Compliance with Marketplace Requirements: Considerations for Agents and Brokers

Transcription

1 Compliance with Marketplace Requirements: Considerations for Agents and Brokers May 24, 2018 Centers for Medicare & Medicaid Services (CMS) Center for Consumer Information & Insurance Oversight (CCIIO)

2 Disclaimer The information provided in this presentation is intended only as a general informal summary of technical legal standards. It is not intended to take the place of the statutes, regulations, and formal policy guidance that it is based upon. This presentation summarizes current policy and operations as of the date it was presented. Links to certain source documents have been provided for your reference. We encourage audience members to refer to the applicable statutes, regulations, and other interpretive materials for complete and current information about the requirements that apply to them. This document generally is not intended for use in the State-based Marketplaces (SBMs) that do not use HealthCare.gov for eligibility and enrollment. Please review the guidance on our Agents and Brokers Resources webpage ( and Marketplace.CMS.gov to learn more. Unless indicated otherwise, the general references to Marketplace in the presentation only includes Federally-facilitated Marketplaces (FFMs) and State-based Marketplaces on the Federal Platform (SBM-FPs). This communication was printed, published, or produced and disseminated at U.S. taxpayer expense. 1

3 Webinar Agenda Requirement to Obtain Consumer Consent Prior to Assistance Assisting Consumers Who Do Not Have an Address Assisting Consumers Who May Qualify for Medicare Coverage How to Report Potentially Fraudulent Activity Key Reminders and Resources Other Marketplace Updates Questions and Answers 2

4 Compliance with Marketplace Requirements: Considerations for Agents and Brokers Requirement to Obtain Consumer Consent Prior to Assistance 3

5 Obtain Consent Prior to Assisting with Marketplace Transactions You must obtain the consent of an individual, employer, or employee prior to helping them apply for financial help and/or enrolling in a Marketplace qualified health plan (QHP).* CMS does not prescribe a standard format or process for obtaining the consent or for maintaining its record, so you have flexibility to determine how you will meet the consent requirement. While CMS does not provide a form, or specify that a form has to be signed, you can use a Broker of Record form from an issuer or state Department of Insurance to satisfy this requirement. Additionally, you may obtain consent verbally (such as over the phone), electronically (such as via ), or in person. * Note: This requirement is different from and in addition to the requirement that consumers must also provide you their informed consent for any use or disclosure of their personally identifiable information (PII) outside the scope of the Privacy Notice Statement and the Authorized Functions for PII in the Marketplace. 4

6 Best Practices to Record Consumer Consent At a minimum, the consent should acknowledge that you have informed the individual, employer, or employee of the functions and responsibilities that apply to your role in the Marketplace. The record of the consent should include the following: The individual s, employer s, or employee s name; The date the consent was given; and The name of the agent(s) or broker(s) to whom consent was given. Note that this could include additional names of agents or brokers if the consenter authorized multiple agents or brokers within the same organization. If you are providing assistance verbally (such as over the phone), you may obtain consent by reading a script that contains, at a minimum, the required elements summarized above, and should record in writing that the required consent was obtained. Obtaining a signed Broker of Record form from an issuer or state Department of Insurance satisfies the consumer consent requirement. 5

7 Expiration and Retention of Consumer Consent CMS does not specify an automatic expiration date for the consent because it could become burdensome for anyone consistently seeking services from the same agent or broker to have to repeatedly renew the consent. Therefore, the consent may last indefinitely, unless the individual, employer, or employee revokes it. Consent documents must be appropriately secured and retained for 10 years. Please Note: This consent does not authorize you to speak with the Marketplace Call Center regarding an application or consumer s question. Consumers must provide a separate authorization to the Marketplace Call Center to allow you to call and access their account information on their behalf. The Call Center authorization can be valid for one call or up to 365 days. If you contact the Marketplace Call Center on behalf of a consumer, the consumer should be available on the line to provide authorization. 6

8 Scenario: Obtaining Consumer Consent Your colleague Beth is taking some time away from your organization during the Marketplace Open Enrollment period (OEP), and you have offered to help meet the needs of her established clients. Before providing assistance, you inform each client of your role in the Marketplace and your functions and responsibilities. What additional steps can you take to ensure that you are compliant with the requirement to obtain consumer consent? A. Include your name and National Producer Number (NPN) on each Marketplace application. B. Record in a spreadsheet the name of each client and the date that you obtained consent. C. Complete a Broker of Record form from an issuer or your state Department of Insurance D. Verify that Beth s records include a record of consumer consent from a prior year. 7

