American Academy of Actuaries-Health section

Tom Wildsmith is the Academy's vice president for health issues. Cori Uccello is the senior health fellow.

Spotlight on health care reform

Critical Issues in Health Reform
The Academy is publishing a new series of papers entitled, Critical Issues in Health Reform. Each of the policy statements is designed to provide an actuarial perspective on various components of comprehensive health care reform proposals.

Comments to CMS on risk-sharing mechanisms proposed rule
The Risk Sharing Work Group submitted comments to CMS in response to the proposed rule implementing risk adjustment, reinsurance, and risk corridors under the ACA.
Risk Adjustment issue brief released
The Academy Health Practice Council released a new issue brief, Risk Assessment and Risk Adjustment. The brief provides an overview of risk adjustment and outlines general considerations for implementing a risk adjustment mechanism under PPACA.
Actuarial Equivalence
Administrative Expenses
Community Living Assistance Services and Supports (CLASS) Act
Gender Considerations in a Voluntary Individual Health Insurance Market and accompanying comments on the Women’s Health Insurance Fairness Act
Health Insurance Cooperatives
Individual Mandate
Market Reform Principles
Merging the Small Group and Individual Markets
Minimum Loss Ratios
Premium Setting in the Individual Market
Public Plan Option
Risk Pooling
State-Level Impact and State Characteristics
Transitioning Into New Markets
Value-Based Insurance Design

Letter to HHS on research brief addressing actuarial value

The Health Practice Council sent a letter to the Assistant Secretary for Planning and Evaluation (ASPE) at HHS providing comments on a recently released research brief, Actuarial Value and Employer-Sponsored Insurance. (01/31/12)

Letter to HHS on Essential Health Benefits Bulletin

The Individual and Small Group Market Task Force provided comments to HHS on its December 2011 bulletin addressing essential health benefits. (01/31/12)

New: Campaign 2012 Toolkits

The first in a series of toolkits designed to provide actuaries in every practice area with the tools necessary to deliver objective information on public policy issues is now available. The toolkit—on Medicare’s financial condition—includes a slide deck that provides an overview of the structure of Medicare, the challenges to the program’s solvency and sustainability, and options that have been proposed to reform the program. Click here to learn more. (01/24/12)

Feb. 8 Webinar: Medical Loss Ratios—Final Regulations and Repercussions for the Health Insurance Marketplace

In December 2011, the Department of Health and Human Services published final regulations implementing the medical loss ratio requirements in the ACA. Insurers have already begun complying with the reporting and rebate requirements under the ACA and this webinar will focus on the implications of the changes in the final regulations. Learn more. (01/17/12)

Upcoming Webinar: The Affordable Care Act—What Every Actuary Should Know

The Academy’s Health Practice Council will present a webinar on Feb. 10 to provide actuaries from all practice areas with essential background on the Affordable Care Act (ACA), including key provisions in the law (focusing on those intended to expand coverage) and the status of implementation. Members are invited free of charge. Learn more. (01/11/12)

Comments to NAIC

The Academy’s Pension Accounting Committee and Joint Committee on Retiree Health submitted a comment letter to the National Association of Insurance Commissioners (NAIC) on the exposure drafts of Statements of Statutory Accounting Principles (SSAP) No. 92 and No. 102. These exposure drafts are intended to replace existing standards governing accounting for pension benefits and postretirement benefits other than pensions (OPEBs). (12/09/11)

Committee Letter to Arizona Insurance Department

The Health Practice Council co-signed a letter with the Committee on Qualifications to the Arizona insurance director pointing out that their regulatory definition of “qualified actuary” for health premium actuarial certifications was inappropriate and suggested corrective language. (11/18/11)

Letter to NAIC on progress of Academy/SOA Cancer Claims Cost Tables Work Group

The Academy’s Cancer Claims Cost Tables Work Group submitted a letter to the NAIC’s Health Actuarial Task Force (HATF) indicating progress it has made over the last year and informing HATF of what it intends to do in the coming year. (11/2/11)

Academy/SOA Group Long-Term Disability Work Group provides update at NAIC Fall Meeting

The Academy’s Group Long-Term Disability Work Group provided an update to the NAIC's Health Actuarial Task Force (HATF) at the NAIC’s Fall Meeting highlighting progress on the Long-Term Disability Valuation Table as well as indicating what work still needs to be completed. (11/2/11)

Letter to Mass. Senate on amendment to H.3535

The Premium Review Work Group sent a letter to the Mass. Senate regarding an amendment to the state budget that would require the disapproval of any health insurance rates to be “supported by sound actuarial assumptions and methods.” (11/1/11)

