Health Comments and Letters

Risk Sharing Work Group letter to CCIIO on the methodology proposed to evaluate the sufficiency of EDGE server data. (May 8, 2015)
Risk Sharing Work Group letter to CMS with comments on the 2014 medical loss ratio (MLR) annual reporting form. (March 31, 2015)
Health Practice Council comments urging HHS to consider implementing measures to counter the potential adverse consequences on health insurance premium rate filings in the event the Supreme Court rules for the petitioners in King v. Burwell. (February 24, 2015)
Rate Review Practice Note Work Group letter to CCIIO with suggested recommendations for modifications to the unified rate review template (URRT) and actuarial memorandum instructions to provide further clarification on a number of issues. (January 16, 2015)
Life Capital Adequacy Committee, Property and Casualty Risk-Based Capital Committee, and Health Solvency Work Group comments to the National Association of Insurance Commissioners (NAIC) on operational risk issues. (January 7, 2015)
Risk Sharing Work Group letter to the U.S. Department of Health and Human Services (HHS) in response to the proposed rule on benefit and payment parameters for 2016. (December 22, 2014)
Medicaid Work Group letter to the Centers for Medicare & Medicaid Services on the introduction of new Breakthrough Therapy Designation medications and their potential impact on Medicaid costs. (November 11, 2014)
The Joint Committee on Retiree Health letter to the Governmental Accounting Standards Board commenting on proposed statements of accounting and financial reporting by governmental employers for other postemployment benefits (OPEBs). (August 29, 2014)
Medicaid Work Group request to the Centers for Medicare and Medicaid Services for specific guidance on the Affordable Care Act's Health Insurance Providers fee and how it affects the Medicaid program. (July 7, 2014)
Tax Work Group comment letter to NAIC Health Actuarial Task Force on tax implications of 2013 Individual Disability Income Valuation Tables. (June 26, 2014)
Health Practice Financial Reporting Committee comments to the NAIC on new accounting proposals for the risk-sharing programs of the Affordable Care Act. (June 20, 2014)
Risk Sharing Work Group letter to CCIIO with comments on a proposed rule related to exchanges and market reforms for 2015, specifically addressing ACA risk-sharing mechanisms. (April 21, 2014)
Letter from Health Solvency Work Group to NAIC Health Risk-Based Capital Working Group regarding the effect of the 3Rs on risk-based capital. (March 11, 2014)
Academy comments to NAIC’s Joint Qualified Actuary (A/B/C) Subgroup on definitions of “qualified actuary” as prescribed by the NAIC.  (February 3, 2014)
Joint Committee on Retiree Health comments to the Actuarial Standards Board on revisions to ASOP No. 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations. (February 2, 2014)
Letter from Academy RBC work groups to the NAIC SMI RBC Subgroup regarding the NAIC’s Dec. 9 Operational Risk Proposal. (January 30, 2014)
The Rate Review Practice Note Work Group submitted comments to the Center for Consumer Information and Insurance Oversight (CCIIO) on a second draft of revisions to the Unified Rate Review Template (URRT) and actuarial memorandum instructions. (January 24, 2014)
In a Jan. 6 letter to the National Association of Insurance Commissioners’ (NAIC) Joint Qualified Actuary subgroup, American Academy of Actuaries President Tom Terry provides comments on a uniform definition of “qualified actuary” for life, health, and property/casualty appointed actuaries signing prescribed NAIC Statements of Actuarial Opinion. (January 6, 2014)
Rate Review Practice Note Work Group letter to the Center for Consumer Information and Insurance Oversight (CCIIO) with comments on a new proposed list of changes to the Unified Rate Review Template (URRT) for quarterly 2014 and annual 2015 filings. The letter also reiterates several other technical comments on the URRT and the actuarial memorandum instructions. (January 3, 2014)
Health Practice Council letter to HHS in response to the proposed rule on benefit and payment parameters for 2015, specifically addressing composite rating, proposed changes to the actuarial value calculator and methodology, and the three risk-sharing mechanisms. (December 20, 2013)