Premium Review Work Group letter to HHS providing an evaluation of several potential methods for defining or measuring unreasonable rate increases. (
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Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC B Committee regarding the October 4 exposure draft of the proposed MLR rebate regulation. (
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Joint Committee on Retiree Health and the Pension Accounting Committee joint comments to the NAIC regarding the exposure draft of SSAP 92 (OPEBs) and proposed revisions to SSAP 89 (pensions). (
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Deferred Tax Asset DTA Bridge Group request for an interim report to the NAIC Capital Adequacy Task Force showing the appropriate treatment of the Deferred Tax Asset (DTA) in the Risk-Based Capital formulas for Life, Property / Casualty (P&C), and Health. (
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Risk Sharing Work Group letter to HHS regarding the ACA reinsurance provision that references the Academy. The letter includes initial input on potential approaches for identifying high-risk individuals and determining reinsurance payments. (
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Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on ACA provisions that eliminate lifetime limits, restrict annual limits, eliminate preexisting condition exclusions, and prohibit rescissions. (
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Medical Loss Ratio Regulation Work Group letter to HHS with input on credibility issues for the purpose of calculating rebates under the new MLR requirements. (
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Grandfathering Provisions Work Group letter to HHS in response to an interim final rule on the ACA provision related to the status of health insurance coverage as a grandfathered plan. (
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Premium Review Work Group letter regarding Massachusetts Senate Bill 2447, which includes a provision that would limit rate increases to medical CPI. (
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Premium Review Work Group comment letter on the NAIC's exposure draft of a rate-filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS. (
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Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on the PPACA provision that extends dependent coverage to age 26. (
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Health Solvency Work Group comment letter to the chair of the NAIC's Capital Adequacy Task Force regarding the evaluation of the current health risk-based capital covariance formula calculation for potential changes to the calculation or methodology. (
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Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Accident and Health Working Group offering input on the potential inclusion of a change in contract reserves in the numerator of the MLR rebate calculation. (
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Joint Committee on Retiree Health letter to the Department of Health and Human Services in response to an interim final rule on the PPACA provision that creates a temporary reinsurance program for early retirees. (
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Medical Loss Ratio Regulation Work Group letter to the NAIC responding to a request for more information on defining statistical credibility within the MLR rebate process as provided in a previous letter.
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Health Care Reform Solvency Impact Subgroup on an exposure draft of a new proposed financial reporting exhibit the Supplemental Health Care Exhibit. (
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Medical Loss Ratio Regulation Work Group letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that requires medical loss ratio reporting and rebates. (
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