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    Identifying and Terminating Inappropriate Interactions Policy

    Scope

    This policy applies to brokers, navigators and certified application counselors (CACs).

    Policy Details

    The objective of this policy is to ensure the safety and security of the public, MNsure staff and our certified assisters.

    A pillar of MNsure's mission is to facilitate the enrollment of consumers into health insurance programs. MNsure staff and certified assisters help consumers with the enrollment process. MNsure staff are trained to be respectful and professional when assisting consumers or assister partners.

    However, there are circumstances under which MNsure staff and certified assisters may terminate a phone call or meeting.

    The general rule is that a call or meeting is inappropriate and should be terminated if the caller/consumer/assister:

    • Threatens physical harm to MNsure staff (or members of the staff’s household), the MNsure office building, a MNsure assister (or members of the assister’s household), the assister’s office location, a public official, a third party, or to the caller himself or herself. For example, the caller threatens to go to MNsure or an assister’s office and cause harm to staff or destroy the building.
    • Is verbally abusive to MNsure staff person or assister. An interaction is verbally abusive if the individual repeatedly uses profane or derogatory language during the call or interaction. For example, the individual repeatedly uses curse words or insults the MNsure staff or assister’s gender, race, ethnicity, religion, nationality, sexual orientation, or language ability or proficiency, etc.
    • Insists on discussing matters unrelated to MNsure’s health insurance programs, including unprofessional or inappropriate behavior. This includes actions, words or physical gestures that could reasonably cause another person distress or discomfort.
      • Individuals wishing to file a complaint related to MNsure should be directed to the Get Help page on the MNsure website which details several avenues, including an anonymous option for filing complaints.
      • Individuals wishing to make a general statement about MNsure or the Affordable Care Act should be directed to the public comments email account at publicfeedback@mnsure.org.

    Procedures for Terminating Inappropriate Telephone Calls

    This procedure outlines the situations in which MNsure staff must terminate inappropriate phone calls with consumers or assister partners, as well as escalation procedures that must be followed once an inappropriate call has been terminated.

    1. If the caller is engaging in inappropriate behavior as described in the policy, MNsure staff will remind the caller that the call is being recorded, and that MNsure policy requires that the call be terminated if the caller continues to make threats of physical harm, continues to verbally abuse the MNsure staff on the call by repeatedly using profane or derogatory language or insist on discussing matters unrelated to MNsure’s health insurance programs.
    2. At least one more attempt will be made to determine the caller’s issue and to assist in resolving it.
      1. If the caller’s issue has already been resolved, advise the caller that the reason for the call has been addressed and since there is nothing else related to MNsure business the call is being ended. At this point, the call will be disconnected.
      2. If the caller continues to make threats of physical harm or be verbally abusive to the MNsure staff on the call by repeatedly using profane or derogatory language or insist on discussing matters unrelated to MNsure’s health insurance programs, MNsure staff will terminate the call.
    3. MNsure staff will document the call and a recording of the call (if available) will be preserved. If the call involved a certified assister, the Broker Relations Director or Senior Director of Partner and Board Relations will be notified.

    Assister Procedures for Terminating Inappropriate Consumer Interactions

    This procedure outlines the situations in which MNsure certified assisters may terminate inappropriate phone calls or meetings with consumers.

    1. If a consumer is engaging in inappropriate behavior as described in the policy, the assister will remind the consumer that MNsure’s policy allows MNsure certified assisters to terminate the call or meeting if the consumer continues to make threats of physical harm or verbally abuse the assister by repeatedly using profane or derogatory language or insist on discussing matters unrelated to MNsure’s health insurance programs.
    2. Make at least one more attempt to determine the consumer’s issue and to assist in resolving it.
      1. If the consumer’s issue has already been resolved, advise the consumer that the reason for the meeting has been addressed and since there is nothing else related to MNsure business the call or meeting is being ended immediately.
      2. If the consumer continues to make threats of physical harm or be verbally abusive to the assister by repeatedly using profane or derogatory language or insists on discussing matters unrelated to MNsure’s health insurance programs, MNsure assisters may terminate the call or end the in-person meeting. The assister should use their best judgment to determine if a call to law enforcement is necessary.
    3. The assister is advised to document the call or meeting and retain this record in case the consumer files a complaint against the assister. The assister may file a complaint by following the Reporting Fraud and Complaints Policy.
    4. If the consumer interaction included threats to of physical harm to MNsure staff or the MNsure building, please report this immediately by calling the Assister Resource Center or Broker Service Line.

    Assister Procedures for Terminating for Suspected Fraud

    • If an assister suspects a consumer may be providing fraudulent information, the assister can remind the consumer of the importance of providing accurate information. The assister should continue to attempt to provide assistance, but refer any suspected fraud to MNsure for investigation by following the Reporting Fraud and Complaints Policy.
    • If a consumer requests that an assister enter information that they acknowledge is fraudulent, the assister should remind the consumer of the importance of providing accurate information. If the consumer continues to request that the assister enter fraudulent information, the assister can terminate the call or meeting.
    • The assister is advised to document the call or meeting and retain this record in case the consumer files a complaint against the assister. The assister may file a complaint by following the Reporting Fraud and Complaints Policy. Preserve all evidence of the call or meeting and avoid discussing it with co‐workers until you have been debriefed by law enforcement officers.

    Terms and Definitions

    • Assister: Certified broker, navigator or certified application counselor.
    • MNsure staff: Includes MNsure’s Contact Center, Assister Resource Center, Broker Service Line, Consumer Assistance Program staff and any external vendor engaged to provide contact center services on behalf of MNsure.
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