Form CMS-10507 SMART Tool

Form Approved- exp.
OMB No: 0938-1244

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

State-based Marketplace Annual Reporting Tool
(SMART)
Introduction

The Affordable Care Act (ACA) established State-based Exchanges (SBEs) and State-based Exchanges on the Federal
Platform (SBE-FPs), also referred to as State Exchanges, to provide individuals and small business employees with
access to health insurance coverage beginning January 1, 2014. The ACA provides states with flexibility in the design and
operation of their Exchanges to best meet the unique needs of their residents and insurance markets.
The Centers for Medicare & Medicaid Services (CMS) is responsible for the oversight and monitoring of State Exchanges
pursuant to 45 CFR § 155.1200 (general program integrity and oversight responsibilities) and 45 CFR § 155.1210
(maintenance of records). Under these provisions, State Exchanges are required to conduct a defined set of oversight
activities to track and monitor how they are meeting ACA program integrity standards. In addition, State Exchanges are
required to comply with Exchange-related policy and operational requirements set forth in statute, regulations, and
guidance.
The State-based Marketplace Annual Reporting Tool (SMART) was developed to assist CMS in the collection of SBE and
SBE-FP reporting and auditing requirements, and, in coordination with other CMS oversight activities, to monitor and
evaluate SBE compliance with applicable regulations and guidance. State Exchanges must submit the SMART on an
annual basis to CMS. Submission of the SMART does not preclude a State Exchange from meeting other CMS reporting
requirements not addressed in the SMART.
SBEs must submit or attest to the submission of these requirements by completing the following SMART elements:
Eligibility and Enrollment, Financial and Programmatic Audit, and Program Integrity. Directions for completing each
attestation and/or document submission are contained in the element description.
Unless otherwise noted, SBEs should answer the SMART questions, as they relate to Exchange operations in place, as of
the most recent open enrollment period.

PRA Disclosure Statement: According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays
a valid OMB control number. The valid OMB control number for this information collection is 0938-1244.

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

SMART REPORTING ELEMENTS

State-based Marketplace Annual Reporting Tool (SMART) ................................................................................................... 1
Introduction.............................................................................................................................................................................. 1
SMART REPORTING ELEMENTS ......................................................................................................................................... 2
I.

Eligibility and Enrollment ................................................................................................................................................. 3

II.

Financial and Programmatic Audit ................................................................................................................................ 10

III.

Program Integrity........................................................................................................................................................... 12

IV.

Attestation of Completion .............................................................................................................................................. 15

2

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

I.

Eligibility and Enrollment
State-based Exchanges (SBEs) must answer all questions under the Eligibility and Enrollment section with a
'Yes' or 'No' response. The N/A response option applies solely to State-based Exchanges using the Federal
Platform (SBE-FPs), for whom this section does not apply. SBE-FPs should skip this section.
Please attest to whether the Exchange is in compliance with the following Exchange-related eligibility and
enrollment policy, operational regulations, and guidance, and submit the required information where noted.
Answer the questions as they relate to Exchange operations in place as of the most recent Open Enrollment
Period, unless otherwise noted.

Qualified Health Plan (QHP) Eligibility Verification: Social Security Number
The Exchange verifies social security number with the Social Security Administration through the Federal Data
Services Hub under 45 CFR § 155.315(b), unless otherwise authorized by CMS.
YES

NO

QHP Eligibility Verification: Citizenship
The Exchange verifies citizenship with the Social Security Administration through the Federal Data Services
Hub under 45 CFR § 155.315(c), unless otherwise authorized by CMS.
YES

NO

QHP Eligibility Verification: Lawful Presence
The Exchange verifies lawful presence with the Department of Homeland Security through the Federal Data
Services Hub Verify Lawful Presence (VLP) Service Step 1 under 45 CFR § 155.315(c), or through an
alternative data source and/or process.
YES

NO

If an alternative process is used, please summarize, and include any alternative data source(s) used:
____________________________
The Exchange verifies lawful presence with the Department of Homeland Security through the Federal Data
Services Hub Verify Lawful Presence (VLP) Service Step 2 under 45 CFR § 155.315(c), or through an
alternative data source and/or process.
YES

NO

If an alternative process is used, please summarize, and include any alternative data source(s) used:
____________________________

