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June 08, 2003 at 08:00 PM
To The Editor:
I want to note that the opinions I express in this letter are mine and not necessarily those of my employer.
I believe laws and regulations work best when they mirror the United States decentralized form of government. An example of this came to me after a National Association of Insurance Commissioners Life and Health Actuarial Task Force conference call.
Recent changes to the NAIC model actuarial opinion and memorandum regulation (AOMR) did not reflect the fact that some indemnity health companies will begin using the orange health annual statement blank and instructions instead of the blue life and health annual statement blank.
The model AOMR includes a table of items and amounts with respect to which the actuary expresses a statement of actuarial opinion. The recommended language and items and amounts with respect to which the actuary expresses a statement of actuarial opinion submitted with a health annual statement appear on pages 27 and 28 of the 2003 NAIC annual statement instructions for the health insurance annual statement. These items clearly are not consistent with the life blank.
My suggestion was to remove the specific references in the AOMR model and direct the appointed actuary to the life and health or health annual statement instructions. The life and health annual statement instructions would then be amended to include the appropriate language deleted from the model.
The advantage is clear: Annual statement pages and line numbers are not the same from year to year. State regulations should change infrequently so that companies can plan ahead. Making changes in the annual statement instructions, where the NAIC has fixed procedures involving regulators and interested parties from companies and the public, allows greater flexibility and quicker action. This is similar to local governments placing and relocating traffic signals and stop signs in their towns.
