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Health Reform

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.

 

Actuarial Value
Essential Health Benefits
Risk Adjustment, Reinsurance and Risk Corridors
Medical Loss Ratio Reporting and Rebates
Premium Review
Consumer Operated and Oriented Plan Programs (CO-OPs)
Early Retiree Reinsurance Program
Exchanges
Near-term Benefit and Eligibility Changes
Grandfathering Provisions
Accountable Care Organizations (ACOs)
Other
Medicare




Newly Released Documents

Letter to HHS on research brief addressing actuarial value

The Health Practice Council sent a letter to the Assistant Secretary for Planning and Evaluation (ASPE) at HHS providing comments on a recently released research brief, Actuarial Value and Employer-Sponsored Insurance. (01/31/12)

Letter to HHS on Essential Health Benefits Bulletin

The Individual and Small Group Market Task Force provided comments to HHS on its December 2011 bulletin addressing essential health benefits. (01/31/12)

Letter to Mass. Senate on amendment to H.3535

The Premium Review Work Group sent a letter to the Mass. Senate regarding an amendment to the state budget that would require the disapproval of any health insurance rates to be “supported by sound actuarial assumptions and methods.” (11/1/11)

Comments to CMS on risk-sharing mechanisms proposed rule

The Risk Sharing Work Group submitted comments to CMS in response to the proposed rule implementing risk adjustment, reinsurance, and risk corridors under the ACA. (10/28/11)

Comments to CMS on Exchanges proposed rule

The Academy submitted comments to CMS in response to proposed regulations establishing health insurance exchanges and qualified health plans under the ACA. (10/06/11)

Letter on NAIC on MedSupp white paper

The Academy recently sent a letter to the NAIC Medigap PPACA Subgroup offering comments on the subgroup’s new discussion paper, Medicare Supplement Insurance First Dollar Coverage and Cost-Shares. (10/04/11)

Letter on Medicare to Joint Select Committee on Deficit Reduction

The Academy recently sent a comment letter to the members of the new Joint Select Committee on Deficit Reduction urging action to improve the long-term solvency and sustainability of the Medicare program. (8/31/11)

Actuarial Value issue brief released

The Academy released a new issue brief, Actuarial Value under the Affordable Care Act. The brief offers an overview of the concept of actuarial value and provides insight into the calculation of actuarial value under ACA. (07/21/11)

Written Testimony on 2011 Medicare Trustees Report

The Academy submits written testimony to the House Ways and Means Subcommittee on Health regarding a hearing on the 2011 Medicare Trustees Report (07/05/11)

Letter to CMS on Rate Review and Disclosure Forms

The Academy submits comments to CMS in response to the revised preliminary justification and consumer disclosure forms for purposes of rate review disclosure and reporting requirements (06/28/11)

ACO issue brief released

The Academy released a new issue brief, An Actuarial Perspective on Accountable Care Organizations. The brief provides an actuarial overview of ACOs and outlines a number of issues that stakeholders should evaluate as ACOs are implemented. (06/16/11)

Risk-Sharing under ACA issue brief released

The Academy released a new issue brief, Risk Adjustment and Other Risk-Sharing Provisions in the Affordable Care Act. The brief provides an overview of the various risk-sharing mechanisms in ACA and the risks each mechanism can mitigate. (06/09/11)

Comments to CMS on ACO proposed regulation

The Academy submits comments to CMS in response to proposed regulations on accountable care organizations and the Medicare Shared Savings Program under ACA. (06/06/11)

Issue brief on the 2011 Medicare Trustees Report

The Academy's Medicare Steering Committee released a new issue brief that highlights the 2011 Medicare Trustees Report and outlines the public policy options to address Social Security's long-term financial soundness. (05/25/11)

Issue brief on Proposals to Improve Medicare's Financial Condition

The Medicare Steering Committee released a new issue brief that summarizes the key cost, access, and quality issues associated with some of the Medicare-related provisions in the various debt and deficit reduction proposals. (05/11/11)

