Public Policy Comments and Letters

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)
P/C Risk-Based Capital Committee comments on an IAA draft concerning an RBC solvency structure. (March 14, 2002)
VAGLB Work Group comments on proposed revisions to Actuarial Guideline MMMM (March 1, 2002)
Joint RBC Task Force updated comparison of the NAIC's life, P/C, and health RBC formulas. (February 12, 2002)
Life Capital Adequacy Subcommittee on Instuction and Formula Modifications report on RBC instruction and formula modification. (February 1, 2002)
Medicare Steering Committee comment letter on proposed changes in the Medicare+Choice risk adjustment methodology and reporting requirements for diagnostic information for use beginning in 2004. (January 30, 2002)
Comments from the Life Liquidity Work Group on the New York Insurance Department's Circular Letter XX. (January 10, 2002)
Academy comments to Connecticut Insurance Department on mapping terms for insurance risks and banking risks. (December 7, 2001)
Casualty Practice Council letter to Senate on terrorism risk insurance legislation. (December 5, 2001)
Mass Tort Work Group overview of asbestos issues and trends. (December 1, 2001)
Life Financial Reporting Committee suggested changes in SSAP form. (November 16, 2001)
Life Product Committee comment letter on life insurance product standards to Michigan and Pennsylvania insurance commissioners. (October 9, 2001)