What type of health insurance exchange/marketplace does my state have?
For the 2025 plan year, there will be 20 fully state-run health insurance marketplaces (SBMs), three state-based marketplaces that use the federal platform (SBM-FP), and 28 federally-run marketplaces (FFMs) — including five state-federal partnership marketplaces, which are a type of FFM.
Note that the federal platform is HealthCare.gov. And “Exchange” and “Marketplace” mean the same thing, so you’ll also see people use the acronyms SBE, SBE-FP, and FFE.
Three of the states that now have SBMs (Kentucky, Maine, and New Mexico) had SBM-FPs as of 2021, but created their own state-run exchange platforms that were up and running as of the fall of 2021. Virginia joined them as of November 2023, so Virginia residents no longer use HealthCare.gov. And Georgia is joining them as of November 2024, so Georgia residents will use a state-run platform (Georgia Access) to sign up for 2025 coverage, instead of HealthCare.gov.
Georgia had intended to have an SBM by the fall of 2023, but CMS delayed Georgia’s transition, clarifying that the state would need to use an SBM-FP starting in the fall of 2023 and then transition to an SBM in the fall of 2024. Illinois has enacted legislation that calls for the state to have an SBM-FP by the fall of 2024 (for the 2025 plan year) and an SBM by the fall of 2025 (so Illinois residents will continue to use HealthCare.gov until the fall of 2025). And Oregon, which currently has an SBM-FP, has enacted legislation that calls for the state to transition to an SBM by the fall of 2026.
Mississippi enacted legislation in 2024 that authorizes the Insurance Commissioner to create a state-run exchange,1 although Mississippi Insurance Commissioner Mike Chaney has clarified that he won’t proceed with this without Governor Reeves’s support.2
Michigan’s Senate passed legislation in 2024 (now under consideration by the House) that would direct the state to create a state-run exchange.3
North Carolina lawmakers are considering a bill in 2024 that would create a state-run exchange.4 Arizona also considered similar legislation but it did not advance out of committee.5
Texas was also considering legislation (HB700, HB2554, and SB344) to create a state-run exchange, but the bills died in committee during the 2023 session.
Rules states must follow when transitioning to a state-run exchange
In the rulemaking process for 2024 coverage, HHS finalized a more lenient approval process timeline for states that are transitioning away from the federally-run exchange to establish their own exchange and/or exchange platform. However, some additional rules have since been finalized for the transition, effective in 2025 and future years.
The previous rules (pre-2024) required a state to have federal approval or conditional approval at least 14 months before the start of open enrollment if they were transitioning from an SBM-FP to an SBM, and at least three months before the start of open enrollment if they were transitioning from the FFM to an SBM-FP.
Under the new rules, the approval or conditional approval simply has to be received before the start of open enrollment. States will continue to go through the same intensive process of working with HHS to ensure a smooth transition and well-functioning exchange, but no longer have to obtain approval more than a year in advance to establish an SBM.
However, HHS has finalized a rule change for 2025 and future years that requires a state to operate an SBM-FP for at least one year (including the open enrollment period for that year) before operating a new SBM. This prohibits a state from transitioning directly from the FFM to an SBM.6
Here’s how each state’s exchange operates, as of the 2025 plan year (for enrollments that began in November 2024):
SBMs: State-run marketplaces (these states have their own enrollment websites)
- California
- Colorado
- Connecticut
- District of Columbia
- Georgia (SBM as of November 2024)
- Idaho
- Kentucky
- Maine
- Maryland
- Massachusetts
- Minnesota
- Nevada
- New Jersey
- New Mexico
- New York
- Pennsylvania
- Rhode Island
- Vermont
- Virginia
- Washington
SBM-FPs: State-based marketplaces that use the federal enrollment platform (HealthCare.gov)
- Arkansas
- Illinois (legislation enacted in 2023 called for the creation of an SBM-FP by 2025 and an SBM by 2026; CMS has confirmed that Illinois is no longer receiving federal Navigator funding as of the 2025 plan year,7 since the state will be running an SBM-FP starting in November 2024)
- Oregon (Oregon plans to operate a state-run exchange platform starting in the fall of 2026, per legislation enacted in 2023)8
Partnership exchanges (these states use the federal HealthCare.gov enrollment platform, and are FFM states)
Federally-run marketplace (these states rely entirely on HealthCare.gov and are FFM states)
- Alabama
- Alaska
- Arizona
- Florida
- Hawaii
- Indiana
- Kansas*
- Louisiana
- Mississippi
- Missouri
- Montana*
- Nebraska*
- North Carolina
- North Dakota
- Ohio*
- Oklahoma
- South Carolina
- South Dakota*
- Tennessee
- Texas
- Utah
- Wisconsin
- Wyoming
(States with an asterisk have a marketplace plan management exchange. Their exchanges are federally-run, but the state is active in certifying QHPs for sale in the exchange.)
