In less than one year, Affordable Insurance Exchanges (“Exchanges”) authorized by the Affordable Care Act (“ACA”) are scheduled to be operational, providing a marketplace for the purchase of Qualified Health Plans (“QHPs”) in the individual and small group markets. The Obama Administration has recently accelerated rulemaking and subregulatory guidance associated with the new Exchange/QHP framework, with many of the key details only now being finalized. Reed Smith’s Client Alert focuses upon some of the most significant features of QHPs and related issues, with a particular emphasis on prescription drugs. This includes a summary of ACA subsidies and associated potential fraud and abuse implications, including the potential for QHPs to be considered federal health care programs subject to the federal anti-kickback statute.