CMS-10424_Supporting_Statement_A

SUPPORTING STATEMENT FOR THE
INFORMATION COLLECTION REQUIREMENTS CONTAINED IN
THE COOPERATIVE AGREEMENTS TO SUPPORT ESTABLISHMENT OF THE
AFFORDABLE CARE ACT’S EXCHANGES
(OFFICE OF MANAGEMENT AND BUDGET (OMB CONTROL NO. 0938-NEW)

A.

Background

The Affordable Care Act creates new competitive private health insurance markets – called
“Exchanges” -- that will give millions of Americans and small businesses access to affordable
coverage. Exchanges will help individuals and small employers shop for, select, and enroll in
high-quality, affordable private health plans that fit their needs at competitive prices. Exchanges
will also assist eligible individuals to receive premium tax credits and cost sharing reductions or
help individuals enroll in other Federal or State health care programs. By providing one-stop
shopping, Exchanges will make purchasing health insurance easier and more understandable and
will put greater control and greater choice in the hands of individuals and small businesses.
Section 1311 of the Affordable Care Act provides for grants to States for the planning and
establishment of American Health Benefit Exchanges (hereinafter referred to as ‘Exchanges’).
The Secretary will disburse funds in at least three phases: first, for planning; second, for early
development of information technology; and third, for implementation. Funding was made
available for the 50 States, the District of Columbia, and the U.S. Territories of American
Samoa, the Commonwealth of the Northern Mariana Islands, Guam, Puerto Rico, and the U.S.
Virgin Islands during the planning phase. Forty-nine States, the District of Columbia, and four
Territories applied and were awarded grant funds during this phase.
In an effort to reduce replication and the cost of work on the IT components of the Exchange, the
Cooperative Agreement to Support Innovative Exchange Information Technology Systems
Funding Opportunity was announced in October 2010. In February of 2011, HHS awarded its
second phase of Exchange funding to six States and one consortium of States to develop
Exchange IT systems that will serve as models for other States. This approach aims to reduce the
need for each State to “reinvent the wheel” and aids States in Exchange establishment by
accelerating the development of Exchange IT systems.
In January, 2011, HHS announced the availability of Cooperative Agreements to Support
Establishment of State-Operated Health Insurance Exchanges. This funding opportunity provided
States with financial support for activities related to the establishment of an Exchange, including
the development of Exchange IT systems. Applications are accepted for that award on a
quarterly basis from March 2011 through June 2012.
In June, HHS intends to announce additional funding through the Cooperative Agreements to
Support Establishment of the Affordable Care Act’s Health Insurance Exchanges. This document
refers to a pre-decisional draft of a funding opportunity announcement that may change before
publication as policy decisions are finalized. It does not represent final policy. Specific

requirements for each Exchange model will be included in the the funding opportunity
announcement.
These funds may be used to support activities in States that are participating in any of the
Exchange models (Federally-facilitated, Partnership, or State-operated). As such, these funds are
available for establishing a State-operated Exchange, to develop activities that are potential areas
of collaboration under the Partnership model, and to support State activities to interface with the
Federally-facilitated Exchange.
This cooperative agreement funding opportunity is designed to give States multiple opportunities
to apply for funding as they progress through Exchange establishment, which helps support their
progress toward the establishment of an Exchange.
The process of “establishing” an Exchange may extend beyond the first date of operation and
may include improvements and enhancements to key functions over a limited period of time.
Funds may be used to establish Exchange functions and operating systems and to test and
improve systems and processes. In addition, a State that does not have a fully certified Statebased Exchange on January 1, 2013 can continue to qualify for and receive a grant award,
subject to the Funding Opportunity Announcement (FOA) eligibility criteria.
There are two levels of awards for States to apply for the Establishment grants. Level One
Establishment grants are open to States that received federal funding for Exchange Planning
activities and awardees of the Cooperative Agreements to Support Innovative Exchange
Information Technology Systems. In addition, Level One grants are open to States that are
participating in either the Federally-facilitated Exchange, including States that will be
collaborating with the Federally-facilitated Exchange on certain activities, or developing a Statebased Exchange. Level Two Establishment grants are open to States that are establishing a Statebased Exchange.
In an effort to promote flexibility, States may initially apply in this announcement for either
Level One or Level Two Establishment grants. Level One Establishment grantees may reapply
for and receive more than one award Level One Establishment category, and Level One
Establishment grantees may apply for Level Two Establishment awards. States may transition
between different Exchange models and will update their project plans accordingly. Grants may
be awarded through the end of 2014, and grant funds are available for such activities integral to
establishing an Exchange.
HHS is aiming to release the new Cooperative Agreement for the Establishment of Health
Insurances Exchanges FOA on June 15, 2012.
HHS anticipates Level One Establishment and Level Two Establishment applications will be
due: August 1, 2012; November 1, 2012; February 1, 2013; May 1, 2013; August 1, 2013;
November 1, 2013; February 3, 2014; May 1, 2014; August 1, 2014; November 3, 2014 with
anticipated Notices of Grant Award made 60 days after application due date.
The project period for each Cooperative Agreement will vary based on when a State is awarded

