March 5, 2018
To:Steve Ostlund, Chair Health Reserves Subgroup
Eric King, NAIC Staff
Re: Exposures APF-25 Changes and APF-30 Changes
Americas’ Health Insurance Plans (AHIP)[1], American Council of Life Insurers (ACLI)[2], and Blue Cross and Blue Shield Association (BCBSA)[3] appreciate the opportunity to provide these comments on the proposed changes to the 2019 Valuation Manual sections VM-25 and VM-30.
Overall, we are supportive of the increased clarity for which mortality tables are to be used for health insurance contract reserves as proposed in APF-VM-25 Changes. Attached is our alternative wording with respect to the use of mortality tables with separate rate based on smoker status (or tobacco use status). We believe that regulations limiting the ability of companies from using mortality tables consistent with rating classifications is inconsistent with the NAIC move toward more use of principles-based reserves as the minimum requirements. Since health reserves are only somewhat aligned with the PBR approach, we have suggested that the use of separate mortality tables be subject to the approval of the domestic state insurance Commissioner.
We support the proposed wording as exposed for APF-VM-30 Changes to incorporate AG51 into the 2019 Valuation Manual.
We appreciate the opportunity to provide these comments.
Sincerely:
William WellerSteve ClayburnBarbara Klever
Consultant to AHIPACLIBCBSA
301-695-2697202-624-2197312-297-5875
c/c:Candy Gallaher, ACLI
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1America’s Health Insurance Plans (AHIP) is the national trade association representing the health insurance community. AHIP’s members provide health and supplemental benefits through employer-sponsored coverage, the individual insurance market, and public programs such as Medicare and Medicaid. AHIP advocates for public policies that expand access to affordable health care coverage to all Americans through a competitive marketplace that fosters choice, quality, and innovation.
2ACLI is a Washington, D.C.-based trade association with approximately 290 member companies operating in the United States and abroad. ACLI advocates in state, federal, and international forums for public policy that supports the industry marketplace and the 75 million American families that rely on life insurers’ products for financial and retirement security. ACLI members offer life insurance, annuities, retirement plans, long-term care and disability income insurance, and reinsurance, representing 95 percent of industry assets, 93 percent of life insurance premiums, and 98 percent of annuity considerations in the United States.
3The Blue Cross and Blue Shield Association is a national federation of 36 independent, community-based and locallyoperated Blue Cross and Blue Shield companies that collectively provide health care coverage for one in three Americans. BCBSA provides health care insights throughThe Health of America Reportseries and the nationalBCBS Health Indexsm.