Application Counselor Sponsoring Entity Program Manual

Maryland Health Benefit Exchange (MHBE)

2

Table of Contents

1. Introduction

2. Background of ACSE Program 3. Application Counselor Sponsoring Entity Regulations 4. MHBE Infrastructure to Support Certified Application Counselors 5. ACSE Financial Sustainability 6. CAC Performance Measurement and Site Visits 7. Application Instructions and Required Forms 8. ACSE Application Submission Instructions 9. ACSE Designation and Renewal 10. PII Protection and Breach Protocol 11. CAC Training and Testing 12. Attachments 13. Index

a. Connector Entity Regional Map and Contact List b. Glossary of Terms

3

Introduction Dear Applicant,

The purpose of this program manual is to designate Application Counselor Sponsoring Entities (ACSEs) that will employ, retain and monitor Certified Application Counselors (CACs).

These designations will cover a two year term and may be renewed for an additional two years.

The designation of an entity as an Application Counselor Sponsoring Entity by the Maryland Health

Benefits Exchange (MHBE) does not entitle an ACSE nor an entity’s Certified Application Counselors to any funds from the MHBE.

As an ACSE you will designate a point of contact to actively partner in monthly communication and updates. MHBE appreciates your interest in this program to help consumers with their health insurance needs.

ACSE applications are accepted at any time, and can be requested via email to acse.cac@maryland.gov.

Cassandra Leach Rita W. Dyer

Business Analyst, ACSE Program Manager, Producer Operations & ACSE Program Maryland Health Benefit Exchange Maryland Health Benefit Exchange 750 E. Pratt Street 750 E. Pratt Street

6th Floor 6th Floor Baltimore, MD 21202 Baltimore, MD 21202 Email: cassandra.leach2@maryland.gov Email: rita.dyer@maryland.gov

Applications and signed agreements should be scanned and submitted to acse.cac@maryland.gov.

4

Background of ACSE Program The state uninsured rate fell to an all-time low of 6.1 percent in 2017 due to the implementation of Maryland Health Connection, Maryland’s state-based marketplace. Many consumers became insured as a result of

expanded Medicaid eligibility and subsidized insurance affordability products offered through Maryland Health Connection.

The State of Maryland and the Maryland Health Benefits Exchange (MHBE) has developed a number of consumer assistance programs to assist consumers with eligibility and enrollment. Among these is the Application Counselor Sponsoring Entity (ACSE) program.

Pursuant to Maryland regulations on the Application Counselor Sponsoring Entity Program (COMAR Subtitle 35.14.35.12 and 35.14.35.13) the MHBE may designate community-based organizations, health care providers,

units of state and local government, or other entities within specific regions of the state to perform enrollment activities through Certified Application Counselors.

Certified Application Counselors are employed or engaged by these designated ACSEs to assist individuals with the application process to determine eligibility for Medicaid, the Maryland Children’s Health Program (MCHP), advance premium tax credits and cost-sharing reductions, and may facilitate individuals in enrolling in

Qualified Health Plans and Qualified Stand-Alone Dental Plans offered through Maryland Health Connection. (Note: CACs are not authorized to assist with MCO selection.)

The general organizational structure is as follows:

Statutory and Regulatory Authority: The Maryland Health Progress Act of 2013 established the Application

Counselor Sponsoring Entity Program. It is built on the Patient Protection and Affordable Care Act (PPACA or, more commonly “the ACA”) and PPACA’s implementing regulations. Further, on June 8, 2015 the MHBE published and the Board of Trustees adopted procedures implementing the Application Counselor Sponsoring

Entity program.

Regional Application Counselor Sponsoring Entity Distribution The number of ACSE’s will be determined by the MHBE based on its assessment, in consultation with the Insurance Commissioner, of overall outreach and consumer assistance needs/demand, and the State’s

available resources for the necessary oversight and management of the program. Entities may seek designation in one or more regions. The MHBE reserves the right to reevaluate the

geographic configuration and entity service areas from time to time and make adjustments as needed.

5

ACSE Goals and Target Population

The primary goal of the ACSE program is to enroll all eligible and uninsured individuals into health coverage,

including Medicaid, Maryland Children’s Health Program, Qualified Health Plans, and Qualified Dental Plans. Application Counselor Sponsoring Entities must demonstrate an extensive history of reaching individuals in their

communities who are likely to be uninsured. The target population is determined by the ACSE to meet the needs of their communities.

