This article describes how you can manage consent records for your clients as it pertains to the new Active Consent rules from CMS. See this article for more information: Summary of CMS Guidance on New Consent Rules -- Effective 6/18
HealthSherpa provides tools for consent capture, storage, and reporting capabilities within your dashboard.
Uploading consent within the enrollment flow
Uploading consent is optional. At the final step of enrollment, you are presented with three choices:
"Upload my consent files to HealthSherpa"
If you choose this option, the consent file will be connected to you and your client and will be visible in the dashboard. For agents who do not have a viable method for collecting consent, we will also provide a consent form for you to download. These forms will also be available at the bottom of this article under "Resources."
"I already have proof of consent in my own records"
If you already have a storage mechanism for your consent records, choosing this option allows you to notate that choice in your dashboard for reconciliation purposes.
"Upload consent files later"
If you do not have the consent files ready, you can choose this option to continue with enrollment. You will be able to upload consent for this client from the dashboard at a later time.
Viewing consent in your dashboard
We've added a new column in Client Exports called "Consent status," with the following possible values:
Collected - If you've already uploaded consent or marked to "store consent in your own records"
Action required - If you've chosen to upload later but have not yet done so
You will notice a new consent records component when you drill into the client details page. This will show the consent history between your and your client.
Method - how the consent was captured
“Agent Upload” - when you manually uploaded the consent
“Agent Retained” - when you marked to store proof of consent in your own records
“Direct to consumer” - a client self-enrolled and provided their own consent
Collection date - when the consent was created in the system
Consent status -
“Collected” - proof of consent was collected, whether it is stored in our platform or in your own records
“Action Required” - When you marked to upload consent later
Plan Year - the related application’s plan year
Download files - you are able to download the available file related to the consent record.
“Collect consent” - will be available if you've marked to upload consent later. We will also make it available for agents who initially decided to store in their own records.
More actions coming soon, such as being able to mark the consent record as "revoked" if your client contacts you to do so.
Collecting consent from the dashboard
If you have chosen to upload later or initially decided to store consent in your own records, you can upload consent for your client from the dashboard.
Pressing the "Collect consent" button will take you to a page to do so.
The options are similar to the enrollment flow: upload consent now or mark to store in your own records. Again, a consent form template will be available for you to download.
We've made available two downloadable forms you can use for consent:
Standard Consent Form - Generic consent form