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HomeMy WebLinkAboutC13-236 Connect for Health Assistance Network Grant Agreementsti A
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CONNECTS HEALTH
OI CIRADO
Connect for Health Assistance Network Grant Agreement
This Connect for Health Assistance Network Grant Agreement (Agreement), entered into between the
Colorado Health Benefit Exchange C4HCO doing business as Connect for Health Colorado (C4HCO) and
Eagle County (Grantee), is part of C4HCO's "Connect for Health Assistance Network" to fund and certify
Assistance Sites and Regional Hubs to supervise Health Coverage Guides as part of C4HCO's efforts to
serve Coloradans by providing impartial information and assistance with the application and enrollment
experience.
1. Scope of Work: The grant shall be used exclusively for the purposes described in the Connect
for Health Assistance Network Funding Opportunity Announcement, whose terms are incorporated by
reference into this Agreement, the Grantee's application dated the 19th of April, 2013, as revised,
including any subsequently submitted revised Scope of Work and/or Budget appended hereto as
Attachment 1, and the terms of this Agreement.
2. Use of Grant Funds:
A. Approved Budget: Expenditure of grant funds shall not exceed the amount approved in the
Grantee's Final Revised Budget. Grant funds are for approved expenditures incurred during the grant
period July 1, 2013 through December 31, 2014. The budget is considered to be a reimbursement of
actual costs incurred. Grantees may submit requests for prospective funding disbursements. Financial
reporting to justify advance disbursements must be submitted in accordance with Connect for Health
Colorado instructions.
B. Budget Revisions: Transfers between budget categories may be completed by the grantee if
they do not exceed 25 percent of the total budget. Transfers between budget categories that exceed 25
percent of the total budget must receive prior written approval from C4HCO. Grantees must track
cumulative transfer of funds between categories.
C. Unexpended Funds: Grantees receiving advance disbursements shall return to Connect for
Health Colorado any unexpended funds within 60 days after the close of the grant period or the
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termination of the grant. C4HCO, at its sole discretion, may extend the original time limit for
expenditure of grant award funds following approval of an extended project timeline. This will be an
extension with no additional funds.
3. Term: This Agreement is effective upon its execution by the parties and remains in force for
eighteen months, July 1, 2013 -December 31, 2014 or until such time as the obligations and conditions
imposed by or otherwise associated with the Grant expire. C4HCO may terminate this Agreement for
Grantee's failure to meet any requirement of the Connect for Health Assistance Network or should it at
any time determine that such termination is in C4HCO's best interest, provided that such termination
shall be in writing and be provided to Grantee at least thirty (30) days in advance of the effective date of
termination. In the event of such termination, C4HCO will pay Grantee for all services rendered, up to
the effective date of termination, it being acknowledged that during the notice period, Grantee will
wind -down its responsibilities under the Grantee's project proposal, and in consultation with C4HCO,
determine which specific activities should be terminated as soon as possible and which should be
continued until the effective date of termination.
4. Unapproved Expenditures. Any expenditure of grant funds not in accordance with the approved
budget submitted or not consistent with the purposes stated in the Grantee proposal are subject to
prior approval by the C4HCO, in its sole discretion. Should any expenditure be disallowed or should the
Grantee violate any of the terms of this Agreement, C4HCO may require repayment, an offset from this
Grant to the Grantee in the current or succeeding fiscal year, or other appropriate action.
5. Liability and Insurance: The Grantee will be liable, to the extent provided by the Colorado
Governmental Immunity Act, for the conduct of individuals serving as Health Coverage Guides under
its supervision, whether employed or volunteer, including (but not limited to) compliance with the roles
and responsibilities set out in Connect for Health Assistance Network Funding Opportunity
Announcement and this Connect for Health Assistance Network Grant Agreement, and processes and
procedures developed by Connect for Health Colorado. The Grantee is a "public entity" within the
meaning of the Colorado Governmental Immunity Act, §24-10-101, et seq., C.R.S., as amended
("Act"). The Grantee will maintain insurance, by commercial policy or self-insurance, as is necessary to
meet the Grantee's liabilities under the Act. With respect to general liability, the Grantor recognizes
that the County is self-insured for general liability in accordance with the provisions of the Colorado
Governmental Immunity Act, as amended. Grantee will be required to show proof of insurance prior to
disbursement of grant funding and provide C4HCO with satisfactory evidence of its compliance with this
requirement during the term of this agreement upon request. Failure to comply with the insurance
requirements may result in termination of this Grant Agreement.
6. Proiect Administration:
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A. The Grantee will directly administer the project supported by the Grant and agrees that no
Grant funds shall be disbursed to any organization or entity, whether or not formed by the Grantee,
other than as specifically set forth in the project proposal cited above.
B. Subcontracts: The Grantee must ensure that all subcontracts and consulting or partnership
agreements are deliverables -based and in compliance with the terms of C4HCO's award and follow the
Grantee's procurement policies. The Grantee is accountable for the deliverables of its subcontractors.
C. Project Revisions: Any material changes in the project goals, objectives, timetable, deliverables,
budget, or evaluation plan must receive prior written approval from C4HCO.
D. Certification: The Grantee must meet certification requirements as defined by Connect for
Health Colorado including, but not limited to agreeing to meet the terms of this Agreement. Grantee
must ensure all Health Coverage Guides under its supervision, meet the requirements for certification as
defined by Connect for Health Colorado and listed below, and obtain certification prior to assisting
customers. Health Coverage Guide certification requires:
o The individual is not on the OIG List of Excluded Individuals/Entities
o The individual has agreed to Connect for Health Colorado Privacy and Security policies
o A background check was completed for the individual with satisfactory results
o The individual has agreed to the Conflict of Interest policy and submitted disclosures
o The individual has completed and passed Connect for Health Colorado Health Coverage
Guide training.
7. Reporting Requirements and Payment Schedule: The Grantee shall submit required reports on
or before the date due, per the instructions provided by Connect for Health Colorado, following C4HCO's
guidelines and formats. Upon receipt, review, and approval of Grantee reports, C4HCO shall issue grant
payments.
8. Grant Monitoring and Evaluation:
A. The Grantee agrees to attend meetings, participate in site visits, and give reports on progress
and accomplishments to the Board of Directors of C4HCO, C4HCO staff and advisors, and other grantees
as requested by C4HCO.
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B. The Grantee agrees to participate in an evaluation of C4HCO's grants program, including
assisting with any data collection and information gathering, such as participation in surveys, site visits,
meetings, and interviews with evaluators.
C. The Grantee agrees to provide quarterly reports with information including but not limited to
characteristics of the population served, numbers served, and outreach and enrollment strategies and
outcomes.
D. The Grantee agrees to produce all documents and reporting required for monitoring of Federal
grant sub -recipients, as determined and directed by C4HCO.
E. The Grantee agrees to comply with the Federal rules and requirements related to C4HCO's grant
including but not limited to circulars A-87, A-122, and A-133, issued by the United States Office of
Management and Budget, as applicable. If Grantee receives funds in excess of $500,000 in the
Grantee's fiscal year, Grantee will be subject to a federal A-133 Audit. Grantee is responsible for
notifying C4HCO in the event that grant funds will exceed the $500,000 threshold for the Grantee fiscal
year.
9. Financial Reporting Requirements:
A. On a monthly basis, beginning on August 15, 2013, for reimbursement the Grantee shall provide to
C4HCO an itemized statement of expenditures, and documentation of expenses showing how the funds
were expended for the preceding month. For prospective disbursement of funds, requests must be
submitted by the 15th of the month preceding the month for which funding is requested and
documentation of expenditures must be provided on the 15th of the month following the month for
which funding was disbursed.
B. The Grantee must provide C4HCO with any audited financial statements including
qualified/unqualified opinion with comments for any year in which C4HCO Grant funds are received.
C. When Grantee identifies a problem or barrier to meeting project timelines or deliverables, Grantee
shall notify C4HCO immediately. Notification shall include specific strategies to deal with or overcome
the problem or barrier and shall include any required revisions to the timeline, budget or deliverables.
Upon approval by C4HCO, the proposed revisions shall be incorporated as an update to Grantee's work
plan for its project. Until approval by C4HCO of any proposed revisions to the grant agreement or
timeline currently in operation, the Grantee shall be responsible for completing all timeline
requirements and objectives, as provided in that agreement, in a timely fashion.
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D. Continued funding for an awarded project is contingent on the Grantee meeting the goals and
objectives stated in the approved original or revised timeline and budget.
10. Failure to perform and corrective action: If it is apparent that the Grantee is failing to meet its
obligations under this Agreement, Connect for Health Colorado will provide notice of the identified
failure to the Grantee, an opportunity to establish a corrective action plan approved by Connect for
Health Colorado, and at least thirty (30) days to cure. Failure to cure will result in suspension or
cancellation of unpaid disbursements.
11. Reversion of Grant: Connect for Health Colorado may suspend or cancel unpaid disbursements if
Grantee becomes unable to carry out the purposes of the Grant or ceases to be an appropriate means
for accomplishing the purposes of the Grant based on, by way of non-exclusive example, the Grantee's
insolvency, receivership, bankruptcy, assignment for the benefit of creditors, or cessation of business on
a regular basis. In any such case, the Grantee shall, at a minimum, within thirty days after written
request by C4HCO, repay the portions of the Grant received but not disbursed, and all portions of the
Grant, which although disbursed, are within the Grantee's control.
12. Non -Discrimination: The Grantee may not discriminate against any employee or applicant for
employment because of race, color, religion, sex, national origin, sexual orientation, or any other
characteristic forbidden as a basis for discrimination by applicable laws, and certifies that its
Constitution or by-laws contains a non-discrimination clause consistent with all applicable law.
