The following questions were submitted during Enroll America’s webinar held on October 11, 2012. Enroll America has provided answers to as many questions as possible. We encourage you to submit any additional questions about the topics covered in the webinar to email@example.com.
- What is a health insurance exchange?
- Will my state have a health insurance exchange?
- What types of assistance will be available to consumers seeking coverage through the health insurance exchange?
The Navigator Program
- What are navigators?
- What types of entities are eligible to become navigators?
- How are navigator programs funded?
The “In-person Assistance” Program
The Arkansas “In-person Assistance” Program
- How is Arkansas approaching their in-person assistance program?
- How many assisters does Arkansas plan to hire?
- How will Arkansas pay its in-person assisters?
- How much funding did Arkansas receive to establish their in-person assistance program?
Comparing Navigator and In-person Assistance Programs
- How is the “in-person assistance” program different from the navigator program?
- Does the type of exchange (state-based, partnership, or federally-facilitated) affect the structure of a navigator or “in-person assistance” program in a state?
- Can an organization be both an assister and a navigator?
- Can a state receive federal matching funds through Medicaid and the Children’s Health Insurance Program (CHIP) to support outreach, screening, and application assistance activities through a navigator or in-person assistance program?
Exchange Establishment Grants and Funding Deadlines
- What is the Exchange Blueprint and when is it due?
- What are Exchange Establishment Grants?
- Can states use Exchange Establishment Grant Funds after 2014?
Answer: Health insurance exchanges are new entities where consumers will be able to compare and purchase private health insurance, access financial assistance to help pay for coverage, and enroll in public programs like Medicaid and the Children’s Health Insurance Program (CHIP).
The new exchanges are required to use a simple, streamlined application and consumer-friendly eligibility and enrollment system to enroll consumers in the appropriate program with minimal collection of information and documentation. Consumers will be able to access the new streamlined application and enrollment system through a variety of different ways – including online, by phone, in person, and through a mail-in application.
Answer: By October 1st of 2013, every state will have a health insurance exchange. States have the option to establish an exchange operated by the state, partner with the federal government to run the exchange, or collaborate with other states to develop a regional exchange. States will need to announce their intention to the federal government by November 16, 2012 by submitting an exchange blueprint. If a state chooses to not create an exchange, the federal government will establish an exchange in the state.
Answer: Consumers who want to enroll in coverage will have a variety of options to obtain assistance with the process. All health insurance exchanges are required by the Affordable Care Act (ACA) to provide assistance. This includes:
- A consumer-friendly website where consumers and businesses can easily view coverage options, enroll in real-time, and use tools like an online calculator to help make informed decisions about the coverage options.
- A toll-free hotline
- A navigator program
- Exchanges also have the option of using health insurance brokers/agents and implementing an in-person assistance program that is distinct from the navigator program.
Answer: Navigators are entities that will assist consumers and small employers with the enrollment process. The Affordable Care Act (ACA) requires all exchanges, whether state based, a state-federal partnership or a Federally Facilitated Exchange (FFE), to have and fund navigators. These entities will conduct public education activities to raise awareness about the exchange, help people apply for and enroll in health plans offered through the exchange, and provide referrals for complaints. Navigators are required to provide information in a manner that is culturally and linguistically appropriate.
To be eligible to receive a grant from the exchange, a potential navigator entity must demonstrate that it has existing relationships, or could readily establish relationships, with employers and employees, consumers (including uninsured and underinsured consumers), or self-employed individuals likely to be qualified to enroll in a qualified health plan. Navigators also cannot accept indirect or direct compensation from health insurance plans for enrolling individuals in specific health plans offered inside or outside of the exchange.
Answer: All exchanges must select at least two types of entities to be navigators, at least one of which must be a community and consumer-focused non-profit. The other eligible entities are:
- Trade, industry and professional associations;
- Commercial fishing industry organizations;
- Ranching and farming organizations;
- Community and consumer-focused nonprofit groups;
- Chambers of commerce;
- Resource partners of the Small Business Administration (SBA);
- Licensed insurance agents and brokers; and
- Other entities that are capable of carrying out the required duties and provide information that is fair, accurate and impartial.
Answer: While exchange establishment grants can be used to plan for and establish a navigator program, federal funds cannot be used to provide grants to the navigator entities in a state-based exchange. The Affordable Care Act requires exchanges to fund the navigator grants from the operational funds of the exchange.
Answer: In the final exchange blueprint released on August 14, 2012, the Center for Consumer Information and Insurance Oversight (CCIIO) outlined an optional “in-person assistance” program that is distinct from the navigator program.
However, with the exception of announcing the existence of the program in the blueprint and approving federal funds to establish the program in Arkansas, CCIIO has yet to provide specific guidance on the new program. It is still unclear who would be eligible to serve as an in-person assistor, what types of services in-person assistors would provide, and what specific standards they will have to meet.
