On the heels of last week's announcement that online enrollment in the federal Small Business Health Options Program ("SHOP") exchange would be delayed for one year, the Centers for Medicare & Medicaid Services has issued a "frequently asked questions" document on the SHOP initiative. The FAQs describe the "direct enrollment" process that employers will need to use in lieu of the HealthCare.gov website, which will offer information on available plans and basic pricing information but no application or enrollment function.

"Direct enrollment" will require completion of a paper application with an agent, broker or insurance company that offers health plans through the SHOP Marketplace. The new rules apply only to states that are using the government's "Federally Facilitated SHOP Marketplace," which was intended to be operated through HealthCare.gov. Small businesses located in states that are running their own SHOP exchanges will need to follow their state’s application and enrollment process.