Health Reform & ACA Implementation

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

Premium Review Work Group comments on the recently released final Unified Rate Review Template (URRT) and Instructions. (March 13, 2019)
Proposals to expand access to public health insurance plans are being put forward as a way to supplement efforts to strengthen insurance markets under the Affordable Care Act (ACA) or to replace the ACA marketplaces and/or other health insurance programs altogether. Goals of these proposals vary and include increasing access to affordable coverage, exerting downward pressure on provider prices, increasing plan availability, and reducing the number of uninsured. This issue paper from the American Academy of Actuaries Health Practice Council briefly outlines four approaches aiming to achieve such goals and highlights the key design elements that would need to be specified for an approach to be fully evaluated and implemented. (March 4, 2019)
Individual and Small Group Markets Committee and Risk Sharing Subcommittee comments on the proposed rule for the 2020 notice of benefit and payment parameters (NBPP). (February 19, 2019)
Committee comments on the Oct. 22, 2018 guidance from the Department of the Treasury and the Department of Health and Human Services on State Relief and Empowerment Waivers under Section 1332 of the Affordable Care Act (ACA), focusing on three areas: evaluation of coverage comprehensiveness and affordability, evaluation of coverage, and waiver funding. (December 18, 2018)
Committees comment on the proposed rule regarding Health Reimbursement Arrangements (HRAs), that would create two new types of HRAs—Integrated HRAs and Excepted Benefit HRAs—which would allow employers to provide HRAs that could be used to pay for individual plan premiums and out-of-pocket health costs.  (December 13, 2018)
Committee and Subcommittee comments on the Centers for Medicare and Medicaid Services’ (CMS) and Department of Health and Human Services’ (HHS) Aug. 10 proposed rule regarding the adoption of methodology for the HHS-operated permanent risk adjustment program. (September 5, 2018)
Individual and Small Group Markets Committee issue brief providing insights on the potential and challenges of using auto-enrollment in the individual health insurance market. (September 4, 2018)
Presentation at the 2018 SOA Health Meeting examining rules surrounding association health plans, short-term limited duration insurance plans, and health reimbursement arrangements from the Trump Administration. (June 27, 2018)
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 2019. (June 13, 2018)
Committee comments on a proposed rule that would lengthen the maximum period of short-term, limited-duration (STLD) insurance through amending the definition of STLD. (April 6, 2018)
Committee comments on the definition of ‘‘Employer’’ under section 3(5) of ERISA—Association Health Plans. (March 5, 2018)
Health Practice Council comments to the Idaho Department of Insurance on allowing health insurers to offer state-based plans that are not compliant with the Affordable Care Act in Idaho. (March 2, 2018)
High-Performance Network Work Group issue paper on addressing the growth in health care spending through high-performance networks, which generally focus on delivering high-quality care that also is efficient care. These networks generally result in lower total costs for health programs. (February 26, 2018)
Committee comments to Office of Regulations and Interpretations within the Employee Benefits Security Administration in response to the Department of Labor's proposed rule on the definition of employer—small business health plans. (February 9, 2018)
Committee comments to Office of the Assistant Secretary for Planning and Evaluation in response to the Department of Health and Human Services’ request for information on promoting healthcare choice and competition. (January 25, 2018)
Health Practice Council comments to the U.S. House and Senate on the potential inclusion of individual mandate repeal in The Tax Cuts and Jobs Act. (December 12, 2017)
Risk Sharing Subcommittee and Premium Review Work Group letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule for the 2019 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, special enrollment periods, essential health benefits, minimum essential coverage, and medical loss ratios.
(November 27, 2017)
Health Practice Council comments to the U.S. Senate on a proposal in the Tax Cuts and Jobs Act to eliminate the ACA's individual mandate. (November 21, 2017)
Health Practice Council comments on the October 12 executive order. (November 7, 2017)
Health Practice Council comments on the Graham-Cassidy-Heller-Johnson Proposal (GCHJ), legislation that would make revisions to the individual health insurance market and approaches to federal Medicaid funding. (September 22, 2017)