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February 28, 2013 VIA ELECTRONIC SUBMISSION Centers for Medicare & Medicaid Services Department of Health and Human Services P.O. Box 8016 Baltimore, MD 21244-‐8016 Attention: CMS-‐10440
Appendix A: List of Questions in the Online Application to Support Eligibility Determinations for Enrollment through the Health Insurance Marketplace and for Medicaid and the Children’s Health Insurance Program Appendix C: FA Paper Application Appendix D: non-‐FA Paper Application
Single, Streamlined Application This document provides very specific detailed suggestions working chronologically through the paper application and online questionnaire. In addition, we provided other comments regarding top priority issues that are not addressed as thoroughly in this document. PAPER APPLICATION COMMENTS NON-‐FINANCIAL ASSISTANCE APPLICATION Our comments will focus on the paper application for financial help and the online questionnaire. To the extent that the same questions are asked or the same language appears on the non-‐financial application, these comments apply. To encourage the many individuals and families who will be able to get help paying for insurance, we recommend the addition of language to the non-‐financial application.
Recommendation: Add this line in parenthesis under the title on the Application for Health Insurance – “If you would like to see if you can get lower payments, do not use this application. Find out more or get a different application online at (insert link) or by calling 1-‐888-‐XXX-‐XXXX.
FINANCIAL ASSISTANCE PAPER APPLICATION Where there is commonality between the paper application and online application, our specific comments apply to both. Our comments start with the paper application for financial assistance. General Comments
Literacy levels: We are concerned that the application may be difficult to complete for people with low literacy skills. For example, research has shown that many people do not understand the meaning of “optional.” We recommend that HHS consult with health literacy experts who have experience with low-‐income populations. There are two specific resources that may be helpful:
“The Health Literacy Style Manual” that was prepared for the Covering Kids and Families Initiative and created by the Center for Health Literacy at Maximus. This manual, which includes specific sections on applications and translations, can be found at: http://www.thesoutherninstitute.org/docs/publications/CKF%20Health%20Literacy%20Style%20Manual%2010-‐2005.pdf “Health Literacy Educational Toolkit” developed by the AMA Medical Association Foundation and the AMA Medicaid Association. This toolkit is available at: http://www.ama-‐assn.org/ama1/pub/upload/mm/367/healthlitclinicians.pdf.
Formatting: Research has shown that cross-‐references, tables and a lack of white space make it difficult for some people to complete forms. In particular, the pages that are required for each person are too dense and have too little white space. Taglines: We appreciate the inclusion of Spanish taglines. However, this is insufficient to meet the needs of the diverse applicants who are eligible for coverage. We suggest adding taglines for the 15 most prevalent languages. If you add a “Things to Know” page as suggested below, there will be space to include this information. Length vs. Clarity and Ease of Use: Although brevity is preferred, it may not always lend itself to being simple and understandable. More information may be needed to ensure that applicants understand the application and what they need to do. Experience in Medicaid and CHIP demonstrated that when states favored shorter applications, they were often more difficult to complete and comprehend. We believe it is more important for the application to build on the best practices in developing and perfecting Medicaid and CHIP applications over time and not err on the side that brevity is best. What core data elements constitute a valid application and establish a Medicaid filing date? It is critically important that HHS establish the core data elements that are needed to constitute an Medicaid application and establish a filing date that determines the effective date of benefits for eligible people. Cover Sheet: Use this application to see what insurance choices you qualify for: To add clarity to this section, we have the following recommendations.
Recommendation: Change bullet two to “A new tax credit that can help pay for private health insurance purchased from the new Health Insurance Marketplace in your state.”
Recommendation: If the non-‐financial application is intended to see if people qualify for exchange coverage, the third bullet could be eliminated. Recommendation: Include more examples for different family sizes. Minimally include the upper income for a single person. Change wording to – “Qualifying for free or low-‐cost health insurance is based on your family size and how much money you make you make (your income). A family of four earning as much as $94,000 (2013 level) or a single person earning as much as $45,000 may qualify for lower premiums.
Apply faster online: While this information should be on the page, if space becomes an issue, it could be a smaller single line at the bottom of the application. Get help with this application: In order for people to know they can get help rather than complete the application on their own, we recommend moving this section higher up on the cover page.
Recommendation: Move the “Get Help” section up to follow “Apply faster online.” Recommendation: Add a bullet to this section; “If you do not speak English, we will get an interpreter to help you. There is no cost to you to use an interpreter. Please call 1-‐888-‐XXX-‐XXXX.”
What you may need to apply: This language doesn’t fully convey that gathering the suggested information will make it easier to complete the application or that not all of the information is required to complete the application.
Recommendation: Change to “This application may be easier to complete if you gather some information in advance if you have it. You can still submit an application even if you do not have some of this information.” Recommendation: The first bullet regarding Social Security numbers (SSN) specifies that document numbers are needed for legal immigrants who need insurance. It doesn’t say that SSNs are needed only for those applying for coverage.
Why do we ask for so much information: This information is not sufficient to reassure applicants about privacy, why information is needed and how it is used. Please see our recommendation below to add a “Things to Know” page that follows the cover sheet. If more thorough descriptions are not added in a “Things to Know” page, we recommend the following changes to the this section:
Recommendation: Add “secure” to the second sentence as follows: “We’ll keep all the information you private and secure, as required by law.” Recommendation: Add this sentence – “Information on this application is only used to determine eligibility for health insurance.”
