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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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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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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Medicare Subcommittee letter to the Senate Finance Committee with comments on the Bipartisan Chronic Care Working Group’s Policy Options Document. (
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Risk Sharing Subcommittee letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule on benefit and payment parameters for 2017. (
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Medicare Supplemental Work Group responses to questions regarding the work group’s recommendations on modifications to the Medicare supplement refund formula.
( )Health Solvency Subcommittee updated on the evaluation of asset risk in the health risk-based capital (HRBC) formula.
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Financial Reporting and Solvency Committee comment letter to the NAIC's Emerging Accounting Issues (E) Working Group on the “ACA Risk Corridors Collectability” exposure draft. (
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Active Benefits Subcommittee letter to the IRS regarding Notice 2015-52 on the excise tax for high-cost employer-sponsored health coverage under the Affordable Care Act (ACA). (
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Premium Review Work Group letter to CCIIO with suggested changes to the unified rate review template (URRT) and rating methodology. (
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Medicaid Subcommittee comment letter to Centers for Medicare and Medicaid Services (CMS) on proposed rules about Medicaid and Children’s Health Insurance Program (CHIP) Programs; Medicaid managed care, CHIP delivered in managed care, Medicaid and CHIP comprehensive quality strategies, and revisions related to third party liability. (
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The Casualty Practice Council, Health Practice Council, Life Practice Council, and Risk Management and Financial Reporting Council comments to the National Association of Insurance Commissioners (NAIC) on its Financial Condition (E) Committee questionnaire that examines the reasons for single-state solutions to help regulators develop a process for creating a uniform framework for state-based regulation. (
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