Medical Bills Covered by Workers’ Compensation Are “Consumer Debts” – Narrowing the Bona-Fide-Error Defense
Comprehensive Commentary on Abdul Crawford v. North American Credit Services, Inc., No. 24-13931 (11th Cir. July 1, 2025)

1. Introduction

In Abdul Crawford v. North American Credit Services, Inc. (“Crawford”), the Eleventh Circuit confronted two recurring questions in Fair Debt Collection Practices Act (FDCPA) litigation:

• Whether medical bills that are, by statute, payable by an employer’s workers’ compensation carrier can still be treated as a “consumer debt” under 15 U.S.C. §1692a(5).
• What a debt collector must show to invoke the Act’s bona fide error defense, 15 U.S.C. §1692k(c).

The plaintiff, Abdul Crawford, sustained work-related injuries while employed as a courier for AdventHealth. Although Florida’s workers’ compensation scheme obligated AdventHealth’s carrier—not Crawford—to pay the resulting hospital charges, the hospital forwarded the bills to North American Credit Services, Inc. (NACS), which sent two collection letters to Crawford. Crawford sued, alleging false representation of the “character, amount, or legal status” of the debt, a violation of §1692e(2)(A). The District Court entered summary judgment for Crawford; NACS appealed.

2. Summary of the Judgment

The Eleventh Circuit (Newsom, Grant, & Wilson, JJ., per curiam) affirmed, holding:

1. The disputed medical bills are “debts” within the meaning of the FDCPA because the underlying transaction—medical treatment—was primarily for personal purposes, regardless of the fact that workers’ compensation ultimately pays the charges.
2. NACS failed, as a matter of law, to establish the third element (“procedures reasonably adapted”) of the bona-fide-error defense; mere reliance on the creditor, statutory validation notices, or post-error instructions is insufficient.

3. Analysis

3.1 Precedents Cited

• Mais v. Gulf Coast Collection Bureau, Inc., 768 F.3d 1110 (11th Cir. 2014) – confirmed that medical bills are ordinarily consumer debts; the panel relied on Mais to reject NACS’s argument that workplace injuries change that result.
• Owen v. I.C. System, Inc., 629 F.3d 1263 (11th Cir. 2011) – the pivotal precedent defining the three-part bona-fide-error test and stressing that procedures must be reasonably adapted to avoid the specific error; extensively quoted by the panel.
• Celotex Corp. v. Catrett, 477 U.S. 317 (1986) – articulated the burdens under Rule 56; used to explain why NACS, the party with the burden on its affirmative defense, had to offer evidence, not mere assertions.
• Thai Meditation Ass’n of Ala. v. City of Mobile, 83 F.4th 922 (11th Cir. 2023) – recited for the standard of review on cross-motions for summary judgment.
• Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) – referenced for the definition of “material fact.”

3.2 Legal Reasoning

3.2.1 “Consumer Debt” Determination

The FDCPA defines a debt as any obligation … arising out of a transaction … primarily for personal, family, or household purposes. NACS tried to characterize the bills as business expenses because the injury occurred in the course of employment. The court distinguished between:

• The injury (occurring while working) and
• The transaction (medical services rendered to Crawford personally).

Observing that receiving medical treatment is not part of a courier’s work duties, the panel treated the medical services as inherently personal. That workers’ compensation law shifts the obligation to an employer/carrier does not alter the underlying purpose of the services. Thus, the Act applied.

3.2.2 Rejection of the Bona-Fide-Error Defense

Only the third prong—maintenance of procedures reasonably adapted to avoid the specific error—was contested. The court found that NACS:

• Presented no admissible evidence (affidavits, deposition testimony, authenticated manuals) showing existing preventive procedures.
• Relied on AdventHealth’s internal screening, which Owen forbids; delegating responsibility to creditors is inadequate.
• Pointed to its statutory validation notice—yet after-the-fact measures do not prevent the initial misrepresentation.
• Cited an insurance work instructions document that assists patients in filing claims; the court characterized it as remedial, not preventative, hence irrelevant under Owen.

Because NACS bore the burden of proof and produced no competent evidence of genuinely preventive systems, summary judgment for Crawford was appropriate.

3.3 Impact of the Decision

1. Expansion of FDCPA Coverage – The opinion cements the principle that medical bills remain “consumer debts” even when workers’ compensation statutes assign payment to the employer or its insurer. Other circuits had not squarely faced this nuance; the Eleventh Circuit’s ruling may be persuasive nationwide.
2. Heightened Compliance Expectations for Medical-Debt Collectors – Collectors cannot rely on hospitals’ internal triage to weed out non-collectible accounts. They must implement front-end validation procedures (e.g., querying workers’ compensation status) before a letter is sent.
3. Narrower Path for the Bona-Fide-Error Defense – The decision reiterates that post-violation fixes and creditor reliance are insufficient. Expect more summary-judgment defeats for collectors who cannot document proactive systems.
4. Workers’ Compensation Quandaries – When employers’ carriers delay or deny payment, providers often turn to collection agencies. After Crawford, such agencies face FDCPA liability if they pursue the employee; hospitals may have to reform billing flows or face higher indemnity claims from carriers.
5. Litigation Strategy – Plaintiffs’ counsel will reference Crawford to overcome motions to dismiss that argue absence of a “debt” in employment-related medical contexts and to defeat bona-fide-error defenses on summary judgment.

4. Complex Concepts Simplified

• FDCPA “Debt” – Think of it as any bill primarily for personal use. Who ultimately pays (insurer, employer) is usually irrelevant.
• Bona-Fide-Error Defense – A narrow safe harbor. The collector must prove: (1) the violation was accidental; (2) it was a genuine (“bona fide”) mistake; and (3) it had real, proactive procedures designed to stop exactly that mistake before it happens.
• Summary Judgment – A procedural tool to end a lawsuit without trial when no real disputes over important facts exist. The moving party must show that even if all evidence is viewed favorably to the opponent, the law still requires judgment for the mover.
• Workers’ Compensation vs. Personal Debt – Workers’ compensation laws shift liability but do not change the nature of the underlying medical service from personal to business.

5. Conclusion

Crawford crystallizes two significant rules within the Eleventh Circuit:

1. Medical bills ordered to be paid by workers’ compensation insurance are nonetheless “consumer debts” subject to the FDCPA, because their purpose is personal care.
2. The bona-fide-error defense demands documented, pre-emptive compliance systems internal to the debt collector; reliance on creditors or back-end notices will not suffice.

These holdings fortify consumer protections for injured workers and place the onus squarely on collection agencies to develop rigorous front-end verification protocols. Given the growing scrutiny of medical debt practices, Crawford is poised to influence federal and state courts alike, prompting industry-wide reforms and shaping litigation strategy for years to come.