CMS-10463 - Navigator FOA Supporting Statement 7-9

Supporting Statement – Part A
Cooperative Agreement to Support Navigators in Federally-facilitated and State Partnership
Exchanges
A. Background
On March 23, 2010, the President signed into law the Patient Protection and Affordable Care Act. On
March 30, 2010, the Health Care and Education Reconciliation Act of 2010 was also signed into law.
The two laws collectively are referred to as the Affordable Care Act.
The Affordable Care Act creates State-based health insurance Exchanges, new competitive marketplaces
where consumers and small businesses can purchase private health insurance. Consumers who access
health insurance coverage through Exchanges will be able to receive direct assistance from Navigators
authorized to help consumers through the registration, eligibility determination, and plan selection process
as they enroll in the Exchanges.
Section 1311(i) requires that an Exchange establish a Navigator Program under which it awards grants to
individuals or entities who satisfy the requirements to be Exchange Navigators. Navigators will assist
consumers by providing education about and facilitating selection of qualified health plans (QHPs) within
Exchanges, as well as other required duties. For Federally-facilitated Exchanges (FFE) and State
Partnership Exchanges (SPEs), CMS will be awarding these cooperative agreements.
Once grants are awarded, Navigator awardees will be required to carry out the duties described in Section
1311(i)(3) and 45 C.F.R. §155.210(e) to assist consumers and employees seeking health coverage in FFEs
or SPEs. Awardees shall:


Maintain expertise in eligibility, enrollment, and program specifications and conduct public
education activities to raise awareness about the Exchange;



Provide information and services in a fair, accurate, and impartial manner. Such information must
acknowledge other health programs (such as the Medicaid program and Children’s Health
Insurance Program (CHIP));



Facilitate selection of a QHP;



Provide referrals to any applicable office of health insurance consumer assistance or health
insurance ombudsman established under Section 2793 of the PHS Act, or any other appropriate
State agency or agencies, for any enrollee with a grievance, complaint, or question regarding their
health plan, coverage, or a determination under such plan or coverage; and



Provide information in a manner that is culturally and linguistically appropriate to the needs of
the population being served by the Exchange, including individuals with limited English
proficiency, and ensure accessibility and usability of Navigator tools and functions for individuals
with disabilities in accordance with the Americans with Disabilities Act and section 504 of the
Rehabilitation Act.

Navigator awardees must provide quarterly and final (at the end of the 12-month cooperative agreement

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period) progress and quarterly financial reports to CMS.1 Navigators will submit quarterly and final
progress reports to CMS electronically via a format provided to awardees by CMS. Due dates for these
progress reports will be provided to grant recipients in the Notice of Award.
Each awardee must submit quarterly financial reports of cash transactions to CMS within 30 days after
the end of each quarter via the Federal Payment Management System (PMS). A final report on
expenditures and any program income generated will be submitted by Navigator awardees on a hard-copy
Federal Financial Report (FFR or Standard Form 425) within 90 days of the budget/project period end
date.2

B. Justification
1.

Need and Legal Basis

The establishment of Navigator Programs to provide education and outreach to consumers about health
insurance exchanges and to provide culturally and linguistically appropriate information in a fair,
accurate, and impartial manner among consumers is authorized by Sections 1311(d)(4)(K) and 1311(i) of
the Affordable Care Act.
Section 1321(c)(1) of the Affordable Care Act authorizes the Secretary of HHS to “establish and operate”
a federal Exchange within any State that does not elect or is not prepared to establish a State-based
Exchange, as well as to “take such actions as are necessary to implement” the requirements for
establishing an Exchange, including the awarding of Navigator grants.
Exchanges must provide various forms of consumer assistance in order to fulfill the requirements of 45
CFR §155.205(d) and (e).

2.

Information Users

Under the terms of the Navigator grant program3, Navigator awardees will be required to provide progress
reports quarterly during the 12 month period of performance, and a final report at the end of the period.
Progress reports will outline:








How grant funds were used;
Details of measureable outcomes;
The program’s progress;
Descriptions of any barriers encountered;
Types of referrals to other entities;
Specific education and outreach efforts;
Key findings and recommendations.

