“CCIIO is encouraging states to allow “unloaded” ACA plans to be offered outside of the marketplace. This includes silver plans (where a state or insurer is using silver loading) or all metal level plans (where a state or insurer is using broad loading). The guidance essentially gives CCIIO’s blessing to states and insurers who have been or would like to restrict CSR loading to on-marketplace plans only.”
More details at HealthAffairs:
https://www.healthaffairs.org/do/10.1377/hblog20180805.711405/full/