How does a state's exchange model affect the open enrollment schedule?
States that use the federally-run marketplace – including SBM-FPs and partnership marketplaces – have to follow the open enrollment schedule set by HHS. The current enrollment schedule in these states is November 1 through January 15.
States that run their own exchange platforms can set their own open enrollment schedules, as long as the final deadline isn’t earlier than December 15. But most of them have opted for an enrollment window that’s at least as long as the enrollment window being used by HealthCare.gov. For 2022, 2023, and 2024 coverage, Idaho is the only state-run exchange that has chosen to have an earlier deadline (December 15). HHS has finalized a rule change for 2025 and future years that requires state-run exchanges to continue their open enrollment periods through at least January 15, although Idaho’s earlier enrollment deadline is grandfathered in, with some conditions.
How has management of the marketplaces changed over time?
The exchanges/marketplaces debuted in the fall of 2013, providing coverage for the 2014 plan year. Since then, several states have made changes to their marketplace management. There was initially a trend of states abandoning their own enrollment platforms and opting for HealthCare.gov instead. But we’re seeing the opposite happening in the 2020s, with a growing number of states choosing to leave HealthCare.gov and operate their own exchanges with their own enrollment platforms. This gives a state added flexibility (for example, the opportunity to extend open enrollment) and control, and some states are finding that it’s less costly to operate their own exchanges. Here’s an overview of the states that have made changes to their marketplace management over the years:
For the 2015 plan year:
- Idaho used HealthCare.gov for enrollment in 2014, but switched to being a fully state-run exchange prior to the 2015 open enrollment period.
- Nevada and Oregon both had state-run exchanges in 2014, but due to technical difficulties, they both opted to become federally-supported state-based exchanges (SBM-FPs) before the 2015 open enrollment period (Nevada has since switched back to having a fully state-run exchange).
For the 2016 plan year:
- Hawaii opted to transition to an SBM-FP, abandoning its state-run enrollment platform (as noted below, Hawaii dropped the state-run aspect altogether the following year).
For the 2017 plan year:
- Arkansas switched from having a state-federal partnership exchange to an SBM-FP (enrollment continued to be via HealthCare.gov, so there was no change from a consumer perspective).
- Hawaii switched from an SBM-FP to the federally-run exchange (enrollment continued to be via HealthCare.gov, so there was no change from a consumer perspective).
- Kentucky switched from a state-based exchange to an SBM-FP (Kentucky switched back to a fully state-run exchange and the Kynect enrollment platform in the fall of 2021).
For the 2020 plan year:
Exchange management stayed unchanged for a few years. But several changes took effect in the fall of 2019, for the 2020 plan year:
- Nevada switched to a fully state-run exchange, after having an SBM-FP since 2015. Nevada enrollees now use Nevada Health Link instead of HealthCare.gov.
- New Jersey transitioned to an SBM-FP, after having a federally-run marketplace since 2014 (New Jersey switched to a fully state-run exchange in the fall of 2020, for coverage effective in 2021).
