Health Comments and Letters

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)
Health Practice Council letter to Sen. Thune and Rep. Boustany clarifying the nature and intent of recent Academy-hosted roundtables focused on addressing the accessibility and affordability of long-term care services. (August 15, 2012)
Joint Committee on Retiree Health comments on the ASB's exposure draft of ASOP 6, Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Plan Costs or Contributions. (July 14, 2012)
Stop-Loss Work Group comments to the Employee Benefits Security Administration regarding stop-loss insurance and the Affordable Care Act (ACA).  (July 2, 2012)
Medicaid Work Group comments to CMS on a proposed rule regarding payments for Medicaid primary care services. (June 12, 2012)
Actuarial Value Subgroup comments to the IRS on Notice 2012-31, Minimum Value of an Employer Sponsored Health Plan, addressing how to account for non-core benefits and non-standard plan features as well as other considerations related to the treatment of health savings account (HSA) contributions. (June 11, 2012)
Joint Committee on Retiree Health comments on the ASB's exposure draft for ASOP 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions, requesting clarification on the implications for retiree group benefits. (May 31, 2012)
Joint Committee on Retiree Health comments on the ASB's exposure draft for ASOP 27, Selection of Economic Assumptions for Measuring Pension Obligations, regarding the implications for retiree group benefits. (May 31, 2012)
Actuarial Value Subgroup letter to CCIIO offering comments on the Actuarial Value and Cost-Sharing Reduction bulletin, specifically addressing the proposed actuarial value calculator. This letter supplements comments submitted April 2 on the cost-sharing inputs for the calculator. (May 16, 2012)
Health Practice Financial Reporting Committee comments to the ASB on revisions to ASOPs 22 and 28. (May 15, 2012)
Medical Loss Ratio Subgroup letter to CMS offering comments on the revised annual reporting form, specifically on the definition of premiums, contract reserves, and the definition of pre-tax underwriting gain/(loss). (May 2, 2012)