9 Scenario: Obtaining Consumer Consent Answer Your colleague Beth is taking some time away from your organization during the Marketplace OEP, and you have offered to help meet the needs of her established clients. Before providing assistance, you inform each client of your role in the Marketplace and your functions and responsibilities. What additional steps can you take to ensure that you are compliant with the requirement to obtain consumer consent? A. Include your name and NPN on each Marketplace application. B. Record in a spreadsheet the name of each client and the date that you obtained consent. C. Complete a Broker of Record form from an issuer or your state Department of Insurance for each client. D. Verify that Beth s records include a record of consumer consent from a prior year. 8

10 Scenario: Obtaining Consumer Consent Answer (Continued) You should keep a record of when the consumer provided you with consent. This record should contain at a minimum the consumer s name, the date consent was provided, and name of the agent or broker to whom the consent was given. CMS does not prescribe a standard format or process for maintaining this record, so you have flexibility to use a system of record that works for you. Each agent or broker working with a consumer must obtain and record the consumer s consent, even if all are working for the same organization. If your name is included in the record of consumer consent Beth obtained in a prior year, you do not need to obtain an additional record of consent. Consent documents must be appropriately secured and retained for 10 years. 9

11 Compliance with Marketplace Requirements: Considerations for Agents and Brokers Assisting Consumers Who Do Not Have an Address 10

12 What If a Consumer Does Not Have an Address? Consumers can enroll in a Marketplace QHP either online with a valid address, by using a paper application, or by calling the Marketplace Call Center. The Marketplace will ask each consumer to specify a preference to receive notices through either mail or . You need to check with your individual clients to confirm their preferred method of communication. You may assist consumers to set up an account for Marketplace enrollment, and may need to allot extra time for working with consumers to set up accounts with an service provider of their choice. 11

13 Do Not Enter Your Address on Consumer Accounts. Never enter your own agent or broker professional or company or mailing address on a consumer s application. You also should not create or use dummy addresses in place of the consumer s or mailing address. Consumer accounts should only have the consumer s (or his or her legally authorized representative s) and mailing addresses. Only consumer and mailing addresses should be entered on Marketplace applications. With a consumer s consent, the Marketplace sends important alerts and updates about coverage that may be missed if a consumer s address is not in the system. These updates are often tailored to a consumer s circumstances, so it is important that they are sent directly to consumers (or their authorized representatives). 12

14 Prohibition on Creating Consumer HealthCare.gov Accounts Only a consumer or his or her legally authorized representative may create a username and password for a HealthCare.gov account and should not share this information with third parties, including agents and brokers. You can assist the consumer in creating his or her account, but the consumer or a legally authorized representative must enter his or her own information into the application. You may not log in to HealthCare.gov on a consumer's behalf (i.e., using the consumer's HealthCare.gov account). 13

15 Scenario: Consumer Does Not Have An Address While assisting your new client Arlene with her Marketplace application, you discover that she does not have an active address. What steps can you take to help her apply for and enroll in Marketplace coverage? A. Use your professional address to create a HealthCare.gov account and complete her online application. B. Create and manage an address for Arlene s HealthCare.gov account and online application, and alert her when the Marketplace sends important communications. C. Help Arlene create a personal address she can use when creating a HealthCare.gov account and completing her application. D. Help Arlene complete her application by contacting the Marketplace Call Center or by mailing in a paper application. 14

16 Scenario: Consumer Does Not Have An Address Answer While assisting your new client Arlene, with her Marketplace application you discover that she does not have an active address. What steps can you take to help her apply for and enroll in Marketplace coverage? A. Use your professional address to create a HealthCare.gov account and complete her online application. B. Create and manage an address for Arlene s HealthCare.gov account and online application, and alert her when the Marketplace sends important communications. C. Help Arlene create a personal address to use when creating a HealthCare.gov account and completing her application. D. Help Arlene complete her application by contacting the Marketplace Call Center or by mailing in a paper application. 15

