Health Comments and Letters

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)

Comments to CMS on Medicare Advantage in Proposed Medicare Rx Regulations

Medicare Steering Committee letter to CMS discusses issues related to the calculation of monthly savings — a step in determining beneficiary rebate amounts for MA plans — and payment adjustments based on the variation in costs among different areas including input prices, utilization, and practice patterns. (October 4, 2004)

Comments to CMS on Proposed Medicare Rx Regulations

Medicare Steering Committee letter discusses issues related to eligibility and enrollment, benefits and beneficiary protections, submission of bids and monthly beneficiary premiums, payments to prescription drug plan sponsors and Medicare Advantage (MA) organizations, etc. Comments on issues related to actuarial equivalence in a separate letter. (October 4, 2004)

Tips on Using Rate Filing Task Force Model

Academy document includes a series of tips to facilitate using the Rate Filing Task Force model. (September 30, 2004)

Report to NAIC with Recommendation for New Long-Term Care RBC Formula

Long Term Care Risk Based Capital Work Group report on the review of the Managed Care Organization RBC formulas for LTC describes the source of data, methodology, analysis, and recommendations. It reflects revisions based on feedback from members of the NAIC subgroup after the interim report was released in June 2003. (June 1, 2004)

Letter to GASB on Accounting by Governmental Employers for Other Postemployment Benefits

Joint Committee on Retiree Health letter to the Governmental Accounting Standards Board (GASB) on accounting by governmental employers for other postemployment benefits. (April 30, 2004)

Letter to FASB regarding MMA

Joint Committee on Retiree Health comments to FASB opportunity to comment on the proposed FASB staff position (FSP) 106-b, Accounting and Disclosure Requirements Related to the Medicare Prescription Drug, Improvement and Modernization Act of 2003. (April 13, 2004)

Letter to IRS on Health Savings Accounts under MMA

Health Savings Account Subgroup comments on IRS Notice 2004-2, which provides guidance on Health Savings Accounts (HSAs) provisions in the Medicare Prescription Drug, Improvement, and Modernization Act of 2003. (March 30, 2004)

Comment Letter to IRS on HSA Provisions in New Medicare Law

Health Savings Account Subgroup comment letter on Notice 2004-2 issued by the Treasury Department and the Internal Revenue Service, which provides guidance on Health Savings Accounts (HSAs). (March 30, 2004)

Letter to House-Senate Conferees on Medicare Rx Bills

Health Practice Council letter to House and Senate conferees, who are reconciling to Medicare Rx bills, that offers assistance in assessing the actuarial implications of changes to the Medicare program. (September 29, 2003)

Letter to EEOC on Proposed Retiree Health Benefit Rule

Retiree Health Work Group comments related to the proposed rule by the Equal Employment Opportunity Commission (EEOC) on the Age Discrimination in Employment Act (ADEA) and retiree health benefits. (September 12, 2003)

Letter to NAIC on Proposed LTC Model Valuation Regulation

Long-Term Care Reserve Work Group letter to NAIC that illustrates the anticipated impact of various hypothetical changes in the mortality, voluntary lapse, interest and morbidity valuation assumptions on net renewal valuation premiums and contract reserves by policy duration. (September 10, 2003)

Letter on LTC RBC Report

Long-Term Care Risk-Based Capital Work Group letter to the Deputy Insurance Commissioner of Pennsylvania responding to concerns regarding total asset adequacy as it relates to the Long-Term Care RBC Work Group's interim report. (September 8, 2003)

HPFRC Letter to NAIC on Reserves

Health Practice Financial Reporting Committee letter addressing general principles that should be considered in the development of and addressed by premium deficiency reserves and gross premium valuations. (September 3, 2003)

Letter to House-Senate Confeeres on Medicare Rx Legislation

Health Practice Council letter on the general risk sharing approaches available, summarizes the risk-sharing provisions in the Senate and House bills, and provides specific comments on the risk-sharing approaches in the Senate and House bills. (July 30, 2003)

Report to NAIC on Status of Health Liquidity Work Group

Health Liquidity Work Group status update to the NAIC on a set of potential ratios to be used to test for health organization liquidity. The ratios would be used in a “safe harbor” test. (June 30, 2003)

Report on Managed Care Organization RBC Formulas from Long-Term Care RBC Work Group

Long-Term Care RBC Work Group interim report on the Managed Care Organization Risk Based Capital formulas for Long Term Care (LTC) insurance products and described the source of data, methodology, analysis, and recommendations. (June 22, 2003)

Letter to Congress on Use of Genetic Information

Health Practice Council comments on legislation that was introduced in both the House and Senate to regulate the use of genetic information, particularly with respect to health insurance. (May 22, 2003)

Letter to GASB on Actuarial Measurement of Retiree Health Benefits

Retiree Health Insurance Work Group letter to the Governmental Accounting Standards Board (GASB) about the actuarial measurement of retiree health benefits. (May 20, 2003)

Comment Letter to Congress on AHP Legislation

Health Plan Work Group comments on the Small Business Health Fairness Act of 2003 (H.R. 660 and S. 545), which would amend ERISA to establish a new “Part 8—Rules Governing Association Health Plans. (April 28, 2003)