More than a dozen states run their own health insurance exchanges separate from Healthcare.gov. For brokers who work primarily in FFM states, the distinction is invisible. For brokers who cross state lines or have clients who move, it is a registration requirement, a different plan set, and in some cases a different open enrollment window. The state exchange is not an alternate route to the same destination. It is a separate system with its own rules.
Key Takeaways
- More than a dozen states operate their own health insurance exchanges separate from Healthcare.gov. Brokers must register on each SBE where they write business, in addition to holding a state insurance license.
- OEP windows differ by state. Several SBEs extend the federal window into January or February. A client who missed the Healthcare.gov deadline may still be able to enroll on their state exchange.
- Some SBE states have plans that are only available through the state exchange, not visible on Healthcare.gov. Brokers who do not use the state platform miss part of the plan set.
- Moving between an SBE state and an FFM state, or between two SBE states, qualifies as a move to a new coverage area and triggers a SEP. The 60-day window runs from the move date.
- Broker compensation in SBE states flows differently than in FFM states. Some SBEs pay carriers who then pay brokers. Others have their own commission structures. Verify before writing business in a new state.
SBE vs FFM: what the distinction means in practice
The federally facilitated marketplace is the exchange operated by CMS through Healthcare.gov. States that do not operate their own exchange use the FFM for individual market enrollment. Brokers who write business in FFM states register through Healthcare.gov and use a single broker portal.
A state-based exchange (SBE) is an exchange operated by the state under ACA authority. The state sets its own broker registration requirements, may set its own OEP window within ACA limits, and hosts its own plan selection. Plans in an SBE state are only available through that state's platform. A broker who has not registered on the SBE cannot enroll clients in that state through Healthcare.gov. The redirect goes one way: if a client in an SBE state visits Healthcare.gov, they are sent to the state platform.
Some states use a hybrid model: they operate their own exchange for plan management and eligibility decisions but use the federal enrollment platform for the technical enrollment process. The distinction matters for broker registration requirements and plan access. If a state's exchange website routes clients to Healthcare.gov for enrollment, the broker follows the FFM registration process. If the state runs enrollment on its own platform, a separate SBE registration is required.
State-based exchanges and broker registration
| State | Exchange name | Broker registration note |
|---|---|---|
| California | Covered California | Separate Covered California certification required in addition to state license |
| Colorado | Connect for Health Colorado | Broker registration on Connect for Health required |
| Connecticut | Access Health CT | Broker registration on Access Health CT required |
| Idaho | Your Health Idaho | Broker registration on Your Health Idaho required |
| Kentucky | kynect | Broker registration on kynect required |
| Maine | CoverME.gov | Broker registration on CoverME.gov required |
| Maryland | Maryland Health Connection | Broker registration on Maryland Health Connection required |
| Massachusetts | Massachusetts Health Connector | Connector certification required; OEP typically extends past federal window |
| Minnesota | MNsure | Broker registration on MNsure required |
| Nevada | Nevada Health Link | Broker registration on Nevada Health Link required |
| New Jersey | Get Covered NJ | Broker registration on Get Covered NJ required |
| New York | NY State of Health | Broker registration on NY State of Health required; extended OEP |
| Pennsylvania | Pennie | Broker registration on Pennie required |
| Rhode Island | HealthSource RI | Broker registration on HealthSource RI required |
| Vermont | Vermont Health Connect | Broker registration on Vermont Health Connect required |
| Washington | Washington Healthplanfinder | Broker registration on Washington Healthplanfinder required |
| Washington DC | DC Health Link | Broker registration on DC Health Link required |
States can transition between SBE and FFM operation. Verify current status and broker registration requirements at CMS.gov before writing business in a new state.
OEP windows: where SBE states differ
The federal OEP runs from November 1 through January 15 for coverage starting the following month. SBE states may extend this window. New York, Massachusetts, and California have all run OEPs that extend into February. The extension is set by the state each year and is not guaranteed to repeat.
