Public Policy Comments and Letters

Medicaid Subcommittee letter to CMS providing comments on Nov. 14, 2018 proposed rule regarding Medicaid and CHIP managed care programs. (January 14, 2019)
Role of the Actuary Subgroup comment letter to NAIC on the treatment and definitions of the term "actuarial opinion" in VM-30.  (January 10, 2019)
Life Reserves Work Group comment letter to the Life Actuarial (A) Task Force on amendment proposal form (APF) 2018-44, regarding credited amounts for indexed accounts.  (January 2, 2019)
Retirement System Assessment and Policy Committee comment letter to the Department of Labor's proposed rule on the Definition of Employer under Section 3(5) of the Employee Retirement Income Security Act (ERISA).  (December 21, 2018)
Academy Pension Vice President letter to U.S. House members on The Retirement, Savings, and Other Tax Relief Act of 2018  (December 20, 2018)
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)
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)
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)
Non-Guaranteed Elements Work Group comment letter to NAIC on their proposal for a life insurance online guide landing page.  (November 28, 2018)
Retirement System Assessment and Policy Committee letter to Congress on the Retirement Enhancement and Savings Act of 2018.  (November 16, 2018)
Letter from Academy Past President Mary D. Miller to NAIC with comments on CASTF’s draft 3-year experience proposal. (November 8, 2018)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) regarding the Risk-based Global Insurance Capital Standard Version 2.0 (ICS 2.0) public consultation document dated July 31, 2018. (October 30, 2018)
Life Operational Risk Work Group follow-up letter to NAIC on exposed Life Risk-Based Capital growth charge proposal.  (October 29, 2018)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) regarding the Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame) public consultation document dated July 31, 2018. (October 19, 2018)
Subcommittee comments on the impact on Health Risk-Based Capital (HRBC) from the Tax Cuts and Jobs Act of 2017 (TCJA). (October 18, 2018)
Annuity Illustration Work Group comment letter to NAIC on proposed changes to Annuity Disclosure Model Regulation #245.  (October 18, 2018)
Life Reserves Work Group revised amendment proposal form on selection of the industry basic table when company experience mortality rates are higher than the industry basic table. (October 3, 2018)
Multiemployer Plans Committee follow-up letter to the Joint Select Committee on Solvency of Multiemployer Pension Plans on key topics discussed during June 22 meeting regarding loan proposals and other solutions for troubled multiemployer pension plans.  (September 26, 2018)
Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on its Scope and Non-Insurance Testing Exposed with Questions document. (September 20, 2018)
Big Data Task Force comments to the  U.S. Senate Committee on Banking, Housing, and Urban Affairs  on their hearing, Fintech: Examining Digitization, Data, and Technology. (September 17, 2018)