Health Comments and Letters

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)
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)