Joint Property and Casualty Risk-Based Capital Committee and Health Solvency Subcommittee letter to the NAIC's Operational Risk Subgroup on proposed changes to the operational risk factor in risk-based capital (RBC) formulas for property/casualty and health. (
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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. (
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Health Practice Council letters to both the U.S. House and Senate on potential adverse consequences of repealing provisions of the Affordable Care Act (ACA) without having a replacement approach in place, and the challenges faced by eliminating the reimbursements to insurers for cost-sharing reduction subsidies.
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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 2018 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, market reforms, and rate review provisions. (
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Health Practice Council letters to both the U.S. House and Senate on potential adverse consequences of legislation to weaken the Affordable Care Act’s (ACA) individual mandate. (
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LTC Reform Subcommittee comment letter to the Maryland Insurance Administration Public Hearing on Long-Term Care Insurance. (
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Risk Sharing Subcommittee letter to the Centers for Medicare & Medicaid Services (CMS) with comments on its recent discussion paper, HHS-Operated Risk Adjustment Methodology. The letter includes comments on partial year enrollment, use of pharmacy data, use of concurrent versus prospective model, high-risk enrollee pooling, recalibration of the model, and the transfer formula. (
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Health Care Receivables Factors Work Group recommendation on credit risk factors for health care receivables to the NAIC’s Health Risk Based Capital (E) Work Group. (
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Premium Review Work Group letter to CCIIO with comments on the 2017 unified rate review template (URRT). (
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Health Solvency Subcommittee letter to the NAIC’s Health Risk-Based Capital (E) Working Group with comments on Proposal 2016-01-H’s individual premiums and claims footnote. (
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