CMS-10472 - Response to Public Comments

Responses to Comments Received
Proposed Rule CMS-9955
Introduction
CMS received 3 comments regarding the Navigator and non-Navigator assistance personnel PRA
package published on April 5, 2013 (78 FR 20581). The comment period closed May 6, 2013.
The PRA package contained the following collections of information: disclosures related to eligibility
requirements for Navigators, the mitigation of conflicts of interest, the methods of disclosure of any
non-prohibited conflicts of interest, registration prior to training, the maintenance of proof of
certification or recertification, and the dissemination to consumers of the full range of QHP options and
insurance affordability programs for which they may be eligible.
The comments CMS received regarding these collections of information are summarized immediately
below. The comments expressed the same appreciation and concern and therefore are summarized
together with a single response.
Comments Regarding CMS-9955 Collections of Information
Comment: The comments generally stated an appreciation for an estimate of a livable wage; however
the comments noted a concern that the wage estimates are unrealistic. Commenters did not
recommended specific wage estimates they considered to be more realistic.
Response: The wage estimates are not being modified. The estimates are not mandatory wages and
are not broken down based on the role geographic differences may play in setting actual wages. There
is nothing in the final rule that would require any Navigators or non-Navigator assistance personnel to
be paid any specific amount. In addition Navigators and non-Navigator assistance personnel wages could
be funded in many different ways. For example, a Navigator grantee may have outside funding sources
for wages, with their Navigator grant completely funding all outreach and education and application
assistance activities not included in wages. These are estimates commonly used for estimating
paperwork burden and do not represent a recommendation or a requirement of how much Navigator
and non-Navigator personnel are to be paid.