an Establishment Cooperative Agreement. Level One Establishment awards will be for up to one
year after the date of award. Level Two Establishment awards will be for up to three years after
the date of award.
HHS reasonably estimates that of the 51 eligible States based on readiness there will be 44
applicants for Level 1 Establishment who may subsequently apply for additional funding under
either Level 1 Establishment or Level 2 Establishment; and six States that will apply initially for
Level 2 Establishment for a total of 94 applications.
Exchanges will perform the following functions, at a minimum:
Implementing procedures for the certification, recertification, and decertification of
health plans as qualified health plans, consistent with guidelines developed by the
Secretary;
Providing for the operation of a toll-free telephone hotline to respond to requests for
assistance;
Maintaining an Internet website through which enrollees and prospective enrollees of
qualified health plans may obtain standardized comparative information on such plans;
Assigning a rating to each qualified health plan offered through the Exchange in
accordance with criteria developed by the Secretary;
Utilizing a standardized format for presenting health benefits plan options in the
Exchange, including the use of the uniform outline of coverage established under section
2715 of the Public Health Service Act;
Informing individuals of eligibility requirements for the Medicaid program under title
XIX of the Social Security Act, the CHIP program under title XXI of such Act, or any
applicable State or local public program, and if through screening of the application by
the Exchange, the Exchange determines that such individuals are eligible for any such
program, enrolls such individuals in such program;
Making available by electronic means a calculator to determine the actual cost of
coverage after the application of any premium tax credit/premium assistance or costsharing reduction;
Granting exemptions from the individual responsibility penalty, and providing
information on exempt individuals to the Treasury;
Providing certain information to employers; and,
Establishing the Navigator program, which will provide grants to entities for public
education activities, facilitate enrollment in qualified health plans, and refer individuals
for assistance with grievances, complaints, or questions about their health coverage.

This grant opportunity will support activities including, but not limited to, the following:
Involving stakeholder groups to gain public input into the Exchange establishment
process;
Developing legislative and regulatory action in accordance with State legislative
calendars to support the State legislature in passing enabling legislation for the
establishment of the Exchange;
Establishing the administrative structure and governance structure of the Exchange;
Coordinating with State Medicaid, CHIP, Department of Insurance, and other State health
subsidy programs throughout Exchange establishment activities related to streamlining
eligibility and enrollment;
Assessing and developing IT systems and modifications/new systems needed to facilitate
eligibility and enrollment and other Exchange functions;
Undertaking financial integrity activities, activities for prevention of waste, fraud, and
abuse, and auditing;
Identifying funding requirements and resources needed to operate the Exchange,
including fees that will be required, in order to achieve self-sustainability by January 1,
2015.
HHS will work with States in establishing processes for Exchanges. As a part of this
collaboration, this grant opportunity will require that States meet certain periodic reporting
requirements, and consult regularly with HHS.
All 50 States and the District of Columbia are eligible for the Cooperative Agreement to Support
Establishment of the Affordable Care Act’s Exchanges. In order to receive a grant, applicants
must be an eligible entity, must meet all technical application requirements (including the
submission of all required forms), and address certain specified areas in the application.

There are several key elements of this FOA:
The new FOA will make clear that funding is available to support activities related to the
establishment of any Exchange model: Federally-facilitated Exchanges (FFE),
Partnership Exchanges, or State Based Exchanges (SBE).
Funding will be available for all Exchange models through a final award date no later
than December 31, 2014.
The Level One Establishment/Level Two Establishment application structure introduced
in the Cooperative Agreements to Support State-Operated Health Insurance Exchanges

