The Pension Committee submitted a comment letter to the Actuarial Standards Board responding to an exposure draft and suggesting modifications to proposed revisions of ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. The Pension Finance Task Force also submitted a letter to the ASB responding to the exposure draft, as did the Joint Committee on Retiree Health whose letter focused on the interaction with retiree group benefits practice.
The Social Security Committee updated an issue brief examining the assumptions used to evaluate Social Security's financial condition. The brief analyzes demographic and economic assumptions used by the federal government and outside experts.
The Joint Committee on Retiree Health submitted comments to the Actuarial Standards Board on the exposure draft for ASOP 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions, requesting clarification on the implications for retiree group benefits.
(May 31, 2012)
The Pension Committee submitted a comment letter to the Actuarial Standards Board responding to an exposure draft of ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. The letter addressed several provisions of the exposure draft, including scope, selection of reasonable assumptions, investment return assumptions, and measurement-specific conditions. The Joint Committee on Retiree Health also submitted a letter, focusing on the interaction of the ASOP to retiree group benefits practice.
The Social Security Committee published a new issue brief examining the significance of the Social Security trust funds from three perspectives: the Social Security system, a unified federal budget, and the whole economy.
The Joint Committee on Retiree Health submitted comments to the Actuarial Standards Board on the exposure draft for ASOP 27, Selection of Economic Assumptions for Measuring Pension Obligations, regarding the implications for retiree group benefits.
(May 31, 2012)
The Medicare Steering Committee updated its annual issue brief that offers an actuarial perspective on Medicare's financial condition and outlines the public policy options to address the program's long-term financial challenges.
(May 22, 2012)The Health Practice Financial Reporting Committee sent comments to the Actuarial Standards Board on revisions to ASOPs 22, Statements of Opinion Based on Asset Adequacy Analysis by Actuaries for Life and Health Insurers and 28, Statements of Actuarial Opinion Regarding Health Insurance Liabilities and Assets.
The Actuarial Value Subgroup sent a letter to CCIIO offering comments on the Actuarial Value and Cost-Sharing Reduction bulletin, specifically addressing the proposed actuarial value calculator. This letter supplements comments submitted April 2 on the cost-sharing inputs for the calculator.
(May 16, 2012)
The cross-practice-Actuarial Soundness Task Force has issued Actuarial Soundness, a Special Report. It provides an overview of the uses of the terms “actuarial soundness” and “actuarially sound” in state and federal legislative and regulatory contexts to inform regulators and the general public of the meanings and implications of these terms.
(May 10, 2012)
The Pension Committee submitted a comment letter to the Internal Revenue Service responding to proposed regulations for longevity annuity contracts. The letter commended the IRS and Treasury Department for focusing on the problem of longevity risk, and recommended modest changes to the proposed regulations to further enhance retirement security.
The Pension Committee submitted a comment letter to the Internal Revenue Service (IRS) responding to proposed regulations for partial annuity distribution options under defined benefit (DB) pension plans, commenting specifically on the proposed structure of Section 417(e) exemptions, and transition issues.
The Medical Loss Ratio Work Group sent a letter to CMS offering comments on the revised annual reporting form, specifically on the definition of premiums, contract reserves, and the definition of pre-tax underwriting gain/(loss).
(May 02, 2012)
The Pension Practice Council submitted a letter to members of the House-Senate Conference Committee commenting on the pension funding stabilization provisions included in S. 1813 as passed by the Senate. The PPC recommended that to the extent the conference committee chooses to include pension funding changes in the final legislation to create more stability in contributions for plan sponsors, this could be accomplished better by smoothing outputs (contribution requirements) rather than inputs (discount rates).
(May 02, 2012)
(May 02, 2012)
COPLFR submitted comments to the NAIC on the Blanks Working Group’s proposed 2012 Actuarial Opinion Instructions.
(May 01, 2012)
The Academy submitted comments to the NAIC on its draft white paper on the Solvency Modernization Initiative and insurance regulation offering suggestions encompassing RBC, ORSA, and NAIC model laws.
(April 30, 2012)
The Financial Regulatory Reform Task Force comments to the Federal Reserve on its proposed rule establishing additional prudential standards to apply to non-bank financial service companies identified by the FSOC as companies that could pose systemic risk. The comments focused on the application of the proposed standards addressing risk based capital, leverage regulations, liquidity standards, risk management processes, counterparty limits, stress test requirements, debt to equity limits, and early remediation to US insurers that currently are under the regulatory supervision of one state functional regulator.
(April 30, 2012)
The Federal Long-Term Care (LTC) Task Force sent a letter to the National Conference of Insurance Legislators in response to a request for information on strategies to reduce costs related to LTC coverage. The task force highlights a number of general approaches that would address both LTC costs and effectiveness.
(April 27, 2012)
The Pension Practice Council published a new issue brief examining the Pension Benefit Guaranty Corporation (PBGC) premium structure and current proposals to revise that structure. The issue brief discusses and differentiates between two categories of costs faced by the PBGC: going-forward costs and legacy costs.
The Health Practice Council and the Committee on Qualifications sent a letter to all state insurance commissioners and chairs of each state house and senate insurance committee regarding the appropriate definition of "Qualified Actuary" as it relates to the Affordable Care Act's rate review provision. Under the Affordable Care Act, the Centers for Medicare and Medicaid Services (CMS) is authorized to determine whether health insurance rate increases filed with states are “unreasonable.” As of September 1, 2011 rate increases equal to or greater than 10 percent may be reviewed by states that have been determined by CMS to have an effective rate review program; otherwise, increases in excess of 10 percent will be reviewed by CMS to determine whether such rate increases are “unreasonable.” As a result, many states are in the process of drafting regulatory language that would create their own rate review program. In the past few months, an inconsistency in the definition of “qualified actuary” in some state regulations has come to the attention of the American Academy of Actuaries. The letter provides recommended language regarding the appropriate definition of qualified actuary as states move to implement the Affordable Care Act’s rate review provision. (April 20, 2012)
