Direct Enrollment by Web Brokers and Insurers

Claire McAndrewMarch 5, 2014

Families USA2014

• 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

• Optional for marketplaces, FFE allows

What is Direct Enrollment?

Families USA2014

• 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

How does direct enrollment work?

Families USA2014

• 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

How does direct enrollment work?

Families USA2014

• 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

Who is performing direct enrollment now?

Families USA2014

• An additional outreach channel

• Potential impact on marketplace web traffic

Benefits of Direct Enrollment

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• Financial incentives influence how insurers and web brokers market to and enroll consumers

• Protection of personal information

• Complete information about financial assistance, including Medicaid

Direct Enrollment: Concerns

Families USA2014

Federal Requirements for Direct Enrollment

Families USA2014

• 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

Requirements for Insurers

Families USA2014

• Distinguish between QHPs and non-QHPs; 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 Insurers

Families USA2014

• 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 USA2014

• 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

Families USA2014

• Not provide financial incentives such as rebates or giveaways

• Comply with applicable state laws regarding agents and brokers

Requirements for Web Brokers

Families USA2014

• 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

Specific FFE Web Broker Requirements

Families USA2014

• 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

Specific FFE Web Broker Requirements

Families USA2014

Additional Protections Needed!

Families USA2014

• 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

Consumer Awareness of Financial Incentives

Families USA2014

• 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

Require Complete and Accurate Plan Info

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• Consumer should be made explicitly aware of APTC and cost-sharing reductions

– After eligibility determination, show premiums with APTC factored in

– Indicate which plans are CSR-eligible and show cost-sharing amounts w/ assistance

Require Info on Financial Assistance

Families USA2014

• 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

Limit Marketing

Families USA2014

• 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

Protect Consumer Information

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• 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

Monitoring, Termination

Families USA2014

• 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

Advocacy steps

Families USA2014

• Contact: cmcandrew@familiesusa.org; 202-628-3030

• Consumer Protections for Web Brokers that Participate in the Health Insurance Marketplace (Families USA, December 2013) http://familiesusa2.org/assets/pdfs/Web-

Brokers-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/Web-Based-Brokers-Recommendations-9-5-12.pdf

Further Resources