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Individual and Small Group Markets Committee

The Individual and Small Group Market Committee furthers the actuarial profession’s involvement in policy issues related to both the small group and individual medical markets. The committee monitors federal legislation and regulatory activities and is charged with developing background papers intended to inform and educate senior federal policy makers on issues related to the small group and individual markets.

Staff Liaison: Michelle Anaba
Senior Fellow:
Chairperson: Jason Karcher
Vice Chairperson: Tammy Tomczyk
Zhongye Bao
Evan Beuscher
Joseph Bojman
Cody Bush
Richard Cadwell
Lauren Case
Ling Hong Chan
Yu- Ching Chen
Timothy Connell
Elaine Corrough
Michelle Faust
Kyle Hall
Ashkaun Hami
Mary Ingram
Annette James
Ryan Jubber
Ethan Kitzmiller
Kenneth Laskowski
Crystal Lassegard
Annie Man
Andrew Meyers
Matthew Mize
Cameron Mortazavi
Ankit Nanda
Jason Nowakowski
Velena Nowling
Dorina Paritsky
Martin Ramsey
Ryan Schultz
Estellene Schweickert
Andrew See
Matthew Self
Isaac Squire
Elizabeth Verticchio
Li Wang

Related Publications

Individual & Small Group Markets Committee Comments to CMS on ACA Rule

The Individual & Small Group Markets Committee sent a comment letter to the Centers for Medicare & Medicaid Services (CMS) on the Proposed Rule: Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability.

(April 11, 2025 )

Health Issue Brief Examines Access, Affordability, Choice, and Competition in the Individual Market

An issue brief from the Individual and Small Group Markets Committee, Ensuring Access, Affordability, Choice, and Competition in the Individual Health Insurance Market, provides an overview of how the laws and rules governing the individual health insurance market support the goals of increasing access to coverage, improving affordability, enhancing consumer choice, and encouraging insurer competition. It also discusses how changes to these laws and rules could affect the achievement of these goals.

(March 06, 2025 )

Committee Comments on 2026 NBPP

The Health Practice Council’s Individual and Small Group Markets Committee submitted comments to the Centers for Medicare & Medicaid Services regarding the proposed rule for the 2026 Notice of Benefit and Payment Parameters.

(November 12, 2024 )

Academy Updates NAIC on the Drivers of Health Insurance Premium Changes

Academy Senior Health Fellow Cori Uccello presented on the “Drivers of 2025 federal Affordable Care Act (ACA) Health Insurance Premium Changes” to the National Association of Insurance Commissioners (NAIC) Health Actuarial (B) Task Force during its 2024 Summer National Meeting. The presentation also highlighted the recently released associated issue brief and infographic.

(August 12, 2024 )

Premium Drivers Infographic Released

Released alongside the annual issue brief, The Individual and Small Group Markets Committee released an infographic, "Drivers of 2025 Health Insurance Premium Changes—Effects on Premiums". The infographic breaks down, in easy-to-understand language, the factors that may drive health insurance premium changes for the 2025 plan year.

(August 09, 2024 )

Premium Drivers Issue Brief Released

The Individual and Small Group Markets Committee released an issue brief, Drivers of 2025 Health Insurance Premium Changes. The brief provides more details on the factors that are likely to drive health insurance premium changes in 2025 for plans operating in the individual and small group markets subject to Affordable Care Act rules.

(August 09, 2024 )

Committee Comments on Portable Health Benefits

The Health Practice Council’s Active Benefits Committee and Individual and Small Group Markets Committee responded to the U.S. Senate Committee on Health, Education, Labor and Pensions’ (HELP) request for information regarding portable benefits for self-employed workers and other individuals in nontraditional working arrangements.

(June 24, 2024 )

Committees Comment on Definition of Employer—Association Health Plans

The Health Practice Council’s Individual and Small Group Markets Committee and Active Benefits Committee responded to the DOL’s Employee Benefits Security Administration’s proposed rule on Association Health Plan’s definition of employer.

(February 14, 2024 )

Committee Comments on Gene Therapy RFI

The Health Practice Council’s Health Care Delivery Committee, Individual and Small Group Markets Committee, and Active Benefits Committee responded to the Committee on Health, Education, Labor, and Pensions’ (HELP) request for information on access to gene therapies for patients with an ultra-rare disease.

(January 22, 2024 )

Committee Comments on 2025 NBPP

(January 08, 2024 )

Committee Comments on Draft 2025 Actuarial Value (AV) Calculator Methodology

The Individual and Small Group Markets Committee submitted comments to the Centers for Medicare & Medicaid Services’ Center for Consumer Information & Insurance Oversight (CCIIO) on the Draft 2025 Actuarial Value (AV) Calculator Methodology.

