The Rate Review Practice Note Work Group submitted comments to the Center for Consumer Information and Insurance Oversight (CCIIO) on a second draft of revisions to the Unified Rate Review Template (URRT) and actuarial memorandum instructions. (
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In a Jan. 6 letter to the National Association of Insurance Commissioners’ (NAIC) Joint Qualified Actuary subgroup, American Academy of Actuaries President Tom Terry provides comments on a uniform definition of “qualified actuary” for life, health, and property/casualty appointed actuaries signing prescribed NAIC Statements of Actuarial Opinion. (
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Rate Review Practice Note Work Group letter to the Center for Consumer Information and Insurance Oversight (CCIIO) with comments on a new proposed list of changes to the Unified Rate Review Template (URRT) for quarterly 2014 and annual 2015 filings. The letter also reiterates several other technical comments on the URRT and the actuarial memorandum instructions. (
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Health Practice Council letter to HHS in response to the proposed rule on benefit and payment parameters for 2015, specifically addressing composite rating, proposed changes to the actuarial value calculator and methodology, and the three risk-sharing mechanisms. (
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Rate Review Practice Note Work Group letter to the Center for Consumer Information and Insurance Oversight (CCIIO) highlighting several technical comments on the current versions of the Unified Rate Review Template and the actuarial memorandum instructions. (
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Health Practice Council letter to members of Congress on potential consequences of proposals that would modify ACA provisions regarding plan cancellations in the individual and small group health insurance markets.
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State Long-Term Care Task Force comment letter to the NAIC's Long-Term Care Valuation Subgroup regarding proposed changes to the NAIC's Health Insurance Reserves Model Regulation. (
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Health Practice Council letter to members of Congress on potential adverse consequences of delaying the Affordable Care Act's (ACA) individual mandate and/or extending its open enrollment period. (
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Pension Committee, Joint Committee on Retiree Health, and Pension Finance Task Force letter to the Actuarial Standards Board (ASB) on coordinating Actuarial Standards of Practice (ASOPs) involving retirement benefits. (
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Health Solvency Work Group response letter to questions raised by the NAIC's Health RBC Working Group regarding the HSWG's model that examines administrative expenses within the context of business concentration risk. (
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MLR Work Group comments to CMS that reiterate previous comments on the proposed rule implementing medical loss ratio (MLR) requirements for Medicare Advantage (MA) and Medicare prescription drug (Part D) programs. (
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Joint Committee on Retiree Health comments to the Actuarial Standards Board on revisions to a second exposure draft of ASOP No. 6, Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Program Periodic Costs or Prefunding Contributions. (
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Health and Pension Practice Council letter to the Actuarial Standards Board on coordinating Actuarial Standards of Practice (ASOP) affecting pension and retiree group benefits. (
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The Solvency Committee submitted comments to the NAIC on its revised version of a draft white paper on the Solvency Modernization Initiative and insurance regulation. (
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Risk Sharing Work Group comments to HHS on the interim final rule implementing amendments to the Notice of Benefit and Payment Parameters final rule. (
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Comments to CMS on the proposed rule implementing MLR requirements for Medicare Advantage (MA) and Medicare prescription drug (Part D) programs. (
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Senior Health Fellow Cori Uccello's suggested language on actuarial value to the NAIC Consumer Information SUbgroup for inclusion in a "frequently asked questions" document. (
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Medical Loss Ratio Work Group's comments to HHS on a proposed rule that requires issuers to offer a new type of individual health insurance policy covering contraceptive benefits. The comments focus only on the effect of the proposed rule on the MLR calculation. (
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Casualty, Health, Life, and Professionalism Council comments to the NAIC’s Joint Qualified Actuary (A/B/C) Subgroup in response to its request for comments to a list of nine questions in anticipation of the Subgroup’s meeting at the NAIC Spring National Meeting on April 5, 2013.
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Long-Term Care Terminations Work Group letter to the NAIC regarding the formation of the work group that is charged with gathering data on terminations in long-term care insurance, and outlines its proposed tasks and timelines. (
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