The Health Practice Council’s Individual and Small Group Markets Committee, Risk Sharing Subcommittee, and Health Equity Work Group submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) on CMS’ proposed rule for the 2023 Notice of Benefit and Payment Parameters (NBPP). The letter addresses network adequacy, standardized plan options, several provisions on health equity, updating quality improvement strategy standards and other topics.
(January 26, 2022)The ERM/ORSA Committee's comments submitted to the IAIS as part of the association's Public Consultation on the Development of Liquidity Metrics: Phase 2.
(January 24, 2022)Comment letter submitted to NAIC’s Climate and Resiliency (EX) Task Force. The comment letter from the Academy’s Climate Change Joint Task Force addresses an exposed proposal by the NAIC for a new climate disclosure, based on the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) guideline and includes a series of observations and three specific suggestions. The comments are based on research conducted by the Academy’s Climate-related Financial Disclosures Work Group.
(January 13, 2022)Climate Related Financial Disclosures Work Group report submitted to the NAIC’s Climate and Resiliency (EX) Task Force. This accompanies a comment letter from the Academy’s Climate Change Joint Task Force that addresses an exposed proposal by the NAIC for a new climate disclosure, based on the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) guideline and includes a series of observations and three specific suggestions. The report and associated comment letter to the NAIC are based upon research conducted by the Academy’s Climate-related Financial Disclosures Work Group.
(January 13, 2022)The C-2 Longevity Risk Work Group's comments to the National Association of Insurance Commissioners’ Longevity Risk (A/E) Subgroup on reserve implications of expanding the scope of C-2 Longevity Risk-Based Capital requirements to include longevity reinsurance contracts in the proposed Principle-Based Reserving framework.
(December 21, 2021)The Academy sent a letter to the chairs of the National Association of Insurance Commissioners’ (NAIC’s) Life Actuarial (A) Task Force and Life Risk-Based Capital (E) Working Group indicating an “as-is” availability of its economic scenario generator, the Academy Interest Rate Generator (AIRG) for those regulators and interested parties wishing to modify the AIRG parameters as a basis for producing an updated model.
(December 17, 2021)The Life Underwriting and Risk Classification Work Group's comments to the NAIC’s Accelerated Underwriting (A) Working Group on its paper summarizing the output of the working group’s recommendations and assessment to understand the current state of the life insurance industry and its use of accelerated underwriting.
(December 03, 2021)A Life Practice Council ad-hoc task force submitted comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on a proposed actuarial guideline (AG) regarding asset adequacy testing.
(December 02, 2021)The Variable Annuity Reserves and Capital Work Group's comments to the Life Actuarial Task Force on amendment proposal form (APF) 2021-11 regarding the proposed assumption disclosure requirements in VM-31.
(December 01, 2021)
The Risk Sharing Subcommittee submitted comments to the Centers for Medicare & Medicaid Services (CMS) Center for Consumer Information and Insurance Oversight (CCIIO) on the HHS-Operated Risk Adjustment Technical Paper on Possible Model Changes, exposed for comment on Oct. 26, 2021.
(November 24, 2021)Climate Change Joint Task Force comments to the U.S. Department of the Treasury and Federal Insurance Office (FIO) request for information (RFI) relating to regarding FIO's future work relating to the insurance sector and climate-related financial risks.
(November 15, 2021)The HEWG sent a comment letter to the NAIC’s Special (EX) Committee on Race and Insurance – Workstream 5 (Health) on the exposure draft of the Principles for Data Collection document. The revised draft was exposed on October 15, 2021, with comments due November 15.
(November 15, 2021)Comments developed by a task force of the Life Practice Council to the Actuarial Standards Board (ASB) on the exposure draft of Actuarial Standard of Practice (ASOP) No. 24.
(November 09, 2021)The Health Equity Work Group sent a comment letter to the NAIC’s Special (EX) Committee on Race and Insurance – Workstream 5 (Health) on the exposure draft of the White Paper on Provider Network outline.