17 Scenario: Consumer Does Not Have An Address Answer (Continued) You are NOT permitted to enter your own professional or company or mailing address on a consumer s application. It is important that communications from the Marketplace go directly to consumers (or their authorized representatives). You should not have direct access to consumers HealthCare.gov accounts. You can help a consumer set up an address. Still, consumers can specify that they prefer to receive communications from the Marketplace by mail instead of through . Consumers always have the option to submit a paper Marketplace application or to call the Marketplace Call Center. Please Note: While you can help enroll a consumer in Marketplace coverage through a Direct Enrollment (DE) partner without an address, consumers who want to access their online Marketplace notices or make changes on HealthCare.gov instead of through a DE partner will need an address when creating their Marketplace account. 16

18 Compliance with Marketplace Requirements: Considerations for Agents and Brokers Assisting Consumers Who May Qualify for Medicare Coverage 17

19 Can Consumers Who Qualify for Medicare Enroll in Marketplace Coverage? It is against the law to knowingly sell or issue a Marketplace plan to a consumer who has Medicare coverage, if you know that the Marketplace plan will duplicate benefits the consumer is entitled to. This is true even if the consumer has only Medicare Part A or only Medicare Part B coverage. Generally, consumers with Medicare coverage should not be enrolled in Marketplace coverage that duplicates Medicare and those who are considered eligible for Medicare that is minimum essential coverage (MEC) are not eligible for a Marketplace plan with advance payments of the premium tax credit (APTC) or cost-sharing reductions.* Agents and brokers SHOULD ask their clients about their eligibility for Medicare coverage. Agents and brokers SHOULD NOT assist Medicare eligible consumers to enroll in Marketplace coverage that duplicates Medicare. The Anti-Duplication Provision of the Social Security Act states it is against the law for a person to sell or issue to a consumer who has Medicare coverage an individual market plan that the person knows duplicates the consumer s Medicare benefits. * Note: Medicare Parts A and C are considered MEC. Medicare Parts B and D are not considered MEC. 18

20 Assisting Consumers Who May Qualify for Medicare Coverage There are exceptions where consumers who are over age 65, may not be Medicareeligible, or may have missed their window for initial enrollment and need coverage until they can enroll in Medicare. The Anti-Duplication Provision also does not prohibit the sale of Marketplace coverage that does not duplicate Medicare benefits or the renewal of Marketplace coverage under the same policy or contract of insurance, which is determined using state insurance rules. For More Information See: Medicare and the Marketplace ( Nonrenewal of Coverage for Marketplace Consumers with Medicare ( 19

21 Scenario: Consumers May Qualify for Medicare Coverage Julien is 65 years old and is retiring soon from his job for the past 38 years in hotel housekeeping. His wife, Natalie, is 52 years old and is unemployed due to a disability. After Julien retires, he and Natalie (who is covered under his employer s group health plan) will no longer have health coverage. Julien calls you to ask whether he and Natalie are eligible for Marketplace coverage or government-sponsored coverage. What should you advise Julien and Natalie? A. They may both be eligible for Medicare since Julien is age 65 and Natalie is under age 65 with a disability. You point out that the Marketplace does not determine eligibility for the Medicare program. B. They should wait until several months after Julien's retirement to get their finances in order, and then follow up with you for assistance in seeking health coverage through the Marketplace. C. Julien and Natalie may be eligible to enroll in a Marketplace plan. You tell Julien that you can assist them with eligibility, plan selection, and enrollment. 20

22 Scenario: Consumers May Qualify for Medicare Coverage Answer Julien is 65 years old and is retiring soon from his job for the past 38 years in hotel housekeeping. His wife, Natalie, is 52 years old and is unemployed due to a disability. After Julien retires, he and Natalie (who is covered under his employer s group health plan) will no longer have health coverage. Julien calls you to ask whether he and Natalie are eligible for Marketplace coverage or government-sponsored coverage. What should you advise Julien and Natalie? A. They may both be eligible for Medicare since Julien is age 65 and Natalie is under age 65 with a disability. You point out that the Marketplace does not determine eligibility for the Medicare program. B. They should wait until several months after Julien's retirement to get their finances in order, and then follow up with you for assistance in seeking health coverage through the Marketplace. C. Julien and Natalie may be eligible to enroll in a Marketplace plan. You tell Julien that you can assist them with eligibility, plan selection, and enrollment. 21

