Today, CCF joined more than 140 national and state organizations asking Secretary of Health and Human Services Burwell to work expeditiously to remove barriers that make it difficult for eligible immigrant and mixed status families to obtain health coverage.

The letter focuses on 5 serious barriers that need to be resolved so that eligible  individuals and families can receive coverage they applied for in the initial open enrollment period and that will remove barriers to enrollment when open enrollment 2015 begins in less than 4 months.  A quick look at our recommendations is below, but you can read the full letter here for a more thorough explanation of each barrier and recommendation.

1.  Individuals stuck in the inconsistency or data matching process – More than one million applications of immigrant families are in the inconsistency process due to problems verifying citizenship or immigration status.  We recommend that these individuals should keep their subsidies and coverage until HHS has fully fixed the errors in both the immigration status verification system and the programming of eligibility for subsidies for lawfully present individuals under 100% FPL; and is able to provide adequate, language appropriate notices about the additional information needed to process their application.
2. Incorrect eligibility determinations for immigrants under 100% FPL—Many lawfully present immigrants with income under 100 percent FPL who are ineligible for Medicaid based on their immigration status have experienced additional barriers to marketplace coverage, even though they are eligible for premium tax credits.   HHS should continue working to fix the system problems so that individuals receive an accurate eligibility determination and don’t need to use the existing workaround.  Until these problems are fully fixed, HHS should create another workaround for people who do not apply for Medicaid because they know they are not eligible.  HHS should also notify people who may not have enrolled in a QHP because they received an improper eligibility determination and allow the to resubmit an application.
3. Identity Verification Barriers – Many lawfully present immigrants have limited, and in some cases nonexistent, credit history, making the electronic identity verification process impossible.  HHS could make the identity proofing process more successful by including additional documents that low-income individuals are more likely to have such as a lease or a telephone bill.  In the short term, HHS could also put in place a number of fixes, like requiring their contractor, Experian to provide language access services in languages other than Engllish and Spanish, tapping into other sources of data other than credit history.  In the long term, HHS should identify additional strategies to protect consumer privacy that does not deter or delay eligible people from submitting applications.
4. Immigration Status Verification Problems – The current system in place to verify immigration status and citizenship has failed to accurately verify the immigration status of nearly 1.5 million eligible immigrants and naturalized U.S. citizens.   Some work-arounds have been put in place, but the fundamental technology problems are not fully fixed. Prior to the next open enrollment, HHS should full fix the remaining problems and establish ways for applicants to check the status of their document review and provide notices in preferred language.
5. Language Access Barriers- For LEP consumers who speak a language other than Spanish, the options for enrollment were very limited.  Only two of the four avenues for enrollment, call center and in-person assitstance – were available to LEP consumers. In the first year of enrollment, language access was insufficient and HHS has not yet promulgated standards to ensure meaningful access for LEP consumers.  Increasing health coverage for all Americans, including immigrants, is integral to the success of the ACA, and addressing language access barriers should be a top HHS priority.

The letter also asks HHS to provide leadership to state marketplaces struggling with similar barriers.