(November 05, 2021)The Committee on Property and Liability Financial Reporting (COPLFR) sent an updated version of its comment letter to the National Association of Insurance Commissioners (NAIC) Blanks Working Group on proposed changes to P/C annual statements. Many of the Committee’s previous comments stand unchanged but were edited in response to the modified exposure draft.
(October 21, 2021)Comments from the Pension Committee, Multiemployer Plans Committee, and Public Plans Committee to the Actuarial Standards Board regarding the third exposure draft of Actuarial Standard of Practice No. 4, Measuring Pension Obligations and Determining Pension Costs or Contributions.
(October 18, 2021)LTC Reform Subcommittee comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care Insurance (EX) Task Force regarding the exposure drafts of the operational and actuarial sections of the Long-Term Care Insurance Multi-State Rate Review Framework released September 10 and September 15, 2021.
(October 08, 2021)Pension Committee comment letter responding to Financial Accounting Standards Board’s (FASB) June 2021 Invitation to Comment on its future standard-setting agenda.
(September 22, 2021)Health Care Delivery Committee and its Telehealth Work Group comments to the Centers for Medicare & Medicaid Services (CMS) on CMS’ proposed rule on Medicare, payment policies, and enrollment regulation updates.
(September 13, 2021)Long-term Care Reform Subcommittee comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care Insurance Reduced Benefit Options (EX) Subgroup regarding the July 22, 2021 exposure draft, Issues Related to LTC Wellness Benefits.
(September 03, 2021)Multiemployer Plans Committee letter to Pension Benefit Guaranty Corporation (PBGC) submitted in response to PBGC’s request for comments on its Interim Final Rule regarding Special Financial Assistance pursuant to the American Rescue Plan Act of 2021.
(August 11, 2021)The Individual and Small Group Markets Committee and its Risk Sharing Subcommittee comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed rule, Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond.
(July 28, 2021)Automobile Insurance Committee comments to the U.S. Department of the Treasury and Federal Insurance Office (FIO) request for information (RFI) relating to regarding FIO's future work relating to monitoring the availability and affordability of automobile (auto) insurance.
(July 26, 2021)Long-term Care Reform Subcommittee comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care (EX) Task Force regarding the June 10, 2021 exposure draft of the actuarial sections within the Long-Term Care Insurance Multi-State Rate Review Framework.
(July 26, 2021)Multiemployer Plans Committee comments to U.S. Department of the Treasury and Internal Revenue Service (IRS) relating to implementation of the multiemployer pension plans temporary funding relief provisions of the American Rescue Plan Act of 2021 (ARPA).
(July 23, 2021)Pension Committee comments to U.S. Department of the Treasury and Internal Revenue Service (IRS) relating to single-employer pension funding relief provisions enacted under the American Rescue Plan Act of 2021 (ARPA).
(July 23, 2021)The Annuity Reserves and Capital Work Group’s (ARCWG) proposed draft of revised NAIC VM-22 requirements for fixed annuity principle-based reserving framework. The following draft includes a version demonstrating the changes to the current VM-22 framework as well as a clean version of the document.
(July 16, 2021)
The Committee on Property and Liability Financial Reporting (COPLFR) sent a comment letter to the National Association of Insurance Commissioners (NAIC) Casualty Actuarial and Statistical (C) Task Force on proposed changes to P/C annual statements. The letter addresses such areas as definition of exposure, calendar date alignment, and existing alternative data sources.
(July 06, 2021)The Data Science and Analytics Committee submitted comments in response to a joint request for information and comment from several federal agencies regarding financial institutions’ use of artificial intelligence (AI) and machine learning.
(June 30, 2021)The Health Practice Council’s Individual and Small Group Markets Committee and the Active Benefits Subcommittee comments to the Departments of Health & Human Services, Labor, and the Treasury as the agencies develop proposed rules related to the recently enacted No Surprises Act pertaining to surprise medical billing.
(June 25, 2021)
