Exchange Blueprint - Crosswalk document

CROSSWALK OF REVISIONS BASED ON 60-DAY COMMENTS FOR BLUEPRINT FOR APPROVAL OF AFFORDABLE HEALTH
INSURANCE MARKETPLACES
(FORMERLY REFERRED TO AS CERTIFICATION APPLICATION)
Original Section of
Marketplace Blueprint
– pre 60-day
Comments

Revised Section of
Marketplace Blueprint –
post 60-day Comments

Change

Rationale

State-Based Marketplace Application
1.0 Legal Authority
and Governance

1.0 Legal Authority
and Governance

• Changed application format.
• Removed U.S. Department of Health and Human

Services (HHS) benchmark dates.
• Removed frequency with which Marketplace needs to
hold board meetings.

The Center for Consumer
Information and Insurance
Oversight (CCIIO) has changed
the format for completing and
attesting to Blueprint activities to
alleviate applicant confusion and
simplify the application process.
The new format will also allow
the Centers for Medicare &
Medicaid Services (CMS) to
more efficiently determine
whether or not a state has
attested to a particular activity
and evaluate a state’s position in
terms of gaining approval.
CCIIO has removed specific
dates and timeframes by which
Marketplaces must complete an
activity to provide flexibility to
state project plans due to
changing Blueprint deadlines
and varying levels of progress
toward Marketplace build a state
is able to leverage. Removal of
HHS benchmark dates will make

1

Original Section of
Marketplace Blueprint
– pre 60-day
Comments

2.0 Consumer and
Stakeholder
Engagement and
Support

3.0 Eligibility and
Enrollment

Revised Section of
Marketplace Blueprint –
post 60-day Comments

2.0 Consumer and
Stakeholder
Engagement and
Support

3.0 Eligibility and
Enrollment

Change

• Changed the application format.
• Removed HHS benchmark dates.
• Included regulatory citations for tribal consultation,

outreach and education, and call center activities.
• Included language for outreach and education, call
center, and website activities to more closely align to
statutory language.
• Removed activity around digital media materials.
• Removed activity around risk mitigation for Navigators
and non-Navigator assistance personnel.

• Changed the application format.
• Removed HHS benchmark dates.
• Separated activities for individual, Small Business
Health Options Program (SHOP) employer, and
SHOP employee applications.
• Revised language for Appeals section to reflect
updated regulations.

4.0 Plan
Management

4.0 Plan Management

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•
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•

Changed the application format.
Removed HHS benchmark dates.
Added language to clarify the Plan Preview process.
Added language to more explicitly define plan
management system requirements.

Rationale

the Blueprint Application
applicable for any state wishing
to apply in subsequent years.
See above.
Included new language and
regulatory citations where
applicable to ensure the
Blueprint Application most
accurately reflects current
rulemaking and to justify
Blueprint activities by statute.
Removed specific activities to
allow for the most flexibility to
states in designing Marketplace
programs that best suit their
population.
See above.

Revisions reflect current
regulatory guidance.
See above.
Added explanatory language
around certain activities to
alleviate any applicant confusion
when completing the Blueprint
Application.

2

Original Section of
Marketplace Blueprint
– pre 60-day
Comments

Revised Section of
Marketplace Blueprint –
post 60-day Comments

Change

Rationale

5.0 Risk Adjustment

5.0 Risk Adjustment

• Changed the application format.
• Removed HHS benchmark dates.
• Removed the 30-day post Federal Payment Notice
requirement to have published the notice of benefit
and payment parameters and included regulatory
citation for activity.

See above.

6.0 SHOP

6.0 SHOP

• Changed the application format.
• Removed HHS benchmark dates.
• Removed specific frequency with which states should
require qualified health plan (QHP) issuers to make
rate changes in the SHOP.
• Removed “If applicable” from activity around uniform
timing for QHP issuer rate changes in the SHOP.
• Added appropriate regulatory citations.
• Included requirement for method to determine how the
state will determine whether an employee is a full-time
employee.
• Clarified the notices that must be demonstrated for the
SHOP.
• Changed the application format.
• Removed HHS benchmark dates.
• Included more robust language for activity description.
• Requested information through 2016 as opposed to
2015.

See above.

