They will also provide additional assistance to consumers who are disabled, do not speak English, or who are unfamiliar with health insurance.

The proposed guidelines specify that while navigators do not have to be licensed insurance agents or brokers, they: 

• Cannot be employed by an insurer;
• Cannot receive compensation or rewards from carriers;
• Must disclose what other lines of insurance they intended to sell during their work;
• Must disclose any prior employment with health insurers in the previous five years; and
• Must certify that they will abide by conflict of interest and impartiality standards developed by HHS.

The proposed rule also states that navigators are not allowed to select a plan for their clients. Also, they are not tasked with determining whether a client is eligible for a subsidy through PPACA.

Additionally, "the navigator must not have a personal interest in the coverage choices made by individuals or employers who receive the navigator's assistance," according to HHS rules, adding, "more specifically, with respect to the assistance offered by a navigator to a small employer, a navigator should not have a personal interest in whether a small employer choose to self-insure its employees, or chooses to enroll in fully-insured coverage inside or outside the exchange."

Exactly what will a navigator do? Navigators are supposed to provide information to consumers about health insurance, the new health insurance marketplace, qualified health plans, and public programs including Medicaid and the Children's Health Insurance Program. They will assist consumers in enrollment and make referrals to health insurance consumer assistance or ombudsman programs.

Additionally, they are directed to provide information and services in a manner that is culturally and linguistically appropriate and accessible to people with disabilities.  Apparently, navigators may be registering voters as well. The draft PPACA application asks the applicant if he would like to register to vote; if so, the consumer is directed to a voter registration form.

According to the U.S. Department of Health and Human Services, anyone can become a navigator with as little as 20 hours of training and without a uniform criminal background check or fingerprint check. Navigators and assisters will have access to personal and sensitive information such as Social Security numbers, tax returns and personal health information.

This disregard for the security of personal information leaves millions of people vulnerable and exposed to identity theft, security breaches or misuse of private information. Attorneys General from 13 states have said that the HHS guidance for navigators, assisters, application counselors and other consumer outreach programs "suffer numerous deficiencies." 

HHS has allocated $54 million in funding grants to train and pay navigators in the 37 states with federally run exchanges. PPACA prohibits federal funding for the assisters program because it does not have to meet the same criteria as the navigators program. Under the final rule that was issued in July, 2013, traditional insurance agents cannot be selected and trained as navigator workers, who must not be affiliated with the insurance industry, according to California Healthline. Navigator workers and in-person assisters can provide information only about specific topics, such as:

• The exchanges' qualified health plans and insurance affordability programs;
• The tax implications of enrollment decisions;
• Eligibility for premium tax credits; and
• Cost-sharing reductions.

However, states with their own exchanges can establish more rigorous selection and training requirements for in-person assisters. For example, Maryland requires such workers to undergo at least 120 hours of training. As well, the 63-page rule covering navigators, drawn up by CMS also said the government will provide free translators for those not fluent in English — no matter what their native language is. Talk about cultural diversity.

The Obama administration plans on hiring tens of thousands of health care professionals, union workers and community activists as navigators to help Americans choose Obamacare options. Navigators are scheduled to be paid $20 to $48 per hour plus benefits, reported by The Washington Examiner. It is still not clear how many navigators will be required. California, however, provides a hint. It wants 21,000. That's a lot of people getting paid lots of money that could be used to reduce the cost of health care instead of increasing the national debt.

The navigator initiative is an expensive, unnecessary program. CMS already has mechanisms to help enrollees; and there are already thousands of qualified, certified insurance brokers who can do this for far less expense. The navigator program adds scores of millions of dollars to the cost of the PPACA.

Why has CMS turned its back on those who are already qualified with many years of experience? Now CMS is concerned about Fraud and abuse by navigators. Bad law equals bad consequences. Leave it to the government to come up with programs that add cost and confusion instead of solutions that work.

In the words of the Beatles, "Help!"