Awardees will submit their progress reports electronically to CMS staff for analysis. The results of the
analysis will provide feedback on the effectiveness of the Navigator Programs, in order that CMS
leadership may evaluate the effectiveness of the program and address any areas that need revisions.

3.

Use of Information Technology

1 45 C.F.R. § 74.51; 45 C.F.R. § 92.40.
2 45 C.F.R. § 74.51; 45 C.F.R. § 92.41.
3 Navigator grant funding opportunity announcement will be available at: http://www.grants.gov.
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Awardees are required to log and track information on consumers assisted through the eligibility
and enrollment process in order to report required data elements to CMS quarterly and annually.
An awardee should be able to provide numbers, which include but are not limited to the number
of consumers that were assisted with profile setup, consumers that filed for affordability
assistance information such as advance payment of tax credits, and eligibility determinations,
along with the number of consumers that selected a QHP, Medicaid/CHIP or neither coverage
type. The log should also track consumers that were referred to Consumer Assistance Programs
(CAPs) established under section 2793 of the PHS Act or other state assistance programs as well
as consumers referred to other health care programs such as TRICARE, VA coverage and
Medicare and other information detailed in the quarterly and annual reporting templates.
All Navigator awardees will submit their progress reports electronically to CMS staff for evaluation and
analysis. The training of Navigator entities will include instructions on how they are to create and submit
quarterly progress reports and a final progress report. Details on the specific electronic format for
submission will be made available to Navigators after awards are made.
Reports sent to CMS will not contain personally identifiable information.

Government Paperwork Elimination Act (GPEA)
Is this collection currently available for completion electronically?



No, this will be a new electronic data collection.

Does this collection require a signature from the respondent(s)?


Navigator awardees will submit progress reports using the format prescribed by CMS. While they
have to identify themselves, there is no requirement for an electronic signature.

If CMS had the capability of accepting electronic signature(s), could this collection be made available
electronically?



Not applicable. The collection will be made electronically. An e-signature will not be required.

If this collection isn’t currently electronic but will be made electronic in the future, please give a date (month &
year) as to when this will be available electronically and explain why it can’t be done sooner.



Not applicable. The collection will be made electronically.

If this collection cannot be made electronic, or if it isn’t cost beneficial to make it electronic, please explain.


4.

Not applicable. The collection will be made electronically.

Duplication of Efforts
This information collection does not duplicate any other effort and the information cannot be
obtained from any other source.

5.

Small Businesses
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There are no unique impacts to small businesses involved.
6.

Less Frequent Collection
It is anticipated that Navigators may be contacted by potentially hundreds, if not thousands, of
consumers per month. Close monitoring, through data collection reports, of the nature of these
contacts will help identify any concerns with implementation.
Since these will be cooperative agreements, CMS will be in close contact with Navigator program
staff within FFEs. Upon request by Navigator entities, CMS may allow less frequent reporting due
to burden on program activities.

7.

Special Circumstances
Explain any special circumstances that would cause an information collection to be conducted in a manner:
Requiring respondents to report information to the agency more often than quarterly;



If specific concerns are reported to CMS, the Secretary may require a more focused report to
study the nature of these findings.

Requiring respondents to prepare a written response to a collection of information in fewer than 30 days
after receipt of it;



If specific concerns are reported, the Secretary may require a more focused report to study the
nature of these findings.

Requiring respondents to submit more than an original and two copies of any document;



Not applicable. CMS will not require more copies than an original and two copies of any
document.

Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or
tax records for more than three years;



Awardees must retain records for three years from date of notice of award for auditing purposes.

In connection with a statistical survey that is not designed to produce valid and reliable results that can be
generalized to the universe of study;



Not applicable. Statistical surveys are not contemplated for this program. The measureable data
obtained from this program will generate important information to assure that the program is
serving consumers as required.

Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;



Statistical surveys are not contemplated for this program. The measureable data obtained from
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this program will generate important information to assure that the program is serving consumers
as intended.
That includes a pledge of confidentiality that is not supported by authority established in statue or
regulation that is not supported by disclosure and data security policies that are consistent with the pledge,
or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or



Not applicable.

Requiring respondents to submit proprietary trade secret, or other confidential information unless the
agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the
extent permitted by law.



8.

Not applicable. This is outside the scope of our reporting requirements.