13. Title VI and ADA Compliance. Pursuant to 45 CFR 155.210(5), the Grantee and its Health
Coverage Guides shall at all times provide information in a culturally and linguistically appropriate
manner in compliance with Title VI of the Civil Rights Act of 1964 and shall ensure accessibility and
usability for individuals with disabilities in accordance with the Americans with Disabilities Act of 1990,
Section 504 of the Rehabilitation Act and 45 CFR 155.205(c).
14. Collusion or Other Offenses:
A. Neither the Grantee, nor any of its officers or directors, has engaged in collusion with respect to the
grantee's application for the Grant or this Agreement or has been convicted of bribery, attempted
bribery, or conspiracy to bribe under the laws of any state or of the United States;
B. The Grantee has not employed or retained any person, partnership, corporation, or other entity,
other than a bona fide employee or agent working for the Grantee, to solicit or secure the Grant or this
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Agreement, and the Grantee has not paid or agreed to pay any such entity any fee or other
consideration contingent on the making of the Grant or this Agreement:
C. The Grantee, if incorporated, is registered or qualified in accordance with the Colorado Secretary of
State's Office, and is in good standing, has filed all required annual reports and filing fees with all
applicable State, County, and/or other local governmental jurisdictional bodies;
D. No money has been paid to or promised to be paid to any legislative agent, attorney, or lobbyist for
any services rendered in securing the passage of legislation establishing or appropriating funds for the
Grant;
E. Neither the Grantee, nor any of its officers or directors, nor any person substantially involved in the
contracting or fundraising activities of the Grantee, is currently suspended or debarred from contracting
with the State or any other public entity; and
F. Neither the Grantee, nor any of its officers, directors, employees nor any other person substantially
involved in the contracting or fundraising activities of the Grantee is currently on the "List of Excluded
Individuals/Entities (LEIS) maintained by the Office of Inspector General of the United States
Department of Health and Human Services.
15. Conflict of Interest
A. Grantee affirms that Grantee and all of its employees are not any of the prohibited entities and will
not engage in any of the prohibited conduct specified in the Conflict of Interest Policy, Attachment 3.
B. Grantee will remain free of conflicts during the term of this Agreement. Grantee agrees that if an
actual or potential conflict of interest arises after the date of this Agreement, the Grantee shall
immediately make a full disclosure in writing to Connect for Health Colorado of all relevant facts and
circumstances. This disclosure shall include a description of actions which the Grantee has taken and
proposes to take to avoid, mitigate, or neutralize the actual or potential conflict of interest. If the
contract has been awarded and performance of the contract has begun, the Grantee shall continue
performance until notified by Connect for Health Colorado per the terms articulated in the Grant
Agreement of any further action to be taken.
16. Conduct, Roles and Responsibilities
A. Grantee agrees to ensure that the employees and volunteers under its supervision pursuant to this
Agreement will adhere to requirements as set forth at 45 CFR § 155.210 (e) and the role as defined in
the Funding Opportunity Announcement.
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B. Grantee will ensure that employees and volunteers under its supervision pursuant to this Agreement
will not represent or conduct themselves in such a way that violates State of Colorado law governing the
licensing and appointment of insurance producers, C.R.S. 10-2-401 et. seq.
17. General Reauirements:
A. The Grantee shall comply with the terms and conditions of the Connect for Health Colorado
Assistance Network, as set forth in the Connect for Health Colorado Assistance Network Funding
Opportunity, the Grantee's application including any subsequently submitted revised Scope of
Work as set forth and incorporated by reference as Attachment #1, and the terms of this
Agreement.
B. The Grantee shall conduct background investigations of its employees and volunteers
performing work related to this Agreement.
C. Grantee understands and acknowledges that under 45 CFR 92.34, the Department of Health
& Human Services (HHS) retains a royalty -free, nonexclusive, and irrevocable license to
reproduce, publish or otherwise use and authorize others to use, for Federal Government
purposes, the copyright in any work developed under a Federal grant, or a subgrant or
subcontract, and in any rights to a copyright purchased with grant support.
D. The Grantee shall comply with C4HCO's privacy and security standards as set forth and
incorporated by reference in Attachment 3 of the Agreement.
D. The laws of Colorado shall govern the interpretation and enforcement of this Agreement.
Any claim, action, suit or proceeding relating to this Agreement shall be brought in the
applicable State or Federal courts for the City and County of Denver, Colorado.
E. The Grantee may not sell, transfer, or otherwise assign any of its obligations under this
Agreement, or its rights, title, or interest in this Agreement, without the prior written consent of
C4HCO. This Agreement shall bind any respective successors and assigns of the parties.
F. No amendment to this Agreement is binding unless it is in writing and signed by both parties.
G. The following items are incorporated by reference and made a part of this Agreement.
Attachment 1: Grantee's Application and Budget Worksheet submitted in response to
Connect for Health Assistance Network Funding Opportunity Announcement, including
any subsequently submitted revised Scope of Work and revised Budget.
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Attachment 2: Privacy and Security Standards
Attachment 3: Conflict of Interest Disclosure and Statement
18 Non-availability of Funds: If third parties fail to make expected funds available (including funds
which may be received from the federal government) for the continued performance for any fiscal
period of C4HCO operations, this Agreement shall be canceled automatically as of the beginning of the
fiscal year for which funds were not appropriated or otherwise made available; provided, however, that
this will not affect either C4HCO's rights or the Grantee's rights under any termination clause in this
Agreement. The effect of termination of the Agreement hereunder will be to discharge both the
Grantee and the C4HCO from future performance of the Agreement, but not from their rights and
obligations existing at the time of termination. C4HCO shall notify the Grantee as soon as it has
knowledge that funds may not be available for the continuation of this Agreement
19. Acceptance of Terms and Conditions: This document shall be signed by an individual legally
authorized to execute contracts on behalf of the Grantee, signifying agreement to comply with all the
terms and conditions specified above.
The above terms and conditions of the grant are hereby accepted and agreed to as of the date specified:
For: Colo d ealt nefit Exchange
By:
Date: 9#1/040 43
For: COUNTY OF EAGLE, STATE OF COLORADO,
By an Through Its BOARD OF COUNTY COMMISSIONERS
By:
Sara J. Fisher, Ch irman
Date: elI�1
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Attachment 1
Grantee's Application
ezCOLORADO
HEALTH
BENEFIT
E X C H A N G E
CONNECT FOR HEALTH ASSISTANCE NETWORK
APPLICATION for FUNDING
Instructions: Please complete all fields of this application. If a question does not apply,
please indicate by typing "NA". For applicants who are applying as a partnership or
coalition, please select one organization to be the contact and fiscal agent, and please be
specific in your responses about which organization is performing which activity or role.
All applications must be typed and must not exceed 25 pages (not including attachments).
Please PDF applications and attachments as one document and submit by email to
grants(&cohbe.org. Applications are due no later than April 8th 2013 Al 5:00 PM.
Contact Information
If several organizations are applying as a partnership or coalition, please select one organization
to serve as the fiscal agent and contact.
Organization Name: Eagle County Health & Human Services
Organization Administrative Address: PO Box 660
City, County, State, Zip: Eagle, Eagle County, CO 81631
Phone Number: 970-328-8840 Fax Number: SSS -848-8828
Web Address: www.eaglecounty.us/HHS
Primary Contact: Kathleen Lyons Title: Economic Services Director
Primary Contact Phone: 970-328-8841
Primary Contact Email: kathleen.lyons@eaglecounty.us
Is your organization applying for funding? X Yes ❑ No
FEIN: 084024447
Is your organization a non-profit? ❑ Yes X No
If not, please describe your organization's tax status. Selected organizations will be asked to
provide W9. Local Government
Fiscal Officer Name (if different from primary contact): Rita Woods
Fiscal Officer Phone: 970-328-8817 Fiscal Officer Email: rita.woods@eaglecounty.us
Application for (select all that apply):
Regional Assistance HUB: ❑ Yes ❑ No
Assistance Site: X Yes ❑ No
Assistance Site with SHOP specialty: X Yes 17 No
Organizational Backel:ound
1. Please describe the organization's history and mission.
The West Mountain Region Health Assistance Network (WMRHAN) includes Eagle County
Health and Human Services (ECHHS), Pitkin County Health and Human Services (PCHHS),
Community Health Services, Inc. (CHS), Garfield County Public Health (GCPF), Garfield County
Human Services (GCHS), and Mountain Family Health Centers (MFHC), a Federally -Qualified
Health Center with clinical sites in all three counties. Eagle County will be the lead agency and
fiscal agent for the Network.
WMRHAN is an operational committee of the West Mountan Region Health Care Coalition
(WMRHCC), a larger ad hoc group formed three years ago to identify service gaps for the
medically -indigent in primary care, dental, and mental health and to plan for the
implementation of the Affordable Care Act. The Coalition convenes quarterly meetings of
regional HHS departments and public health agencies, hospitals, Colorado West Regional
Mental Health, and private human service non -profits providing safety net services in the
region.
All three counties are located within an area of the state known as the Rural Resort Region,
and have a long history of collaboration to address the unique demographics of our
populations, seasonal economies, and geographic challenges due to large size and
mountainous terrain. The role of geography cannot be understated; EI Jebel is in Eagle County
along the Roaring Fork River, but separated by a mountain range. The region experienced
shared significant challenges over the past decade with the doubling of the Hispanic
population and rapid growth of methane gas drilling operations.