3

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

The Exchange verifies lawful presence with the Department of Homeland Security through the Federal Data
Services Hub Verify Lawful Presence (VLP) Service Step 3 under 45 CFR § 155.315(c), or through an
alternative data source and/or process.
YES

NO

If an alternative process is used, please summarize, and include any alternative data source(s) used:
____________________________

QHP Eligibility Verification: State Residency
The Exchange verifies state residency through attestation under 45 CFR § 155.315(d), unless otherwise
authorized by CMS.
YES

NO

The Exchange verifies state residency through a non-Federal Data Services Hub data source for this eligibility
verification procedure.
YES

NO

If yes, please list data source(s): ____________________________

QHP Eligibility Verification: Standards and Process for American Indian/Alaska Natives
The Exchange verifies American Indian/Alaska Native (AI/AN) through consumer attestation, relevant
documentation, and/or an approved electronic data source as provided under 45 CFR § 155.350(c), unless
otherwise authorized by CMS.
YES

NO

If yes, please select how the verification is completed.
Attestation
Documentation
Data Source
If data source is used, please list: ____________________________

QHP Eligibility Verification: Incarceration Status
The Exchange verifies incarceration status through the Federal Data Services Hub or attestation under 45
CFR § 155.315(e), unless otherwise authorized by CMS.
YES

NO

4

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

If yes, please select how the verification is completed.
Attestation
Documentation
Data Source

Affordability Program Eligibility Verification: Household Income and Size
The Exchange verifies household income and family/household size through the Federal Data Services Hub
under 45 CFR § 155.320(c), unless otherwise authorized by CMS.
YES

NO

The Exchange verifies household income through an alternative process when the Federal Data Services Hub
Modified Adjusted Gross Income (MAGI) data is not available.
YES

NO

If yes, please list alternative process: ____________________________
The Exchange uses a non-Federal Data Services Hub data source in addition to, or as a contingency for, the
Federal Data Services Hub for this eligibility verification procedure.
YES

NO

If yes, please list data source(s): ____________________________

Affordability Program Eligibility Verification: Employer-sponsored Plan
The Exchange verifies eligibility related to enrollment in an eligible employer-sponsored plan and eligibility for
qualifying coverage in an eligible employer-sponsored plan through the Federal Data Services Hub Office of
Personnel Management Service under 45 CFR § 155.320(d)(2)(i), unless otherwise authorized by CMS.
YES

NO

The Exchange uses a CMS-approved non-Federal Data Services Hub data source in accordance with 45 CFR
§ 155.320(d)(2)(ii), for this eligibility verification procedure.
YES

NO

The Exchange employs a random sampling process in accordance with 45 CFR § 155.320(d)(4), for this
eligibility verification procedure.
YES

NO

The Exchange employs other CMS-approved risk-based processes in accordance with 45 CFR § 155.315(h)
and 155.320(a), for this eligibility verification procedure.
YES

NO

If yes, please list data source(s) and/or risk-based process: ____________________________
5

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

Affordability Program Eligibility Verification: Medicaid, Children’s Health Insurance
Program (CHIP) and Basic Health Program (BHP)
The Exchange verifies eligibility related to enrollment in Medicaid, CHIP, and BHP (if applicable), through a
state-level data source under 45 CFR § 155.320(b)(1)(ii).
YES

NO

Affordability Program Eligibility Verification: Non-Employer-sponsored Plan
The Exchange verifies eligibility related to enrollment in minimum essential coverage, other than through an
eligible employer-sponsored plan (e.g., Medicare, Veterans Health Administration, TRICARE/Department of
Defense, and the Peace Corps), through the Federal Data Services Hub under 45 CFR § 155.320(b)(1)(i).
YES

NO

The Exchange uses a non-Federal Data Services Hub data source in addition to, or as a contingency for, the
Federal Data Services Hub for this eligibility verification procedure.
YES

NO

If yes, please list data source(s): ____________________________

Inconsistency Resolution
In cases where the Exchange cannot verify information required to determine eligibility for enrollment in a QHP
through the Exchange, Advance Premium Tax Credits (APTCs), and cost-sharing reductions (CSRs), the
Exchange has a process in place to identify, notify consumers of, and resolve inconsistencies in accordance
with 45 CFR § 155.315(f), relating to the following eligibility factors:
Y

