Public Policy Comments and Letters

Social Insurance Committee letter to the Social Security trustees about a technical panel recommendation on measuring unfunded obligations. (December 19, 2003)
Joint Financial Reporting Task Force comments on an IASB proposal for international accounting standards for insurance contracts. (October 31, 2003)
Academy comments to COSO about its draft "Enterprise Risk Management Framework. (October 14, 2003)
Health Practice Council letter to House and Senate conferees, who are reconciling to Medicare Rx bills, that offers assistance in assessing the actuarial implications of changes to the Medicare program. (September 29, 2003)
Retiree Health Work Group comments related to the proposed rule by the Equal Employment Opportunity Commission (EEOC) on the Age Discrimination in Employment Act (ADEA) and retiree health benefits. (September 12, 2003)
Long-Term Care Reserve Work Group letter to NAIC that illustrates the anticipated impact of various hypothetical changes in the mortality, voluntary lapse, interest and morbidity valuation assumptions on net renewal valuation premiums and contract reserves by policy duration. (September 10, 2003)
Long-Term Care Risk-Based Capital Work Group letter to the Deputy Insurance Commissioner of Pennsylvania responding to concerns regarding total asset adequacy as it relates to the Long-Term Care RBC Work Group's interim report. (September 8, 2003)
Health Practice Financial Reporting Committee letter addressing general principles that should be considered in the development of and addressed by premium deficiency reserves and gross premium valuations. (September 3, 2003)
Health Practice Council letter on the general risk sharing approaches available, summarizes the risk-sharing provisions in the Senate and House bills, and provides specific comments on the risk-sharing approaches in the Senate and House bills. (July 30, 2003)
Health Liquidity Work Group status update to the NAIC on a set of potential ratios to be used to test for health organization liquidity. The ratios would be used in a “safe harbor” test. (June 30, 2003)
Annuity Nonforfeiture Implementation Work Group comments to the NAIC regarding the implementation of a new model nonforfeiture law for deferred annuities. (June 25, 2003)
Long-Term Care RBC Work Group interim report on the Managed Care Organization Risk Based Capital formulas for Long Term Care (LTC) insurance products and described the source of data, methodology, analysis, and recommendations. (June 22, 2003)
Illustrations Work Group comments to the NAIC on mortality assumptions used in life insurance. (June 1, 2003)
Health Practice Council comments on legislation that was introduced in both the House and Senate to regulate the use of genetic information, particularly with respect to health insurance. (May 22, 2003)
Retiree Health Insurance Work Group letter to the Governmental Accounting Standards Board (GASB) about the actuarial measurement of retiree health benefits. (May 20, 2003)
Workers' Compensation Subcommittee comments in response to a Federal Register request by the Treasury Department for comments on implementation of Title I of the Terrorism Risk Insurance Act of 2002 and the related April 15, 2003 Interim Final Rule. (May 16, 2003)
Life Financial Reporting Committee comments on an AICPA proposed statement of opinion for deferred acquisition costs on internal replacements. (May 15, 2003)
Health Plan Work Group comments on the Small Business Health Fairness Act of 2003 (H.R. 660 and S. 545), which would amend ERISA to establish a new “Part 8—Rules Governing Association Health Plans. (April 28, 2003)
LTC Reserve Work Group outline of the proposed near-term and long-term objectives as they relate to the NAIC's request for the Academy to review the reserve methodology for LTC insurance. (March 7, 2003)
Academy comments to the SEC on proposed Sarbanes-Oxley Act auditor independence rules. (January 6, 2003)