Health Comments and Letters

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)
Task Force on HORBC comments that offer a counterproposal regarding the redesign of the Property & Equipment page. The counterproposal would achieve the objectives of attaining compliance with the new Health blank and reducing the amount of data collected, and it would leave the NAIC working group flexibility to make a change to the HCDA risk factor in 2001. (January 10, 2001)
Medicare Reform Task Force letter to Senate about the debate around changes to the Medicare program, including proposals to provide prescription drug coverage to seniors. (July 17, 2000)
Health Insurance Rate Filing Task Force letter request for NAIC assistance in narrowing the scope of the Academy's Health Insurance Rate Filing Task Force work on developing guidelines for filing health insurance rates with state regulatory agencies. (February 24, 2000)
Academy comments to HHS on the proposed federal regulations regarding the privacy of individually identifiable health information (IIHI). (February 17, 2000)
Health Committee comment letter to members of the House and Senate on the 1999 Medicare Trustees Report. (April 27, 1999)
Health Practice Council letter to National Bipartisan Commission on the Future of Medicare in response to the questions the commission raised regarding possible changes to the current Medicare benefit structure as well as modifications to the coverage requirements for Medicare supplement insurance. (February 17, 1999)
Association Health Plan Work Group comments on the “Health Coverage for Employees of Small Businesses” provisions in Title I (Subtitle D) of the Patient Protection Act of 1998 (H.R. 4250). (October 5, 1998)
Health Codification Subgroup of the State Health Committee comments to NAIC on the exposure of health related Statements of Statutory Accounting Principles (SSAPs), specifically to the March 25, 1998 exposure of seven modified SSAPs and one new SSAP. (May 5, 1998)
Mental Health Parity Work Group comments on the interim final rule implementing the Mental Health Parity Act of 1996. (March 23, 1998)
Federal Health Committee preliminary comments to HHS on the PSO solvency standards development process. (February 18, 1998)
Various reports on Medical Savings Accounts (MSAs)
Note: The following three reports on medical savings accounts (MSAs) were published in 1995, before the emergence of two related concepts: health savings accounts (HSAs)and health reimbursement accounts (HRAs). The conclusions in the 1995 reports may not be appropriate for HSAs and HRAs. More recent reports on such consumer-driven health plans (also known as consumer-directed health plans and defined contribution health plans) as HSAs and HRAs are available online or by contacting Academy staff. (October 31, 1995)