Health Practice Area Comment Letter Submitted to the Center for Consumer Information and Insurance Oversight (CCIIO) on Cost-Sharing Reduction Premium Load Factors

The Individual and Small Group Markets Committee and its Risk Sharing Subcommittee submitted a letter to the CCIIO on cost-sharing reduction (CSR) premium load factors. The letter was also submitted to state regulators and legislators. The letter first discusses using actual experience data/issuer pricing models to develop the load factor. It then discusses a method using federal actuarial value (AV) levels to develop the load and potential drawbacks of this approach.