Health Comments and Letters

Health Care Quality Work Group comments to CMS in response to proposed regulations on accountable care organizations and the Medicare Shared Savings Program under the Affordable Care Act. (June 6, 2011)
Premium Review Work Group comments to CMS in response to a notice on rate increase disclosure and review reporting requirements. (May 2, 2011)
Exchanges Work Group comments to the National Assocation of Insurance Commissioners (NAIC) Exchanges (B) Subgroup regarding its white paper on adverse selection and exchanges created through the Affordable Care Act. (April 5, 2011)
CO-OP Subgroup letter to HHS in response to its request for comments on the consumer operated and oriented plan programs (CO-OPs). (March 4, 2011)
Premium Review Work Group comments to HHS in response to proposed regulations on rate increase disclosure and review. (February 22, 2011)
Long-Term Care Practice Note Work Group letter to the NAIC regarding the formation of a new work group in charge of updating the Academy's 2003 practice note, Long-Term Care Insurance Compliance with the NAIC LTCI Model Regulation Relating to Rate Stability. The letter also outlines the proposed tasks and timeline for completion. (February 17, 2011)
Medicare Part D RBC Subgroup letter to the NAIC's Health RBC Working Group asking it to sponsor and administer a survey of carriers that write Medicare Part D business. The survey is designed to gather additional data that may support any needed changes to the formula. (February 9, 2011)
Life, Health, and Property/Casualty RBC committees joint report in response to the NAIC's request for assistance with the Solvency Modernization (SMI) project on the NAIC's Risk-Based Capital (RBC) formulas. The report discusses the intended/expected safety levels for RBC and identifies risks that are missing from the RBC formulas. (January 31, 2011)
Medical Loss Ratio Regulation Work Group letter to HHS in response to an interim final rule on the medical loss ratio (MLR) provisions in the Affordable Care Act. (January 31, 2011)
Academy report to the NAIC in response to its request for assistance with the Solvency Modernization project on the NAIC's Risk-Based Capital (RBC) formula. (January 31, 2011)
Health Practice Council letter to CMS in response to its request for comments on the Medicare Advantage risk adjustment data validation (RADV) payment error calculation methodology. (January 21, 2011)
Medicaid Work Group letter to CMS in response to CMS' request for assistance in revising the Medicaid rate setting checklist. (January 14, 2011)
Premium Review Work Group comment letter on the NAIC Health Insurance and Managed Care (B) Committee's exposure draft of a rate filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS. (November 5, 2010)
Medical Loss Ratio Regulation Work Group letter to HHS addressing three components of the NAIC's proposed regulation on medical loss ratios: credibility adjustments, exclusion of federal taxes from the denominator, and the use of three months' runout. (November 5, 2010)
Joint Committee on Retiree Health and the Pension Accounting Committee comments to the NAIC regarding the exposure draft of SSAP 92 (OPEBs) and proposed revisions to SSAP 89 (pensions). (October 30, 2010)
Health Practice Financial Reporting Committee comments to the Actuarial Standards Board regarding a proposed revision to ASOP 28. (October 30, 2010)
Premium Review Work Group letter to HHS providing an evaluation of several potential methods for defining or measuring unreasonable rate increases. (October 29, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC B Committee regarding the October 4 exposure draft of the proposed MLR rebate regulation. (October 8, 2010)
Exchanges Work Group letter to HHS in response to its request for comments on the exchange-related provisions in ACA. (October 4, 2010)
Joint Committee on Retiree Health and the Pension Accounting Committee joint comments to the NAIC regarding the exposure draft of SSAP 92 (OPEBs) and proposed revisions to SSAP 89 (pensions). (October 4, 2010)