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 to HHS in response to proposed regulations on rate increase disclosure and review. (February 22, 2011)
Medical Loss Ratio Regulation Work Group letter to HHS in response to an interim final rule on the medical loss ratio (MLR) provisions in the Affordable Care Act. (January 31, 2011)
Premium Review Work Group comment letter on the NAIC Health Insurance and Managed Care (B) Committee's exposure draft of a rate filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS. (November 5, 2010)
Medical Loss Ratio Regulation Work Group letter to HHS addressing three components of the NAIC's proposed regulation on medical loss ratios: credibility adjustments, exclusion of federal taxes from the denominator, and the use of three months' runout. (November 5, 2010)
Premium Review Work Group letter to HHS providing an evaluation of several potential methods for defining or measuring unreasonable rate increases. (October 29, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC B Committee regarding the October 4 exposure draft of the proposed MLR rebate regulation. (October 8, 2010)
Exchanges Work Group letter to HHS in response to its request for comments on the exchange-related provisions in ACA. (October 4, 2010)
Risk Sharing Work Group letter to HHS regarding the ACA reinsurance provision that references the Academy. The letter includes initial input on potential approaches for identifying high-risk individuals and determining reinsurance payments. (September 22, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on first-dollar coverage of preventive services. (September 17, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on ACA provisions that eliminate lifetime limits, restrict annual limits, eliminate preexisting condition exclusions, and prohibit rescissions. (August 27, 2010)
Medical Loss Ratio Regulation Work Group letter to HHS with input on credibility issues for the purpose of calculating rebates under the new MLR requirements. (August 20, 2010)
Grandfathering Provisions Work Group letter to HHS in response to an interim final rule on the ACA provision related to the status of health insurance coverage as a grandfathered plan. (August 16, 2010)
Health Practice Council brief providing definitions for commonly used terms associated with health care reform implemenation. (August 1, 2010)
Premium Review Work Group letter regarding Massachusetts Senate Bill 2447, which includes a provision that would limit rate increases to medical CPI. (July 27, 2010)
Premium Review Work Group comment letter on the NAIC's exposure draft of a rate-filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS. (July 14, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on the PPACA provision that extends dependent coverage to age 26. (July 12, 2010)
Steven Schoonveld presentation before the July 11 National Conference of Insurance Legislators (NCOIL) Summer Meeting. The presentation focuses on educating lawmakers about the CLASS Act (the new voluntary, long-term care services program). (July 11, 2010)
Senior Health Fellow Cori Uccello presentation before a June 15 American Enterprise Institute event, offering an actuarial perspective on health care reform implementation. (June 15, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Accident and Health Working Group offering input on the potential inclusion of a change in contract reserves in the numerator of the MLR rebate calculation. (June 7, 2010)
Joint Committee on Retiree Health letter to the Department of Health and Human Services in response to an interim final rule on the PPACA provision that creates a temporary reinsurance program for early retirees. (June 3, 2010)