Health Reform & ACA Implementation

Implementation of the Affordable Care Act, the health care reform law passed in 2010, and other health care reform issues.

Practice note by the Rate Review Practice Note Work Group on the preparation, review, and disclosure of rate filings under the Affordable Care Act. (October 9, 2012)
Decision brief highlighting some of the issues that federal and state policymakers and regulators should consider as they are making their Medicaid expansion decisions. (September 10, 2012)
Health Practice Council webinar slides addressing the Supreme Court decision on the individual mandate and next steps in state and federal implementation of the Affordable Care Act (ACA). (July 11, 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)
Voter guide to help explain why broad participation is necessary in the health insurance system to avoid higher premiums. (June 28, 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 Academy/SOA research brief on risk-mitigation programs under the Affordable Care Act appear to reduce financial risks to health plans but overly restrictive limitations on premium rate increases can lead to high federal risk-corridor payments. (June 4, 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)
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)
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 webinar regarding Affordable Care Act (ACA) information every actuary should know. The webinar presentation provides background on the uninsured and pre-reform markets, key provisions of the ACA, and the current status of the ACA's implementation. (February 10, 2012)
Individual and Small Group Market Task Force comments to the HHS on the essential health benefits bulletin. (January 31, 2012)
Health Practice Council letter to the Assistant Secretary for Planning and Evaluation (ASPE) at HHS providing comments on a research brief, Actuarial Value and Employer-Sponsored Insurance. (January 31, 2012)
The brief addresses a very narrow aspect of the case before the court—the severability of the individual mandate from the other market reform provisions, namely guaranteed issue and modified community rating. The brief does not take a position on the constitutionality of the individual mandate or whether any other provisions in the law are severable from the mandate—nor does it support or oppose the law as a whole. (January 27, 2012)
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)
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)
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)