Individuals who act as navigators assisting consumers in applying for health coverage through state insurance exchanges should have extensive training and exam-based certification, the trade association for brokers and agents has told the CMS.
In comments submitted May 6 regarding a proposed CMS rule on standards for navigators and other assistance personnel
, National Association of Health Underwriters Senior Vice President of Government Affairs Jessica Waltman writes that navigators will also need recertification and that appropriate steps must be taken to guard against conflict-of-interest issues impacting navigators' work.
“It is also imperative that legal consequences for actions that harm consumers be specified in the final rule and those consequences be clear for both entities who may receive federal funds for assisting marketplace consumers and the individual people who may work or volunteer for such entities,” she wrote.
In addition, NAHU asks for additional clarification on “entities that have been awarded navigator and non-navigator assister funding from the marketplace and the individual people who may be employed … who may communicate marketplace information to consumers.”
NAHU expressed concern about the role of navigators in terms of how they will help consumers. “Our association is unclear as to how the distinction between advising consumers about QHP (qualified health plan) options and merely helping consumers through the eligibility and enrollment process, which is admittedly a gray area, will be made, monitored and enforced,” the association's comments stated.
NAHU argues that exchange personnel should disclose to consumers that there are non-exchange coverage options and where they can find information on them. The group said HHS should say how it plans to deal with the potential fraud issues, as well as assistance to potentially defrauded consumers. HHS should develop ways so consumers can better identify legitimate navigators, the group urged.
America's Health Insurance Plans, in its comments submitted May 6, agrees that “the importance of robust training of navigators and non-navigators cannot be overstated.” In addition, the group wants the CMS to clarify how it will evaluate training modules for navigators “to ensure that necessary information is being communicated to consumers.”
AHIP also recommends “extensive consultation with issuers” about QHPs offered in exchanges. The organization calls on the CMS to elucidate that exchanges need to provide a comprehensive list of navigators and other assistors that includes licensed agents and brokers.
Hospital groups also weighed in on the rule. The Federation of American Hospitals in its comments sent May 6 argues that the proposed rule does not specifically state that hospitals can serve as navigators or other assistors, and the final rule should clarify that hospitals can do so.
FAH also asked the CMS to revise the standards and duties of Certified Application Counselors so that hospitals have as much time as possible between now and Oct. 1 to make appropriate decisions about the most effective role they can play in enrolling patients in the exchanges.”
In its May 3 comments, the American Hospital Association recommended that consumer assistance programs and standards be consolidated into one set of rules. Currently, the law breaks down standards based on three different types of consumer assistance personnel: navigators, in-person assistors and Certified Application Counselors.
In addition, the AHA urges the CMS to have exchange information available in the “15 to 20 most frequently encountered languages.”
At least two health insurers, BlueCross and BlueShield of Tennessee and Cigna Corp., have applied to offer plans in the Volunteer State, the Memphis Business Journal
reports. In some markets, the Blues insurer is offering a narrow network plan known as E Network, will only be available on the exchange. The deadline for carriers interested in providing qualified health plans on federally facilitated exchanges was May 3.
When consumers begin to apply for coverage through exchanges later this year, they can be helped by agents, brokers, navigators, in-person assistors and, if Simeon Schindelman, has his way, decision-making supporters. Schindelman, CEO of Minneapolis-based Bloom Health, which develops defined-contribution health benefits solutions using a private exchange for employers, tells Modern Healthcare that he has been having discussions with federal regulators to have his company's employees work with consumers using health exchanges to help make plan selections. He says the company's proprietary plan evaluation technology would be useful for consumers who may be unsure of what policy they should choose given that navigators and assistors can't recommend a particular plan. Follow Jonathan Block on Twitter: @MHjblock