7.0 Organization and
Human Resources

7.0 Organization and
Human Resources

8.0 Finance and
Accounting

8.0 Finance and
Accounting

• Changed the application format.
• Removed HHS benchmark dates.
• Requests long-term budget information for the
upcoming five years as opposed to 2015.
• Requests budget documentations describing sources
of revenue, enrollment projections, etc.

Ensured activities most
accurately reflect and assess
readiness for specific
Marketplace functioning based
on most current policy.

See above.
Requested long-term information
to adequately prepare for longterm sustainability for the
Marketplace.
See above.
Necessary to gain a better
assessment of a state’s
sustainability.

3

Original Section of
Marketplace Blueprint
– pre 60-day
Comments
9.0 Technology

10.0 Privacy and
Security

Revised Section of
Marketplace Blueprint –
post 60-day Comments
9.0 Technology

10.0 Privacy and
Security

Change

• Changed the application format.
• Removed HHS benchmark dates.
• Request CALT ID numbers for enterprise lifecycle
(ELC) artifacts as opposed to actual document.
• Removed specific ELC artifacts from application.
• Removed 70 percent build demonstration.

• Changed the application format.
• Removed HHS benchmark dates.
• Request CALT ID numbers for privacy and security
artifacts as opposed to actual document to reflect
current protocol.

11.0 Oversight and
Monitoring

11.0 Oversight and
Monitoring

12.0 Contingency
Planning

12.0 Contingency
Planning

13.0 Re-use

13.0 Re-use
14.0 Coordination
between the Statebased Marketplace
and the Federallyfacilitated Marketplace

• Changed the application format.
• Removed HHS benchmark dates.
• Included requirement to maintain documentation
•
•
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•

demonstrating compliance with Federal standards for
oversight and monitoring activities.
Changed the application format.
Removed HHS benchmark dates.
Changed the application format.
Removed HHS benchmark dates.
Added activity related to coordination between the
State-based Marketplace and the Federally-facilitated
Marketplace.

State Partnership Marketplace Application
1.0 Legal Authority
and Governance

1.0 Legal Authority
and Governance

• Removed section.

Rationale

See above.
Requesting the ID numbers for
CALT documentation as
evidence to reduce the burden
placed on states as they
complete their Blueprint and
avoid duplication.
See above.
Change reflects current protocol
for submitting privacy and
security artifacts to CMS for
review.
See above.

Additional activity was needed to
ensure appropriate transfer of
data between the State-based
Marketplace and the Federallyfacilitated Marketplace.
As Plan Management activities
will no longer be available for the
State Partnership model, no

4

Original Section of
Marketplace Blueprint
– pre 60-day
Comments

Revised Section of
Marketplace Blueprint –
post 60-day Comments

2.0 Consumer and
Stakeholder
Engagement and
Support

2.0 Consumer and
Stakeholder
Engagement and
Support

4.0 Plan
Management
9.0 Technology

4.0 Plan Management
9.0 Technology

Change

•
•
•
•

Changed the application format.
Removed HHS benchmark dates.
Included regulatory citations when appropriate.
Included language for outreach and education
activities to more closely align to statutory language.
• Included more descriptive language for development
of outreach materials.
• Removed section.

• Changed the application format.
• Removed HHS benchmark dates.
• Tailored technology requirements to Partnership
Marketplace model.

10.0 Privacy and
Security

10.0 Privacy and
Security

• Changed the application format.
• Removed HHS benchmark dates.
• Request CALT ID numbers for ELC artifacts as
opposed to actual document.

11.0 Oversight and
Monitoring

11.0 Oversight and
Monitoring

12.0 Contingency
Planning

12.0 Contingency
Planning

13.0 Re-Use

13.0 Re-Use

• Changed the application format.
• Removed HHS benchmark dates.
• Included the requirement for the capacity to maintain

books, records, documents, and other evidence of
procedures and practices to demonstrate compliance
for each benefit year for at least 10 years.
• Changed the application format.
• Removed HHS benchmark dates.
• Changed the application format.

Rationale

activities under Legal Authority
and Governance apply for
Partnership states.
See above.

See above.
Requirements were tailored to
reflect more refined guidance
around model.
See above.
Change reflects current protocol
for submitting privacy and
security artifacts to CMS for
review.
See above.

See above.
See above.

5

Original Section of
Marketplace Blueprint
– pre 60-day
Comments

Revised Section of
Marketplace Blueprint –
post 60-day Comments

Change

Rationale

• Removed HHS benchmark dates.

