Question: As a broker who has 5 licensed support staff members, will they have to be Certified to help our current clients or prospective new clients with enrollment in to the Exchange or SHOP?
Answer: Yes, if licensed staff actually enroll people in Covered California they must be certified. No, if they only provide assistance and the Certified Agent does the “enrolling”.
Only individual agents may submit enrollments through the Exchange. An agency with multiple agents or endorsed agents cannot submit applications through the Exchange. Obviously, commissions are an internal discussion in an agency, and since no agent is being compensated for enrollments through the Exchange it probably doesn’t matter whose name is on an application submitted through the Exchange. But it could create some technical problems for individual agents and insurance companies, in terms of recordkeeping.
It is probably best that each individual agent who expects to submit one or more applications through the Exchange be certified, because an agent who is not certified and who submits an application through the Exchange will have that application rejected. If this happens late in the year, it could expose a consumer to not having coverage on January 1, 2014.