Federal Register/Outside Consultation
The 60-day Federal Register notice was published on April 12, 2013 (78 FR 21957).
Several commenters suggested Navigator awardees reporting requirements be expanded to include
demographics and CLAS standards, specifically sexual orientation and gender identity. These same
commenters suggested the use of a survey instrument that would allow for self-identification by
consumers. CMS has added “describe your plans for addressing consumers’ needs related to
culturally appropriate services, including services appropriate based on race, ethnicity, age, gender
identity, physical ability or limitation, sex, sexual orientation, socioeconomic status, and other
factors” to the quarterly and annual reporting templates. Since Navigators do not retain any PII on a
consumer other than a consent form to allow them to assist a consumer, there would be no reason to
ask a consumer for specific demographic information. The only demographic information associated
with a consumer is the information provided by the consumer in their application for coverage
through the Marketplace. Navigators will not retain copies of the application.
One commenter suggested increased funding for data collection infrastructure, permitting Navigators
to enroll individuals into QHPs, longer record retention periods, differentiating reporting
requirements, eliminating a quarterly report, and certifying accuracy and completeness of reports.
Based on statutory, regulatory and cooperative agreement requirements and funding limitations,
these suggestions have not been included in the revised supporting statement. This same commenter
had metric specific suggestions for reporting requirements including: number limit of unsatisfactory
training and certification attempts, organizational specific identifier, consumers needing multiple
sessions using media such as over the phone or internet, expanded education and outreach and CMS
review of Navigator awardee materials, number of personnel COI disclosures and resolutions and
consumer satisfaction surveys. Based on the comments, “consumers needing multiple sessions using
media such as over the phone or internet” and “the number of personnel COI disclosures as well as
the resolution of any such conflicts” have been included in the revised quarterly and annual reporting
templates. The remaining comments were not incorporated into the reporting templates as they are
outside the scope of the Navigator awardee reporting requirements.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data,
frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if
any), and on the data elements to be recorded, disclosed, or reported.

CMS frequently receives comments and telephone calls from consumer assistance organizations and
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non-profit groups about the importance of collecting data on Navigator activities, including the
number of consumers who will receive assistance as they contemplate their health insurance options,
as well as how well the process of rendering assistance is performing. CMS has been in frequent
contact with tribal organizations, and Exchanges are required to consult with and receive input from
any tribal governments within the geographic area they serve. Additionally, CMS has been in
frequent contact with federal offices that represent consumer needs including the Ryan White
Program administered by HRSA and the Office of Refugee Resettlement within HHS.
Consultation with representatives of those from whom information is to be obtained or those who must
compile records should occur at least once every 3 years - even if the collection of information activity is the
same as in prior periods. There may be circumstances that may preclude consultation in a specific
situation. These circumstances should be explained.

We do not foresee circumstances that would preclude CMS from consulting with awardees. CMS
will work with each Navigator award recipient to evaluate its progress relative to its Navigator Work
Plan and may condition funding based on progress and adherence to Federal guidance and Exchange
requirements including training, conflict of interest and Culturally and Linguistically Appropriate
Services (CLAS) standards. CMS will track awardee progress and provide technical assistance when
needed.

9.

Payments/Gifts to Respondents
Payments and gifts will not be provided.

10. Confidentiality
CMS will not collect personally identifiable information from awardees as a part of this grant. All
reporting will be of aggregate nature.

11. Sensitive Questions

12.



In order to perform their required duties, Navigators may need to communicate with clients about
sensitive topics, such as their health status and needs, in order to assist with eligibility
determinations and enrollment. As such, some information such as individual or family income,
employment status, citizenship, and other characteristics that people might commonly consider
private may be communicated.



As part of awardees’ reporting requirements, awardees will provide CMS with aggregated data on
total numbers of consumers enrolled in QHPs, numbers of consumers ineligible for QHPs, and
number of consumers referred to other agencies. See II. Data Collection Reporting for additional
information.

