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 With the enactment of the Patient Protection and Affordable Care Act (PPACA) and the Health Care and Education Reconciliation Act, which made a number of adjustments to PPACA, attention now shifts to the implementation phase of health care reform. The Academy's Health Practice Council has established a number of work groups charged with providing input on implementation of a variety of provisions in the new law. Actuaries bring a unique perspective that is crucial to the development of workable health care reform regulation. On this page, you will find links to HPC comment letters related to the various provisions included in PPACA, as well as other resources related to the new law and its implementation. Please bookmark this page and check back with us frequently. As implementation proceeds, we'll be updating and adding information regularly. The Academy's Critical Issues in Health Reform series and other documents related to the health care reform dialogue can still be found on the Health Reform Now page.
Risk Adjustment, Reinsurance and Risk Corridors Risk Adjustment, Reinsurance and Risk CorridorsRisk Adjustment issue brief releasedThe Academy Health Practice Council released a new issue brief, Risk Assessment and Risk Adjustment. The brief provides an overview of risk adjustment and outlines general considerations for implementing a risk adjustment mechanism under PPACA.
Medical Loss Ratio Reporting and RebatesLetter to HHS on MLR credibilityThe Academy provides input to HHS on credibility issues for the purpose of calculating rebates under the new MLR requirements. Letter to NAIC on Contract ReservesThe Academy writes a letter to the chair of the NAICs 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. Letter to the NAIC on Supplemental Health Care Exhibit exposure draftThe Academy writes a letter to the chair of the NAIC's Health Care Reform Solvency Impact Subgroup on an exposure draft of a new proposed financial reporting exhibit the Supplemental Health Care Exhibit. Letter to HHS regarding MLR provisionsThe Academy writes a letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that requires medical loss ratio reporting and rebates. Letter to the NAIC regarding statistical credibilityThe Academy writes a letter to the chair of the NAIC's Accident and Health Working Group responding to his request for input on defining an appropriate way to maintain statistical validity within the rebate process. The Academy sent a subsequent letter to respond to a request from the NAIC for more information on statistical credibility. Letter to the NAIC regarding MLR considerations and potential disruption in the individual marketThe Academy writes a second letter to the chairs of the NAIC's Health Care Reform Solvency Impact Subgroup and the Accident and Health Working Group regarding the medical loss ratio provisions and the potential for individual market disruption under the Patient Protection and Affordability Act. Letter to the NAIC regarding medical loss ratio provisions in health reform lawThe Academy writes a letter to the Chairs of the NAIC's Health Care Reform Solvency Impact Subgroup and the Accident and Health Working Group regarding considerations related to the Patient Protection and Affordability Act Medical Loss Ratio Provisions (2718).
Premium ReviewLetter to Mass. legislature on SB 2447The Academy writes a letter regarding Massachusetts Senate Bill 2447, which includes a provision that would limit rate increases to medical CPI. Letter to the NAIC on draft rate-filing disclosure formThe Academy writes a 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. Letter to HHS regarding rate reviewThe Academy writes a letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that establishes a review process for unreasonable rate increases. Letter to the NAIC regarding premium reviewThe Academy writes a letter to the chairs of the NAIC's Health Care Reform Solvency Impact Subgroup, the Accident and Health Working Group, and the Rate Review Subgroup regarding the Patient Protection and Affordability Act (PPACA) provision that establishes a review process for unreasonable rate increases.
Early Retiree Reinsurance ProgramLetter to HHS on Early Retiree ReinsuranceThe Academy writes a 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.
Near-term Benefit and Eligibility ChangesLetter to HHS on Annual/Lifetime Limits and Pre-ExThe Academy writes a 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. Letter to HHS on dependent coverageThe Academy writes a letter to HHS in response to an interim final rule on the PPACA provision that extends dependent coverage to age 26.
Grandfathering ProvisionsLetter to HHS on grandfathered coverageThe Academy writes a 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.
OtherHealth Reform GlossaryHealth Reform Implementation: Understanding the Terminology Presentation to NCOIL on the CLASS ActSteven Schoonveld presents during the July 11 National Conference of Insurance Legislators (NCOIL) Summer Meeting. His presentation focused on educating lawmakers about the CLASS Act (the new voluntary, long-term care services program). Presentation on Health Reform ImplementationAcademy Senior Health Fellow Cori Uccello presents during a June 15 American Enterprise Institute event, offering an actuarial perspective on health care reform implementation.
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