Health Comments and Letters

2020 Benefit and Payment Parameters Proposed Rule

Individual and Small Group Markets Committee and Risk Sharing Subcommittee comments on the proposed rule for the 2020 notice of benefit and payment parameters (NBPP). (February 19, 2019)

Subcommittee Comment Letter on Medicaid and CHIP Proposed Rule

Medicaid Subcommittee letter to CMS providing comments on Nov. 14, 2018 proposed rule regarding Medicaid and CHIP managed care programs. (January 14, 2019)

Comments on (1332) State Relief and Empowerment Waivers Guidance

Committee comments on the Oct. 22, 2018 guidance from the Department of the Treasury and the Department of Health and Human Services on State Relief and Empowerment Waivers under Section 1332 of the Affordable Care Act (ACA), focusing on three areas: evaluation of coverage comprehensiveness and affordability, evaluation of coverage, and waiver funding. (December 18, 2018)

Comments on Risk Adjustment Data Validation (RADV)

Council letter to the Centers for Medicare and Medicaid Services (CMS) in response to its request for comments on proposed rules pertaining to the Medicare Advantage (MA) program, including provisions to revise the risk adjustment data validation (RADV) payment error calculation methodology and process. (December 17, 2018)

Comments on Health Reimbursement Arrangements and Other Account-Based Group Health Plans

Committees comment on the proposed rule regarding Health Reimbursement Arrangements (HRAs), that would create two new types of HRAs—Integrated HRAs and Excepted Benefit HRAs—which would allow employers to provide HRAs that could be used to pay for individual plan premiums and out-of-pocket health costs. (December 13, 2018)

Comments on the impact of corporate tax rate change on HRBC

Subcommittee comments on the impact on Health Risk-Based Capital (HRBC) from the Tax Cuts and Jobs Act of 2017 (TCJA). (October 18, 2018)

Comments on Adoption of Methodology for HHS-Operated Permanent Risk Adjustment Program for 2018 Benefit Year

Committee and Subcommittee comments on the Centers for Medicare and Medicaid Services’ (CMS) and Department of Health and Human Services’ (HHS) Aug. 10 proposed rule regarding the adoption of methodology for the HHS-operated permanent risk adjustment program. (September 5, 2018)

Comments on the Medicare Long-Term Care Services and Supports Act of 2018

Committee comments on proposed legislation to add a long-term care benefit to the Medicare program, evaluating in terms of financing, benefits, and coordination with other programs. (June 15, 2018)

Comments on Short-term, Limited Duration Insurance

Committee comments on a proposed rule that would lengthen the maximum period of short-term, limited-duration (STLD) insurance through amending the definition of STLD. (April 6, 2018)

Comments on Association Health Plans

Committee comments on the definition of ‘‘Employer’’ under section 3(5) of ERISA—Association Health Plans. (March 5, 2018)

Letter to Idaho Department of Insurance

Health Practice Council comments to the Idaho Department of Insurance on allowing health insurers to offer state-based plans that are not compliant with the Affordable Care Act in Idaho. (March 2, 2018)

Comments on Considerations Related to Modeling the Potential Impact of Association Health Plans

Committee comments to Office of Regulations and Interpretations within the Employee Benefits Security Administration in response to the Department of Labor's proposed rule on the definition of employer—small business health plans. (February 9, 2018)

Comments on Promoting Healthcare Choice and Competition

Committee comments to Office of the Assistant Secretary for Planning and Evaluation in response to the Department of Health and Human Services’ request for information on promoting healthcare choice and competition. (January 25, 2018)

Letter to U.S. House and Senate on Proposal to Eliminate Individual Mandate

Health Practice Council comments to the U.S. House and Senate on the potential inclusion of individual mandate repeal in The Tax Cuts and Jobs Act. (December 12, 2017)

Comments on 2019 Benefit and Payment Parameters Proposed Rule

Risk Sharing Subcommittee and Premium Review Work Group letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule for the 2019 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, special enrollment periods, essential health benefits, minimum essential coverage, and medical loss ratios.
(November 27, 2017)

Letter to Senate on Proposal to Eliminate Individual Mandate

Health Practice Council comments to the U.S. Senate on a proposal in the Tax Cuts and Jobs Act to eliminate the ACA's individual mandate. (November 21, 2017)

Comments on Presidential Executive Order to Departments of Treasury, Labor, and HHS

Health Practice Council comments on the October 12 executive order. (November 7, 2017)

Comments on the Graham-Cassidy-Heller-Johnson Proposal

Health Practice Council comments on the Graham-Cassidy-Heller-Johnson Proposal (GCHJ), legislation that would make revisions to the individual health insurance market and approaches to federal Medicaid funding. (September 22, 2017)

Letter to Senate HELP Committee on Stabilization

Health Practice Council letter to the U.S. Senate HELP Committee on stabilizing the individual health insurance market. (September 12, 2017)

Comments on Investment RBC Bond Factors

Comment letter submitted jointly by the P/C RBC Committee and the Health Solvency Subcommittee regarding changes to corporate bond factors being considered by the NAIC’s Investment Risk-Based Capital Working Group. (July 25, 2017)