Health Comments and Letters

Individual and Small Group Markets Committee comments to the U.S. House Committee on Education and the Workforce on  H.R. 1101, the Small Business Health Fairness Act, related to association health plans.
(March 8, 2017)
Individual and Small Group Markets Committee letter to the Centers for Medicare & Medicaid Services regarding the proposed rule for market stabilization. (March 7, 2017)
Health Financial Reporting and Solvency Committee comments to the Long-Term Care Valuation (B) Subgroup on asset treatment for stand-alone LTC asset adequacy analysis. (January 26, 2017)
LTC Reform Subcommittee comment letter to the Maryland Insurance Administration Public Hearing on Long-Term Care Insurance. (January 6, 2017)
GASB 74 Implementation Work Group comments on the GASB 74 implementation guide exposure draft that addresses financial reporting for postemployment benefit plans other than pension plans. (December 19, 2016)
Joint Property and Casualty Risk-Based Capital Committee and Health Solvency Subcommittee letter to the NAIC's Operational Risk Subgroup on proposed changes to the operational risk factor in risk-based capital (RBC) formulas for property/casualty and health. (December 19, 2016)
Health Practice Council letters to both the U.S. House and Senate on potential adverse consequences of repealing provisions of the Affordable Care Act (ACA) without having a replacement approach in place, and the challenges faced by eliminating the reimbursements to insurers for cost-sharing reduction subsidies.
(December 7, 2016)
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)
Health Practice Council letters to both the U.S. House and Senate on potential adverse consequences of legislation to weaken the Affordable Care Act’s (ACA) individual mandate. (September 22, 2016)
LTC Reform Subcommittee comment letter to the Maryland Insurance Administration Public Hearing on Long-Term Care Insurance. (April 28, 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)
Health Care Receivables Factors Work Group recommendation on credit risk factors for health care receivables to the NAIC’s Health Risk Based Capital (E) Work Group. (April 15, 2016)
Premium Review Work Group letter to CCIIO with comments on the 2017 unified rate review template (URRT). (March 30, 2016)
Health Solvency Subcommittee letter to the NAIC’s Health Risk-Based Capital (E) Working Group with comments on Proposal 2016-01-H’s individual premiums and claims footnote. (March 28, 2016)
Medicare Subcommittee letter to the Senate Finance Committee with comments on the Bipartisan Chronic Care Working Group’s Policy Options Document. (January 26, 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)
Individual Disability Tables Work Group (IDTWG) presented updated incidence modifiers report for use in active life reserve calculations for employer-sponsored disability income policies along with a corresponding memo memo to the chair of the Health Actuarial Task Force. (November 18, 2015)
Medicare Supplemental Work Group responses to questions regarding the work group’s recommendations on modifications to the Medicare supplement refund formula.
(November 10, 2015)
Health Solvency Subcommittee updated on the evaluation of asset risk in the health risk-based capital (HRBC) formula.
(November 9, 2015)
Financial Reporting and Solvency Committee comment letter to the NAIC's Emerging Accounting Issues (E) Working Group on the “ACA Risk Corridors Collectability” exposure draft. (October 30, 2015)