Life Operational Risk Work Group comment letter to NAIC on prospective operational risk growth charge for Life RBC Formula.  (June 6, 2018)
RBC Tax Reform Work Group follow-up letter to NAIC Life Risk-Based Capital Working Group on additional comments regarding impact of changes to corporate tax rate on risk-based capital calculation.  (April 24, 2018)
RBC Tax Reform Work Group update to NAIC on effects of tax reform on life risk-based capital.  (March 24, 2018)
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 2018 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, market reforms, and rate review provisions. (October 6, 2016)
Risk Sharing Subcommittee letter to the Centers for Medicare & Medicaid Services (CMS) with comments on its recent discussion paper, HHS-Operated Risk Adjustment Methodology. The letter includes comments on partial year enrollment, use of pharmacy data, use of concurrent versus prospective model, high-risk enrollee pooling, recalibration of the model, and the transfer formula.  (April 22, 2016)
Risk Sharing Subcommittee letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule on benefit and payment parameters for 2017. (December 20, 2015)
Risk Sharing Work Group letter to CCIIO on the methodology proposed to evaluate the sufficiency of EDGE server data. (May 8, 2015)
Risk Sharing Work Group letter to the U.S. Department of Health and Human Services (HHS) in response to the proposed rule on benefit and payment parameters for 2016. (December 22, 2014)
Senior Health Fellow testimony to the U.S. House Oversight and Government Reform Subcommittee on Economic Growth, Job Creation, and Regulatory Affairs hearing on the Affordable Care Act's risk-sharing mechanisms, also known as the 3Rs. (June 18, 2014)
Risk Sharing Work Group letter to CCIIO with comments on a proposed rule related to exchanges and market reforms for 2015, specifically addressing ACA risk-sharing mechanisms. (April 21, 2014)