Exchanges will take one of three forms: state-based, state/federal partnership around claims management or consumer assistance or both, and federally facilitated. But HHS officials have said they believe that state-based exchanges are the best models for states.
“Standing up a health benefit exchange is an enormous and complex undertaking," Social Interest Solutions' Page said. "Even for states that already have the ball rolling, meeting the aggressive deadlines is going to be an enormous challenge."
In the blueprint required by Dec. 14, for instance, states must provide details of their plans for a state-based or state/federal partnership exchange. Besides a letter of intent, the blueprint calls for an application to be filled out that will provide HHS with details of state plans.
States need to verify they can perform certain required activities or the date when they anticipate being able to, such as involved with eligibility and enrollment; qualified health plan certification, management and oversight; consumer outreach and education, Internet website, support from consumer navigators; small business health options program or SHOP, technology infrastructure and compliance with HHS IT guidance; and privacy and security standards, policies and procedures.
Some of the activities will need supporting documentation, and states and their vendors will come up with testing and validation programs as part of a standard systems development process.
With all that is involved, however, the delay may not mean as much to states still resisting an HIX.
“We all know the dozen or so states planning to stand up an exchange,” Page said, “ but those are not the ones we're all curious about.”