Letter to HHS on implications of GINA application to long-term care

A joint work group comprised of members of the SOA Long-Term Section Council and the Academy’s Federal Long-Term Care Task Force submitted a letter to HHS Secretary Sebelius regarding the department’s extension of the Genetic Information Nondiscrimination Act (GINA) to long-term care insurance in proposed regulations. (10/13/11)

Comments to CMS on Exchanges proposed rule

The Academy submitted comments to CMS in response to proposed regulations establishing health insurance exchanges and qualified health plans under the ACA. (10/06/11)

Letter on NAIC on MedSupp white paper

The Academy recently sent a letter to the NAIC Medigap PPACA Subgroup offering comments on the subgroup’s new discussion paper, Medicare Supplement Insurance First Dollar Coverage and Cost-Shares. (10/04/11)

Letter on Medicare to Joint Select Committee on Deficit Reduction

The Academy recently sent a comment letter to the members of the new Joint Select Committee on Deficit Reduction urging action to improve the long-term solvency and sustainability of the Medicare program. (8/31/11)

Group Long-Term Disability Work Group Update to the NAIC

The Academy/SOA Long-Term Disability Work Group gave an update to the NAIC's Health Actuarial Task Force on the work group's progress regarding the creation of a valuation table for group long-term disability. The work group expects the table to be completed by March of 2012. (8/31/11)

Medicare Supplement Work Group Assists NAIC with Refund Formula

The Academy's Medicare Supplement Work Group sent a letter to the NAIC's Medicare Supplement Refund Formula Subgroup with a proposed charge to have the work group review the Medicare Supplement Refund Formula for potential changes that may need to be addressed. (8/31/11)

Actuarial Value issue brief released

The Academy released a new issue brief, Actuarial Value under the Affordable Care Act. The brief offers an overview of the concept of actuarial value and provides insight into the calculation of actuarial value under ACA. (07/21/11)

Medicaid Work Group discusses Medicaid rate-setting process

The Academy's Medicaid Work Group presented to the Centers for Medicare and Medicaid Services (CMS) on the Medicaid rate-setting process for Medicaid Managed Care programs. The presentation included a discussion about base data sources, base data adjustments, risk adjustment, risk-sharing arrangements, and performance incentives. (07/21/11)

Update on the CLASS Act at NCOIL Summer Meeting

Co-chairperson of the Joint Academy/Society of Actuaries CLASS Act Task Force Steve Schoonveld gave an update on the Community Living Assistance Supports and Services (CLASS) program at the National Conference of Insurance Legislators (NCOIL) Summer Meeting in Newport, RI. (07/21/11)

Written Testimony on 2011 Medicare Trustees Report

The Academy submits written testimony to the House Ways and Means Subcommittee on Health regarding a hearing on the 2011 Medicare Trustees Report (07/05/11)

Letter to CMS on Rate Review and Disclosure Forms

The Academy submits comments to CMS in response to the revised preliminary justification and consumer disclosure forms for purposes of rate review disclosure and reporting requirements (06/28/11)

Fact sheet on Medicare Shared Savings Program and ACOs under the Affordable Care Act

The Academy released a new fact sheet that provides an overview of the Medicare Shared Savings Program and how ACOs are addressed in the Affordable Care Act. (06/16/11)

ACO issue brief released

The Academy released a new issue brief, An Actuarial Perspective on Accountable Care Organizations. The brief provides an actuarial overview of ACOs and outlines a number of issues that stakeholders should evaluate as ACOs are implemented. (06/16/11)

Risk-Sharing under ACA issue brief released

The Academy released a new issue brief, Risk Adjustment and Other Risk-Sharing Provisions in the Affordable Care Act. The brief provides an overview of the various risk-sharing mechanisms in ACA and the risks each mechanism can mitigate. (06/09/11)

Comments to CMS on ACO proposed regulation

The Academy submits comments to CMS in response to proposed regulations on accountable care organizations and the Medicare Shared Savings Program under ACA. (06/06/11)

May 27 Capitol Hill briefing: An Actuarial Perspective on the 2011 Medicare Trustees Report

Presenters from the Health Practice Council examined the financial projections from the newly released 2011 Medicare Trustees Report and discussed the outlook for Medicare's sustainability. (05/27/11)

Issue brief on the 2011 Medicare Trustees Report

The Academy's Medicare Steering Committee released a new issue brief that highlights the 2011 Medicare Trustees Report and outlines the public policy options to address Medicare's long-term financial soundness. (05/25/11)

Issue brief on Proposals to Improve Medicare's Financial Condition

The Medicare Steering Committee released a new issue brief that summarizes the key cost, access, and quality issues associated with some of the Medicare-related provisions in the various debt and deficit reduction proposals. (05/11/11)

