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What if your exchange site changes?

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The public exchange program managers aren’t enthusiastic about spending Patient Protection and Affordable Care Act cash on information technology changes.

Officials at the Center for Consumer Information & Insurance Oversight, the arm of the Centers for Medicare & Medicaid Services responsible for running the exchanges, talk about IT change orders in the latest batch of guidance.

CCIIO developed the guidance for managers of state-based exchanges getting bills from IT vendors for enrollment system and other changes.

The states with state-based exchanges have used money provided by PPACA Section 1311 to cover the cost of setting up exchanges.

Some states tried to make the job of setting up an exchange cheaper, quicker or easier by putting off work on some exchange components, such as automated, Web-based systems for helping small groups get coverage.

CCIIO will approve change orders that result from new federal laws, regulations or agency guidance, but, “due to large investments in CCIIO generally does not plan to approve changes related to IT activities that were approved as part of a grantee’s initial proposal, but were later deferred or de-scoped by the grantee,” agency officials write in an answer to exchange manager questions.

Reviewers of change order funding will look to see whether an exchange used contract contingency clauses to address the issue that triggered the change order, and whether the change is really necessary to make the IT systems of a state-based exchange functional.

The reviewers also will ask why the work isn’t covered under existing maintenance or option years, and whether the work will be performed by the original vendors or new ones.

In an answer to another question, CCIIO officials say exchanges can use Section 1311 money to cover the “reasonable, allowable and allocable” costs associated with answering congressional inquiries, but not to pay for lobbying.

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