Direct Enrollment & the Federally Facilitated Marketplace: the Risks

Last time around, we took a look at the four options payers have when it comes to integrating their own consumer shopping portals with the Federally Facilitated Marketplace (FFM), formerly known as the Federally Facilitated Exchange (FFE). Which is in no way affiliated with the Future Farmers of America (FFA).

At first blush, the Fully-Integrated model may seem like the best option because of the control it gives payers over their customers' shopping experience and their brand. But, it is technically complex to implement and poses quite a number of implementation risks. Here are just a few of the immediate risks that I can see to the approach, which leverages an evolving Direct Enrollment Application Programmatic Interface (API) that is still under development by the FFM. 

Seven Risks

1. Complexity of Integration: The integration pattern the FFM has defined is complex, requiring two web session transfers (first from the issuer site out to the FFM's and then from the FFM's back to the issuer) and two web services calls from the issuer to the FFM/Data Hub, the first to retrieve household and subsidy information for the applicant and the second to submit the enrollment once complete.

2. A New, Untested API: Real-time integration between two systems can be challenging in their own right, but in this case we are dealing with a brand new system being developed against an aggressive timeline and an integration pattern that has not been attempted before. The newness alone raises a considerable risk of bugs and errors in the web services and redirect.

3. The Test Pool Is Crowded: The biggest  challenge in system integration is generally the coordination, testing, and triaging of issues between the two supporting parties—that is, when an exception occur, tracking down which system is responsible and determining the root cause. In this instance, it's not two organizations alone attempting to implement an integration but potential a large number of parties attempting to integrate with the FFM all at the same time, which only raises the risk of delays in testing and working through issues

4. Multiple Browser Windows: The FFM's integration pattern calls for the FFM's web pages to open in a new browser window from the one used to navigate the issuer's site, which from a user experience perspective is less than ideal.

5. Impact on Issuer's Shopping Portal Flow: To implement the full direct enrollment pattern, an issuer would need to update their own shopping experience to take into account the APTC's and CSR's from the subsidies in the experience (for example, when displaying premiums to users) as well as handle the more complex enrollment scenarios of dual-taxpayer households. In other words, the development effort is not just in the bouncing out and bouncing back from the FFM site but in fact changes the overall shopping experience.

6. Brand & Customer Satisfaction: When a user's shopping experience begins on the payer's site but bounces out to the FFM, the user is quite likely to associate any problems or issues incurred on the FFM's site with the issuer itself, putting at risk the issuer's brand and customer satisfaction if there are problems on the FFM's end

7. Can I Come Back Later? The complexity of the integration is compounded by the functionality needed to handle a shopper who doesn't complete the process in a single web session. Because of the complexity of the information required for the APTC/CSR application process, it is quite likely that users will "save and come back later." The issuer's web site will need to be able to handle those situations and all the various user paths: e.g. What happens if they come back to the issuer's website when they are ready to continue? What if they return to the FFM's site?

Considerations

These are some significant risks, and each payer will have to decide for themselves if the rewards are worth the risk and expense of the fully-integrated model. Because Exchanges and QHPs are brand new, there is not solid track record or set of best practices to draw upon to understand consumer behavior when it comes to shopping for insurance with government subsidies.

In my view, brokers with automated sales systems have much more to gain from the integration than payers do, and it would be perfectly understandable for payers to decide that they'll let other organizations be the crash test dummies and work out all the kinks and implement their own integrations later if they prove valuable.

But, it may well be worth the risk for your organization to get out ahead of the pack. We'll look at some of those considerations next.

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.