Burden Estimates (Hours & Wages)

CMS estimates that there will be approximately 33 FFEs and SPEs and will accommodate adjustments to
this number. Wage per hour data for Navigator caseworkers, project leads, and senior level executives are
as follows:
Caseworker – GS-9 equivalent
Mid-Level Project Lead – GS-12 equivalent

$20
$29
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Senior Level Executive – GS-15 equivalent

$48

33 FFE and Partnership states x 8 awardees each
264 awardees x 7 Navigators on awardee’s staff
1 senior level executive per awardee
1 mid-level project lead per Navigator awardee
Total numbers of individuals providing assistance

264 Awardees
1848 Navigator caseworkers
264 senior level executives
264 mid-level project leads
1848 Navigator caseworkers

The total cost to Navigator awardees over a 3 year period, assumes a 26% attrition and turnover rate of
the caseworkers in the second and third years4, though the total number of these individuals will remain
constant (1848). The number of Project Leads (264) remains constant in all three years as well, with 15%
of them expected to turnover and new staff to require initial registration and training in 2014 and 2015.
I.

APPLICATION

This is already captured in SF-424 authority to collect information based on funding opportunity
announcement requirements (OMB Approval Number: OCN-4040-0004). Therefore, burden hour and
cost have not been estimated for this collection.
II. DATA COLLECTION REPORTING
Data elements enumerated in the CMS-developed progress reporting template will be required from all
Navigator awardees. CMS expects awardees to collect information that is relevant to tracking the
operation of the Navigator program.
Analysis of progress and financial data reporting will enable CMS to ensure that the standards for
Navigators are being upheld. Program data also can offer CMS one indication of the effectiveness of FFE
Navigator programs, affording opportunities to provide technical assistance and support to Navigator
entities and, in extreme cases, inform the need for increased monitoring and possible intervention.
The proposed collection fields are subject to modification based on available technology and
informational needs.
1. Navigator Quarterly Progress Report
Navigator Quarterly Progress Report Collection Fields
Estimated total number of consumers assisted through eligibility and enrollment process - Estimates
should also include individuals who are represented by another member of their family during the
Navigator session (for example, when an adult receives assistance from Navigator for all 5 members of
their family, even though all 5 members are not present):




4

Total number of consumers assisted to set up a profile in the portal
Total number of consumers helped file affordability assistance information, such as the Advance
Premium Tax Credit (APTC) and Cost Sharing Reduction (CSR).
Total number of consumers helped receive an eligibility determination. Include consumers who
already had a portal profile as well as those who did not go further in the enrollment and
eligibility process.

http://smallbusiness.chron.com/standard-employee-turnover-call-center-industry-36185.html
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





Total number of consumers who selected a QHP during session with Navigator.
o Indicate the 5 plans most frequently selected by consumers
Total number of consumers helped who selected Medicaid/CHIP as their coverage option
Total number of consumers helped who elected neither a QHP nor Medicaid/CHIP.
Number of consumers requiring multiple sessions (more than one) of in person help
Number of consumers requiring multiple sessions (more than one) through other media, such as
over the phone or via internet

Estimated total number of consumers seeking post-enrollment assistance
Exchange Navigators may assist consumers with QHP related issues after enrollment. Under 45 C.F.R. §
155.210(e)(4), Navigators are also able to refer consumers to other programs for additional assistance
after enrollment. Awardees should estimate the number of consumers who were referred to Consumer
Assistance Programs (CAPs) established under section 2793 of the PHS Act or other state assistance
programs, such as those in state departments of insurance for help with post-enrollment questions about
appeals and grievances or other private health insurance questions and needs.
Estimated total number of consumers referred for out of scope assistance


The number of consumers referred to other health care programs such as TRICARE, VA
coverage, or Medicare.

Training, certification and other standards







Number of staff who have gone through training and certification/recertification.
o Of those staff who went through training, how many obtained certification or
recertification?
o How many attempts at certification were required by trained staff before successfully
passing the required assessment?
Provide information on how the awardee is ensuring adherence to conflict of interest standards,
including the number of personnel who disclose conflicts of interest as well as the resolution of
any such conflicts.
Provide information and at least one example on how the awardee is ensuring adherence to CLAS
standards.
o Describe your plans for addressing consumers’ translation needs, including but not
limited to translating materials about health insurance coverage
o Number of consumer assisted whose primary language spoken is a language other than
English
o Indicate the top 5 most prevalent primary languages used by consumers served by the
Navigator awardee.
o Describe your plans for addressing consumers’ needs related to culturally appropriate
services, including services appropriate based on race, ethnicity, age, gender identity,
physical ability or limitation, sex, sexual orientation, socioeconomic status, and other
factors
Provide information on how the awardee is ensuring that consumer with disabilities have
reasonable modifications and accommodations to access Exchange assistance services in
accordance with the Americans with Disabilities Act and Section 504 of the Rehabilitation Act.

