The Health Practice Council’s Long-Term Care (LTC) Reform Committee submitted comments to the Office of the State Actuary for the state of Washington on key issues related to LTC financing and risk management. The letter provides information on considerations necessary to achieve and maintain long-term services and supports (LTSS) trust solvency for the WA Cares Fund Program.

The Health Practice Council’s Medicare Committee submitted a comment letter to the Centers for Medicare & Medicaid Services on the draft part one guidance for the Maximum Monthly Cap on Cost-Sharing Payments Program.

The Health Practice Council’s Individual and Small Group Markets Committee, Risk Sharing Subcommittee, and Active Benefits Committee submitted a comment letter to the Department of Health and Human Services (HHS), Department of Labor (DOL), and the Department of the Treasury on the Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Accident and Health Insurance notice of proposed rulemaking (NPRM).

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).