Health Reform & ACA Implementation

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

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)
Risk Sharing Work Group comments to CMS on proposed rule, Benefit and Payment Parameters for 2014, addressing payment methodologies and data collection for risk adjustment, reinsurance, and risk corridor mechanisms in the ACA. (December 31, 2012)
MLR Work Group comments to CMS on the proposed rule, Benefit and Payment Parameters for 2014, addressing proposed changes to the final rule on MLR. (December 31, 2012)
Individual and Small Group Market Task Force and Premium Review Work Group comments to CMS on a proposed rule regarding health insurance market reforms, which included modifications to the final rule on rate review and disclosure requirements. (December 21, 2012)
Individual and Small Group Market Task Force comments to CMS on the EHB components of the proposed rule, Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation. (December 21, 2012)
Actuarial Value Subgroup comment letter on plan data collection requirements, specificially asking for clarification on whether any AV-related data collection elements will be consistent with those data elements in the AV calculator. (December 20, 2012)
Update of a June 2011 fact sheet by the Health Care Quality Work Group providing an overview of the Medicare Shared Savings Program and the Pioneer ACO program. (December 19, 2012)
Update of a June 2011 issue brief by the Health Care Quality Work Group highlighting a number of actuarial issues that should be considered when designing and implementing accountable care organizations (December 19, 2012)
Actuarial Value Subgroup comment letter on the proposed rule establishing standards for actuarial value determinations under the Affordable Care Act (December 18, 2012)
Guide to help voters understand what premium support is and the potential implications of shifting Medicare to a premium support program. (October 9, 2012)
Practice note by the Rate Review Practice Note Work Group on the preparation, review, and disclosure of rate filings under the Affordable Care Act. (October 9, 2012)
Decision brief highlighting some of the issues that federal and state policymakers and regulators should consider as they are making their Medicaid expansion decisions. (September 10, 2012)
Health Practice Council webinar slides addressing the Supreme Court decision on the individual mandate and next steps in state and federal implementation of the Affordable Care Act (ACA). (July 11, 2012)
Stop-Loss Work Group comments to the Employee Benefits Security Administration regarding stop-loss insurance and the Affordable Care Act (ACA).  (July 2, 2012)