Letter to NAIC on Adverse Selection White Paper

The Academy submits comments to the NAIC Exchanges (B) Subgroup regarding its white paper on adverse selection. (04/05/11)

Actuary testifies to congressional subcommittee

Al Schmitz testified on behalf of the Academy during the U.S. House Committee on Energy and Commerce Subcommittee on Health's hearing regarding the Community Living Assistance Services and Supports (CLASS) program. (3/18/11)

Letter to the NAIC Regarding New Long-Term Care Work Group

Letter to the NAIC on Medicare Part D Survey Request

The Academy's Medicare Part D RBC Subgroup writes a letter to the NAIC's Health RBC Working Group asking it to sponsor and administer a survey of carriers that write Medicare Part D business. The survey is designed to gather additional data that may support any needed changes to the formula. (02/09/11)

Joint report on SMI project

The Academy's life, health, and property/casualty RBC committees released a joint report in response to the NAIC's request for assistance with the Solvency Modernization (SMI) project on the NAIC's Risk-Based Capital (RBC) formulas. This report discusses the intended/expected safety levels for RBC and identifies risks that are missing from the RBC formulas. (02/04/2011)

Revised Actuarial Statement of Opinion Instructions for the NAIC Health Annual Statement

The Academy has published a new practice note to help actuaries both understand and comply with new requirements for the NAIC Health Annual Statement that became effective on Dec. 31, 2010. The revised actuarial statement of opinion instructions were adopted in the NAIC's 2010 health actuarial opinion requirements. All practicing health actuaries need to be aware of the revised instructions in advance of the filing.

Comments to CMS on RADV

The Academy writes a letter to CMS in response to its request for comments on the Medicare Advantage risk adjustment data validation (RADV) payment error calculation methodology.

Letter to CMS on the Medicaid rate setting checklist

The Academy writes a letter to CMS in response to CMS' request for assistance in revising the Medicaid rate setting checklist.

Medicare's Financial Condition:

Comments to NAIC re: rate filing disclosure form

The Academy writes a comment letter on the NAIC B Committee's exposure draft of a rate filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS.

Health comments on ASOP 28

The Academy's Health Practice Financial Reporting Committee submitted comments to the Actuarial Standards Board regarding a proposed revision to ASOP 28.

Contract Reserves Practice Note

The Health Contract Reserves Practice Note Subcommittee issued a practice note on practices for preparing health contract reserves.

Comments to NAIC on SSAPs (OPEBs and Pensions)

The Joint Committee on Retiree Health and the Pension Accounting Committee jointly submitted comments to the NAIC regarding the exposure draft of SSAP 92 (OPEBs) and proposed revisions to SSAP 89 (pensions)

Letter to Mass. legislature on SB 2447

The Academy writes a letter regarding Massachusetts Senate Bill 2447, which includes a provision that would limit rate increases to medical CPI.

Letter to the NAIC on draft rate-filing disclosure form

The Academy writes a comment letter on the NAIC's exposure draft of a rate-filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS.

Letter to HHS on dependent coverage

The Academy writes a letter to HHS in response to an interim final rule on the PPACA provision that extends dependent coverage to age 26.

Letter to the NAIC on Covariance

On June 11, the Health Solvency work group sent a comment letter to the chair of the NAIC's Capital Adequacy Task Force regarding the evaluation of the current health risk-based capital covariance formula calculation for potential changes to the calculation or methodology.

DTA Bridge Group Report

The Academy's DTA Bridge Group submits a requested interim report to the NAIC Capital Adequacy Task Force showing the appropriate treatment of the Deferred Tax Asset (DTA) in the Risk-Based Capital formulas for Life, Property / Casualty (P&C), and Health.

Presentation on Health Reform Implementation

Academy Senior Health Fellow Cori Uccello presents during a June 15 American Enterprise Institute event, offering an actuarial perspective on health care reform implementation.

Letter to NAIC on Contract Reserves

The Academy writes a letter to the chair of the NAICs Accident and Health Working Group offering input on the potential inclusion of a change in contract reserves in the numerator of the MLR rebate calculation.

Letter to HHS on Early Retiree Reinsurance

The Academy writes a letter to the Department of Health and Human Services in response to an interim final rule on the PPACA provision that creates a temporary reinsurance program for early retirees.

Letter to NAIC regarding Health Annual Statement Instructions

The Health Practice Financial Reporting Committee sent a comment letter to the chair of the National Association of Insurance Commissioners' (NAIC) Blanks Working Group on the proposed changes to the NAICs Health Annual Statement Instructions.

Letter to the NAIC on Supplemental Health Care Exhibit exposure draft

The Academy writes a letter to the chair of the NAIC's Health Care Reform Solvency Impact Subgroup on an exposure draft of a new proposed financial reporting exhibit the Supplemental Health Care Exhibit.