- Pennsylvania also transitioned to an SBM-FP, after having a fully federally-run marketplace in previous years. (Like New Jersey, Pennsylvania stopped using HealthCare.gov in the fall of 2020).
For the 2021 plan year:
The following changes occurred in the fall of 2020:
- Pennsylvania transitioned to a fully state-run exchange, called Pennie (residents no longer use HealthCare.gov).
- New Jersey transitioned to a fully state-run exchange, utilizing the GetCoveredNJ platform (residents no longer use HealthCare.gov).
- Virginia transitioned to an SBE-FP (Virginia transitioned to a fully state-run exchange with its own enrollment platform in the fall of 2023).
- Maine transitioned to an SBM-FP (Legislation was enacted in Maine in 2020 to move forward with the process of creating a state-run exchange, and Maine transitioned to a fully state-run exchange in the fall of 2021.)
For the 2022 plan year:
- New Mexico, Maine, and Kentucky transitioned away from HealthCare.gov as of November 1, 2021, for people enrolling in coverage with a 2022 effective date. All three states had used SBM-FPs for the 2021 plan year.
For the 2024 plan year:
- Virginia has a fully state-run exchange that became operational in the fall of 2023.
For the 2025 plan year:
- Georgia will have a fully state-run exchange platform starting in November 2024.
- Illinois will have an SBM-FP starting in November 2024 (and an SBM starting in November 2025). This change is due to legislation the state enacted in 2023).
Anticipated changes for future years:
- Oregon has an SBM-FP and plans to have a state-run exchange platform starting in the fall of 2026, for coverage effective in 2027 (under the terms of legislation enacted in 2023).9
- Mississippi enacted legislation in 2024 that authorizes the Insurance Commissioner to create a state-run exchange. But the legislation (HB1647) became law without the governor’s signature.1 Mississippi Insurance Commissioner Mike Chaney has long supported the idea of a state-run exchange,10 but he also clarified that he won’t proceed without Governor Reeves’s support.2
Change to SHOP (small business) exchange management
Arkansas, Mississippi, and Utah previously ran their own SHOP exchange (the platform for small businesses to enroll in coverage), but switched to using the federal platform or a direct-to-carrier process by 2018. But by that point, even the federal platform for small business enrollment was no longer functioning as it had in past years, and small group enrollment had switched to a direct-to-carrier process in nearly every state. New Mexico was still running its own SHOP exchange platform as of early 2023, but switched to a direct-to-carrier system in mid-2023.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health insurance marketplace updates are regularly cited by media who cover health reform and by other health insurance experts.
Footnotes
- ”Mississippi HB1647” BillTrack50. Enacted May 14, 2024 ⤶ ⤶
- ”Commissioner won’t create Mississippi health insurance exchange unless governor approves” SunHerald. June 20, 2024 ⤶ ⤶
- ”Michigan SB633” BillTrack50. Accessed March 21, 2024. ⤶
- ”North Carolina S.789” BillTrack50. Accessed June 26, 2024 ⤶
- ”Arizona SB1069” BillTrack50. Accessed June 27, 2024. ⤶
- Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2025; Updating Section 1332 Waiver Public Notice Procedures; Medicaid; Consumer Operated and Oriented Plan (CO-OP) Program; and Basic Health Program. U.S. Department of the Treasury; U.S. Department of Health and Human Services. April 2, 2024. ⤶
- ”2024-2025 CMS Navigator Cooperative Agreement Awardees” Centers for Medicare & Medicaid Services. Aug. 26, 2024 ⤶
- Oregon Senate Bill 972. BillTrack50. Enacted August 2023. ⤶
- Oregon Senate Bill 972. BillTrack50. Enacted August 2023. And Oregon Health Plan (OHP) Bridge Frequently Asked Questions. Oregon Health Authority. May 3, 2024 ⤶
- ”Legislature considering creating a state-based healthcare exchange” WLBT3. April 15, 2024 ⤶
