Did HHS Just Wipe Out Most WBE's?

Enrollment will take 2-3X longer.
The HHS Queen Sebellius said it from her vacation home.
(or the current queen).
They both answer to the King.
We just got thrown in the moat.

Thanks for putting it compact form, YAgents. As long as the Web Broker Entities, like Health Sherpa, are able to avoid the dreaded Email & ID Verification crap on the front end, and still deliver Enrollment Confirmation, along with the associated documents attached to that confirmation e-mail on the back end, using a WBE is still preferable to Healthcare.gov don't cha think?

BTW.. Where can I find the story describing what HHS secretary Burwell said from her vacation retreat? A link, if you please. Grazie.
ac
 
Pre-Thanksgiving ACA Regulation Dump

H. Marketplace Enrollment Directly on Insurer’s Websites – The proposed rules request comments on standards that would allow insurers and web-brokers to directly enroll individuals in the Marketplace while remaining on their own website.

Which leads me to believe, that the current process is no longer allowed for the time being. Allowing the current expedient method will be considered on the fast track path as the Keystone pipeline.

There is a CMS fact sheet also on the link above (at bottom) that states this:

Direct Enrollment Enhancements, Agent and Broker Enforcement, and Standards for HHS-Approved Vendors of FFM Training for Agents and Brokers: We seek comment on standards for web-brokers and QHP issuers under which an applicant may remain on the web-broker’s or issuer’s website to complete the Marketplace application and enroll in coverage. We also propose additional standards for terminating agreements between agents and brokers and the Federally-facilitated Marketplace (FFM), establish standards of conduct for FFM-registered agents and brokers to better protect consumers, and establish penalties other than terminations of the FFM agreements. Lastly, we propose eliminating the requirement that HHS-approved vendors of FFM training for agents and brokers perform information verification functions, including state licensure verification and identity proofing.

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The 2017 Benefit and Payment Parameters Proposed Rule: Drilling Down

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See, they don't even allow it now. Single site enrollment is under consideration.
Sounds like we got to taste the wine before it aged properly.
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Currently a consumer applying for exchange enrollment through a web-broker or directly through an insurer must be redirected to the exchange website to complete the enrollment and receive an eligibility determination. HHS is considering an option where the consumer could remain on the web-broker’s or insurer’s website to complete the application and enroll in coverage, with the web-broker or insurer obtaining eligibility information from the exchange. The web-broker or insurer would have to use the FFE single streamlined application without change to obtain information. CMS is examining the web-broker experience and consider expanding audits or requiring additional information displays from web-brokers.



CMS is further proposing standards of conduct for agents and brokers. These would include requirements that they provide consumers with correct information without omission of material fact; refrain from marketing that is misleading, coercive or discriminatory; obtain consent before enrolling individuals or employers in coverage; protect consumers’ personally identifiable information; and otherwise comply with federal and state laws and regulations. The use of the words “exchange” or “marketplace” in a name or URL that would cause confusion with a federal program or website may be considered misleading.
 
Thanks for posting that "Drill Down" dissertation from Timothy Jost. Indeed, it looks like the Web-Brokers we're most familiar with have not been adhering to the initial guidelines laid out for them by CMS in 2013 & 2014.

Reference Document: https://www.cms.gov/CCIIO/Programs-.../May_1_2013_CCIIO_AB_-Guidance_110414_508.pdf

Item #8 (Page 8/9) of this CMS "Role of Agents, Brokers & Web-Brokers" document says:

"The Direct Enrollment pathway enables a qualified individual to initiate his or her shopping experience on the web-broker’s website, connect securely to HealthCare.gov to complete the eligibility application and determination process, and return securely to the web-broker’s site to compare plans and enroll in a QHP."

I think CMS allowed some Web-Brokers (like Health Sherpa) to bypass the cumbersome re-direct, to and from Healthcare.gov, in the interest of efficiency. But for one reason or another, that leniency is being rescinded. Could be next week, next year, or _________(fill in the blank). It's a good bet that the WBEs are petitioning CMS to keep things as they are for as long as possible.
 
Pre-Thanksgiving ACA Regulation Dump

CMS is further proposing standards of conduct for agents and brokers. These would include requirements that they provide consumers with correct information without omission of material fact; refrain from marketing that is misleading, coercive or discriminatory; obtain consent before enrolling individuals or employers in coverage; protect consumers’ personally identifiable information; and otherwise comply with federal and state laws and regulations. The use of the words “exchange” or “marketplace” in a name or URL that would cause confusion with a federal program or website may be considered misleading.

