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Federal requirements for navigators in a state-operated insurance exchange

August 23, 2012 - In its "Draft Blueprint for Approval of Affordable State-based and State Partnership Insurance Exchanges" published in May 2012 the U.S. Department of Health and Human Services makes several requests from states regarding navigators in its application for insurance exchange approval. The primary areas of concern are:

  1. Training
  2. Conflict of interest standards
  3. Privacy and security
  4. Consistency with federal law
  5. Some navigators operating through non-profit organizations
  6. Proficiency in 5 duties of navigators

 

Documentation is requested to provide a brief description of Exchange’s plan to operate a Navigator program, including documentation outlining the Exchange’s progress in developing conflict of interest and training standards; how it will ensure Navigators are appropriately trained and meet the Exchange’s conflict of interest, privacy and security standards; and a timeline and strategy for funding for the Navigator program and making the program fully operational.

 

The following are excepts from the state insurance exchange application that pertain to navigators. Emphasis is added.

 

"The Exchange has established or has a process in place to establish and operate a Navigator program that is consistent with the applicable requirements of 45 CFR 155.210, including the development of training and conflict of interest standards, and adheres to privacy and security standards specified in 45 CFR 155.210 and 45 CFR 155.260."

 

"The Exchange has established or has a process in place to establish and operate a Navigator program that is consistent with the applicable requirements specified in 45 CFR 155.210 and 45 CFR 155.260."

 

"The Exchange has a plan for the ongoing funding of an Exchange Navigator program, and has awarded grants to at least two (2) types of entities, one of which is a consumer-focused organization or non-profit entity. Grant agreements ensure that Navigator grantees (“Navigators”) will conduct the five (5) duties outlined in 45 CFR 155.210."

 

A review of specific state responses to these inquiries on the completed applications may provide more insight to navigator candidates.