Health

The Committee on Property Liability and Financial Reporting (COPLFR) and the Health Practice Council’s Committee on Financial Reporting and Solvency submitted a comment letter to the National Association of Insurance Commissioners (NAIC) Blanks Working Group on proposed exposure to add instructions for the appointed actuary and qualified actuary contacts to the Jurat electronic only section in order to address any actuarial questions.

The Active Benefits Committee released an issue brief focusing on the role of actuaries in employee benefits for health policy development.

The Medicare Committee released an issue brief focusing on the near and long-term financing challenges facing the Medicare program based on the 2023 Medicare Trustees Report.

The Long-term Care Reform Subcommittee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care Actuarial (B) Working Group featuring an Academy issue brief, Long-Term Care Insurance: Considerations for Treatment of Past Losses in Rate Increase Requests (October 2018), in response to a working group concern about the lack of a consistent definition of “past losses” in the context of recoupment.

The Life Practice Council, Health Practice Council, and Casualty Practice Council submitted a joint comment letter to the Colorado Division of Insurance on its recent exposure of a draft regulation on Governance and Risk Management Framework Requirements for Life Insurance Carriers’ Use of External Consumer Data and Information Sources, Algorithms, and Predictive Models: the first exposed implementation regulation for Colorado Revised Statute (C.R.S.) § 10-3-1104.9, signed into law on July 6, 2021.

The Health Practice Council’s Financial Reporting and Solvency Committee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care Actuarial (B) Working Group inquiring if the Working Group might issue an accounting interpretation for the interaction between Actuarial Guideline LI (AG 51) and Appendix A-010.

The Health Solvency Subcommittee sent a comment letter responding to a request from the NAIC’s Health Risk-Based Capital (E) Working Group to provide additional investment return scenarios within the subcommittee’s summary of the Investment Income Adjusted Health H2 Experience Fluctuation Risk Factors.

The Health Practice Council’s Individual and Small Group Markets Committee and Risk Sharing Subcommittee submitted a comment letter to the Centers for Medicare & Medicaid Services’ (CMS) proposed rule for the 2024 Notice of Benefit and Payment Parameters (NBPP).

The Individual and Small Group Markets Committee submitted comments to the Centers for Medicare & Medicaid Services’ Center for Consumer Information & Insurance Oversight (CCIIO) on the Draft 2024 Actuarial Value (AV) Calculator Methodology.

Health Solvency Subcommittee Chairperson Derek Skoog provided an update to the NAIC’s Health Risk-Based Capital (E) Working Group at the NAIC’s Fall 2022 National Meeting in Tampa, FL, on the H2—underwriting risk component and the managed care credit calculation in the health risk-based capital formula.

Academy Health Practice Council (HPC) Vice President, Barb Klever, provided an update on HPC activities to the National Association of Insurance Commissioners (NAIC) Health Actuarial (B) Task Force during their virtual meeting in lieu of the 2022 Fall National Meeting.

Presentation at the National Association of Insurance Commissioners (NAIC) Affordable Care Act (ACA) State Rate Review Discussion Meeting on Considerations for Calculating Cost-Sharing Reduction (CSR) Premium Load Factors.

The Medicaid Committee released a public policy issue brief providing an overview of Medicaid managed care state-directed payments. The brief discusses: how these payments have evolved from supplemental and pass-through payments; recent changes to federal guidance governing them; and recommendations from the Medicaid and CHIP Payment and Access Commission (MACPAC).

The Individual and Small Group Markets Committee and its Risk Sharing Subcommittee submitted a letter to the CCIIO on cost-sharing reduction (CSR) premium load factors. The letter was also submitted to state regulators and legislators. The letter first discusses using actual experience data/issuer pricing models to develop the load factor. It then discusses a method using federal actuarial value (AV) levels to develop the load and potential drawbacks of this approach.

The Health Equity Committee released a public policy issue brief on health care and health insurance system risk assessment and risk adjustment in the context of health equity. Risk assessment and risk adjustment are valuable tools that are used for a variety of purposes and are being reexamined to understand whether and how they should incorporate social risk factors.