Q&A Document on Designation of Certified Application Counselor Organizations

CMS has issued a question and answer (Q&A) document answering some common questions regarding the designation of certified application counselor (CAC) organizations in the federally facilitated (health insurance) marketplaces (FFM).


On July 17, 2013, CMS issued a final rule (78 FR 42824) addressing requirements applicable to Navigators and non-Navigator assistance personnel in the Federally-facilitated Exchanges, including State Partnership Exchanges, and to non-Navigator assistance personnel in State Exchanges that are funded through federal Exchange Establishment grants. It also established, in 45 C.F.R. 155.225, CACs as the assistance personnel available to provide information to consumers and to help facilitate consumer enrollment in qualified health plans (QHPs) and insurance affordability programs. The Final rule and related CMS guidance provide that an Exchange may designate organizations to certify staff or volunteers to perform the duties of CACs according to the standards set forth in the rule. This certification process is designed to assure consumers that they are receiving assistance from persons trained by the Exchange who are overseen by organizations that are required to protect personally identifiable information.

The Q&A Document

The Q&A provides answers to 106 questions. In its answers, it indicates that certain types of organizations, by their very nature, will clearly meet the criteria to be a CAC. These organizations, however, such as Health Resources and Services Administration grantees, Federally Qualified Health Centers, and the Indian Health Service, will still have to submit an application to CMS for CAC designation.

The Q&A’s answers also indicate that: (1) an organization may be a Navigator grantee or a Champion for Coverage and also be a designated CAC; (2) in a FFM, each separate legal component of a larger organization must submit its own application to be a designated CAC organization; (3) a single legal entity with multiple locations within a single state may submit the application for all of its locations; (4) if an entity has locations in several different states in which a FFM will be operating, it must submit a separate application for each state; (5) organizations in states with a State-based Marketplace (SBM) should contact the SBM or go to the SBM’s website for information about the CAC program in that state; and (6) CAC designated organizations and individual CACs will not be funded through the Marketplace, but may seek funding through outside sources, such as other available federal, state, or private funds.

Training materials for CACs are publically available through CMS.