Last summer in a refresh of the exchange establishment grants, CMS quietly offered federal funding for a new category of assisters, called “in-person assisters” (IPAs). In November, I summarized what we did and didn’t know about IPAs in this blog post. In a nutshell, IPAs are intended to help exchanges meet their requirement to provide consumer assistance distinct from navigators. But the fact is, very little federal guidance has been put in writing about IPAs. There were these excerpts from the federal funding opportunity announcement (FOA) and exchange blueprints but for more than six months, we waited for more details.

We knew from the FOA that in-person assisters programs were a state option for state-based exchanges and a required component of the consumer assistance plan if a state was planning to partner with the federally-facilitated exchange. And while there is nothing in writing to back it up, we fully expected there to be IPAs in pure FFEs because that’s what administration officials had said. We were also being told that IPAs would (will) receive the same training, be subject to the same conflict of interest and privacy standards, and perform the same duties as navigators in FFE states. The expectation was that IPAs would supplement navigators to ensure that consumers would have sufficient access to help in applying for financial assistance and enrolling in coverage starting in (tick tock, tick tock) a little less than seven months.

As word of the availability of federal funding for in-person assistance began to spread to the states, Arkansas, the first state to declare a state partnership exchange, was also the first state to be approved for $17 million to develop and deploy in-person assistance program. This was very exciting news because it signaled that federal funding for in-person assistance could be significant at a time when we need all hands on deck.

Then, about the time the January 3, 2013 Guidance on State Partnership Exchanges revealed more details about the IPA programs in partnership states, I first got wind of troubling news that there will be NO in-person assisters in pure FFE states. That means consumer assistance in more than half of the states will be limited to navigators. And these are the very states where legislation is cropping up to restrict what navigators can and can’t do.

As we anxiously await the navigator funding announcement, there is growing and gnawing concern that resources to support consumer assistance will not be sufficient to meet the needs of consumers. All the while, research is stacking up to show that most consumers want and need assistance in making health coverage decisions. The latest Enroll America survey found that over half of uninsured people want help either applying for financial assistance or selecting a health plan. And 75% of those who want help would prefer to get help in-person.

Anticipating less than adequate resources for navigators and no in-person assistance in FFE states, we are even more appreciative of the role that Certified Application Counselors may play in helping to connect consumers to coverage. It is unlikely though that a program that looks to tackle consumer assistance by relying on a volunteer and unpaid network of organizations will be sufficient to fill the gap.

Stay tuned for the finale in this series, when we’ll explore whether or not assisters will be plentiful enough to meet the need.

(Editor’s Note:  For more information on assisters, click here.)