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.

The Health Practice Council’s Individual and Small Group Markets Committee and Active Benefits Subcommittee submitted comments to the Internal Revenue Service (IRS) on the proposed rule for “Affordability of Employer Coverage for Family Members of Employees.” The comments relate to provisions addressing the so-called “family glitch,” revisions to the employer coverage affordability test, and the Minimum Value (MV) Calculator.

The Long-Term Care Medicaid Subcommittee submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) on the proposed rule, “Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs.” The comments focused on dual-eligible special needs plans (D-SNP’s) and separate medical loss ratio (MLR) requirements.

Academy President Maryellen Coggins submitted a letter to the Colorado Division of Insurance in advance of the upcoming stakeholder engagement process for the recently passed state law aimed to protect consumers from unfair discrimination in insurance practices. The comments addressed potential concerns of the law’s impact on casualty, health, and life insurance.

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 2023 Actuarial Value (AV) Calculator Methodology.

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.

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.

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. 

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.

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.

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.

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.

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.

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.

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.  

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.

Long-term Care Reform Subcommittee comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care (EX) Task Force regarding the April 9, 2021 exposure draft of the Long-Term Care Insurance Multi-State Rate Review Framework.  

The Financial Reporting and Solvency Committee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Health Actuarial (B) Task Force regarding the definition of “actuarial assets” in the revised proposed instructions for the Health Statement of Actuarial Opinion.