{"id":5806,"date":"2026-03-30T07:24:20","date_gmt":"2026-03-30T07:24:20","guid":{"rendered":"https:\/\/thelawyerworld.com\/blog\/?p=5806"},"modified":"2026-03-30T15:25:40","modified_gmt":"2026-03-30T15:25:40","slug":"what-a-voicemail-got-wrong-levins-v-hrrg-and-the-fdcpas-true-name-rule","status":"publish","type":"post","link":"https:\/\/thelawyerworld.com\/blog\/what-a-voicemail-got-wrong-levins-v-hrrg-and-the-fdcpas-true-name-rule\/","title":{"rendered":"What a Voicemail Got Wrong: Levins v. HRRG and the FDCPA’s True Name Rule"},"content":{"rendered":"\n

A few years back, a colleague of mine got a voicemail. Robotic voice, unknown number, said something like “this is an attempt to collect a debt”<\/em> and she had absolutely no idea who had called. She ignored it for two weeks. Turns out it was a legitimate collector, but the damage was done: confusion, anxiety, delayed response. That situation? It’s exactly what the FDCPA was written to prevent.<\/p>\n\n\n\n

And it’s almost exactly what happened to Elaine and William Levins.<\/p>\n\n\n\n

Who Is HRRG and Why Does It Keep Showing Up in Lawsuits?<\/strong><\/h2>\n\n\n\n

Healthcare Revenue Recovery Group, LLC most people encounter it as ARS Account Resolution Services<\/strong> is a Florida-based debt collection agency. It’s specialty is medical debt, working on behalf of hospitals, physician groups and healthcare systems trying to recover unpaid balances.<\/p>\n\n\n\n

Headquartered in Sunrise, Florida, HRRG operates across multiple states. In New Jersey, it’s registered as “ARS Account Resolution Services.” That registered name matters a lot, as we’ll see.<\/p>\n\n\n\n

On paper, HRRG does what most collectors do:<\/strong> phone calls, voicemails, letters, credit reporting. Standard stuff. But it’s been a repeat defendant in federal court class actions targeting it’s voicemail scripts, envelope designs, debt validation language and more. Some settlements have exceeded $500,000. That’s not a one-off compliance slip. That’s a pattern.<\/p>\n\n\n\n

The Levins Case: What Actually Happened<\/strong><\/h2>\n\n\n\n

The Levinses had a medical debt. It got assigned to HRRG. Then their phone started getting calls pre-recorded voicemails that said, roughly:<\/em><\/strong><\/p>\n\n\n\n

“ARS calling. Please return our call at 1-800-694-3048. ARS is a debt collector. This is an attempt to collect a debt…”<\/em><\/p>\n\n\n\n

That was it. “ARS calling.”<\/p>\n\n\n\n

Here’s the thing, neither Elaine nor William Levins had ever received a letter from HRRG before those calls. They had no written communication establishing who “ARS” was. And “ARS” isn’t exactly an uncommon acronym in the debt world. There’s ARS National Services, Inc., another debt collector. Dozens of New Jersey businesses use those same initials.<\/p>\n\n\n\n

So the Levinses did what any reasonable person would do: <\/strong>they had no idea who was calling them.<\/p>\n\n\n\n

They sued. Class action. Three claims under the Fair Debt Collection Practices Act (FDCPA):<\/em><\/strong><\/p>\n\n\n\n