"[CMS has] determined that the HHS exemption option is an efficient process for [state-based marketplaces (SBMs)] that has minimized confusion for consumers. We, therefore, intend to propose regulations that would authorize this option on a permanent basis, and, in the interim, will not take any enforcement action against SBMs that continue to use the HHS service for exemptions beyond the start of open enrollment for 2016.... States that did not establish SBMs or use their own eligibility platforms do not have the option to process their own exemptions.... As a condition of using the HHS exemption option, the SBM must furnish HHS with 'any information available through the Exchange that is necessary for an applicant to utilize the process administered by HHS' ... Electronic exemption application capabilities are not a requirement."