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Comment Letter by the Health Practice Council Rate Review Practice Note Work Group of the American Academy of Actuaries to CCIIO on Revised Unified Rate Review Template and Instructions (PDF)

Specific recommendations include: clarifying language to be added several points in the description of entries for index rate; a change to the description of the entry for projected risk adjustments; adjustments to the description of the entry for reinsurance recoveries and taxes and fees; and changes to the description of AV pricing value.

American Academy of Actuaries Comment Letter to Actuarial Standards Board on Proposed Revisions to Actuarial Standard of Practice (ASOP) No. 27, Selection of Economic Assumptions for Measuring Pension Obligations (PDF)

"There are numerous instances in which the exclusive use of the word 'pension' makes the application of the standard to retiree group benefit practice tenuous. We encourage the ASB to clarify in this ASOP that mastery of pension practice is not the same as mastery of retiree group benefit practice (or vice versa).... In addition, Section 1.1.c. indicates that the purpose of the standard is to enhance those provisions of ASOP No. 6 that relate to the selection and use of economic assumptions.... There are a number of economic assumptions important to retiree health benefit measurement (most obviously, health care cost trend) that are not mentioned in ASOP No. 27."

Risk Management and Public Retirement Systems: Prepared by Public Plans Practices Task Force of American Academy of Actuaries (PDF)

56 pages. Excerpt: Ultimately, the task force, through this report, recommends initiatives to strengthen the management of public pension and post retirement health plans through incorporating an actuarial application of emerging risk management techniques. A continuous risk management practice is an essential component for a sound public employee retirement system.

American Academy of Actuaries Submission to ERISA Advisory Council for DOL Consultation on Interpretive Bulletin 95-1 (PDF)

28 pages. "[This submission includes:] [1] Materials ... outlining the state insurance regulations applicable to life insurance companies operating in the United States. The materials focus on the regulatory framework governing solvency requirements, including the establishment of liabilities and required capital for benefit obligations that are the result of a pension risk transfer. [2] An issue brief authored by the Pension Committee of the American Academy of Actuaries focusing on 'buy-out' annuity contract transactions."

Testimony of American Academy of Actuaries to ERISA Advisory Council on Lifetime Income Solutions as a QDIA (PDF)

"Steps can be taken to improve the util ization of QLACs: [1] Through regulations or legislation, allow variable/index-based returns; eliminate unisex pricing; allow aggregation among DC plans for 25 percent rule. [2] Modify annuity selection safe harbors in order to remove fiduciary concerns. [3] Consumer education, starting with efforts by the DOL."

American Academy of Actuaries Comments to ERISA Advisory Council on Annual Funding Notice for DB Plans (PDF)

"We have three suggestions for improving the notice: narrow the focus, encourage helpful narrative, and provide generic information on the internet. We have included a sample of the first two pages of the notice incorporating the key suggestions in the appendix to this letter."

American Academy of Actuaries Testimony to the ERISA Advisory Council on Model Notices and Disclosures for Pension Risk Transfer (PDF)

"The [Academy] offers the following recommendations ... [1] Develop consumer information material to be made available on the DOL website, or another appropriate government or government-sponsored web portal, to provide objective information to plan participants being offered a lump sum distribution, either through a pension risk transfer transaction (i.e., lump sum window) or in the course of regular plan administration.... [2] Consider additional mandatory disclosures to be made by plan providers to assist plan participants in evaluating a lump sum offer.... [3] Review the current relative value disclosure requirements to ensure they are adequately addressing the needs of today's plan participants."

Text of Statement of American Academy of Actuaries to ERISA Advisory Council: 'Managing Disability Risks in an Environment of Individual Responsibility' (PDF)

"Starting to save early, saving consistently, investing prudently, and avoiding early use of retirement funds can lead to a financially secure retirement.... Unfortunately, there is much less activity in addressing another serious threat to the retirement security of workers: ... the loss of earnings and the related ability to save for retirement due to a long-term disability. While most of the challenges mentioned earlier can be addressed by improving individual decisions, the individual generally has little control over the onset of a disability. Losses due to disability are not adequately mitigated by saving more or starting earlier."

Testimony of American Academy of Actuaries to ERISA Advisory Council on DB Plan Funding Issue (PDF)

14 pages. Excerpt: The investment risks, coupled with complicated solvency rules after three years of low interest rates and market returns have created a funding crisis for DB plans. At the same time, plan participants are starting to appreciate the value of being covered by a DB plan. Employees are beginning to recognize the value of the commitment and insurance element of pooling both investment risk and mortality risk through a company-sponsored plan.