(January 02, 2024 )

Committees Comment on Short-Term, Limited-Duration Insurance Proposed Rules

The Health Practice Council’s Individual and Small Group Markets Committee, Risk Sharing Subcommittee, and Active Benefits Committee submitted a comment letter to the Department of Health and Human Services (HHS), Department of Labor (DOL), and the Department of the Treasury on the Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Accident and Health Insurance notice of proposed rulemaking (NPRM).

(September 11, 2023 )

Drivers of 2024 Health Insurance Premium Changes

The Individual and Small Group Markets Committee released its annual issue brief laying out the factors underlying premium rate setting and highlighting the major components driving premium changes in the individual and small group markets for 2024.

(July 19, 2023 )

HPC Committees Comment on 2024 NBPP

The Health Practice Council’s Individual and Small Group Markets Committee and Risk Sharing Subcommittee submitted a comment letter to the Centers for Medicare & Medicaid Services’ (CMS) proposed rule for the 2024 Notice of Benefit and Payment Parameters (NBPP).

(January 30, 2023 )

Committee Comments on Draft 2024 Actuarial Value (AV) Calculator Methodology

(January 12, 2023 )

Academy Presentation to NAIC on Considerations for Calculating Cost-Sharing Premium Reduction Load Factors

Presentation at the National Association of Insurance Commissioners (NAIC) Affordable Care Act (ACA) State Rate Review Discussion Meeting on Considerations for Calculating Cost-Sharing Reduction (CSR) Premium Load Factors.

(November 16, 2022 )

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.

(September 08, 2022 )

Drivers of 2023 Health Insurance Premium Changes - Infographic

This infographic illustrates the factors underlying premium rate setting and highlighting the major components driving premium changes in the individual and small group markets for 2023, that are discussed in the recently released issue brief.

(June 22, 2022 )

Drivers of 2023 Health Insurance Premium Changes

The Individual and Small Group Markets Committee released an issue brief laying out the factors underlying premium rate setting and highlighting the major components driving premium changes in the individual and small group markets for 2023.

(June 21, 2022 )

HPC Committees Comment on Proposed Rule on Affordability of Employer Coverage for Related Individuals

The Health Practice Council’s Individual and Small Group Markets Committee and Active Benefits Subcommittee submitted comments to the Internal Revenue Service (IRS) on the proposed rule for “Affordability of Employer Coverage for Family Members of Employees.” The comments relate to provisions addressing the so-called “family glitch,” revisions to the employer coverage affordability test, and the Minimum Value (MV) Calculator.

(June 06, 2022 )

Committee Comments on Draft 2023 Actuarial Value (AV) Calculator Methodology

(January 31, 2022 )

HPC Committees Comment on 2023 NBPP

The Health Practice Council’s Individual and Small Group Markets Committee, Risk Sharing Subcommittee, and Health Equity Work Group submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) on CMS’ proposed rule for the 2023 Notice of Benefit and Payment Parameters (NBPP). The letter addresses network adequacy, standardized plan options, several provisions on health equity, updating quality improvement strategy standards and other topics.

(January 26, 2022 )

Comment Letter to CMS/CCIIO on Exposure Draft of Risk Adjustment Technical Paper

The Risk Sharing Subcommittee submitted comments to the Centers for Medicare & Medicaid Services (CMS) Center for Consumer Information and Insurance Oversight (CCIIO) on the HHS-Operated Risk Adjustment Technical Paper on Possible Model Changes, exposed for comment on Oct. 26, 2021.

(November 24, 2021 )

Drivers of 2022 Health Insurance Premium Changes

The Individual and Small Group Markets Committee released an issue brief laying out the factors underlying premium rate setting and highlighting the major components driving premium changes in 2022.

(September 02, 2021 )

Committee/Subcommittee Comments to CMS on Payment Parameters Proposed Rule

The Individual and Small Group Markets Committee and its Risk Sharing Subcommittee comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed rule, Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond.

(July 28, 2021 )

Committee/Subcommittee Comments to HHS, DOL, and the Treasury on the No Surprises Act

The Health Practice Council’s Individual and Small Group Markets Committee and the Active Benefits Subcommittee comments to the Departments of Health & Human Services, Labor, and the Treasury as the agencies develop proposed rules related to the recently enacted No Surprises Act pertaining to surprise medical billing.

