Covered California managers are drafting regs that would govern certified application counselors and certified application entities.
The rules would let an organization that has a financial stake in increasing public health insurance exchange plan enrollment help consumers sign up for exchange plans, as long as the counselors that worked for the entities disclosed the conflicts of interest in writing.
Covered California, a state-based exchange that has received private plan selection information for more than 728,410 people, is hoping that the counselors will help it reach out to uninsured consumers who have been tough to reach, especially in the Latino community.
Proposed certified application counselor rules would encourage the counselors to be individuals with “significant experience” with providing health and social services.
The counselors couldn’t accept payments from consumers or enter premium payment information on behalf of consumers, and they could not steer consumers toward any particular plan. They couldn’t mail paper applications for consumers.
Drafters haven’t specified which groups could be certified entities or employ the counselors.
Caroline Sanders of the California Pan-Ethnic Health Network and representatives from other groups suggest that the lack of a clear description of who can get certified could be “leaving the door wide open to unnamed categories of certified application counselors.”
Some of the entities that might want to employ counselors could include pharmacies, substance abuse treatment providers, and vendors that help hospitals with bad debt, Sanders and colleagues write.
In another letter, Sanders and colleagues suggest the exchange might let representatives for commercial carriers that aren’t selling through the exchange get certified.
In some cases, Sanders and colleagues write, reps with a conflict of interest might get certified as counselors simply to capture leads for off-exchange products.