Consumer Communications— Eligibility Determination Notice May 02, 2013 COHBE Merged Advisory Group Meeting 1
Scope A notice, as defined by COHBE is: Formal written letter or e-mail correspondence to COHBE’s customers to inform them of a consumer or Exchange initiated action. Notices are intended for the consumer’s record keeping purposes and does NOT include all messaging that occurs on the user interface. COHBE users will be able to see all notifications they have received from COHBE through their COHBE user account. 2
Scope COHBE Consumer Communication “Buckets” Account Creation and Maintenance Broker Certification/ Client Authorization Assistance Site / Health Coverage Eligibility / Verifications Guide Certification Enrollment Mid-Year Changes SHOP Billing Disenrollment Annual Eligibility Appeals Redeterminations Not included: applications, notices from issuers to consumers, notices from COHBE to issuers. 3
Eligibility Determination Notice Information communicated by COHBE related to a determination or re- determination of eligibility for the advance premium tax credit and cost- sharing reductions. Requirements (ACA Sections, 1411, 1413 & 2201, 45 CFR Part 155) •Must provide the determination •Citation to specific regulation •Explanation of appeal rights •Delivery method can be either electronic or post mail Coordination of Insurance Affordability Program Eligibility Notices •In accordance with the Jan. 2013 NPRM, COHBE and HCPF will coordinate eligibility determination notices •In 2015 the proposed federal requirement is to ensure a single communication that delivers an eligibility determination across all IAPs 4
Trigger A user has submitted the Single Streamlined Application (SSAp) for an Insurance Affordability Program (IAP) either during annual enrollment or through reporting a life change. The rules engine has been run and an eligibility determination has been made (data verifications may or may not be pending). User has requested an Account creation Applicant Eligibility results IAP eligibility or Log-In information is notice is sent to determination & sent to the rules applicant based on completes the SSAp engine for an IAP communication determination preference (email/paper letter) Potential Actors: • Individual (self service or with a Coverage Guide) • Back Office/Service Rep/Broker (on behalf of) 5
Approach Holistic Review Readability & Accessibility Testing Legal & Privacy Review Incorporate branding/messaging Subject Matter Expert Review Identify Triggers/Data Elements/Rough Draft Note : English language notices will be translated into Spanish after the Holistic Review. 6
Next Steps for Go Live Notices December 2012-May 2013 Collaboration − Continue to gather lessons learned from our federal partners and their health literacy consultants (also awaiting final guidance) − Continue to work collaboratively with HCPF on coordinating eligibility notices for 2014 benefit year and the roadmap for combined notices in 2015 − Gather stakeholder feedback April-May 2013 Readability & Accessibility Testing − Ensure our notices meet readability and accessibility requirements − User testing May-June 2013 Holistic Review − Approve notices for system testing and Go Live 7
Developing Accessible Health Materials Writing is more art than science. Our goal is to make the material as readable as possible. Three Steps to Creating Quality Materials 1.Develop Plain Language Logical Organization Clear Layout and Design Full Accessibility 2.Assess Reading Level Analysis Accessibility Review User Review 3.Rewrite 8
Readability & Accessibility Language Layout and Design Everyday words vs. technical White Space terminology Use of Graphics Technical references are Use of Labels explained Conversational style Accessibility Active voice, with short sentences Structured Meaningful and contextual Organization alternative text Order Labeled Form Fields Grouping Proper markup and use of Tables Headings 9
Status − Completed review, assessment and revision of an initial draft of the Individual Eligibility Notice provided by COHBE Focus on readability Partial accessibility work complete Individual Notice 8 th -9 th Grade Level Some Technical Terms Remain Headings in Place Graphics Labeled Open Enrollment Notice 5th-6th Grade Level 10
Next Steps − Conduct User Testing with Target Population − Garner feedback from Constituencies − Perform Complete Accessibility Review (MS Word and PDF formats) Automated analysis of accessibility errors Expert (manual) review of accessibility Testing with Screen Readers (Jaws, NVDA, Window Eyes) Testing with individuals who use Screen Readers − Incorporate findings into the revision process − Provide final results to COHBE for holistic review 11
Feedback − Comments on the individual eligibility determination notice: Formatting: Bold and/or highlight, “If you do not report changes….” Bold/highlight the last paragraph, “If your income on your tax return is lower….” Wording: “Earliest effective date is confusing” Eligibility “for up to $XX” amount, can you provide the exact amount” “I would suggest referencing the reduced copays & deductibles only if someone gets approved for them” Include COHBE url in the first line of the Appeal section “Clarify that out of pocket costs include deductibles, co-payments and coinsurance for medical services if prescription is excluded from the out of pocket maximum” 12
Feedback What we are interested in learning from you! Concise vs. Comprehensive . Are their sections of the notice that aren’t needed? We are trying to balance providing the right information vs. providing too much information. Clear understanding of the message. Are there sections/words of the notice that could be better developed or formatted for clarity? Message Placement . Any concerns or comments on message placement? General Comments. What do really like about the sample notice? What don’t you like? 13
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