GAO Statement Highlights Deficiencies in Federal Exchange Enrollment Process

On July 16, 2015, the Government Accountability Office issued a written statement entitled “Patient Protection and Affordable Care Act: Observations of 18 Undercover Tests of Enrollment Controls for Health-Care Coverage and Consumer Subsidies Provided under the Act.” This statement contained the findings of “undercover testing of the [Exchange] application, enrollment, and eligibility verification controls using 18 fictitious identities” that GAO submitted or attempted to submit through the Exchange in several states in a variety of ways.

Testing began in January 2014 before the original ACA enrollment period and concluded in April 2015. GAO provided preliminary results on this testing in July 2014 testimony, which described the results of the tests at that time. This most recent testimony extends that testimony to include the post-application process and the maintenance of the fictitious identities through the remainder of 2014-2015.

First, 12 of these undercover tests focused on phone or online applications, while six focused on the “extent to which, if any, in-person assisters would encourage applicants to misstate income in order to qualify for income-based subsidies during coverage year 2014.”

The GAO found that the Exchange approved subsidized coverage under the ACA for 11 of the 12 fictitious GAO applicants for the 2014 enrollment period. As part of these tests:

The GAO applicants obtained a total of about $30,000 in annual advance premium tax credits, plus eligibility for lower costs due at time of service. For 7 of the 11 successful fictitious applicants, GAO intentionally did not submit all required verification documentation to the Marketplace, but the Marketplace did not cancel subsidized coverage for these applicants. While these subsidies, including those granted to GAO’s fictitious applicants, are paid to health-care insurers, and not directly to enrolled consumers, they nevertheless represent a benefit to consumers and a cost to the government.

The GAO did clarify that its “undercover testing, while illustrative, cannot be generalized to the population of all applicants or enrollees.”

As to the remaining six undercover tests, the test consisted of contacting three Navigators and three Non-Navigators. “GAO was unable to obtain in-person assistance in 5 of the 6 undercover attempts.” One assister told GAO “that it only provided help for those applying for Medicaid and not health-care insurance applications.” Only one Navigator correctly advised that the income presented at the time of application “would not qualify for the subsidy.” Representatives from the relevant organizations acknowledged the deficiencies GAO raised. The Centers for Medicare & Medicaid Services advised “that their experience from the first open-enrollment period helped improve training for the 2015 enrollment period.”

A final report with recommendations will be issued.

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