FOA will be maintained. Level 2 funding will remain exclusively for states with the legal
authority to establish a State-based exchange. However, Level 1 funding may be used by
States for State-Operated Exchanges, Federally-facilitated Exchanges, and the
Partnership model.
Similar to the Cooperative Agreements to Support State-Operated Health Insurance
Exchanges FOA, a Governor’s letter of support endorsing the application will be
required.
However, for Level 1 applicants the Governor will now be required in this letter to
identify which Exchange model the State is proposing to move towards (e.g., SBE, FFE,
Partnership). The FOA allow States the flexibility to transition between Exchange
models while maintaining funding.
States that previously received Level 1 and Level 2 funding will be eligible to apply for
funds under this FOA. Funding must support activities that are clearly distinct from those
supported by other grants and cooperative agreements.
The new FOA will move from the existing structure of eleven Core Areas to one in which
States conduct thirteen Exchange Activities. These areas will be:
1. Legal Authority and Governance
2. Consumer and Stakeholder Engagement and Support
3. Eligibility and Enrollment
4. Plan Management
5. Risk Adjustment, and Reinsurance
6. Small Business Health Options Program
7. Organization and Human Resources
8. Finance and Accounting
9. Technology
10. Privacy and Security
11. Oversight, Monitoring, and Reporting
12. Contracting, Outsourcing, and Agreements
13. State Partnership Exchange Activities

This FOA will continue to fund all activities associated with establishing the policy,
operations and IT components of an Exchange, including building and testing the
functions of the Exchange.

The FOA will provide guidance on the types of activities that can be supported with this
funding in different Exchange models, such as those carried out by the State Department
of Insurance.
Publication of this new announcement does not impact cooperative agreements that have already
been awarded, or applications under review.
Funding is available to eligible entities regardless of whether or not the applicant already
receives an Establishment award. However, the applicant cannot apply to fund a specific activity
that is already supported by another award. Grantees are required to track activities under each
award to determine that activity is not otherwise supported by an Exchange grant.

B.

Justification

1 .Need and Legal Basis
Section 1311(b) of the Affordable Care Act provides the opportunity for each State to establish
an Exchange no later than January 1, 2014. Section 1311 of the Affordable Care Act provides
for grants to States for the planning and establishment of these Exchanges. Given the innovative
nature of Exchanges and the statutorily-prescribed relationship between the Secretary and States
in their development and operation, it is critical that the Secretary work closely with States to
provide necessary guidance and technical assistance to ensure that States can meet the prescribed
timelines, federal requirements, and goals of the statute.
In order to provide appropriate and timely guidance and technical assistance, the Secretary must
have access to timely, periodic information regarding State progress. Consequently, the
information collection associated with these grants is essential to facilitating reasonable and
appropriate federal monitoring of funds, providing statutorily-mandated assistance to States to
implement Exchanges in accordance with Federal requirements, and to ensure that States have all
necessary information required to proceed, such that retrospective corrective action can be
minimized.
2.

Information Users

Information collected as a part of the application for this grant will be used to evaluate the
applications and determine awardees. Information collected pursuant to the reporting
requirements for awardees will be used to evaluate the progress of States in planning for and
implementing Exchanges, and determine how the Secretary can provide assistance to achieve the
goals of the grant program and the Affordable Care Act.

3.

Use of Information Technology

The information collection requirements associated with this grant will primarily involve
programmatic narrative based on policy research and strategic planning processes, and
accompanying budget narrative and appropriate supporting documentation. This grant does not
involve the tracking or submission of person-level data. As such, it is expected that States will
create data with readily available word processing and spreadsheet programs, and submit such
information electronically. This should result in 100 percent of information being transmitted
electronically.
Government Paperwork Elimination Act (GPEA)
Is this collection currently available for completion electronically?
Yes, awardees are required to send electronic reporting to HHS. Our intent is to have the
awardees report to HHS using the Microsoft Word application, in PDF format, or by a
grant-oriented data collection mechanism.
Does this collection require a signature from the respondent(s)?
Yes, the application will require a signature. Progress reports will utilize e-signature.
If HHS had the capability of accepting electronic signature(s), could this collection be made
available electronically?
Given the one or two-time nature of application for funding, an e-signature will not be
utilized. E-signature could be utilized as appropriate as part of a grant-oriented data
collection mechanism.
If this collection isn’t currently electronic but will be made electronic in the future, please give a
date (month & year) as to when this will be available electronically and explain why it can’t be
done sooner.
Not applicable since all data collections will be electronic.
If this collection cannot be made electronic or if it isn’t cost beneficial to make it electronic,
please explain.
Not applicable since all data collections will be electronic.
4.

Duplication of Efforts

Since this is a new program that was created through the Affordable Care Act, the
information that will be collected has never been collected before by the Federal government.
5.

Small Businesses
The information collection requirements of the Regulation do not have a significant impact
on a substantial number of small entities.

6.

