Health Comments and Letters

Federal Long-Term Care Task Force letter to the Senate Committee on Health, Education, Labor and Pensions regarding actuarial issues and policy implications on the the Community Living Assistance Services and Supports Act (CLASS Act). (July 22, 2009)
Medicare Steering Committee comments on the first in a series of Senate Finance Committee policy options papers, Transforming the Health Care Delivery System. (May 29, 2009)
Health Practice Council comments on the Senate Finance Committee’s series of policy options papers, Expanding Healthcare Coverage: Proposals to Provide Affordable Coverage to All Americans. (May 22, 2009)
Health Practice Council comments to the Senate related to introduced legislation, the Women's Health Insurance Fairness Act, that would eliminate gender as a rating factor for individual health insurance. (May 15, 2009)
Medicare Steering Committee and Health Care Quality Work Group comments to the Senate Finance Committee on the draft legislation "Medicare Hospital Quality Improvement Act of 2008", which would link Medicare hospital payments to performance on certain quality measures. (December 15, 2008)
Medicare Part D RBC Subgroup letter to the Centers for Medicare and Medicaid Services for financial data related to Medicare Part D, which will be used to update a report on Medicare Part D RBC risk factors. (October 6, 2008)
Health RBC Trend Test Work Group report to the NAIC on evaluating the effectiveness of three proposed trend tests. (August 26, 2008)
Health Practice Financial Reporting Committee comments on proposed changes in the actuarial opinion instructions for NAIC health annual statements. (February 19, 2008)
Joint Committee on Retiree Health letter to Texas officials about misinterpretations of the committee's 2006 comments on accounting standards for OPEBs. (June 15, 2007)
Medicare Part D RBC Subgroup revision proposals to the NAIC life and health RBC instructions for Medicare Part D to address a potential unintended consequence related to the Authorized Control Level (ACL) RBC results. (June 3, 2007)
Medicare Part D RBC Subgroup comment letter to NAIC's Health Risk Based Capital Working Group on a possible update of proposed risk factors previously developed by the Academy's Medicare Part D subgroup. (May 3, 2007)
Health Practice Financial Reporting Committee letter to Julia T. Philips, the Chair of the NAIC's Health Risk-Based Capital (RBC) Working Group, that comments on a proposal made by Blue Cross Blue Shield of Florida regarding the treatment in the NAIC RBC formulas of medical insurance products for which active life reserves are held. The letter provided initial thoughts on the matter and seeks further input from the NAIC in light of these thoughts. (May 3, 2007)
Health Practice Financial Reporting Committee comments to the NAIC on a proposal to include a trend test in the health RBC formula. (May 3, 2007)
Part D Lessons Learned Work Group comment letter on what has worked well and what has not in Medicare Part D. The letter also offers recommendations to improve the overall operation and administration of the Part D program, specifically including the bidding process, management of eligibility, and coordination with Medicaid and with the Social Security Administration. (March 21, 2007)
Health Practice Council comment letter to members of the House and Senate on the actuarial implications of restricting insurers' use of genetic information. (February 16, 2007)
Health Practice Council comments that urge CMS to reconsider the one-role-per-user rule for actuaries for Part D attestations and to investigate alternatives that would not prevent actuaries from fulfilling their actuarial obligations. (December 19, 2006)
Subgroup on Long-Term Care Experience Forms comments to the NAIC regarding American Council of Life Insurers (ACLI) Proposed Recommendation to Report Non-Exempt LTC accelerated-type products. (November 17, 2006)
Committee on Federal Health Issues letter to Citizens' Health Care Working Group on its interim recommendations for improving health care. (August 24, 2006)
Medicare Supplement Work Group comments to NAIC's Medigap Modernization Subgroup of the Senior Issues Task Force identifying potential transitional issues that will need to be addressed as part of Medicare Supplement modernization that the Subgroup has recently taken up. (August 17, 2006)
Joint Committee on Retiree Health letters to FASB expressing concern over proposed changes in financial accounting standards for pensions and OPEBs. (May 31, 2006)