What happens next: It is most important that this information appear at the end of the application after instructions for mailing. If space becomes an issue on this page you can abbreviate this section as follows:
Recommendation: “What happens after you complete the application…At the end of the application, we tell you where to send the application and what happens next.
You do not have all the information we ask in order to sign and send in the application.
Add “Things to Know” page: Information provided at the beginning of the application is critical to ensuring that applicants feel secure in submitting personal and confidential information. This is particularly true for mixed immigrant families and we address their unique needs in separate comments. We recommend the inclusion of a “Things to Know” page after the coverage page that includes the following information:
We keep all information you tell us private and secure. We will keep all the information you provide private and secure as required by law. We will use it only to check if you are eligible for health insurance. You can tell us if you do not want us to check to see if everyone in your family or living with you can get health insurance. You may file applications for families and households that include some members applying for health coverage and others who are not. You do not have to provide a Social Security number (SSN) or immigration status for people in your family who are not seeking coverage. We will not delay or deny health coverage because there are family members who are not seeking coverage. For those who do not apply, we can give you information about other ways to get health care. You cannot be discriminated against. Under federal law, discrimination is not permitted on the basis of race, color, national origin (language or limited English proficiency), sex, or disability. To file a complaint of discrimination, go to www.hhs.gov/ocr/office/file.
Families that include immigrants are welcome to apply for help with health insurance costs. If you do not speak English, we will get an interpreter to help you at no cost to you. Please call (XXX) XXX-‐XXXX. (In top 15 languages) Applying for health insurance or getting help with health insurance costs will not make you a “public charge”* and will not affect your immigration status or chances of becoming a lawful permanent resident (getting a “green card”) on that basis. Applying for health benefits won’t prevent you from becoming a citizen, as long as you tell the truth on the application.
Step 1 – Tell us about yourself: The instructions below “Step 1” are too vague to allow an individual to understand the purpose of this step. We suggest CMS add additional language explaining that this information is requested of the person who should be contacted about the application.
Recommendation: Amend the wording to: “Tell us about yourself. (We need one adult member in the family to be the contact person for your application. We will
contact this person if we have any questions and to provide information about your eligibility. If this is not you, please tell us who should be the contact person.)”
Step 2 – Leading instructions: This section should provide more background and context. Applicants need to understand why they are being asked detailed questions regarding their income, family size, and living arrangements that may seem intrusive and, at times, repetitive. Also, applicants are likely seeking the best coverage, not the most coverage possible as the text currently includes. The best coverage may include considerations related to cost-‐sharing which most coverage may not.
Recommendation: We suggest changing the language as follows: “You and your family members may qualify for low or no cost health insurance programs or for lower payments to buy health insurance. The amount of assistance or type of health insurance depends on your family size, income, and living arrangements in your household. By providing information in the following sections, we can make sure everyone applying for health insurance coverage gets the best coverage possible.”
Who needs to be included on this application: This bulleted list should start with “You.” Additionally the language here is not completely consistent to the instructions that follow on the individual person pages (Step 2 Persons 1-‐6). The bulleted list says to include your spouse, partner who lives with you (but only if you have children together who need health insurance) and anyone you include on your federal income tax return. The Step 2 doesn’t qualify whether to include your partner. Additionally, if you don’t file a tax return, remember to still add family members who live with you. It’s not clear who “family members” are. It’s also confusing (and contradictory to the statement about everyone getting the most (best) coverage possible) why an applicant needs to list anyone included on their tax return but that person will have to file their own application. More explanatory text is needed.
Recommendation: Replace the statement about a separate application with “While you must include anyone on your tax return in order for us to know the size of your household, any person on your tax return that is not your spouse, partner with whom you have a child or your child will need to file their own application if they want insurance.”
Step 2 Pages for Providing Information for Persons 1-‐6. Child Specific Pages – For children who do not file taxes, less information is required. If space is an issue, consider drafting child only pages that eliminate unnecessary information. White Space and Crowding – There is insufficient white space on these pages, and additional information (specifically language preferences for everyone) needs to be added. Use of Word “Optional” – The Health Literacy Style Manual referenced earlier specifically notes that many people do not understand the meaning of this work.
Recommendation: Replace optional with “not required.” Redundant Request for Social Security Number – The second SSN request can be eliminated by amending the explanatory text associated with the first request. The recommended language below could be trimmed if it is fully explained on the “Things to Know” page. However, repetition can be useful when communicating key messages to mixed status families.
Recommendation: Move the SSN field to align with the explanatory text so they are clearly associated. Remove the OPTIONAL next to the SSN field. Amend the explanatory language to read: “You only need to provide Social Security Numbers (SSNs) for family members applying for health insurance, if they have one. An SSN is not required for people listed on the application but not applying for insurance. We will not delay or deny health coverage because there are family members who are not seeking coverage. SSNs are used to check how much money you make (your income) and citizenship to see who is eligible for help with insurance. However, providing the SSN for all family members who earn income can speed up the application process. If someone who is applying for coverage does not have an SSN, you can get help by…..
Is Person X applying for health insurance – We suggest more language to encourage people who have insurance to apply.
Recommendation: Amend the text in parenthesis to: “You can apply if you have current private insurance. Even people who have insurance may be able to get better coverage or lower costs.”