Less Frequent Collection
Close monitoring will be critical to ensuring that States receive prompt Federal guidance and
technical assistance that is responsive to any State-specific issues that may arise, and that
State activities meet statutory and other Federal requirements. In the absence of regularly
reporting, there is a risk that States could invest resources and conduct activities that are not
aligned with requirements. As such, HHS will be in close contact with awardees. Upon
request by awardees, HHS may allow less frequent reporting due to burden on program
activities.

7.

Special Circumstances
Requiring respondents to report information to the agency more often than quarterly;
CCIIO may wish to follow up with States in between reporting periods in order to ensure
close collaboration on Exchange development.
Requiring respondents to prepare a written response to a collection of information in fewer
than 30 days after receipt of it;
CCIIO may wish to follow up with States in between reporting periods in order to ensure
close collaboration on Exchange development.
Requiring respondents to submit more than an original and two copies of any document;
Not applicable. We will not require more copies than an original and two copies of any
document.
Requiring respondents to retain records, other than health, medical, government contract,
grant-in-aid, or tax records for more than three years;
Not applicable.
In connection with a statistical survey that is not designed to produce valid and reliable
results that can be generalized to the universe of study

Not applicable. Statistical surveys are not contemplated for this program.
Requiring the use of a statistical data classification that has not been reviewed and
approved by OMB;
Not applicable. Statistical surveys are not contemplated for this program.
That includes a pledge of confidentiality that is not supported by authority established in
statue or regulation that is not supported by disclosure and data security policies that are
consistent with the pledge, or which unnecessarily impedes sharing of data with other
agencies for compatible confidential use; or
Not applicable. These information collections do not include a pledge of confidentiality.
Requiring respondents to submit proprietary trade secret, or other confidential information
unless the agency can demonstrate that it has instituted procedures to protect the
information's confidentiality to the extent permitted by law.
Not applicable. This is outside the scope of our reporting requirements.
8.

Federal Register/Outside Consultation

As required by the Paperwork Reduction Act of 1995 (44 U.S.C.2506 (c)(2)(A)), the Center for
Consumer Information and Insurance Oversight (CCIIO) published a notice in the Federal
Register on March 2, 2012 (Vol. 77, p42), requesting public comment on its proposed
information collection requirements specified in the Cooperative Agreements to Support
Establishment of the Affordable Care Act’s Exchanges (OMB Control No. 0938-NEW). The
notice was part of a preclearance consultation program intended to provide those interested
parties the opportunity to comment on CCIIO’s request by the Office of Management and
Budget (OMB) of the collections of information required by the grant. No outside parties were
consulted in the development of this collection CCIIO will publish a second notice in the
Federal Register for additional public comment.
The Centers for Medicare and Medicaid (CMS) received four comments, all conveyed via email
from States, related to CMS-10424, which is entitled “Cooperative Agreement to Support
Establishment of the Affordable Care Act's Health Insurance Exchanges.” The information
presented below is a synopsis of the comments received and CMS’ responses to them.
(1)

Comment:

Several commenters questioned why the Federal Register Notice stated that applicants would
have four opportunities to apply for funding and listed ten application dates.
Response:

This was a typographical error. Applicants will have ten opportunities to apply for Establishment
Cooperative Agreements, on the application cycles presented in the Supporting Statement:
August 1, 2012; November 1, 2012; February 1, 2013; May 1, 2013; August 1, 2013; November
1, 2013; February 3, 2014; May 1, 2014; August 1, 2014; November 3, 2014.
(2)

Comment:

One commenter asked whether the new funding opportunities would be subject to the same
format and content requirements as the existing Cooperative Agreement and FOA, Cooperative
Agreements to Support Establishment of State-Operated Health Insurance Exchanges (funding
opportunity number IE-HBE-11-004.)
Response:
Certain format and content requirements are determined by HHS grants policy; FOA specificcontent and format is still being finalized, but the PRA package provides an estimate of
respondent burden to prepare an application.
(3)

Comment

One commenter asked whether the new application cycles provided in this application would be
open to both Level One and Level Two applications. The commenter also asked whether the
new structure would allow Level Two requests in multiple stages.
Response:
HHS anticipates this Funding Opportunity will be open to both Level One and Level Two
applications. Level One funds are available to States eligible for Level Two funding, and offer
the flexibility of multiple stages of funding. More information will be available when the
Funding Opportunity Announcement is finalized.
(4)

Comment

One commenter asked if there were any process or timing implications of releasing this as a PRA
request for comment rather than a less formal bulletin.
Response:
Under the Paperwork Reduction Act (PRA), HHS is required to share proposed information
collections with the public and receive and respond to comments on the burden it would impose
on respondents. This Funding Opportunity represents an information collection subject to PRA.
Typical timing of a PRA clearance process is available at the following link:
http://www.hhs.gov/ocio/policy/collection/infocollectfaq.html#17
(5) Comment

