Exchange Timeline

 

High-level timeline
Q1 2010 Affordable Care Act (ACA) passed
Q2 2010 HHS makes Exchange planning grants available to states
2010 - 2013 Development of federal and state Exchanges
Q1 2013 States notify HHS of intent to create their own Exchange or participate in partnership model
Q3 2013 Exchanges go live for open enrollment
2015 Exchanges must be financially self-sufficient
2017 States may permit large employers on Exchange


Detailed timeline

2010

Q1

  • Affordable Care Act (ACA), with provision creating insurance exchanges, passed

Q2

2011

Q1

Q2

  • Exchange notice of proposed rule making

Q4

  • CMS awards contract for vendor to design federal exchange plan certification/procurement process

2012

Q1

  • CMS awards various vendor contracts for federal exchange

Q2

  • Final rules issued on exchanges and qualified health plans (QHP); health premium tax credit

  • Regulatory guidance on the Federal Exchange structure issued

  • Individual Mandate Supreme Court ruling

  • Proposed rule issued on Essential Health Benefits (EHB) Data Collection and QHP Accreditation

Q3

  • States identify EHB benchmark plans

  • Final rule issued on EHB data collection and QHP accreditation

  • States begin defining QHP requirements

Q4

  • States notify HHS of intent to operate their own Exchange and submit Exchange plan to HHS

  • States publish requirements for qualified health plans

  • Release of further regulations and/or guidance (e.g., Rating and Market Rules; Federal 3R Program Rules; EHB and Exchange Rules; Actuarial Value/Cost Sharing Caps, Wellness, Quality, Federal Facilitated Exchanges

  • Presidential Election


2013

Q1

  • States notify HHS of intent to enter into Partnership Exchange model with federal government

  • HHS anticipated to "conditionally approve" state–run exchanges

  • HHS anticipated to officially identify states that will have a Federally-Facilitated Exchange (FFE)

  • Possible release of further regulations/guidance on other Exchange final rule on pending IFR provisions, Employer Notices, FFE specifications, Eligibility appeals, Transparency*

  • QHP Rate and Form filings submitted

  • Plans need to build new health insurance fees and taxes into 2014 pricing

Q2

  • QHP plan bids due

  • Employer notice of exchange offering due to employees

Q3

  • Qualified health plans selected by Exchanges

  • Plan marketing begins

Q4

  • Exchange websites become operational

  • Initial enrollment


2014

Q1

  • Exchanges operational for individuals and small employers


2015

Q1

  • Exchanges must be financially self-sustaining


2016

Q1

  • States must allow small employers up to 100 employees into Exchange


2017

Q1

  • States may permit large employers in Exchange

  • States may modify HHS requirements through waivers


*Timeframes and estimates are subject to change.