(June 25, 2021 )

Committee/Subcommittee Comments to Treasury, DOL, and HHS, on Insurance and Health Plan Coverage of COVID-19 Testing

The Individual and Small Group Markets Committee and the Active Benefits Subcommittee submitted comments to the Department of the Treasury, the Department of Labor (DOL), and the Department of Health & Human Services (HHS), on insurance and health plan coverage of COVID-19 testing, as put forward in a presidential executive order, Establishing the COVID-19 Pandemic Testing Board and Ensuring a Sustainable Public Health Workforce for COVID-19 and Other Biological Threats.

(February 11, 2021 )

Committee/Subcommittee Comment to CMS on Payment Parameters Proposed Rule

The Individual and Small Group Markets Committee and its Risk Sharing Subcommittee comments to the Centers for Medicare & Medicaid Services (CMS) on the Proposed Notice of Benefit and Payment Parameters for 2022.

(December 30, 2020 )

Committee Comments on 2021 Actuarial Value (AV) Calculator

Comments from the Individual and Small Group Markets Committee to the Center for Consumer Information & Insurance Oversight (CCIIO) expressing concerns on the claims data updates finalized in the 2021 Actuarial Value (AV) Calculator. These comments are for consideration in preparing the draft 2022 AV Calculator.

(November 12, 2020 )

Drivers of 2021 Health Insurance Premium Changes: The Effects of COVID-19

Individual and Small Group Markets Committee issue brief outlining the major factors driving premium changes for the next plan year. This year’s issue brief focuses primarily on the impact of COVID-19 on the 2021 premium rate filings.

(June 09, 2020 )

Individual and Small Group Markets Committee and Risk Sharing Subcommittee Comments on the Proposed Rule for the 2020 NBPP

Comments of the Individual and Small Group Markets Committee and Risk Sharing Subcommittee on the proposed rule for the 2020 Notice of Benefit and Payment Parameters (NBPP).

(March 02, 2020 )

Wellness Program Demonstration Project in the Individual Market

Individual and Small Group Markets Committee comments on the September 30, 2019 bulletin, Opportunity for States to Participate in a Wellness Program Demonstration Project to Implement Health-Contingent Wellness Programs in the Individual Market.

(January 14, 2020 )

Committee Comments on Changes to RADV timing in the final 2020 NBPP and related documents

Individual and Small Group Markets Committee sent comments to Centers for Medicare & Medicaid Services on rules finalized in the 2020 Notice of Benefit and Payment Parameters (NBPP) concerning risk adjustment data validation (RADV)-related transfers.

(October 03, 2019 )

Drivers of 2020 Health Insurance Premium Changes

Individual and Small Group Markets Committee issue brief outlines the major drivers behind why 2020 premiums could differ from those in 2019. The brief focuses primarily on the individual market, yet many of the factors discussed are also relevant to the small group market.

(June 27, 2019 )

Nearly a Decade Later the ACA is...

This presentation was a session at the SOA Health Meeting which reviewed the challenges the Affordable Care Act (ACA) has faced since its enactment in 2010 and will looked forward to where it’s headed in the future. Panelists discussed current ACA legislative and regulatory activities as well as ongoing ACA litigation.

(June 24, 2019 )

Committee Comments on Selling Insurance Across State Lines

Individual and Small Group Markets Committee comments in response to the Department of Health and Human Services’ request for information on selling insurance across state lines through Health Care Choice Compacts.

(May 06, 2019 )

2020 Benefit and Payment Parameters Proposed Rule

Individual and Small Group Markets Committee and Risk Sharing Subcommittee comments on the proposed rule for the 2020 notice of benefit and payment parameters (NBPP). (February 18, 2019 )

Comments on (1332) State Relief and Empowerment Waivers Guidance

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 )

Comments on Health Reimbursement Arrangements and Other Account-Based Group Health Plans

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 )

Comments on Adoption of Methodology for HHS-Operated Permanent Risk Adjustment Program for 2018 Benefit Year

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 )

Auto-Enrollment Into Individual Market Health Insurance Coverage

Individual and Small Group Markets Committee issue brief providing insights on the potential and challenges of using auto-enrollment in the individual health insurance market. (September 03, 2018 )

The AHP, Short-Term Duration and HRA Rules: What’s the Latest?