What can funds be used for in 2014 if Exchange are to be operational January 1, 2014?
Response:
The process of “establishing” an Exchange may extend beyond the first date of operation and
may include improvements and enhancements to key functions over a limited period of time.
Funds may be used to establish Exchange functions and operating systems and to test and
improve systems and processes. In addition, a State that does not have a fully certified Statebased Exchange on January 1, 2013 can continue to qualify for and receive a grant award,
subject to the Funding Opportunity Announcement (FOA) eligibility criteria.
Also, below are two links that provide additional information on the recently released PRA as
well as FAQs that are posted on the CCIIO website you may find helpful in relation to your
questions about funding availability and use of funds.
PRA:
http://cciio.cms.gov/resources/fundingopportunities/index.html#hie
FAQs:
http://cciio.cms.gov/resources/files/Files2/11282011/exchange_q_and_a.pdf.pdf
(6) Comment
What are the anticipated application due dates? When will the FOA be released?
Response:
HHS is aiming to release the new Cooperative Agreement for the Establishment of Health
Insurances Exchanges FOA on June 15, 2012.
HHS anticipates Level One Establishment and Level Two Establishment applications will be
due: August 1, 2012; November 1, 2012; February 1, 2013; May 1, 2013; August 1, 2013;
November 1, 2013; February 3, 2014; May 1, 2014; August 1, 2014; November 3, 2014 with
anticipated Notices of Grant Award made 60 days after application due date.
9.

Payments/Gifts to Respondents
Not applicable. We will not provide any payments or gifts.

10.

Confidentiality
Not applicable. No assurance of confidentiality is provided to respondents. Further,
HHS will not collect personally identifiable information from awardees as a part of this
grant. All reporting will be of an aggregate nature.

11.

Sensitive Questions
Not applicable. Data collection will not include sensitive questions.

12.

Burden Estimates (Hours & Wages)
For the purposes of obtaining a PRA approval, we anticipate that 50 States and the District
of Columbia will receive a Notice of Grant Award.

I. APPLICATION
In order to complete the application, each applicant will need to read the application
requirements, assemble, review, finalize and submit an application package to the Department of
Health and Human Services (HHS). This burden estimate encompasses the entire application
process, which includes assembly of all required application content (standard forms, project
narrative, work plan, budget narrative, and applicable supporting documents), certification of the
application package by a senior official at the State, application submission to HHS and any
subsequent application amendments, corrections or supporting documentation that may be
necessary. The final application must be submitted electronically via Grants.gov using the
directions furnished in the application by HHS.

Estimated Annualized Burden Table - Application

Forms

Grant
Application
Total

Type of
Respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
hours per
Response

Total
Burden
Hours

51

1

564
564

28764
28764

State
Government

We estimate that it will take approximately 564 hours per applicant to read, assemble, review,
finalize and submit their application package to HHS. We believe up to 19 people per applicant
will be involved in the application assembly at a cost of $28,081. We reasonably estimate that of
the 51 eligible States based on readiness there will be 44 applicants for Level 1 Establishment
who may subsequently apply for additional funding under either Level 1 Establishment or Level
2 Establishment; and six States that will apply initially for Level 2 Establishment for a total of 94
applications, with an annualized estimate of one application per eligible entity per year. The
estimated annualized burden is 28,764 hours and $1,432,178.
Fifty States and the District of Columbia are eligible applicants for this funding opportunity. The
Governor of a State (the Mayor, if from the District of Columbia) may designate a State agency
or quasi-governmental entity to apply for grants on behalf of that State. Non-profit organizations
are not eligible to apply. Only one application per State is permitted.
Because States have different staffing levels and pay scales, we make the following assumptions
about completing the application. We calculate total hourly wage based on the mean hourly
wage, 34.3% of compensation from benefits, and fringe rate. We calculate total annual salary by
multiplying total wage by a full-time, year-round working year of 2,080 hours. (Source: May
2009 National Industry-Specific Occupational Employment and Wage Estimates - State
Government htttp://www.bls.gov/oes/current/naics4_999200.htm.)
Estimated Annualized Cost Table for Completing the Application

Type of respondent

Senior-level manager
to oversee application
Senior-level manager
to conduct most
writing

Number of
Respondents

Number of
Responses per
Respondent

Average
Burden
Hours

Wage per
Hour
(including
fringe)