Illustrative Examples

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

Provide at least one, but not more than three, examples of how your Navigator Program helped a
consumer determine affordability and/or coverage options under the Marketplace added by the
ACA. (Note: that under no circumstances should any personally identifiable information (PII) be
reported to CMS.)



Provide at least one, but not more than three examples of how a consumer’s situation was
positively impacted by the assistance provided by or involvement of the Navigator.

Privacy and Security
Provide a detailed description on how your Navigator program is adhering to the privacy and security
requirements outlined in regulation at 45 C.F.R. §155.260, and any security breaches that may have
occurred during the course of the quarter.
Burden Estimates for Navigator Quarterly Progress Reports

Total Hours: 300,432
Costs: $6,211,392

The cost burden associated with the Quarterly Progress Reports will apply to all Navigator awardees.
There will be four quarterly reports prepared as a result of information logged by Navigator caseworkers.
CMS estimates that each of the 264 grantees (8 grantees x 33 states = 264) will have 7 caseworkers who
will spend approximately one hour with each consumer and .16 hours (10 minutes) of that time would be
allocated to logging data. CMS estimates that each of the 264 awardees will require 1 mid-level project
lead working 12 hours to draft and compile a quarterly report of the caseworker’s activities. A senior
level executive will take 3 hours to review and grant clearance to each quarterly report.
Hours: 7 caseworkers x 38.5 hours x 4 quarterly submission = 1078 hours
1078 hours x 264 awardees = 284,592 hours
Costs: 284,592 hours x $20 caseworker wage = $5,691,840
Hours: 1 mid-level project lead x 12 hours x 4 quarterly submissions = 48 hours
48 hours x 264 awardees = 12,672 hours
Costs: 12,672 hours x $29 mid-level wage = $367,488
Hours: 3 hours of senior level time x 4 quarterly reports = 12 hours/year
12 hours x 264 awardees = 3168 hours
Costs: 3,168 hours x $48 senior level wage = $152,064
2. Navigator Prevention Fund Bi-Annual Reports
Navigator Prevention Fund Bi-Annual Report Collection Fields
Name of Any Sub-awardees – Navigator awardees will provide the names of any sub-awardees
receiving funds to perform activities under the Cooperative Agreement to Support Navigators in
Federally-facilitated and State Partnership Exchanges.
Description of Activities – Navigator awardees will provide a written description of the activities
undertaken with the use of prevention fund dollars and the outcome of those activities.
Burden Estimates for Navigator Prevention Fund Bi-Annual Reports

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Total Hours: 1,584
Costs: $55,968

Reporting requirements for Navigator awardees include the submission of two Bi-Annual Prevention
Fund Progress Reports due no later than 30 days from the end of each 6 -month cooperative agreement
period. CMS estimates that each awardee will require 1 mid-level project lead working 2 hours to
complete each bi-annual report at mid-level wage:
Hours:

1 mid-level project lead x 2 hours x 2 reports per year = 4 hours
4 hours x 264 awardees = 1,056 hours

Costs:

1,056 hours x $29 mid-level wage = $30,624

CMS estimates that a senior level executive will take 1 hour to review and grant clearance to each biannual report for a total of 2 hours per year.
Hours:

2 hours x 264 awardees = 528 hours

Costs:

528 hours x $48 senior level wage = $25,344

3. Navigator Annual Progress Report
Navigator Annual Report Collection Fields
Consumer Contacts




Estimate the number of consumers reached during the grant period of performance through
outreach and public education efforts.
List all public education and outreach events by date and location.
Is there anything else you would like to share with CMS about the Navigator’s outreach and
public education efforts (e.g., brochures, toolkits and social media campaigns)?

