Consumer Consent Forms - From the Desk of Allison Johnson
(Posted on 10/30/23)
Hi everyone!
I am back with yet another notice that you need to be aware of - Consumer Consent Forms. CMS recently confirmed that agents and brokers assisting individuals in enrolling in any marketplace plans, including state-based exchanges, need to comply with this requirement. This is true regardless of subsidy eligibility. I linked to the FAQs below in case you want to read them. Both NABIP and CMS have provided model notices that you can use and I have linked to those as well. Horizon’s BOR template also contains the consent language. A few things I want to point out about this requirement-
1- You need to provide your privacy policy and the consent form before beginning to help them apply.
2- Be sure to review the application with them and read all of the attestations that pop up prior to final submission. This is especially important because the information they provide regarding their income affects whether they receive a subsidy and how much they receive.
3- You need to keep this form on file for 10 years. Make sure you have it someplace secure, just in case!
4- You are, as always, responsible for keeping their PHI and PII secure. In a world where a new huge hacking incident seems to happen once a week, it’s important to make sure that you have good security protocols in place to protect yourself and your clients.
Get Covered added a section to their training about the consent forms, so you’ll see that when you are completing it for the 2024 season. Don’t forget to complete your training before Open Enrollment starts on November 1. If you are planning on selling Horizon on or off the exchange, you’ll need to register with Miramar as well.
As always, we are here to help and answer any questions you may have. Add this to your checklist and let’s have a great 4th quarter!
I am back with yet another notice that you need to be aware of - Consumer Consent Forms. CMS recently confirmed that agents and brokers assisting individuals in enrolling in any marketplace plans, including state-based exchanges, need to comply with this requirement. This is true regardless of subsidy eligibility. I linked to the FAQs below in case you want to read them. Both NABIP and CMS have provided model notices that you can use and I have linked to those as well. Horizon’s BOR template also contains the consent language. A few things I want to point out about this requirement-
1- You need to provide your privacy policy and the consent form before beginning to help them apply.
2- Be sure to review the application with them and read all of the attestations that pop up prior to final submission. This is especially important because the information they provide regarding their income affects whether they receive a subsidy and how much they receive.
3- You need to keep this form on file for 10 years. Make sure you have it someplace secure, just in case!
4- You are, as always, responsible for keeping their PHI and PII secure. In a world where a new huge hacking incident seems to happen once a week, it’s important to make sure that you have good security protocols in place to protect yourself and your clients.
Get Covered added a section to their training about the consent forms, so you’ll see that when you are completing it for the 2024 season. Don’t forget to complete your training before Open Enrollment starts on November 1. If you are planning on selling Horizon on or off the exchange, you’ll need to register with Miramar as well.
As always, we are here to help and answer any questions you may have. Add this to your checklist and let’s have a great 4th quarter!