N

Partial
Annual Income
Citizenship
Immigration Status
Incarceration Status
American Indian/Alaskan Native Status
Minimum Essential Coverage: NonEmployer Sponsored Coverage
Minimum Essential Coverage: Employer
Sponsored Coverage

If answered no and/or partial, please explain: ____________________________
The Exchange has established an income verification threshold policy per 45 CFR 155.320(c)(3)(vi).
YES

NO

If yes, please list the policy including the threshold amount: ____________________________
6

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

Benefit Year Eligibility Redetermination and Verification
The Exchange conducts eligibility redeterminations and verifies applicant-reported changes in circumstances
during the benefit year in accordance with 45 CFR § 155.330.
YES

Y

N

NO

Partial
Annual Income
Citizenship
Immigration Status
Incarceration Status

If answered no or partial, please explain: ____________________________

Periodic Data Matching
The Exchange conducts periodic data matching at least twice during the benefit year in accordance with 45
CFR § 155.330(d) to identify updated information for applicable enrollees in regard to the following eligibility
factors. Exchanges that have an integrated eligibility system with their State Medicaid Agency and have a
single eligibility rules engine that uses MAGI to determine eligibility for advance payments of the premium tax
credit, cost-sharing reductions, Medicaid, CHIP, and the BHP (if applicable), are deemed compliant with the
Medicaid/CHIP periodic data matching requirement and should answer ‘Yes’ for that specific item below.

Y

N

Frequency
Death
Enrollment in Medicare
Enrollment in Medicaid, CHIP, and
BHP (if applicable)

If answered no, please explain: ____________________________

Annual Eligibility Redeterminations and Verification
The Exchange performs annual eligibility redeterminations and verifies reported changes in accordance with
45 CFR § 155.335. If yes, please upload the redeterminations plan using the CMS required template.
YES

NO

If answered no, please explain: ____________________________

7

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

QHP Eligibility Process: Employer Notices
The Exchange notifies an employer that an employee has been determined eligible for APTCs and CSRs has
enrolled in a QHP through the Exchange within a reasonable timeframe under 45 CFR 155.310(h).
YES

NO

QHP Eligibility Standards: Income Tax Return Filing Requirement
The Exchange verifies the tax filing status of new applicants and renewing enrollees with the IRS through the
Federal Data Services Hub under 45 CFR § 155.305(f)(4).
YES

NO

PARTIAL

If answered no or partial, please explain: ____________________________
The Exchange denies or discontinues APTC for new applicants and renewing enrollees who are identified as
having APTC paid on their behalf, but who did not file a tax return or reconcile APTC for that year.
YES

NO

PARTIAL

If answered no or partial, please explain: ____________________________

Eligibility Determinations: Right to Appeal
The Exchange includes the notice of the right to appeal and instructions regarding how to file an appeal in any
eligibility determination notice issued to the applicant in accordance with 45 CFR § 155.355.
YES

NO

Administration of Advance Payments of the Premium Tax Credit: CMS Reporting
The Exchange is compliant with applicable requirements regarding submission of Policy-level data to CMS for
plan year 2022 and prior plan years to support the administration and reconciliation of payments of APTCs and
CSRs to issuers under 45 CFR § 155.340(a), 45 CFR 155.340(i), and 45 CFR § 155.400(b).
YES

NO

PARTIAL

If answered no or partial, please explain: ____________________________

Administration of Advance Payments of the Premium Tax Credit: IRS and Taxpayer
Reporting
The Exchange is in compliance with applicable requirements regarding reporting to the IRS and to taxpayers
in accordance with 45 CFR § 155.340(c).
YES

NO

PARTIAL

If answered no or partial, please explain: ____________________________

8

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

Monthly Reconciliation of Enrollment Information with QHP issuers
The Exchange reconciles their enrollment information, including historical dates of coverage, with QHP issuers
no less than on a monthly basis in accordance with 45 CFR § 155.400(d).
YES

NO

If yes, submit the internal and external procedures for reconciliation with issuers per 45 CFR § 155.400(d)
only, if not previously provided or if it has undergone significant changes since the last submission.
Procedures previously submitted and have not undergone significant changes.

