Health Comments and Letters

Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on the PPACA provision that extends dependent coverage to age 26. (July 12, 2010)
Health Solvency Work Group comment letter to the chair of the NAIC's Capital Adequacy Task Force regarding the evaluation of the current health risk-based capital covariance formula calculation for potential changes to the calculation or methodology. (June 11, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Accident and Health Working Group offering input on the potential inclusion of a change in contract reserves in the numerator of the MLR rebate calculation. (June 7, 2010)
Joint Committee on Retiree Health letter to the Department of Health and Human Services in response to an interim final rule on the PPACA provision that creates a temporary reinsurance program for early retirees. (June 3, 2010)
Medical Loss Ratio Regulation Work Group letter to the NAIC responding to a request for more information on defining statistical credibility within the MLR rebate process as provided in a previous letter. (May 20, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Health Care Reform Solvency Impact Subgroup on an exposure draft of a new proposed financial reporting exhibit the Supplemental Health Care Exhibit. (May 17, 2010)
Medical Loss Ratio Regulation Work Group letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that requires medical loss ratio reporting and rebates. (May 14, 2010)
Premium Review Work Group letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that establishes a review process for unreasonable rate increases. (May 14, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Accident and Health Working Group responding to his request for input on defining an appropriate way to maintain statistical validity within the rebate process. The Academy sent a subsequent letter to respond to a request from the NAIC for more information on statistical credibility. (May 12, 2010)
Premium Review Work Group letter to the chairs of the NAIC's Health Care Reform Solvency Impact Subgroup, the Accident and Health Working Group, and the Rate Review Subgroup regarding the Patient Protection and Affordability Act (PPACA) provision that establishes a review process for unreasonable rate increases. (May 8, 2010)
Medical Loss Ratio Regulation Work Group second letter to the chairs of the NAIC's Health Care Reform Solvency Impact Subgroup and the Accident and Health Working Group regarding the medical loss ratio provisions and the potential for individual market disruption under the Patient Protection and Affordability Act. (April 28, 2010)
Medical Loss Ratio Regulation Work Group letter to the Chairs of the NAIC's Health Care Reform Solvency Impact Subgroup and the Accident and Health Working Group regarding considerations related to the Patient Protection and Affordability Act Medical Loss Ratio Provisions (2718). (April 20, 2010)
Committee on State Health Issues letter to the North Carolina Department of Insurance regarding the Department's proposal to change the definition of "qualified actuary." (April 14, 2010)
Health Practice Council letter to members of House and Senate pledging to work with regulatory authorities on the implementation of the health reform law. (March 24, 2010)
Health Practice Council letter to Congress outlining technical and policy issues that need to be addressed before the passage of health reform legislation to ensure success of the reforms. (March 8, 2010)
Health Practice Council letter to the White House and invitees of the Feb. 25 bipartisan health summit stressing critical actuarial aspects of health reform legislation that will need to be addressed to support the stated goals of reducing the number of uninsured, increasing the availability and affordability of coverage, and enhancing the focus on quality of care and health spending growth. (February 24, 2010)
Letter to NAIC regarding the joint Academy State LTC Task Force and SOA Valuation Committee project to develop and recommend valuation morbidity tables for long-term care insurance. (February 22, 2010)
Medicare Supplement Work Group additional comments to NAIC on the draft revisions to the Medicare Supplement Compliance Manual, clarifying the use of the pooling approach used in the manual and how it may interact with loss ratio standards. (February 2, 2010)
Health Practice Council letter to House Speaker Nancy Pelosi and Senate Majority Leader Harry Reid highlighting some of the key differences on actuarial issues between the House's Affordable Health Care for America Act (HR 3962) and the Senate's Patient Protection and Affordable Care Act. (January 14, 2010)
Health Practice Council letter to Sens. Harry Reid and Mitch McConnell that outlines key isuses that need to be considered when evaluating whether the Senate's health care reform bill will lead to a viable health insurance system and discusses whether the Patient Protection and Affordable Care Act addresses the outlined issues. (November 20, 2009)