Application Counselor Sponsoring Entity Regulations1

1. A designated application counselor sponsoring entity may employ or engage certified application counselors to:

a. Provide information to consumers about the full range of qualified health plan and qualified dental plan options and insurance affordability programs, including Advance Premium Tax Credits, the Maryland Medical Assistance Program, and the Maryland Children’s Health

Program, for which they are eligible;1 b. Assist consumers with the application process for determining eligibility for insurance

affordability programs, including Advance Premium Tax Credits, the Maryland Medical

Assistance Program, and the Maryland Children’s Health Program; c. Facilitate plan selection and enrollment of eligible individuals in qualified health plans, qualified

dental plans, and access to advance premium tax credits.

d. Provide to consumers uniform, factual, and unbiased information approved by the Maryland Medical Assistance Program about all participating managed care organizations, including report cards, lists of enhanced benefits and covered services and participating providers.

2. A designated application counselor sponsoring entity may not permit certified application counselors to: a. Enroll Maryland Medical Assistance Program/Maryland Children’s Health Program eligible

individuals into managed care organizations; or

b. Express a personal or professional assessment about which Maryland Medical Assistance Program/Maryland Children’s Health Program managed care organization may be most appropriate for an eligible individual, may not make a managed care organization selection on

the applicant’s behalf, and may not otherwise counsel an applicant about the selection of a managed care organization.

3. Where a Maryland Medical Assistance Program/Maryland Children’s Health Program eligible consumer

seeks further counseling or additional assistance in choosing a managed care organization, a designated application counselor sponsoring entity shall instruct the certified application counselor to refer the consumer to the Consolidated Services Center or to a caseworker.at the local department of

social services or local health department in the county in which the consumer lives. 4. An Individual Exchange connector entity may also be a designated application counselor sponsoring

entity only under the following conditions:

a. No agent, employee, or volunteer of the Individual Exchange connector entity may hold more than a single certification as either an Individual Exchange navigator, an assister, or a certified application counselor;

b. All Individual Exchange connector entity grant funds must be wholly segregated from certified application counselor program funding;

c. No certified application counselor may be compensated in whole or in part from Individual

Exchange connector entity grant funding and no Individual Exchange navigator or assister may be compensated in whole or in part from application counselor program funding;

d. All utilities, computer systems, and other components of operations which are utilized jointly by

both the Individual Exchange connector and application counselor programs, including executive and administrative staff, shall be cost allocated as directed by the Maryland Health Benefit Exchange and the Department of Health in relation to the percentage of consumers

served by the entity who are determined eligible for Maryland Medical Assistance Program/Maryland Children’s Health Program, or advance premium tax credits and who are enrolled in qualified health plans and managed care organizations; and

1 Authority: Insurance Article, §§31-106 and 31-113(r), Annotated Code of Maryland

6

e. No individuals seeking assistance in enrolling in a managed care organization may be referred by a certified application counselor engaged by an Individual Exchange connector entity to an

Individual Exchange navigator employed by the same individual exchange connector entity, and no consumers served by an Individual Exchange connector entity, Individual Exchange navigator may be referred to or served also by a certified application counselor retained by the

same Individual Exchange connector entity.

MHBE Infrastructure to Support Certified Application Counselors MHBE has developed an infrastructure to support consumers and consumer assistance workers. Certified Application Counselors will use the following resources to assist consumers.

Below is a summary of the infrastructure and specific capabilities and resources available to ACSEs and CACs:

Maryland Health Connection website (www.marylandhealthconnection.gov) Maryland Health Connection is a full service website and on-line marketplace that provides consumers with one

stop shopping for health insurance coverage. Individuals can use the Maryland Health Connection website to get an estimate on health coverage options, determine eligibility for insurance affordability programs, and enroll in health plans. The MHC website also has resources, guides and fact sheets to educate and inform

consumers. The website is available in English and Spanish. The system will securely store consumers’ information,

eliminating the need to collect the same information more than once throughout the enrollment process, even if the consumer switches between assistance programs.

To access the Maryland Health Connection website, Certified Application Counselors will need computers that are connected to the internet with one of the following minimum browser requirements:

Google Chrome 14+

Internet Explorer 9 or 10

CACs must have printing and scanning capabilities to scan identification and/or verification documents. CAC’s may also need to print completed applications and/or proof of enrollment.