Disability – There is insufficient detail in the question about daily living activities to adequately screen for people who may qualify for other categories of Medicaid but do not have a confirmed disability. One suggestion would be to insert a new step between the current Steps 2 and 3 or 3 and 4. This step could better articulate the kinds of questions that would lead to better screening and give applicants information about the possibility of getting better benefits by applying for non-‐MAGI Medicaid. Such questions might include those used by the American Community Survey to collect data on disability status, as well as other child-‐specific questions noted below.
Recommendation: Retain the question on whether the person has a disability. Delete the question about daily activities and add a step for disabilities that includes these questions: You or a family member may be eligible for more benefits and lower costs if you answer yes to any of the questions below.
1. Are you or is anyone on this application deaf, or have serious difficulty hearing? Yes ____ No ____ If yes, who _____________________________________________________?
2. Do you or does anyone on this application have serious difficulty seeing even when wearing glasses? Yes ____ No ____ If yes, who _____________________________________________________?
3. Because of a physical, mental, or emotional condition, do you or does anyone on this application have serious difficulty concentrating, remembering, or making decisions? Yes ____ No ____ If yes, who _____________________________________________________?
4. Do you or does anyone on this application have serious difficulty walking or climbing stairs? Yes ____ No ____ If yes, who _____________________________________________________?
5. Do you or does anyone on this application else have difficulty dressing or bathing? Yes ____ No ____ If yes, who _____________________________________________________?
6. Because of a physical, mental, or emotional condition, do you or does anyone on this application have difficulty doing errands alone such as visiting a doctor's office or shopping? Yes ____ No ____ If yes, who _____________________________________________________?
7. Is any child on this application limited or prevented in any way in his or her ability to do the things most children of the same age can do? Yes ____ No ____ If yes, who _____________________________________________________?
8. Does this child need or use more medical care, mental health or educational services than is usual for most children of the same age? Yes ____ No ____ If yes, who _____________________________________________________?
9. Do any of your children have a medical condition that left untreated would result in the death or serious physical injury of the child?
10. Yes ____ No ____ If yes, who _____________________________________________________?
The disability page should include additional information on how to get more information or apply for non-‐MAGI Medicaid.
Foster Care Question – Explain why this information is needed.
Recommendation: Add this information to this question. “If you or someone else applying for health insurance were once in the foster care system, that person may be eligible for more benefits at lower costs. Help us decide if you are eligible by answering the following question.”
Race and Ethnicity –The ACA requires collection and reporting of these data, including primary language, for applicants, recipients or “participants” (emphasis added). The household contact is a participant.
Recommendation: Move the questions on race and ethnicity to above whether the person is applying for coverage.
Language – As noted above, the ACA requires collecting and reporting primary language.
Recommendation: Preferences for written and spoken language should be asked for all applicants.
Person 1 vs. Persons 2-‐6 – The starting instructions on page 3 are unclear.
Recommendation: Amend the language on Person 1 to read “Complete Step 2 for yourself. On subsequent pages, amend the language to read “Complete Step 2 to for your spouse/partner (if you and your partner have a child), each of your children who live with you, other family members who live you and anyone else you include on your federal tax return.
Domestic Partnerships: It is important to provide additional information on when domestic partners can qualify for help with health insurance. Income – Current Jobs: Many people work jobs that are seasonal or where their work is on call.
Recommendation: Add seasonal and varies to the list of frequency with space for an explanation.
Income – Changes in Past Six Months: This section seems connected to the current job 2.
Recommendation: Make the separating line wider and gray or insert additional space to separate.
Income – Other Income: Clarify that veteran’s payments means veteran’s benefits not veteran’s retirement. Income – Pretax Contributions and Deductions: MAGI-‐based income excludes contributions for health insurance premiums paid, child care, transportation benefits and certain retirement plans. Additionally, qualifying deductions for alimony, student loan interest and other items should be included. The application does not gather this information and will thus overstate income significantly in some cases, which will result in improperly screening for Medicaid eligibility or understating the level of APTCs and cost-‐sharing reductions
Recommendation: Add questions regarding pre-‐tax contributions and deductions. Income – Yearly Income: This section needs a definition for what should be included in yearly income.
Recommendation: Asking someone to project annual income is extremely difficult. In the online environment, we recommend the use of a worksheet that helps someone calculate his/her yearly income less pre-‐tax deductions. For the paper application, we are concerned about the accuracy of what is reported and how it might be used.
Step 3 – Insurance from Jobs Employee SSN – It is redundant to ask for an SSN for a third time on the application.
Recommendation: Delete the field for SSN.
Employer EIN – The asterisk explanation requires a cross-‐reference and is hard to find. Provide this help text in the field or suggest the applicant check their W-‐2.
Recommendation: Insert this statement in the field with the request for the EIN. “You can ask your employer for this information (see page XX) or find it on the W-‐2 year end wages form from your employer.”
Minimum Value Standard Coverage Questions: We are very concerned about asking individuals questions that few people can answer. Trying to get at whether the employee is “offered” or “eligible for” enrollment is just too complicated to get valid answers. We recommend that the applicant not be requested to provide this information. Preferably, the only question should be “does your employer offer health coverage?” If yes, the exchange should contact the employer to obtain necessary information. Name of Lowest Cost Self-‐Only Health Plan: Most, if not all, people will not understand what this means. Self-‐only should be clearly articulated as coverage for the employee only. Additionally, it should be clarified what information is being request by “name of the health plan.” Is it the insurance carrier name? Is it whether the plan is a PPO or HMO? Is it the product name such as Carefirst?