State-Based Small Business Health Options Program (SHOP) Marketplace Blueprint
Application
1.0 Legal Authority
and Governance

1.0 Legal Authority
and Governance

2.0 Consumer and
Stakeholder
Engagement and
Support

2.0 Consumer and
Stakeholder
Engagement and
Support

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•
•
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•
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•

3.0 Eligibility and
Enrollment

3.0 Eligibility and
Enrollment

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•
•
•

4.0 Plan
Management

4.0 Plan Management

5.0 Risk Adjustment

5.0 Risk Adjustment

6.0 SHOP

6.0 SHOP

•
•
•
•
•

Changed the application format.
Removed HHS benchmark dates.
Included regulatory citations.
Listed all governing board structure requirements.
Changed the application format.
Removed HHS benchmark dates.
Included regulatory citations when necessary.
Included language for outreach and education, call
center, and website activities to more closely align to
statutory language.
Included certified application counselor (CAC)
activities.
Changed the application format.
Removed HHS benchmark dates.
Separated activities for SHOP employer and SHOP
employee applications.
Revised appeals activities

Changed the application format.
Removed HHS benchmark dates.
Changed the application format.
Removed HHS benchmark dates.
Removed the 30-day post Federal Payment Notice
requirement to have published the notice of benefit
and payment parameters and included regulatory
citation for activity.
• Changed the application format.

See above.

See above.
Activities were included as
additional guidance was
released around the CAC
program.

Changes were made to the E&E
section to ensure application
mirrored SBM application to the
extent feasible.
See above.
See above.

See above.

6

Original Section of
Marketplace Blueprint
– pre 60-day
Comments

Revised Section of
Marketplace Blueprint –
post 60-day Comments

Change

Rationale

• Removed HHS benchmark dates.
• Included requirement for method to determine how the Changes were made to the
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•
•
•
7.0 Organization and
Human Resources

7.0 Organization and
Human Resources

8.0 Finance and
Accounting

8.0 Finance and
Accounting

9.0 Technology

9.0 Technology

10.0 Privacy and
Security

10.0 Privacy and
Security

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•
•
•
•
•
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•
•
•
•
•
•

state will determine whether an employee is a full-time
employee.
Included activity to develop policies to ensure SHOP
compliance with regulation.
Removed SHOP premium calculator activity and
folded associated activities into SHOP Marketplace
compliance activities.
Included optional activity around minimum
participation requirements in the SHOP.
Included activity regarding demonstrating SHOP
website’s ability to make employer and employee
eligibility determinations and QHP comparisons.
Changed the application format.
Removed HHS benchmark dates.
Changed the application format.
Removed HHS benchmark dates.
Included request for tentative budget and operations
plan for 2016.
Changed the application format.
Removed HHS benchmark dates.
Request CALT ID numbers for ELC artifacts as
opposed to actual document.
Removed specific ELC artifacts from application.
Changed the application format.
Removed HHS benchmark dates.
Modified Privacy and Security activities and artifacts
to reflect SHOP-only Marketplace requirements.
Request CALT ID numbers for privacy and security
artifacts as opposed to actual document.

SHOP section of the Statebased SHOP application to
ensure the application mirrored
the SBM application to the
greatest extent possible.

See above.
See above.

See above.

See above.

Change reflects current protocol
for submitting privacy and

7

Original Section of
Marketplace Blueprint
– pre 60-day
Comments

11.0 Oversight and
Monitoring

Revised Section of
Marketplace Blueprint –
post 60-day Comments

11.0 Oversight and
Monitoring

12.0 Contingency
Planning

12.0 Contingency
Planning

13.0 Re-Use

13.0 Re-Use

14.0 Coordination
Between the SHOP
and the Federallyfacilitated
Marketplace (FFM)

14.0 Coordination
Between the SHOP
and the FFM

Change

• Changed the application format.
• Removed HHS benchmark dates.
• Included the requirement for the capacity to maintain

•
•
•
•
•
•

books, records, documents, and other evidence of
procedures and practices to demonstrate compliance
for each benefit year for at least 10 years.
Changed the application format.
Removed HHS benchmark dates.
Changed the application format.
Removed HHS benchmark dates.
Changed the application format.
Removed HHS benchmark dates.

Rationale

security artifacts to CMS for
review.
See above.

See above.
See above.
See above.

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