Burden Costs

51

1

14

$

56.48

$

40,326.72

51

1

56

$

56.48

$

161,306.88

Type of respondent

Number of
Respondents

Number of
Responses per
Respondent

51

1

51

$

41.23

$

107,239.23

51

1

35

$

56.48

$

100,816.80

51

1

35

$

41.23

$

73,595.55

51

1

45

$

56.48

$

129,621.60

51

1

45

$

41.23

$

94,622.85

51

1

40

$

56.48

$

115,219.20

51

1

30

$

41.23

$

63,081.90

51

1

48

$

64.98

$

159,071.04

51

1

33

$

49.56

$

83,409.48

51

1

48

$

37.78

$

92,485.44

51

1

14

$

24.67

$

17,614.38

Lawyer
Budget analyst from
outside core team

51

1

17

$

60.55

$

52,496.85

51

1

39

$

44.60

$

88,709.40

Agency head (1)

51

1

4

$

76.47

$

15,599.88

Agency head (2)

51

1

4

$

76.47

$

15,599.88

Agency head (3)
Official in Governor's
office

51

1

4

$

76.47

$

15,599.88

51

1

2

$

56.48

$

5,760.96

$

1,432,177.92

Mid-level policy
analyst to support
writing
Senior-level manager
with insurance
expertise
Mid-level policy
analyst with insurance
expertise
Senior-level manager
from Medicaid agency
Mid-level policy
analyst from Medicaid
agency
Senior-level manager
with health policy
expertise
Mid-level policy
analyst with health
policy expertise
Computer and
Information Systems
Managers
Computer Systems
Analyst
Administrative budget
analyst
Administrative
assistant

Average
Burden
Hours

Wage per
Hour
(including
fringe)

Total

Burden Costs

II. DATA COLLECTION REPORT
During each one-year grant cycle, grantees must submit data a minimum of two times: two
semiannual reports, and a number of periodic reports based on the grantee’s progress and funded
activities. Each data submission will be based on a reporting template (OMB Control No. 0938NEW), and must address the following:

Estimated Annualized Burden Table – Reporting by Awardees

Forms

Progress Report
Public Report
Establishment
Review

Type of
Respondent

Number of
Respondents

Number of
Responses per
Respondent

Estimated
Burden hours
per Response

51

2

115

11730

51

2

8.5

867

51

1.5

115

8797.5

238.5

21394.5

State
Government
State
Government
State
Government

Total

Total Estimated
Burden Hours

1. Progress Report
Grantees must provide HHS with information such as, but not limited to, project status,
implementation activities initiated, accomplishments, barriers, and lessons learned in order to
ensure that funds are used for authorized purposes. Such performance includes submission of the
State’s progress toward the Exchange Activities in its Work Plan. The Cooperative Agreement to
Support Establishment of the Affordable Care Act’s Health Insurance Exchanges funding
opportunity announcement (Funding Opportunity Number: TBD) provides a series of subfunctions organized under each Exchange Function. Each State Exchange should draw from
these sub-functions in the development of its Work Plan. The report could include, but will not
be limited to:
Progress on State determined goals, milestones, and activities
Changes in work plan components
Lessons learned
The final progress report will serve as the final project report and should discuss
accomplishments throughout the entire project period.
We estimate that it will take approximately 115 hours per applicant to assemble, review, finalize
and submit each progress report to HHS. We believe that 24 personnel will be required for the
production and delivery of required progress reports. The total burden for 51 applicants to
submit two reports each is 11,730 hours and $584,424.
Because staffing levels and pay scales vary by state, we make the following assumptions about
the reporting process.

Annualized Cost Estimate for All Respondents Completing the Progress Report

Type of
respondent

Senior-level
manager to
oversee efforts
Senior-level
manager to
conduct most
writing
Mid-level
policy analyst
to support
writing
Senior-level
manager with
insurance
expertise
Mid-level
policy analyst
with insurance
expertise
Senior-level
manager from
Medicaid
agency
Mid-level
policy analyst
from
Medicaid
agency
Senior-level
manager with
health policy
expertise
Mid-level
policy analyst
with health
policy
expertise
Administrativ
e budget
analyst
Budget
analyst with
insurance
expertise
Budget

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours Per
Response

Wage per Hour
(including
fringe)

