Public Policy Comments and Letters

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)
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)