Comment letter to NAIC Statutory Accounting Principles Working Group (Aug. 29, 2001)

August 29, 2001Norris ClarkChair, Statutory Accounting Principles Working GroupNational Association of Insurance Commissioners2301 McGee, Suite 800Kansas City, Missouri 64108-2604RE: Comments on Items Discussed at the June 2001 SAPWG MeetingDear Mr. Clark:1The Health Practice Financial Reporting Committee (HPFRC) of the American Academy of Actuarieswas formed earlier this year and charged with the responsibility on behalf of the actuarial profession forcommenting on health insurance financial reporting issues.We wish to comment on some of the items discussed by the Statutory Accounting Principles WorkingGroup at its June 2001 meeting.#2001-22 (Conflicting References)In responding to this issue, the Working Group has proposed an amendment to paragraph 37 of SSAP No.54 (Individual and Group Accident & Health Contracts). We have a concern with both the proposedamendment and the paragraph as it currently reads, and hence we propose that this paragraph instead beamended as follows:“This statement incorporates the requirements of Appendices A-010, A-225, A-641, A-820, A-822(as applicable), and the Actuarial Standards Board Actuarial Standards of Practice, and theactuarial guidelines found in Appendix C of this manual (as applicable).”We are aware that our proposal would eliminate the current linkage between this paragraph of SSAP No.54 and the corresponding paragraphs of SSAP No. 51 and SSAP No .52. However, we believe that this isfully justified by ...