The Consolidated Services Center The Consolidated Services Center (CSC) will provide a spectrum of services to enable a seamless experience

for consumers, including: responding to basic questions, providing eligibility and enrollment support services, providing website access support. The CSC will also assist consumers directly by accepting applications via telephone, and provide advice and support to those enrolling online or through the mail. The CSC also supports

interpreter services for consumers, offering a language line for enrollment and customer support. During open enrollment, CSC hours are 8am-6pm Monday through Friday, 8a-2p on Saturday. Hours are subject to change.

Certified Application Counselors may also utilize the CSC for technical assistance using a dedicated line. This dedicated line is for CACs only and may not be shared with consumers or other consumer assistance workers : (844) 649.5848. CACs will need their certification number to verify their identity and CAC designation when they

call.

Managed Care Organization Materials The Maryland Medical Assistance Program will provide pre-approved, uniform, factual, and unbiased

information about all Managed Care Organizations participating in the Medicaid program, including report cards, lists of enhanced benefits and covered services and participating providers which Certified Application Counselors may solely provide consumers during the Managed Care Organization selection process.

7

Connector Entity The Connector Entity (CE) engages or employs Certified Individual Navigators who assist with eligibility

determination and facilitate enrollment into a Qualified Health Plan, Medicaid or Maryland Children’s Health Program (MCHP). (Note: Navigators cannot assist with MCO enrollment.) There is one Connector Entity for each of the eight regions as outlined on the map. Each ACSE shall affiliate with at least one Connector Entity.

The CE will provide support to the ACSE and its CACs to help leverage resources, augment training, share best practices, and any relevant information or updates.

ACSE Financial Sustainability2 The designation of an entity as an ACSE by the MHBE comes with no funding from the State of Maryland. The statutory and regulatory conflict of interest requirements3 regarding both the Certified Application Counselor and

the Application Counselor Sponsoring Entity Program require that neither receive compensation from a carrier, insurance producer, a third party administrator or a managed care organization for enrollment services provided by Certified Application Counselors.

Thus, it is critically important to ensure that an entity seeking designation by MHBE as an ASCE is financially sustainable and able to self-support its enrollment efforts.

CAC Performance Measurement and Site Visits

Application Counselor Sponsoring Entities will be required to report performance metrics on consumer assistance by Certified Application Counselors. ACSEs will be required to monitor the performance of employed or engaged Certified Application Counselors. ACSEs are responsible for reporting metrics including number of

face to face encounters, eligibility and enrollment work completed for the quarter. These metrics are reported on a quarterly basis and can be sent to acse.cac@maryland.gov.

MHBE program staff may also participate in occasional phone or in-person check-ins, which will be coordinated with the ACSE point of contact.

Oversight and Accountability

Application Counselor Sponsoring Entities are required to conduct, and have on file, a successfully passed and current criminal background report for all affiliated Certified Application Counselors. Such records are subject to MHBE and MIA review.

2 According to COMAR 35.14.35.12. Application Counselor Sponsoring Entity Designation Standards 3 According to COMAR 35.14.35.13 Application Counselor Training and Certification Standards

8

ACSE Application Instructions and Required Forms The following provides detailed instructions to complete and submit the ACSE application, required forms and assurances.

The applicant is required to fill out each section when completing an application seeking designation as an Application Counselor Sponsoring Entity (ACSE).

Section One: Applicant demographic information

Each ACSE with a unique or separate tax identification number must have a separate application. Include the following information for the ACSE applicant:

Full Name of Organization Trade Name (if applicable)

Federal Tax ID number Contact Person

Title Address

Direct Telephone Number Email Address

Type of Organization (e.g., community-

based, health care provider, unit of local or state government or other entity)

Section Two: Region(s) where applicant plans to serve You may select more than one region. Indicate the region(s) for which the applicant is applying for designation as an Application Counselor Sponsoring Entity. A link to the regional map is found here.

Section Three: Certified Application Counselors Indicate the number of proposed Certified Application Counselors the entity intends to employ or engage.

Section Four: ACSE Qualifications

Discuss the ACSE’s qualifications with regard to:

Conducting enrollment of individuals into health insurance plans and programs

Existing relationships with target population and/or the ability to readily establish such relationships

Experience working with vulnerable and hard-to-reach populations.

Addressing the needs the ACSE will fill within the region

Experience in working with other state agencies, including Local Departments of Social Services (LDSS), Local Health Departments (LHDs) and Connector Entities (CE).

