Public Policy Comments and Letters

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)
Financial Reporting Committee comments to FASB on its Proposed Accounting Standards Update, Health Care Entities (Topic 954) - "Accounting for Legal Costs Associated with Medical Malpractice and Similar Claims." (October 8, 2010)
Joint Committee on Retiree Health and the Pension Accounting Committee joint comments to the NAIC regarding the exposure draft of SSAP 92 (OPEBs) and proposed revisions to SSAP 89 (pensions). (October 4, 2010)
Exchanges Work Group letter to HHS in response to its request for comments on the exchange-related provisions in ACA. (October 4, 2010)
ERM Committee response to the NAIC on its consultation paper on Own Risk and Solvency Assessment (ORSA) for the Solvency Modernization Initiative. (October 4, 2010)
Joint Committee on Retiree Health and the Pension Accounting Committee joint comments to the NAIC regarding the exposure draft of SSAP 92 (OPEBs) and proposed revisions to SSAP 89 (pensions). (October 4, 2010)
P/C Risk-Based Capital Committee response to the NAIC's request on risk-based capital issues. (October 1, 2010)
Deferred Tax Asset DTA Bridge Group request for an interim report to the NAIC Capital Adequacy Task Force showing the appropriate treatment of the Deferred Tax Asset (DTA) in the Risk-Based Capital formulas for Life, Property / Casualty (P&C), and Health. (September 30, 2010)
Annuity Illustration Work Group letter to the NAIC Annuity Disclosure Working Group explaining their suggestions to the Annuity Disclosure Model Regulation and included a sample illustration. (September 30, 2010)
Financial Reporting Committee and Life Financial Reporting Committee comments to FASB on its Proposed Accounting Standards Update, Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities. (September 30, 2010)
Casualty Practice Council request for research assistance from the Casualty Actuarial Society in conjunction with its efforts to aid the National Association of Insurance Commissioners with its RBC SMI project. (September 30, 2010)
Risk Sharing Work Group letter to HHS regarding the ACA reinsurance provision that references the Academy. The letter includes initial input on potential approaches for identifying high-risk individuals and determining reinsurance payments. (September 22, 2010)