Public Policy Comments and Letters

Actuarial Equivalence Work Group letter to CMS regarding actuarial equivalence issues related to prescription drug plans (PDPs), Medicare Advantage (MA) plans, Medicare supplement plans, and retiree health benefits. (October 4, 2004)
Medicare Steering Committee letter to CMS discusses issues related to the calculation of monthly savings — a step in determining beneficiary rebate amounts for MA plans — and payment adjustments based on the variation in costs among different areas including input prices, utilization, and practice patterns. (October 4, 2004)
Medicare Steering Committee letter discusses issues related to eligibility and enrollment, benefits and beneficiary protections, submission of bids and monthly beneficiary premiums, payments to prescription drug plan sponsors and Medicare Advantage (MA) organizations, etc. Comments on issues related to actuarial equivalence in a separate letter. (October 4, 2004)
Academy document includes a series of tips to facilitate using the Rate Filing Task Force model. (September 30, 2004)
Financial Reporting Committee comments on FASB exposure draft, "Proposed Statement of Financial Accounting Standards: Fair Value Measurements." (September 30, 2004)
Pension Practice Council letter to the Internal Revenue Service (IRS) on proposed changes to the Employee Retirement Income Security Act of 1974 (ERISA) regulations. (September 1, 2004)
Extreme Events Committee comment letter to the U.S. House in preparation for its consideration of proposed legislation to extend the Terrorism Risk Insurance Act of 2002. (July 28, 2004)
Multiemployer Plans Task Force letter to the International Accounting Standards Board (IASB) commenting on a draft interpretation concerning financial reporting for multiemployer plans. (July 9, 2004)
Risk Management and Solvency Committee comments on an IAA comment letter on an IAIS paper, "Draft Supervisory Standard on Suitable Forms of Capital." (July 1, 2004)
Stock Options Task Force comment letter to the Financial Accounting Standards Board (FASB) regarding the measurement of employee stock options. (June 30, 2004)
Long Term Care Risk Based Capital Work Group report on the review of the Managed Care Organization RBC formulas for LTC describes the source of data, methodology, analysis, and recommendations. It reflects revisions based on feedback from members of the NAIC subgroup after the interim report was released in June 2003. (June 1, 2004)
Committee on Property and Liability Financial Reporting comments to the Financial Accounting Standards Board in response to the American Institute of Certified Public Accountants' paper evaluating risk transfer in reinsurance of short-duration contracts. (May 1, 2004)
Joint Committee on Retiree Health letter to the Governmental Accounting Standards Board (GASB) on accounting by governmental employers for other postemployment benefits. (April 30, 2004)
Joint Committee on Retiree Health comments to FASB opportunity to comment on the proposed FASB staff position (FSP) 106-b, Accounting and Disclosure Requirements Related to the Medicare Prescription Drug, Improvement and Modernization Act of 2003. (April 13, 2004)
Health Savings Account Subgroup comments on IRS Notice 2004-2, which provides guidance on Health Savings Accounts (HSAs) provisions in the Medicare Prescription Drug, Improvement, and Modernization Act of 2003. (March 30, 2004)
Health Savings Account Subgroup comment letter on Notice 2004-2 issued by the Treasury Department and the Internal Revenue Service, which provides guidance on Health Savings Accounts (HSAs). (March 30, 2004)
Risk Management and Solvency Committee addendum to a March 25 comment letter on an IAA framework for assessing insurer solvency. (March 29, 2004)
Risk Management and Solvency Committee comments to the IAA on its framework for assessing insurer solvency. (March 25, 2004)
Pension Practice Council comment letter to staff on the Senate Health, Education, Labor and Pensions (HELP) Committee regarding the multiemployer provisions of H.R. 3108. (March 4, 2004)
Social Insurance Committee letter to the Social Security trustees about a technical panel recommendation on measuring unfunded obligations. (December 19, 2003)