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HHS Releases Guidance on Federally Facilitated Exchanges and a Draft Blueprint for Approval of Exchanges

Erin Hertzog

Melissa Bianchi

17 May 2012
The Center for Consumer Information and Insurance Oversight (CCIIO) within the Centers for Medicare & Medicaid Services (CMS) released its long-awaited guidance regarding the federally facilitated exchanges (FFEs) on May 16, 2011.  The Patient Protection and Affordable Care Act (PPACA) established the state-run health insurance exchange as a marketplace for individuals and small employers to purchase affordable health insurance coverage.  Coverage through exchanges will begin on January 1, 2014, with enrollment beginning October 1, 2013.  Recognizing that not all states may choose to create state-run exchanges within this timeframe, however, PPACA also directs the Secretary of HHS to establish an FFE in any state that will not have a fully operable exchange by January 1, 2014 (as determined by the Secretary of HHS by January 1, 2013).  HHS’ FFE guidance addresses:
HHS Releases Guidance on Federally Facilitated Exchanges and a Draft Blueprint for Approval of Exchanges

  • How states can partner with HHS to implement selected functions in an FFE (aka “State Partnership Model”);
  • Key policies organized by exchange function; and
  • How HHS will consult with a variety of stakeholders to implement an FFE. 

The agency is accepting comments regarding this guidance through June 18, 2012.  Comments should be sent to FFEcomments@cms.hhs.gov.

Also on May 16, 2012, CCIIO released a draft blueprint for approval of a state-based or partnership exchange on May 16, 2012.  According to this guidance, HHS will approve states wishing to operate either State-Based or Partnership Model Exchanges based on the state’s submission of a Blueprint, which must include both of the following components: (1) a Declaration Letter; and (2) an Exchange Application.  The required elements of this letter and application are spelled out in further detail in the guidance.  For plan year 2014, the complete Blueprint must be submitted by November 16, 2012.

Erin Hertzog

Melissa Bianchi

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