Public Policy Comments and Letters

Life, Health, and Property/Casualty RBC committees joint report in response to the NAIC's request for assistance with the Solvency Modernization (SMI) project on the NAIC's Risk-Based Capital (RBC) formulas. This report discusses the intended/expected safety levels for RBC and identifies risks that are missing from the RBC formulas. (February 2, 2011)
Committee on Property & Liability Financial Reporting's report on its recent activities to the NAIC's Casualty Actuarial & Statistical Task Force. (February 1, 2011)
Academy report to the NAIC in response to its request for assistance with the Solvency Modernization project on the NAIC's Risk-Based Capital (RBC) formula. (January 31, 2011)
Life, Health, and Property/Casualty RBC committees joint report in response to the NAIC's request for assistance with the Solvency Modernization (SMI) project on the NAIC's Risk-Based Capital (RBC) formulas. The report discusses the intended/expected safety levels for RBC and identifies risks that are missing from the RBC formulas. (January 31, 2011)
Medical Loss Ratio Regulation Work Group letter to HHS in response to an interim final rule on the medical loss ratio (MLR) provisions in the Affordable Care Act. (January 31, 2011)
Health Practice Council letter to CMS in response to its request for comments on the Medicare Advantage risk adjustment data validation (RADV) payment error calculation methodology. (January 21, 2011)
Medicaid Work Group letter to CMS in response to CMS' request for assistance in revising the Medicaid rate setting checklist. (January 14, 2011)
Pension Committee comments to the Internal Revenue Service regarding proposed regulations for hybrid retirement plans. (January 12, 2011)
ERM Committee comments to the IAIS on its draft paper ICP7: "Corporate Governance." (December 31, 2010)
IFRS Task Force comments to the IASB on its Insurance Contracts Exposure Draft and comments to the FASB on its accompanying discussion paper. (November 30, 2010)
Annuity Illustration Work Group comment letter regarding the Annuity Disclosure Model Act to the NAIC Annuity Disclosure Working Group. (November 11, 2010)
Premium Review Work Group comment letter on the NAIC Health Insurance and Managed Care (B) Committee's exposure draft of a rate filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS. (November 5, 2010)
Medical Loss Ratio Regulation Work Group letter to HHS addressing three components of the NAIC's proposed regulation on medical loss ratios: credibility adjustments, exclusion of federal taxes from the denominator, and the use of three months' runout. (November 5, 2010)
IAWG Comment Lettter on ACLI Proposal for Commercial Mortgages
Invested Asset Work Group letter to the NAIC Life RBC Working Group regarding the ACLI's Proposal on Risk-Based Capital for Commercial Mortgages. (November 4, 2010)
Multiemployer Pension Plans Subcommittee comments to the Financial Accounting Standards Board regarding proposed updates to disclosures required for employers that participate in multiemployer plans (November 1, 2010)
Joint Committee on Retiree Health and the Pension Accounting Committee comments to the NAIC regarding the exposure draft of SSAP 92 (OPEBs) and proposed revisions to SSAP 89 (pensions). (October 30, 2010)
Health Practice Financial Reporting Committee comments to the Actuarial Standards Board regarding a proposed revision to ASOP 28. (October 30, 2010)
Premium Review Work Group letter to HHS providing an evaluation of several potential methods for defining or measuring unreasonable rate increases. (October 29, 2010)
Solvency Committee and ERM Subcommittee comments to NAIC on its Group Capital Assessment Options Paper. (October 11, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC B Committee regarding the October 4 exposure draft of the proposed MLR rebate regulation. (October 8, 2010)