Estimated total number of consumers assisted through the eligibility and enrollment process during
the period of performance - Estimates should also include individuals who are represented by another
member of their family during the Navigator session (ex: adult receives assistance from Navigator for all
5 members of their family, even though all 5 members are not present).









Total number of consumers assisted to set up a profile in the portal
Total number of consumers helped file affordability assistance information, such as the Advanced
Premium Tax Credit (APTC) and Cost Sharing Reduction (CSR).
Total number of consumers helped receive an eligibility determination. Include consumers who
already had a portal profile as well as those who did not go further in the enrollment and
eligibility process.
Total number of consumers who selected a QHP during session with Navigator
o Indicate the 5 plans most frequently selected by consumers
Total number of consumers helped who selected Medicaid/CHIP as their coverage option
Total number of consumers helped who elected neither a QHP or Medicaid/CHIP
Number of consumers requiring multiple sessions (more than one) of in-person help
Number of consumers requiring multiple sessions (more than one) through other media, such as
over the phone or via internet

Estimated total number post-enrollment assistance during the period of performance Exchange
Navigators may assist consumers with QHP related issues after enrollment. Under 45 C.F.R. §
10

155.210(e)(4), Navigators are also able to refer consumers to other programs for additional assistance.
Awardees should estimate the number of consumers who were referred to Consumer Assistance Programs
(CAPs) established under section 2793 of the PHS Act or other state assistance programs, such as those in
state departments of insurance, for help with post-enrollment questions about appeals and grievances or
other private health insurance questions and needs.
Estimated total number of consumers referred for out of scope assistance during the period of
performance
The number of consumers referred to other health care programs such as TRICARE, VA coverage,
Medicare
Training, certification and other standards







Number of staff who have gone through training and certification/recertification.
o Of those staff who went through training, how many obtained certification or
recertification?
o How many attempts at certification were required by trained staff before successfully
passing the required assessment?
Provide information on how the awardee is ensuring adherence to conflict of interest standards,
including the number of personnel who disclose conflicts of interest as well as the resolution of
any such conflicts.
Provide information and at least one example on how the awardee is ensuring adherence to CLAS
standards.
o Describe your plans for addressing consumers’ translation needs, including but not
limited to translating materials about health insurance coverage
o Number of consumer assisted whose primary language spoken is a language other than
English
o Indicate the top 5 most prevalent primary languages used by the consumers served by the
Navigator awardee
o Describe your plans for addressing consumers’ needs related to culturally appropriate
services, including services appropriate based on race, ethnicity, age, gender identity,
physical ability or limitation, sex, sexual orientation, socioeconomic status, and other
factors
Provide information on how the awardee is ensuring that consumers with disabilities have
reasonable modifications and accommodations to access Exchange assistance services in
accordance with the Americans with Disabilities Act and Section 504 of the Rehabilitation Act.

How the Navigator has addressed CLAS and Disability Access during the period of performance


Provide a brief summary of how the program has provided assistance that is culturally and
linguistically appropriate. Include information about translation services provided by the
Navigator, including but not limited to the translation of materials that were developed by the
Navigator. Include information on activities performed to ensure that services are provided on a
culturally appropriate basis with respect to all aspects of culture. Refer to the Office of Minority
Health’s websites for the national standards on culturally and linguistically appropriate services
(http://minorityhealth.hhs.gov/templates/browse.aspx?lvl=2&lvlID=15 and
https://www.thinkculturalhealth.hhs.gov/Content/clas.asp).



Provide a brief summary of how the program has provided reasonable modifications and
11

accommodations to individuals with disabilities.
Program Effectiveness
As part of the application process, Navigator program awardees were asked to describe the
community(ies) they expected to serve during their term as a Navigator, the reason for expecting to serve
primarily that community(ies), and the number of people they expected to serve. To ensure Navigator
programs are effectively engaging the target community(ies), provide a description of the successes and
struggles you have experienced in serving the target community(ies).
Lessons Learned
Provide a description of the lessons the program has learned that could inform the actions your program
takes in the future or that could be helpful to other programs.
Major Accomplishments
Provide a description of the accomplishments your program has made as a result of the cooperative
agreement.
Policy Changes Implemented
Provide a description of any Navigator-specific policy changes implemented as a result of, or that were
informed by, information collected by your program.
Illustrative Examples




Provide at least one, but not more than three, examples of how your Navigator program helped a
consumer determine affordability and/or coverage options under the Exchanges marketplace
added by the ACA. (Note: Under no circumstances should any personally identifiable information
(PII) be reported to CMS.)
Provide at least one, but not more than three examples of how a consumer’s situation was
positively impacted by the assistance provided by or involvement of the Navigator.