Comments of American Academy of Actuaries on HHS' Essential Health Benefits Bulletin (PDF)

The American Academy of Actuaries' Health Practice Council appreciates the opportunity to provide comments on the recently released [HHS] research brief, 'Actuarial Value and Employer-Sponsored Insurance.' ... There are additional factors that should be considered when interpreting the results and formulating policies to regulate [actuarial value] calculations for [employer-sponsored insurance]: ...

Comments by American Academy of Actuaries to Senate Finance Committee on Improving the Individual Health Insurance Market and Changing the Approach to Medicaid Funding (PDF)

"Continuing uncertainty could lead to additional insurers exiting the market, leaving consumers with fewer insurance choices -- or none at all. Improving the market would entail funding cost-sharing reductions (CSR) reimbursements, enforcing the individual mandate (or other continuous coverage provisions), directing external funding to offset premiums, and avoiding destabilizing actions."

American Academy of Actuaries Comment Letter to California Actuarial Advisors Panel on Model Actuarial Funding Policies and Practices (MAFPP) for Public Pension Plans (PDF)

"The subcommittee recommends that the MAFPP specifically be limited to ... ongoing public pension plans (i.e., plans whose members earn future accruals and that are open to new hires).... [T]he MAFPP would categorize the current Pension Protection Act (PPA) funding method (traditional unit credit) as 'unacceptable'. This seems politically sensitive and potentially highly charged."

American Academy of Actuaries Comments on Proposed Revision of Actuarial Standard of Practice on Selection of Economic Assumptions for Measuring Pension Obligations (PDF)

"The Pension Committee of the American Academy of Actuaries [provides] comments on the Actuarial Standards Board's proposed revision of ASOP No. 27[.]"

American Academy of Actuaries' Comments on Proposed Revision of Actuarial Standard of Practice (ASOP) No. 35 (PDF)

Excerpt: The Pension Committee of the American Academy of Actuaries appreciates the opportunity to provide comment on the Actuarial Standards Board's (ASB) revision of ASOP No. 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations.

New American Academy of Actuaries Practice Note on Working with Pension Plan Auditors (PDF)

The Academy's Pension Accounting Committee has issued a practice note with information for actuaries on current practices relevant to the audit of pension plan financial information that is subject to US generally accepted accounting principles (US GAAP).

ACOPA Comments to American Academy of Actuaries on Exposure Draft of Public Policy Practice Note on Variable Annuity Plans (PDF)

13 pages. "The scope of the Exposure Draft should be expanded to discuss the application of Code Section 411 (a)(9) and Section 415 to VAPs.... The Exposure Draft should include empirical data and analysis supporting the use of a 'pure' VAP as the baseline for discussion of liability measurement and lump sum determination for a VAP.... The Exposure Draft should encourage actuaries to disclose benefit determination and regulatory uncertainties known to the actuary, the financial implications of such uncertainties, and if the actuary is relying on outside counsel or the plan administrator for plan document and/ or regulatory interpretations."

Comments of American Academy of Actuaries on HHS' Research Brief Entitled 'Actuarial Value and Employer-Sponsored Insurance' (PDF)

"The American Academy of Actuaries' Health Practice Council appreciates the opportunity to provide comments on the recently released [HHS] research brief, 'Actuarial Value and Employer-Sponsored Insurance.' ... There are additional factors that should be considered when interpreting the results and formulating policies to regulate [actuarial value] calculations for [employer-sponsored insurance]:"

American Academy of Actuaries' Answers to Questions Posed by Joint Select Committee on Multiemployer Plans (PDF)

39 pages. "On behalf of the Pension Practice Council of the American Academy of Actuaries, I appreciate the opportunity to provide the following responses for the record to questions provided us pursuant to [April 18, 2018 hearing on] The History and Structure of the Multiemployer Pension System[.] ... The Pension Practice Council ... stands ready to help you at each step of the way with objective and nonpartisan input." [Editor's note: Includes more than 40 questions from legislators, with detailed answers.]

American Academy of Actuaries Comments to House Ways and Means Committee on Expanding Access to Public Insurance Plans (PDF)

33 pages. "Proposals to expand access to public health insurance plans are being put forward to provide a way to supplement efforts to strengthen insurance markets under the [ACA] or to replace the ACA marketplaces and/or other health insurance programs altogether.... This issue paper ... outlines four approaches aiming to achieve such goals and highlights the key design elements that would need to be specified for an approach to be fully evaluated and implemented."

American Academy of Actuaries Comment Letter to HHS on Proposed 'Actuarial Value Calculator' (PDF)

"The Health Practice Council submitted a comment letter to the Center for Consumer Information and Insurance Oversight (CCIIO) providing responses to questions ... on the structure of a proposed actuarial value calculator (for purposes of the ACA). The letter addresses cost-sharing inputs for the calculator, incorporation of induced demand, number of geographic pricing tiers, and incorporation of multiple network tiers."