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Re: Exposure Draft: Issues Related to LTC Wellness Benefits
Dear Commissioner Altman,
As highlighted in the exposure draft, actuarial input is important from the beginning of any process involving the consideration, design, and evaluation of a potential long-term care insurance (LTCI) policy approach. An actuarial perspective can provide a basis for exploration of new and innovative review frameworks, including evaluating wellness benefits for the potential impact on LTCI claim severity and health outcomes. Actuaries are uniquely qualified according to their professional standards. Actuaries have specialized expertise in managing the risk of adverse selection in insurance coverages, the ability to recognize and incorporate uncertainty into cost projections and premiums, and experience in evaluating the long-term solvency and sustainability of public and private insurance programs. They play a crucial role in the financing and design of LTC financing systems--from private LTCI to public programs that provide LTC benefits.
Specifically related to some of the considerations raised in the exposure draft, the Academy subcommittee is open to providing research and analysis on:
* Actuarial issues such as valuation, rate increase reviews, and reasonable value of benefits and options impacted by LTC wellness benefits;
* LTC wellness programs in Medicare Advantage,
* Equity and data privacy in wellness programs.
As the subgroup evaluates options to overcome the potential barriers identified in the exposure draft, we would welcome the opportunity to speak with you in more detail about considerations raised in the exposure draft, relevant analysis provided in recent publications from the Academy,/2 and/or any other considerations pertaining to wellness benefits on which actuaries might bring expertise.
If you would like to discuss further, please contact
Chairperson, LTC Reform Subcommittee
2/ For examples of Academy publications, see: