Health Comments and Letters

Health Practice Council comments to the U.S. House and Senate on the potential inclusion of individual mandate repeal in The Tax Cuts and Jobs Act. (December 12, 2017)
Risk Sharing Subcommittee and Premium Review Work Group letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule for the 2019 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, special enrollment periods, essential health benefits, minimum essential coverage, and medical loss ratios.
(November 27, 2017)
Health Practice Council comments to the U.S. Senate on a proposal in the Tax Cuts and Jobs Act to eliminate the ACA's individual mandate. (November 21, 2017)
Health Practice Council comments on the October 12 executive order. (November 7, 2017)
Health Practice Council comments on the Graham-Cassidy-Heller-Johnson Proposal (GCHJ), legislation that would make revisions to the individual health insurance market and approaches to federal Medicaid funding. (September 22, 2017)
Health Practice Council letter to the U.S. Senate HELP Committee on stabilizing the individual health insurance market. (September 12, 2017)
Comment letter submitted jointly by the P/C RBC Committee and the Health Solvency Subcommittee regarding changes to corporate bond factors being considered by the NAIC’s Investment Risk-Based Capital Working Group. (July 25, 2017)
Health Practice Council letter to the U.S. Senate on potential adverse consequences of legislation to eliminate the Affordable Care Act’s (ACA) individual mandate. (July 25, 2017)
Health Financial Reporting and Solvency Committee comments to NAIC Statutory Accounting Principles Working Group in Form A Maintence Maintenance Agenda Submission Form. (July 7, 2017)
Indivdiual and Small Group Markets Committee and Medicaid Subcommittee comments on the Better Care Reconciliation Act (BCRA) of 2017, the proposed legislation to repeal and replace provisions in the Affordable Care Act. (June 30, 2017)
Medicare Subcommittee comments to House Ways and Means Health Subcommittee on preserving and strengthening the Medicare program.
(June 1, 2017)
Health Practice Council comments to Senate Finance Committee on improving the individual health insurance market and changing the approach to Medicaid funding.
(May 23, 2017)
Stop-Loss Work Group comments to the NAIC’s Capital Adequacy (E) Task Force concerning calibration of risk factors in the Stop-Loss Factors Report. (May 9, 2017)
Premium Review Subgroup comments to the Center for Consumer Information and Insurance Oversight on the final 2018 unified rate review template (URRT) instructions. (April 27, 2017)
Indivdiual and Small Group Markets Committee and Medicaid Subcommittee comments on H.R. 1628, the American Health Care Act, the proposed legislation to repeal and replace provisions in the Affordable Care Act. (March 22, 2017)
Individual and Small Group Markets Committee comments to the U.S. House Committee on Education and the Workforce on  H.R. 1101, the Small Business Health Fairness Act, related to association health plans.
(March 8, 2017)
Individual and Small Group Markets Committee letter to the Centers for Medicare & Medicaid Services regarding the proposed rule for market stabilization. (March 7, 2017)
Health Financial Reporting and Solvency Committee comments to the Long-Term Care Valuation (B) Subgroup on asset treatment for stand-alone LTC asset adequacy analysis. (January 26, 2017)
LTC Reform Subcommittee comment letter to the Maryland Insurance Administration Public Hearing on Long-Term Care Insurance. (January 6, 2017)
GASB 74 Implementation Work Group comments on the GASB 74 implementation guide exposure draft that addresses financial reporting for postemployment benefit plans other than pension plans. (December 19, 2016)