Special Enrollment Periods
The Exchange provides special enrollment periods consistent with 45 CFR § 155.420, during which qualified
individuals may enroll in QHPs and enrollees may change QHPs.

Y

N

SEP Verification (Y/N)
Loss of Minimum Essential Coverage
Permanent Move
Change in Household Size*
Denial of Medicaid/CHIP Eligibility
Newly APTC Eligible or Ineligible, Change in CSR
Eligibility
Gaining Access to ICHRA or QSEHRA
Exchange Error, Misrepresentation, Misconduct
Exceptional Circumstances (describe):
Other State-specific SEP (describe):
Other State-specific SEP (describe):
Other State-specific SEP (describe):

*Includes Marriage, Divorce, Gaining/Becoming a Dependent.

9

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

Self-Reporting: Eligibility and Enrollment Opportunity for Comments
If applicable, please use this section to provide any additional information or clarification on eligibility and
enrollment that was not captured in the previous attestations.

II.

Financial and Programmatic Audit
Under 45 CFR § 155.1200, SBEs and SBE-FPs are required to report to CMS on financial and program
integrity and engage an independent qualified auditing entity or entities to conduct a financial and a
programmatic audit. An independent qualified auditing entity is as an entity that is in good standing with the
state oversight agency and licensed with the state board of accountancy, not affiliated with the Exchange, and
that follows generally accepted governmental auditing standards (GAGAS). Please attest to having completed
the applicable activities and submit any requested documentation.

Accurate Accounting
The Exchange keeps accurate accounting of all activities, receipts, and expenditures in accordance with
generally accepted accounting principles (GAAP), as required under 45 CFR § 155.1200(a)(1).
YES

NO

If answered no, please explain: ____________________________

Accurate Accounting and Financial Statement: Independent External Auditor Attestation
The Exchange has prepared an annual financial statement in accordance with GAAP, as required under 45
CFR § 155.1200(b)(1).
YES

NO

If answered no, please explain: ____________________________
An independent qualified auditing entity attests that the Exchange has demonstrated to CMS accurate
accounting of all activities, receipts, and expenditures and an accurate annual financial statement in
accordance with GAAP.
YES

NO

10

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

If yes, please upload the annual financial statement confirming the Exchange has demonstrated accurate
accounting and prepared an accurate financial statement.
If applicable, please upload a Comprehensive Annual Financial Report (CAFR) and a stand-alone statement of
Exchange appropriations and expenditures.
If answered no, please explain: ________________________________

Financial Independent External Audit
The Exchange has engaged with an independent qualified auditing entity that follows generally accepted
governmental auditing standards (GAGAS) to perform an annual independent external financial audit of the
Exchange, as required under 45 CFR § 155.1200(c), and submitted these results to CMS. If yes, and not
already provided above, upload results of the final annual independent external financial audit. If the internal
controls report is separated from the financial audit, please upload as well.
YES

NO

If answered no, please explain: ____________________________

Material Weaknesses: Financial Audit
The independent external financial audit identified a material weakness or significant deficiency.
YES

NO

If yes, the Exchange has informed CMS of any material weakness or significant deficiency and any intended
corrective action identified by the independent external financial audit, as required under 45 CFR §
155.1200(c)(2).
YES

NO

If yes, and not already provided above with the financial audit report, upload a corrective action plan (CAP)
addressing the material weakness or significant deficiency identified by the external financial audit.

Programmatic Independent External Audit
The Exchange has engaged with an independent external auditor to perform an annual independent external
programmatic audit of the Exchange, as required under 45 CFR § 155.1200(c), and in compliance with the
standards in 45 CFR Subpart M, § 155.1200. If yes, upload results of the annual independent external
programmatic audit.
YES

NO

If answered no, please explain: ____________________________

11

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

Material Weaknesses: Programmatic Audit
The independent external programmatic audit identified a material weakness or significant deficiency.
YES

NO

If yes, the Exchange has informed CMS of any material weakness or significant deficiency and any intended
corrective action identified by the independent external programmatic audit, as required under 45 CFR §
155.1200(c)(2).
YES

NO

If yes, and not already provided above with the programmatic audit report, upload a corrective action plan
(CAP) addressing the material weakness or significant deficiency identified by the independent external
programmatic audit.

