Q1: My State is pursuing a State-based Exchange or a State Partnership Exchange for plan year 2014 (beginning on October 1, 2013). What do we need to do now?A1: A State that intends to pursue a State-based Exchange or a State Partnership for 2014 should prepare to submit an Exchange Blueprint, which is comprised of two parts:
- An Exchange Model Declaration Letter from your Governor; and
- An Application describing readiness to perform Exchange activities and functions.
Q2: My State is considering a Federally-facilitated Exchange. Is there anything we need to do?A2: A Blueprint Application is not required. However, it is recommended that your Governor submit an Exchange Model Declaration Letter as described in the Exchange Blueprint. This will improve service to your residents by helping to ensure alignment between your existing State markets and the Federally-facilitated Exchange.
Q3: What happens if my State does not submit a Declaration Letter to HHS about its decision to pursue an Exchange Model?A3: If a State does not choose an Exchange model, HHS will assume that the State is not planning to operate as a State-based Exchange or a State Partnership Exchange. HHS will operate the Federally-facilitated Exchange in the State and will perform the Exchange-related programs of risk adjustment and reinsurance. Your State will work with the Center for Medicaid and CHIP Services within CMS to determine whether the Federally-facilitated Exchange will make eligibility determinations or assessments for these programs.
Q4: Are there any advantages for a State if it submits a Declaration Letter prior to the submission of its Exchange Blueprint?A4: Yes. A State pursuing a State-based Exchange or a State Partnership Exchange will be offered an opportunity to consult with CMS staff to discuss the Application portion of the Blueprint (“Blueprint Consultation”) when its Model Declaration Letter is received, provided the letter is received at least 20 business days prior to the submission of the application. A Blueprint Consultation is optional; it provides a State with the opportunity to ask questions and receive feedback on the preparation of the remainder of its Exchange Blueprint, prior to submission.
Q5: Where can I find the Blueprint? Must the application be filed electronically?A5: The Blueprint Declaration Letter must be submitted through an email to State.Exchange.Group@cms.hhs.gov, as well as mailed to CMS Center for Consumer Information and Insurance Oversight (CCIIO), 200 Independence Ave SW, Suite 739H, Washington, DC 20201. The Blueprint Application must be submitted electronically, and will be available on the State Exchange Resource and Virtual Information System (SERVIS), available at: Https://servis.cms.hhs.gov on September 14, 2012. The individual(s) designated by the Governor in the Model Declaration Letter may complete and electronically sign the application.
Q6: When will approval of the Exchanges be granted by HHS?A6: The Affordable Care Act directs HHS to make initial Exchange approval determinations no later than January 1, 2013, for Exchange operation in plan year 2014. However, States that submit their Blueprints early may receive an earlier determination. States seeking HHS approval to operate an Exchange for coverage years beginning after 2014 (e.g., plan year 2015 beginning on October 1, 2014), will submit a Model Declaration Letter and Blueprint in accordance with the same process and timeframes specified for States seeking to operate an Exchange, beginning January 1, 2014.
Q7: What information is required for the Blueprint?A7: States are asked to submit a compilation of attestations, descriptions of processes, supporting documentation and reference files. The State may be asked to provide additional information after the Blueprint has been submitted, as determined necessary by CMS. In addition to completing the Exchange Blueprint, HHS may conduct on-site or virtual Exchange assessments, as part of its verification of an Exchange’s operational readiness. HHS will use the results from a State’s Reference File submissions to determine the timing for a State’s operational readiness assessment. HHS will make an approval or conditional approval decision based on the documentation and the completed Exchange Blueprint.
Additionally, the Establishment Review process has been designed to support States as they work toward Exchange approval. States may submit documentation from HHS that confirms successful Establishment Review performance, in place of certain Blueprint required documentation.
Q8: What are reference files?A8: These are files and documentation that the State will submit to demonstrate its Exchange’s ability to perform a particular Exchange activity. Where noted, the State may attest to having received confirmation from HHS of successfully providing the relevant documentation as part of the Establishment Review. In such cases, the State does not need to upload the files, and HHS will confirm the State’s submitted files and documentation from the Establishment Review conducted during oversight of the § 1311(a) grants to ensure adequate compliance related to the activity. The following provides a description of the types of reference files that may be required:
- Summary of results of State-developed testing: These summaries document comprehensive State-defined and executed system testing, including details of Exchange activities tested, the scope of testing activities conducted, and metrics detailing the results of that testing as they relate to each designated Exchange Blueprint requirement.
- Results of State execution of CMS-developed test scenarios: These scenarios will be developed by CMS to confirm implementation of those Exchange activities that require standardization across all State Exchanges. These scenarios will be released to a central Test Library on the Collaborative Application Lifecycle Tool (CALT).
- Summary of Independent Verification & Validation (IV&V) of applicable system components: These reports by an independent third party provide verification and validation that designated Exchange activities are built and operating as designed and in compliance with documented requirements.