Health Comments and Letters

Medicare Part D RBC Subgroup comment letter to NAIC's Health Risk Based Capital Working Group on a possible update of proposed risk factors previously developed by the Academy's Medicare Part D subgroup. (May 3, 2007)
Health Practice Financial Reporting Committee letter to Julia T. Philips, the Chair of the NAIC's Health Risk-Based Capital (RBC) Working Group, that comments on a proposal made by Blue Cross Blue Shield of Florida regarding the treatment in the NAIC RBC formulas of medical insurance products for which active life reserves are held. The letter provided initial thoughts on the matter and seeks further input from the NAIC in light of these thoughts. (May 3, 2007)
Health Practice Financial Reporting Committee comments to the NAIC on a proposal to include a trend test in the health RBC formula. (May 3, 2007)
Part D Lessons Learned Work Group comment letter on what has worked well and what has not in Medicare Part D. The letter also offers recommendations to improve the overall operation and administration of the Part D program, specifically including the bidding process, management of eligibility, and coordination with Medicaid and with the Social Security Administration. (March 21, 2007)
Health Practice Council comment letter to members of the House and Senate on the actuarial implications of restricting insurers' use of genetic information. (February 16, 2007)
Health Practice Council comments that urge CMS to reconsider the one-role-per-user rule for actuaries for Part D attestations and to investigate alternatives that would not prevent actuaries from fulfilling their actuarial obligations. (December 19, 2006)
Subgroup on Long-Term Care Experience Forms comments to the NAIC regarding American Council of Life Insurers (ACLI) Proposed Recommendation to Report Non-Exempt LTC accelerated-type products. (November 17, 2006)
Committee on Federal Health Issues letter to Citizens' Health Care Working Group on its interim recommendations for improving health care. (August 24, 2006)
Medicare Supplement Work Group comments to NAIC's Medigap Modernization Subgroup of the Senior Issues Task Force identifying potential transitional issues that will need to be addressed as part of Medicare Supplement modernization that the Subgroup has recently taken up. (August 17, 2006)
Joint Committee on Retiree Health letters to FASB expressing concern over proposed changes in financial accounting standards for pensions and OPEBs. (May 31, 2006)
Small-Group Market Task Force comment letter on S. 1955, the Health Insurance Marketplace Modernization and Affordability Act of 2006. (May 4, 2006)
Joint Committee on Retiree Health comments on the proposed GASB technical bulletin, Accounting and Financial Reporting by Employers and OPEB Plans for Payments from the Federal Government Pursuant to the Provisions of Medicare Part D. (April 17, 2006)
Subgroup on LTC Experience Forms letter that addresses several issues raised by the NAIC in response to the Academy's Long-Term Care Experience Subgroup's May 20, 2005 letter with proposed revisions to the LTC experience reporting instructions and forms. (August 18, 2005)
Federal Health Committee letter in response to HR 2355, the Health Care Choice Act of 2005, which contained language that would allow a non-actuary to offer statements of opinions on reserves. The letter recommended only a member of the Academy be permitted to provide such an opinion. (July 19, 2005)
Letter to the NAIC from the LTC Experience Forms Subgroup on proposed LTC loss experience exhibit forms (Forms 1, 2, and 3) along with the proposed instructions. This was updated in August 2005 in a subsequent letter to NAIC. (May 20, 2005)
Committee on Federal Health Issues comment letter on Coverage and Reimbursement of Genetic Tests and Services, a report of the Secretary’s Advisory Committee on Genetics, Health, and Society, and raises issues pertaining to genetic testing in general, health insurance markets, cost effectiveness data, and the Medicare and Medicaid programs. (May 5, 2005)
Letter offers the Academy as a resource on health care issues and shares some recent publications on key issues including Medicare and the uninsured. (March 4, 2005)
Academy comment letter recommending to Congress that individuals serving in the positions of SSA and CMS chief actuary be members in good standing of the American Academy of Actuaries. (March 3, 2005)
Actuarial Equivalence Work Group letter to CMS regarding actuarial equivalence issues related to prescription drug plans (PDPs), Medicare Advantage (MA) plans, Medicare supplement plans, and retiree health benefits. (October 4, 2004)
Medicare Steering Committee letter to CMS discusses issues related to the calculation of monthly savings — a step in determining beneficiary rebate amounts for MA plans — and payment adjustments based on the variation in costs among different areas including input prices, utilization, and practice patterns. (October 4, 2004)