Comment Letters: A Key Channel to Inform Policymakers 

By Ted Gotsch 
Policy Content and Publications Manager 

The Academy is deliberate when it comes to formally sharing its policy insights with government authorities—after all, we don’t lobby. We remain firmly tied to providing objective and balanced actuarial perspective, and there are times when that means taking a strong and defined position as a necessary and obvious approach to fulfill our public policy mission. 

Following last November’s election, the new administration and the change in the Senate’s majority has caused a shift in policy priorities in the nation’s capital. New faces in government provide greater opportunities for the Academy to focus on outreach and education to the executive and legislative branches, sharing our expertise, offering insights and thoughtful consideration of potential policy solutions and the downstream impacts of various proposed options, and offering the Academy as a dependable resource that has long maintained a consistent voice in the hallways and conference rooms of downtown D.C. 

One of the most common ways to communicate and respond to proposed legislation or facilitate introductions is a very old-fashioned device—a letter. Specifically, the Academy drafts public comment letters. Short, specific, and with the benefit of a quick turn-around from drafting to submission, these can be incredibly impactful and effective channels of communication to respond to the ever-shifting policy landscape, as is often needed here in Washington as well as with state regulators.  

One recent example was the July 1 letter that the Health Practice Council’s Medicaid and Individual and Small Group Markets committees sent to House Speaker Mike Johnson of Louisiana and House Minority Leader Hakeem Jefferies of New York. As our volunteers, senior health fellow, and policy staff were monitoring the various conversations about and proposals within the evolving HR 1 One Big Beautiful Bill, there was a growing awareness that an actuarial perspective on the potential immediate and downstream impacts of the proposed Medicaid provisions were missing from some of the debates.  

The letter noted that the stricter Medicaid eligibility requirements and reduced federal financing would affect many stakeholders and that it was “important to recognize that while financing or eligibility policy adjustments may offer Medicaid program cost savings, these modifications also impact the other health insurance markets, including the individual and employer marketplaces. These direct and indirect impacts may affect enrollment numbers and the rising health care costs that are felt by every American.”   

Similarly, a June 5 cross-practice letter sent to Laura Grimm, acting administrator of the National Oceanic and Atmospheric Administration (NOAA) offered the Academy’s serious concerns regarding the anticipated retirement of NOAA’s Billion Dollar Weather and Climate Disasters database. The letter, from the Casualty Practice Council, the Risk Management and Financial Reporting Council, and the Research Committee, laid out, in no uncertain terms, the negative impact that retiring the database will have on the Academy’s work, the work of state and local governments, and the work of industry—all at a high cost to serving the American public. 

“The Database is a resource utilized by insurers, reinsurers, actuaries, and state and local level decision makers in planning for and mitigating the damage and costs of future extreme weather events,” the Academy wrote. “The loss of this data will stifle research and progress on mitigation efforts, which are used to prevent or limit losses to property while keeping individuals and communities safe. Furthermore, this data loss will likely make catastrophe modeling and effective insurance pricing more difficult, at the risk of exacerbating the problem of insurance availability and affordability that is already seen in some parts of the country.” 

Comment letters aren’t solely the domain of the federal policy world. Indeed, the Academy frequently communicates with the National Association of Insurance Commissioners (NAIC) via comment letters, such as a recent joint letter from the vice presidents of the Health, Life, Casualty, and Risk Management and Financial Reporting councils. The March correspondence, sent to the co-chairs of the newly established Risk-Based Capital Model Governance (EX) Task Force, was in response to their proposed 2025 goals and anticipated work products and priorities. 

In the letter, Academy vice presidents agreed with the spirit of the proposals, writing, “We believe that developing guiding principles and completing a gap analysis to promote consistency [in risk-based capital] will be beneficial to regulators, regulated entities, and other external stakeholders. We look forward to working with the Task Force, external consultants, and stakeholders to support these objectives.” 

Comment letters, often considered one of the simplest work products that the Academy produces, are, in fact, one of the more impactful and visible ways we participate in the public policy process. They stand as a testament to the Academy fulfilling its core mission of serving the public and the actuarial profession by informing public policy while advocating for including the essential voice of the actuary in debate and discussion.