Medicare comment letter 1(Oct. 4, 2004)

October 4, 2004 Centers for Medicare & Medicaid Services Department of Health and Human SeAttention: CMS-4068-P Room 445-G, Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, DC 20201 Dear Sir or Madame: 1This letter presents the comments of the American Academy of Actuaries’ Actuarial Equivalence Work Group regarding the Centers for Medicare and Medicaid Services’ (CMS) proposed regulations (CMS-4068-P) on the Medicare prescription drug benefit portion of the Medicare Modernization Act (MMA). In particular, this letter discusses actuarial equivalence issues related to prescription drug plans (PDPs), Medicare Advantage (MA) plans, Medicare supplement plans, and retiree health benefits. (We provide comments on other Medicare PDP and MA issues in separate letters.) We provide comments, where appropriate, on issues specifically requested by CMS, and we also comment on other issues where we feel our perspective may be useful. Determining actuarial equivalence with respect to the Medicare prescription drug benefit is a complex task and our comments only begin to address CMS’s concerns regarding implementation of the MMA. The Academy would be glad to meet with CMS to elaborate on these issues and to help develop practical ways to implement the MMA. We suggest that wherever possible, CMS provide numerical examples to further clarify the various regulatory provisions. The proposed rule requires Part D plan sponsors, ...