American Academy of Actuaries: Health Equity Work Group Sends Comment Letter to National Association of Insurance Commissioners Committee on Revised Health Insurance Data Principles Exposure Draft

WASHINGTON, Nov. 16 -- The American Academy of Actuaries issued the following letter to Comments on the Revised Exposure Draft of Principles for Data Collection:

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To: Commissioner Jessica Altman, Co-Chair, Commissioner Ricardo Lara, Co-Chair, Special (EX) Committee on Race and Insurance--Workstream 5 (Health), National Association of Insurance Commissioners (NAIC)

Attn: Jolie H. Matthews, Senior Health and Life Policy Counsel, NAIC

Re: Comments on the Revised Exposure Draft of Principles for Data Collection

Dear Commissioners Altman and Lara:

On behalf of the American Academy of Actuaries1 Health Equity Work Group (HEWG), I appreciate the opportunity to offer comments on the exposure draft of the Revised Principles for Data Collection (Principles) document released by the NAIC's Special (EX) Committee on Race and Insurance--Workstream 5 (Health) on October 15, 2021. Our suggestions reflect the need for uniformity and consistency across all types of entities assuming health insurance risk.

We recognize the need for consistent, accurate, and comprehensive collection of data to understand and quantify health disparities and evaluate the effectiveness of initiatives to address health inequity. We believe the Principles document will go a long way toward achieving your goals and would serve as a framework not only for state departments of insurance, but also for other governmental agencies regulating entities bearing health insurance risk as they develop criteria for the collection and use of demographic and other related policy-level data. We also acknowledge the need to start addressing this type of data collection sooner rather than later, yet we suggest that the framework should allow flexibility to refine these processes as our collective understanding of the issues and opportunities related to the collection and analysis of this type of data become more apparent.

Finally, we note that insurers following consistent principles could decide to use valid yet different sets of data collection questions. Unless data are collected in a uniform way, the ability to analyze the data at a market level or geographic area level could be compromised. Therefore, you may wish to encourage in the data collection principles uniformity in addition to consistency of the collection of the data addressed in the Principles document.

Please find our redlined edits and comments in Attachment A.

We note that the Academy's Health Equity Work Group is looking at health equity from a broader perspective, which includes race and ethnicity concerns across all types of health plans. The work group is also exploring issues related to algorithms and the use and collection of data as they relate to health equity. As we continue our work in these areas, we hope to have the opportunity to provide you with our findings and further recommendations and to learn from your experience as you work with states in launching these principles.

Thank you for the opportunity to provide input on the revised Principles for Data Collection. We welcome the opportunity to speak with you in more detail and answer any questions you have regarding these comments or on other topics related to health equity. If you do have any questions or would like to discuss further, please contact Matthew Williams, the Academy's senior health policy analyst, at [email protected].

Sincerely,

Annette V. James, MAAA, FSA, FCA

Chairperson, Health Equity Work Group

American Academy of Actuaries

CC: Brian R. Webb, Assistant Director, Life and Health Policy and Legislation, NAIC