Recommendation: If this section is not deleted, rephrasing of this question is needed. We recommend that extensive consumer testing be conducted to craft the best wording of these questions to ensure an accurate outcome of eligibility.
Is Employer Coverage Affordable: It is not clear why this question is needed or how it will be used.
Recommendation: Eliminate this question. Will Employer Coverage Be Affordable Next Year: It is not clear why this question is needed or how it will be used.
Recommendation: Eliminate this question. Other Health Coverage: We offer several recommendations for this section. However, we are particularly concerned about people who are enrolled in COBRA coverage and paying more than 100% of the cost of coverage, which is often considered unaffordable. While they cannot get APTCs while enrolled in COBRA, they can drop COBRA and enroll in a QHP with financial assistance at open enrollment. Additional information should be provided to inform applicants that they may be able to get better and lower cost coverage if they do so. Eligibility should be processed for those with COBRA coverage and pended until disenrollment from COBRA is verified.
Recommendation: Substitute “Coverage” for “Insurance” in this section. Recommendation: Clarify that this section pertains to people “enrolled” in other coverage and not just eligible for. Recommendation: Add Student Health Insurance to the list. Recommendation: Ask when the COBRA coverage ends and add this question: “Would you terminate your COBRA coverage if you were found eligible for another health program?”
Step 5 – Review and Sign Reporting Changes (Bullet 2): It would be helpful to be more specific about what changes people are required to report. Also since this application is used for Medicaid as well, it is not just the Exchange that needs to be notified. Reported income changes in the Exchange are treated differently than in Medicaid and this section does not address those differences. It may be that this information is best dealt with in eligibility notices, or at least reiterated and specific to the program of eligibility.
Recommendation: Rephrase the second sentence in the second bullet (or include it as a separate bullet) as follows “I know that I must tell the Health Insurance Marketplace or Medicaid if I move, have a change in income or someone is added to or leaves my household.
Renewal of Coverage: Ideally, renewal information is addressed in the notice of eligibility because at the time of application, it is not clear which program rules will apply at renewal.
Recommendation: Delete instructions about renewal and include appropriate information regarding renewal and reporting charges on the notice of eligibility.
Medicaid Eligibility/Medical Support: Recommendation: Rephrase the second sentence as follows: “If I think that cooperating to collect medical support will harm me or my children, I can tell Medicaid when they contact me and I will not have to cooperate.”
Your Right to Appeal: We suggest testing whether “action” is the right word to be used here. Decision could be a better alternative. Two Signature Lines: It is not clear who should sign (if anyone) on the second signature line. What Happens Next: Consider moving to the next page below where to mail, fax or e-‐mail the application. Authorized Representative: We have the following recommendations for this section:
Recommendation: Add relative to the examples of who might serve as an authorized representation. Recommendation: Ask if any renewal notices should also be sent to the authorized representative. Even if selecting, notices should also be sent to the enrollee. Recommendation: Include language that tells the applicant that they can change or remove their authorized representative at any time and how they would do so.
Step 6 Ways to Submit Application: Applications can be mailed or submitted via common electronic transmission including fax and e-‐mail. Additionally, some people will prefer to drop off applications personally.
Recommendation: Include instructions for faxing or e-‐mailing a scanned version of the application. Provide information on where an applicant can drop off the application in person (either the exchange office or at a navigator or certified application counselor site).
Instructions for Eligible Immigration Status: Need to clarify that this means “immigration status that is eligible to enroll in health insurance.” It is also important to repeat reassuring language that immigration status is only used to see if someone can get help with health insurance, and not for enforcement purposes. Employer Coverage Form: The application should provide for the applicant to attach a form developed by their employer that includes the needed information. Employers may choose to post similar information their website or provide directly to employees at open enrollment, and thus requiring that they fill out the application form is duplicate and unnecessary. ONLINE QUESTIONNAIRE General Comments We commend the effort that has gone into to simplifying and streamlining the online and paper applications. In the online environment, the use of dynamic questioning and help text or pop-‐up/hoover alerts can be extremely helpful in making the process as smooth and easy as possible. However, it is difficult to provide well-‐rounded feedback without being able to “test drive” the application or review the planned “help or explanatory” text language. We ask that there be future opportunities to weigh in on the ease of use of a working version of the application, as well as review proposed wording of help text and alerts. Literacy levels: We are concerned that the application may be difficult to complete for people with low literacy skills. For example, research has shown that many people do not understand the meaning of “optional.” We recommend that HHS consult with health literacy experts that have experience with low-‐income populations. Taglines: We appreciate the inclusion of Spanish taglines. However, this is insufficient to meet the needs of the diverse applicants who are eligible for coverage. We suggest adding taglines for the 15 most prevalent languages. Additionally, the online application should be translated in to these languages.
Recommendation: Add language: “If you do not speak English, we will get an interpreter to help you at no cost to you. Please call 1-‐888-‐XXX-‐XXXX.
Landing Page: The home page of the health portal that houses the online application should be inviting and welcoming. It should provide additional information about the insurance affordability programs, as well as encourage language for individuals and families to apply for financial assistance and reassuring language for immigrants and mixed immigration status families. Before someone starts to enter data, it should provide privacy
notices and clear information about how information will be used (i.e. to check income and citizenship) and how it will not be used (for enforcement purposes). Suggestions include:
You may file applications for families that include some members applying for health coverage and others who are not. You do not have to provide a Social Security number (SSN) or citizenship or immigration status for those in your family who are not seeking coverage. We will not delay or deny health coverage because there are family members who are not seeking coverage. We will keep all the information you provide private, confidential and secure as required by law. We will use it only to check if you or family members who are applying are eligible for health insurance. Under federal law, discrimination is not permitted on the basis of race, color, national origin (language or limited English proficiency), sex, or disability. To file a complaint of discrimination, go to www.hhs.gov/ocr/office/file.
