Last week, the Department of Health and Human Services (HHS) issued two guidance documents to advance the process of exchange implementation as part of the Affordable Care Act:
- General Guidance on Federally Facilitated Exchanges: If a state decides not to operate an exchange, HHS will operate a federally facilitated exchange (FFE) in that state. This guidance describes how HHS will consult with stakeholders to implement a federally facilitated exchange, how states can partner with HHS through a state partnership exchange to implement certain functions of this exchange, and key policies for the exchange. Comments on the guidance are due on June 18, 2012, and should be sent to FFEcomments@cms.hhs.gov.
- Exchange Blueprint: States seeking to operate their own exchanges or a partnership exchange with HHS must submit an Exchange Blueprint to HHS by November 16, 2012, that demonstrates how they will meet exchange requirements. You can find the draft Blueprint requirements here. Comments are due June 18, 2012 and instructions for commenting on the draft Blueprint can be found here.
Please take this opportunity to review these guidance documents and provide us your feedback so that we can include your comments in our analysis. We will be providing our collective recommendations in early June.