Public Policy Comments and Letters

The Academy responded in writing to questions from the House Subcommittee on Health, Education, Labor, and Pensions as a follow-up to the panel’s March 7 hearing, “The Cost of Inaction: Why Congress Must Address the Multiemployer Pension Crisis,” at which Josh Shapiro, the Academy’s vice president, pension, testified. (March 29, 2019)
Premium Review Work Group comments on the recently released final Unified Rate Review Template (URRT) and Instructions. (March 13, 2019)
Life Illustrations Work Group letter addressing questions raised by the NAIC's IUL Illustration (A) Subgroup. (March 8, 2019)
Lifetime Income Risk Joint Committee, Retirement System Assessment and Policy Committee (RSAP) and Social Security Committee comment letter to the Bipartisan Policy Center on the 2016 Report of the Commission on Retirement Security and Personal Savings. (February 22, 2019)
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 19, 2019)
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 19, 2019)
Life Reserves Work Group comment letter to the Life Actuarial (A) Task Force regarding exposed APF 2019-04, which seeks to provide clarification for expense allowance formulas for universal life with secondary guarantee (ULSG).  (February 19, 2019)
Life Experience Committee comment letter to Life Actuarial (A) Task Force on questions raised during the NAIC Fall 2018 National Meeting rearding the current process used to develop the AG38 and VM-20 annual mortality improvement scale recommendations. (February 19, 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 15, 2019)
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 15, 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 13, 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 31, 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 22, 2019)
Medicaid Subcommittee letter to CMS providing comments on Nov. 14, 2018 proposed rule regarding Medicaid and CHIP managed care programs. (January 14, 2019)
Role of the Actuary Subgroup comment letter to NAIC on the treatment and definitions of the term "actuarial opinion" in VM-30.  (January 10, 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 2, 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 21, 2018)
Academy Pension Vice President letter to U.S. House members on The Retirement, Savings, and Other Tax Relief Act of 2018  (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 18, 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 17, 2018)