Health Comments and Letters

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)
Federal Long-Term Care (LTC) Task Force letter to NCOIL in response to a request for information on strategies to reduce costs related to LTC coverage. (April 27, 2012)
Health Practice Council and the Committee on Qualifications letter to all state insurance commissioners and chairs of each state house and senate insurance committee regarding the appropriate definition of "Qualified Actuary" as it relates to the Affordable Care Act's rate review provision. (April 20, 2012)
Health Practice Council comment letter to the Center for Consumer Information and Insurance Oversight (CCIIO) providing responses to questions raised during a meeting with representatives of CCIIO on the structure of a proposed actuarial value calculator (for purposes of the ACA). (April 2, 2012)
Health Practice Council comment letter to House leadership on legislation (HR 5) that would include a provision to repeal the Independent Payment Advisory Board, which was created under the ACA to provide recommendations to reduce growth in Medicare expenditures if spending exceeds a certain growth rate. (March 21, 2012)
Medical Loss Ratio (MLR) Work Group comments to CMS on the exposure draft of the MLR annual reporting form. (February 14, 2012)
Health Practice Council and Committee on Qualifications letter to the Arizona insurance director stressing its concern that their regulatory definition of “qualified actuary” for health premium rate actuarial certifications was inappropriate and suggested corrective language. (February 10, 2012)
Individual and Small Group Market Task Force comments to the HHS on the essential health benefits bulletin. (January 31, 2012)
Health Practice Council letter to the Assistant Secretary for Planning and Evaluation (ASPE) at HHS providing comments on a research brief, Actuarial Value and Employer-Sponsored Insurance. (January 31, 2012)
Pension Accounting Committee and Joint Committee on Retiree Health letter to the National Association of Insurance Commissioners (NAIC) on the exposure drafts of Statements of Statutory Accounting Principles (SSAP) No. 92 and No. 102. (December 9, 2011)
Premium Review Work Group letter to the Massachusetts Senate regarding an amendment to the state budget that would require the disapproval of any health insurance rates to be supported by "sound actuarial assumptions and methods." (November 30, 2011)
Health Practice Council and Committee on Qualifications letter to the Arizona insurance director pointing out that their regulatory definition of “qualified actuary” for health premium actuarial certifications was inappropriate and suggested corrective language. (November 18, 2011)
Cancer Claims Cost Tables Work Group letter to the NAIC’s Health Actuarial Task Force discussing the progress it has made over the past year and outlining its objectives for the coming year. (October 31, 2011)
Risk Sharing Work Group comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule implementing the risk-spreading mechanisms included in the Affordable Care Act (ACA) and related to reinsurance, risk corridors, and risk adjustment. (October 28, 2011)
Joint work group of the SOA Long-Term Section Council and the Academy’s Federal Long-Term Care Task Force letter to HHS Secretary Sebelius regarding the department’s extension of the Genetic Information Nondiscrimination Act (GINA) to long-term care insurance in proposed regulations. (October 13, 2011)
Exchanges Work Group comments to CMS in response to proposed regulations establishing health insurance exchanges and qualified health plans under the ACA.  (October 6, 2011)
Medicare Supplement Work Group letter to the NAIC Medigap PPACA Subgroup offering comments on the subgroup’s new discussion paper, Medicare Supplement Insurance First Dollar Coverage and Cost-Shares. (October 4, 2011)
Medicare Steering Committee comment letter to the members of the new Joint Select Committee on Deficit Reduction urging action to improve the long-term solvency and sustainability of the Medicare program. (August 31, 2011)
Medicare Supplement Work Group letter to the NAIC's Medicare Supplement Refund Formula Subgroup with a proposed charge to have the work group review the Medicare Supplement Refund Formula for potential changes that may need to be addressed. (August 24, 2011)
Premium Review Work Group comments to CMS in response to the revised preliminary justification and consumer disclosure forms for purposes of rate review disclosure and reporting requirements. (June 28, 2011)