Summary of Audit Results Available to Public: Independent External Financial Audit
The Exchange has made a summary of the results from the independent external financial audit available to
the public, as required under 45 CFR § 155.1200(c) (3).
YES

NO

If yes, include a link to where the independent external financial audit results are posted: _____________
If answered no, please include the date when the independent external financial audit results will be posted on
the Exchange’s website: ____________________

Summary of Audit Results Available to the Public: Independent External Programmatic
Audit
The Exchange has made a summary of the results from the independent external programmatic audit
available to the public, as required under 45 CFR § 155.1200(c) (3).
YES

NO

If yes, include a link to where the independent external programmatic audit results are posted:
_______________________
If answered no, please include the date when the independent external programmatic audit results will be
posted on the Exchange’s website: ____________________

III. Program Integrity
Maintenance of Records
The Exchange adheres to the maintenance of records requirements as required under 45 CFR § 155.1210(a)(c).
YES

NO
12

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

Enrollment Indicator Metrics
The Exchange submits individual and/or SHOP enrollment indicator metric reports in accordance with CMS
timelines and templates, as required under 45 CFR § 155.1200(a)(3) and the Paperwork Reduction Act.
YES

NO

N/A

Oversight and Monitoring, including Fraud, Waste, and Abuse Policies and Procedures
The Exchange has a comprehensive, documented oversight and monitoring program to ensure program
integrity, which include policies and procedures to identify incidents of fraud, waste, and abuse, as required
under § 1313(a)(5) of the ACA.
YES

NO

If yes, upload the oversight and monitoring plan and fraud, waste, and abuse policies and procedures if not
previously provided or if it has undergone significant changes since the last submission.
Policies and procedures previously submitted and have not undergone significant changes.

Non-Discrimination Policies and Standards
The Exchange has policies and clear enforcement standards to safeguard against discrimination in health
insurance determinations and practices in accordance with § 1557 of the Affordable Care Act.
YES

NO

If yes, upload the Exchange’s non-discrimination policies and standards if not previously provided or if it has
undergone significant changes since the last submission.
Policies and standards previously submitted and have not undergone significant changes.

Consumer Assistance Tools
The Exchange has policies and procedures in place to provide all consumers with information and assistance
that is timely and accessible in accordance with 45 CFR § 155.205. For SBE-FPs, the Exchange has, at a
minimum, an informational website and toll-free hotline that directs consumers to the Federal platform for
eligibility and enrollment.
YES

NO

Navigator Program and Standards
The Exchange has a Navigator program through which it awards grants to eligible entities and has applicable
Navigator standards and processes in place in accordance with 45 CFR § 155.210.
YES

NO

If answered no, please explain: __________________________________
13

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

Financial Information
The Exchange publishes on its website average licensing costs, regulatory fees, administrative costs, and any
other additional fees required by the Exchange, along with any monies lost to waste, fraud, and abuse, in
accordance with 45 CFR § 155.205(b)(2). (Please note: The Exchange may already include this information in
its publicly posted financial statement or financial audit summary or may publish it separately.)
YES

NO

If yes, include a link to where the information is posted: ____________________________
If answered no, please explain: __________________________________

CMS Annual Budget Template
The Exchange submitted its completed CMS annual budget template to CMS, as required under 45 CFR
§ 155.1200(b)(2).
YES

NO

If answered no, please include the date when the Exchange will submit the CMS annual budget template to
CMS: ___________________

Certification of Qualified Health Plans
The Exchange has standards and processes in place to certify Qualified Health Plans (QHP) as specified
under 45 CFR § 155.1000 - 1090.
YES

NO

Self-Reporting: Financial and Programmatic Audit & Program Integrity Opportunity for
Comments
If applicable, please use this section to provide any additional information or clarification on financial and
program integrity that was not captured in the previous attestations.

14

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
Center for Consumer Information and Insurance Oversight
7501 Wisconsin Avenue
Bethesda, MD 20814

IV.

Attestation of Completion
On this date, I attest that the statements and information contained in this State-based Marketplace Annual
Reporting Tool (SMART), and the documents submitted in conjunction with this report accurately represent the
SBE’s compliance with the regulatory requirements.
YES

NO

STATE:

ELECTRONIC SIGNATURE:

DATE:

PRINT NAME:

15