Standards for Navigators and Non-Navigator Assistance Personnel

VIA ELECTRONIC SUBMISSION

Centers for Medicare & Medicaid Services Department of Health & Human Services

P.O. Box 8010

Baltimore, MD 21244-1850

Re:
CMS-9955-P Standards for Navigators and Non-Navigator Assistance Personnel

Dear Sir/Madam:

The National Health Law Program (NHeLP) is a public interest law firm working to advance access to quality health care and protect the legal rights of low-income and underserved people. NHeLP provides technical support to direct legal services programs, community-based organizations, the private bar, providers and individuals who work to preserve a health care safety net for the millions of uninsured or underinsured low-income people. We are pleased to submit the following comments in response to the proposed rule issued on April 5, 2013 regarding standards for navigators and non-navigator personnel.

As an overarching comment, we recognize that three types of individuals may potentially provide information and enrollment assistance to consumers ? navigators, non- navigator assistance personnel, and certified application counselors (CACs). Throughout these comments, we use the general term ?assisters? to include all three types. When we wish to address comments to only one or two of the types, we will use the specific terminology.

We commend HHS on reiterating the requirement throughout the preamble that all assisters provide fair, accurate and impartial information. This is a critical protection to ensure consumers can rely on assisters without concern about an assisters? potential conflict of interest or values that may conflict with providing comprehensive information.

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