Rose Naff - CEO Florida Health Choices

What’s in a brand?

I didn’t set out after graduating from college with a plan to launch three separate startup companies but I have.  With each venture, establishing a brand, developing style guides to ensure consistent use of colors and fonts, building brand equity, and protecting the brand became regular items on my executive to-do list.

First was the Florida Healthy Kids Corporation.  Seventeen years later, I launched Government Policy Solutions.  In 2010 I was asked to lead Florida Health Choices and the familiar life cycle of brand development commenced for the third time in my career.  However, this time it was different.

Initially, proponents of the 2008 legislation to create Florida Health Choices described the concept as being similar to a farmers’ market but formally adopted the term “exchange” when enacting 408.910, Florida Statutes.  By 2010, the federal Patient Protection and Affordable Care Act (PPACA) used the term “exchange” to refer to a place where consumers could buy health insurance with federal subsidies.  With the passage of PPACA, it became clear that Florida Health Choices needed to differentiate itself as separate and apart from the federal exchanges implemented at healthcare.gov.   A unique descriptor was desirable, and the first published use of our adopted identity as the “Health Insurance Marketplace” can be found in an Invitation to Negotiate dated July 14, 2010.

To further differentiate the state program from the federal exchanges, legislation was filed in 2011 to eliminate the term “exchange” from the law creating Florida Health Choices and replace it with “marketplace.”  The final bill, CS/HB 1125, also added the definition “Corporation’s Marketplace” to mean the single, centralized marketplace established by the program that facilitates the purchase of products made available in the marketplace.  Now firmly committed to the Marketplace descriptor both in practice and in law, the term and related slogan “the Health Insurance Marketplace” were used extensively by Florida Health Choices.

Meanwhile, in a parallel universe operating in Washington D.C., federal officials decided to test a variety of descriptors for the soon to be launched federal exchange called for in the PPACA.  A few months later Gant Daily reported that federal staff was recommending the word “exchange” be replaced with “marketplace” when referring to healthcare.gov, though the federal law clearly labeled it as an exchange.

In December 2012, federal officials published a white paper expressing intent to go beyond adopting the single word descriptor of “Marketplace” when referring to healthcare.gov.  Instead, federal officials wanted to adopt the entire slogan in use by Florida Health Choices which is “the Health Insurance Marketplace.”   I objected to the proposed descriptor for healthcare.gov during a telephone call with federal officials that same month.

On January 16, 2013, it was formally announced that healthcare.gov would be re-launched under a new name as part of its marketing effort: the “Health Insurance Marketplace.”  In a written message to federal officials on the same day, I described the agency’s use of the slogan adopted by Florida Health Choices as problematic in Florida.  To date, I have received no response to my message.

Our use of the slogan “the Health Insurance Marketplace” is well documented and began in July 2010.  It is also our official slogan and registered with the Florida Division of Corporations.  I recently wrote letters to ask several Florida-based organizations to remove our slogan from their websites and printed materials.  We were gearing up to launch a new line of comprehensive health insurance offerings and would begin a marketing campaign that relies heavily on our slogan.

A recipient of one of my letters wrote a note that included the words “shame,” “threatening,” “wrongheaded motives,” and “potentially problematic consequences for consumers.”  The writer went on further to state that “The English language requires that one capitalize the first word at the beginning of each sentence.  This may be the source of the confusion, but we will review it.”

I want to be perfectly clear here:  I did not ask that a Florida-based organization check its capitalized and lowercase letters.  There is no confusion.  Florida Health Choices is the Health Insurance Marketplace registered with the State of Florida – with or without a capital “T”.

I want to acknowledge the professional and cooperative manner by which some organizations have acknowledged their unintentional use of our slogan and the resulting corrections they have made.  Others have chosen to engage in new abuses after receiving my letter – and there is the real shame.



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