Applying for health insurance or getting help with health insurance costs will not make you a “public charge” and will not affect your immigration status or chances of becoming a lawful permanent resident (getting a “green card”) on that basis. Applying for health benefits won’t prevent you from becoming a citizen, as long as you tell the truth on the application.
Use of Word Optional: Many people will not understand what “optional” means. The use of this word and alternatives such as “not required” should be tested with diverse groups of likely eligible people.
Recommendation: Replace optional with “not required.” Use of Confusing, Interchangeable Words: In a number of places household and family and exchange and marketplace are used interchangeably. The latter is easier to address given that the preferred reference to the exchange is Health Insurance Marketplace. The former is trickier because the words household and family may be used in different contexts.
Recommendation: Replace all uses of exchange with Health Insurance Marketplace Recommendation: Provide pop-‐up explanations of what is needed or meant in each specific use of family and household.
Use of Alerts (pop-‐up explanations or warnings) and Help Text: We are pleased to know that technology tools will be used to facilitate the application process. In our comments, we refer to alerts as tools that are enabled by “hovering” over text or by an “automatic pop-‐ups” when someone clicks on a data entry field. On the other hand, “help text” is something (i.e. an icon or ?) the user clicks for further information. The primary delineation is that alerts/pop-‐ups occur when the user is about to enter information into a field. Help text
icons or question marks are clicked when a user wants additional information at certain point in the application. Given that alerts and help text are critically important to successfully self-‐navigation of the application, we request an opportunity to review proposed text and messages and provide feedback. Additionally, it is imperative that alerts and help text language be tested with diverse groups of likely eligible people. General Comments & Concerns
Screen first for Medicaid – We would expect that the single, streamlined application for all insurance affordability programs would treat the programs equally, yet the application is generally seems more focused on collecting information to determine APTC eligibility than Medicaid. Since individuals eligible for Medicaid or CHIP are not eligible for APTCs, it is important to first screen for Medicaid or CHIP eligibility. However, the sequencing of this application puts much emphasis on collecting information regarding tax-‐filers and eligibility for APTCs to construct both the MAGI and APTC household sizes simultaneously. We would recommend that HHS consider an alternative that builds a straightforward assessment of Medicaid eligibility without unnecessary questions related to tax filings and future income. Further recommendations are detailed below. Insert Privacy Notification Prior to Account Set-‐Up: Before data is entered or an account set-‐up, the online application should provide detailed information about the privacy of data and how information will be used.
Recommendation: Before asking someone to set up an account, display detailed data about why information is needed and how it will be used in an active voice. Provide reassuring messages for immigrant and mixed status families.
As currently phrased, the privacy statement attests that the household contact has consent from all people listed on the application allow their information to be retrieved from data sources.
Recommendation: It is important to be specific about what information will be retrieved, from what data sources and how it will be used.
Account set-‐up and Authentication: We appreciate that recommended NIST 800-‐530 standards for security of government information technology systems protect access to information housed in federal databases. Conduct authentication only after the applicant affirms that they wish to apply for themselves and/or other family members.
Recommendation: Display an alert that when the person clicks to get started, what is going on behind the scenes to authenticate who they are.
We are concerned that potentially eligible applicants who are unable to provide an SSN that is required for account set-‐up will be locked out of an electronic option for applying.
Recommendation: Provide an electronic path for individuals and families to complete and submit an electronic application that does not require an account set-‐up but allows the applicant to start, save and return to an application. We recognize
that in these circumstances, applicants will not be able to take advantage of real-‐time verification of eligibility. However, we are concerned that locking these individuals and families out of the online application process will be administratively inefficient and result in eligible people slipping through the cracks because they misinterpret the inability to set up an account as ineligibility.
Additionally, we believe that it will be very confusing to set up an account that will be used going forward in the exchange but not in Medicaid. Additional thought needs to go into communicating with consumers what the account is and how it be used. If all members of the family are found Medicaid eligible, consumers should have the option to the delete the account if they have to go through a process of setting up a different account in Medicaid. If some members are eligible for Medicaid and some for the exchange, consumers will needed to be educated about why they will need to have two online accounts. Getting Started Contact Information: Clarify that the household contact should be an adult member of the family and not a friend or relative who is assisting with the application.
Recommendation: Provide help text when someone starts to enter the household contact information such as: “We need one adult member in the family to be the contact person for your application. We will contact this person if we have any questions and to provide information about your eligibility. If this is not you, please tell us who should be the contact person. We will ask you later if you would also given a trusted friend, relative or partner permission to talk to us about this application with us. However, you should not enter that person’s information here.”
No Home Address – We appreciate that the application recognizes that an applicant might be homeless, however we believe further guidance needs to be provided when requiring a mailing address.
Recommendation: Please provide the address of a trusted friend or relative, or organization (such as a homeless shelter or general delivery post-‐office) that agrees to receive mail on your behalf.
Preferred Language – We are pleased that the application asks for both preferred spoken and written language. It would be helpful to explain why this is being asked, how it will be used and why is helpful to collect this information.