23 Scenario: Consumers May Qualify for Medicare Coverage Answer (Continued) Julien and Natalie may both be eligible for Medicare and should explore that option first. Consistent with the longstanding prohibition on the sale of duplicate coverage to Medicare beneficiaries, it is illegal to sell or issue a QHP to a Medicare beneficiary with the knowledge that the QHP duplicates the beneficiary s Medicare benefits. As an agent or broker, you should protect yourself by asking each applicant about his or her Medicare status and, for consumers who may be eligible for Medicare, direct them to contact Medicare at for information on eligibility, the enrollment process, and enrollment timeframes. 22

24 Compliance with Marketplace Requirements: Considerations for Agents and Brokers How to Report Potentially Fraudulent Activity 23

25 What Are Examples of Potentially Fraudulent Activity? You play an important role in observing and reporting any potentially fraudulent practices taking place in relation to the Marketplace. Examples of Potential Fraud and Abuse A client tells you he has been contacted by an individual seeking his personal and financial information. A client, or another agent or broker you work with, submits false documentation to the Marketplace. An agent or broker is enrolling consumers without their consent. An agent or broker is assisting consumers without a valid health license or without completing Marketplace registration. A registered agent or broker with a valid health license is assisting consumers but is not licensed in the state where the consumer lives An agent or broker has disclosed a consumer s personally identifiable information. You or a client discovers unauthorized changes were made to the client s online application. You suspect a consumer or insurance company is providing false or misleading information to the Marketplace. 24

26 How Can You Report Potentially Fraudulent Activity? If you suspect that a consumer or another agent or broker has engaged in fraud or abusive conduct, report your concerns to one of the following: Name Contact Topics Department of Health & Human Services (HHS) Office of Inspector General Hotline Federal Trade Commission HHS-TIPS ( ) or hotlineoperations/index.as px ssistant.gov HHS employee fraud or misconduct Grant and contract fraud Identity theft Contact from someone posing to be from the government Agent/Broker Help Desk FFMProducer- AssisterHelpDesk@cms.hh s.gov Unregistered agents or brokers operating in the Marketplace Inappropriate agent or broker marketing practices Submission of false information 25

27 Program Integrity for Consumer-Reported Income You should ensure your clients are reporting accurate income when completing or updating the eligibility application. Remember, consumers must reconcile APTC with the premium tax credit they are allowed for the year based on their actual household income when filing federal income taxes. If a consumer misrepresents his or her income (intentionally or otherwise), the consumer (or tax filer for that consumer s household) may be required to repay the excess APTC paid on the consumer s behalf. Reinforce to consumers that it is in their best interest to report the most accurate income estimate, not the income estimate that necessarily maximizes the amount of APTC for which the consumer is eligible. Remember to report to the Agent/Broker Help Desk if you suspect a consumer has submitted false documentation. 26

28 Penalty for Providing False Information to the Marketplace Any person who fails to provide correct application information to the Marketplace may be subject to a maximum civil money penalty of $25,000 for each application, if the failure is negligent or in disregard of federal rules or regulations (45 CFR (c)(1)(i)). Any person who knowingly and willfully provides false or fraudulent application information to the Marketplace may be subject to a maximum civil money penalty of $250,000 for each application (45 CFR (c)(1)(ii)). Application information is described under 1411(b) of the Affordable Care Act. 27

29 Scenario: Consumer May Report False Income Your long-time client Doug recently started his own business as an independent consultant. He explains that he does not have a set salary, and is nervous about the cost of maintaining health coverage, but is hoping APTC will help out. When you review Doug s Marketplace application with him, you notice that the income he is reporting is significantly lower than what he was making in previous years. When you ask him how he arrived at his estimated annual income, he gives you a vague answer and then tells you how much he is depending on a high level of APTC. What should you do? A. Accept Doug s explanation. He is more knowledgeable about his finances and any misrepresentation is his responsibility. B. Explain the importance of reporting the most accurate income information to the Marketplace, reminding Doug he may have to repay excess APTC when he files his federal tax return. C. Remind Doug that there are penalties for reporting false application information to the Marketplace. D. Report your suspicions to the Agent/Broker Help Desk. 28

