The Long-Term Care (LTC) Committee submitted comments to the NAIC’s Long-Term Care (B) Task Force (LTCAWG) in response to the NAIC Long-Term Care Insurance (B) Task Force’s November 20, 2024, request for comments on the exposure draft of the Long-Term Care Insurance Multistate Rate Review (LTCI MSA) Framework.

The Health Practice Council’s Individual and Small Group Markets Committee submitted comments to the Centers for Medicare & Medicaid Services regarding the proposed rule for the 2026 Notice of Benefit and Payment Parameters.

The Long-Term Care (LTC) Committee submitted comments to the NAIC’s Long-Term Care Actuarial (B) Working Group (LTCAWG) in response to LTCAWG's August 12, 2024, request for comments on Proposals A and B as candidates for a Single LTCI Multistate Rate Review Approach.

The Long-Term Care (LTC) Committee submitted comments to the NAIC’s Long-Term Care Actuarial (B) Working Group (LTCAWG) in response to LTCAWG's July 2 request for comments on the Minnesota approach. 

The Health Practice Council’s Active Benefits Committee and Individual and Small Group Markets Committee responded to the U.S. Senate Committee on Health, Education, Labor and Pensions’ (HELP) request for information regarding portable benefits for self-employed workers and other individuals in nontraditional working arrangements.

The Health Practice Council submitted comments on the exposure draft of Actuarial Standard of Practice (ASOP) No. 12, Risk Classification (for All Practice Areas).

The Academy’s Health, Life, and Casualty practice councils submitted comments on New York State Department of Financial Services’ proposed insurance circular letter on the use of Artificial Intelligence Systems (AIS) and External Consumer Data and Information Sources (ECDIS) in insurance underwriting and pricing. The councils support efforts to curb underwriting and pricing methods that “reflect systemic biases and can reinforce and exacerbate inequality.”

The Health Practice Council’s Health Care Delivery Committee, Individual and Small Group Markets Committee, and Active Benefits Committee responded to the Committee on Health, Education, Labor, and Pensions’ (HELP) request for information on access to gene therapies for patients with an ultra-rare disease.

The Health Practice Council’s Individual and Small Group Markets Committee submitted comments to the Centers for Medicare & Medicaid Services regarding the proposed rule for the 2025 Notice of Benefit and Payment Parameters.

The Individual and Small Group Markets Committee submitted comments to the Centers for Medicare & Medicaid Services’ Center for Consumer Information & Insurance Oversight (CCIIO) on the Draft 2025 Actuarial Value (AV) Calculator Methodology.

The Health Solvency Subcommittee’s Health Underwriting Risk Factors Analysis Work Group sent a letter updating the NAIC’s Health Risk-Based Capital (E) Working Group (HRBC) on progress on the NAIC’s request to comprehensively review the H2—Underwriting Risk Component and the Managed Care Credit Calculation included in the HRBC formula.

The Health Practice Council’s Long-Term Care (LTC) Reform Committee submitted comments to the Office of the State Actuary for the state of Washington on key issues related to LTC financing and risk management. The letter provides information on considerations necessary to achieve and maintain long-term services and supports (LTSS) trust solvency for the WA Cares Fund Program.

The Health Practice Council’s Medicare Committee submitted a comment letter to the Centers for Medicare & Medicaid Services on the draft part one guidance for the Maximum Monthly Cap on Cost-Sharing Payments Program.

The Health Practice Council’s Individual and Small Group Markets Committee, Risk Sharing Subcommittee, and Active Benefits Committee submitted a comment letter to the Department of Health and Human Services (HHS), Department of Labor (DOL), and the Department of the Treasury on the Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Accident and Health Insurance notice of proposed rulemaking (NPRM).

The Health Practice Council’s Medicaid Committee submitted a comment letter to the Centers for Medicare & Medicaid Services’ (CMS) notice of proposed rulemaking (NPRM), Medicaid and Children’s Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality (Managed Care NPRM).

The Committee on Property Liability and Financial Reporting (COPLFR) and the Health Practice Council’s Committee on Financial Reporting and Solvency submitted a comment letter to the National Association of Insurance Commissioners (NAIC) Blanks Working Group on proposed exposure to add instructions for the appointed actuary and qualified actuary contacts to the Jurat electronic only section in order to address any actuarial questions.

The Long-term Care Reform Subcommittee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care Actuarial (B) Working Group featuring an Academy issue brief, Long-Term Care Insurance: Considerations for Treatment of Past Losses in Rate Increase Requests (October 2018), in response to a working group concern about the lack of a consistent definition of “past losses” in the context of recoupment.

The Life Practice Council, Health Practice Council, and Casualty Practice Council submitted a joint comment letter to the Colorado Division of Insurance on its recent exposure of a draft regulation on Governance and Risk Management Framework Requirements for Life Insurance Carriers’ Use of External Consumer Data and Information Sources, Algorithms, and Predictive Models: the first exposed implementation regulation for Colorado Revised Statute (C.R.S.) § 10-3-1104.9, signed into law on July 6, 2021.

The Health Practice Council’s Financial Reporting and Solvency Committee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care Actuarial (B) Working Group inquiring if the Working Group might issue an accounting interpretation for the interaction between Actuarial Guideline LI (AG 51) and Appendix A-010.

The Health Solvency Subcommittee sent a comment letter responding to a request from the NAIC’s Health Risk-Based Capital (E) Working Group to provide additional investment return scenarios within the subcommittee’s summary of the Investment Income Adjusted Health H2 Experience Fluctuation Risk Factors.