Burden Costs

51

2

15

$

56.48

$

86,414.40

51

2

18

$

56.48

$

103,697.28

51

2

24

$

41.23

$

100,931.04

51

2

2

$

56.48

$

11,521.92

51

2

2

$

41.23

$

8,410.92

51

2

2

$

56.48

$

11,521.92

51

2

2

$

41.23

$

8,410.92

51

2

2

$

56.48

$

11,521.92

51

2

2

$

41.23

$

8,410.92

51

2

8

$

37.78

$

30,828.48

51

2

3

$

44.60

$

13,647.60

51

2

3

$

44.60

$

13,647.60

Type of
respondent

analyst from
Medicaid
agency
Budget
analyst with
systems
expertise
Senior-level
financial
manager with
insurance
expertise
Senior-level
financial
manager from
Medicaid
agency
Senior-level
financial
manager with
health policy
expertise
Senior-level
manager with
systems
architecture
expertise
Mid-level
analyst with
systems
architecture
expertise
Systems
project
manager
Administrativ
e assistant
Lawyer

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours Per
Response

Wage per Hour
(including
fringe)

Burden Costs

51

2

3

$

44.60

$

13,647.60

51

2

2

$

62.69

$

12,788.76

51

2

2

$

62.69

$

12,788.76

51

2

2

$

62.69

$

12,788.76

51

2

6

$

64.98

$

39,767.76

51

2

4

$

49.56

$

20,220.48

51

2

4

$

41.23

$

16,821.84

51

2

2

$

24.67

$

5,032.68

51

2

2

$

60.55

$

12,352.20

Lawyer

51

2

2

$

60.55

$

12,352.20

Budget
analyst from
outside core
team
Agency head

51

2

2

$

44.60

$

9,098.40

51

2

1

$

76.47

$

7,799.94

$

584,424.30

Total

2. On-Site Performance Review (“Establishment Review”)

HHS intends to use the grant process and its evaluation of a State’s progress in completing its
Work Plan as the opportunity to provide hands-on assistance and counseling to States. Our
mutual goal is the successful certification and operation of each State’s Exchange.
HHS is interested in enhancing the performance of its funded programs within communities and
States. As part of this agency-wide effort, grantees will be required to participate, where
appropriate, in an on-site performance review of their HHS-funded project(s) by a review team.
The timing of the performance review is at the discretion of HHS. States may also be subject to
site visits to enable HHS to conduct evaluations of Exchange progress as needed to support the
determinations HHS must make related to Exchange certification, as detailed in the Cooperative
Agreement to Support Establishment of the Affordable Care Act’s Health Insurance Exchanges
(Funding Opportunity Number: TBD).

Annualized Cost Estimate for All Respondents Completing Establishment Reviews

Type of
respondent

Senior-level
manager to
oversee efforts
Senior-level
manager with
insurance
expertise
Mid-level
policy analyst
with insurance
expertise
Senior-level
manager from
Medicaid
agency
Mid-level
policy analyst
from
Medicaid
agency
Administrativ
e budget
analyst
Budget
analyst with
insurance
expertise
Budget
analyst from

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours Per
Response

Wage per Hour
(including
fringe)

Burden Costs

51

1.5

24

$

56.48

$

103,697.28

51

1.5

6

$

56.48

$

25,924.32

51

1.5

11

$

41.23

$

34,695.05

51

1.5

6

$

56.48

$

25,924.32

51

1.5

7

$

41.23

$

22,078.67

51

1.5

10

$

37.78

$

28,901.70

51

1.5

4

$

44.60

$

13,647.60

51

1.5

4

$

44.60

$

13,647.60

Type of
respondent

Medicaid
agency
Budget
analyst with
systems
expertise
Senior-level
financial
manager with
insurance
expertise
Senior-level
financial
manager from
Medicaid
agency
Senior-level
manager with
systems
architecture
expertise
Mid-level
analyst with
systems
architecture
expertise
Administrativ
e assistant
Total

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours Per
Response

Wage per Hour
(including
fringe)

Burden Costs

51

1.5

4

$

44.60

$

13,647.60

51

1.5

6

$

62.69

$

28,774.71

51

1.5

6

$

62.69

$

28,774.71

51

1.5

6

$

64.98

$

29,825.82

51

1.5

7

$

49.56

$

26,539.38

51

1.5

14

$

24.67

$

26,421.57

$

422,500.32

We estimate that it will take approximately 115 hours per applicant to assemble, review, finalize
and make available materials and presentations for each Establishment Review. We estimate
that fourteen of the personnel involved in reporting would be involved in completing on-site
reviews. The annualized total burden for 51 applicants to complete three Establishment Reviews
in two years each is 8,797 hours and $422,500.
3. Public Report
Grantees are required to prominently post progress reports about grant activity on their
respective Internet websites to ensure that the public has information on the use of funds. The
Public Report must be compliant with Section 508. The content of each public report should
include information on the progress of each State’s Exchange.

