Health Comments and Letters

Long-Term Care Risk-Based Capital Work Group letter to the Deputy Insurance Commissioner of Pennsylvania responding to concerns regarding total asset adequacy as it relates to the Long-Term Care RBC Work Group's interim report. (September 8, 2003)
Health Practice Financial Reporting Committee letter addressing general principles that should be considered in the development of and addressed by premium deficiency reserves and gross premium valuations. (September 3, 2003)
Health Practice Council letter on the general risk sharing approaches available, summarizes the risk-sharing provisions in the Senate and House bills, and provides specific comments on the risk-sharing approaches in the Senate and House bills. (July 30, 2003)
Health Liquidity Work Group status update to the NAIC on a set of potential ratios to be used to test for health organization liquidity. The ratios would be used in a “safe harbor” test. (June 30, 2003)
Long-Term Care RBC Work Group interim report on the Managed Care Organization Risk Based Capital formulas for Long Term Care (LTC) insurance products and described the source of data, methodology, analysis, and recommendations. (June 22, 2003)
Health Practice Council comments on legislation that was introduced in both the House and Senate to regulate the use of genetic information, particularly with respect to health insurance. (May 22, 2003)
Retiree Health Insurance Work Group letter to the Governmental Accounting Standards Board (GASB) about the actuarial measurement of retiree health benefits. (May 20, 2003)
Health Plan Work Group comments on the Small Business Health Fairness Act of 2003 (H.R. 660 and S. 545), which would amend ERISA to establish a new “Part 8—Rules Governing Association Health Plans. (April 28, 2003)
LTC Reserve Work Group outline of the proposed near-term and long-term objectives as they relate to the NAIC's request for the Academy to review the reserve methodology for LTC insurance. (March 7, 2003)
Health Liquidity Work Group status update to the NAIC on a set of potential ratios to be used to test for health organization liquidity. The ratios would be used in a “safe harbor” test. (December 31, 2002)
Health Practice Council and Pension Practice Council letter to GASB discussing concerns actuaries have about two aspects of the proposed standard, including the use of a common premium concept to determine whether an employer is subject to the accounting and reporting aspects of this standard, and, the use of an alternative (non-actuarial) approach that could be used by small employers. (December 13, 2002)
EEOC-ADEA and Retiree Health Work Group letter that provides a list of potential issues that could complicate implementation of retiree medical safe harbors are placed into three categories — rating and measurement, plan interpretation, and other. (October 16, 2002)
Life Products Committee comments on the proposed Genetic Discrimination Model Act to the National Conference of Insurance Legislators (NCOIL) Life Committee as it considers the proposal. (July 13, 2002)
Health Practice Council letter to Congress offers the Academy as a resource on questions related to Medicare and prescription drugs, and notes that adding any additional benefits, in particular a prescription drug benefit, without addressing the financing of the entire Medicare program would be unwise given the uncertainties for future funding of the current benefit structure. (June 20, 2002)
Health Plan Work Group comments on the association health plan (AHP) provisions in Title IV, Subtitle B of the Bipartisan Patient Protection Act (H.R. 2563), which would amend the Employee Retirement Income Security Act of 1974 to establish a new “Part 8—Rules Governing Association Health Plans. (April 9, 2002)
Health Liquidity Work Group status update to the NAIC on a set of potential ratios to be used to test for health organization liquidity. The ratios would be used in a “safe harbor” test. (March 31, 2002)
Medicare Steering Committee comment letter on proposed changes in the Medicare+Choice risk adjustment methodology and reporting requirements for diagnostic information for use beginning in 2004. (January 30, 2002)
Health Practice Financial Reporting Committee letter proposing several amendments to paragraphs within SSAP 54. (August 29, 2001)
Academy comments on the proposal developed and approved on a preliminary basis by the NAIC’s Speed to Market Working Group that pertain to the definitions of “minimum experience and education requirements” for actuaries contained in the preface to the proposal. (March 29, 2001)
Academy letter on proposed standards for privacy of health information to the Department of Health and Human Services. (February 17, 2001)