Health Reform & ACA Implementation
Implementation of the Affordable Care Act and other health care reform issues.

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Health Reform & ACA Implementation Resources
Comment / Letter
Work Group Comments on Amendment to Benefit and Payment Parameters Rule
Risk Sharing Work Group comments to HHS on the interim final rule implementing amendments to the Notice of Benefit and Payment Parameters final rule.
Comment / Letter
Actuarial Practices Relating to Preparing, Reviewing, and Commenting on Rate Filings Prepared in Accordance with the Affordable Care Act
Exposure draft of an addendum to the October 2012 practice note, Actuarial Practices Relating to Preparing, Reviewing, and Commenting on Rate Filings Prepared in Accordance with the Affordable Care…
Comment / Letter
MLR Work Group Comments on Proposed Rule on Requirements for Medicare Advantage, Part D Programs
Comments to CMS on the proposed rule implementing MLR requirements for Medicare Advantage (MA) and Medicare prescription drug (Part D) programs.
Topics: Medicare / Medicaid
Comment / Letter
Senior Health Fellow Comments on Actuarial Value FAQ
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.
Topics: NAIC
Comment / Letter
MLR Work Group Comments on Proposed Rule for Preventive Services
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…
Comment / Letter
Work Group Comments on ACA Rate Review Template
Rate Review Practice Note Work Group letter to CCIIO recommending several modifications to the unified rate review template and instructions associated with the final rules implementing the rate…Analysis on ACA-Related Potential Risks to Health RBC
Health Solvency Work Group letter to the NAIC’s Health Risk-Based Capital Working Group on the work group’s analysis of Affordable Care Act-related possible risks to the health risk-based capital…
Comment / Letter
Comment Letter on Benefit and Payment Parameters Proposed Rule
Risk Sharing Work Group comments to CMS on proposed rule, Benefit and Payment Parameters for 2014, addressing payment methodologies and data collection for risk adjustment, reinsurance, and risk…
Topics: Reinsurance
Comment / Letter
Comment Letter on MLR Provisions in Benefit and Payment Parameters Proposed Rule
MLR Work Group comments to CMS on the proposed rule, Benefit and Payment Parameters for 2014, addressing proposed changes to the final rule on MLR.
Comment / Letter
Comment Letter on Health Insurance Market Reforms Proposed Rule
Individual and Small Group Market Task Force and Premium Review Work Group comments to CMS on a proposed rule regarding health insurance market reforms, which included modifications to the final rule…
Topics: Health Insurance