The Government Accountability Office (GAO) found the Centers for Medicare & Medicaid Services (CMS) completed many activities necessary to establish FFEs by October 1, but many remain to be completed and some are behind schedule. The activities remaining cross the core exchange functional areas of eligibility and enrollment, plan management, and consumer assistance.
“Much progress has been made, but much remains to be accomplished within a relatively short amount of time,” the GAO said in a report. However, commenting on a draft of the GAO report, the Department of Health and Human Services (HHS) emphasized the progress it has made in establishing exchanges, and expressed its confidence that exchanges will be open and functioning in every state by October 1.According to the GAO findings, to support consumer-eligibility determinations, CMS is developing a data hub that will provide electronic, near-real-time access to federal data, as well as provide access to state and third party data sources needed to verify consumer-eligibility information. While CMS has met project schedules, several critical tasks, such as final testing with federal and state partners, remain to be completed.
For plan management, CMS must review and certify the qualified health plans (QHP) that will be offered in the FFEs. Though the system used to submit applications for QHP certification was operational during the anticipated time frame, several key tasks regarding plan management, including certification of QHPs and inclusion of QHP information on the exchange websites, remain to be completed.
In the case of consumer assistance, for example, funding awards for Navigators—a key consumer assistance program—have been delayed by about two months, which has delayed training and other activities. CMS is also depending on the states to implement specific FFE exchange functions, and CMS data show that many state activities remained to be completed and some were behind schedule.
“CMS’s timelines provide a roadmap to completion; however, factors such as the still-evolving scope of CMS’s required activities in each state and the many activities yet to be performed—some close to the start of enrollment—suggest a potential for challenges going forward,” the GAO warned. “And while the missed interim deadlines may not affect implementation, additional missed deadlines closer to the start of enrollment could do so.”In a separate report, GAO noted that CMS granted conditional approval to 18 states to establish state-based Small Business Health Options Programs (SHOPs). Just as with FFEs, the agency found much still needs to be completed to establish SHOPs, and additional missed deadlines could jeopardize implementation. Again, HHS expressed confidence SHOPs would be ready by October 1.