The onset of the recession in 2008, which had devastating consequences for hospitality,
construction, and oil and gas businesses in the region, further motivated the counties to
strengthen and expand our partnerships to better serve residents by enhancing
communications, searching for economies of scale, and co -developing opportunities that are
conducive to bridging county lines. For example, the counties contract with one another for
certain services for Public Assistance, Child Support, Child Welfare, Adult Protection, and
Prenatal Services. Other partnerships include Emergency Preparedness and the Tobacco
Education, Prevention and Cessation program. MFHC has played a prime clinical role in many
of these collaborative efforts; for example, screening over 4,500 persons in the three country
region for cardiovascular disease from 2009 to 2011. Further, each of the counties has played
critical roles in the expansion of MFHC, making it the fastest growing rural health center in
Colorado and creating an efficient system of primary care for a large number of medically -
indigent and uninsured residents.
WMRHAN shares a mission to promote the health and well-being of all residents in the region
to ensure healthy children and families and a productive workforce. As such, we are
motivated and organized to maximize the COBHE initiative.
2. Please describe the type of work your organization performs and the services
provided.
Our Public Health and Human Service agencies provide a broad range of social and medical
services, including senior services, disease prevention and control, family planning,
immunizations, child support services, child services such as foster care, services for the
disabled and blind, Single Point of Entry for Long Term Care, Women, Infants and Children
(WIC) nutrition program, Veteran's Services, and public assistance programs, e.g., cash, food,
shelter, medical, energy and emergency services. MFHC provides comprehensive primary
care, including internal medicine, integrated behavioral health, and dental services.
3. Describe any experience the organization has with recognizing health coverage needs,
or assistance with applications for health coverage, or outreach and education.
All WMRHAN agencies have extensive experience in identifying and addressing health needs
through studies, needs assessments, and extensive participation in every major safety net
health inititative in the state, including tobacco cessation, disease prevention and screening,
as well as direct services delivery, such as prenatal care and immunizations. In collaboration
with other members of the regional coalition, we address all aspects of health, including
access to healthcare, nutrition, safety, environmental health, mental health and substance
abuse.
As the safety net agencies in our region, we are responsible for eligibility determination and
enrollment for residents in Medicaid, Food Assistance, TANF, and other financial assistance
programs, such as the Colorado Indigent Care Program and WIC. We have established
relationships with local businesses, churches, schools, and other non-profit human services
agencies with which our staffs work daily to disseminate information or convene communites
of interest, e.g., senior citizens, mono -lingual Spanish speakers, emergency assistance
providers.
4. Please describe the populations the organization currently serves (for example:
families with school -aged children, young adults, low-income families, businesses or
entrepreneurs, individuals with limited English proficiency, people with a particular
diagnosis or disability, people of faith, uninsured individuals, small employers or
workers of a particular industry, etc.). Please describe how many customers the
organization currently serves and in what geographic area.
WMRHCC agencies serve a large cross-section of the working poor, children, disabled persons
and seniors in the region. ECHHS serves 3,460 Medicaid clients (2,718 20 years of age (YOA) or
under and 742 21 YOA or older) and over 700 individuals through CHP+. In addition ECHHS
serves approximately 700 low-income households with food assistance benefits, 150 with
cash assistance benefits, and more than 1750 individuals per month with direct public health
services such as immunizations, family planning, WIC and Nurse Family Partnership program.
GCHS serves 7,663 Medicaid clients (5,203 20 YOA or under and 2,460 21 YOA or older) and
1,342 individuals through CHP+. In addition GCHS serves approximately 2,324 low-income
households with food assistance benefits and 309 with cash assistance benefits. GCPH serves
more than 1850 individuals per month with direct public health services such as
immunizations, prenatal case management, WIC, blood pressure screening and health
education. PCHHS serves 416 Medicaid clients (256 20 YOA or under and 160 21 YOA or
older) and 97 individuals through CHP+. In addition PCHHS serves approximately 150 low-
income households with food assistance benefits and 50 with cash assistance benefits. CHS
serves 200 individuals per month with direct public health services such as family planning,
WIC, immunizations, women's health screenings and HIV and STD testing. MFHC serves 9,375
patients from all three counties; 41% are 19 YOA or younger and 590A are 20 YOA or older.
Note that 52% are uninsured. These data reflect persons receiving direct services and do not
include a large number of residents whom benefit from various outreach and education
activities.
5. Please describe the geographic area you serve. If your organization is statewide,
please describe all the areas where you have a presence and the type of presence.
The members of WMRHAN serve Eagle, Garfield, and Pitkin Counties, which have a total
population of 125,743 residents dispersed over 5,620 square miles of mountainous terrain.
The major industries are tourism, hospitality, and methane gas drilling. The major population
centers are clustered in valleys along the north -south axis of 1-70 between Vail and Parachute
and the east -west axis of Highway 82 between Glenwood Springs and Aspen.
6. Is the organization a health plan? ❑ Yes X No
7. Is the organization a subsidiary of a health plan? ❑ Yes X No
8. Is the organization a member of a health plan association? ❑ Yes X No
9. Does the organization receive any type of funding from a health plan? ❑ Yes X No
a. If yes, please describe. Include the types of services funded by health plans and
whether or not funding is received for enrollment into health insurance.
N/A
10. Describe how you currently collaborate with other organizations or service providers
to provide service to your clients, to enhance service delivery, increase capacity,
facilitate information sharing, or to provider referrals.
WMRHAN agencies employ staff whose job it is to match clients to services available in
the region. But beyond these core service activities to individual clients, the individual
coalition members all have notable broad-based community involvement projects. For
example, the Garfield County LiveWell coalition is developing a public/private intiative to
address the availability of nutritious food, opportunities to exercise safely, e.g., bike paths
separated from automobile traffic for children to ride to school. Likewise, Eagle County
has established a Healthy Communities Coalition that is working to address areas such as
school/youth wellness, food policy, healthy aging, built environment and includes a
workplace wellness program underway with area businesses. Eagle and Pitkin Counties
established and lead the regional Coalition of Emergency Assistance Providers (LEAP) to
create a seamless network of emergency assistance services which maximizes available
resources. All three have worked closely with MFHC to secure financial commitments
from area hospitals to help support access to primary care for the uninsured. Similarly, all
of us are involved in the Roaring Fork Mid -Valley Coalition working with non-profit service
providers to match services to population centers and needs, and expand and promote
the 211 information and referral service to facilitate residents' access to services.
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11. Please describe your organizational leadership and management structure.
Eagle County is a government entity which is guided by the Eagle County Board of
Commissioners, composed of three elected members. The policies of the Board are
carried out by the County Manager. All departments heads, including the Director of
Health and Human Services, report to the County Manager. The HHS Economic Services
Director, who will supervise the project, reports to the HHS Assistant Executive Director.
Eagle County will assume fiscal and management responsibility for the project. WMRHAN
Advisory Committee will act in an advisory capacity to the Eagle County HHS Economic
Services Director to oversee the successful execution of the network assistance project.
The WMRHAN Advisory Committee includes the Eagle County HHS Economic Services
Director, Eagle County HHS Assistant Executive Director, Eagle County Public Health
Director, the Pikin County HHS Director, the Pitkin County Public Health Director, the
Garfield County Public Health Director, the Garfield County Human Services Director and
MFHC Executive Director. The Organizational Chart in Attachment 6 includes Eagle County
Health & Human Services, Eagle County Economic Services and WMRHAN.
Mal
If $ * • ! II ® It
Scope of Work
1. Describe how participating in the Connect for Health Assistance Network as an
Assistance Site or Regional Hub fits within the mission of your organization.
WMRHAN shares a mission to promote the health and well being of all residents In the region
to ensure healthy children and families and a productive workforce. Affordable insurance
removes a major obstacle to the working poor in our region. While the census -estimated
povery rate is low for this region of the state (12%), costs of living are much higher, for
example, the annual self-sufficiency standard in Eagle County for one adult and one
preschooler is 374% of the Federal Poverty Level ($54,994), compared to the Colorado
average of 251% FPL ($47,448). This is a major reason the Rural Resort Region has one of the
highest rates of uninsurance in the state. In addition, the high cost of living disproportinately
affects Hispanic/Latino households, whose reported median income is half that of non -
Hispanic households in the region.
2. Describe how the organization plans to conduct outreach and education to raise
awareness of the Exchange and new opportunities for coverage. Include activities such
as presentations, attendance at health fairs, or making print materials and advertising
available.
WMRHAN will use a variety of means to provide outreach and public education that helps
inform our communities about new opportunities for accessing health care coverage, and
assistance paying for health coverage, including:
1) Presentations and/or booths at back to school nights, health fairs, and health screening
events in which HHS agencies and MFHC participates throughout the region.
2) Presentations to civic and business organizations, church groups, Colorado Mounain
College campuses, and at individual businesses.
3) Public service announcements on the local radio stations and in print media.
4) Articles in various newsletters published and distributed by partner organizations.
5) Websites for the three county organizations and MFHC will each contain a page dedicated
to WMRHAN with a schedule of events and educational sessions, link to COHSE, and contact
information for the nearest HCGs.
6) Business networking events focused on Connect for Health Colorado in each county.
7) Work site presentations for small businesses, as requested.
Residents who are eligible for Medicaid and Exchange subsidies will look to HHS departments
for assistance accessing these programs. As the region's trusted safety net providers,
WMRHAN agencies are in daily contact, both in our offices and in the field, with the
populations targeted by COHBE. On a typical day, agency staff are giving presentations or
delivering services throughout the three counties. The non-WMRHAN field staff from our
departments will also be trained in basic health network assistance information and make
sure appropriate audiences receive brochures and contact information, thus augmenting the
efforts of the WMRHAN staff.
