AHIP Comments on VM Maintenance Agenda Item 2017-81
January 12, 2018
Page 1
January 12, 2018Submitted electronically
Mr. Mike Boerner
Chair, Life Actuarial Task Force
National Association of Insurance Commissioners
2301 McGee Street, Suite 800
Kansas City, Missouri 64108-2662
Re: Proposed Changes to Valuation Manual – Maintenance Agenda Item 2017-81
DearMr. Boerner:
America’s Health Insurance Plans (AHIP)’s members provide insurance coverage for health care and other related services to improve and protect the health and financial security of consumers, families, businesses, and public programs.For many of these products, we do not believe that there is a useful reserve-focused need for industry data.
There have been times in the past where industry data has been collected, never used to address actuarial assumptions used in reserves, but has been offered for sale by the NAIC. We are concerned that this data is not needed for reserve and solvency considerations, and will represent significant data collection and reporting resources and time on the part of insurers. We are concerned that the data represents a resource for the NAIC as information to be used to develop and provide reports for sale, and the NAIC’s move to become the statistical agent could be to position itself to sell potentially valuable information to researchers and competitors. Statistical agents have profited from data collection,but they have also assisted in the collecting of it. History has shown little consideration of insurers’ costs of maintaining the data in the format demanded by the NAIC to meet their data calls.
As such, we oppose the changes to the Valuation Manual that would establish the NAIC as the statistical agent for the Valuation Manual collection required by the SVL Section 13 with respect to health insurance - unless the Manual clearly establishes limits on what data could be collected, and approaches it with a conservative consideration of the frequency and complexity of submitting the data. For example, where there is a long tail to claim reserves (e.g. DI and possibly LTC), the collection of claim termination data could be seen as truly useful. However, claim incidence and claim payment amounts vary widely by type of product, as do elimination and deductible values and contract terms. These are examples of the types of data that should be specifically excluded from potential experience data to be collected by the NAIC.We urge consideration of these concerns, and would be pleased to have further discussions on data collected.
If you have any questions, please contact me.
Sincerely,
William C. Weller
Actuarial Consultant to AHIP
c/c: Kevin Dyke, Chair Health Actuarial Task Force
ReggieMazyck, NAIC Staff
Eric King, NAIC Staff
Candy Gallaher, AHIP