Recently, the Centers for Medicare and Medicaid Services (CMS) removed a PDF titled “Marketplace Outreach: Best Practices for Outreach to Latino Communities” from its Health Insurance Marketplace website. The PDF was removed in late September 2018, about a month before the November 1st start of Open Enrollment — the period each year when people can sign up for health insurance plans on the federal Health Insurance Marketplace created by the Affordable Care Act (ACA).

The Web Integrity Project’s latest report details the removal of this PDF from the Health Insurance Marketplace website, a CMS website that serves as “the official Marketplace information source” for assisters — individuals or organizations trained to provide free help to consumers and small businesses searching for and enrolling in health coverage. The PDF was a slide presentation intended as a training resource on outreach to Latino communities for assisters. The slides included information about the challenges Latinos might face when enrolling for coverage, such as fear of immigration enforcement, and best practices for assistance, such as making services culturally and linguistically appropriate. A link corresponding to the PDF was removed from two webpages on the CMS website — the “Training for navigators, agents, brokers, and other assisters” page and the “Special populations” page.

Existing regulations require that navigators — assisters specifically funded through the Marketplace budget — receive training to ensure they understand the needs of underserved and vulnerable populations, like Latinos. Yet CMS did not provide advance notice for why it removed a resource that could have been used to train navigators in how to better engage with these communities and increase enrollment.

The removal of the PDF comes at a time when outreach to Latino communities is particularly necessary. Reports indicate that, in response to the Trump administration’s immigration policies, legal Latino immigrants have avoided participation in health care programs, particularly during last year’s open enrollment, due to fears that family members in the country illegally might be found.

Snapshot of a slide from the removed PDF, captured by the Internet Archive’s Wayback Machine on September 19, 2018.

This year, advocates are concerned about the potential impact on health insurance enrollment of a rule proposed in September 2018 that would add several health programs to the list of programs the government considers in “public charge” determinations. Public charge policies stipulate that the government can make decisions to deny individuals entry to the U.S. or adjust their legal permanent resident status based on their use of public benefits and programs. Legal Latino immigrants may refuse certain healthcare services because of concerns that their participation could hurt their chances at gaining permanent residency and the chances of family members being able to enter the country in the future.

Kaiser Family Foundation data show that Hispanic individuals are already more likely to face challenges in accessing healthcare services, and are more likely to be uninsured compared to their White, non-Latino counterparts. In fact, according to the Office of Minority Health (OMH), an office of the Department of Health and Human Services (HHS) like CMS, Latinos have the “highest uninsured rates of any racial or ethnic group within the United States.”

According to the Commonwealth Fund, outreach from navigator programs can broadly improve enrollment success among consumers, and can be particularly effective in expanding coverage among Latinos. Yet the Trump administration has twice cut funding for the navigator programs that might have used the removed PDF for training their staff. This year navigator programs received $10 million, down from $36.8 million last year and about $63 million in 2016.

Last year, over half of navigator programs said the funding cuts would make it difficult for them to hire bilingual staff. Insufficient numbers of bilingual staff pose an additional obstacle in performing outreach to consumers with limited English proficiency, including many Latino immigrants.

The removal of the “Marketplace Outreach: Best Practices for Outreach to Latino Communities” PDF by CMS not only reduces access to a potentially valuable training resource for improving outreach efforts, it also signals CMS’s de-emphasis on improving access to healthcare for Latino communities and other underserved populations.

In response to WIP’s request for comment, a CMS spokesperson claimed that CMS “routinely performs updates and maintenance of CMS.gov” and that in the case of the PDF removal “the slide presentation contained outdated information.” However, with the exception of one bullet point that referenced the now-eliminated individual mandate, the information in the PDF remains accurate and relevant to assisters. In fact, another document on the website, the “September Marketplace Update for Assisters” PDF, published in September 2017 with information relevant to assisters, still includes a link to the removed PDF, noting that the best practices “identified in the slide presentation” are examples of how to “model targeted outreach efforts” to other populations.

As the official source of information for assisters and navigators, CMS’s Health Insurance Marketplace website should reliably provide and update resources that enable assisters and navigators to do their jobs. And yet it has failed to maintain its information source about an issue that, based on their job description, should be a top priority for assisters and navigators.