Health Comments and Letters

Rate Review Practice Note Work Group letter to the Center for Consumer Information and Insurance Oversight (CCIIO) highlighting several technical comments on the current versions of the Unified Rate Review Template and the actuarial memorandum instructions. (December 4, 2013)
Health Practice Council letter to members of Congress on potential consequences of proposals that would modify ACA provisions regarding plan cancellations in the individual and small group health insurance markets.
(November 14, 2013)
State Long-Term Care Task Force comment letter to the NAIC's Long-Term Care Valuation Subgroup regarding proposed changes to the NAIC's Health Insurance Reserves Model Regulation. (November 6, 2013)
Health Practice Council letter to members of Congress on potential adverse consequences of delaying the Affordable Care Act's (ACA) individual mandate and/or extending its open enrollment period. (November 5, 2013)
Pension Committee, Joint Committee on Retiree Health, and Pension Finance Task Force letter to the Actuarial Standards Board (ASB) on coordinating Actuarial Standards of Practice (ASOPs) involving retirement benefits. (October 29, 2013)
Health Solvency Work Group response letter to questions raised by the NAIC's Health RBC Working Group regarding the HSWG's model that examines administrative expenses within the context of business concentration risk. (October 18, 2013)
MLR Work Group comments to CMS that reiterate previous comments on the proposed rule implementing medical loss ratio (MLR) requirements for Medicare Advantage (MA) and Medicare prescription drug (Part D) programs. (September 6, 2013)
Joint Committee on Retiree Health comments to the Actuarial Standards Board on revisions to a second exposure draft of ASOP No. 6, Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Program Periodic Costs or Prefunding Contributions. (August 30, 2013)
Health and Pension Practice Council letter to the Actuarial Standards Board on coordinating Actuarial Standards of Practice (ASOP) affecting pension and retiree group benefits. (August 30, 2013)
The Solvency Committee submitted comments to the NAIC on its revised version of a draft white paper on the Solvency Modernization Initiative and insurance regulation. (June 6, 2013)
Risk Sharing Work Group comments to HHS on the interim final rule implementing amendments to the Notice of Benefit and Payment Parameters final rule. (April 30, 2013)
Comments to CMS on the proposed rule implementing MLR requirements for Medicare Advantage (MA) and Medicare prescription drug (Part D) programs. (April 25, 2013)
Senior Health Fellow Cori Uccello's suggested language on actuarial value to the NAIC Consumer Information SUbgroup for inclusion in a "frequently asked questions" document. (April 1, 2013)
Medical Loss Ratio Work Group's comments to HHS on a proposed rule that requires issuers to offer a new type of individual health insurance policy covering contraceptive benefits. The comments focus only on the effect of the proposed rule on the MLR calculation. (March 28, 2013)
Casualty, Health, Life, and Professionalism Council comments to the NAIC’s Joint Qualified Actuary (A/B/C) Subgroup in response to its request for comments to a list of nine questions in anticipation of the Subgroup’s meeting at the NAIC Spring National Meeting on April 5, 2013. (March 27, 2013)
Long-Term Care Terminations Work Group letter to the NAIC regarding the formation of the work group that is charged with gathering data on terminations in long-term care insurance, and outlines its proposed tasks and timelines.  (March 15, 2013)
Rate Review Practice Note Work Group letter to CCIIO recommending several modifications to the unified rate review template and instructions associated with the final rules implementing the rate review and disclosure provisions in the ACA. (March 7, 2013)
Academy's letter to President Obama and top administration officials urging them to require Academy membership as a qualification for any candidate to the chief actuary position at the Centers for Medicare & Medicaid Services. (February 19, 2013)
Councils' letter to NAIC's Joint Qualified Actuary (A/B/C) Subgroup on the subgroup's two new charges related to defining a "qualified actuary" and recommending a process to address "unprofessional" actuarial work. (February 11, 2013)
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, 2013)