Privacy and Security
Provide a detailed description on how your Navigator program is adhering to the privacy and security
requirements outlined in regulation at 45 C.F.R. §155.260, and any security breaches that may have
occurred during the course of the period of performance.

Burden Estimates for Navigator Annual Progress Report

Total Hours: 6,336
Costs: $223,872

Reporting requirements for Navigator awardees include the submission of an Annual Progress Report due
within 30 days from the end of the 12-month cooperative agreement period. CMS estimates that each
awardee will require 1 mid-level project lead working 16 hours to complete their annual report on their
activities for the previous year at mid-level wage:
Hours:

1 mid-level project lead x 16 hours = 16 hours
16 hours x 264 awardees = 4,224 hours
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Costs:

4,224 hours x $29 mid-level wage = $122,496

CMS estimates that a senior level executive will take 8 hours to review and grant clearance to each annual
report.
Hours:
8 hours x 264 awardees = 2,112 hours
Costs:

2013
Navigator
Report
Submissions
Quarterly
Progress
Submissions
Bi-Annual
Prevention
Fund Reports
Annual Report
Submissions
2013 Total
Navigator
Report
Submissions

2,112 hours x $48 senior level wage = $101,376
Table 2 – Burden Estimates for Navigator Report Submissions
# of
Frequency
Responses Annual
Annual Cost
Respondents
Burden Hours

264

4 reports/year

1056/year

300,432

$6,211,392

264

2 reports/year

528/year

1,584

$55,968

264

1

264

6,336

$223,872

308,352

$6,491,232

2014
Navigator
Report
Submissions
Quarterly
Progress
Submissions
Bi-Annual
Prevention
Fund Reports
Annual Report
Submissions
2014 Total
Navigator
Report
Submissions

# of
Frequency
Respondents

2015
Navigator
Report
Submissions
Quarterly
Progress

# of
Frequency
Respondents

Responses

Annual
Burden Hours

Annual Cost

264

4 reports/year

1056/year

264

2 reports/year

528/year

1,584

$55,968

264

1

264

6,336

$223,872

308,352

$6,491,232

264

4 reports/
year

Responses

1056/year
13

300,432

Annual
Burden Hours

300,432

$6,211,392

Annual Cost

$6,211,392

Submissions
Bi-Annual
Prevention
Fund Reports
Annual Report
Submissions
2015 Total
Navigator
Report
Submissions

264

2 reports/year

528/year

1,584

264

1

264

6,336

$55,968
$223,872

308,352

3-Year Hours & Costs for Navigator
Reports
Annual Burden

Total Burden
Hours
925,056
308,352

$6,491,232

Total Cost

$19,473,696
$6,491,232

13. Capital Costs
The grant announcement indicates that entities or individuals eligible to be Navigators must have
expertise in the needs of underserved and vulnerable populations; eligibility and enrollment rules and
procedures; the range of QHP options and insurance affordability programs; and privacy and security
standards. Therefore, we do not anticipate that programs will need additional capital or startup costs
beyond what is covered in awardees grant application.