Answer: Federal funding is available through the Exchange Establishment grants to establish and operate the in-person assistance programs.
Answer: Arkansas is working closely with the Center for Consumer Information and Insurance Oversight (CCIIO) to establish an exchange using the partnership model. Under this exchange model, Arkansas has agreed to manage the consumer assistance and the plan management components of the exchange.
An important part of the state’s approach to consumer assistance is their in-person assistance program, designed to provide outreach, education and assistance to Arkansas communities and uninsured Arkansans who will be eligible to enroll in health insurance plans through the Health Benefits Exchange that Arkansas is developing in partnership with the U.S. Department of Health and Human Services (HHS). CCIIO recently awarded the state a $18.6 million Exchange Establishment Grant with nearly $17 million for consumer assistance functions including the In-Person Assister Program and the Arkansas Outreach/Education program.
For more information, read the Enroll America guest blog post by Anna Strong, Director of Health Care Policy for Arkansas Advocates for Children and Families and one of three co-chairs of the state’s Consumer Assistance Advisory Committee.
Answer: Arkansas plans to issue a Request for Proposals (RFP), soliciting entities to provide services which will lead to the enrollment of uninsured Arkansans into qualified health plans through the Federally-facilitated Partnership Exchange. Selected contractors will be responsible for hiring individuals who will be trained by the Arkansas Insurance Department to provide outreach and education and facilitate consumer enrollment. We estimate that approximately 535 trained individuals will be needed. The state anticipates a great need for outreach and in-person assistance in the summer of 2013, leading up to the Exchange’s six month open enrollment period starting October 2013. Outreach and education through the in-person assistance program will continue beyond the end of the initial open enrollment period, but on a more limited basis.
Answer: Arkansas plans to initially pay IPAs with Exchange Implementation (1113) funding. Arkansas plans to issue a Request for Proposals (RFP), soliciting entities to provide services which will lead to the enrollment of uninsured consumers. Each selected entity will be responsible for paying its staff. We estimate that each individual assister will be paid approximately $12/hour and will work full time for a limited period of time. The In Person Assister program is based on a census model whereby a large number of well trained individuals will be needed during the initial open enrollment period, with that number decreasing as the need declines.
Answer: Arkansas applied for and was awarded an Exchange Establishment Grant of $18.6 million on September 27, 2012 to help establish and operate Plan Management and Consumer Assistance functions of the FFE Partnership Model. Of that funding, approximately $17 million is earmarked for consumer assistance functions including Outreach/Education and Arkansas’s In-Person Assister program. See the narrative section of their exchange establishment grant application for more information on this award.
Answer: The navigator program and the in-person assistance program are distinct enrollment assistance programs. While they may ultimately meet similar enrollment assistance needs, there are some important differences between the two programs.
Many of these distinctions between the two programs are driven by the fact that the navigator program is a required function of all exchanges, and many aspects of this program are spelled out in the Affordable Care Act (ACA) and related regulations from HHS. However, HHS has yet to provide specific guidance on the in-person assistance program and, it is still unclear who would be eligible to serve as an in-person assistor, what types of services they would provide, and what specific standards they will have to meet.
One key difference between the two programs is related to funding. States with a state-based or partnership exchange can use federal funding through the exchange establishment grants to establish and operate the in-person assistance program and make grants to in-person assister entities. While exchange establishment grants can be used to plan for and establish a navigator program, these federal funds cannot be used to provide grants to the navigator entities in a state-based exchange. The Affordable Care Act requires grants to navigators to come from the operational funds of the exchange implementing the program.
The Navigator Program
|Type of Exchange||Entity Responsible for Selection of Navigators||Entity Responsible for Oversight and Training|
|State-Based Exchanges||The state-based exchange|
|Partership Exchanges||In all partnership exchanges (including those where the state has agreed to manage consumer assistance), the federal government will select an provide grants to navigator entities.||In consumer assistance partnership exchanges, the state government agency that partners with the federal government to manage the consumer assistance function. plan management partnership exchanges follow FFEs.|
|Federally Facilitated Exchanges (FFEs)||The federal government. HHS will implement a navigator program in all states with an FFE or a plan management partnership exchange.|
The “In-Person Assistance” (IPA) Program
|Type of Exchange||State Role in Developing an IPA program||Federal Role|
|State-Based Exchanges||All state-based exchanges have the option to establish an IPA program that is distinct from the navigator program and tailored to the unique needs of the state.||The federal government can provide funding to support the establishment and operation of the IPA program through exchange establishment grants, available through January 1, 2015.|
|Partership Exchanges||HHS is working with states that have agreed to manage consumer assistance in the partnership exchange model, such as Arkansas, to develop an IPA program that is tailored to the unique needs of the state.|
|Federally Facilitated Exchanges (FFEs)||None||The federal government plans to implement an IPA program in all states with an FFE.|
Answer: Yes. There is no federal guidance that prohibits an organization from participating in both the navigator program and the in-person assistance program. This may change with future guidance. It’s important to note that these are distinct programs, and they may require different training and certification standards.
