By now we know people will need information and assistance to find and enroll in the right health coverage for them under the Affordable Care Act (ACA). But there has been some confusion about the different roles consumer assisters can play as the ACA rolls out this October. In a previous post , we clarified the various kinds of consumer assistance in the ACA. While states and the federal government are actively developing programs for Navigators and in-person Assisters, less information has been available about Certified Application Counselors (CACs). And though we’ve seen little information previously about the training for all consumer assisters, recent regulations provide more details about how the Navigators, in-person Assisters and Certified Applications Counselors will operate. Here, we provide some information from those rules about training and certification requirements for different consumer assisters.

Clarifying CACs

In states with limited resources for providing consumer assistance, CACs are another option to help people understand and enroll in coverage through the ACA. When we last heard about CACs, there were still a number of missing details. But this final regulation fills in many of the blanks. First, while CACs cannot be paid by Marketplace dollars, the regulation does encourage other funding methods, like public and private sponsors. In addition, the rule reinforces the concept that CACs may have conflicts of interest – they may be funded by insurers or providers. However, they must disclose these conflicts to consumers in plain language. And in a win for consumers, CACs are required to provide information on the full range of health plan options, and not just those plans that they might receive payment from.

While CACs are not required to have as significant training as Navigators, it appears that they could choose to take the entire Navigator training course. Some people have asked, “Why would anyone become a CAC?” Given financial limitations, not everyone will be chosen to become a Navigator. And some organizations may want training without taking on the full range of Navigator duties. A person can only receive the seal of approval to assist consumers by becoming certified as a CAC through a Marketplace. HHS will post a public registry of all forms of assistance available to consumers, but will only include those that are certified.

Talking about training

Like other parts of the ACA, training programs depend on the type of Marketplace (formerly known as Exchange) in your state. States running their own Marketplace will create their own training for Navigators and other assisters, but that training must include a number of topics required by Centers for Medicare and Medicaid Services (CMS), including tax credits, Medicaid and CHIP enrollment, and working with vulnerable populations. States can pull from (or use wholesale) the HHS-developed training, or develop their own. States also can choose to use the same training materials for all types of assisters, even though CACs are not required to have as many hours of training.

For all other states, HHS will run the training  for Navigators and CACs. And in a positive turn, that training will also be open to the general public. HHS realizes that some organizations or community leaders may want to understand enrollment processes for ACA affordability programs without becoming an official assister. The training will be available online and at no cost, and also be open to people in State-based Marketplace areas. While the training is open to all, a person must become officially certified by the Marketplace to be considered an official CAC.

Now that we have more information, it is time for organizations to determine the best way they can get involved with enrollment. One thing remains certain: We will need many advocacy organizations and their partners to get up-to-speed on financial assistance programs and do what they can to help spread the word about enrollment in the ACA come October. Visit and stay tuned for more resources and tips from Community Catalyst.