Section Five: CAC management and oversight Submit a description for how the prospective ACSE will oversee compliance and day -to-day management and quality assurance of employed or engaged Certified Application Counselors. List the name(s) and contact

information of the key individual(s) who will be responsible for oversight and management.

Section Six: Strategic approach to insuring the uninsured Describe the ACSE applicant’s approach to meeting the ACSE program’s objective of insuring the uninsured. Discuss the strategic approach and mechanisms and tactics for conducting education about Maryland Health

Connection, as well as fair and impartial enrollment assistance into MHC programs.

9

Section Seven: Letter of Support Attach a letter of support from the Connector Entity with which Applicant plans to affiliate. See the index for the

contact list by clicking here.

Section Eight: Signature Page An authorized representative must sign, print and date the signature page, which indicates you understand and agree to the terms as detailed on page five of the ACSE application.

ACSE Application Submission Instructions

Applications (new and renewal) may be submitted to: acse.cac@maryland.gov

Please print, fill out and sign each document before submitting to MHBE. The required documents to print and sign are on pages 12-36. You may then scan and send the signed documents back to MHBE.

Submission Checklist The following items must be submitted when applying to one of the email address listed above:

o Signed ACSE Application o Letter of Support from Connector Entity you plan to

affiliate

o Signed Attestation Form o Signed Non-Exchange Entity Agreement

Evaluation Criteria and Weight Once received your application will reviewed and approved for by MHBE for designation as an ACSE. The

MHBE will be reviewing your application to determine the entity mission, experience and ability to provide full range of services. MHBE will also review the operational approach for meeting the needs of the target populations.

ACSE Designation and Renewal

After MHBE has approved the application and the ACSE has signed the Designation agreement, the ACSE is subsequently able to have perspective CACs complete training and sit for the final exam.

The ACSE is responsible for renewing their designation with MHBE every two years. The ACSE must submit the renewal application, and signed Non-Exchange Entity, Attestation and Designation agreements to acse.cac@maryland.gov.

PII Protection and Breach Protocol

Each ACSE enters into a Non-Entity Exchange (NEE) Agreement with MHBE, and the agreement stipulates the correct protocol in cases of breach of Personally Identifiable Information, or PII. Each ACSE must adhere to PII safety and security standards as detailed in the NEE agreement.

A breach shall mean: the compromise, unauthorized disclosure, unauthorized acquisition, unauthorized access, loss of control, or any similar term or phrase that refers to situations where persons other than authorized users

10

or for an other than authorized purpose have access or potential access to personally identifiable information whether physical or electronic.

The ACSE will use the Form of Notification to MHBE of Breach of Unsecured PII (Exhibit 1 in NEE agreement) in potential cases of breach. The ACSE is responsible for reporting suspected cases of disclosure of unsecured

PII to MHBE no later than five (5) calendar days after the incident. Further, ACSEs must report cases of suspected or confirmed incidents involving loss or suspected loss of PII within one (1) hour of discovery.

Please review the NEE agreement for additional information about reporting possible breaches of PII.

CAC Training and Testing Once the ACSE is designated with the MHBE, prospective CACs may begin training and subsequently sit for an in-person exam to become a Certified Application Counselor.

MHBE offers training online through the Salesforce Learning Management System. Potential CACs can register for the training by going to https://mhbe.force.com/training/CustomCommunityLogin and clicking “Register” to

begin the application process. The prospective CAC must include their mailing and work address and work email address on the registration

application. The affiliated ACSE must also be included on the application. Once the application is reviewed and approved by MHBE the CAC will receive the following instructions:

1. Log into the MHBE Training Portal at https://mhbe.force.com/training (Please use the same username

and password that was used to submit the application)

2. Click on the “Learn” tab to see all courses that have been assigned to you. 3. Click on any course to access the training, and click “Launch” to start the course. You will be able to

track the progress of all courses that have been assigned to you.

4. If you have submitted a new application, all pre-credentialing training must be completed before you register for the final exam.

5. Once the required pre-credentialing training is complete, click the “Session Registration” tab to register

for an upcoming final exam. The prospective CAC may then have access to login and take policy training (14 modules) which includes

compliance training, voter registration, online policy assessment and systems training. All pre-credentialing training must be completed before the CAC will be permitted to register to sit for the final exam.

Once the training is complete, the CAC may register for the final exam via Salesforce LMS.

