Health Reform & ACA Implementation

Implementation of the Affordable Care Act, the health care reform law passed in 2010, and other health care reform issues.

Health Practice Council letters to both the U.S. House and Senate on potential adverse consequences of legislation to weaken the Affordable Care Act’s (ACA) individual mandate. (September 22, 2016)
Written testimony on the general factors underlying premium rate setting and the major components driving premium changes for 2017 under the Affordable Care Act to a U.S. House Ways and Means Committee hearing on rising health care premiums. (July 22, 2016)
Individual and Small Group Markets Committee issue brief providing an overview of the general factors underlying premium rate setting and highlighting the major components driving premium changes in 2017 under the Affordable Care Act (ACA). (May 9, 2016)
Risk Sharing Subcommittee letter to the Centers for Medicare & Medicaid Services (CMS) with comments on its recent discussion paper, HHS-Operated Risk Adjustment Methodology. The letter includes comments on partial year enrollment, use of pharmacy data, use of concurrent versus prospective model, high-risk enrollee pooling, recalibration of the model, and the transfer formula.  (April 22, 2016)
Subcommittee Issue Paper on ACA Risk Adjustment Program
Risk Sharing Subcommittee issue paper that reviews the first year of experience under the Affordable Care Act’s (ACA) risk adjustment program with focus on experience in the individual market. (April 12, 2016)
Risk Sharing Subcommittee presentation to the Health Actuarial Task Force (B) on its report on the risk adjustment program. (April 5, 2016)
Premium Review Work Group letter to CCIIO with comments on the 2017 unified rate review template (URRT). (March 30, 2016)
Risk Sharing Subcommittee letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule on benefit and payment parameters for 2017. (December 20, 2015)
Premium Review Work Group practice note on Actuarial Practices Relating to Preparing, Reviewing, and Commenting on Rate Filings Prepared in Accordance with the Affordable Care Act, providing information on general rate filing requirements and considerations related to the URRT adn actuarial memorandum. (December 3, 2015)
Active Benefits Subcommittee letter to the IRS regarding Notice 2015-52 on the excise tax for high-cost employer-sponsored health coverage under the Affordable Care Act (ACA). (October 1, 2015)
Premium Review Work Group letter to CCIIO with suggested changes to the unified rate review template (URRT) and rating methodology. (September 22, 2015)
Academy Senior Health Fellow Cori Uccello written testimony on potential implications of expanding small-group definition to companies with 51-100 employees to a U.S. House Energy & Commerce Subcommittee on Health hearing on affordable health care.  (September 9, 2015)
Individual and Small Group Markets Committee issue brief providing an overview of the factors underlying the general premium rate setting and highlighting the major drivers behind why 2016 premiums could differ from those in 2015 under the Affordable Care Act (ACA). (August 5, 2015)
Health Practice Council issue brief examining the approaches included in various proposals policymakers are considering in case the Supreme Court rules in King v. Burwell that federal premium subsidies are not available for individual market plans in states participating in the federally facilitated marketplace. (May 28, 2015)
Risk Sharing Work Group letter to CCIIO on the methodology proposed to evaluate the sufficiency of EDGE server data. (May 8, 2015)
Senior Health Fellow Cori Uccello written testimony to the U.S. House Ways and Means Subcommittee on Health hearing on alternatives to the individual and employer mandates under the Affordable Care Act (ACA). (April 27, 2015)
Risk Sharing Work Group letter to CMS with comments on the 2014 medical loss ratio (MLR) annual reporting form. (March 31, 2015)
Individual and Small Group Market Task Force issue brief examining how the rules applying to groups sized 51-100 will change with the Affordable Care Act's scheduled expansion of the definition of small employers to those with up to 100 employees and what that will mean for insurance offerings in the small group market. (March 2, 2015)
Health Practice Council comments urging HHS to consider implementing measures to counter the potential adverse consequences on health insurance premium rate filings in the event the Supreme Court rules for the petitioners in King v. Burwell. (February 24, 2015)
Rate Review Practice Note Work Group letter to CCIIO with suggested recommendations for modifications to the unified rate review template (URRT) and actuarial memorandum instructions to provide further clarification on a number of issues. (January 16, 2015)