RBC Tax Reform Work Group comment letter to NAIC Life Risk-Based Capital Working Group on their exposed guidance document on the interpretation of 2018 Life Risk-Based Capital Results. (February 18, 2019
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Life Reinsurance Work Group comment letter to NAIC on APF 2018-58, which provides guidance for determination of future nonguaranteed yearly renewable term reinsurance rates under VM-20. (January 30, 2019
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RBC Tax Reform Work Group letter to NAIC on the interpretation of year-end 2018 life risk-based capital results in light of the 2017 Tax Cuts and Jobs Act. (September 06, 2018
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RBC Tax Reform Work Group follow-up letter to NAIC Life Risk-Based Capital Working Group on additional comments regarding impact of changes to corporate tax rate on risk-based capital calculation. (April 23, 2018
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Risk Sharing Subcommittee and Premium Review Work Group letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule for the 2018 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, market reforms, and rate review provisions. (October 06, 2016
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Risk Sharing Subcommittee letter to the Centers for Medicare & Medicaid Services (CMS) with comments on its recent discussion paper, HHS-Operated Risk Adjustment Methodology. The letter includes comments on partial year enrollment, use of pharmacy data, use of concurrent versus prospective model, high-risk enrollee pooling, recalibration of the model, and the transfer formula. (April 22, 2016
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