Letter to CMS on Rate Review and Disclosure Forms

The Academy submits comments to CMS in response to a notice on rate increase disclosure and review reporting requirements. (5/2/11)

Letter to NAIC on Adverse Selection White Paper

The Academy submits comments to the NAIC Exchanges (B) Subgroup regarding its white paper on adverse selection. (04/05/11)

Letter to HHS on CO-OPs

The Academy writes a letter to HHS in response to its request for comments on the consumer operated and oriented plan programs. (3/4/11)

Comments to HHS on rate review proposed regulations

The Academy submits comments to HHS in response to proposed regulations on rate increase disclosure and review. (2/22/11)

Comments to HHS re: MLR interim final rule

The Academy writes a letter to HHS in response to an interim final rule on the medical loss ratio provisions in ACA. (1/31/11)

Comments to NAIC re: rate filing disclosure form

The Academy writes a comment letter on the NAIC B Committee's exposure draft of a rate filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS.

 




Actuarial Value

Letter to HHS on research brief addressing actuarial value

The Health Practice Council sent a letter to the Assistant Secretary for Planning and Evaluation (ASPE) at HHS providing comments on a recently released research brief, Actuarial Value and Employer-Sponsored Insurance. (01/31/12)

Actuarial Value issue brief released

The Academy released a new issue brief, Actuarial Value under the Affordable Care Act. The brief offers an overview of the concept of actuarial value and provides insight into the calculation of actuarial value under ACA. (07/21/11)

 




Essential Health Benefits

Letter to HHS on Essential Health Benefits Bulletin

The Individual and Small Group Market Task Force provided comments to HHS on its December 2011 bulletin addressing essential health benefits. (01/31/12)

 




Risk Adjustment, Reinsurance and Risk Corridors

Comments to CMS on risk-sharing mechanisms proposed rule

The Risk Sharing Work Group submitted comments to CMS in response to the proposed rule implementing risk adjustment, reinsurance, and risk corridors under the ACA. (10/28/11)

Risk-Sharing under ACA issue brief released

The Academy released a new issue brief, Risk Adjustment and Other Risk-Sharing Provisions in the Affordable Care Act. The brief provides an overview of the various risk-sharing mechanisms in ACA and the risks each mechanism can mitigate. (06/09/11)

Letter to HHS on Reinsurance Provision

The Academy writes a letter to HHS attached 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. (09/22/10)

Risk Adjustment issue brief released

The 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 Rebates

Comments to HHS re: MLR interim final rule

The Academy writes a letter to HHS in response to an interim final rule on the medical loss ratio provisions in ACA. (1/31/11)

Comments to HHS re: NAIC MLR proposed regulation

The Academy writes a 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.

Letter to NAIC on draft MLR rebate regulation

The Academy writes a letter to the chair of the NAIC B Committee regarding the October 4 exposure draft of the proposed MLR rebate regulation. (10/13/10)

Letter to HHS on MLR credibility

The Academy provides input to HHS on credibility issues for the purpose of calculating rebates under the new MLR requirements.

Letter to NAIC on Contract Reserves

The 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 draft

The 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 provisions

The 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 credibility

The 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 market

The 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 law

The 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 Review

Letter to Mass. Senate on amendment to H.3535

The Premium Review Work Group sent a letter to the Mass. Senate regarding an amendment to the state budget that would require the disapproval of any health insurance rates to be “supported by sound actuarial assumptions and methods.” (11/1/11)

Letter to CMS on Rate Review and Disclosure Forms

The Academy submits comments to CMS in response to the revised preliminary justification and consumer disclosure forms for purposes of rate review disclosure and reporting requirements (06/28/11)

Letter to CMS on Rate Review and Disclosure Forms

The Academy submits comments to CMS in response to a notice on rate increase disclosure and review reporting requirements. (5/2/11)

Comments to HHS on rate review proposed regulations

The Academy submits comments to HHS in response to proposed regulations on rate increase disclosure and review. (2/22/11)

Comments to NAIC re: rate filing disclosure form

The Academy writes a comment letter on the NAIC B Committee's exposure draft of a rate filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS.

