Consumer advocates who work with the National Association of Insurance Commissioners say the organization deserves passing marks for most of its efforts.

The consumer advocates who assigned the ratings are “funded consumer representatives,” or individuals who receive stipends from the NAIC, Kansas City, Mo., to help them represent consumer interests at NAIC meetings.

One of the best known consumer representatives, Birny Birnbaum, urged the NAIC to expand its market analysis operations. He noted here at the NAIC’s winter meeting that the market regulation section of the NAIC’s budget got the smallest allocation.

But “you do have consumers in your interest at all times,” Birnbaum said. “I have never failed to believe that you are trying to protect consumers.”

Birnbaum gave a grade of “very good” to NAIC work on the viatical settlements model, portions of the principles-based reserving project relating to term life insurance, and most life insurance and annuity projects.

Birnbaum said he is “greatly disappointed” in the new Interstate Insurance Product Regulation Commission because of concerns about issues such as public accountability and public access.

Mila Kofman, another funded consumer representative, gave the NAIC an “A” for its opposition to the Health Care Choice Act, which would have let a health insurer domiciled in any state sell coverage in any other state without obeying the rules in the purchaser’s state. But Kofman gave the NAIC an “F” for its response to S.B. 1955, a bill that would have let small employers get around their own states’ health insurance laws and regulations by joining national association health plans that would be supervised by the associations’ home-state regulators.

Karroll Kitt praised the NAIC’s new Insure U consumer education program.

Brenda Cude gave the NAIC an “incomplete” on consumer disclosures. The “incomplete” will become an “F” if the NAIC fails to advance disclosure efforts by the end of 2007, Cude said.

Bonnie Burns, a consumer rep who retired from her position at the winter meeting, said she is disappointed that the NAIC’s revised Long-Term Care Model Act and regulation require only 8 hours of initial training for agents who sell long term care insurance.