CACs and CDOs

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Certified Application Counselor Designated Organizations (CDOs) wishing to operate in Virginia must register at Information on CDO and CAC regulations are found in 14 VAC 7-10 "Rules Governing the Certified Application Counselor Program".
Questions? Call 804-371-9631 or email

What is a Certified Application Counselor Designated Organization (CDO)?

CDOs are a vital component of the assister community. They oversee Certified Application Counselors (CACs), who are trained and able to help consumers seeking health insurance coverage options through the Virginia Health Benefit Exchange. CDOs must be designated by the Virginia Exchange to operate in Virginia. CDOs designated by the Virginia Exchange certify CACs.

CDO Designation Requirements:

Register as a CDO in Virginia by submitting an application.

You will need to provide the following as part of the application:
  • Signed Virginia Exchange Compliance Agreement
  • Demographic and Operational Information
  • Completed List of Certified CACs Form
  • List of Counties and Cities in which you intend to operate
  • Pay CDO Fees- $0 Application Fee and $8.55 Sircon Service Fee (approx.)
  • Provide the following data and information to the Virginia Exchange on a quarterly basis:
    • Certifying individuals to serve as CACs in accordance with 45 CFR §155.225(d) and execution of agreements with CACs pursuant to 45 CFR § 155.225(d)(6).  
    • Requiring CACs complete required training in accordance with 45 CFR §155.225(d). For Plan Year 2022, the Virginia Exchange will require the completion of the FFE’s training; no state-specific training will be used.
    • Maintaining a registration process and method to track the performance of CACs as specified in 45 CFR § 155.225 (b)(ii).
    • Administration of a system to handle and protect personally identifiable information (PII) and provision of a PII authorization form attesting to adherence to all terms and conditions of privacy and security pursuant to 45 CFR § 155.260(b)(2). 
    • Provide data and information to the Virginia Exchange on a quarterly basis a list of CACs and their performance in accordance with 14 VAC 7-10-40

The Virginia Health Benefit Exchange published rules to outline the designation requirements that CDOs will need to meet to be designated in Virginia. CDO and CAC regulations are found in 14 VAC 7-10: Rules Governing the Certified Application Counselor Program.


  • CDOs are required to renew their registration with the Virginia Exchange every 2 years from date of initial registration.

What is a Certified Application Counselor (CAC)?

A CAC is an individual staff member or volunteer who is certified by a CAC designated organization (CDO) and trained to help consumers look for health coverage options through the Virginia Exchange and Virginia's Medicaid program. This includes helping consumers complete the eligibility and enrollment process. Their services are free to consumers.

What are the certification requirements for a CAC?

  1. Successfully complete assister training through the CMS Marketplace Learning Management System (MLMS). There is no additional state-specific training required this year.
    • When accessing the training on the MLMS landing page, select “SBE-FP Assister” under the “Assister type” drop-down. For the “Organization Type” drop-down, select “State-based Exchange using the Federal Platform.” 
      • The MLMS system will not recognize the previously-issued assister IDs. The CDO you are affiliated with will issue you a new assister ID for use with the Virginia Exchange. The new ID should be input in the MLMS system; however, it is not required to complete the training.
  2. Achieve a passing score on all Virginia Exchange-approved certification examinations.
  3. ​Execute privacy and security agreement with your CDO.
  4. Receive certification from CDO. 

CACs are not required to register with the Virginia Exchange. CDOs will register and provide a list of CACs certified to operate through that organization.