Question: Can a state receive federal matching funds through Medicaid and the Children’s Health Insurance Program (CHIP) to support outreach, screening, and application assistance activities through a navigator or in-person assistance program?
Answer: Yes, under Medicaid and the Children’s Health Insurance Program (CHIP), states may claim outreach, screening and application assistance activities as administrative costs and receive federal reimbursement. Medicaid administrative costs are reimbursed at 50 percent, while CHIP costs are reimbursed at a higher rate, which varies by state.
To the extent that a navigator program or in-person assistance program’s work involves Medicaid or CHIP (the exchange, Medicaid, and CHIP will all share a single streamlined application), the state can receive federal matching funds for these activities. States will need to work with HHS to determine how to allocate federal dollars for these activities and the extent to which the state will be responsible for matching funds.
Answer: States seeking to operate a state-based or state-federal partnership exchange must submit an exchange blueprint to the Department of Health and Human Services (HHS) by December 14, 2012. The exchange blueprint has two components: 1) a declaration letter from the governor of the state outlining the type of exchange model the state chooses to pursue; and 2) an exchange application that documents how the exchange meets or will meet all applicable legal and operational requirements by October 1, 2013. If HHS does not receive a state’s declaration letter by November 16, they will plan to implement a federally facilitated exchange for the state.
HHS will evaluate the exchange blueprints it receives and approve or conditionally approve the proposed exchanges by January 1, 2013. State-based exchanges need this approval by January 1, 2013 to begin enrolling applicants in October 2013 and offering coverage through the exchange in January 2014.
Answer: The Affordable Care Act (ACA) authorizes funding through Exchange Establishment Grants for states preparing for an exchange in their state. These grants are available for establishing a State-based Exchange, to build functions that a State elects to operate under a Partnership Exchange (Plan Management and/or Consumer Assistance), and to support State activities that build interfaces with a Federally-facilitated Exchange.
States can choose how to design their grant proposals and the activities funded through these grants, and they do not need to pass exchange legislation or make decisions about how to operate their exchange before they apply for these grants.
States have multiple opportunities to apply for establishment grant funding. The next deadline for applications for the exchange establishment grant is November 15, 2012. Coming deadlines are: February 15, 2013; May 15, 2013; August 15, 2013; November 15, 2013; February, 14, 2014; May 15, 2014; and October 15, 2014.
There are two levels of funding states can apply to receive. “Level 1” grants are designed to support one year’s worth of planning for the state’s role in operating a health insurance exchange. States can apply for multiple Level 1 grants to focus on different exchange establishment objectives. States that have developed longer term plans for implementation and that have successfully completed establishment milestones in their Level 1 grant can apply for a “Level 2” grant which are designed to provide enough funding to see the state through exchange implementation until December 31, 2014. States that have received a Level 2 grant can continue to apply for subsequent Level 1 grants to support discrete exchange establishment objectives.
As of October 2012, 33 states and the District of Columbia have been awarded a total of $1.2 billion in Level 1 and Level 2 exchange establishment grant funding. The amount each state receives depends on what it is proposing to do with the funds and how much progress it has already made in establishing its exchange.
More details about the Establishment Grants is available in the Funding Opportunity Announcement (FOA) at: https://www.grantsolutions.gov/gs/preaward/previewPublicAnnouncement.do?id=15353. Click on the pdf link at the bottom of the page.
Answer: Yes. The deadline of December 2014 is for the end of the period in which states will be awarded the grants – not the end of the period in which states can use those funds.
The actual performance period for all grants – including those awarded December 2014 – will ultimately depend on the type of establishment grant, the activities proposed by the state in their grant application, and the details of the cooperative agreement with the Center for Consumer Information and Insurance Oversight (CCIIO). According to the Funding Opportunity Announcement (FOA) for the grant, states will have up to one year for Level One grants and up to three years for Level Two grants to use funding after the date of award.
It is important to also note that the time periods for the project period can be extended. CCIIO can provide state grantees with a no-cost extension, and project periods can be extended for a maximum of five years past the date of the award.
More details about the Establishment Grants is available in the FOA for the opportunity at: https://www.grantsolutions.gov/gs/preaward/previewPublicAnnouncement.do?id=15353. Click on the pdf link at the bottom of the page.
CCIIO has also created FAQs for the program: http://www.cciio.cms.gov/resources/factsheets/index.html#peg