Recommendation: Provide help text at the preferred language fields such as: “We ask for your language so we can help you apply for coverage. This information is confidential and will not be used to determine if you get health insurance. You do not have to provide your language to complete this application.
Method of Contact – It is not clear whether this question establishes the preferred method of contact just for follow-‐up on the application or carries forward on an ongoing basis. If this is how the applicant will receive communications and notices on an on-‐going basis, it is important to state this clearly. However, there will confusion for families who are found eligible for Medicaid and will not be using the same account for managing their insurance
going forward. Recommendation: Clarify if this is how only follow-‐up communication on the application will be received or whether it sets up preferences that carries over to a permanent exchange account where enrollees manage their enrollment and other personal information.
Text charges – When someone selects receipt of notices via text message, make sure they are alerted that receiving text messages could be subject to phone charges. Changing Preferences – Be clear that these preferences can be changed at any time and how they can be changed. Authorized Representative We have the following recommendations for this section:
Recommendation: Add relative to the examples of who might serve as an authorized representation. Recommendation: Ask if any renewal notices should also be sent to the authorized representative. Even if selecting, notices should also be sent to the enrollee. Recommendation: Include language that tells the applicant that they can change or remove their authorized representative at any time and how they would do so. Recommendation: Embed an alert that provides additional information when and what documents may be needed to establish the legal reason for authorizing a representative. Also include a dropdown list of acceptable documents that can be submitted as proof.
Help Paying for Coverage Who needs health insurance: The first question asks, who are you apply for health insurance and health benefits for. We think the use of these two terms is confusing.
Recommendation: Change the first question to “Tell us who wants to get health insurance.”
Do you want to find out if you/your family can get help paying for health insurance: It is critically important to explain what kind of help is available. As noted in comments on the paper application, give several family examples, ranging from a single person to a family of three or four is minimally needed to demonstrate the higher levels of income that can still qualify for lower premiums and potentially out-‐of-‐pocket costs. Income Screener We commend the inclusion of a screener that may help someone who has made a pre-‐determination that they are not eligible to look again. If you provide realistic examples as suggestion above, hopefully fewer people will hastily select “no.” It will also be important to inform people at various key times they can go back apply for financial assistance (this will be particularly important when they are looking at plans and prices.)
We are pleased to know that screening will include a buffer to account for pre-‐tax deductions. At 400 percent of the poverty level, families could have significant childcare, retirement or other deductions that reduce their gross income for eligibility purposes. We suggest additional wording at B.2.b as follows:
Recommendation: Insert “be denied or” before ay higher costs for pre-‐existing conditions.
Tell Us How Many People are Applying This section is only displayed if the household contact indicates there are other family members who want insurance. It is not clear why the household contact needs to provide a “count” of people in the household who want insurance, including himself if applying. The system should be able to count the number of people who are entered and redisplay them to confirm the list is accurate.
Recommendation: Start by reconfirming that household contact is or is not asking for health insurance by saying, “You have told us that you DO/DO NOT want coverage AND/BUT other family or household members do. Next please tell us the names and date of births of the people who need health insurance.” After entering one person, the prompt can be to enter another person or click “I am done” or “no more people to enter.” In this section, it is important to give clear instructions on what is meant by someone in the family vs. household and to reiterate that although other tax dependents must be listed on the application, they will have to file their own application to get health insurance.
Family and Household This section is extremely difficult to follow the logic and assess the ease of use and accuracy for complex family situations. We are concerned that there are some discrepancies in the skip patterns and next steps and recommend that HHS do further testing of complex families. We also urge HHS to provide an opportunity for stakeholders to be able to review and comment on a working version of the application. Given the difficulty in following the flow of the skip patterns, the following may not be a complete list of areas that need attention. Question A3 – Need an alert that married couple must file jointly to receive APTCs, but filing is not required for Medicaid. Questions A11 may be particularly worrisome to some applicants when asked to whether someone else intends to file taxes in a future year. Question A13 should specify that all tax dependents whether they live with the tax filer or not should be included here. Questions A20 and A21 could be confusing. However, given that it is difficult to follow the
flow of this information, we believe it is critically important that stakeholders be given an opportunity to see a working version of the application and make further comment. At first mention of filing taxes – Provide reassuring language that not everyone who can get help is required to file taxes. Clarify taxes for coverage year are filed in the following year (Question A1). Household Changes for Upcoming Tax Year: Question 28 is trying to see if the household size will change in the coverage year. It will be more accurate to probe with specific questions and important for HHS to determine what things it may prompt based on information already entered. For example, how does the system deal with knowledge that a child will turn 19 in the tax year or that there is a pregnant woman on the application? Other questions could be asked such as “are you planning to get married next year; will someone be moving out of the household? Asking these questions should be focused on determining what the household size might be for both Medicaid and tax filing families. Ultimately, it would be helpful for HHS to provide a guide or details on the system logic to determining the different household sizes for Medicaid vs. APTCs. Examine Possibility of Screening for Medicaid First. Even if you have to establish