Health Practice Council comment letter on a revised draft of Colorado Senate Bill 21-169, dated April 21, 2021, aimed to protect consumers from unfair discrimination in insurance practices. This letter follows up on previous Health Practice Council comments on the introduced version of the bill, submitted on March 29, 2021, and again focuses on the potential impact to health insurance.

Financial Reporting and Solvency Committee comment letter to the National Association of Insurance Commissioners (NAIC) Health Actuarial (B) Task Force regarding the proposal to modify the definition of “actuarial assets” as used in the instructions for the Health Statement of Actuarial Opinion.

Health Practice Council comment letter on Colorado Senate Bill 21-169 which is aimed to protect consumers from unfair discrimination in insurance practices. The comments focus on potential impacts to health insurance.

The Health Practice Council submitted a comment letter to the Department of the Treasury, the Department of Labor (DOL), and the Department of Health & Human Services (HHS), on review of agency actions related to the Affordable Care Act and Medicaid, as put forward in a recent presidential executive order. The letter provides references to previous Academy comment letters to agencies regarding relevant proposed rules.

The Individual and Small Group Markets Committee and the Active Benefits Subcommittee submitted comments to the Department of the Treasury, the Department of Labor (DOL), and the Department of Health & Human Services (HHS), on insurance and health plan coverage of COVID-19 testing, as put forward in a presidential executive order, Establishing the COVID-19 Pandemic Testing Board and Ensuring a Sustainable Public Health Workforce for COVID-19 and Other Biological Threats.

Academy President Thomas A. Campbell’s letter of recommendation for Annette V. James as a candidate for appointment to the COVID-19 Health Equity Task Force as put forward in a presidential executive order, Ensuring an Equitable Pandemic Response and Recovery.

The Individual and Small Group Markets Committee and its Risk Sharing Subcommittee comments to the Centers for Medicare & Medicaid Services (CMS) on the Proposed Notice of Benefit and Payment Parameters for 2022.

The Health Practice Council’s Health Equity Work Group comments to the National Association of Insurance Commissioners (NAIC) highlighting their efforts to facilitate solutions to address health disparities.

The Health Practice Council’s Long-Term Care (LTC) Reform Subcommittee Task Force to Review ASOP No. 22 comments on the proposed revision of Actuarial Standard of Practice (ASOP) No. 22, Statements of Actuarial Opinion Based on Asset Adequacy Analysis for Life Insurance, Annuity, or Health Insurance Reserves and Other Liabilities (the "Second Exposure Draft").

Comments from the Individual and Small Group Markets Committee to the Center for Consumer Information & Insurance Oversight (CCIIO) expressing concerns on the claims data updates finalized in the 2021 Actuarial Value (AV) Calculator. These comments are for consideration in preparing the draft 2022 AV Calculator.

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.