Health Comments and Letters

Actuarial Value Subgroup comment letter on plan data collection requirements, specificially asking for clarification on whether any AV-related data collection elements will be consistent with those data elements in the AV calculator. (December 20, 2012)
Actuarial Value Subgroup comment letter on the proposed rule establishing standards for actuarial value determinations under the Affordable Care Act (December 18, 2012)
Casualty, Life, Health, Professionalism, and Financial Reporting Council comments to the NAIC's Corporate Governance Working Group on its Proposed Responses to a Comparative Analysis of Existing U.S. Corporate Governance Requirements. (September 28, 2012)
Health Practice Council letter to Sen. Thune and Rep. Boustany clarifying the nature and intent of recent Academy-hosted roundtables focused on addressing the accessibility and affordability of long-term care services. (August 15, 2012)
Joint Committee on Retiree Health comments on the ASB's exposure draft of ASOP 6, Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Plan Costs or Contributions. (July 14, 2012)
Stop-Loss Work Group comments to the Employee Benefits Security Administration regarding stop-loss insurance and the Affordable Care Act (ACA).  (July 2, 2012)
Medicaid Work Group comments to CMS on a proposed rule regarding payments for Medicaid primary care services. (June 12, 2012)
Actuarial Value Subgroup comments to the IRS on Notice 2012-31, Minimum Value of an Employer Sponsored Health Plan, addressing how to account for non-core benefits and non-standard plan features as well as other considerations related to the treatment of health savings account (HSA) contributions. (June 11, 2012)
Joint Committee on Retiree Health comments on the ASB's exposure draft for ASOP 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions, requesting clarification on the implications for retiree group benefits. (May 31, 2012)
Joint Committee on Retiree Health comments on the ASB's exposure draft for ASOP 27, Selection of Economic Assumptions for Measuring Pension Obligations, regarding the implications for retiree group benefits. (May 31, 2012)
Actuarial Value Subgroup letter to CCIIO offering comments on the Actuarial Value and Cost-Sharing Reduction bulletin, specifically addressing the proposed actuarial value calculator. This letter supplements comments submitted April 2 on the cost-sharing inputs for the calculator. (May 16, 2012)
Health Practice Financial Reporting Committee comments to the ASB on revisions to ASOPs 22 and 28. (May 15, 2012)
Medical Loss Ratio Subgroup letter to CMS offering comments on the revised annual reporting form, specifically on the definition of premiums, contract reserves, and the definition of pre-tax underwriting gain/(loss). (May 2, 2012)
Federal Long-Term Care (LTC) Task Force letter to NCOIL in response to a request for information on strategies to reduce costs related to LTC coverage. (April 27, 2012)
Health Practice Council and the Committee on Qualifications letter to all state insurance commissioners and chairs of each state house and senate insurance committee regarding the appropriate definition of "Qualified Actuary" as it relates to the Affordable Care Act's rate review provision. (April 20, 2012)
Health Practice Council comment letter to the Center for Consumer Information and Insurance Oversight (CCIIO) providing responses to questions raised during a meeting with representatives of CCIIO on the structure of a proposed actuarial value calculator (for purposes of the ACA). (April 2, 2012)
Health Practice Council comment letter to House leadership on legislation (HR 5) that would include a provision to repeal the Independent Payment Advisory Board, which was created under the ACA to provide recommendations to reduce growth in Medicare expenditures if spending exceeds a certain growth rate. (March 21, 2012)
Medical Loss Ratio (MLR) Work Group comments to CMS on the exposure draft of the MLR annual reporting form. (February 14, 2012)
Health Practice Council and Committee on Qualifications letter to the Arizona insurance director stressing its concern that their regulatory definition of “qualified actuary” for health premium rate actuarial certifications was inappropriate and suggested corrective language. (February 10, 2012)
Individual and Small Group Market Task Force comments to the HHS on the essential health benefits bulletin. (January 31, 2012)