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Revenue cycle

What should a hospital include in an RFP for early-out and bad-debt collection services?

Under 501(r), your vendor's mistake is your mistake. This kit gives you the pass/fail gates, weighted criteria, model questions and an editable scoring template for an early-out and bad-debt RFP.

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Short answerLast reviewed Nov 5, 2026

A hospital's early-out and bad-debt RFP should first confirm that a vendor will follow its financial assistance policy and 501(r) timelines, sign its business associate agreement and stop collecting when a patient applies for help or disputes a bill. Then it should score patient protections, compliance, security, recovery by stage, reporting and price on a written scale.

About this page

TSI (Transworld Systems Inc.) publishes it. TSI provides Accounts Receivable Management (ARM), Healthcare Revenue Cycle Management (RCM), CXBPO and Loan Servicing (via UAS). DebtNext, a TSI company, makes recovery management software for creditors. Some options this page describes compete with services TSI sells. Each figure names its publisher and date so you can check it yourself.

Change any gate, weight or question in the template to fit your hospital; the scoring summary recalculates.

How to use this kit

Decide 4 things before you write:

  1. Stage and scope: early-out (patient balances worked in your name before write-off), bad debt (after write-off, in the agency's name) or both, and how accounts move between vendors. See how EBO, early-out and bad debt differ.
  2. Your policy: whether credit reporting, lawsuits, liens, interest or late fees are allowed at all. The vendor follows it, so write it down first.
  3. Your systems: which EHR and billing system the vendor exchanges files with, and whether bad-debt accounts stay in your system or move to the vendor's.
  4. Who scores. Revenue cycle, compliance, privacy and security, patient experience and finance each score their own section alone before the panel meets.

The rules that shape the RFP

For a tax-exempt hospital, 501(r) follows the account to the vendor. The hospital is treated as having taken any extraordinary collection action (ECA) that "any debt collection agency or other party to which the hospital facility has referred the individual's debt" takes (26 CFR 1.501(r)-6(a)(2)). ECAs include selling the debt, reporting it to credit bureaus, and actions that need a legal or judicial process, such as lawsuits, liens and wage garnishment.

Before any ECA, the hospital must make reasonable efforts to learn whether the patient qualifies for financial assistance. One way is to notify the patient and hold ECAs "for at least 120 days from the date the hospital facility provides the first post-discharge billing statement for the care" (26 CFR 1.501(r)-6(c)(3)(i)), while accepting applications through at least the 240th day after that statement (26 CFR 1.501(r)-1(b)(3)). A hospital that refers debt needs a written agreement that makes the vendor suspend ECAs if the patient applies within that period, and pass the same terms to anyone it refers the debt to (26 CFR 1.501(r)-6(c)(10)).

When an uninsured or self-pay patient disputes a bill that's substantially higher than the good faith estimate, the provider "must not move the bill for the disputed item or service into collection or threaten to do so" while the dispute is pending, should stop collection already under way, and must suspend late fees (45 CFR 149.620(c)(5)).

HIPAA lets you share protected health information with a vendor only with assurances documented in a written contract, the business associate agreement, and the vendor needs the same from its own subcontractors (45 CFR 164.502(e)). At contract end, that agreement requires the vendor to return or destroy the information where feasible (45 CFR 164.504(e)(2)(ii)(J)).

Credit reporting rules are moving. A federal court vacated the CFPB's January 2025 medical debt rule on July 11, 2025. The National Consumer Law Center counts 15 states and the District of Columbia that limit medical-debt reporting (September 2026 update), and a CFPB interpretive rule from October 2025 says federal law "generally preempts State laws that touch on broad areas of credit reporting." Your policy can be stricter than all of them.

Where the rule stands

Rule501(r) billing and collection (26 CFR 1.501(r)-1 and 1.501(r)-6)
Stage
In effect
Date
Final rules published Dec 31, 2014 (79 FR 78954), effective Dec 29, 2014; eCFR text last amended Jul 12, 2016
What applies today
A tax-exempt hospital answers for its vendors' ECAs, and ECAs wait for reasonable efforts
Next trigger
None scheduled
Last checked
TSI Marketing, Sep 28, 2026
RuleNo Surprises Act patient-provider disputes (45 CFR 149.620(c)(5))
Stage
In effect
Date
Interim final rules published Oct 7, 2021 (86 FR 55980); apply generally from Jan 1, 2022
What applies today
While an eligible dispute is pending, the bill stays out of collection and late fees stop
Next trigger
None scheduled
Last checked
TSI Marketing, Sep 28, 2026
RuleHIPAA business associate contracts (45 CFR 164.502(e) and 164.504(e))
Stage
In effect
Date
As amended Jan 25, 2013 (78 FR 5566), effective Mar 26, 2013
What applies today
A written agreement before PHI is shared, and return or destruction at contract end where feasible
Next trigger
A final rule on HHS's Jan 6, 2025 Security Rule proposal (90 FR 898); none published as of Oct 13, 2026
Last checked
TSI Marketing, Sep 28, 2026
RuleCFPB medical information rule (Regulation V)
Stage
Vacated
Date
Published Jan 14, 2025 (90 FR 3276); vacated Jul 11, 2025
What applies today
The rule doesn't apply
Next trigger
None scheduled
Last checked
TSI Marketing, Sep 28, 2026
RuleCFPB interpretive rule on FCRA preemption
Stage
In effect
Date
Published Oct 28, 2025 (90 FR 48710)
What applies today
The CFPB's view of preemption; courts decide each case
Next trigger
None scheduled
Last checked
TSI Marketing, Sep 28, 2026

Pass/fail gates

Screen every response on these before scoring. A vendor that fails one doesn't reach the scoring sheet.