WMRHAN will coordinate activities with the major Chambers of Commerce in the region to
promote the exchange and SHOP; note the letters of support in the Attachments.
I Describe how your organization plans to conduct day to day in person assistance
activities with individuals, families, small employers and employees. Include
descriptions of activities like how appointments will be made, if the organization plans
to be mobile, and whether the organization plans to execute enrollment events.
Potential individual customers will call a central number in Eagle or send an email to a
centralized email address to obtain general information and schedule an appointment at any
WMRHAN assistance location. Walk-in customers will be accommodated at HHS and MFHC
locations as schedules allow, although scheduling an appointment will be strongly
encouraged. WMRHAN is already exploring the feasibility of providing an online scheduling
capability through Eagle County whereby customers could view the schedules at network
assistance locations.
SHOP activities will follow a sequence in which mobile SHOP -trained Health Coverage Guides
(HCGs) support small employers and their employees with education and information about
SHOP, assist employers with understanding contribution strategies and setting up plans, then
will be available to assist employees, at the site of employment or other Assistance Network
location, in enrollment and determining eligibility for subsidy support.
'Enrollment events will be scheduled, but details are not available at the time of this
submission.
4. Describe the target populations the organization plans to serve with public education
and in person assistance, whether adding Health Coverage Guide services will increase
the volume of customers served, how the organization plans to reach those
populations and respond to the increased workload (if applicable).
WMRHAN will focus our efforts on three populations: (1) Medicaid eligible, (2) Uninsured
individuals under 400% Federal Poverty Level (ages 0 — 64), and (3) small employers and their
employees. (Note: Data sources appear at the end of this section.) Individuals and families
who currently purchase insurance on their own will also be served if they request assistance
and capacity is available. Community education events will target these populations but be
open to the general public.
Medicaid Population - WMRHAN will provide information and enrollment services to a total
of 8,654 children and adults who are potentially eligible for Medicaid from Oct. 1, 2013 to
Oct. 14, 2014. This projection is based on the data in the table below, showing the total target
population for expansion for Medicaid in all three counties. The estimate includes those
Newly Eligible for Medicaid in 2014. It assumes a 90% penetration rate. Note: This chart
shows individuals. To determine the HCG hours needed to provide enrollment services to this
population, a household size of 2.5 members was applied the Parents + Kids 0-18 category
and the Adult category was calculated as individuals.
Subsidy/Premium Tax Credit Eligible Uninsured — WMRHAN will assist 3,470
subsidy/premium tax credit eligible uninsured persons with information and enrollment
services during the 1St Enrollment Period (Oct. 1, 2013 - Mar. 31, 2014). This forecast assumes
a 25% market penetration rate and average household size of 2.5 persons as shown in the
chart below. An additional 3,470 subsidy eligible uninsured persons will receive assistance
during the 2nd Enrollment Period (Oct. 13, 2014 — Dec. 7, 2014). Further, during the Non -Open
Enrollment Period (April 1, 2014 — Oct. 12, 2014) an estimated 1,388 persons will receive
enrollment assistance due to life changes, e.g., divorce. It is also anticipated that 50% of the
subsidy/premium tax credit population that enrolled during the 1St open enrollment period
will return during the 2"d open enrollment period for assistance with renewal.
Uninsured individuals (0-64)
under 400% FPL less New
Eligible for Medicaid from
above Individuals
Eagle 5821
Garfield 6489
Eagle
Garfield I
Pitkin
Newly Eligible for Medicaid in 2014
Parents + Kids 0-18
2004
2329
716
Adults*
2288
2003
275
Total by County
4292
4332
991
Total for Region
9615
Subsidy/Premium Tax Credit Eligible Uninsured — WMRHAN will assist 3,470
subsidy/premium tax credit eligible uninsured persons with information and enrollment
services during the 1St Enrollment Period (Oct. 1, 2013 - Mar. 31, 2014). This forecast assumes
a 25% market penetration rate and average household size of 2.5 persons as shown in the
chart below. An additional 3,470 subsidy eligible uninsured persons will receive assistance
during the 2nd Enrollment Period (Oct. 13, 2014 — Dec. 7, 2014). Further, during the Non -Open
Enrollment Period (April 1, 2014 — Oct. 12, 2014) an estimated 1,388 persons will receive
enrollment assistance due to life changes, e.g., divorce. It is also anticipated that 50% of the
subsidy/premium tax credit population that enrolled during the 1St open enrollment period
will return during the 2"d open enrollment period for assistance with renewal.
Uninsured individuals (0-64)
under 400% FPL less New
Eligible for Medicaid from
above Individuals
Eagle 5821
Garfield 6489
Pitkin 1 1573
Combined Total by Region 1 13,883
Small Businesses — WMRHAN SHOP guides will assist 1,100 small businesses with 2 to 50
employees. This forecast assumes 20% penetration rate, based on data in the chart below,
which includes all businesses with 5 to 49 FTE, plus 25% of small business with 1 to 4 FTE.
Eagle
2,283
Garfield
2,004
Pitkin
1,302
Total
5,589
Data Sources:
Newly Eligible for Medicaid and Under 400% FPL (2010 Small Area Health Insurance
Estimates, US Census Bureau)
Small Employers with 1 to 49 FTE (Colorado LMI Gateway website)
5. Please estimate how many customers does your organization plan to serve with
Health Coverage Guide services in a month (include current and new customers) and
in which geographic areas? If the organization plans on specializing in SHOP, please
include the number of small employers planned to be served in a month.
WMRHAN HCGs will assist an average of 1,132 individuals per month starting in October
2013. These will be distributed approximately 43% in Eagle, 46% in Garfield, and 11% in
Pitkin.
Lead HCGs will assist an average of 73 small businesses per month, distributed as described
above. These will be distributed approximately 41% in Eagle, 36% in Garfield, and 23% in
Pitkin.
6. Describe how the organization will ensure information and services are provided in a
fair, accurate, and impartial manner and why the organization feels it is important.
This will be accomplished in four ways: l) Including the requirement in the job description to
deliver the information in such manner, 2) Re-emphasize this requirement in all trainings,
meetings, and performance reviews, 3) Periodic random participation/supervision by the
MWRHAN Manager of Client -HCG encounters, and 4) the Support Specialist will administer a
standard, short questionnaire via phone to persons who have been in contact with HGCs to
measure customer satisfaction, including that they are receiving "fair, accurate, and
impartial' information. ECHHS and WMRHAN partners believe that individuals and families
are the experts in knowing what is best for their situation and that the role of the HCG is to
provide comprehensive information and assistance in enrollment.
8
7. How does the organization currently ensure it provides culturally and linguistically
appropriate services?
All the agencies in the coalition have had training in the provision of culturally and
linguistically appropriate services and currently provide services in that manner. Most
materials and presentations are available in both English and Spanish. Many
presentations are also provided in Spanish -only format for mono -lingual Spanish
residents; for example, MFHC hosts the American Diabetes Association's "Por to Familia"
program to teach self-management skills to Spanish speaking -only patients.
S. Describe the languages other than English spoken by staff.
The majority of line staff in all coalition agencies are bilingual English -Spanish. If awarded
the grant, some of the HCG positions hired will include staff who are bilingual English -
Spanish. There are provisions in the proposed budget to pay for translation services for
sign language or via phone for other languages other than English or Spanish, as needed.
9. Describe the additional services the organization provides that complement the
delivery of Health Coverage Guide Services. Please include the potential impact of
these complementary services and the potential number of clients benefitting from
the complementary services. See selection criteria chart for examples.
As stated in the first section of this grant, HHS agencies provide a broad range of social
and medical services, including senior services, disease prevention and control, family
planning, immunizations, child support services, child services such as foster care, services
for the disabled and blind, Single Point of Entry for Long Term Care, Women, Infants and
Children (WIC) nutrition program, Veteran's Services, and public assistance programs,
e.g., cash, food, shelter, medical, energy and emergency services. MFHC provides
comprehensive primary care, including internal medicine, integrated behavioral health,
and dental services. MFHC deals extensively with various private insurance programs and
routinely assists patients with benefits issues. All our agencies offer assistance applying
for assistance programs, education and health care literacy, mobile navigator services,
and telephone support.
10. If applying for Assistance Site with SHOP specialty please answer this question.
Otherwise, please type N/A. Describe the organization's current work providing
assistance to small businesses and the self-employed. Please describe the
organization's plan for also serving the employees of those employers.
WMRHAN members work on a daily basis with local employers and employees. For instance,
Eagle County works with the Vail Valley Partnership, the area's Chamber of Commerce, to
conduct worksite wellness programs. During the past six years, MFHC collaborated with an
number of businesses in the region to emplolyees for cardiovascular disease.
Mobile SHOP outreach staff will be available for presentations and individual enrollment
sessions at places of employment (when privacy and internet access is available).
11. Describe the organization's experience with providing quality oversight of programs,
feedback to stakeholders, and reporting.
9
Every agency in the WMRHAN presently reports to numerous boards of county
commissioners, boards of directors, state and federal agencies, and private foundations, such
as The Colorado Health Foundation. In recent years, reporting and accountability
requirements have steadily increased as budgets have tightened. All state and federal
programs now incorporate quality expectations and performance targets, e.g., rates of
Immunizations for 2 year olds. Human service programs are required to perform county level
auditing to assure the quality of the work within those programs. All members of WMRHAN
measure their performance against annual quantified goals, and have considerable
experience in collecting, consolidating and reporting information online or through printed
forms and reports.
