A comment letter to the Casualty Actuarial and Statistical (C) Task Force (CASTF) from Mary D. Miller, on behalf of the American Academy of Actuaries, pertaining to the CASTF 's draft qualification and related documentation requirements and copy of a letter to the Executive (EX) Committee's Ad Hoc commissioner group’s proposed changes of the Property and Casualty 2019 Actuarial Opinion Instructions, including the Ad Hoc Group's draft qualified actuary definition. (February 14, 2019)
A comment letter from Mary D. Miller, on behalf of the American Academy of Actuaries, pertaining to the Executive (EX) Committee's Ad Hoc commissioner group’s proposed changes of the Property and Casualty 2019 Actuarial Opinion Instructions, including the Ad Hoc Group's draft qualified actuary definition. (February 14, 2019)
Role of the Actuary Subgroup comment letter to NAIC on the use of the terms "actuary" and "qualified actuary" in draft revisions to VM-21. (February 12, 2019)
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)
Academy senior casualty fellow Rich Gibson's comments to the NAIC's Casualty Actuarial and Statistical Task Force regarding exposure draft of white paper on Regulatory Review of Predictive Models. (January 21, 2019)
Medicaid Subcommittee letter to CMS providing comments on Nov. 14, 2018 proposed rule regarding Medicaid and CHIP managed care programs. (January 13, 2019)
Life Reserves Work Group comment letter to the Life Actuarial (A) Task Force on amendment proposal form (APF) 2018-44, regarding credited amounts for indexed accounts. (January 01, 2019)
Retirement System Assessment and Policy Committee comment letter to the Department of Labor's proposed rule on the Definition of Employer under Section 3(5) of the Employee Retirement Income Security Act (ERISA). (December 20, 2018)
Committee comments on the Oct. 22, 2018 guidance from the Department of the Treasury and the Department of Health and Human Services on State Relief and Empowerment Waivers under Section 1332 of the Affordable Care Act (ACA), focusing on three areas: evaluation of coverage comprehensiveness and affordability, evaluation of coverage, and waiver funding. (December 17, 2018)
Council letter to the Centers for Medicare and Medicaid Services (CMS) in response to its request for comments on proposed rules pertaining to the Medicare Advantage (MA) program, including provisions to revise the risk adjustment data validation (RADV) payment error calculation methodology and process. (December 16, 2018)
Committees comment on the proposed rule regarding Health Reimbursement Arrangements (HRAs), that would create two new types of HRAs—Integrated HRAs and Excepted Benefit HRAs—which would allow employers to provide HRAs that could be used to pay for individual plan premiums and out-of-pocket health costs. (December 12, 2018)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) regarding the Risk-based Global Insurance Capital Standard Version 2.0 (ICS 2.0) public consultation document dated July 31, 2018. (October 29, 2018)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) regarding the Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame) public consultation document dated July 31, 2018. (October 18, 2018)
Life Reserves Work Group revised amendment proposal form on selection of the industry basic table when company experience mortality rates are higher than the industry basic table. (October 02, 2018)
Multiemployer Plans Committee follow-up letter to the Joint Select Committee on Solvency of Multiemployer Pension Plans on key topics discussed during June 22 meeting regarding loan proposals and other solutions for troubled multiemployer pension plans. (September 25, 2018)
Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on its Scope and Non-Insurance Testing Exposed with Questions document. (September 19, 2018)
Big Data Task Force comments to the U.S. Senate Committee on Banking, Housing, and Urban Affairs on their hearing, Fintech: Examining Digitization, Data, and Technology. (September 16, 2018)
ERM/ORSA Committee comments to the NAIC’s Financial Regulation Standards and Accreditation (F) Committee on the ORSA Review Timelines exposure. (September 04, 2018)
Committee and Subcommittee comments on the Centers for Medicare and Medicaid Services’ (CMS) and Department of Health and Human Services’ (HHS) Aug. 10 proposed rule regarding the adoption of methodology for the HHS-operated permanent risk adjustment program. (September 04, 2018)
Life and Health Valuation Law Manual Task Force comment letter to Life Actuarial (A) Task Force on recommendations to changes for the 2019 Life and Health Valuation Law Manual. (August 15, 2018)