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 letter to HHS in response to the proposed rule on benefit and payment parameters for 2015, specifically addressing composite rating, proposed changes to the actuarial value calculator and methodology, and the three risk-sharing mechanisms. (December 20, 2013)
Health Practice Council fact sheet providing and overview of the three risk-sharing mechanisms included in the Affordable Care Act (ACA) - the permanent risk-adjustment program, temporary risk corridors, and the transitional reinsurance program. (December 4, 2013)
Rate Review Practice Note Work Group letter to the Center for Consumer Information and Insurance Oversight (CCIIO) highlighting several technical comments on the current versions of the Unified Rate Review Template and the actuarial memorandum instructions. (December 4, 2013)
Presentation to the National Conference of Insurance Legislators about new models of care delivery. (November 24, 2013)
Presentation to the National Conference of Insurance Legislators about the Affordable Care Act's effect on premiums. (November 21, 2013)
Health Practice Council letter to members of Congress on potential consequences of proposals that would modify ACA provisions regarding plan cancellations in the individual and small group health insurance markets.
(November 14, 2013)
Health Practice Council letter to members of Congress on potential adverse consequences of delaying the Affordable Care Act's (ACA) individual mandate and/or extending its open enrollment period. (November 5, 2013)
Webinar slides for the Sept. 20, 2013 webinar, "Minimum Value and Actuarial Value Determinations Under the Affordable Care Act"
(September 20, 2013)
MLR Work Group comments to CMS that reiterate previous comments on the proposed rule implementing medical loss ratio (MLR) requirements for Medicare Advantage (MA) and Medicare prescription drug (Part D) programs. (September 6, 2013)
Exposure draft of a new practice note related to determinations of minimum value and actuarial value under the Affordable Care Act (ACA). Comments on the exposure draft should be submitted by September 30. (August 12, 2013)
Health Practice Financial Reporting Committee white paper providing an overview of provisions in the Affordable Care Act - the premium-stabilization programs, new taxes and fees, advanced payments, and existing actuarial liabilities - that may create a certain amount of volatility on future financial statements. (June 25, 2013)
Academy Senior Health Fellow Cori Uccello's written testimony to the House Energy and Commerce Subcommittee on Oversight and Investigations for a hearing on the impact of the Affordable Care Act on premiums. Responses from Uccello to follow-up questions asked during and after the hearing can be found here. (May 20, 2013)
Issue brief by Senior Health Fellow Cori Uccello provides an overview of the basic concepts underlying premium calculations, and highlights and examines several Affordable Care Act-related provisions that could affect premiums. (May 9, 2013)
Risk Sharing Work Group comments to HHS on the interim final rule implementing amendments to the Notice of Benefit and Payment Parameters final rule. (April 30, 2013)
Exposure draft of an addendum to the October 2012 practice note, Actuarial Practices Relating to Preparing, Reviewing, and Commenting on Rate Filings Prepared in Accordance with the Affordable Care Act. Comments on the addendum, which highlights changes to the rate review and disclosure requirements since the initial practice note was finalized, are due by June 3. (April 26, 2013)
Comments to CMS on the proposed rule implementing MLR requirements for Medicare Advantage (MA) and Medicare prescription drug (Part D) programs. (April 25, 2013)
Senior Health Fellow Cori Uccello's suggested language on actuarial value to the NAIC Consumer Information SUbgroup for inclusion in a "frequently asked questions" document. (April 1, 2013)
Medical Loss Ratio Work Group's comments to HHS on a proposed rule that requires issuers to offer a new type of individual health insurance policy covering contraceptive benefits. The comments focus only on the effect of the proposed rule on the MLR calculation. (March 28, 2013)
Rate Review Practice Note Work Group letter to CCIIO recommending several modifications to the unified rate review template and instructions associated with the final rules implementing the rate review and disclosure provisions in the ACA. (March 7, 2013)
Health Solvency Work Group letter to the NAIC's Health Risk-Based Capital Working Group on the work group's analysis of Affordable Care Act-related possible risks to the health risk-based capital formula. (February 8, 2013)