The brief addresses a very narrow aspect of the case before the court—the severability of the individual mandate from the other market reform provisions, namely guaranteed issue and modified community rating. The brief does not take a position on the constitutionality of the individual mandate or whether any other provisions in the law are severable from the mandate—nor does it support or oppose the law as a whole. (
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Health Practice Council and Committee on Qualifications letter to the Arizona insurance director pointing out that their regulatory definition of “qualified actuary” for health premium actuarial certifications was inappropriate and suggested corrective language. (
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Risk Sharing Work Group comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule implementing the risk-spreading mechanisms included in the Affordable Care Act (ACA) and related to reinsurance, risk corridors, and risk adjustment. (
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Exchanges Work Group comments to CMS in response to proposed regulations establishing health insurance exchanges and qualified health plans under the ACA. (
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Actuarial Value Subgroup issue brief offering an overview of the concept of actuarial value, and insight into the calculation of actuarial value under the Affordable Care Act. (
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Co-chairperson of the Joint Academy/Society of Actuaries CLASS Act Task Force Steve Schoonveld presentation on the Community Living Assistance Supports and Services (CLASS) program before the National Conference of Insurance Legislators (NCOIL) Summer Meeting in Newport, RI. (
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Premium Review Work Group comments to CMS in response to the revised preliminary justification and consumer disclosure forms for purposes of rate review disclosure and reporting requirements. (
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Health Practice Council fact sheet providing an overview of the Medicare Shared Savings Program and how accountable care organizations (ACOs) are addressed in the Affordable Care Act. (
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Health Care Quality Work Group issue brief offering an actuarial perspective on accountable care organizations (ACOs) and outlining a number of issues that stakeholders should evaluate as ACOs are implemented. (
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Health Care Quality Work Group comments to CMS in response to proposed regulations on accountable care organizations and the Medicare Shared Savings Program under the Affordable Care Act. (
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Premium Review Work Group comments to CMS in response to a notice on rate increase disclosure and review reporting requirements. (
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Exchanges Work Group comments to the National Assocation of Insurance Commissioners (NAIC) Exchanges (B) Subgroup regarding its white paper on adverse selection and exchanges created through the Affordable Care Act. (
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Community Living Assistance Services and Supports (CLASS) Act Task Force testimony to the U.S. House Committee on Energy and Commerce Subcommittee on Health regarding the CLASS program. (
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CO-OP Subgroup letter to HHS in response to its request for comments on the consumer operated and oriented plan programs (CO-OPs). (
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Premium Review Work Group comments to HHS in response to proposed regulations on rate increase disclosure and review. (
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Medical Loss Ratio Regulation Work Group letter to HHS in response to an interim final rule on the medical loss ratio (MLR) provisions in the Affordable Care Act. (
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Medical Loss Ratio Regulation Work Group letter to HHS addressing three components of the NAIC's proposed regulation on medical loss ratios: credibility adjustments, exclusion of federal taxes from the denominator, and the use of three months' runout. (
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Premium Review Work Group comment letter on the NAIC Health Insurance and Managed Care (B) Committee'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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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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