A recent posting of a Paperwork Reduction Act (PRA) notice in the federal register details plans by CMS to tweak navigator entity reporting requirements, which I’ll say more about in a few minutes.
But what really excited me about the notice – drumroll please – is that, in the supporting statement, CMS signaled its intent to provide three years of funding in the next round of navigator grants. Extending the length of the funding period is important to build stability in enrollment assistance programs. No longer will individual navigators have to put their resume on the street at the end of the grant year, just in case. Three-year funding periods will enable navigator entities to recruit and retain permanent, professional consumer assisters and assure high quality assistance for consumers. If you like this change, I definitely recommend that you submit supporting comments.
As to the reporting requirements, according to the supplemental information, CMS has reduced the weekly reporting requirements significantly. However, the monthly data collection has increased to account for more monitoring and oversight of grantee performance. Furthermore, the quarterly reporting requirements have been reduced substantially. In the end, it seems like the same amount of effort will be required to comply with the reporting requirements.
Here are some thoughts about the proposed reporting requirements:
- How do the navigator reporting requirements align with the reporting requirements for enrollment counselors in community health centers receiving HRSA outreach and enrollment grants? While I recognize there are some differences (but not many) in the expectations of the two different types of enrollment assistance, much of what these assisters do is the same. So why not align the data collection so we can get a big picture view of federally financed outreach and enrollment assistance?
- And what about transparency? Public reporting of these data could be very useful in a number of ways, from advocating for more adequate funding levels to demonstrating the value of consumer assistance.
- CMS could enhance its technology so that specific functionality enables the system to track and report on data from applications and accounts served by assisters. This would further reduce the time and expense of reporting so that more dollars could be dedicated to direct consumer assistance. Such system capacity could report even more robust data, while adding new capabilities for assisters to better serve consumers. For example, Kynect (Kentucky’s equivalent of Healthcare.gov) allows assisters to send emails to consumers and check the status of applications.
While we’re on the subject of consumer assistance, I want to commend CCIIO for boosting its training and technical assistance to navigators. A hotline was established this year that is dedicated to helping assisters with complex cases. And certainly the folks in the Consumer Support Group are working round the clock to open up the lines of communication between the group and assisters or the organizations that coordinate and support them. But there is more that can be done systemically to strengthen and improve our enrollment assistance programs, as we recommended to Secretary Sebelius more than a year ago. We hope CMS will continue to chunk away at these strategies, which would allow Navigators to stretch their resources to reach the largest numbers of consumers.
Stakeholders are welcome to comment on any aspect of the PRA, just as they submit comments when CMS proposes new rules. Comments on this notice are due by May 29, 2015, and can be submitted electronically at http://www.regulations.gov.