Under the law, the application forms must be easy to complete, and they must interface with an electronic eligibility system than can tell applicants about the federal benefits to which they are entitled.
Access is another key component of the law — all systems must be reachable online, in person and by fax, mail and telephone.
According to HHS, 35 of the 45 states that replied to the 2012 survey said they would be ready with new systems by the 2014 deadline.
Forty states, meanwhile, said they would at least have program application forms that meet the Affordable Care Act's requirements.
States that reported challenges meeting the deadline cited time pressure and lack of funds to make the necessary changes. Eleven states said their healthcare eligibility and enrollment systems are so outdated that they need complete overhauls.
"Without a prior online system, we are having to create something from scratch," an unidentified state reported to HHS. "Creating both the policy and the technical capacity in such a short timeframe, with inadequate federal guidance, is the biggest hurdle."
Many states called for more guidance from HHS on application requirements and the Affordable Care Act's federal data hub, which will undergird state eligibility systems.
It is difficult to say whether those requests for further detail have been satisfied, as the survey took place nearly one year ago, before the Supreme Court's decision to uphold the law and before state implementation began in earnest.