30 Scenario: Consumer May Report False Income Answer Your long-time client Doug recently started his own business as an independent consultant. He explains that does not have a set salary, and is nervous about the cost of maintaining health coverage, but is hoping APTC will help out. When you review Doug s Marketplace application with him, you notice that the income he is reporting is significantly lower than what he was making in previous years. When you ask him how he arrived at his estimated annual income, he gives you a vague answer and then tells you how much he is depending on a high level of APTC. What should you do? A. Accept Doug s explanation. He is more knowledgeable about his finances and any misrepresentation is his responsibility. B. Explain the importance of reporting the most accurate income information to the Marketplace, reminding Doug he may have to repay excess APTC when he files his federal tax return. C. Remind Doug that there are penalties for reporting false application information to the Marketplace. D. Report your suspicions to the Agent/Broker Help Desk. 29

31 Scenario: Consumer May Report False Income Answer (Continued) As an agent or broker, you can help your clients avoid future problems by advising them of the risks and potential consequences of providing inaccurate information, including any potentially fraudulent activity. Remember that HHS may impose civil money penalties for failure to report correct application information to the Marketplace. These potentially could be in addition to other penalties for perjury. If you suspect or identify potentially fraudulent activity, you can report your concerns to the HHS Office of Inspector General Hotline, the Federal Trade Commission, or the Agent/Broker Help Desk, depending on the situation. 30

32 Compliance with Marketplace Requirements: Considerations for Agents and Brokers Key Reminders and Resources 31

33 Points to Remember Obtain consent from each client you work with prior to assisting him or her. Do not create or maintain access to a client s HealthCare.gov account or associated account. If a client may be eligible for Medicare, direct him or her to Medicare for a determination before you assist that client to enroll in a Marketplace QHP. Identify and report suspicious activity or potentially fraudulent behavior you observe in relation to the Marketplace. 32

34 Key Sources for Agent and Broker Requirements Resource Agent and broker standards of conduct: 45 C.F.R (j)(2) Requirement for Marketplace agents and brokers to complete annual registration and training: 45 C.F.R (d) Requirement for Marketplace agents and brokers to comply with state law: 45 C.F.R (e) Standards and process for terminating an agent s or broker s Marketplace agreement: 45 C.F.R (f),(g), and (h) Banning an agent or broker from future Marketplace participation penalty: 45 C.F.R (k)(1)(i) Civil money penalties for provision of false information to the Marketplace: 45 C.F.R (k)(1)(ii) and CMS eight privacy principles: 45 C.F.R (a) Link mc=true&node=se _1220&rgn=div8 mc=true&node=se _1285&rgn=div8 mc=true&node=se _1260&rgn=div8 33

35 Compliance with Marketplace Requirements: Considerations for Agents and Brokers Other Marketplace Updates 34

36 Upcoming Activities The slides from this webinar will be available on the Registration for Technical Assistance Portal (REGTAP) at and the Resources for Agents and Brokers webpage in the coming days. Watch your for invitations to upcoming webinars. Upcoming Agent/Broker Webinar* June 21, 2:00-3:00 PM ET Part II: Marketplace Privacy & Security Requirements for Agents and Brokers Upcoming Assister Webinar* June 22, 2:00-3:30 PM ET Agents/Brokers Welcome! Medicaid Fast Facts Assisting American Indians/ Alaska Natives *Webinar dates and topics are subject to change. CMS will share current webinar information via . 35

37 General Resources: New Search Tool Based on your feedback, CMS has recently redesigned the General Resources page to include a new search tool that makes it easier for you to find the information you are looking for. 36

38 General Resources: New Search Tool (Continued) Now you can quickly search through over 100 resources by filtering on: Date uploaded Topic name Title Type of resource Keywords 37

39 General Resources: New Search Tool (Continued) To search by topic name, type the topic of the resource you are looking for (such as Help On Demand ) in the Filter On search bar. 38

40 General Resources: New Search Tool (Continued) To view or download a resource, click on its date. 39

41 General Resources: New Search Tool (Continued) You will then be directed to a new page with resource details and a link to download. 40

42 General Resources: New Search Tool (Continued) To return to the Agents and Brokers Resources webpage home page at any time, click the Agent and Broker Landing Page link at the bottom of the General Resources page. 41

43 General Resources: New Search Tool (Continued) To go to the Health Insurance Marketplaces home page at any time, click the Health Insurance Marketplaces button on the left sidebar. 42

44 New Tip Sheet for Validating Your Address in Your MLMS Profile A new Tips for Address Validation resource is available on the Agents and Brokers Resource Webpage. Use this resource if you get an error message that your address in the Marketplace Learning Management System (MLMS) is invalid. Ensure your MLMS profile address is correct so consumers can find you in the Find Local Help tool on HealthCare.gov and the Help On Demand service that connects you directly with consumers looking for application assistance. 43

