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On July 12, the Centers for Medicare & Medicaid Services (CMS) issued its final rule for the various types of assisters that will help consumers enroll in the health insurance marketplaces, beginning this October. Below are some key take-aways from the final rule:What’s the difference between navigators, non-navigator assistance personnel, and a certified application counselor (CAC)? The final rule spells out three main distinctions among these three types of consumer assisters:Funding
Conflicts of interest/reporting
What roles can hospitals and provider organizations play? It appears that hospitals and other provider organizations can serve as any type of exchange assister. The section of the final rule discussing CACs explicitly states “healthcare providers” when listing types of organizations that would qualify. The navigator/non-navigator is less explicit; however, page 42832 of the final rule discusses whether or not a healthcare provider’s contract with a payer to provide medical services to members would constitute a conflict of interest. It clarifies that while the provider may have to disclose the relationship, it would not serve as a bar. This seems to suggest that providers can be navigators/non-navigators. Can providers who have insurance plans under their corporate umbrella act as navigators, non-navigators, or CACs? Yes, as long as the individuals performing the assister function don’t have any existing conflicts of interest and have no reporting relationships with the entity that sells insurance.Do provider organizations have to be certified to provide assistance enrolling individuals in exchange products? No. Only individuals who represent themselves to the public as “certified application counselors” need to be certified. As detailed on page 42843 of the final rule, individuals and entities providing application and enrollment assistance related are not required to be certified application counselors, whether by the exchange, state Medicaid, or CHIP agencies. Nor are they required to be organizations designated by the exchange in order to continue providing those services or communicating with consumers. The certified application counselor program is not designed to limit existing or potential application assistance programs. Rather, the certification of an individual as a certified application counselor provides an assurance to consumers that they are receiving assistance from persons trained by the exchange and overseen by organizations that protect personally identifiable information. CMS plans to make the training material for the certified application counselor program publicly available once it is developed. Anyone will be able to access that training material, regardless of whether you intend to become certified.
Chad Mulvany is director, healthcare finance policy, strategy and development, HFMA. This summary was based, in part, on a special members-only bulletin from the American Hospital Association and a recent Health Affairs blog piece by Timothy Jost.
This is a sample article from HFMA's CFO Forum, which is a networking and discussion community for senior healthcare finance leaders. Learn more about the CFO Forum.
Tom Myers, chief strategy officer, The SSI Group, discusses the shifting payment environment and how it affects providers' patient access and claims management processes.
Jeff Chester, senior vice president and chief revenue officer at Availity, shares his thoughts on "Revenue Cycle 2.0" and how to best meet its challenges.
Mitch Morris, vice chair and global leader, healthcare, Deloitte, and Michael O'Rourke, senior vice president and chief information officer, Catholic Health Initiatives (CHI), share perspectives on the need for transformational IT in health care today.
Brian Kueppers, founder and CEO, Apex, discusses the importance of a robust patient payment strategy in boosting organization revenue and enhancing patient satisfaction.
Brian Grazzini, CFO, HealthPort, describes the importance of efficient and compliant information exchange and audit management in helping HIM staff spend less time on paperwork and more on mission-critical projects.
Cindy Matthews, executive vice president, Community Hospital Corporation, discusses how rural and community hospitals can use collaborative partnering to position for success through tough market conditions.
Rick Heise, senior vice president, revenue cycle, at Cerner Corporation, discusses the importance of integrating clinical and financial data to excel in health care’s changing payment environment.
Russ Graney, founder and CEO for Aidin, and John Laursen, head of business development for Aidin, share insights on how to improve care transitions between acute and post-acute care settings and incentivize high-quality patient outcomes.
Scott Elston, strategic accounts manager, GE Healthcare Services, describes how substantial cost reduction in health care requires rethinking business strategy and asset use.
Robert Williams, MD, director, Deloitte Consulting LLP, and Arielle Freiberger, product strategist, ConvergeHEALTH by Deloitte, explain how sophisticated retrospective, real-time, and predictive data analytics can inform decision making to reduce costs and improve care.
Stuart Hanson, director of business development (healthcare solutions) at Citi Retail Services, discusses how improving the payment experience can benefit consumers and healthcare providers.
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