Provide consumers with correct information with omission of material fact? Of course we do

Refrain from Marketing that is misleading, etc? I don't market, my business is all referrals

Obtain consent before enrolling individuals in coverage? How else can we do it?

I'm sure CMS has the solution to all of these issues-coming soon, Scope of Appointments with a 48 hour advance notice.mm:mad:
 
There are WBE's that send the agent INTO HC.gov to complete the client's application.

I've never used them.
But, it sounds like THEY might be an acceptable pathway.

It definitely by-passes client log-in issues!
Don't know if it by-passes Identity Verification.

Anyone use one of these WBE pathways?

*********************************
I've seen something on Sherpa....when you ACCESS the client's government account.......a BOX next to the BOX called "Look up existing applications".

It says something like: "Start a Client's New Application"

Has anyone used this box?

Is this what SOME of the WBEs use (for agents to Direct Enroll)?

*********************************

Here's a WBE that has sent me invitations to use their Pathway for $30/month:
https://www.plandetail.com/
https://plandetail.recurly.com/subscribe/wbe-swt30

It seems like THEY send the agent INTO the govt site...to fill out everything FOR the client.

Never was interested in them. Wanted the QUICKEST way for my clients to self-enroll....so I never investigated their system.

...
 
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There are WBE's that send the agent INTO HC.gov to complete the client's application.

I've never used them.
But, it sounds like THEY might be an acceptable pathway.

It definitely by-passes client log-in issues!
Don't know if it by-passes Identity Verification.

Anyone use one of these WBE pathways?

*********************************
I've seen something on Sherpa....when you ACCESS the client's government account.......a BOX next to the BOX called "Look up existing applications".

It says something like: "Start a Client's New Application"

Has anyone used this box?

Is this what SOME of the WBEs use (for agents to Direct Enroll)?

*********************************

Here's a WBE that has sent me invitations to use their Pathway for $30/month:
https://www.plandetail.com/
https://plandetail.recurly.com/subscribe/wbe-swt30

It seems like THEY send the agent INTO the govt site...to fill out everything FOR the client.

Never was interested in them. Wanted the QUICKEST way for my clients to self-enroll....so I never investigated their system.

...

I use a couple of the "double-redirect" WBEs, and have since they became available. I'm a fan of redundancy, so I have accounts with 4 WBEs to minimize the impact of one of them having downtime. I've been primarily using the double-redirect WBEs to complete apps for clients who I know have an auto-generated 2016 app.

The double-redirect method takes you into HC.gov with your agent CMS login info, allows you to lookup an existing application to continue or start a new application. It makes it easy to avoid duplicate apps, as it will find the auto-created 2016 app. It also provides the "is someone helping you complete your application" question to enter agent info.

I'd say it takes me about 15 minutes per app using the double-redirect.

The workflow is:
  1. Quote and compare plans on the WBE site
  2. Enter client basic info into WBE site
  3. WBE kicks over to HC.gov for agent login
  4. Enter client info into HC.gov app
  5. HC.gov gives elegibility notice
  6. HC.gov kicks back over to WBE site
  7. Finalize plan selection on WBE site
  8. WBE has an access button if I need to submit docs to Hc.gov
 
I use a couple of the "double-redirect" WBEs, and have since they became available. I'm a fan of redundancy, so I have accounts with 4 WBEs to minimize the impact of one of them having downtime. I've been primarily using the double-redirect WBEs to complete apps for clients who I know have an auto-generated 2016 app.

The double-redirect method takes you into HC.gov with your agent CMS login info, allows you to lookup an existing application to continue or start a new application. It makes it easy to avoid duplicate apps, as it will find the auto-created 2016 app. It also provides the "is someone helping you complete your application" question to enter agent info.

I'd say it takes me about 15 minutes per app using the double-redirect.

The workflow is:
  1. Quote and compare plans on the WBE site
  2. Enter client basic info into WBE site
  3. WBE kicks over to HC.gov for agent login
  4. Enter client info into HC.gov app
  5. HC.gov gives elegibility notice
  6. HC.gov kicks back over to WBE site
  7. Finalize plan selection on WBE site
  8. WBE has an access button if I need to submit docs to Hc.gov

Thank-you, mwoodbrid. That was very helpful.
 
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