  • Licensed or registered wherever the work and the law require it, with a license inventory
  • Will sign your business associate agreement, and has one with every subcontractor that touches PHI
  • Every regulatory order, consent agreement, settlement and pending lawsuit disclosed, with dates
  • Will follow your policies on financial assistance, interest, credit reporting and legal action, including any prohibition
  • Insurance, including cyber coverage, at the levels you set
  • Current independent security audit reports, with scope and dates
  • References from hospitals or health systems like yours

The 8 criteria and default weights

Criterion Weight What it covers TSI's answer
Patient financial protections and 501(r) 20 Assistance screening, ECA and dispute holds, your policy on interest, credit reporting and lawsuits
Compliance and regulatory record 15 Compliance ownership, orders and remediation, state medical-debt law tracking, licensing Company facts
Data security and HIPAA 15 Business associate terms, audit reports, data locations, offshore access, breach notice, PHI at contract end Trust center and data at contract end
Recovery performance by stage 15 Early-out resolution and bad-debt liquidation by placement month, outcomes other than cash, coverage found Early-out and bad-debt costs
Patient experience and complaints 10 Statements, portal, payment plans, language access, complaints, call quality Call monitoring and complaint handling
EHR integration, reporting and oversight 10 File exchange with your EHR, where accounts are worked, reports, audit rights Healthcare revenue cycle services
Pricing and commercial terms 10 Rates by stage, costs outside the rate, fees on accounts moved to assistance or recalled, termination Early-out and bad-debt costs
Implementation, staffing and transition 5 Interface testing, staffing and surge plan, handover from your current vendor Healthcare revenue cycle services
Total 100

Patient protections get the most weight because a vendor's mistake there is the hospital's mistake under 501(r), and it lands on your patients first.

Model questions, and what a strong answer shows

The template holds 35 questions. These separate vendors fastest.

Question A strong answer shows
How does your system hold ECAs until we confirm reasonable efforts under our financial assistance policy? ECAs off by default, our policy rules loaded, clocks run from the first post-discharge statement date we send, and an audit trail for every hold and release
What happens when a patient applies for financial assistance after placement? Collection suspended at once, the application routed to us, reversals or refunds if the patient qualifies, and the same terms passed to anyone else holding the account
How do you learn that a No Surprises Act dispute is pending, and how fast do you stop? A flag from us, collection stopped the same day, late fees off and no threats while it's open
Will you follow our policy on interest, credit reporting and lawsuits, including a full prohibition? Yes, enforced by system settings you can see, plus a state matrix of medical-debt reporting limits with effective dates
How do early-out letters and calls differ from bad-debt ones, and how do you control the handoff? Separate letters and scripts by stage, clear caller identification, and every hold and dispute flag carried across
Will you sign our business associate agreement, and which data fields do you need? Yes, a field list limited to what the work needs, and agreements with every subcontractor that touches PHI
Report early-out resolution and bad-debt liquidation by placement month for hospitals like ours. Data by stage with definitions, sample size and period, and a stated rule for accounts moved to assistance or insurance
What costs sit outside your rate, and how do fees apply to accounts moved to assistance, coverage found or recalled? Every cost listed, with the fee rule for each of those outcomes written into the contract

How to score each answer

Score each answer from 0 (no answer) to 5 (checked evidence plus a commitment you can write into the contract), on the scale the collection services RFP kit defines point by point. The template averages scores within each criterion, then weights them: criterion points = weight × (average score ÷ 5), for a total out of 100.

Before you award

  • Send a test file through your EHR interface, and check the acknowledgement, the exceptions and the first statement or letter.
  • Check test accounts for hold dates that match your policy and your first post-discharge statement dates.
  • Listen to scored calls, including one where a patient asks about financial assistance.
  • Consider a pilot on one facility or segment before a full award.

This template is a starting point, current as of Nov 5, 2026. It isn't legal advice. Change it to fit your needs, and have your own counsel review any contract terms before you use them.

Download the template

The early-out and bad-debt vendor RFP template (Excel) has 5 tabs: instructions, pass/fail gates, criteria and weights, the 35 model questions with what a strong answer shows and a score column for each vendor, and a scoring summary for up to 5 vendors. It uses plain formulas, so it works in Excel, Excel for the web and SharePoint. Download the template.

Add TSI to your invite list

If you're building an invite list now, send your RFP or invite-list request to TSI. The pages linked in the criteria table are TSI's own answers to this kit. Outside healthcare, use the collection services RFP kit. For a wider look at partners, see how to evaluate a healthcare RCM partner.

Test a vendor on your own claims first

Before a full award, the Denials Economics Sprint takes one payer and one denial class, sets a baseline and reports overturn, paid yield, cash, cost per claim and the economic threshold.

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