StafHne
1. Please describe how the organization will staff Health Coverage Guides. Will the
organization use current or new staff? How many current and new full time equivalent
(FTE) Health Coverage Guides will the organization employ (or supervise if using
volunteers)? Where will each Health Coverage Guide be located?
Our staffing plan for Health Coverage Guides (HCGs) is based on two assumptions: 1) Most
enrollments will occur as households of an average of 2.5 persons, and 2) 90 minutes will be
required for 65% of the assistance sessions that will be with English speakers and 120 minutes
for 35% of sessions with Spanish -only speakers. The FTE requirement was calculated based on
man-hours calculated, the forecast number needing services and language mix of customers.
Based on the above, WMRHAN will hire 16 new FTE staff, including 3 Lead Health Coverage
Guides with SHOP and individual market skills, and 8 Health Coverage Guides (HCGs) focused
on the individual market, 1 Manager, 1 Supervisor and 1 Program Support technician and 2
Medicaid eligibility technicians. In addition,1 short term (30 -day) temporary human resource
specialist will be hired.
The HCGs will be based in the following locations and will travel throughout the region, as
needed to ensure a broad reach:
Eagle County: HHS offices in Eagle and EI Jebel (covering Vail, Avon, Edwards, Eagle, Gypsum,
EI Jebel, Basalt, Snowmass and Aspen)
Garfield County: HHS offices in Glenwood Springs and Rifle (covering Glenwood Springs,
Rifle, Carbondale, Parachute, New Castle and Silt)
In addition, an HCG will be on-site daily at MFHC clinics in Glenwood Springs, Rifle, Basalt and
Edwards.
2. Describe the organization's. recruitment and retention practices. If the organization is
hiring new staff or engaging new volunteers to serve as Health Coverage Guides,
describe the organizational approach and timing to recruiting and hiring staff or
volunteers.
10
Eagle County will hire and supervise all WMRHAN employees except 1 Medicaid Eligibility
technician who will be hired and supervised by Garfield County Human Services. Eagle County
provides a salary/wage that is competitive in both the public and private sectors, along with
an excellent benefit package, a robust wellness program and flexible work arrangements to
retain its employees. These effective retention strategies have kept the overall turnover rate
for at a low 7% for the past three years.
Preliminary job descriptions and salary levels have already been developed in the preparation
of the budget for this grant request. Upon notice of grant award, the job opportunities will
immediately be posted in all three counties, both online and in print media. The top priority
will be to hire the WMRHAN Manager so this person can take the lead in hiring the HCGs. The
goal is to get all the hiring completed by July so the HCG regional team could focus on training
and outreach from July through September 2013.
3. Describe the organization's plan for supervision and oversight of Health Coverage
Guides. Include the title of the supervisor or manager, the other duties the person is
responsible for within the organization, and the approximate portion of the
supervisor's time that is anticipated.
A newly -hired WMRHAN Manager, based at Eagle County HHS, will oversee activities and
report to the Eagle County Economic Services Director. The Manager will hire and oversee
the activities of the HCGs in all three counties, interface with COBHE and other pertinent
agencies, develop and implement a quality assurance plan, ensure adherence with program
requirements and budget, and coordinate and conduct community education activities. The
Manager will be assisted by a Supervisor and Program Support Specialist. The Supervisor will
supervise 2 Lead HCGs and 6 HCGs located in EI Jebel, Glenwood Springs and Rifle. The
Program Support Specialist will be responsible for customer service, scheduling, report
preparation, and logistical and marketing support to community education efforts. Each
county will have a Lead Health Guide, expert in both the individual and SHOP markets, who
will be located in the respective HHS office. Detailed duties for the non -Health Coverage
Guide positions can be found on the Personnel tab within the Budget Worksheet.
4. Describe the # of and titles of other staff expected to be used to support the work of
Health Coverage Guides and the approximate FTE's associated with their support.
Please also describe the other duties these persons serve.
Support positions include 1 FTE Manager, 1 FTE Supervisor, and 1 FTE Program Support
Technician. These positions do not have other duties outside those of the WMRHAN.
S. Does the organization currently require a background check of employees or
volunteers? If not, will the organization agree to facilitate background checks for
employees or volunteers working with COHBE system access?
Yes, all are subject to background checks.
11
6. Please describe how the organization will ensure employed or volunteer Health
Coverage Guides can meet certification requirements.
All members of WMRHAN routinely recruit and supervise employees who must competently
navigate complex eligibility and financial assistance programs. To accomplish this, employees
are carefully selected and receive extensive training. Project management will ensure that all
HCGs attend Hub and other trainings, which will be a requirement in the job description.
7. Does the organization have a nondiscrimination and inclusion policy? X Yes ❑ No
If yes, please describe, or include a copy as an attachment. If no, please explain.
This is a requirement of any agency receiving state or federal funding, as do all the agencies in
the WMRHAN.
8. How will the organization support Health Coverage Guides to provide appropriate
referrals for customers who have grievances, complaints, or with additional needs
outside the scope of the organization. Please describe any similar referral services the
organization currently provides.
HCGs will be trained to determine the appropriate referral based on the nature of the
grievance. If the issue involves billing, claims, and benefits, the person will be directed to the
insurance carrier. HCGs will also be able to identify complaints that can best be addressed by
the Department of Insurance, and will provide instructions how to contact it. If the grievance
pertains to a breach of confidentiality or inappropriate employee behavior, the grievance falls
within the purview of the Eagle County HHS Standards of Conduct. In such cases, the
grievance first goes to the WMRHAN Project Manager for resolution. If that is not
satisfactory, the grievance will then go to the Economic Services Director for further
consideration. Employees who violate the Standards of Conduct are subject to disciplinary
measures and termination.
Facilities
9. Does the organization have a Privacy and Security polity? X Yes ❑ No
a. If yes, please describe.
All WMRHAN agencies have policies regarding client confidentiality, building
securing, and information technology firewalls to prevent unauthorized access
to records, per various state and federal regulations. All ECHHS staff are
required to sign a Confidentiality Agreement annually.
10. Describe how the organization plans to comply with federal and state privacy
standards including controlling access to sensitive information, record storage and
destruction, monitoring of employees and vendors, and how incidents of breech in
privacy is reported. Please name who within the organization is responsible for
privacy and their title, or the name of the vendor contact if contracted.
All WMRHAN agencies routinely handle sensitive personal health and financial information
and conduct their activities under strict HIPAA rules and regulations. Any possible breach of
12
M
confidentiality will be reported to Jennifer Ludwig, Eagle County Public Health Director and
HIPAA Compliance Officer at 970-328-8819.
11. Please describe the days of the weeks and the hours that your organization plans on
having Health Coverage Guide service in each geographic location.
As described in Question #1 under "Staffing," fulltime HCGs will be based at HHS offices and
will be mobile and stationary, depending on demand, and be located at HHS offices in Eagle,
Aspen, Glenwood Springs, and Rifle. This distribution will be modified, if needed, based on
customer demand within the region.
HGC will be assigned to each MFHC site in Glenwood Springs (Garfield), Rifle (Garfield),
Edwards (Eagle) and Basalt (Pitkin/Eagle).
HGCs work normal office hours from 8 am to 5 pm. However, some HGCs will work flex hours
based on whether they are stationed all day in a particular location or attending a special
activity, e.g., health fair, after church gathering, back to school night.
12. Describe the spaces your organization plans to use to meet with individuals in person.
Is the space accessible under the Americans with Disabilities Act? If not, how do you
plan to provide reasonable accommodation to meet with people who cannot access
your facility?
All offices are in ADA compliant facilities. The HCGs will be located with other eligibility and
enrollment staff where there is ready access to phones, printers, document shredders,
facsimilies, and high speed internet connectivity. They will be in cubicles with soundproof
walls where clients will meet at a desk across from the HGC.
13. Does this space currently have access to computer, high speed internet, scanning,
phones service, and printing? If not, what is the time frame anticipated for the
organization implementing these capabilities?
Yes, all fixed sites have all these capabilities because they will be housed in government
and/or clinic sites with well developed infrastructures that address all these requirements.
The availability of these services at mobile locations will vary. However, all HCGs will be
equipped with WiFi enabled laptops, cel phones and secure broadband service.
14. Do you have the ability to respond to telephone and email inquiries within 1 business
day and to set up appointments for in person meetings? X Yes ❑ No
a. If no, please describe how the organization plans to respond to inquiries by
phone and email, and requests for appointments.
15. Describe how the organization is located in a place that is accessible for the target
population it plans to serve.
All the HCG locations are in public buildings conveniently located on main roads in high traffic
13
areas that are well known and frequented by the local population and served by public
transportation systems.
Regional Hubs
If applying for a Regional Assistance Hub please answer the following questions. Otherwise, type
N/A.
1. Please define the region you propose to serve and how you will ensure reach to
organizations in that area.
N/A
2. Describe the organization's experience with convening community partners for
education, resource sharing, networking, support, or outreach coordination.
N/A
3. Describe the organization's plan for convening health coverage guides for COHBE
trainings and other networking or support activities.
N/A
4. Describe the organization's plan for coordinating outreach and public education
opportunities in the region.
N/A
Additional Information
This is an opportunity to provide any additional information you would like to submit for
consideration.
