More states are stepping away from the federal ACA exchange to run their own. Today, almost two dozen states already operate as state-based exchanges (SBEs), and that number continues to climb.
For health plans, that shift changes more than where consumers shop for coverage. It can change which authority certifies a plan, which systems and templates issuers use, how data moves between platforms and which timelines govern the filing process.
In this episode of Regulatory Joe, we explore the shift toward state-based exchanges and what it means for ACA issuers filing across state lines.
Why Are More States Moving to State-Based Exchanges?
The movement toward greater state control isn’t new, but the marketplace map continues to change. At ACA launch, 14 states plus the District of Columbia operated their own exchanges. Today, 20 states and D.C. operate state-based exchanges, with additional states moving toward either an SBE-FP or a full state-based model.
Virginia transitioned for PY2024, followed by Georgia for PY2025 and Illinois for PY2026. Oregon is preparing to launch its full state-based exchange for PY2027, while Oklahoma became an SBE-FP in 2026 as part of its planned move to a full SBE for PY2028.
States have several reasons to assume more control over marketplace operations. A state-run model gives states more say over day-to-day operations within the QHP ecosystem, since member populations differ by state in demographics and health needs. States still have to meet CMS’s federal baseline requirements, including essential health benefits, but a state-based model gives them room to build on that baseline, through options like cost-share reconciliation, alternate funding methods or product-type mandates for issuers in that state.
How a State-Based Exchange Changes ACA Filing for Issuers
More states running their own marketplaces changes real systems and processes for the teams doing the filing. Depending on the marketplace model, the filing pathway, certification authority, templates and handoffs may all change.
While individual state processes can vary, issuers generally need to account for the following differences:
| Exchange Model | General Filing Structure | Key Issuer Consideration |
| Federally Facilitated Exchange (FFE) | Federal QHP application work runs through MPMS in HIOS, alongside any applicable state filing requirements. | Issuers manage federal submissions directly but still need to coordinate CMS and state review timelines. |
| State-Based Exchange on the Federal Platform (SBE-FP) | The state oversees QHP certification while continuing to use HealthCare.gov for eligibility and enrollment. Filing work may involve SERFF, MPMS and state-managed data transfers. | Some steps may depend on the state completing a review or transferring data before the issuer can move forward. |
| Full State-Based Exchange (SBE) | The state operates its own marketplace and determines the systems, templates and certification process issuers must follow. | Issuers need to learn a state-specific filing playbook that may differ from both the federal process and other SBEs. |
These differences matter because they change which steps the issuer controls and which depend on action by the state. In some state-run processes, an issuer may submit filing materials and then wait for the state to complete a review, transfer data or open the next stage of the process. That dependency needs to be built into the filing timeline rather than treated as an administrative detail.
Network adequacy reviews and filing calendars can vary by state, too. The PY2027 NBPP gives qualifying states additional flexibility to conduct their own provider access reviews, while states may also establish their own submission, review and certification timelines.
For a multistate issuer, the practical challenge is maintaining the correct process for every market. Filing in ten states can mean tracking different systems, review authorities, handoffs and deadlines across each one.
How Health Plans Can Prepare for More ACA State-Based Exchanges
- Maintain a transition calendar. Track declarations, conditional approvals, planned platform launches and applicable plan years.
- Build a state-level filing map. Document every portal, template, review authority and data transfer by filing component.
- Identify external dependencies. Flag steps that cannot begin until the DOI, marketplace or CMS completes an action.
- Reconcile state and federal calendars. Do not assume certification, binder, rate, network and open-enrollment milestones align.
- Run a post-transition readiness review. Confirm user access, testing requirements, data mappings, final submission records and ownership before the first filing cycle under the new model.
As more states assume control over marketplace operations, issuers cannot treat ACA filing as one national process with minor state variations. Teams need a clear operating map for every market, including the systems, review authorities, dependencies and deadlines that determine how each filing moves forward.
Watch the full episode for more of Joe’s insights on the shift toward state-based exchanges.
