Consumer Advocates Respond to HHS’s Model Application

By Jocelyn Guyer

Let’s just say it straight out. Congress handed the Administration a Mt. Everest-sized challenge when it said they must develop a simple, streamlined model application for enrollment in all possible sources of ACA coverage – Exchange coverage, Advance Premium Tax Credits (APTCs), Medicaid and CHIP.  It would be hard enough to figure out eligibility for any one of these programs, but to develop a single, unified application for all three is truly a tall order.  But, it is one that I’m glad HHS is taking on.  As hard as it will be to develop a simple, streamlined application, it would have been even harder for families to have to navigate up to three different application procedures and eligibility systems.

The good news is that HHS has jumped in and put forth a draft application.  Moreover, it has actively solicited feedback from states, consumer advocates and others on the draft under a comment period that closed February 28, 2013.  Thanks to the Robert Wood Johnson Foundation, CCF had some resources to bring into town a group of seasoned state advocates from around the country to provide HHS with some consumer-oriented feedback on their draft. If I had to summarize the overall reaction, it would be that HHS should get an A for effort, but that many low and moderate-income people would be stymied by the complexity of the application and simply “get stuck”.  Of particular concern is that the decision by Congress to use IRS-based rules for figuring out who qualifies for affordability programs means that the application feels a lot like filling out a tax form, and not the 1040EZ version.

In detailed comments that grew out of the meeting, we offer some ideas for changes that HHS can make to improve the model application.  They include making sure people can file an application based on a few key data elements; getting them help if they do get stuck; shortening and simplifying the application; better facilitating the enrollment of people with disabilities into the right coverage; and making the application more friendly and welcoming to families with immigrant members.

We are looking forward to round 2, and quickly.  The time is rapidly dwindling between now and when open enrollment begins on October 1, 2013.