Should a new individual disability table split employer business?

"Fully underwritten multi-life business has better experience," Koch and Streck wrote in a comment letter.

If insurers started using the draft table as is, they could end up setting reserves too low for guaranteed standard issue programs, and especially for voluntary guaranteed standard issue programs that let workers in a group choose whether to apply and pay for coverage, the actuaries said.

Koch and Streck said regulators should consider distinguishing between underwritten individual disability purchased through an employer-sponsored program, employer-paid individual guaranteed standard issue coverage, and voluntary, employee-paid individual guaranteed standard issue coverage purchased through an employer-sponsored program.

Koch and Streck also asked table drafters to think about distinguishing between different types of medical professionals, rather than creating a single medical professional category.

"Chiropractors and nurses are a much different risk than pediatricians and allergists," the actuaries said. "Specialists doing invasive procedures are a different risk than those primarily doing office visits. This is evident when looking at how companies assign the various medical occupations to classes for pricing purposes. If there is going to be a separate standard for medical, it seems that there should be more than one class."