Direct Enrollment by Web Brokers and Insurers

Direct Enrollment by Web
Brokers and Insurers
Claire McAndrew
March 5, 2014
What is Direct Enrollment?
• Insurer or web broker facilitates
enrollment, including with financial
assistance
• Consumer never has to directly visit
marketplace website or call center
• AKA enrollment “through the
marketplace” by an insurer or web broker
Families USA
2014
• Optional for marketplaces, FFE
allows
How does direct enrollment work?
• Step 1: Consumer starts on insurer or broker
website and enters basic personal information
• Step 2: Consumer is securely redirected to
marketplace website to complete coverage and
financial assistance application
• Step 3: Marketplace securely transmits eligibility
determination to the web broker or insurer
Families USA
2014
How does direct enrollment work?
• Step 4: Consumer is security redirected back to
insurer or broker site select a qualified health
plan (QHP) and determine amount of advance
premium tax credit (APTC) to accept
• Step 5: Web broker or insurer submits plan
selection and APTC amount to the marketplace
Families USA
2014
Who is performing direct enrollment now?
• Fewer entities than expected. WHY?
– Dependent on marketplace eligibility systems
• HHS “pilot” program for insurer direct
enrollment: OH, FL, TX
• Web brokers: getinsured.com, healthsherpa.com
(full process); ehealth.com, gohealth.com
reportedly using call center determination
• Expressing strong interest in increased
involvement next year
Families USA
2014
Benefits of Direct Enrollment
• An additional outreach channel
• Potential impact on marketplace
web traffic
Families USA
2014
Direct Enrollment: Concerns
• Financial incentives influence how
insurers and web brokers market to
and enroll consumers
• Protection of personal information
• Complete information about financial
assistance, including Medicaid
Families USA
2014
Federal Requirements for
Direct Enrollment
Families USA
2014
Requirements for Insurers
• Display comprehensive info about
each plan they offer:
– Premiums and cost-sharing
– Summary of Benefits and Coverage
– Enrollee satisfaction survey results and quality
ratings
– Medical loss ratio
– Transparency of coverage measures
– Provider directory
Families USA
2014
Requirements for Insurers
Families USA
2014
• Distinguish between QHPs and nonQHPs; indicate financial assistance is
only for QHPs
• Indicate other QHPs are available in
marketplace via approved universal
disclaimer; link to marketplace
• Allow consumers to select and attest
to an advanced premium credit
amount
Requirements for Web Brokers
Families USA
2014
• List names of all marketplace QHPs
• If provided by a marketplace or an insurer,
post comprehensive plan details
• If all plan details aren’t available, provide
disclaimer that all QHP info is on
marketplace site and link to site
• If provided by marketplace or insurers,
provide information that is accessible to
individuals with disabilities and those with
limited-English proficiency
Requirements for Web Brokers
Families USA
2014
• Allow consumers to withdraw from the
process and use the official marketplace
website at any time
• Complete an agreement and register with
the marketplace
• Receive training in QHP options and
financial assistance programs
• Comply with marketplace privacy and
security standards for personally
identifiable information
Requirements for Web Brokers
• Not provide financial incentives such as
rebates or giveaways
• Comply with applicable state laws
regarding agents and brokers
Families USA
2014
Specific FFE Web Broker Requirements
• Link to the official marketplace site and
display a disclaimer stating:
– Not the official marketplace site
– Web broker may not display all QHP
information
– Web broker must meet federal requirements
for how it enrolls consumers
– Web broker must comply with privacy and
security standards for consumer info
Families USA
2014
Specific FFE Web Broker Requirements
• Follow a formal
termination process to
end agreement with HHS
– 30 days notice to HHS,
notice and transitional
support to customers, etc.
• HHS can terminate web
brokers for cause under a
formal termination
process
Families USA
2014
Additional Protections
Needed!
Families USA
2014
Consumer Awareness of Financial Incentives
• Expand FFE web broker disclaimer to all
web brokers and add statements that:
– Web brokers receive financial compensation
for enrollment
• Require web brokers to post information
on their compensation
• Forbid separate transaction or service
fees
Families USA
2014
Require Complete and Accurate Plan Info
• Require web brokers to give
comprehensive info about all plans
• Prevent biased sorting of plans
• Prevent posting of misleading information
• Clearly distinguish marketplace QHPs from
non-QHPs; prevent sales on same page
• Always require compliance with
accessibility requirements for language
access and disability accommodations
Families USA
2014
Require Info on Financial Assistance
• Consumer should be
made explicitly aware of
APTC and cost-sharing
reductions
Families USA
2014
– After eligibility
determination, show
premiums with APTC
factored in
– Indicate which plans are
CSR-eligible and show
cost-sharing amounts w/
assistance
Limit Marketing
• No advertisements for health insurance
products should be allowed
• Could prohibit marketing of additional
products (life and disability insurance,
etc.) on insurer or broker sites
– At a minimum, should not market them
while consumers are shopping for/ enrolling
in QHPs
Families USA
2014
Protect Consumer Information
• Prohibit use of personal
info for marketing
• Require disclosures for
how info will be used;
require proactive
consumer consent
before requesting info
• Marketplaces must
monitor for breaches;
require immediately
reporting of breaches
Families USA
2014
Monitoring, Termination
• Marketplaces should have formal monitoring
systems in place
– Monitor sites throughout the year, not just at
beginning
• Federal rules detail process for termination for
cause for FFE web brokers; process needed in all
marketplaces for web brokers and insurers
– Should allow for immediate termination when
misconduct is sufficiently egregious
Families USA
2014
Advocacy steps
• Gather Information
– FFE: What web brokers/ insurers are doing
direct enrollment in your state?
– SBE: Is your state allowing direct enrollment?
Have they been approached by insurers/ web
brokers about it? What are future plans?
• If direct enrollment permitted, advocate for
standards: marketplace (HHS or state-run),
insurance regulators, legislators
• Monitor and report
Families USA
2014
Further Resources
• Contact: [email protected];
202-628-3030
• Consumer Protections for Web Brokers that Participate
in the Health Insurance Marketplace (Families USA,
December 2013) http://familiesusa2.org/assets/pdfs/WebBrokers-Brief.pdf
• Recommended Consumer Protections for Web-Based
Agents and Brokers Offering Exchange Coverage
(Consumers Union, September 2012):
http://consumersunion.org/wp-content/uploads/2013/03/WebBased-Brokers-Recommendations-9-5-12.pdf
Families USA
2014