Public Policy Comments and Letters

Letter to NAIC on Proposed Revisions to LTC Experience Reporting Instructions

Letter to the NAIC from the LTC Experience Forms Subgroup on proposed LTC loss experience exhibit forms (Forms 1, 2, and 3) along with the proposed instructions. This was updated in August 2005 in a subsequent letter to NAIC. (May 20, 2005)

Letter to IRS on Relative Value Regulations

Pension Committee letter to the Internal Revenue Service (IRS) suggesting refinements to the relative value regulations. (May 10, 2005)

Letter to IRS on Circular 230 and Application to Actuarial Work

Pension Committee letter to the Internal Revenue Service (IRS) about revisions to IRS Circular 230 and its application to actuarial work. (May 9, 2005)

Comments on HHS Draft on Genetic Testing Coverage

Committee on Federal Health Issues comment letter on Coverage and Reimbursement of Genetic Tests and Services, a report of the Secretary’s Advisory Committee on Genetics, Health, and Society, and raises issues pertaining to genetic testing in general, health insurance markets, cost effectiveness data, and the Medicare and Medicaid programs. (May 5, 2005)

Letter to IRS on Crediting Contributions for Multiemployer Pension Plans

Multiemployer Plans Task Force letter to the Internal Revenue Service (IRS) expressing concerns about the IRS position on crediting contributions for multiemployer pension plans. (March 22, 2005)

COPLFR Suggestions for Insurers Writing Workers' Comp Coverage in California

Committee on Property and Liability Financial Reporting comment letter offering suggestions for insurers writing workers' comp coverage in California. (March 21, 2005)

Response to House Subcommittee for Information on Medical Malpractice Liability Reform

Medical Malpractice Insurance Subcommittee letter to members of the House Energy and Commerce Health Subcommittee in response to its request for additional information on medical malpractice liability reform. (March 14, 2005)

Letter to Labor Department on Proposed Regulations for Annual Funding Notice

Multiemployer Plans Task Force comment letter to the Department of Labor regarding proposed regulations for the annual funding notice for multiemployer pension plans. (March 7, 2005)

Letter to Congress Offering Academy Assistance as Resource on Medicare Issues

Letter offers the Academy as a resource on health care issues and shares some recent publications on key issues including Medicare and the uninsured. (March 4, 2005)

EEC Letter to NCOIL on State of U.S. Catastrophe Insurance Marketplace

Extreme Events Committee comment letter to the National Conference of Insurance Legislators summarizing the current state of the U.S. catastrophe insurance marketplace. (March 3, 2005)

Letter to Congress Urging MAAA designation for SSA and CMS Chief Acturies

Academy comment letter recommending to Congress that individuals serving in the positions of SSA and CMS chief actuary be members in good standing of the American Academy of Actuaries. (March 3, 2005)

Follow-up Comments on Medical Malpractice Liability Reform

Medical Malpractice Subcommittee follow-up comments supplementing testimony from a House subcommittee hearing on medical malpractice liability reform. (February 22, 2005)

Comments on IAA draft 'Measurement of Investment Contracts and Service Contracts under International Financial Reporting Standards'

Financial Reporting Committee comments to the IAA on its draft Practice Guideline: "Measurement of Investment Contracts and Service Contracts under International Financial Reporting Standards." (February 15, 2005)

Comments on IAA Draft Practice Guideline: Current Estimates

Financial Reporting Committee comments to the IAA on its draft Practice Guideline: Current Estimates. (February 15, 2005)

Comments on IAA Draft Practice Guidelines on International Financial Reporting Standards

Financial Reporting Committee comments to the IAA on its draft Practice Guideline: "Actuarial Practice When Providing Professional Services to Reporting Entities Concerning Financial Reporting of Insurance Contracts, Financial Instruments, and Service Contracts Under International Financial Reporting Standards." (February 15, 2005)

Letter to IRS on Proposed Regulations for Distributions under Phased-Retirement Programs

Pension Practice Council comments to Internal Revenue Service (IRS) regarding proposed regulations on distributions from pension plans under a phased-retirement program. (February 8, 2005)

Letter to IRS on Delay of Amortization Relief for Multiemployer Plans under IRC

Multiemployer Plans Task Force letter to Internal Revenue Service (IRS) concerning the delay of amortization relief for multiemployer pension plans under Internal Revenue Code (IRC) Section 412. (January 28, 2005)

Letter to SEC on P/C Liabilities Disclosure in Financial Reporting

Committee on Property and Liability Financial Reporting comments in response to the SEC's Financial Reporting Release requiring tabular disclosure of payments due under P/C liabilities for specified time periods. (January 24, 2005)

Letter to ASB on Proposed Pension Valuation Standard

Pension Committee comment letter to the Actuarial Standards Board (ASB) on a proposed pension valuation standard. (October 4, 2004)

Comments to CMS on Actuarial Equivalence Issues in Proposed Medicare Rx Regulations

Actuarial Equivalence Work Group letter to CMS regarding actuarial equivalence issues related to prescription drug plans (PDPs), Medicare Advantage (MA) plans, Medicare supplement plans, and retiree health benefits. (October 4, 2004)