The CAC final exam is facilitated at the MHBE office each Wednesday at 10 a.m. Registration for the

exam closes every Tuesday at 12 noon. Note: Prospective CACs have 45 days, complete the required pre-credentialing training and sit for the final

exam. If the training and/or testing is not satisfactory completed before the 45 day window, the prospective CAC must re-register and re-take the training again.

Every year prior to open enrollment, each CAC is required to take annual continuing education training courses , such as policy updates and compliance. Reminders to complete annual compliance training are sent to the ACSE by MHBE once available.

The prospective CAC is required to get an 80% on the exam to pass. There are two attempts allowed, after the second attempt the prospective CAC cannot train or test again for one year.

11

Attachments The following section provides the forms that ACSE applicants are to complete and submit with the application. Before submitting your application, please be sure you have the following:

Signed ACSE Application4

Signed Non-Exchange Entity Agreement4

Signed ACSE Attestation4

Designation Agreement – this is the agreement that an ACSE will be required to sign upon designation as an Application Counselor Sponsoring Entity. It is provided with the program manual for informational purposes and is not required at the time of submission of the application. After certification, this

agreement will be filled out, signed and submitted to MHBE via email to acse.cac@maryland.gov.

IMPORTANT: There is a separate Non-Exchange Entity Agreement and Designation Agreement for a state government agency. Send email request to: acse.cac@maryland.gov for government entity agreements.

4 These documents must be completed and submitted at the time of submission of the application

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

Index Regional Map

Connector Entity contact list

38

39

Glossary of Terms For the purpose of this program the following terms are defined as:

Term Definition

Advance Premium Tax Credit (APTC) Financial subsidies for individuals whose Modified Adjusted Gross Income (MAGI) is up to 400% of the poverty level who enroll

in a qualified health plan through an Exchange.

Certified Application Counselor (CAC) Individuals who have completed training and received

certification to provide information to consumers about the full range of Qualified Health Plan and Qualified Dental Plan options

and Insurance Affordabil ity Programs, assist consumers with the application process for determining eligibility for Insurance Affordabil ity Programs, facilitate plan selection and enrollment of eligible individuals in Qualified Health Plans, Qualified Dental Plans,

and access to advance premium tax credit and other cost-sharing subsidies and provide consumers uniform, factual, and unbiased information approved by the Maryland Medical Assistance Program

about all participating Managed Care Organizations. Certified Application Counselors must be employed by or engaged with Application Counselor Sponsor Entities at all times to maintain an active certification.

Application Counselor Sponsoring

Entity (ACSE)

Community-based organizations, health care providers, units of

State or local government, or other entities designated by MHBE

within specific regions of the State to perform enrollment activities

through their employed or engaged certified Application

Counselors.

Authorized Producer A licensed insurance producer (also sometimes called broker or

agent) who has been authorized to use Maryland Health Connection

to enroll Marylanders in Qualified Health Plans and Qualified Dental

Plans. These individuals hold a l icense issued by the Maryland

Insurance Commissioner and are required to take special training in

order to qualify.

Commissioner The Maryland Insurance Commissioner.

Connector Entity (CE) A community-based organization or other entity or partnership of

entities that is authorized by the MHBE and employs or engages

Individual Navigators.

Insurance Affordability Program Advance premium tax credits and cost-sharing subsidies, the Maryland Medical Assistance Program, and the Maryland Children’s Health Program.

40

Managed Care Organization (MCO) A private health insurer that accepts payment from the State to

manage a Medicaid or Maryland Children’s Health Program recipient’s

benefits.

Maryland Children’s Health Program (MCHP) Public health insurance program funded under Title XXI of the

Social Security Act for qualifying low-income children up to age 19 and pregnant women of any age.

Maryland Health Benefit Exchange (MHBE) The unit of State government responsible for designing and

administering the Maryland Health Connection.

Maryland Health Connection The state-based health insurance marketplace where Maryland residents and small businesses will be able to explore and

compare health insurance plans, qualify for cost- sharing subsidies and tax credits and complete the enrollment process.

Maryland Insurance Administration (MIA) Independent State agency that regulates Maryland's

Insurance industry and protects consumers by enforcing

insurance laws. Oversees Application Counselor program

compliance with State law.

Maryland Medical Assistance Program The State Medicaid program.

Qualified Dental Plan A stand-alone dental plan that has been certified by and is sold on the

marketplace.

Qualified Health Plan

A health benefit plan that has been certified by MHBE and is sold on

the Maryland Health Connection.