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In Latest ACA Sabotage, Administration Nearly Eliminates Marketplace Enrollment Assistance Funds

The Trump Administration this week slashed funding for consumer enrollment assistance and outreach through the Affordable Care Act (ACA) navigator program. The funding cuts, and other changes to the program, will reduce access to crucial assistance that helps consumers make informed decisions about their insurance and sign up for and maintain comprehensive coverage – yet another in the Administration’s efforts to weaken the ACA.

The latest cut reduces funding for the navigator program to just $10 million for the 34 states whose ACA marketplaces are facilitated by the federal government. Combined with the large cut last year, navigator funding has now fallen more than 80 percent from its 2016 level.

Navigators raise awareness about the availability of ACA coverage and subsidies, help vulnerable and hard-to-reach communities complete complex eligibility and enrollment processes, assist people with grievances, and connect people to other resources, such as tax experts, as needed.

The Centers for Medicare & Medicaid Services (CMS) makes three flawed arguments to justify slashing navigator funding.

  • First, it claims that the need for navigators has “diminished” as the ACA marketplaces have become more visible and familiar. In fact, outreach remains critical in building awareness among people who could benefit from marketplace coverage, research shows. For example, 35 percent of uninsured adults didn’t know about the ACA marketplaces in the fall of 2017 and an earlier survey found that nearly half of uninsured adults didn’t know about marketplace financial assistance, even though many would likely qualify.
  • Second, CMS argues that the navigator program is inefficient, based on a misleading metric. The metric, which finds a relatively high program cost per person enrolled, focuses only on marketplace enrollments completed by navigators. It ignores navigators’ other duties, including raising awareness about coverage more broadly. That often results in enrollment in the marketplace by consumers completing the process on their own or enrollment in other programs like Medicaid or the Children’s Health Insurance Program (CHIP) that the CMS metric doesn’t capture.

    CMS unfairly compared navigator performance to that of agents and brokers using this metric. The metric likely undercounts the enrollments completed by navigators because it links enrollments to navigators using identification numbers that, up to last year, most navigators believed were optional to provide and that they have received little or no training in using. By comparison, insurance agents and brokers have long routinely used identification numbers to ensure they are compensated for work they’ve completed to enroll consumers.

    In addition, navigators’ enrollment counts may be lower than typical insurance brokers’ because they work with hard-to-reach and vulnerable populations — including people who live in rural areas, have limited access to the Internet, have limited English proficiency, or have disabilities or other special needs — who often take more time to assist and may have complex eligibility or coverage questions.

  • Third, CMS suggests that agents and brokers reimbursed by health insurers can replace navigators. But navigators differ from agents and brokers in that they are required to provide fair and impartial information about health plan options, rather than promoting particular options. They also provide services that agents and brokers generally don’t, such as making referrals for individuals to get appropriate assistance if they have a grievance related to their coverage, helping eligible individuals enroll in Medicaid or CHIP, and assisting people in resolving eligibility inconsistencies when their application does not match federal data records.   

Unfortunately, CMS also indicates that it seeks to interfere with navigators’ impartial role by pushing them to promote limited-benefit coverage options, “such as association health plans, short-term, limited-duration insurance, and health reimbursement arrangements.” As we’ve explained, such plans can leave consumers exposed to significant financial risk if they become ill or injured, and the proliferation of such plans will result in higher costs for people needing comprehensive coverage.

Finally, the funding announcement, building on an earlier CMS rule, opens the door to other significant changes that may leave consumers in some states without access to in-person, marketplace-funded assistance. The CMS rule changed the parameters for navigator program design, no longer requiring that they have a physical presence in the state they serve or that at least one navigator group in a state be a community-based non-profit focused on vulnerable populations.

Building on these changes, CMS encourages a single group to apply as the navigator organization serving multiple states. It claims that there’s less need for face-to-face assistance, and it encourages navigator groups to present “less resource-intensive” outreach and enrollment strategies, like relying on virtual or mobile assistance to consumers. But some consumers — often including the vulnerable populations that navigators have designed their programs to serve — continue to need and seek in-person help.

The dramatic cut in navigator funding and other changes to the program will weaken navigators’ effectiveness and ultimately reduce the viability of community-based enrollment and outreach programs tailored to each state’s diverse populations. As a result, fewer people will get the impartial assistance they need to enroll in and maintain coverage.