CEC - Certified Enrollment Counselor Privacy and Security Standards Questions and Answers

Question 1

A Certified Enrollment Counselor (CEC) is working with a consumer who is hesitant to provide their Social Security Number on the Marketplace application. According to the privacy and security standards CECs must follow, what is the most appropriate action for the CEC to take?

Accepted Answer

Advise the consumer that providing the SSN is voluntary, but failing to do so may prevent or delay a determination of eligibility for health coverage and financial assistance.

Answer

According to the Privacy Act Statement on the HealthCare.gov application, providing a Social Security Number (SSN) is voluntary. However, Certified Enrollment Counselors must also inform consumers of the potential consequences of not providing it, which can include delays or an inability to determine eligibility for coverage or financial assistance programs. Refusing assistance, suggesting false information, or claiming the Marketplace can bypass the consumer's input are all incorrect and violate CEC standards.

Question 2

Under 45 CFR § 155.260, a core regulation for Marketplace privacy and security, a CEC must only collect, use, and disclose a consumer's Personally Identifiable Information (PII) to the extent necessary to perform which of the following?

Accepted Answer

Fulfill authorized functions like assisting with eligibility and enrollment.

Answer

45 CFR § 155.260 and related CMS guidance strictly limit the use of a consumer's PII to the functions necessary for the efficient operation of the Marketplace. For a CEC, this means using the information solely for authorized activities such as helping a consumer determine eligibility and enroll in a Qualified Health Plan or insurance affordability program. Using PII for marketing, research, or fundraising is a violation of these standards.

Question 3

A consumer emails their CEC copies of their pay stubs and driver's license. The CEC downloads the documents to their personal, unencrypted laptop to review them before entering the information into the Marketplace portal. Which security principle has the CEC most clearly violated?

Accepted Answer

Safeguards

Answer

The 'Safeguards' principle, as outlined in 45 CFR § 155.260, requires that Personally Identifiable Information (PII) be protected with reasonable operational, administrative, technical, and physical safeguards to ensure its confidentiality and prevent unauthorized access. Storing sensitive consumer documents on a personal, unencrypted device fails to meet this standard and puts the consumer's data at significant risk.

Question 4

Before a Certified Enrollment Counselor can access a consumer's Personally Identifiable Information (PII) to assist with their Marketplace application, what must the CEC obtain from the consumer?

Accepted Answer

Informed consent and authorization.

Answer

A fundamental privacy standard for CECs is obtaining informed consent and authorization from the consumer before accessing their PII. This ensures the consumer understands who is helping them, what information will be accessed, and for what purpose. CECs are prohibited from charging for their services, and while certain documents may be needed for the application, they are not a prerequisite for the CEC to simply begin the assistance process with authorization.

Question 5

Which of the following is a key requirement a Certified Application Counselor Designated Organization (CDO) must impose on its Certified Enrollment Counselors (CECs) regarding privacy and security training?

Accepted Answer

CECs must successfully complete role-based privacy and security training before accessing PII and on an ongoing basis.

Answer

CMS standards require that Certified Application Counselor Designated Organizations ensure their counselors complete privacy and security training tailored to their role and responsibilities. This training is mandatory and must be completed *before* the counselor is granted access to any consumer PII. There is also an expectation of ongoing or annual refresher training to keep CECs aware of their obligations.

(CEC) Certified Enrollment Counselor Practice Test

(CEC) Certified Enrollment Counselor Practice Test

CEC - Certified Enrollment Counselor Privacy and Security Standards Questions and Answers