States have consistently asked for more guidance on health insurance exchanges, and, today, federal regulators delivered (at least partially). Today, the Center for Consumer Information & Insurance Oversight (CCIIO) released the final Blueprint for Approval of Affordable State-based and State Partnership Insurance Exchanges. Before a state receives approval to operate its own exchange or partner with the federal government on a federally facilitated exchange, it must submit one of these Blueprints and document how it will meet legal and operational requirements of the exchange. The Blueprint is essentially a checklist of all the tasks the state must complete before it can be certified to run its own exchange or partner with CCIIO on key exchange functions like plan management and consumer assistance. Because CCIIO must certify a state’s decision on whether to operate an exchange (or not) by January 1, 2013, states have been asked to submit their Blueprints by November 16, 2013.

Here are some brief highlights from the final Blueprint. First, the Blueprint provided a little more information about the new “in-person assistance” concept first floated in July. To assist consumers in enrolling in coverage before 2014, CCIIO noted the creation of a distinct funding mechanism to support an in-person assistance program that is distinct from the Navigator program (which will not receive funding until 2014).  However, aside from announcing the existence of federal funds to support such a program, CCIIO has yet to provide guidance on what in-person assistors would be required to do, who would be eligible to serve as an assistor, and what standards assistors will have to meet. The Blueprint suggests that, at a minimum, in-person assistors would have to meet conflict of interest requirements and receive training to ensure they can effectively advise consumers on public and private coverage options.

Second, the Blueprint requires exchanges that contract with brokers (including web-based brokers) to describe their broker compensation policy and the strategies they will adopt to ensure that brokers are appropriately trained and can meet the exchange’s privacy and security standards. States must also describe how the exchange website will interface with brokers’ websites.

Other areas where the state (or exchange) must demonstrate readiness include:

• Legal authority (existing law or executive order that provides authority to establish the exchange);
• Governance (demonstrating that leadership board meets the ACA requirements regarding conflict of interest and consumer participation);
• Consumer education and outreach, including the development of culturally and linguistically appropriate materials;
• A website that provides up-to-date information on qualified health plans;
• Operation of a Navigator program, including a plan for ongoing financial support;
• A plan and the capacity for streamlined eligibility determinations and enrollment, including the use of a single, HHS-approved application for enrollment (the exchange also has to demonstrate the ability to accept and process updates and responses to redeterminations regarding eligibility status);
• The authority to certify and oversee qualified health plans, as well as a defined process and the capacity for doing so;
• The ability for employees to select qualified health plans within the level of coverage selected by their employer; and
• A long-term operational cost, budget, and management plan and defined methods for generating revenue.

To date, only 12 states have submitted letters declaring their intent to operate their own exchange. Many more, however, are likely to enter into partnership with the federal government to operate plan management and/or consumer assistance. Regardless of which option a state chooses, state regulators and lawmakers should be actively considering the tasks described in the Blueprint and devise strategies demonstrating their readiness to take on the job.