The Risk Sharing Subcommittee filed comments with the Department of Health and Human Services and the Centers for Medicare and Medicaid Services on exposed Amendments to the HHS-Operated Risk Adjustment Data Validation Under the Patient Protection and Affordable Care Act’s HHS-Operated Risk Adjustment Program. 

The Health Practice Council and its Task Force to Review Actuarial Standard of Practice (ASOP) 11 filed a comment on the Actuarial Standards Board exposure draft, Reinsurance Involving Life Insurance, Annuities, or Health Benefit Plans in Financial Reports.

The Health Solvency Subcommittee submitted a response letter to the NAIC Health Risk-Based Capital (HRBC) Working Group for their request to provide the health bond factors over a range of additional time horizons - spanning one to five years. 

Comments of the Individual and Small Group Markets Committee and Risk Sharing Subcommittee on the proposed rule for the 2020 Notice of Benefit and Payment Parameters (NBPP).

The Medicaid Subcommittee submitted comments on the proposed rule, Medicaid Fiscal Accountability Regulation (MFAR).

Individual and Small Group Markets Committee comments on the September 30, 2019 bulletin, Opportunity for States to Participate in a Wellness Program Demonstration Project to Implement Health-Contingent Wellness Programs in the Individual Market.

Risk Sharing Subcommittee comments on the HHS Risk Adjustment Validation (RADV) White Paper, released on December 6, 2019.

Individual and Small Group Markets Committee sent comments to Centers for Medicare & Medicaid Services on rules finalized in the 2020 Notice of Benefit and Payment Parameters (NBPP) concerning risk adjustment data validation (RADV)-related transfers.

The Health Solvency Subcommittee sent comments to the NAIC Health Risk-Based Capital (HRBC) Working Group on the comment letters received on the exposure of the Draft Bond Structure and Instructions.

Members of the LTC Reform Subcommittee submitted comments following their discussion with the Federal Interagency Task Force on Long-Term Care Insurance (LTCI) earlier this year. These comments reiterate and expand on their original discussion including addressing regulatory hurdles to innovation.