Public Policy Comments and Letters

Casualty Practice Council request for research assistance from the Casualty Actuarial Society in conjunction with its efforts to aid the National Association of Insurance Commissioners with its RBC SMI project. (September 30, 2010)
Risk Sharing Work Group letter to HHS regarding the ACA reinsurance provision that references the Academy. The letter includes initial input on potential approaches for identifying high-risk individuals and determining reinsurance payments. (September 22, 2010)
Pension Practice Council response to the Governmental Accounting Standards Board (GASB)'s "Preliminary Views on Pension Accounting and Financial Reporting by Employers." (September 17, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on first-dollar coverage of preventive services. (September 17, 2010)
Pension Accounting Committee comments to the International Accounting Standards Board (IASB) regarding  proposed amendments to IAS 19. (September 3, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on ACA provisions that eliminate lifetime limits, restrict annual limits, eliminate preexisting condition exclusions, and prohibit rescissions. (August 27, 2010)
Medical Loss Ratio Regulation Work Group letter to HHS with input on credibility issues for the purpose of calculating rebates under the new MLR requirements. (August 20, 2010)
Grandfathering Provisions Work Group letter to HHS in response to an interim final rule on the ACA provision related to the status of health insurance coverage as a grandfathered plan. (August 16, 2010)
Risk Management and Solvency Committee comments to the IAIS on its Draft Standard on Group-wide Regulatory Requirements and Guidance on Group-wide Supervision Framework. (August 10, 2010)
Financial Reporting Committee and Risk Management and Solvency Committee comments on the June 2010 Primary Considerations to the NAIC Statutory Accounting and Financial Reporting (EX) Subgroup. (August 4, 2010)
Terrorism Risk Insurance Subgroup comments to the President's Working Group on Financial Markets in response to its Federal Register request for an analysis of terrorism risk insurance. (August 2, 2010)
Premium Review Work Group letter regarding Massachusetts Senate Bill 2447, which includes a provision that would limit rate increases to medical CPI. (July 27, 2010)
Premium Review Work Group comment letter on the NAIC's exposure draft of a rate-filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS. (July 14, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on the PPACA provision that extends dependent coverage to age 26. (July 12, 2010)
Pension Committee comments to the Cost Accounting Standards Board on the proposed rulemaking for harmonization of CAS Nos. 412 and 413 with the Pension Protection Act of 2006. (July 9, 2010)
Pension Committee letter to the Department of the Treasury and the Internal Revenue Service (IRS) with suggestions for the 2011 schedules SB and MB instructions and forms. (July 7, 2010)
Financial Reporting Committee and Life Financial Reporting Committee comments to the IASB concerning its report, "Exposure Draft Financial Instruments: Amortised Cost and Impairment." (June 30, 2010)
Property and Casualty Risk-Based Capital Committee update to the National Association of Insurance Commissioners (NAIC)'s Property & Casualty Risk-Based Capital Working Group regarding the RBC Committee's prior March 2010 update of the property/casualty RBC underwriting factors. (June 22, 2010)
Health Solvency Work Group comment letter to the chair of the NAIC's Capital Adequacy Task Force regarding the evaluation of the current health risk-based capital covariance formula calculation for potential changes to the calculation or methodology. (June 11, 2010)
Financial Regulatory Reform Task Force letter to Congress urging the inclusion of an Office of the Chief Actuary in the Office of Financial Research as Congress was in conference reconciling bills H.R.4173 and S.3217. (June 9, 2010)