Letter to HHS regarding MLR provisions

The Academy writes a letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that requires medical loss ratio reporting and rebates.

Letter to HHS regarding rate review

The Academy writes a letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that establishes a review process for unreasonable rate increases.

Letter to the NAIC regarding statistical credibility

The Academy writes a letter to the chair of the NAIC's Accident and Health Working Group responding to his request for input on defining an appropriate way to maintain statistical validity within the rebate process. The Academy sent a subsequent letter to respond to a request from the NAIC for more information on statistical credibility.

Letter to the NAIC regarding premium review

The Academy writes a letter to the chairs of the NAIC's Health Care Reform Solvency Impact Subgroup, the Accident and Health Working Group, and the Rate Review Subgroup regarding the Patient Protection and Affordability Act (PPACA) provision that establishes a review process for unreasonable rate increases.

Letter to the NAIC regarding MLR considerations and potential disruption in the individual market

The Academy writes a second letter to the chairs of the NAIC's Health Care Reform Solvency Impact Subgroup and the Accident and Health Working Group regarding the medical loss ratio provisions and the potential for individual market disruption under the Patient Protection and Affordability Act.

Letter to the North Carolina Department of Insurance

The Academy writes to the North Carolina Department of Insurance regarding the Department's proposal to change the definition of "qualified actuary."

Letter to the NAIC regarding medical loss ratio provisions in health reform law

The Academy writes a letter to the Chairs of the NAIC's Health Care Reform Solvency Impact Subgroup and the Accident and Health Working Group regarding considerations related to the Patient Protection and Affordability Act Medical Loss Ratio Provisions (2718).

Additional comments on the Medicare Supplement Compliance Manual

The Academy's Medicare Supplement Work Group provides additional comments to NAIC on the draft revisions to the Medicare Supplement Compliance Manual, clarifying the use of the pooling approach used in the manual and how it may interact with loss ratio standards. The Work Group first submitted comments Feb. 2.

Letter to Feb. 25 health summit invitees outlining key criteria for viable health reform

The Academy's Health Practice Council writes to the White House and all invitees of the Feb. 25 bipartisan health summit stressing critical actuarial aspects of health reform legislation that will need to be addressed to support the stated goals of reducing the number of uninsured, increasing the availability and affordability of coverage, and enhancing the focus on quality of care and health spending growth.

Letter to NAIC regarding morbidity tables

Letter to NAIC regarding the joint Academy State LTC Task Force and SOA Valuation Committee project to develop and recommend valuation morbidity tables for long-term care insurance.

Testimony to Massachusetts policymakers

The Academy's State Health Committee provides written testimony to the Massachusetts House and Senate Joint Committee on Financial Services regarding gender rating for disability insurance.

Updated: Actuaries urge comprehensive Medicare reform

Medicare faces serious financial challenges that require comprehensive reforms to the program now to avoid the need for even more drastic actions in the future. The Academy supports efforts by the President and Congress to address these challenges and urges action to restore the long-term solvency and financial sustainability of Medicare.

Letter to congressional leaders detailing health care reform concerns

The Academy writes to Speaker Nancy Pelosi and Senate Majority Leader Harry Reid highlighting some of the key differences on actuarial issues between the House’s Affordable Health Care for America Act (HR 3962) and the Senate’s Patient Protection and Affordable Care Act.

Actuaries recommend change to "Cadillac Plan" tax structure

The Academy and Society of Actuaries release a report to help policymakers and the public understand the potential implications of an excise tax on high-cost employer-provided health plans.

Updated: Practice note on small group certifications

In an updated practice note, the Academy provides guidance to actuaries that prepare small group actuarial certifications, incorporating the passage of ASOP 26 and relevant revisions to certification requirements in various states.

Comments on the "grandfather provisions" within the Patient Protection and Affordable Care Act

The Academy responds to a request for analysis on the "grandfathering provisions" contained in the Patient Protection and Affordable Care Act and whether they would mitigate “rate shock” for those individuals who keep the coverage they have.

Letter to the Senate

In a letter to Senators Harry Reid and Mitch McConnell, the Academy outlines key issues that need to be considered when evaluating whether the Senate’s health care reform bill will lead to a viable health insurance system and discusses whether the Patient Protection and Affordable Care Act addresses the outlined issues.

Letter to the House of Representatives

The Academy writes to Speaker Nancy Pelosi and Republican Leader John Boehner providing an actuarial perspective on health insurance market reforms, outlining three criteria to ensure that the current markets remain viable, and offering comments on how certain provisions of the House’s Affordable Health Care for America Act (HR 3962) conform with those criteria.

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