CMS Now Requires Agencies to Certify

Ann H

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Please bear with me if this has been posted elsewhere. I don't have time to go through those massive threads about CMS registration to see.

I was just alerted by a local GA that CMS made it clear in their last documents that an AGENCY must also certify for the FFM. Previously it was thought that only agents must certify. Following is the quote from the CMS document, and the link to it:

A3: If an entity has a corporate National Producer Number (NPN), that NPN should be registered with the Federally-facilitated Marketplaces (FFM), based on the steps described below. In addition, each individual agent should register with the FFM using their individual NPN. Prior to assisting consumers, each agent or broker needs to have completed the FFM training and registration process.
http://origin.library.constantcontac...+9-19-2013.pdf
 
Awesome! Good thing to learn day before, are we saying I need to do all the testing now for the agency as well?
It looks like my link above isn't working. Let's try that again http://origin.library.constantconta...2875256-177/CMS+Operational+FAQ+9-19-2013.pdf

It looks like we have to do training for the agency, but Part 2 registering just for the NPN that you are going to do the majority of business through. Here is the quote from the document:

For Part I of the FFM registration process:
• It is vital that you enter your NPN correctly in your MLN profile. Do not add any leading zeroes.
• If you have multiple NPNs—for example, if you are an agent/broker who is licensed as an individual and you also own a business entity that has a separate NPN—you must create a separate MLN account for each NPN and you must complete the required training for each MLN account/NPN.
• For business entities that wish to register and participate in the FFM, the business entity must select an authorized official to complete the required training on MLN using the NPN of the corporate entity. For example, the business entity may select the president or the CEO to complete the MLN training, using the business entity's NPN. (Remember, however—in addition to the business entity registering, each individual agent should register with the FFM using their individual NPN. Prior to assisting consumers, each agent or broker needs to have completed the FFM training and registration process.)
• Remember, all compensation arrangements must be made directly with the issuers or web-brokers with whom you are affiliated.

For Part II of the FFM registration process:
• It is vital that you enter your NPN and your MLN user ID correctly in Part II.Do not add any leading zeroes to your NPN.
• If you have multiple NPNs: During Part II of the registration process, you should enter the NPN that you anticipate will be included on the majority of the QHP enrollment applications you assist with. In other words, enter the NPN under which you expect to conduct the majority of your FFM business. You will need to enter the MLN user ID that is associated with that NPN. You will only complete Part II identity verification for one of your NPNs; you will not complete identity verification for each of your NPNs.
• In the case of business entities, the authorized official who completed the MLN training with the NPN of the corporate entity is the individual who must complete Part II of the registration process.When completing Part II, the authorized official should again enter the NPN of the corporate entity, and the MLN user ID that is associated with that account.
 
This message is intended for agents and brokers who are registering for the Federally-facilitated Marketplaces (FFM)--including State Partnership Marketplaces (SPM).

9-30-2013

We have a number of very important announcements today:

1. We are pleased to advise that the Federally-facilitated Marketplaces (FFM) and State Partnership Marketplaces (SPM) will open for business on Tuesday, October 1! On Tuesday, the side-by-side model, or "Marketplace pathway" will be available for FFM-registered agents and brokers to assist consumers. Using this pathway, an agent/broker will be able to assist a consumer as the consumer completes the application process on the FFM or SPM website.

The agent/broker should work with the consumer to make sure that the consumer enters the agent's/broker's identifying information, including National Producer Number (NPN), so that the FFM can associate the transaction with the agent/broker so that an issuer may facilitate compensation. When the consumer is logged in to the healthcare.gov page, the consumer will be shown a screen labeled, "Help applying for coverage." On this screen, it is vital that the consumer enters the agent's/broker's name, NPN, and FFM User ID (if the agent/broker has an FFM User ID). Accurate entry of the agent's/broker's information on that screen will enable an issuer to facilitate compensation.

Please refer to our May 2013 guidance that describes the two pathways which agents/brokers may use. (See page 3: http://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/agent-broker-5-1-2013.pdf) We will continue to keep you apprised via this listserve about the status of the Issuer-based pathway (or "direct enrollment" model).


2. If you would like to see which Qualified Health Plans (QHPs) are available in the FFM in your state, you will be able to view them on 10/1 via the following links. (Please note that these links will not be active until Tuesday, 10/1/13.)

https://www.healthcare.gov/health-plan-information/ (Individual Health Plans)
https://www.healthcare.gov/dental-plan-information/ (Individual Dental Plans)
https://www.healthcare.gov/shop-health-plan-information/ (SHOP Health Plans)
https://www.healthcare.gov/shop-dental-plan-information/ (SHOP Dental Plans)


3. Agents/brokers are reminded that in order to complete registration for the individual market, they must complete identity proofing process occurs on the CMS Enterprise Portal. To set up an FFM account and complete identity proofing, visit the CMS Enterprise Portal: https://portal.cms.gov/
For agents/brokers who are mid-registration, please be reminded of these useful links that should be useful to you during that process:
http://www.cms.gov/CCIIO/Programs-and-Initiatives/Health-Insurance-Marketplaces/Downloads/agent-broker-reg-faq-9-23-2013.pdf

http://www.cms.gov/CCIIO/Programs-and-Initiatives/Health-Insurance-Marketplaces/Downloads/agent-broker-registration-webinar.pdf

4. Lastly, for questions related to the FFM registration process, agents/brokers may submit email inquiries to: FFMProducer-AssisterHelpDesk@cms.hhs.gov
 
Ok, this is the problem with this:

I am a one-person agency. I first certified using my name and NPN. Well and good. Then when I read the document and posted it last week on the forums no one could tell me how to re-register as an agency.

I went and took the test for my one-man agency but when I got to the registration and ID proofing for my agency, since I am the only agent, the system told me no can do as your already registered as your original ID.

Sent an email to the FFM-help desk on 9/24 which they received no 9/28 and still no answer on how to do this.

It seems that we dammed if we do and dammed if we don't. Frustrated: :mad:
 
Duaine,

I was able to re-test and verify identity with the agency NPN with no problem.

You were using a different NPN number correct (the agencies NPN#)?
 
You have to use different User ID's also - one for your agency and one for the agent.
 
For anyone who's completed this, what did you put in for the birthday? Because my agency is definitely not 18 years old yet.
 
You have to use different User ID's also - one for your agency and one for the agent.

I did use different ID's. One for myself and one for my agency. The problem is when you go to Verify your ID. Then the systems says that you've already been ID verified as you use you own name as an agent and as the principal of the agency.

Still can't figure out how to get around this?


For business entities that wish to register and participate in the FFM, the business entity must select an authorized official to complete the required training on MLN using the NPN of the corporate entity.

For example, the business entity may select the president or the CEO to complete the MLN training, using the business entity's NPN. (Remember, however—in addition to the business entity registering, each individual agent should register with the FFM using their individual NPN. Prior to assisting consumers, each agent or broker needs to have completed the FFM training and registration process.)

• Remember, all compensation arrangements must be made directly with the issuers or web-brokers with whom you are affiliated. :goofy:
 
Response from MI BCBS about this question.

We have received a response from Blues to your question. Below is their response:

I just spoke with public policy on this one.

We are not certain why this is being required but the legislation itself leaves the compensation work to the issuer. As long as the individual agent/broker NPN is on the enrollment transaction, that is what drives commission payment. The agency NPN will not be on the transaction. We are still doing some follow up work on this but our assumption at this point based on guidance is that commissions should not be impacted."
 
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