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Navigator

What are Navigators?

The Navigator position was created by the Affordable Care Act to provide helpers for people to enroll in coverage through the health insurance exchange, and refer or assist with Medicaid enrollment.

Navigators are not licensed health insurance brokers, so they cannot recommend one plan over another or direct consumers towards a particular policy. Instead, they provide consumers with general information that can make it easier to understand what’s available, in terms of coverage and financial assistance. Navigators are paid by state and federal grant programs, and they cannot be compensated by the insurance companies.

What training and qualifications do Navigators have?

Navigators must meet cultural competency standards and go through training and certification. Standards and regulations for the Navigator program are outlined in 45 CFR 155.210 and CFR 45 155.215.

State-run exchanges do their own certification and training for Navigators. CMS conducts the certification and training for Navigators in states that use HealthCare.gov; you can see specific training information and requirements here. (Note that state-run exchanges that use the HealthCare.gov enrollment platform are required to operate and fund their own Navigator programs.)

Although Navigators are not the same as state-licensed agents and brokers, states can impose stronger requirements for Navigators than the federal minimums, and this is true in both states that run their own exchanges as well as states that use the federally-run HealthCare.gov platform.

For example, Louisiana requires Navigators to be licensed and regulated by the state insurance commissioner, and so does Wisconsin. In other states, such as Ohio, Navigator Organizations are certified by the state and then people who are interested in becoming Navigators must do so directly through the Navigator Organizations.

What assistance can Navigator provide?

Navigators provide enrollees with unbiased information about the health insurance exchange and the health plans that are available. They can help applicants determine whether they qualify for subsidies or Medicaid, and assist with the enrollment process.

As of 2018, HHS enhanced the requirements for Navigators. The new requirements, detailed in 45 CFR 155.210(e)(9), ensured that Navigators would provide targeted assistance for underserved and uninsured populations, and post-enrollment assistance for things like eligibility appeals, subsidy reconciliation, and health insurance utilization questions.

In the guidelines for 2020, HHS reversed course somewhat on this, making those duties optional, rather than required, for Navigator organizations. But in the rules for 2022 and beyond, HHS reinstated the previous requirements. This means that Navigators in the states with federally-run marketplaces are once again required to provide post-enrollment assistance with things like eligibility appeals and how to utilize health coverage after a person has already enrolled.

Previous federal regulations prohibited Navigators from providing enrollment assistance by going door-to-door, cold-calling, or using “other unsolicited means of direct contact,” but those rules have changed for 2024. Navigators were already allowed to use these methods in order to conduct general outreach and education — they just couldn’t enroll people via unsolicited contact.

But in the rulemaking guidance for 2024 and future years, HHS has repealed that prohibition. So Navigators are allowed to initiate direct contact with potential enrollees and help them enroll without having to wait for the people to reach back out to the Navigator organization for help with the enrollment process. HHS notes that this rule change “will allow Navigators and other assisters in the FFEs to help more consumers.”

How are Navigators funded?

Navigators are funded by the federal government in states that use the federally-run exchange (HealthCare.gov) and by the states that run their own exchange platforms (states that run their own exchanges but use HealthCare.gov for enrollment are responsible for funding their own Navigators).

The Biden administration has dramatically increased federal Navigator funding in recent years. $80 million was distributed in the summer of 2021 in 30 states that used the federally-run Marketplace, to provide funding for Navigator assistance for the 2022 plans year.

Total funding was even larger in 2022 and 2023. In 2022, nearly $99 million was distributed to the 59 Navigator organizations in those 30 states. And in 2023, another $99 million was distributed to 57 Navigator organizations in 29 states (Georgia has transitioned to a state-run Marketplace that uses the HealthCare.gov platform for 2024, so the state is funding its own Navigator program).

Although there are 32 states that use HealthCare.gov for the 2024 plan year, three of them have state-run marketplaces and just use the federal platform for enrollment; those three states fund their own Navigator programs, just like the states with fully state-run exchanges.

Prior to 2021, the previous record high for federal Navigator funding had been $63 million, provided in the fall of 2016. The Trump administration had subsequently reduced federal Navigator funding down to only $10 million per year, so the funding that was provided in advance of the open enrollment period in the fall of 2022 was ten times more than had been available just a few years earlier.

And that’s despite the fact that fewer states need to rely on the federal Navigator funding: New Jersey, Pennsylvania, Virginia, Maine, and Georgia have all transitioned away from the federally-run exchange over the last few years, making the nearly $100 million in annual federal Navigator funding stretch even further (Georgia still uses HealthCare.gov, but has a state-run exchange using the federal enrollment platform, so the state funds its own Navigator program).

New Mexico and Kentucky both switched to their own state-run exchange platforms in the fall of 2021, but they already had state-run exchanges that used the federal platform for enrollment, so they weren’t receiving federal Navigator funding even when they used HealthCare.gov.

New Jersey, Pennsylvania, Maine, and Virginia all had fully federally-run exchanges initially, then switched to state-run exchanges using the federal enrollment platform, and then switched to fully state-run exchanges (Virginia’s transition will be complete by the fall of 2023). So they previously received federal Navigator funding, but now fund their own Navigator programs.

You can see the lists of Navigator grant recipients for each year on this page. That page was updated in August 2023 with Navigator funding grants for the 2024 plan year.

How can I find a Navigator in my area?

You can enter your zip code on HealthCare.gov’s “find local help” tool. If you’re in a state that runs its own exchange, you’ll be directed to your state’s exchange website. If you’re in a state that uses HealthCare.gov (32 states as of 2024), the tool will show you who can help you enroll in your area.

You’ll need to select the “assisters” filter to see only Navigators and enrollment counselors (if you don’t limit it, the tool will show you everyone who is certified to help you, including brokers and agents; note that brokers and agents are licensed by the state and are allowed to provide specific plan recommendations, whereas Navigators are not).

You can see a list of the organizations that have received federal Navigator grants on this page.

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