The Health Practice Council’s Medicaid Committee submitted a comment letter to the Centers for Medicare & Medicaid Services’ (CMS) notice of proposed rulemaking (NPRM), Medicaid and Children’s Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality (Managed Care NPRM).
( )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 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.
( )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 sent comments responding to the Centers for Medicare & Medicaid Services’ (CMS) request for information (RFI) that was seeking public comment on the Medicare Advantage program. The committee specifically focused on the health equity aspects of the questions posed within the RFI.
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