whether the household contact will file taxes, is there a streamlined way to get at the Medicaid household first. In our top priority issue comments, we provide a detailed outline of questions that may fast track the determination of the MAGI-‐Medicaid household size. Given time constraints, we were not able to thoroughly test the logic and note that there may be other paths for expediting the determination of this key element in order to screen for Medicaid/CHIP first. From this expedited section, the application would continue to gather personal information and citizenship/immigration status, followed by current income to arrive a MAGI-‐Medicaid assessment or determination. Further information needed for APTCs after that point would not be needed for eligible individuals. Expedited APTC Assessment for Single Adults With Tax Data. Our recommendation for screening the MAGI-‐Medicaid household size above will also help the application fast track a single person and married couple without children where tax data is well above the MAGI-‐Medicaid cutoff. These applications could then follow the route of the expedited income determination for APTCs. Keep in mind the buffer for determining APTCs must be sufficient to account for all pre-‐tax contributions, which may be substantial. Personal Information SSN Alerts should clearly note how SSNs are used and who needs to provide. We recommend dropping “other information” and specify citizenship and participation in other health coverage programs. Also delete the note about the SSN helping with enrolling in a health plan, which adds no real value to this section. Race and Ethnicity (move to Personal Information Section) – We strongly recommend that race and ethnicity be asked and encouraged for all persons listed on the application,
whether applying or not. It will be helpful to include pop-‐up alerts of non-‐discrimination, does not impact eligibility but can be helpful in efforts to improve health equity for everyone. IOM Standards should be used to collect race and ethnicity data. These recommendations should apply to approval for alternative applications. Preferred Written and Spoken Language – It is critically important to ask for preferred written and spoke language for all applicants. This information should be shared with health plans so they can accommodate language needs of enrollees. Citizenship and Immigration Status Naturalized Citizens – Add “I do not know.” Not all naturalized citizens will be able to access documents that were issued at the time of naturalization, and rely on passports for proof of citizenship. Ultimately, these individuals may need to provide passports as proof of citizenship if passport information will not accessed electronically by the federal data services hub. Eligible Immigration Status – The term could be confused with a “status that is eligible for immigration’ but is intended to be an “immigration status eligible for health insurance.” We recommend that the application clearly articulate this. This question should be accompanied by an alert that it is not necessary to answer this question for non-‐applicants and this will not impact the eligibility of others. Question 9 – This question can be skipped in states that have elected to cover lawfully-‐residing immigrant children and/or pregnant women, who are therefore exempt from 5-‐year bar. Other Addresses Homelessness needs to be option under Question 2 in this section. Help Text should be used to provide guidance for truly transient situations (families that rotate among residencies). Dependents Away at School – It may be helpful to explain what families need to know about dependent children away at school. We recommend moving related questions under special circumstances to this section.
Special Circumstances Questions 1 and 2: Disability Screening – There is insufficient detail in the question about daily living activities to adequately screen for people who may qualify for other categories of Medicaid but do not have a confirmed disability. Instead of question 2, the application might present a statement such as “Individuals with special health care needs or who have physical, mental or emotional limitations or challenges may qualify for more benefits at a lower cost. Click here to determine if anyone on this application may qualify.” Then a pop-‐up
sheet could appear that would ask more questions such as those used by the American Community Survey to collect data on disability status and other child-‐specific questions that we also suggested for the paper application.
Recommendation: Retain the question on whether the person has a disability. Then delete the question about daily activities and insert a new statement as noted in italics above. At that point a pop-‐up supplemental form appears with this information. You or a family member may be eligible for more benefits and lower costs if you answer yes to any of the questions below.
1. Are you or is anyone on this application deaf, or have serious difficulty hearing? Yes ____ No ____ If yes, who _____________________________________________________?
2. Do you or does anyone on this application have serious difficulty seeing even when wearing glasses? Yes ____ No ____ If yes, who _____________________________________________________?
3. Because of a physical, mental, or emotional condition, do you or does anyone on
this application have serious difficulty concentrating, remembering, or making decisions? Yes ____ No ____ If yes, who _____________________________________________________?
4. Do you or does anyone on this application have serious difficulty walking or climbing stairs? Yes ____ No ____ If yes, who _____________________________________________________?
5. Do you or does anyone on this application else have difficulty dressing or bathing? Yes ____ No ____ If yes, who _____________________________________________________?
6. Because of a physical, mental, or emotional condition, do you or does anyone on this application have difficulty doing errands alone such as visiting a doctor's office or shopping? Yes ____ No ____ If yes, who _____________________________________________________?
7. Is any child on this application limited or prevented in any way in his or her ability to do the things most children of the same age can do? Yes ____ No ____ If yes, who _____________________________________________________?
8. Does this child need or use more medical care, mental health or educational services than is usual for most children of the same age? Yes ____ No ____ If yes, who _____________________________________________________?
9. Do any of your children have a medical condition that left untreated would result in the death or serious physical injury of the child?
10. Yes ____ No ____ If yes, who _____________________________________________________?
The disability page should include additional information on how to get more information or apply for non-‐MAGI Medicaid. It could also include a check box if the applicant would like any persons to be reviewed for eligibility under other categories.
