Is PII Keeping You Up at Night? Keep Reading…

By Sophie Stern and Liz Hagan

Lots of good news this week, but we’re especially excited about the Centers for Medicare and Medicaid Services’ (CMS) new tip sheet for in-person assisters on PII (Personally Identifiable Information). This tip sheet includes example scenarios on how PII can be obtained, used, and shared by in-person assisters conducting outreach and follow-up to make sure consumers #GetCovered and #StayCovered.

For those that don’t know, PII includes any information that can be used (on its own or in combination with other information) to identify an individual (e.g. name, phone number, address). Outreach organizations and assisters alike have raised many questions about how to appropriately use and protect consumer PII. The new tip sheet provides much-needed clarity. Key points are below, but in many situations, in-person assistance organizations can implement follow-up and outreach best practices that require use of PII as long as the consumer has consented in a form and manner that is appropriate.

Here are some highlights:

  • Assisters can use sign-up sheets (and can work with third-party organizations that use sign-up sheets) to collect PII from consumers that would like follow-up contact. Consumers must provide consent — either written or verbal (including over the phone) — to be contacted for application and enrollment assistance in the future. This consent should make it clear to a consumer that their information will be used for follow-up purposes. It does not replace consent that the assister is required to obtain before helping the consumer with the application and enrollment process.
  • Assisters can follow up with consumers whose contact information is obtained through a third party, through a phone bank or tabling event for example, as long as the third party has received consent — either written or verbal — to share it.
  • If an assister has an existing relationship with a consumer and received their consent at that time, they can follow up with the consumer now. For example, assisters can reach out to past clients to provide renewal information, even if this was not explicitly mentioned in the consumer’s original consent.
  • Assister organizations only need to obtain a single consent form to access a consumer’s PII. They are not required to obtain separate consent forms for each individual assister that helps a consumer or for each individual appointment.

CMS has also produced model consent forms for Navigators and Certified Application Counselors. These are provided as examples, but assisters can modify or use a different form if they choose.

This new guidance should give assisters reassurance that they can exercise the outreach and follow-up best practices that are core to any successful enrollment effort.

And now, assisters can implement these best practices with the peace of mind that comes from knowing how to appropriately collect, use, and protect consumer information in the process.

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