Comments to HHS re: defining "unreasonable" rate increases

The Academy writes a letter to HHS providing an evaluation of several potential methods for defining or measuring "unreasonable" rate increases. (10/29/10)

Letter to Mass. legislature on SB 2447

The 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 form

The 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 review

The 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 review

The 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.

 




Consumer Operated and Oriented Plan Programs (CO-OPs)

Letter to HHS on CO-OPs

The Academy writes a letter to HHS in response to its request for comments on the consumer operated and oriented plan programs. (03/04/11)

 




Early Retiree Reinsurance Program

Letter to HHS on Early Retiree Reinsurance

The 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.

 




Exchanges

Comments to CMS on Exchanges proposed rule

The Academy submitted comments to CMS in response to proposed regulations establishing health insurance exchanges and qualified health plans under the ACA. (10/06/11)

Letter to HHS on Exchanges

The Academy writes a letter to HHS in response to its request for comments on the exchange-related provisions in ACA. (10/05/10)

 




Near-term Benefit and Eligibility Changes

Letter to HHS on Preventive Services

The Academy writes a letter to HHS in response to an interim final rule on first-dollar coverage of preventive services. (09/22/10)

Letter to HHS on Annual/Lifetime Limits and Pre-Ex

The 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 coverage

The 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 Provisions

Letter to HHS on grandfathered coverage

The 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.

 




Accountable Care Organizations (ACOs)

Fact sheet on Medicare Shared Savings Program and ACOs under the Affordable Care Act

The Academy released a new fact sheet that provides an overview of the Medicare Shared Savings Program and how ACOs are addressed in the Affordable Care Act. (06/16/11)

ACO issue brief released

The Academy released a new issue brief, An Actuarial Perspective on Accountable Care Organizations. The brief provides an actuarial overview of ACOs and outlines a number of issues that stakeholders should evaluate as ACOs are implemented. (06/16/11)

Comments to CMS on ACO proposed regulation

The Academy submits comments to CMS in response to proposed regulations on accountable care organizations and the Medicare Shared Savings Program under ACA. (06/06/11)

 




Other

Letter on NAIC on MedSupp white paper

The Academy recently sent a letter to the NAIC Medigap PPACA Subgroup offering comments on the subgroup’s new discussion paper, Medicare Supplement Insurance First Dollar Coverage and Cost-Shares. (10/04/11)

Letter to NAIC on Adverse Selection White Paper

The Academy submits comments to the NAIC Exchanges (B) Subgroup regarding its white paper on adverse selection. (04/05/11)

Health Reform Glossary

Health Reform Implementation: Understanding the Terminology
(August 2010)

Presentation to NCOIL on the CLASS Act

Steven 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 Implementation

Academy Senior Health Fellow Cori Uccello presents during a June 15 American Enterprise Institute event, offering an actuarial perspective on health care reform implementation.

 




Medicare

Letter on Medicare to Joint Select Committee on Deficit Reduction

The Academy recently sent a comment letter to the members of the new Joint Select Committee on Deficit Reduction urging action to improve the long-term solvency and sustainability of the Medicare program. (8/31/11)

Written Testimony on 2011 Medicare Trustees Report

The Academy submits written testimony to the House Ways and Means Subcommittee on Health regarding a hearing on the 2011 Medicare Trustees Report (07/05/11)

Issue brief on the 2011 Medicare Trustees Report

The Academy's Medicare Steering Committee released a new issue brief that highlights the 2011 Medicare Trustees Report and outlines the public policy options to address Social Security's long-term financial soundness. (05/25/11)

Issue brief on Proposals to Improve Medicare's Financial Condition

The Medicare Steering Committee released a new issue brief that summarizes the key cost, access, and quality issues associated with some of the Medicare-related provisions in the various debt and deficit reduction proposals. (05/11/11)

 



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