Practices for Agencies to Stay Legally Compliant

Colorado’s medical debt laws require agencies to reexamine how they collect, communicate, and document every transaction. By embedding compliance into your daily operations, you can reduce risk exposure and maintain the trust of both regulators and clients.

These are a few tips that can ensure you remain within the legal boundaries:

  • Adopt State-Specific Compliance Frameworks: Customize your workflows to reflect Colorado’s rules, including the 3% interest cap and itemized statement requirements. Use state-by-state compliance mapping to ensure no overlap or omission.
  • Automate Regulatory Oversight: Use technology to monitor legal thresholds and documentation requirements automatically. Use technology to integrate these rules directly into your processes to prevent accidental violations.
  • Conduct Regular Staff Training: Ensure collectors understand current legislation, disclosure standards, and HIPAA requirements for handling sensitive data. Refresher training sessions can help your team stay current with enforcement interpretations.
  • Implement Internal Audits and Quality Checks: Review a random sample of active accounts each month to confirm adherence to statutory notice, reporting, and documentation rules. Document corrective measures for any discrepancies found.
  • Maintain Audit-Ready Documentation: Keep digital records of every notice, payment communication, and itemized statement. Comprehensive records not only support transparency but also protect your agency during audits or consumer complaints.
  • Engage Legal Counsel and Compliance Experts: Consult attorneys or compliance specialists familiar with Colorado’s collection framework to periodically review policies, scripts, and third-party vendor practices.

Tratta offers a Compliance-by-Code architecture where every workflow is built to uphold regulatory integrity from the ground up. The platform maintains audit-ready records and configurable compliance policies that align with laws like Colorado’s SB23-093 and HB23-1126. Contact us to understand how these standards can be directly integrated into your collection operations.

How to Build Patient-Centric Collection Strategies

Patients are not traditional debtors. They require a sensitive approach that addresses their medical, emotional, and often financial challenges.

Building patient-centric strategies not only aligns with HIPAA regulations but also enhances trust, improves recovery rates, and strengthens your agency’s professional credibility. These are a few proven ways:

  • Prioritize HIPAA-Compliant Communication: All patient data shared, stored, or processed must be handled according to HIPAA’s Privacy and Security Rules. Use encrypted communication channels and ensure collectors are trained to avoid discussing sensitive information with unauthorized parties.
  • Establish Clear Business Associate Agreements (BAAs): If your agency handles protected health information (PHI) on behalf of healthcare providers, you must establish BAAs. The BAA must define responsibilities, permissible uses of PHI, and breach notification procedures.
  • Adopt Empathetic Communication Protocols: Encourage agents to communicate respectfully and transparently, providing patients with itemized details and repayment options. Scripts should focus on support rather than pressure, making each interaction compliant and humane.
  • Offer Flexible Payment Arrangements: Customize payment plans that reflect patients’ ability to pay, in accordance with Colorado’s medical debt laws and billing transparency requirements. This reduces disputes and strengthens long-term engagement.
  • Integrate Secure Digital Payment and Consent Tools: Use secure portals where patients can review balances, consent to terms, and make payments privately. Maintaining digital audit trails also supports compliance during reviews or audits.
  • Monitor Feedback and Adjust Practices: Collect patient feedback regularly to assess communication tone, privacy handling, and satisfaction. Use this data to refine policies and demonstrate good faith in compliance audits.

To make these principles actionable, the next section explores how Tratta automates risk controls and embeds compliance directly into medical debt workflows.

Tratta Can Automate Risk Controls in Medical Debt Workflows

If your agency manages medical debt portfolios, compliance cannot be an afterthought. Tratta offers a modern, all-in-one debt collection platform that automates risk controls and enforces laws like Colorado’s SB23-093 and HB23-1126.

These features can help you stay compliant while maintaining debtor trust:

1. Consumer Self-Service Payment Portal

This feature allows patients to access and resolve their accounts directly through a secure, branded portal. They can review itemized statements, set up payment plans, and make payments online without involving an agent. By capturing every action automatically, the portal supports documentation for audits and ensures you meet medical debt communication requirements.