8
❑ Attachment 1: 2 Letters of reference from clients or partner organizations
❑ Attachment 2: Completed Budget Worksheet
❑ Attachment 3: Most recent annual audited financial statement
❑Attachment 4: Most recent prepared interim financial statement
❑Attachment 5: Organizational operational budget for upcoming year excluding
Assistance Network activity or funding
❑Attachment 6: Organizational Chart showing existing organization and structure if
funded
❑ Attachment 7: Memorandum of Understanding if applying as partnership or coalition
❑ Attachment 8: Optional Attachments
14
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CONN ECT.HEALTH"vr
COLORADO
Connect for Health Colorado
Connect for Health Assistance Network
Funding Opportunity
Request for Application Revision
Eagle County Health & Human Services
May 24th, 2013
Submission Due Date June 10th, 2013
3773 Cherry Creek N. Dr. • suite 1015 • Denver, C080209. 720-496-2530 • connectforhealthco.com
Instructions................................................................................................................................................................. 3
New Information about the Connect for Health Assistance Network ............................................... 3
Termof the Grant................................................................................................................................................ 4
Performance Based Metrics and Evaluation............................................................................................4
Scopeof Work.......................................................................................................................................................4
HealthCoverage Guide FTE............................................................................................................................. 5
Administrative SuRport/Reception and Supervision FTE................................................................. 6
HubPersonnel.......................................................................................................................................................6
OtherPersonnel Costs.......................................................................................................................................6
Travel......................................................................................................................................................................... 6
Supplies.................................................................................................................................................................... 6
OtherExpenses..................................................................................................................................................... 7
Indirect..................................................................................................................................................................... 8
Contractual............................................................................................................................................................. 8
NotAllowed............................................................................................................................................................ 8
Revisionof Scope of Work.................................................................................................................................... 8
Revisionof Budget............................................................................................................................................... 11
2
The purpose of this Request for Application Revision is to provide Connect for Health
Colorado an opportunity to balance its geographic needs and funding approach for
implementing the Assistance Network after having undergone two levels of application
review and detailed budget analysis. Application revisions will allow Connect for Health
Colorado to work with applicants to modify scopes of work and budgets to fit within our
parameters.
The Request for Application Revision is also intended to provide applicants an opportunity
to refine their approach to the Assistance Network based on the new information provided
by Connect for Health Colorado, the needs of the organization, and other factors.
The Request for Application Revision is divided into 4 sections. The first section requests
information Connect for Health Colorado will use to prepare a grant agreement. The second
section is new information applied to all Applicants. The third section includes a request
for revisions to the Applicant's proposed scope of work. The last section is a request for
revisions to the Applicant's proposed budget. Responses must be submitted
to grants@connectforhealthco.com and must be submitted on this form with the
attached budget worksheet no later than June 10th, 2013. The budget worksheet does
include formulas. It is the responsibility of the applicant to make sure all formulas remain
intact. Please e-mail us with technology issues or other concerns as soon as they are
identified to grants Pconnectforheatlhco.com or call 720-496-2536.
Grant Agreement Information
To prepare grant agreements, please respond to the questions below:
1. Name of Authorized Signatory: Jon Stavney
2. Title of Authorized Signatory: Chairman, Eagle County Board of County
Commissioners
3. Legal form of (lead) Entity (ie tribal/gov't, corp, partnership, non-profit): Government
New Information about the Connect for Health Assistance Network
Connect for Health Colorado was fortunate to receive over 70 applications from community
organizations willing to provide education and in person assistance to individuals, families,
and small businesses throughout the state of Colorado. The availability of a variety of
locations and skilled organizations to serve the diverse needs of Coloradans will be an asset
to Connect for Health Colorado. However, due to budget considerations Connect for Health
Colorado is not able to fund the majority of proposals at the level of funding requested by
applicants. Because of significant variations in the way that applicants approached their
goals and budgets, and some advancement in Connect for Health Colorado's organizational
approach to outreach and evaluation, we are providing clarified definitions of services that
can be paid for through the Assistance Network Funding Opportunity and asking that
applicants modify their goals and budget requests accordingly. These definitions will allow
Connect for Health Colorado to further standardize the approach to using available funding
and reporting, while allowing individual applicants to retain creativity and flexibility in
their approach to service.
Term of the Grant
Connect for Health Colorado is requesting all applicants be prepared for an 18 month grant
term, July 1, 2013 -December 31, 2014. Please email grants@connectforhealthco.com or call
720-496-2545 for exceptions.
Performance Based Metrics and Evaluation
In addition to funding initially awarded through the revised application, Connect for Health
Colorado intends to create a mechanism under which we will allocate incentive payments
to organizations that demonstrate high performance. Incentive payments will only be
awarded after the initial open enrollment period, provided adequate funding is available to
Connect for Health Colorado. Performance metrics used to evaluate organizations are still
in development and are anticipated to use goals relative to all organizations while giving
consideration to the differences in geographic regions and population characteristics.
Connect for Health Colorado will use a variety of methods to conduct ongoing evaluation of
Assistance Sites including system reports, reports from Assistance Sites, site visits, and
surveys. This evaluation will help target additional training and support to organizations in
the Network and help identify best practices to inform future program development.
Organizations that do not demonstrate progress towards goals will be given an opportunity
to revise their strategy and goals. Consistent failure to progress towards goals could result
in loss of funding prior to the second enrollment period, October 15th -December 7th 2014.
Scope of Work
The Assistance Network is expected to provide outreach, education, and in person
assistance with affordability program applications and enrollment in health coverage. In
person assistance is expected to be primarily education for pre or post enrollment, and
assistance with online application submission, account management, and online health
plan enrollment.
4
We ask that applicants take this opportunity to re-evaluate the number of applicants you
propose to serve through outreach activities and in person assistance appointments.
Please consider some of the following factors as appropriate for your organization:
• Contributions of all partners participating in the application.
• The number of the applicant's current clients who are likely eligible to purchase
health coverage in Connect for Health Colorado and/or who are eligible for
premium tax credits (133-400% of the federal poverty level).
• The possibility of customer participation in available outreach and in person
assistance activities given the availability of other customer service channels like
the customer service center, brokers, the possibility of completing applications
online without assistance, and the possibility of completely forgoing coverage.
Connect for Health Colorado used as a reference the following report by Price
Waterhouse Coopers, http://www.pwc.com/us/en/health-
industries/publications/change-the-channel.jhtml#media-feature-2
• Variations in customer needs during and outside enrollment periods.
• Target audiences for health coverage through Connect for Health Colorado include
the uninsured, people without access to employer based coverage, people who
currently purchase coverage in the individual market, and small businesses.
• Audiences not likely to apply for health coverage through Connect for Health
Colorado include people eligible for insurance through an employer or eligible for
public health programs.
• While assisting individuals with affordability program applications, it is
acknowledged that some customers will discover they are eligible for Medicaid or
CHP+. Outreach and in person assistance with a 'no wrong door' approach is
expected.
While developing staffing plans and numbers served, please take into consideration
possible needs for flexibility to meet varying demands for outreach and in person
assistance throughout the term of the grant.
Health Coverage uis e FTE
Connect for Health Colorado assumes that Health Coverage Guide (HCG) FTE time will be
spent providing both in person assistance and outreach activities in a balanced approach
method such that outreach leads to and drives application assistance and enrollment.
Whether focusing on outreach or enrollment, all HCGs will receive the same training. One
HCG FTE is assumed to equal 40 hours per week for a total of 3120 hours in 18 months.
Reductions or increases in what Connect for Health Colorado can fund for HCG FTE per
applicant reflect the total available funding, proportionate to the population and uninsured
in a given geographic area, as well as the general target audience characteristics described
by the applicant.
Administrative Suppo / peep i n and Supervision FT
Connect for Health Colorado assumes that dedicated administrative and reception support
will be necessary for some applicants. The allowance for this support is to provide phone,
email, reporting, scheduling, ordering, reception, and similar assistance to customers and
HCGs.
There is also the assumption that dedicated and skilled supervision is required for Health
Coverage Guides and associated administrative support/reception staff. No more than 0.2
FTE per each HCG FTE will be allowed for administrative and supervision. Please specify in
the budget narrative whether supervisory staff will split time as a HCG providing direct
service or only provide oversight for direct service staff.
Hub Personnel
At least one FTE will be allowed for each Hub to facilitate their goals. Applicants including
plans for providing trainers or training support should specify how this resource will be
used throughout the grant term within their staffing plan. Please include narrative
description of which costs are Hub costs if also serving as an Assistance Site. Please specify
whether or not Hub staff will also provide HCG services as needed.
Other Personnel Costs
So that funding can be focused on in person assistance and education, only the above
personnel responsible for direct delivery of education and in person assistance can be
funded through the direct personnel allowance. Any other personnel cost must be
considered indirect expenses and subject to the 10% indirect expense limitation. No
funding from Connect for Health Colorado, direct or indirect, can be used for personnel
who are lobbyists.
"Urav l
Funding is available to help offset the costs of travel directly related to providing outreach
and in-person assistance, or other activities directly associated with services that support
the Assistance Network, such as supplemental training. This is particularly important for
applicants who are serving large geographic areas in rural and frontier areas of the state.
Supervisory travel is expected to be minimal. Travel for initial training will be reimbursed
outside this funding opportunity so do not include those costs in travel estimates. Connect
for Health Colorado requests that applicants use the most direct and efficient means of
travel to meet goals including traveling together, combining trips, and centralizing
activities where it makes sense. Metro area applicants should be reasonable in their travel
requests and use locations easily accessible to customers with the least cost for travel.