Annualized Cost Estimate for All Respondents Completing Public Report

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Wage per Hour
(including fringe)

General and Operations
Managers
Management Analysts

51

2

2

$ 56.48

$ 11,521.92

51

2

3

$ 41.23

$ 12,616.38

Budget Analysts

51

2

3.5

$ 44.60

$ 15,922.20

TOTAL

Burden Costs

$ 40,060.50

We estimate that it will take approximately 8.5 hours per applicant to assemble, review, finalize
and make available each public report, and that grantees will make reports available
semiannually. We estimate that three of the personnel involved in reporting would be involved
in making progress reports public. The total burden for 51 entities to post two public reports
each is 867 hours and $40,060.
13. Capital Costs
We anticipate that contracts will be awarded to existing entities, not to start-up organizations,
therefore we do not anticipate a total capital and start-up cost component. As such, we have
not estimated these costs to applicants.
We do not anticipate applicants incurring operational costs beyond those estimated above.
As we expect that existing entities will be the recipients of these awards, we have not
calculated costs related to electronic communication. However, we have estimated possible
costs that might arise from States that may not conduct the application development process
entirely electronically via either email or facsimile.
It may be necessary to make up to 500 copies in black and white on 8.5” by 11” paper. HHS
reasonably estimates that of the 51 eligible States based on readiness there will be 44
applicants for Level 1 Establishment who may subsequently apply for additional funding
under either Level 1 Establishment or Level 2 Establishment; and six States that will apply
initially for Level 2 Establishment for a total of 94 applications. At an estimated maximum
price of $0.10 per page, this results in a price of $50 per state per application or $4,700 for
all 94 applications.
Applicants may also incur costs associated with mailings. A maximum estimated price for a
mailing, based on the use of Express Mail by the United States Postal Service is $40.50.
This is calculated by the cost of an Express Mail flat rate envelope, for a package weighing
8 ounces, delivered at the highest zone (8) price on a non-holiday Monday through Saturday.
The total cost, based on an estimate of ten mailings per State is $405 per applicant or a total
of $38,070.

14. Cost to Federal Government
Preparation of the Funding Opportunity Announcement was a one-time cost of $4,805 of
ordinary labor costs based on a full-time GS-11 salary, which we annualized over the four
program years. The applications will be prepared and reviewed by staff in the Washington,
D.C. area at the GS-13, GS-11, and GS-9 levels. Applications will only be reviewed in the
first three program years, but we have annualized this cost over four program years.
Based on the 2012 GS pay schedule, a GS-13, Step 1 earns $89,033 annually; a GS-11, Step
1 earns $62,467 annually; and a GS-9, Step 1 earns $51,630 annually. To derive hourly
estimates, HHS divided annual compensation estimates by 2,080, the number of hours in the
Federal work year. HHS then multiplied hourly rates by a standard government benefits
multiplication factor of 1.6.
Federal staff will convene an outside panel of experts to evaluate applications and assist in
the selection process as an objective review panel. We assume that the panelists will be local
and their travel expenses will not be reimbursed, and those who choose not to travel will use
existing HHS conference calling capabilities.
Total annual estimated cost to the federal government for preparation of funding
announcements, review of applications and selection of grantees is therefore $6,097 of
ordinary labor costs.
Federal staff will prepare and review progress reports. Reports will be evaluated across all
program years. Federal staff will also conduct remote and on-site reviews with State
planners, as appropriate.
Total annual estimated cost to the federal government for review of reports and other grantee
progress, including labor and travel costs, is $136,292.
Total annual cost to the federal government is estimated at $142,390.
15.

Changes to Burden

In the Federal Register Notice dated March 2, 2012 (Vol.77, p42), HHS identified 49 States and
the District of Columbia as eligible applicants for this award. Subsequent review by HHS has
found that all States are eligible applicants for this award. HHS has therefore revised its overall
burden estimates to include 51 eligible entities, rather than 50. This resulted in an overall change
of 564 hours and $28,081 in application burden, and an annual overall change of 420 hours and
$20,059 in reporting burden. This change did not impact the burden on individual respondents.
This resulted in an overall increase of $6,340 in cost to the Federal government.

16.

Publication/Tabulation Dates
The Department will not publish the information collected under this application.

17.

Expiration Date

CCIIO would like an exemption from displaying the expiration date as these forms are used on a
continuing basis. To include an expiration date would result in having to discard a potentially
large number of forms.
18.

Certification Statement
There are no exceptions to the certification statement identified in Item 19, “Certification for
Paperwork Reduction Act Submissions,” of OMB Form 83-I.