"We recommend HHS clarify the proposal for composite rating.... Preliminary analyses of plans using the proposed 2015 AV calculator reveal that many plans that previously met the AV target now fall outside of the de minimis range. Moreover, many plans falling outside of the range will require increases in plan generosity -- which in turn may result in premium increases -- in order to meet the target.... [We] request additional disclosure of ... underlying elements of the AV calculator, including how claims were distributed across the various service categories ... and [t]he frequency units for each of the service categories (e.g., per visit, per service)."  MORE >>