Crosswalk of Changes

Blueprint for Approval of SBEs PRA package

Removed, Relocated, and New Provisions (as of 07/15/2025)

Original Section	Section Title	New Section	Regulatory Requirement	Reason Removed, Relocated, or New	Increased or Decreased Burden Hours?
Supporting Statement
		Table of Contents		Updated to include a table of contents that is hyperlinked.	N/A
		List of Tables		Updated to include a list of tables section that is hyperlinked.	N/A
A.	Background		Affordable Care Act Section 1311 (b)	Updated language to bring current	N/A
B.	Justification		45 CFR § 155.105(b) § 155.106(a)	Updated section to include PY25 Payment Notice updates regulatory language.	N/A
12.	Burden Estimates (Hours & Wages)		45 CFR § 155.105(b) § 155.106(a)	Updated burden table estimates. Updated hourly rates and Occupation Codes/Titles according to the most recent BLS Wage Estimate Table 2023.	N/A
14.	Cost to Federal Government		45 CFR § 155.105(b) § 155.106(a)	Updated Cost to Federal Government table to reflect updated GS pay schedule effective 1/1/2024.	N/A
15.	Changes to Burden		45 CFR § 155.105(b) § 155.106(a)	Updated burden hours and estimates to account for increase in Blueprint Application attestations questions per respondent	Increase
15.	Changes to Burden		45 CFR § 155.105(b) § 155.106(a)	Updated total burden hours and estimates to account for decrease in estimated respondents over the next three year period (four to two applications).	Decrease
Blueprint Application Tool
Section I	Introduction		45 CFR § 155.200(f)	Added: In order to operate a SBE, a State must first operate a SBE-FP per § 155.106(c), meeting all requirements established under § 155.200(f), for at least one plan year, including its first open enrollment period.	N/A
Section I	Introduction Figure 1.		45 CFR § 155.106(b)	Added language to Figure 1. State Exchange Model Options and Exchange Blueprint Application Requirements and Timelines for Coverage Years Beginning On, or After, January 1, 2025	N/A
Section I	Introduction – Exchange Blueprint Application, Submission, Review and Approval Process		45 CFR § 155.106(b)	Added: HHS conditionally approves the State's Exchange Blueprint application, a State must conduct at least one public engagement (such as a townhall meeting or public hearing) either in-person or virtually, regarding the State's Exchange Blueprint application progress, in a timeline and manner considered effective by the State and with HHS' concurrence. A State shall provide public notice of the public engagement. Such public engagement shall also provide interested parties the opportunity to learn about the State's progress in transitioning to a State Exchange and offer input on that transition. Following the initial public engagement described in this paragraph and until HHS approves or conditionally approves the State Exchange Blueprint application, a State shall conduct periodic public engagements, either in-person or virtually, in a timeframe and manner considered effective by the State.	N/A
Section I	Introduction – Monitoring of State Progress and Readiness Reviews		45 CFR § 155.106(b)	Removed: CMS will approve an SBE or SBE-FP once the state has demonstrated the ability to satisfactorily perform all required Exchange activities, and comply with all Federal program rules and requirements applicable to the Exchange model they are conditionally-approved to operate.	N/A
Section I	PRA Disclosure Statement		5 CFR § 1320.8(b)(3)	Updated language to provide required information per federal regulation.	N/A
Section II	Declaration of Intent Letter		45 CFR § 155.106(b)	Added: The Declaration of Intent Letter should indicate the State’s intent to transition to a SBE-FP for a particular coverage year, followed by the State’s intent to transition to a SBE for a particular coverage year.	N/A
Section III	Application For Approval of State-Based Health Insurance Exchanges		45 CFR § 155.106(b)	Updated dates in section to Jan 1, 2025	N/A
Section III	Part B. Exchange Declarations 2. State Exchange Model and Plan Year		45 CFR § 155.106(b)	Removed: Regional Exchange and Plan Year	N/A
Section III	Part B. Exchange Declarations 3. Declaration of Intent Letter		45 CFR § 155.106(b)	Added: Declaration of Intent Letter will be submitted by	N/A
Section III	Part C. State-Based Exchange Blueprint Application 1.0		45 CFR § 155.106(b)	Updated title: Legal Authority and Governance	N/A
Section III	Part C. State-Based Exchange Blueprint Application 1.0	1.8	45 CFR § 155.106(b)	Added new attestation.	Increase
Section III	Part C. State-Based Exchange Blueprint Application	1.1; 1.6; 1.7,; 1.8; 2.2; 2.3; 2.6; 2.7; 2.8; 2.9; 2.10; 3.1; 3.2; 3.3; 3.4; 3.5; 3.6; 3.7; 3.9; 3.10; 3.11; 3.12; 4.7;	45 CFR § 155.106(b)	New Attestations added to various sections of Part C. Updated language to attestations.	Increase
Section III	Part C. State-Based Exchange Blueprint Application	2.11 ; 5.9	45 CFR § 155.106(b)	Removed	Decrease
Section III	Part C. State-Based Exchange Blueprint Application	6.0	45 CFR § 155.106(b)	Updated heading to “Finance and Organization”	N/A
Section III	Part D. State-Based Exchange Blueprint Application	1.0; 2.3; 2.6; 2.8; 2.9; 2.10; 4.1; 4.6; 9.2; 9.3; 9.4	45 CFR § 155.106(b)	New Attestations added to various sections of Part D.	Increase
Sec III	Part D: Privacy and Security	5.9	45 CFR § 155.105(b) § 155.106	Removed	Decrease
Sec III	Part D: Privacy and Security	8.0	45 CFR § 155.105(b) § 155.106	Removed two empty rows/cells from application tool.	N/A
Section III	Part D. Privacy and Security	6.0	45 CFR § 155.106(b)	Updated heading to “Finance and Organization”	N/A
Sec III	Part D: Privacy and Security	9.2; 9/3	45 CFR § 155.105(b) § 155.106	Swapped indicator order and updated language.	N/A