Answering Your Questions on Certified Application Counselors

By Tricia Brooks, Georgetown University Center for Children and Families

I’ve been getting lots of questions on certified application counselors, so I thought it was time to loop back to this issue and try to answer a few based on what I’ve heard along the way.

How long does it take to receive approval of a CAC application?

HHS has received several thousand applications from health care providers and 501(c) organizations to become certified application counselor entities and the level of interest has created a backlog that CMS is working through. So if your organization has applied but hasn’t gotten final word, be patient, it could take a couple of weeks. Some tips for your application – be sure you understand the requirements of CAC designated entities and fill out the application accordingly:

  • Beyond basic organizational information, take care to fill out all information as completely as possible. Your application may be denied if it’s incomplete. However, if you think you missed something, you can re-apply.
  • There are three important questions about your organization’s privacy and security experience that have a yes/no checkbox. Underneath there is a box that states “if you have selected yes, please explain your qualifications.” You should address all three questions in this box, not just the last one.
  1. Does your organization already screen the employees/volunteers it will certify as application counselors? (Unless your state requires it, criminal background checks aren’t mandated. But I don’t know of any organization that doesn’t minimally screen employees through reference checks and I-9 forms to confirm identity. Explain what your organization does in hiring employees or screening volunteers.)
  2. Does your organization already handle personally identifiable information (PII) and have processes in place to protect PII? (If you are a healthcare provider, you can point out that your organization is HIPAA compliant. You can speak to the kind of training you provide and what employee or volunteer policies you have in place to protect PII.)
  3. Does your organization assist people with health coverage decisions? (CMS is looking for organizations that have experience in helping people connect to coverage or other public benefit programs. So speak to your experience in doing this.)

If my organization operates in multi-states do I have to fill out an application for each location?

No, but you should list each of the locations where you will have trained and certified counselors working. There’s a “find local help” button on that people can click to find assisters. The only way each of your locations will be listed is to include them on your application.

How can we access the formal training?

Once your organization is certified, you will receive additional information about signing the agreement and how to take the next steps for training and certification.

Is CAC training the same regardless of where a CAC entity is located?

Yes, the federal training is the same but CAC entities may want to supplement the training, particularly as it relates to state-specific Medicaid, CHIP and private insurance information. There may be navigator entities or other community-based organizations in your state that can provide additional training, or CAC entities could work together to reach out to funders or pool their resources to develop supplemental training.

Is there anything I can do to get started while my organization is waiting for approval?

Yes, screen shots of the training can be found here, along with other helpful information. So individuals can get a head start on reviewing the material. Many organizations are stepping up to provide additional materials. Check out Enroll America’s website. And I’m particularly fond of the excellent work the Center on Budget and Policy Priorities has done in creating a special website – – where you’ll find fact sheets, webinar recordings, slides, and other resources on some of the more complicated aspects of financial assistance and coverage options. It’s probably not the best starting point for entry-level assisters, but is a great resource for those with a foundation of knowledge about the ACA’s coverage options.

What liability do certified application counselors have?

I’m not a lawyer so I can’t give legal advice. There is some risk if a consumer is provided with bad information that results in harm. And there are clear penalties for someone improperly disclosing or using personal information. However, most organizations have some kind of professional liability insurance, so they should check with their insurance broker on what it covers. In doing so, they should explain what CACs are required to do, including disclosing conflicts of interest, while clarifying what they don’t do such as make eligibility determinations or recommend on a specific plan.

What can we do to overcome public concerns about enrollment scams and identity theft?

Give your certified application counselors some kind of official badge to identify them. You could also provide a toll-free number for someone to call to confirm that a CAC is affiliated with your organization, or post of list of certified counselors on your website. Also be thoughtful in describing to consumers the role of a CACs and if there are relationships that must be disclosed.

Why should my organization become a CAC entity?

The ACA provides an historic opportunity to expand coverage to Americans who aren’t offered coverage through their jobs and can’t afford to buy it on their own. But applying for financial help to pay for coverage and thinking through what factors to consider in selecting a plan aren’t necessarily easy. Consumers need assistance and the level of funding for navigators particularly in states where there will be a federal marketplace will fall short of meeting that need. Your organization can make a difference in connecting people in your community to coverage.

[Editor’s Note:  This blog originally appeared on Georgetown University’s Center for Children and Families’ Say Ahhh! Blog.]

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The opinions expressed here are solely those of the individual blog post authors and do not represent the views of Georgetown University, the Center on Health Insurance Reforms, any organization that the author is affiliated with, or the opinions of any other author who publishes on this blog.