Travel for joint program goals, for instance mobile clinics, should be allocated
appropriately.
upplit"m
Mobile and reliable technology equipment will be essential to effective outreach and in
person assistance. The technology needs to support these activities are a high speed
internet connection, mobile computer device (such as thin client or laptop) with access to a
full internet browser, and possibly mobile printer with scanning function, and accessories
like keyboard, carrying case, locking device etc. Communication devices that are dedicated
to the program like cell phones and mobile internet devices are also allowed as supplies.
G
Applicants are expected to keep each new technology and communication set up below
$2000.
Office furniture items such as desks and chairs can only be allowed when unavailable from
existing office resources. Connect for Health Colorado does not anticipate the need for file
storage furniture as the application and enrollment process is primarily in person and
online. Printing by Assistance Sites is expected to be minimal and should not require direct
cost of office machinery.
General office supplies (examples: printer toner, pens, paper, sticky notes of all sizes,
staples, file folders) will be allowed in the budget as one line item and limited to no more
than $540/FTE/grant term.
Other Expenses
Connect for Health Colorado is conducting a broadcast media campaign throughout the
state in English and Spanish that includes television, radio, and print. For this reason the
allowance for advertising costs to Assistance Sites is expected to be minimal and primarily
used for local print advertising of services and events. There will be an opportunity to work
directly with Connect for Health Colorado for art file templates to be used with local print
vendors. Connect for Health Colorado will also work directly with Assistance Sites to
centralize social media advertising at no cost to the Assistance Sites.
Connect for Health Colorado will be using a print on demand vendor for ordering
brochures and flyers, with the opportunity for some customization, at no cost to Assistance
Sites. For this reason, brochure development and printing is not expected to be included in
Assistance Site budgets.
Interpretation services for customers with hearing impairment or for non-English speakers
will be available through Connect for Health Colorado at no cost to Assistance Sites. Only
applicants with access to interpretation services at a lower cost than $0.95/minute for
language interpretation services and $3.35/minute for video ASL interpretation will be
allowed interpretation costs.
Connect for Health Colorado recognizes that applicants currently use a wide variety of
software for scheduling and reporting. Unfortunately, funding cannot be allowed to
purchase improvements to existing programs unless the cost is minimal. Low cost
subscription services for virtual meeting and synchronized scheduling can be supported.
Connect for Health Colorado will provide reporting functions to Assistance Sites at no cost.
In addition to device costs listed in supplies, cell phone service costs and mobile internet
service costs can be considered for funding in the other area, but if used for other
programs, should be allocated proportionally.
Indirect.
Costs expected to be allocated proportionately to indirect expenses include personnel such
as management, human resources, finance, executive leadership, IT, auditors, and
7
maintenance. Insurance, rent, utilities, and communications systems like servers can be
included in indirect costs and should be allocated. Rent allocation should be based on total
organization square footage divided by FTE. Indirect expenses can be no more than 10% of
the total of the Personnel, Supplies and Other categories.
Contractual
Partner contracts for categories described above as HCG personnel, Admin/Supervisory,
associated travel, supplies, other, and indirect will be allowed to enhance outreach,
education, and in person assistance. Legal contracts related directly to implementing
Assistance Network activities can also be included at a maximum of $5,000.
Not. Allowed
Food, direct rent, policy or political activity, travel for initial training, consultants,
incentives, and recruitment fees cannot be allowed through this grant.
Revision of Scope of Work
Eagle County Health & Human Services
Connect for Health Colorado is pleased to offer Eagle County Health and Human
Services $750,000 to provide Health Coverage Guide services in Eagle, Garfield and
Pitkin counties. The reduced budget offer reflects our need to balance requests with
our available resources while trying to recognize the higher costs of providing
services in mountain and resort communities. We would like to work with you to use
the new budget worksheet to submit a final budget.
Please respond to the below prompts to describe your final work plan:
1. How many Health Coverage Guide FTE will be staffed within each geographic region
(for instance a location, city, county, or mobile region)
Eagle County Health & Human Services (ECHHS), as the lead and fiscal agentfor the
West Mountain Regional Health Assistance Network (WMRHAN), will employ 4 full-
time Health Coverage Guides who will be bi-lingual (English/Spanish). Each guide will
be mobile, having a primary location with an assigned coverage area. Each guide will
have 2 to 3 designated service locations with regularly scheduled appointments and
will be available on an as requested and as available basis to work in other community
sites/events within the coverage area. The locations will be:
➢ Eagle (Eagle County) - the HCG housed in Eagle at ECHHS will have a coverage
area encompassing the 1-70 corridorfrom Vail to Dotsero as well as outlying areas
of Redcliff on Hwy 24 and communities along the Colorado River Road such as
McCoy and Bond. Designated service locations currently identified are ECHHS
facilities in Eagle and Avon and Mountain Family Health Center in Edwards (when
opened). Other locations being considered are Vail Valley Medical Center in Vail
and Colorado West Regional Mental Health Centers in Eagle and Vail.
➢ Glenwood Springs (Garfield County) - the HCG housed in Glenwood Springs at
Garfield County Human Services will have a coverage area encompassing the Hwy
82 corridor from Glenwood to Carbondale (including the Town of Carbondale) as
well as communities along the 1-70 corridor west of Glenwood Springs to New
Castle. Designated service locations currently identified are Garfield County
Human Services, Mountain Family Health Center and Valley View Hospital, all in
Glenwood Springs. Another location being considered on a rotating basis is
Colorado West Regional Mental Health Center in Glenwood Springs.
➢ Rifle (Garfield County) - the HCG housed in Rifle at Garfield County Human Services
will have a coverage area encompassing the I-70 corridor from New Castle to
Parachute. Designated service locations currently identified are Garfield County
Human Services, Mountain Family Health Center and Grand River Hospital, all in
Rifle. Another location being considered on a rotating basis is Colorado West
Regional Mental Health Center in Rifle.
➢ El Jebel (Western Eagle County & Pitkin County) - the HCG housed in El Jebel at
ECHHS will have a coverage area encompassing the Hwy 82 corridor from
Carbondale to Aspen. Designated service locations currently identified are ECHHS
in El Jebel, Mountain Family Health Center in Basalt and Pitkin County Health &
Human Services in Aspen. Another location being considered is Aspen Valley
Hospital in Aspen
In addition, the Health Assistance Network Manager, based in Eagle, will serve as HCG
for approximately. 60 FTE. This position, across the entire 3 county region, will fill in
as needed for the 4 primary HCGs, provide services to community partner locations as
requested, provide coverage of "overflow" if the need in a particular area is higher
than anticipated, and conduct outreach and public education presentations/events.
All HCGs will provide individual market as well as SHOP services.
2. Please describe how the proposed Health Coverage Guide FTE would be staffed
within each geographic region listed, and for each contracted partner. If the
organization(s) will provide in kind FTE, please separate that number here and
describe how that staff would be used in each geographic region.
4.0 FTE Health Coverage Guides, the 1.0 FTE Health Assistance Network Manager
(including .60 HCG FTE) and a.40 FTE Program Support Technician will be new hires
for ECHHS. These positions will be geographically located as outlined in #1 above and
on the attached organizational chart. The Program Support position will be located in
Eagle at ECHHS. There are no contracted partners or in-kind FTE.
3. Please describe how the proposed Health Coverage Guide FTE will be used to
provide outreach and in person assistance. Please include plans for staff activities
throughout the term of the grant that reflects balancing outreach and in person
assistance as well as the possibility of seasonal changes in staff levels.
Outreach and education that helps inform our communities about new opportunities
for accessing health care coverage and assistance paying for health coverage will
include:
➢ Centralized webpage that can be accessed through the three county organizations
and Mountain Family Health Center websites.
➢ Presentations and/or booths at back -to -school nights, health fairs and health
screening events throughout the region.
➢ Presentations to civic and business organizations, church groups, Colorado
Mountain College campuses and at individual businesses.
➢ Public service announcements on the local radio stations and in print media.
➢ Articles in various newsletters published and distributed by partner organizations.
➢ Business networking events focused on Connect for Health Colorado and SHOP
services in partnership with the local Chamber of Commerce in each county.
➢ Work site presentations for small businesses as requested.
➢ Provide basic health assistance network information training to community
partners including outreach materials and contact information to ensure
community partners are able to connect their customers with health assistance
network services
The Health Assistance Network Manager will be responsible for coordinating outreach
and public education. A focus on outreach will occur during the months ofAugust,
September and early October 2013. Each HCG FTE (total 4.56 FTE) will be responsible
for both outreach/education activities and providing in-person assistance. During
open enrollment periods, the proposed in-person assistance schedule for each HCG
allows approximately 6-8 hours per week to be in the community, either attending a
community event, presenting to communitygroups or connecting with community
partners to identify events, presentation opportunities or scheduling and planning
such events/presentations. During non -open enrollment periods, time available for
outreach will be increased.
In person assistance will be provided from October 2013 through December 2014 in
several ways:
➢
Face-to-face scheduled appointments at designated service locations (and walk-in
appointments as the schedule allows).
➢
Face-to-face scheduled appointments at various community partner locations (and
walk-in appointments as the schedule allows).
➢ Face-to-face appointments at various community events.
➢
Face-to-face appointments as scheduled with small businesses at the business site
or other location. These appointments will support small employers in
understanding contribution strategies and setting up plans and to assist employees
in enrollment and eligibility determination for subsidy support.
➢ Each HCG will have a published phone number within their coverage area to
respond to phone inquiries and to schedule appointments.
➢ Web -based appointment scheduling system that can be accessed by customers
through a centralized website
➢ Centralized email address to provide general information and schedule an
appointment.