Presentation at the 2018 SOA Health Meeting examining rules surrounding association health plans, short-term limited duration insurance plans, and health reimbursement arrangements from the Trump Administration. (June 26, 2018 )

Drivers of 2019 Health Insurance Premium Changes

Individual and Small Group Markets Committee issue brief providing an overview of the general factors underlying premium rate setting and highlighting the major components driving premium changes in 2019. (June 12, 2018 )

Comments on Short-term, Limited Duration Insurance

Committee comments on a proposed rule that would lengthen the maximum period of short-term, limited-duration (STLD) insurance through amending the definition of STLD. (April 05, 2018 )

Comments on Association Health Plans

Committee comments on the definition of ‘‘Employer’’ under section 3(5) of ERISA—Association Health Plans. (March 05, 2018 )

Comments on Considerations Related to Modeling the Potential Impact of Association Health Plans

Committee comments to Office of Regulations and Interpretations within the Employee Benefits Security Administration in response to the Department of Labor's proposed rule on the definition of employer—small business health plans. (February 09, 2018 )

Comments on Promoting Healthcare Choice and Competition

Committee comments to Office of the Assistant Secretary for Planning and Evaluation in response to the Department of Health and Human Services’ request for information on promoting healthcare choice and competition. (January 25, 2018 )

Presentation on Drivers of 2018 Health Insurance Premium Changes

Presentation to the National Conference of Insurance Legislators about the Akey drivers of 2018 premiums and what goes into developing a premium. (July 14, 2017 )

Drivers of 2018 Health Insurance Premium Changes

Comments on the Better Care Reconciliation Act of 2017 (BCRA)

Indivdiual and Small Group Markets Committee and Medicaid Subcommittee comments on the Better Care Reconciliation Act (BCRA) of 2017, the proposed legislation to repeal and replace provisions in the Affordable Care Act. (June 30, 2017 )

Comments on American Health Care Act (AHCA)

Indivdiual and Small Group Markets Committee and Medicaid Subcommittee comments on H.R. 1628, the American Health Care Act, the proposed legislation to repeal and replace provisions in the Affordable Care Act. (March 22, 2017 )

Comments on Association Health Plans in U.S. House Bill

Individual and Small Group Markets Committee comments to the U.S. House Committee on Education and the Workforce on H.R. 1101, the Small Business Health Fairness Act, related to association health plans.
(March 08, 2017 )

Committee Comments on Market Stabilization Proposed Rule

Individual and Small Group Markets Committee letter to the Centers for Medicare & Medicaid Services regarding the proposed rule for market stabilization. (March 07, 2017 )

Association Health Plans

Individual and Small Group Markets Committee issue brief highlighting the various policy consideration and potential implications of establishing association health plans (AHPs). (February 13, 2017 )

Selling Insurance Across State Lines

Individual and Small Group Markets Committee issue brief highlighting the various policy considerations and the potential implications of allowing the sale of insurance across state lines. (February 13, 2017 )

Using High-Risk Pools to Cover High-Risk Enrollees

Individual and Small Group Markets Committee issue brief providing an overview of three potential high-risk pool approaches to covering the costs of high-risk enrollees and examining the implications of various design features, including eligibility criteria, benefit coverage, funding sources, and regulatory responsibility. (February 10, 2017 )

Academy Congressional Testimony on Effectiveness of Individual Mandate in ACA

Written testimony on the effectiveness of the individual mandate under the Affordable Care Act (ACA) to a U.S. House Ways and Means Oversight. (February 06, 2017 )

Committee Issue Paper Evaluating the Individual Health Insurance Market

Individual and Small Group Markets Committee issue paper examining the experience in the Affordable Care Act (ACA) individual market, outlining the conditions necessary for a sustainable market, examining whether these conditions are currently being met, and discussing the implications of potential changes to improve the ACA market rules or replace ACA with an alternative approach. (January 18, 2017 )

Comments on 2018 Benefit and Payment Parameters Proposed Rule

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 )

Academy Congressional Testimony on Drivers of 2017 Health Insurance Premium Changes

Written testimony on the general factors underlying premium rate setting and the major components driving premium changes for 2017 under the Affordable Care Act to a U.S. House Ways and Means Committee hearing on rising health care premiums. (July 22, 2016 )

Drivers of 2017 Health Insurance Premium Changes

Congressional Testimony on Small Group Definition

Academy Senior Health Fellow Cori Uccello written testimony on potential implications of expanding small-group definition to companies with 51-100 employees to a U.S. House Energy & Commerce Subcommittee on Health hearing on affordable health care. (September 09, 2015 )

Drivers of 2016 Health Insurance Premium Changes

Individual and Small Group Markets Committee issue brief providing an overview of the factors underlying the general premium rate setting and highlighting the major drivers behind why 2016 premiums could differ from those in 2015 under the Affordable Care Act (ACA). (August 05, 2015 )