2. Multilingual Payment IVR

Tratta’s IVR system supports multiple languages, allowing you to serve diverse patient populations while maintaining compliance with state disclosure rules. Patients can make payments securely over the phone and receive information in a language they understand. Every interaction is recorded for transparency and HIPAA compliance.

3. Omnichannel Communications

With voice, SMS, email, and portal messages managed from one dashboard, Tratta keeps your outreach consistent and compliant. You can send legally approved messages and maintain a record of all communications for audit purposes. This reduces the risk of unwanted contact, consumer complaints, and regulatory violations.

4. Tratta Campaigns

Campaigns allow you to segment portfolios and automate state-specific workflows. You can customize triggers, send compliance-aligned notices, and adjust workflows as laws evolve. This ensures every medical debt account follows the correct process from first contact to closure.

5. Payment and Merchant Services

Tratta’s integrated payment solution simplifies secure payment processing while maintaining compliance with interest rate limits and refund requirements. You can accept multiple payment types and track every transaction in real time. Built-in fraud prevention and detailed audit logs protect both consumers and your agency.

6. Reporting and Analytics

The platform’s reporting tools give you real-time insight into operational performance, compliance metrics, and patient engagement. You can monitor dispute rates, payment timelines, and credit-reporting timelines across all accounts. These insights help identify risks early and keep your agency compliant with state and federal standards.

7. Customization and Flexibility

Tratta allows you to tailor workflows, disclosures, and templates to your agency’s specific medical debt processes. You can embed state rules, such as Colorado’s 3% interest cap, directly into your system logic. This flexibility ensures compliance without disrupting your existing operations.

8. Integrations

Tratta integrates seamlessly with CRMs, billing systems, and healthcare provider databases to maintain data accuracy and compliance. You can validate insurance status or itemized statements before initiating collections, reducing dispute risk. All data transfers remain encrypted and fully HIPAA-compliant.

9. Security and Compliance

Tratta’s architecture is built for regulatory integrity, backed by SOC 2 Type II and PCI DSS Level 1 certifications. It enforces compliance through embedded rules and maintains detailed audit-ready records for seven years. These safeguards ensure your agency operates securely and remains aligned with changing debt collection regulations.

Tratta helps agencies stay ahead by automating jurisdictional rules, enforcing disclosure timing, and suppressing non-compliant accounts before they reach credit bureaus.

Conclusion

Collection agencies must prepare for a shifting compliance framework. State-level laws like Colorado’s continue to change, and federal actions—such as attempts to ban medical debt from credit reports—may resurface. You need to stay agile and informed. Investing now in robust compliance frameworks will help you stay ahead and turn regulatory change into a strategic advantage.

With Tratta, you gain a partner that updates its platform in real time to reflect legislative amendments, state-specific rules, and changing consumer protections. Our flexible subscription plans let you select the level of automation, oversight, and audit support that fits your agency’s size and complexity.

Explore our compliance solution today. Schedule a demo to see how you can simplify medical-debt collections while mitigating risk.

Frequently Asked Questions

1. How do Colorado’s medical debt collection laws differ from federal regulations like the Fair Debt Collection Practices Act (FDCPA)?

Colorado’s laws add specific consumer protections beyond the FDCPA, such as a 3% annual interest cap, stricter credit reporting timelines, and mandatory itemized statements before collection begins. These rules are designed to address the state’s medical debt crisis more directly than federal standards.

2. Can a collection agency contact a patient’s employer about unpaid medical debt in Colorado?

No. Under both state and federal laws, contacting a consumer’s employer about medical debt is generally prohibited except for verifying employment or insurance details. Agencies must ensure all communications comply with privacy and disclosure requirements.

3. How does Colorado law handle medical debt for minors or dependents?

When the patient is a minor, the debt typically becomes the responsibility of the parent or guardian who signed the treatment agreement. Agencies must verify account ownership carefully to avoid collecting from the wrong party or violating HIPAA.

4. What documentation must a debt collection agency keep to prove compliance under Colorado’s medical debt laws?

Agencies must retain detailed records of communications, itemized statements, interest calculations, and credit reporting timelines. Maintaining audit-ready documentation is essential for demonstrating compliance during state or federal reviews.

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