July 18, 2013
Testimony in opposition to Rule 3901-5-13- Insurance navigator certification and agency exchange requirements
My name is Danielle Smith and I am the Executive Director of the National Association of Social Workers- Ohio Chapter. NASW represents the 22,000 licensed social workers in the state who work in a myriad of settings providing a wide range of services. I am testifying in opposition to rule 3901-5-13 which would set procedures and requirements for certification of insurance navigators. I am primarily concerned about the limited number of exempted settings where employees could talk to clients about their health insurance options which would negatively impact the work of thousands of licensed social workers in the state. The rule currently states only employees of the following employers would be allowed to inform clients of their health insurance options:
(1)LicensedhealthcareproviderorahospitalregisteredwiththeOhiodepartmentofhealth;
(2)Federallyqualifiedhealthcenterora federallyqualifiedhealthcenterlook-alikeasdefinedinsection3701.047oftheRevisedCode;
(3)Non-profitorganizationwhoseprimarypurposeisthedistributionoffoodstuffs,groceries,donatedgoodsorpurchasedgoodsintheircommunityorsurroundingcommunities,tomeettheemergencyneedsofthecommunitiesorparticipatingoutlets;
(4)Anagencyofthestateorapoliticalsubdivisionasdefinedindivision(D)ofsection3905.36oftheRevisedCode
Most social workers provide case management services on some level which often includes help with finding health insurance and affording the cost of treatment. Therefore, this list of exempted settings leaves out many employers of licensed social workers including other non-profit organizations and social services agencies that are not health care providers or food banks. Examples include schools, individual private practices, mental health agencies, and other social service agencies. If implemented this rule would allow a licensed social worker who works for a food bank to talk to clients about their health insurance options but would not allow a social worker with the exact same scope of practice who works at another type of social service agency to provide the same information to clients with the same types of needs.
NASW Ohio Chapter strongly urges the Ohio Department of Insurance to expand the list of exempted employers to include all non-profit organizations and to add an exemption for all licensed health care professionals regardless of their employer. The exemption for licensed health care professionals as individuals instead of by employers is highly important as there are many social workers who work in private practice and provide case management services.
Thank you,
Danielle Smith, MSW, MA, LSW
Executive Director
NASW Ohio Chapter
33 N. Third St., Suite 530
Columbus, OH 4315
614-461-4484