State Exchange Models

A state’s Exchange model determines which online system(s) issuers must use to submit their QHP Application, who performs the certification, and who sends certification notifications.

State Exchange Models

Exchange ModelWho performs functions?Where do consumers apply & enroll?Plan Submission System 
Federally-facilitated Exchange (FFE)HHS performs all Exchange functionsHealthCare.gov HIOS
State Performing Plan Management FunctionsStates administer in-person consumer assistance functions; HHS performs remaining Exchange functionsHealthCare.govSERFF & HIOS (for rate filing information and marketing URLs)
State-based Exchange on the Federal Platform (SBE-FP)States perform all Exchange functions but use the FFE IT platformHealthCare.govSERFF & HIOS (for rate filing information and marketing URLs)
State-based Exchange (SBE)States perform all Exchange functionsExchange websites established & maintained by the statesState-specific system
Direct Enforcement State (MO, OK, TX, WY)These states have notified CMS that they do not have the authority to enforce or are not otherwise enforcing the Affordable Care Act market reform provisions. Issuers must submit policy forms to CMS for review.HealthCare.govContact formfiling@cms.hhs.gov for details on requirements for form filing in these states.