Direct Enrollment Integration with Federally Facilitated Marketplace: An Overview

One of the questions many payers are wrestling with as they prepare to participate in the Federally Facilitated Marketplace (FFM) is whether they should undertake to integrate their own online shopping experiences with the FFM's site and, if they do, whether they should use the simpler "Lead Generation API" model or the more complex full integration model. When you break it down there are really four options:

Option 1: No Integration 

In this model, the payer assumes that subsidy-eligible consumers will find their own way to the FFM site if they want to take advantage of a subsidy. The payer's site is assumed to be used only by those who are not eligible or not interested in a subsidy and provides no features to help shopper understand subsidy options.

Pros: 

• The simplest and cheapest to implement (in fact, no action required) and avoids confusing shoppers and introducing the risk of their considering competitors products. 

Cons: 

• Subsidy-eligible consumers who might otherwise purchase one of your plans may go to the FFM to get their subsidy and in the process pick a competitor's product.
• Risk of consumer dissatisfaction if they later discover they are eligible for a subsidy or don't understand their options

Option 2: Offramp to FFM For Subsidy Eligible Shoppers

In this model, the payer provides information to consumers about the subsidies they might be eligible for and redirects, if they want to determine whether they are eligible, redirects them to the FFM through a simple link. 

Pros: 

• Very simple and inexpensive to implement (just some text and a link)
• Helping consumers discover subsidies they are eligible may increase the likelihood they will purchase a product from you

Cons: 

• Redirects potential subsidy-eligible consumers to the FFM, where they may select competitors products regardless of whether they qualify for a subsidy or not 

Option 3: Fully-Integrated Shopping Experience

In this model, consumers who come to  your site can shop for and enroll in your Qualified Health Plans without ever being exposed to competitor products. The shopper is redirected to the FFM web site to apply for a subsidies and determine whether they are eligible for one, but then they are returned to your website to complete the plan selection and enrollment process.

Pros: 

• Subsidy-eligible consumers are never exposed to your competitors' products
• Apart from the subsidy application, you control the entire shopping experience
• Supports marketing efforts to drive subsidy-eligible consumers to your site to purchase plans and to follow up through offline channels to complete abandoned sales

Cons: 

• Most expensive and technologically complex approach
• Requires a rather clunky back-and-forth bouncing between your website and the FFM's
• High implementation risk due to the complex integration and newness of the FFM's API technology

The Fully-Integrated Shopping Flow for a New Individual (from CMS Web Broker API Overview)

Option 4: Lead Generation API
This option is a bit of a compromise, allowing issuers to control the plans their potential customers see but still redirect them to the FFM so that they can get their subsidies and enroll in the plan. This is a handoff of a potential customer from your site to the FFMs, where they will complete the entire rest of the shopping and enrollment process. But, you are able to specify up to 10 of your products to be displayed to the shopper when they are selecting plans on the FFM. The shopper would have the ability to clear the filter and see other plans if they like, but in their initial view they will see only yours.

Pros: 

• Drastically reduced cost of development, integration, and testing compared to the Fully-Integrated Shopping Experience
• Removes the complexity of abandoned shopping sessions and returning shoppers, exception handling, etc.

Cons:

• Shoppers will have the ability to unfiltered their plan listing and view competitors' products once they are on the FFM site, so there is a chance they may shop for competitors products
• You lose control of the rest of the shopping and enrollment experience, which may make it difficult to conduct typical sales activities such as following up via telesales with consumers who began the enrollment process but abandoned it.
• Because the transaction is completed through the FFM, there's a risk of losing brand loyalty

Which of these approaches is right for your organization? It depends greatly upon your go-to-market strategy for your Qualified Health Plans and your on-Exchange/off-Exchange marketing approach. We'll look at those considerations in an upcoming post.