Health Comments and Letters

Health Practice Council letters to both the U.S. House and Senate on potential adverse consequences of legislation to weaken the Affordable Care Act’s (ACA) individual mandate. (September 22, 2016)
LTC Reform Subcommittee comment letter to the Maryland Insurance Administration Public Hearing on Long-Term Care Insurance. (April 28, 2016)
Risk Sharing Subcommittee letter to the Centers for Medicare & Medicaid Services (CMS) with comments on its recent discussion paper, HHS-Operated Risk Adjustment Methodology. The letter includes comments on partial year enrollment, use of pharmacy data, use of concurrent versus prospective model, high-risk enrollee pooling, recalibration of the model, and the transfer formula.  (April 22, 2016)
Health Care Receivables Factors Work Group recommendation on credit risk factors for health care receivables to the NAIC’s Health Risk Based Capital (E) Work Group. (April 15, 2016)
Premium Review Work Group letter to CCIIO with comments on the 2017 unified rate review template (URRT). (March 30, 2016)
Health Solvency Subcommittee letter to the NAIC’s Health Risk-Based Capital (E) Working Group with comments on Proposal 2016-01-H’s individual premiums and claims footnote. (March 28, 2016)
Medicare Subcommittee letter to the Senate Finance Committee with comments on the Bipartisan Chronic Care Working Group’s Policy Options Document. (January 26, 2016)
Risk Sharing Subcommittee letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule on benefit and payment parameters for 2017. (December 20, 2015)
Individual Disability Tables Work Group (IDTWG) presented updated incidence modifiers report for use in active life reserve calculations for employer-sponsored disability income policies along with a corresponding memo memo to the chair of the Health Actuarial Task Force. (November 18, 2015)
Medicare Supplemental Work Group responses to questions regarding the work group’s recommendations on modifications to the Medicare supplement refund formula.
(November 10, 2015)
Health Solvency Subcommittee updated on the evaluation of asset risk in the health risk-based capital (HRBC) formula.
(November 9, 2015)
Financial Reporting and Solvency Committee comment letter to the NAIC's Emerging Accounting Issues (E) Working Group on the “ACA Risk Corridors Collectability” exposure draft. (October 30, 2015)
Active Benefits Subcommittee letter to the IRS regarding Notice 2015-52 on the excise tax for high-cost employer-sponsored health coverage under the Affordable Care Act (ACA). (October 1, 2015)
Premium Review Work Group letter to CCIIO with suggested changes to the unified rate review template (URRT) and rating methodology. (September 22, 2015)
The Casualty Practice Council, Health Practice Council, Life Practice Council, and Risk Management and Financial Reporting Council comments to the National Association of Insurance Commissioners (NAIC) on its Financial Condition (E) Committee questionnaire that examines the reasons for single-state solutions to help regulators develop a process for creating a uniform framework for state-based regulation. (July 27, 2015)
Medicaid Subcommittee comment letter to Centers for Medicare and Medicaid Services (CMS) on proposed rules about Medicaid and Children’s Health Insurance Program (CHIP) Programs; Medicaid managed care, CHIP delivered in managed care, Medicaid and CHIP comprehensive quality strategies, and revisions related to third party liability. (July 27, 2015)
Individual Disability Tables Work Group comments on the “The Individual Disability Valuation Standard Report” of the Joint American Academy of Actuaries/Society of Actuaries Individual Disability Tables Work Group. (July 22, 2015)
The Financial Reporting Committee, Pension Accounting Committee, Casualty Committee on Property and Liability Financial Reporting, Health Financial Reporting and Solvency Committee, and Life Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) “The Auditor's Use of the Work of Specialists” consultation paper. (July 15, 2015)
Health Solvency Work Group comment letter to the NAIC's Investment Risk-Based Capital Working Group on the evaluation of asset risk factors for the health risk-based capital formula. (May 20, 2015)
Risk Sharing Work Group letter to CCIIO on the methodology proposed to evaluate the sufficiency of EDGE server data. (May 8, 2015)