Health Comments and Letters

Premium Review Work Group letter to the Massachusetts Senate regarding an amendment to the state budget that would require the disapproval of any health insurance rates to be supported by "sound actuarial assumptions and methods." (November 30, 2011)
Health Practice Council and Committee on Qualifications letter to the Arizona insurance director pointing out that their regulatory definition of “qualified actuary” for health premium actuarial certifications was inappropriate and suggested corrective language. (November 18, 2011)
Cancer Claims Cost Tables Work Group letter to the NAIC’s Health Actuarial Task Force discussing the progress it has made over the past year and outlining its objectives for the coming year. (October 31, 2011)
Risk Sharing Work Group comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule implementing the risk-spreading mechanisms included in the Affordable Care Act (ACA) and related to reinsurance, risk corridors, and risk adjustment. (October 28, 2011)
Joint work group of the SOA Long-Term Section Council and the Academy’s Federal Long-Term Care Task Force letter to HHS Secretary Sebelius regarding the department’s extension of the Genetic Information Nondiscrimination Act (GINA) to long-term care insurance in proposed regulations. (October 13, 2011)
Exchanges Work Group comments to CMS in response to proposed regulations establishing health insurance exchanges and qualified health plans under the ACA.  (October 6, 2011)
Medicare Supplement Work Group letter to the NAIC Medigap PPACA Subgroup offering comments on the subgroup’s new discussion paper, Medicare Supplement Insurance First Dollar Coverage and Cost-Shares. (October 4, 2011)
Medicare Steering Committee comment letter to the members of the new Joint Select Committee on Deficit Reduction urging action to improve the long-term solvency and sustainability of the Medicare program. (August 31, 2011)
Medicare Supplement Work Group letter to the NAIC's Medicare Supplement Refund Formula Subgroup with a proposed charge to have the work group review the Medicare Supplement Refund Formula for potential changes that may need to be addressed. (August 24, 2011)
Premium Review Work Group comments to CMS in response to the revised preliminary justification and consumer disclosure forms for purposes of rate review disclosure and reporting requirements. (June 28, 2011)
Health Care Quality Work Group comments to CMS in response to proposed regulations on accountable care organizations and the Medicare Shared Savings Program under the Affordable Care Act. (June 6, 2011)
Premium Review Work Group comments to CMS in response to a notice on rate increase disclosure and review reporting requirements. (May 2, 2011)
Exchanges Work Group comments to the National Assocation of Insurance Commissioners (NAIC) Exchanges (B) Subgroup regarding its white paper on adverse selection and exchanges created through the Affordable Care Act. (April 5, 2011)
CO-OP Subgroup letter to HHS in response to its request for comments on the consumer operated and oriented plan programs (CO-OPs). (March 4, 2011)
Premium Review Work Group comments to HHS in response to proposed regulations on rate increase disclosure and review. (February 22, 2011)
Long-Term Care Practice Note Work Group letter to the NAIC regarding the formation of a new work group in charge of updating the Academy's 2003 practice note, Long-Term Care Insurance Compliance with the NAIC LTCI Model Regulation Relating to Rate Stability. The letter also outlines the proposed tasks and timeline for completion. (February 17, 2011)
Medicare Part D RBC Subgroup letter to the NAIC's Health RBC Working Group asking it to sponsor and administer a survey of carriers that write Medicare Part D business. The survey is designed to gather additional data that may support any needed changes to the formula. (February 9, 2011)
Life, Health, and Property/Casualty RBC committees joint report in response to the NAIC's request for assistance with the Solvency Modernization (SMI) project on the NAIC's Risk-Based Capital (RBC) formulas. The report discusses the intended/expected safety levels for RBC and identifies risks that are missing from the RBC formulas. (January 31, 2011)
Medical Loss Ratio Regulation Work Group letter to HHS in response to an interim final rule on the medical loss ratio (MLR) provisions in the Affordable Care Act. (January 31, 2011)
Academy report to the NAIC in response to its request for assistance with the Solvency Modernization project on the NAIC's Risk-Based Capital (RBC) formula. (January 31, 2011)