Question: How can the Exchange control the tendency for assisters to steer consumers to certain Qualified Health Plans rather than others?

Answer: The steerage concern is an important one. Both the ACA and the Exchange have safeguards in place to minimize it, For example, having the same commission structure both in and out of the Exchange. However, the steerage concern needs to be balanced against a far greater concern, particularly in the early years of the Exchange: the need to successfully enroll individuals on a massive scale. The failure to achieve very substantial participation rates in the Exchange will, more than any other single factor, undermine the viability of the Exchange, and force premiums up. It must be recognized that direct benefit assisters will have a financial incentive to enroll individuals in a particular way. Health plans will not extend great effort to enroll people into competing health plans. Providers will not generally enroll individuals into plans that exclude the provider from their networks. This must be recognized and accepted. Instead of attempting to eradicate the natural tendency of private entities to enroll individuals in their own systems, the Exchange might choose instead to embrace this incentive to generate the massive enrollment that will be needed for the Exchange to succeed.