Health Comments and Letters

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)
Cancer Claims Cost Tables Work Group letter to the NAIC's Health Actuarial Task Force on it's valuation table progress.  (February 1, 2013)
HPC letter to President Obama and congressional leaders urging them to appoint an actuary to the new Commission on Long-Term Care that was enacted as part of the American Taxpayer Relief Act of 2012. (January 10, 2013)
Health Care Receivables Factors Work Group letter to the NAIC's Health Risk-Based Capital Working Group providing recommendations for receivables factors for the current RBC formula.  (January 8, 2013)
Health Care Receivables Factors Work Group letter to the NAIC on a revised proposal providing recommendations for receivables factors for the current RBC formula.  (January 7, 2013)
Risk Sharing Work Group comments to CMS on proposed rule, Benefit and Payment Parameters for 2014, addressing payment methodologies and data collection for risk adjustment, reinsurance, and risk corridor mechanisms in the ACA. (December 31, 2012)
MLR Work Group comments to CMS on the proposed rule, Benefit and Payment Parameters for 2014, addressing proposed changes to the final rule on MLR. (December 31, 2012)
Individual and Small Group Market Task Force and Premium Review Work Group comments to CMS on a proposed rule regarding health insurance market reforms, which included modifications to the final rule on rate review and disclosure requirements. (December 21, 2012)
Individual and Small Group Market Task Force comments to CMS on the EHB components of the proposed rule, Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation. (December 21, 2012)
Actuarial Value Subgroup comment letter on plan data collection requirements, specificially asking for clarification on whether any AV-related data collection elements will be consistent with those data elements in the AV calculator. (December 20, 2012)
Actuarial Value Subgroup comment letter on the proposed rule establishing standards for actuarial value determinations under the Affordable Care Act (December 18, 2012)
Casualty, Life, Health, Professionalism, and Financial Reporting Council comments to the NAIC's Corporate Governance Working Group on its Proposed Responses to a Comparative Analysis of Existing U.S. Corporate Governance Requirements. (September 28, 2012)