Public Policy Comments and Letters

Health Practice Council and Pension Practice Council letter to GASB discussing concerns actuaries have about two aspects of the proposed standard, including the use of a common premium concept to determine whether an employer is subject to the accounting and reporting aspects of this standard, and, the use of an alternative (non-actuarial) approach that could be used by small employers. (December 13, 2002)
Academy commments to the SEC on proposed Sarbanes-Oxley Act disclosure rules. (November 26, 2002)
Committee on Property and Liability Financial Reporting letter to Casualty Actuarial Society on Statement of Principles Regarding Property and Casualty Loss and Loss Adjustment Expense Reserves. (November 12, 2002)
Life Financial Reporting Committee comment on draft of the proposed statement of position, "Accounting and Reporting by Insurance Enterprises for Certain Nontraditional Long-Duration Contracts and for Separate Accounts." (October 30, 2002)
Life Financial Reporting Committee comments on an AICPA Proposed Statement of Position: "Accounting and Reporting by Insurance Enterprises for Certain Nontraditional Long-Duration Contracts and for Separate Accounts." (October 30, 2002)
EEOC-ADEA and Retiree Health Work Group letter that provides a list of potential issues that could complicate implementation of retiree medical safe harbors are placed into three categories — rating and measurement, plan interpretation, and other. (October 16, 2002)
Workers' Compensation Subcommittee comments on a proposed federal backstop for potential terrorism-related workers' compensation losses. (October 10, 2002)
Workers' Compensation Subcommittee letter to the Social Security Committee of the International Actuarial Association (IAA) regarding draft IAA guidelines of actuarial practice for social security programs. (October 7, 2002)
Workers' Compensation Subcommittee letter to the International Actuarial Association (IAA) regarding draft IAA guidelines of actuarial practice for social security programs. (September 27, 2002)
Academy letter to SEC nominating Richard Robertson to the Public Company Accounting Oversight Board. (August 28, 2002)
Follow-up comments of James Hurley of the Medical Malpractice Subcommittee after providing testimony to the House Subcommittee on Health hearing on the availability and pricing of medical malpractice liability insurance. (July 31, 2002)
Automobile Insurance Subcommittee letter to the Environmental Protection Agency addressing the actuarial issues raised by the EPA's voluntary pay-as-you-drive initiative. (July 19, 2002)
Academy letter to the House Committee on Financial Services on the definitions of "actuarial services" and "appraisal or valuation and fairness opinions" in H.R. 3763, the Public Company Accounting Reform and Investor Protection Act of 2002. (July 19, 2002)
Life Products Committee comments on the proposed Genetic Discrimination Model Act to the National Conference of Insurance Legislators (NCOIL) Life Committee as it considers the proposal. (July 13, 2002)
Health Practice Council letter to Congress offers the Academy as a resource on questions related to Medicare and prescription drugs, and notes that adding any additional benefits, in particular a prescription drug benefit, without addressing the financing of the entire Medicare program would be unwise given the uncertainties for future funding of the current benefit structure. (June 20, 2002)
Workers' Compensation Subcommittee comment letter on HHS privacy regulations to the U.S. Department of Health and Human Services. (April 25, 2002)
Life, Health, and Property/Liability Financial Reporting Committees comment on NAIC exposure draft of Issue Paper 118. (April 19, 2002)
Life Practice Council comments to the California Insurance Department on the AOMR. (April 15, 2002)
Health Plan Work Group comments on the association health plan (AHP) provisions in Title IV, Subtitle B of the Bipartisan Patient Protection Act (H.R. 2563), which would amend the Employee Retirement Income Security Act of 1974 to establish a new “Part 8—Rules Governing Association Health Plans. (April 9, 2002)
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. (March 31, 2002)