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Exchange Operational Models for 2022

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In plan year (PY) 2022, most states continue to rely on the federal government for some or all exchange operational functions. However, 3 states have transitioned to state-based exchanges (SBEs).

For PY 2022, KY, ME, and NM transitioned to SBEs, which increases the number of SBEs to 17 states and Washington, DC. Additionally, VA and GA are currently in the process of transitioning to SBEs, with VA expecting to fully transition to an SBE for PY 2023. In the remaining 33 states, the federal government performs some or all exchange operational activities, including eligibility determinations, enrollment, website operation, and consumer outreach. Of these 33 states, 10 are contributing to exchange management under a state-federal partnership agreement or as a state-based exchange using the federal platform (SBM-FP).

States transitioning to SBEs is a relatively new trend. After the implementation of the ACA, in which 16 states implemented an SBE, no new states transitioned to an SBE until PY 2020. In fact, the opposite trend was true, with 3 states (HI, KY, and OR) abandoning their SBEs between PYs 2015 – 2017. Since PY 2020, 6 states (KY, ME, NJ, NM, NV, and PA) have transitioned to SBEs.

Figure 1. States’ Exchange Operational Models for Plan Year 2022
Figure 1. States’ Exchange Operational Models for Plan Year 2022

FFE: Federally Facilitated Exchange; SBE: State-Based Exchange; SBE-FP: State-Based Exchange Using Federal Platform

Source: Avalere State Policy 360.

  1. The governor of VA signed a law transitioning the state from a FFE model to an SBE model in 2023.
  2. The Centers for Medicare and Medicaid Services (CMS) has approved GA’s Section 1332 waiver request for seeking to transition from a FFE model to a SBE model in plan year 2023. Since that approval in 2020, the CMS has requested an updated analysis of the state’s approved model.​
Table 1. Exchange Operational Model Changes
Plan Year State to Federal Model Federal to State Model
2015 OR
2016 HI
2017 KY
2020 NV
2021 NJ, PA
2022 KY, ME, NM
2023+ GA*, VA


Figure 2. Total Number of States with SBEs, by Plan Year
Figure 2. Total Number of States with SBEs, by Plan Year

*VA is expected to fully transition to an SBE for PY 2023, while GA’s transition date is currently unclear.

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