Congress’ non-partisan investigative branch has taken a long, hard look at the implementation timeline for the Patient Protection and Affordable Care Act (ACA), and its findings don’t bode well for those hoping for a timely roll-out of the bill’s major provisions.

In a report issued in early June, the Government Accountability Office (GAO) found that the federal government, which is expected to operate exchanges in 34 states, has missed a wide variety of key deadlines leading up to the scheduled October 1 launch of pre-enrollment in state exchanges, which will serve as subsidized insurance marketplaces and are the lynchpin of ACA’s reforms. While the federal Department of Health and Human Services (HHS) continues to express confidence in the October 1 go live date, the GAO’s report concludes that the government could very well miss this key milestone should any further complications arise between now and October.

Throughout the implementation process, federal deadlines have continued to shift and, in most cases, be pushed back in response to challenges faced by states and HHS as they establish the framework for a new health care landscape. While recognizing these challenges, the GAO’s report notes that roughly 44 percent of key activities initially targeted for completion by March 31, 2013, were behind schedule at the time the report was compiled. Among the delayed components were several major issues, including those that determine consumer eligibility for federal subsidies, the process of selecting health plans to be offered on federally operated exchanges and the hiring and training of “navigators,” who will be responsible for helping the roughly 22 million people expected to gain coverage by 2016 navigate the ACA’s various complexities.

While a majority of states could see reform efforts dramatically impacted by a delay in pre-enrollment, it remains to be seen how California would be affected. Many of the deadlines mentioned in the GAO’s report, specifically the selection of qualified health plans (QHPs) have come together in recent months, and the Golden State looks to be far better off than several other state-based exchanges in key implementation activities (see table at right). For instance, at Covered California’s June meeting, the development of the online consumer interface and related screening systems was generally on schedule, as was the implementation of the exchange’s vast customer service network and the hiring of its hundreds of call center employees.

States pursuing the active purchaser model of the exchange, like California, have had to build in time for more comprehensive negotiations between the exchange and each participating health plan. This is because active purchaser exchanges take on the role of a large purchaser negotiating the terms of coverage on behalf of a pool of covered lives – unlike an open marketplace exchange, which allows all issuers that meet minimal threshold requirements to participate in the exchange.

Needless to say, there is still an immense amount of work to be completed and any setbacks within the next 90 days will jeopardize the October 1 activation of the www.CoveredCA.com eligibility and enrollment interface. In the event of a potential delay, HHS said in the GAO report that it is “working on strategies in each state to address contingencies.” HHS added, however, “Whether [the] contingency planning will assure the timely and smooth implementation of the exchanges by October 2013 cannot yet be determined.”

Stakeholders continue to hope such contingency planning is never tested.