Public Policy Comments and Letters

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)
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 13, 2018)
Non-Guaranteed Elements Work Group comment letter to NAIC on their proposal for a life insurance online guide landing page.  (November 28, 2018)
Retirement System Assessment and Policy Committee letter to Congress on the Retirement Enhancement and Savings Act of 2018.  (November 16, 2018)
Letter from Academy Past President Mary D. Miller to NAIC with comments on CASTF’s draft 3-year experience proposal. (November 8, 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 30, 2018)
Life Operational Risk Work Group follow-up letter to NAIC on exposed Life Risk-Based Capital growth charge proposal.  (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 19, 2018)
Subcommittee comments on the impact on Health Risk-Based Capital (HRBC) from the Tax Cuts and Jobs Act of 2017 (TCJA). (October 18, 2018)