14. Cost to Federal Government
NAVIGATOR GRANT APPLICATIONS
The review of the applications from FFE and SPE states for Navigator grants will be initially performed
by an outside contractor with oversight by federal employees. The contractor will convene a panel of
outside experts to evaluate applications and assist in the selection process. The recommendations of the
panel of experts will be analyzed by the contractor. The contractor will then submit its recommendations
to CMS for review.
A. Application Review by Federal Employees
CMS anticipates that the review of the recommendations of the contractor will include the review of the
Navigator cooperative agreement applications of the 264 applications recommended for funding by the
contractor, and may include the review of as many as 300 applications before a final selection is made.
CMS estimates that each application will require one hour for an initial review by mid-level staff:
Hours: 300 applications x 1 hour (initial review) = 300 hours
Costs: 300 hours x $29 mid-level wage = $8,700
B. Outside Panel Review
1. Identification of potential reviewers
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Two mid-level staff will help to identify a panel of experts with the contractor. Mid-level staff will take
about 4 hours to identify potential reviewers. CMS staff is limited to providing non-binding
recommendations; the contractor will have ultimate authority in selecting panel members.
Hours: 2 mid-level staff identifying potential reviewers (4 hours each) = 8 hours
Costs: 8 hours x $29 mid-level wage = $232
Total for Identification of Potential Reviewers = $232
2. Participation in the panel review
Outside subject matter experts will participate as panel experts to review applications. In addition, two
CMS senior level staff will participate in the panel review to answer questions from the panel of experts.
CMS staff will not manage or control the agenda. CMS assumes the review process will take 10 eighthour days.
Hours: 2 (senior level staff) x 8 hour work days x (10) days = 160 hours
Costs: 160 hours x $48 senior level wage = $7680
Total Hours for Outside Panel Review = 168 Hours
Total Cost for Outside Panel Review = $7912
C. Follow-up
Some applications will require follow-up telephone calls and other attempts to clarify information or seek
additional information. CMS estimates that 75 applications will require follow-up review. Three midlevel CMS staff will require one hour each for follow-up.
Hours: 75 follow-up telephone calls x 3 mid-level CMS x 1 hour = 225 hours
Costs: 225 hours x $29 mid-level wage = $6525
D. Award Announcement and Awardee Notification
Mid-level CMS staff will be devoted to developing rollout materials (factsheets, FAQs, website language,
press release, etc.) and follow-up notifications to awardees. CMS assumes that developing rollout
materials will take 16 hours. A CMS senior level staff person will take two hours to review these
materials. Further, it is anticipated that CMS mid-level staff will provide notification of the award to
awardees, and this will take 15 minutes per awardee.
Development of rollout materials:
Hours: 16 hours x 1 mid-level staff + 2 hours x 1 senior level staff x 1 = 18 hours
Costs: 16 hours x $29 (mid-level wage) = $464
2 hours x $48 (senior level wage) = $96
Total for Award Announcement: $560
Awardee notification:

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Hours: 264 awardees x .25 hour = 66 hours
Costs: 66 hours x $29 = $1,914
Total for Awardee Notification: $1,914
Total Hours for Award Announcement and Awardee Notification: 84 hours
Total Cost for Award Announcement and Awardee Notification: $2,474
E. Costs of Review of Quarterly and Annual Reports
Mid-level CMS staff will review quarterly and annual report submissions from Navigator awardees.
CMS assumes that it will take 45 minutes to review each quarterly report and two hours to review each
annual report. CMS further assumes that there will be 264 awardees submitting quarterly and annual
Reports.
Hours: 264 Quarterly reports x 4 submissions per budget year x .75 hours = 792 hours
264 Annual Reports x 1 submission per budget year x 2 hours = 528 hours
Costs: 1320 hours x $29 mid-level staff wage = $38,280
CMS estimates it will take Senior Level staff two hours to review the aggregate quarterly reports four
times per year (for a total of eight hours) and four hours to review the aggregate annual report.
Hours: 8 hours for Quarterly Reports + 4 hours for Annual Reports = 12 hours of
senior level staff time
Costs: 12 hours x $48 senior level staff wage = $576
Total Hours for Review of Quarterly and Annual Reports = 1,332 Hours
Total Cost for Review of Quarterly and Annual Reports = $38,856

Total Cost to Federal Government:

Description
Application review
Outside panel review
Follow-up
Award announcement and
Awardee notification
Costs of review of quarterly and
annual reports
Total

Hours
300
168
225
84

Costs
$8,700
$7,912
$6,525
$2,474

1,332

$38,856

2,109

$64,467

15. Changes to Burden
This is a new collection; therefore there are no burden adjustments.
16. Publication/Tabulation Dates

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At this time, CMS does not expect that the data collected in the quarterly and annual reports will be
published or shared with other agencies.
17. Expiration Date
CMS would like an exemption from displaying the expiration dates as these forms are used on a
continuing basis. To include an expiration date would result in having to discard a potentially large
number of forms.

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