How will the California Health Benefit Exchange carry out the exchange provisions of the federal Affordable Care Act (ACA)? A table prepared by Ed Neuschler and Rick Curtis of the Institute for Health Policy Solutions compares provisions of California's legislation to establish and define the state's exchange (AB 1602/SB 900) with the corresponding ACA guidelines.

The side-by-side comparison addresses the principal components of both sets of laws regarding the exchange, including the following:

• Organizational location, governance, and staffing
• Funding of exchange operations
• Plan certification and contracting
• Product offerings
• Role as a clearinghouse for outside market
• Premium collection and plan payment
• Small Business Health Options Program (SHOP) and the small employer market
• Eligibility and enrollment
• Outreach, marketing, and consumer information

To help clarify the differences between the state and federal legislation, California provisions are categorized as (1) those that go beyond the federal requirements, (2) those that restate the federal provisions, or (3) those that choose among federal options or make a federal option more specific.

In addition, several unresolved issues are identified. Many provisions of the federal ACA are phrased in general terms, and their implications and requirements for the California exchange will not be fully understood until further administrative guidance or federal regulations are released.