Health Comments and Letters

P/C Risk-Based Capital Committee response to the NAIC's request on risk-based capital issues. (October 1, 2010)
Deferred Tax Asset DTA Bridge Group request for an interim report to the NAIC Capital Adequacy Task Force showing the appropriate treatment of the Deferred Tax Asset (DTA) in the Risk-Based Capital formulas for Life, Property / Casualty (P&C), and Health. (September 30, 2010)
Risk Sharing Work Group letter to HHS regarding the ACA reinsurance provision that references the Academy. The letter includes initial input on potential approaches for identifying high-risk individuals and determining reinsurance payments. (September 22, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on first-dollar coverage of preventive services. (September 17, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on ACA provisions that eliminate lifetime limits, restrict annual limits, eliminate preexisting condition exclusions, and prohibit rescissions. (August 27, 2010)
Medical Loss Ratio Regulation Work Group letter to HHS with input on credibility issues for the purpose of calculating rebates under the new MLR requirements. (August 20, 2010)
Grandfathering Provisions Work Group letter to HHS in response to an interim final rule on the ACA provision related to the status of health insurance coverage as a grandfathered plan. (August 16, 2010)
Premium Review Work Group letter regarding Massachusetts Senate Bill 2447, which includes a provision that would limit rate increases to medical CPI. (July 27, 2010)
Premium Review Work Group comment letter on the NAIC's exposure draft of a rate-filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS. (July 14, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on the PPACA provision that extends dependent coverage to age 26. (July 12, 2010)
Health Solvency Work Group comment letter to the chair of the NAIC's Capital Adequacy Task Force regarding the evaluation of the current health risk-based capital covariance formula calculation for potential changes to the calculation or methodology. (June 11, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Accident and Health Working Group offering input on the potential inclusion of a change in contract reserves in the numerator of the MLR rebate calculation. (June 7, 2010)
Joint Committee on Retiree Health letter to the Department of Health and Human Services in response to an interim final rule on the PPACA provision that creates a temporary reinsurance program for early retirees. (June 3, 2010)
Medical Loss Ratio Regulation Work Group letter to the NAIC responding to a request for more information on defining statistical credibility within the MLR rebate process as provided in a previous letter. (May 20, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Health Care Reform Solvency Impact Subgroup on an exposure draft of a new proposed financial reporting exhibit the Supplemental Health Care Exhibit. (May 17, 2010)
Medical Loss Ratio Regulation Work Group letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that requires medical loss ratio reporting and rebates. (May 14, 2010)
Premium Review Work Group letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that establishes a review process for unreasonable rate increases. (May 14, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Accident and Health Working Group responding to his request for input on defining an appropriate way to maintain statistical validity within the rebate process. The Academy sent a subsequent letter to respond to a request from the NAIC for more information on statistical credibility. (May 12, 2010)
Premium Review Work Group letter to the chairs of the NAIC's Health Care Reform Solvency Impact Subgroup, the Accident and Health Working Group, and the Rate Review Subgroup regarding the Patient Protection and Affordability Act (PPACA) provision that establishes a review process for unreasonable rate increases. (May 8, 2010)
Medical Loss Ratio Regulation Work Group second letter to the chairs of the NAIC's Health Care Reform Solvency Impact Subgroup and the Accident and Health Working Group regarding the medical loss ratio provisions and the potential for individual market disruption under the Patient Protection and Affordability Act. (April 28, 2010)