45 Reminder: Complete Plan Year 2018 Agent and Broker Training Plan year 2018 Marketplace agent and broker registration and training is still available on the CMS Enterprise Portal. For a detailed description of the requirements and how to complete the registration steps, please select one of the following hyperlinks to download a helpful guide: Guide to Plan Year 2018 Marketplace Registration and Training for New Agents and Brokers Guide to Plan Year 2018 Marketplace Registration and Training for Returning Agents and Brokers For more information, select the Plan Year 2018 Registration and Training link on the sidebar of the Agents and Brokers Resources webpage. 44

46 Agent and Broker Resources Resource Description Link Agents and Brokers Resources webpage HealthCare.gov Marketplace information source for Agents and Brokers Plan Year 2018 Marketplace Registration and Training for Agents and Brokers Primary outlet for information about participating in the Health Insurance Marketplace Official site of the Health Insurance Marketplace used for researching health coverage choices, eligibility, and enrollment Provides additional technical assistance resources about Marketplace eligibility, financial assistance, enrollment, and more Describes the process and requirements for completing annual Marketplace registration and training for agents and brokers s-and-initiatives/health-insurance- Marketplaces/Plan-Year Registration-and-Training.html 45

47 Agent and Broker Resources (Continued) Resource Description Link Registration Completion List Public list of agents and brokers who have completed Marketplace registration; used by issuers to verify your eligibility for compensation for assisting with consumer enrollments _registration_lists Find Local Help Help On Demand Agent and Broker National Producer Numbers (NPNs) Tool available on HealthCare.gov that enables consumers to search for a local, Marketplaceregistered agent or broker with a valid health line of authority to assist with FFM enrollment A third-party service that connects consumers seeking assistance with Marketplaceregistered, state-licensed agents and brokers in their area who can assist with Marketplace enrollment when the consumer is available A third-party service that provides a search function to determine the correct NPN to enter in your MLMS profile and on Marketplace applications

48 Most Frequently Used Agent/Broker Marketplace Help Desks and Call Centers Name Phone # and/or Address Types of Inquiries Handled Hours (Closed Holidays) Direct Agent/ Broker Partner Line Note: Enter your NPN to access this line. Assist consumers with HealthCare.gov account password resets SEPs not available on the consumer application Individual Marketplace eligibility and enrollment issues Mon Sun 24 hours/day Agent/Broker Help Desk FFMProducer- AssisterHelpDesk@c ms.hhs.gov General enrollment and compensation questions Manual identity proofing/experian issues Escalated general registration and training questions (not related to a specific training platform) Agent/Broker Registration Completion List issues Find Local Help and Help On Demand issues Mon Fri 8:00 AM 6:00 PM ET Agent/Broker Training and Registration Help Desk MLMSHelpDesk@cms.hhs.gov Technical or system-specific issues related to the agent/broker training and registration system (i.e., the MLMS) User-specific questions about maneuvering in the MLMS site, or accessing training and exams Mon Fri 8:00 AM 5:30 PM ET Marketplace Service Desk 855-CMS CMS_FEPS@cms. hhs.gov CMS Enterprise Portal password resets and account lockouts Login issues on the DE agent/broker landing page Other CMS Enterprise Portal account issues or error messages 501 Downstream Error message on HealthCare.gov website issues General registration and training questions (not related to a specific training platform) Mon-Fri 8:00 AM 8:00 PM ET For a full list of Agent/Broker Help Desks and Call Centers, see Insurance-Marketplaces/Downloads/Agent-Broker-Help-Desks.pdf. 47

49 Acronym Definitions Acronym APTC CCIIO CMS DE FFM HHS MEC MLMS NPN OEP PII QHP REGTAP SBM SBM-FP Definition Advance Payments of the Premium Tax Credit Center for Consumer Information and Insurance Oversight Centers for Medicare & Medicaid Services Direct Enrollment Federally-facilitated Marketplace Department of Health & Human Services Minimum Essential Coverage Marketplace Learning Management System National Producer Number Open Enrollment period Personally Identifiable Information Qualified Health Plan Registration for Technical Assistance Portal State-based Marketplace State-based Marketplace on the Federal Platform 48