With the passage of health care reform, the Academy's Health Reform Now campaign has given way to the regulatory implementation process. The Health Practice Council has launched a new webpage—Actuarial Compass: Navigating Health Reform Implementation—as a means for tracking developments, including Academy Health Practice Council work.

As health care reform now focuses on the considerable details of regulations and implementation, Health Check will cease regular publication as an Academy-wide newsletter and instead will be distributed bi-weekly via e-mail only to health actuaries. All members can still access HealthCheck at http://www.actuary.org/healthcheck.asp. Health Practice Council groups will continue their hard work to help steer the regulatory and implementation processes in the months and years ahead. All Academy members can continue to stay updated on the Health Practice Council's work by visiting the new implementation webpage and by reading news from the council—and that of all Academy practice councils—in Actuarial Update.

Academy Activities

The Academy's Benefits and Eligibility Work Group submitted a comment letter to the Department of Health and Human Services (HHS) on the interim final rule related to the extension of dependent coverage to age 26. The work group commented on three primary issues: premium surcharges due to age, limitations on coverage due to dependents' eligibility for employer-sponsored insurance, and the definition of "dependent." The work group also expressed concern that the financial impact of the issues addressed in the letter may not have been reflected in the economic impact section of the interim final rule.

The Academy's Premium Review Work Group sent a comment letter to the National Association of Insurance Commissioners regarding its exposure draft of a rate filing disclosure form, which is intended to facilitate the reporting of unreasonable rate increases to HHS. The letter outlines a number of general comments, as well as comments specific to each section of the draft form.

Legislative and Regulatory Updates

The departments of Health and Human Services (HHS), Labor, and the Treasury on July 17 issued interim final rules that would implement the rules for group health plans and health insurance coverage in the group and individual markets under the preventive health services provisions of the Patient Protection and Affordable Care Act (PPACA) (P.L. 111-148). These regulations will require private health plans to cover all preventive services given an "A" or "B" recommendation by the U.S. Preventive Services Task Force, as well as preventive services recommended by the Advisory Committee on Immunization Practices. The interim final regulations will apply to plans on or after Sept. 23. Comments are due by Sept. 17.

The departments of the Treasury, HHS and Labor issued interim final rules on July 22 for group health plans and health insurance issuers relating to internal claims and appeals, and external review processes under PPACA. Effective Sept. 23, the interim final rules will guarantee consumers the right to appeal denials directly to their insurers and, if necessary, to external review boards. The rules will not apply to grandfathered plans. Comments are due by Sept. 23.

Sen. Jay Rockefeller (D-W.Va.) sent a letter on July 20 to the NAIC encouraging state insurance commissioners to reject insurers' positions on several controversial issues while they work on the final recommendations for implementing the PPACA's medical loss ratio provision. The medical loss ratio provision requires insurers to spend 85 percent of large group health insurance premium revenue and 80 percent of individual and small group health premium revenue on health claims and quality improvement efforts.

In the News

The Academy's Critical Issues in Health Reform paper on minimum loss ratios was cited in an article published on July 21 by The New England Journal of Medicine. The actuaries wrote that it could be difficult for some small-group and individual market insurers to satisfy the new medical loss ratio requirements. These insurers could exit the market resulting in significant disruption.

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