10
4. In the below form, please use reasonable scope of work definitions above to
estimate your goals:
In Person Assistance: based on funded HCG
FTE, estimate number of unique encounters
(new customer served or new issue for
existing customer)
July 1, 2013 -March 31, 2014:
2,000
April 1, 2014 -September 30, 2014:
1,875
October 15, 2014 -Dec 31, 2014:
750
Total estimated unique in person appointments:
4,625
*Note: these numbers include individuals,
households (with an estimated average of 2.5
members per household) and small businesses.
In Person Assistance: If providing in kind
HCG FTE, based on all available HCG,
estimate number of unique encounters (new
customer served or new issue for existing
customer)
July 1, 2013 -March 31, 2014:
N/A
April 1, 2014 -September 30, 2014:
N/A
October 15, 2014 -Dec 31, 2014:
N/A
Total estimated unique in person appointments:
N/A
Outreach/Education: estimate number of
people reached through direct contact
outreach/education strategies (direct staff
interaction with customer in group or event
setting, for instances number of attendees at
presentations or number of people
interacting at event)
July 1, 2013 -March 31, 2014:
3,500
April 1, 2014 -September 30, 2014:
3,500
October 15, 2014 -Dec 31, 2014:
500
Total estimated direct outreach contacts:
7,500
Revision of Budget
Eagle County Health & Human Services
Maximum Budget Amount: $750,000.00
On the form attached to the Application Revision email, please provide information
about how you will use your available budget. Please check that changes to the form
have kept formulas intact.
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21
Attachment 2
Privacy and Security Standards
Grantee shall:
(a) Not use or disclose C4HCO information other than as permitted or required by the Agreement or as
required by law;
(b) Use appropriate safeguards, and comply with or exceed C4HCO supplied policies and guidance with
respect to C4HCO information, to prevent use or disclosure of information other than as provided for by
the Agreement;
(c) Report to C4HCO any use or disclosure of C4HCO information not provided for by the Agreement of
which it becomes aware, including breaches of unsecured C4HCO information, and any security incident
of which it becomes aware;
(d) If applicable, ensure that any subcontractors that create, receive, maintain, or transmit C4HCO
information on behalf of the Grantee agree to the same restrictions, conditions, and requirements that
apply to the f Partnerl with respect to such information;
(e) Maintain and make available the information regarding accounting of disclosures; and
(f) Make its internal practices, books, and records available to C4HCO for purposes of determining
compliance with the C4HCO Polices and Guidance.
6
Attachment 3
Conflict of Interest Policy
Connect for Health Assistance Network: Conflict of Interest Framework for
Assistance Sites and Health Coverage Guides
Revised May 2013
It is Connect for Health Colorado's intent that the Connect for Health Assistance Network Program
provides Exchange customers with impartial, high quality, community based education and information,
and in-person assistance. In order to assure the delivery of high quality services, to minimize or
eliminate the existence of conflicts of interest and ensure the integrity of the program Connect for
Health Colorado will'
1. Monitor for potential conflicts of interest during the Assistance Site and Regional Hub selection
process and throughout the term of engagement with the Assistance Site or Regional Hub.
2. Provide robust initial and ongoing training that includes instruction on providing impartial
education and in person assistance with customer selection of a qualified health plan.
3. Require from Assistance Sites, Regional Hubs and Health Coverage Guides disclosures of
affiliations that may present a direct or indirect conflict of interest.
4. Monitor Health Coverage Guide enrollment practices through use of reporting in Connect for
Health Colorado's system.
5. Monitor Health Coverage Guide conduct through feedback tools on Connect for Health
Colorado's website and through use of qualitative and quantitative evaluation tools like secret
shopping.
6. Actively solicit customer satisfaction feedback on their experience working with Health
Coverage Guides.
7. As circumstances command where a conflict of interest arises, require mitigation, revocation of
certification, or termination of the grant.
1. Prohibition on conduct
1.1. As required by 45 CFR 155.210 (d) a Navigator [Health Coverage Guide] or Navigator entity
[Assistance Site or Regional Hub] must not:
1.1.1.Be a health insurance issuer or issuer of stop loss insurance
1.1.2.Be a subsidiary of a health insurance issuer or issuer of stop loss insurance
1.1.3.Be an association that includes members of, or lobbies on behalf of, the insurance
industry; or
1.1.4.Receive any consideration directly or indirectly from any health insurance issuer or issuer
of stop loss insurance in connection with the enrollment of any individuals or employees in
a QHP [qualified health plan] or non-QHP [qualified health plan].'
1 The comments in the final federal regulations state, ""consideration," as used in § 155.210(d)(4) of the final rule,
should be interpreted to both mean financial compensation—including monetary or in-kind of any type, including
grants—as well as any other type of influence a health insurance issuer could use, including but not limited to
things such as gifts and free travel, which may result in steering individuals to particular QHPs offered in the
Exchange or plans outside of the Exchange."" Patient Protection and Affordable Care Act; Establishment of
Exchanges and Qualified Health Plans; Exchange Standards for Employers; Final Rule and Interim Final Rule,"
Federal Register 77:59 (March 27, 2012) 18333. Connect for Health Colorado thus interprets the words "indirect
1.2. A Health Coverage Guide, Assistance Site or Regional Hub must not:
1.2.1. Be a provider entity (including, but not limited to, hospitals, clinics, and physician
practices) that is directly owned by, a subsidiary of, or exclusively contracts with, a single
insurer or its subsidiaries, except in cases where the provider can demonstrate that due to
geography or other factors, there are significant limitations on available insurers with
whom to contract.
1.3. Receive any consideration directly or indirectly from any health insurance producer in
connection with the enrollment of any individuals or employees in a QHP [qualified
health plan] or non-QHP [qualified health plan].
2. Health Coverage Guide conflict of interest
2.1. A Health Coverage Guide shall not allow any philosophical, professional or personal financial or
non-financial interests to influence or appear to influence the ability of the Health Coverage
Guide to perform his/her duties impartially.
2.2. Health Coverage Guides shall disclose to Connect for Health Colorado and to customers
personal and professional financial and non-financial interests that may present a conflict of
interest.
2.3. Health Coverage Guides shall attest that they are not a prohibited entity or employed by a
prohibited entity as described in Paragraph 1.
2.4.
2.4.1.Health Coverage Guides shall not receive direct or indirect consideration from any health
insurance issuer in connection with enrollment of individuals or employees.
2.5. Health Coverage Guides shall not charge for their services.
2.6. Health Coverage Guides shall provide to customers impartial information about all plans for
which customers are eligible and shall not allow personal or professional interests to influence
the customers' decisions. In an effort to maintain impartiality in providing assistance:
2.6.1.Health Coverage Guides must not in any way solicit or persuade customers to enroll in any
specific health insurance plan.
2.6.2.Health Coverage Guides must not in any way solicit or persuade customers to switch from
one health insurance issuer to another.
2.6.3.Health Coverage Guides must not in any way persuade or compel customers to select a
particular provider, but may assist a customer in locating or selecting a provider.
2.6.4.Health Coverage Guides must not in any way solicit or persuade customers to engage a
particular agent or broker, but may assist a customer in locating or selecting a broker.
2.7. Health Coverage Guides shall not use their role as a Health Coverage Guide for lead generation
or profit.
2.8. Health Coverage Guides shall adhere to Connect for Health Colorado monitoring and evaluation
requirements.
3. Assistance Site and Regional Hub conflict of interest
3.1. An Assistance Site or Regional Hub shall not allow any philosophical, financial or non-financial
interests or affiliations to influence or appear to influence the ability of the Assistance Site to
impartially deliver Health Coverage Guide services or assure that the Health Coverage Guides
consideration" to mean in-kind compensation and other types of influence as stated above. Connect for Health
Colorado further interprets this provision to say that Health Coverage Guides and Assistance Sites cannot receive
compensation (cash or in-kind) for enrollment.
12
4
employed, contracted or otherwise supervised by the Assistance Site are able to impartially
perform their duties as Health Coverage Guides.
3.2. Assistance Sites and Regional Hubs shall disclose to Connect for Health Colorado and to
Connect for Health Colorado customers all philosophical, financial and non-financial interests or
affiliations that may present a conflict of interest, including professional relationships between
the entity and any health insurance issuer.
3.3. Assistance Sites and Regional Hubs shall not be any of the prohibited entities described in
Paragraph 1.
3.3.1. Assistance Sites and Regional Hubs shall disclose to Connect for Health Colorado and
customers all relationships with prohibited entities as described in paragraph 1.
3.3.2.Assistance Sites and Regional Hubs receiving any cash or in-kind compensation from health
insurance issuers shall disclose to Connect for Health Colorado and customers the nature
of the compensation, what the compensation is intended to support, and from whom it is
received.
3.4. Assistance Sites and Regional Hubs shall not direct or permit Health Coverage Guides to solicit
or persuade customers to enroll in any specific health insurance plan, switch from one carrier
to another, or select a particular provider.
3.5. Assistance Sites and Regional Hubs shall not charge for Health Coverage Guide services or
otherwise utilize the Assistance Program, or their association with the Assistance Program for
lead generation or profit.
3.6. Assistance Sites and Regional Hubs shall not utilize interests or affiliations for purposes of
soliciting or persuading customers to enroll in a specific health insurance plan, switch from one
plan to another, or to select a particular provider.
3.7. Assistance Sites and Regional Hubs shall monitor Health Coverage Guides they employ, contract
with or otherwise supervise for fair and impartial performance of Health Coverage Guide
duties.
3.8. Assistance Sites and Regional Hubs shall adhere to Connect for Health Colorado monitoring and
reporting requirements.
13