The practical implication for brokers: a client who calls in mid-January believing they missed enrollment may have options if they live in an SBE state. Check the state exchange's current enrollment window before telling that client to wait for next year. One phone call to confirm the window is open is less painful than finding out it was open after the client gave up.
On the enrollment timing rules that apply regardless of which exchange the client uses, including what qualifies as an on-Marketplace enrollment for subsidy purposes, read on Marketplace vs off Marketplace: when to quote each.
Moving between states and SEP implications
A client who moves from a California zip code to a Texas zip code is moving from an SBE state to an FFM state. Both the coverage area and the exchange change. That is a qualifying life event. The 60-day SEP window runs from the move date. The client loses access to Covered California plans and gains access to Texas FFM plans. The prior California coverage satisfies the prior coverage requirement for the moving SEP.
The same logic applies in reverse and between SBE states. A move from New York to Washington state is a move between two SBE states, two different plan sets, two different exchanges. The coverage area changes. The SEP applies. Document the move date. Collect proof of the new address. Run updated APTC math with the new state's plan data before the plan selection conversation. For the full moving SEP documentation requirements, read how brokers handle SEP qualifying life events.
Commission flow in SBE states
Broker commissions in FFM states are paid by carriers. The commission schedule is the carrier's contract with the broker, governed by state law. In SBE states, the commission structure varies. Some state exchanges have their own commission schedules that differ from FFM carrier rates. Some SBEs pay carriers who then pay brokers on a schedule that may differ by state.
Covered California, for example, has its own commission structure that applies to brokers certified on the exchange. It is not identical to what a carrier might pay in an FFM state. Before writing significant volume in a new SBE state, verify the commission flow: who pays, on what schedule, and what the carrier-specific rates are in that exchange. For the full commission structure in ACA, including how APTC affects carrier payment, read how ACA broker commissions work in 2026.
Quoting tools and SBE state coverage
Most national quoting tools, including Quotit and GetInsured, default to FFM plan data for quoting and may not surface SBE-state plans through the same interface. Brokers who write business in SBE states typically need to use the state exchange portal directly for plan selection and enrollment, even if they use a third-party tool for subsidy estimation and client comparison.
QuoteTurbo pulls CMS Marketplace plan data for FFM states. For SBE states, the authoritative source for plan data, pricing, and enrollment is the state exchange platform itself. Use the plan finder for preliminary subsidy math and plan exploration in FFM states. For SBE clients, treat the state portal as the enrollment source of truth.
FAQ
Questions brokers ask when working with state-based exchanges for the first time.
Can I enroll a client in an SBE state through Healthcare.gov?
No. Clients in states with their own exchange must enroll through that state's exchange to access Marketplace plans. Healthcare.gov redirects users in SBE states to the state platform. Brokers who try to enroll an SBE-state client through Healthcare.gov will not find the state's plan offerings there.
Do I need a separate registration for each state-based exchange?
Yes. A state insurance license is required to sell in the state, and most SBEs also require a separate broker registration or certification on their platform. Covered California is the most well-known example, requiring its own certification distinct from the California resident license. Check each SBE's broker portal for their specific registration requirements before writing business.
Do SBE states have longer open enrollment periods?
Several do. Massachusetts, New York, and California historically extend their OEP past the federal November 1 to January 15 window. The extension varies by year and state. Brokers who have clients who missed the federal deadline should check whether the client's state exchange is still open before concluding enrollment is not possible.
Does moving from an SBE state to an FFM state trigger a SEP?
Yes. Moving to a new coverage area is a qualifying life event regardless of whether the move crosses between SBE and FFM states or between two states of the same type. The 60-day window runs from the move date. The client loses access to their prior state's plans and gains access to plans in the new state. Prior coverage in the old state satisfies the prior coverage requirement for the moving SEP.
Are the plans on an SBE different from Healthcare.gov plans?
Plans in SBE states are only available through the state exchange. Healthcare.gov does not show SBE-state plans. Some states also have state-specific plan designs or carrier arrangements that exist only because of the state exchange. A broker working in California who has not registered on Covered California is missing the entire plan set available to California clients.
