The Multiemployer Plans Committee submitted comments to the Pension Benefit Guaranty Corporation (PBGC) regarding simplified methods and other aspects of computing withdrawal liability under the Multiemployer Pension Reform Act of 2014.
(April 05, 2019)Medicare Subcommittee comments on the proposed rule regarding the removal of safe harbor protection for rebates involving prescription pharmaceuticals and the creation of new safe harbor protections.
(April 03, 2019)The Academy responded in writing to questions from the House Subcommittee on Health, Education, Labor, and Pensions as a follow-up to the panel’s March 7 hearing, “The Cost of Inaction: Why Congress Must Address the Multiemployer Pension Crisis,” at which Josh Shapiro, the Academy’s vice president, pension, testified.
(March 29, 2019)Life Practice Council letter to Life Actuarial (A) Task Force on concerns with the NAIC moving in a direction that would deviate from principle-based approach for life insurance.
(March 19, 2019)Premium Review Work Group comments on the recently released final Unified Rate Review Template (URRT) and Instructions. (March 12, 2019)
Life Illustrations Work Group letter addressing questions raised by the NAIC's IUL Illustration (A) Subgroup. (March 07, 2019)
Lifetime Income Risk Joint Committee, Retirement System Assessment and Policy Committee (RSAP) and Social Security Committee comment letter to the Bipartisan Policy Center on the 2016 Report of the Commission on Retirement Security and Personal Savings.
(February 21, 2019)Individual and Small Group Markets Committee and Risk Sharing Subcommittee comments on the proposed rule for the 2020 notice of benefit and payment parameters (NBPP). (February 18, 2019)
Life Reserves Work Group comment letter to the Life Actuarial (A) Task Force regarding exposed APF 2019-04, which seeks to provide clarification for expense allowance formulas for universal life with secondary guarantee (ULSG). (February 18, 2019)
RBC Tax Reform Work Group comment letter to NAIC Life Risk-Based Capital Working Group on their exposed guidance document on the interpretation of 2018 Life Risk-Based Capital Results. (February 18, 2019)
Life Experience Committee comment letter to Life Actuarial (A) Task Force on questions raised during the NAIC Fall 2018 National Meeting rearding the current process used to develop the AG38 and VM-20 annual mortality improvement scale recommendations. (February 18, 2019)
A comment letter from Mary D. Miller, on behalf of the American Academy of Actuaries, pertaining to the Executive (EX) Committee's Ad Hoc commissioner group’s proposed changes of the Property and Casualty 2019 Actuarial Opinion Instructions, including the Ad Hoc Group's draft qualified actuary definition. (February 14, 2019)
A comment letter to the Casualty Actuarial and Statistical (C) Task Force (CASTF) from Mary D. Miller, on behalf of the American Academy of Actuaries, pertaining to the CASTF 's draft qualification and related documentation requirements and copy of a letter to the Executive (EX) Committee's Ad Hoc commissioner group’s proposed changes of the Property and Casualty 2019 Actuarial Opinion Instructions, including the Ad Hoc Group's draft qualified actuary definition. (February 14, 2019)
Role of the Actuary Subgroup comment letter to NAIC on the use of the terms "actuary" and "qualified actuary" in draft revisions to VM-21. (February 12, 2019)
Life Reinsurance Work Group comment letter to NAIC on APF 2018-58, which provides guidance for determination of future nonguaranteed yearly renewable term reinsurance rates under VM-20. (January 30, 2019)
Academy senior casualty fellow Rich Gibson's comments to the NAIC's Casualty Actuarial and Statistical Task Force regarding exposure draft of white paper on Regulatory Review of Predictive Models. (January 21, 2019)
Medicaid Subcommittee letter to CMS providing comments on Nov. 14, 2018 proposed rule regarding Medicaid and CHIP managed care programs. (January 13, 2019)
Role of the Actuary Subgroup comment letter to NAIC on the treatment and definitions of the term "actuarial opinion" in VM-30. (January 09, 2019)
Life Reserves Work Group comment letter to the Life Actuarial (A) Task Force on amendment proposal form (APF) 2018-44, regarding credited amounts for indexed accounts. (January 01, 2019)
Retirement System Assessment and Policy Committee comment letter to the Department of Labor's proposed rule on the Definition of Employer under Section 3(5) of the Employee Retirement Income Security Act (ERISA). (December 20, 2018)
Academy Pension Vice President letter to U.S. House members on The Retirement, Savings, and Other Tax Relief Act of 2018 (December 19, 2018)
Committee comments on the Oct. 22, 2018 guidance from the Department of the Treasury and the Department of Health and Human Services on State Relief and Empowerment Waivers under Section 1332 of the Affordable Care Act (ACA), focusing on three areas: evaluation of coverage comprehensiveness and affordability, evaluation of coverage, and waiver funding. (December 17, 2018)
Council letter to the Centers for Medicare and Medicaid Services (CMS) in response to its request for comments on proposed rules pertaining to the Medicare Advantage (MA) program, including provisions to revise the risk adjustment data validation (RADV) payment error calculation methodology and process. (December 16, 2018)
Committees comment on the proposed rule regarding Health Reimbursement Arrangements (HRAs), that would create two new types of HRAs—Integrated HRAs and Excepted Benefit HRAs—which would allow employers to provide HRAs that could be used to pay for individual plan premiums and out-of-pocket health costs. (December 12, 2018)
Non-Guaranteed Elements Work Group comment letter to NAIC on their proposal for a life insurance online guide landing page. (November 27, 2018)
Retirement System Assessment and Policy Committee letter to Congress on the Retirement Enhancement and Savings Act of 2018. (November 15, 2018)
Letter from Academy Past President Mary D. Miller to NAIC with comments on CASTF’s draft 3-year experience proposal. (November 07, 2018)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) regarding the Risk-based Global Insurance Capital Standard Version 2.0 (ICS 2.0) public consultation document dated July 31, 2018. (October 29, 2018)
Life Operational Risk Work Group follow-up letter to NAIC on exposed Life Risk-Based Capital growth charge proposal. (October 28, 2018)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) regarding the Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame) public consultation document dated July 31, 2018. (October 18, 2018)