Questions 3 and 4: Students Away at School – We suggest incorporating this question in the “other address” section, which is when parents would be thinking about their dependents away at school. Question 7 and 8: Pregnancy – If you take our recommendation to do an expedited Medicaid/CHIP screen first, it will be helpful to move these questions to that section. Question 9: Foster Care – Need pop-‐up text explaining why this information is needed. Suggested language: “If someone under the age of 26 is applying for health insurance was once in the foster care system, that person may be eligible for more benefits at lower costs.” Expedited Income Challenge Question – Given the vagueness of how this works, it is unclear whether will be problematic. Screening for APTCs – We understand that an “income buffer” will be used to ensure that no one who is Medicaid/CHIP eligible is screened as APTC eligible. It would be helpful to understand how HHS arrives at determining the “buffer” amount. Furthermore, if any one member of the family including a child that is eligible for Medicaid or CHIP, the application will not do an APTC expedited income determination. Projecting Annual Income for next Year – We strongly encourage the use of a pop-‐up worksheet to help someone projected annual income. This worksheet would use logic and questioning similar to what is in the current monthly income section, allowing people to enter data any number of ways. Additionally, this section must take into consideration pre-‐tax contributions and deductions from income such as alimony. Those questions could also be asked in specifically, giving people the option to enter the data based on weekly, monthly or annual contributions. The worksheet should be a smart form that calculates the projected income and enters into the projected annual income field. To the extent that this worksheet data can prepopulate the current monthly income section, it is recommended. Current Monthly Income Definition of “Income” – It would be helpful to include a pop-‐up that defines income as “money you make from jobs and wages, as well as other sources of money paid to you such as social security payments.” Additionally, specific questions or sources of income should be accompanied by help text or pop-‐ups defining each source. Separate Current and One-‐time Income Questions – We appreciate that the application
provides prompts and drop downs for entering income and provides multiple frequencies. Recommendation: Separate current and one-‐time income questions.
Question 5: Self-‐Employment Income – Need to clarify that only “business” expenses should be deducted. Income Frequency – Questions 10, 11, 12, 13 and 15 should have option for reporting income that is not received on a regular basis.
Recommendation: Add varies or seasonal to the options of payment frequency with ability to provide a descriptive answer.
Question 15: Veterans Payments – needs clarification, disability income is not counted but retirement is. Question 16 and 17: Deductions – These questions will be difficult to answer, particularly as it relates to “other” deductions. Additional pre-‐tax contributions to childcare, health insurance premiums, transportation benefits and certain retirement plans should be specifically itemized in this section. Additionally, qualifying deductions for alimony, student loan interest and other items should be included. Discrepancies The notes to reviewers indicate that this section will appear if the total attested income is under the MAGI-‐Medicaid cutoff but electronic data income it is above. Likewise, it is critically important and strongly recommended that this section be displayed when consumer attests income in APTC range but electronic sources show Medicaid/CHIP eligibility. Overtime, and other common discrepancies should be reported; we recommend that the specific discrepancies in this section be expanded.
Health Coverage Access (APTC eligible) This section needs explanatory text why this information is needed. Additionally “offer” of insurance need to be defined through pop-‐up text. Question 4 and 5 – The application should emphasize the difference between eligible for and enrolled in. Please also see our comments regarding COBRA on the paper application. The online application with the ability to provide pop-‐up information can be more explicit about when someone might be able to drop COBRA in order to get lower cost coverage (if not better benefits) if they otherwise qualify for APTCs. Employer Health Coverage Information
Please see our comments on the paper application that apply to requiring that these sections be completed. We prefer a simplified process that asks about access to employer-‐based coverage and then requires an administrative process for verification purposes. Questions 3 and 4 – It is not clear at all what is important for someone to report. For example, if a co-‐pay is going to from $5 to $10, does the applicant need to report this? We suggest deleting this question. Alternatively, there needs better explanation of the kind of “changes” that the application needs to know. These questions could be combined rather than starting with a yes, no question. Minimally, “I do not know” needs to be added to the possible responses. Questions 5 and 6 – We are particularly concerned about asking for the name of the lowest “self-‐only” plan that meets “minimum value standard” set by the Affordable Care Act. The terms in quotation marks have no common meaning and cannot be easily explained in order to secure the correct information. Help text here must be specific and indicate that the applicant can submit the application even if they do not have this information. Question 7 – This question needs to be specific in clarifying how much the individual would pay to enroll the “employee” only. Question 9 – Whether the individual believes this coverage to be affordable has no relevance to eligibility. This question should be deleted. Tax Filer and Other Information We recommend rewording question in text regarding why it is helpful to provide an SSN. “You do not have to provide a SSN but if you do, it may help us get a better idea of how much financial assistance you can get in paying for health insurance coverage for the people who are applying.” Medicaid & CHIP Specific Questions We are hopeful that the final regulations will eliminate CHIP waiting periods and that related questions can be eliminated.
Sign and Submit Statement 2: Medical support – Repeat reassuring language and provide information on how to tell agency of concerns. Statement 4: Renewal – This statement is particularly worrisome. We recommend moving this information to the time when the individual enrolls in a plan. In particular, the text regarding the Marketplace will continue eligibility “at the level indicated by the data” needs work. Additionally, option 4.a.v. should be changed to “Do not automatically renew my coverage, please contact me when it is time to renew.”
Statement 5: Reporting Changes – It would be helpful to specify the kind of changes (only those that impact eligibility) that need to be reported. For example, “I need to tell the program if I move, have a change in income, get married, give birth or adopt a baby.” Additionally, the notices will need to clarify differences in what is expected to be report to Medicaid vs. the exchange. Statement 6: Penalty of Perjury – We strongly recommend that the language used in the paper application should be used here. “I have provided true answers to all the questions on this form to the best of my knowledge. I know that they may be a penalty if I’m not truthful.” Required Documents If documents are required and not uploaded, we recommend that a cover sheet, account number, bar graph or other mechanism be used to facilitate the matching up of documents that may be mailed or faxed in. Eligibility Results We strongly urge that Item 3 regarding withdrawing the Medicaid application be removed. Individuals who are eligible for Medicaid are not eligible for APTCs.