Public Policy Comments and Letters

Joint Committee on Retiree Health letter to Texas officials about misinterpretations of the committee's 2006 comments on accounting standards for OPEBs. (June 15, 2007)
Medicare Part D RBC Subgroup revision proposals to the NAIC life and health RBC instructions for Medicare Part D to address a potential unintended consequence related to the Authorized Control Level (ACL) RBC results. (June 3, 2007)
Risk Margin Task Force comments to IAA on draft "Measurement of Liabilities for Insurance Contracts: Current Estimates and Risk Margins." (May 25, 2007)
Pension Committee comments to the Department of Energy (DOE) on the issues faced by the DOE and its contractors in managing the costs of pension and medical benefits. (May 10, 2007)
Medicare Part D RBC Subgroup comment letter to NAIC's Health Risk Based Capital Working Group on a possible update of proposed risk factors previously developed by the Academy's Medicare Part D subgroup. (May 3, 2007)
Health Practice Financial Reporting Committee letter to Julia T. Philips, the Chair of the NAIC's Health Risk-Based Capital (RBC) Working Group, that comments on a proposal made by Blue Cross Blue Shield of Florida regarding the treatment in the NAIC RBC formulas of medical insurance products for which active life reserves are held. The letter provided initial thoughts on the matter and seeks further input from the NAIC in light of these thoughts. (May 3, 2007)
Health Practice Financial Reporting Committee comments to the NAIC on a proposal to include a trend test in the health RBC formula. (May 3, 2007)
Social Security Committee comments to the Federal Accounting Standards Advisory Board (FASAB) regarding a preliminary views document on accounting for social insurance. (April 16, 2007)
Financial Reporting Committee and Actuarial Standards Board joint response to FASB on its request for comments on valuation guidance in financial reporting. (April 13, 2007)
Life Financial Reporting Committee comment letter to FASB on accounting for life insurance contracts acquired in a business combination. (April 2, 2007)
Workers’ Compensation Subcommittee comments to NCOIL about a proposed model law concerning professional employer organizations and workers' comp insurance. (March 30, 2007)
Part D Lessons Learned Work Group comment letter on what has worked well and what has not in Medicare Part D. The letter also offers recommendations to improve the overall operation and administration of the Part D program, specifically including the bidding process, management of eligibility, and coordination with Medicaid and with the Social Security Administration. (March 21, 2007)
Pension Committee comments to the Internal Revenue Service (IRS) regarding changes to the combined plan deduction limit under IRS Notice 2007-28. (March 1, 2007)
Public Plans Task Force letter to the International Public Sector Accounting Standards Board (IPSASB) regarding  Exposure Draft (ED) 31, Employee Benefits. (February 28, 2007)
Health Practice Council comment letter to members of the House and Senate on the actuarial implications of restricting insurers' use of genetic information. (February 16, 2007)
Risk Management and Solvency Committee comments on a 2007 version of an IAIS paper regarding a common structure for insurer solvency assessment. (January 5, 2007)
Health Practice Council comments that urge CMS to reconsider the one-role-per-user rule for actuaries for Part D attestations and to investigate alternatives that would not prevent actuaries from fulfilling their actuarial obligations. (December 19, 2006)
Life Reserves Work Group update on draft actuarial guidelines on reserve documentation and disclosure. (December 1, 2006)
Updated Actuarial Guideline PBR-VAL from the Life Reserves Work Group presented to the National Association of Insurance Commissioners’ Life and Health Actuarial Task Force. (December 1, 2006)
Life Reserves Work Group update of draft model regulation on principle-based life reserving. (December 1, 2006)