Minnesota Hospital Association

Policy & Advocacy

rules, regulations and comments

The Minnesota Hospital Association continually monitors state and federal rules and regulations to keep members informed and advocates on behalf of members regarding the impact of regulations on the state’s hospitals and health systems. MHA submits comment letters to share recommendations and feedback with the appropriate government organizations and health care stakeholders. Examples of rules and regulations that MHA addresses include those implementing federal or state health care reform efforts, changing payment methodologies, establishing community benefit or other standards for tax-exempt organizations, or modifying government oversight of health care activities.

April 19, 2013

Proposed rules for MNsure Consumer Assistance Services

To: Jim Schowalter, Commissioner, Minnesota Management and Budget
Via email to publiccomments.HIX@state.mn.us

RE: Minnesota Management and Budget Proposed Exempt Permanent Rules Relating to Policies and Procedures to Certify Entities to Deliver Consumer Assistance Services

Dear Commissioner Schowalter:
On behalf of our 144 member hospitals and their health systems, the Minnesota Hospital Association (MHA) appreciates the opportunity to comment on proposed rules for MNsure Consumer Assistance Services.

MHA supports a robust health care exchange marketplace that allows consumers to compare, shop for and enroll in quality, affordable health care coverage. The success of this new marketplace relies in large part on the participation of consumers, many of whom will be lower income and/or uninsured and purchasing insurance for the first time. These consumers will need reliable resources and clear, easy to understand information in order to make the best choices for themselves and their families. The proposed rules go a long way toward ensuring the consumer assistance partners and services are reliable and provide independent information to consumers when they need it, whether it is for state programs, tax credits, or commercial insurance questions.

7700.0030, subpart 3: Eligible organizations
The proposed rule defines “eligible consumer organizations” as follows:

any of the following organizations or entities able to demonstrate to the board that the entity has existing relationships, or could readily establish relationships with consumers in Minnesota, including uninsured and underinsured consumers, likely to be eligible to enroll through MNsure: 501(c)(3) community-based organizations, for-profit businesses, government agencies, and any other organization recognized by the Office of the Secretary of State including, but not limited to:
A. community and consumer-focused nonprofit groups;
B. trade, industry, and professional associations;
C. farming organizations;
D. religious organizations;
E. chambers of commerce;
F. insurance producers, subject to subpart 1;
G. coalitions and collaborative efforts are encouraged;
H. tribal organizations; and
I. state or local human services agencies.

MHA has two questions that arise from subpart 3:

  • Will organizations and entities that currently assist consumers in enrolling in public programs or finding affordable insurance coverage be required to become consumer assistance organizations, with their employees becoming certified consumer assistance partners, in order to continue providing this assistance?
  • If so, could health care providers, such as hospitals and clinics, that already assist consumers in this manner be considered eligible consumer assistance organizations? Hospitals currently have a number of employees who work with uninsured or underinsured patients to find appropriate public programs or financial assistance for health coverage. Allowing these employees to continue this service, either in their current capacities or if they choose to become certified consumer assistance partners, will ensure a larger number of people get the enrollment assistance they need.

Hospitals and health systems meet many of the criteria in subpart 3, as most are 501(c)(3) community-based organizations or public entities with established or readily established relationships with consumers in Minnesota, including uninsured and underinsured consumers. It only makes sense for MNsure to allow hospitals and health systems to continue providing this assistance, or allow them to become consumer assistance organizations if the entity wishes. MHA does not support mandating all entities that currently offer enrollment assistance become consumer assistance organizations, but we believe that health care providers, or hospitals at a minimum, should be enumerated as eligible entities in this subpart.

Thank you again for the opportunity to comment. If you have any questions, please feel free to contact me at (651) 659-1405 or jmcnertney@mnhospitals.org.


Jennifer McNertney
MHA Policy Analyst