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Vice Chair, Dartmouth College Geisel School of Medicine

Documentation of the credibility procedure used shall include a description of the procedure cholesterol levels us discount rosuvastatin 10 mg without a prescription, the statistical basis for the specific elements of the credibility procedure cholesterol high medication generic 10mg rosuvastatin mastercard, and any material changes from prior credibility procedures cholesterol rich foods buy cheap rosuvastatin 10mg line. The credibility-adjusted table used for plus segments may be and the credibility adjusted date used for minus segments must be adjusted for applicable published industrywide experience from the experience weighted average date underlying the company experience used in the credibility process to the valuation date cholesterol medication makes me sick discount rosuvastatin 10 mg overnight delivery. If such an adjustment would reduce the Conditional Tail Expectation Amount, such assumptions are permitted, but not required. In either case, the assumption must be based on current relevant data with a margin for error (increasing assumed rates of improvement if that results in a higher reserve, reducing them otherwise). While there is some sentiment for a June adoption with a 2006 effective date, there is general agreement that adoption in September with effective in 2007 is still acceptable. We have sent a data call to member companies, and are expecting results by early May. As such, we would ask that no changes to the Guideline be exposed until there are numbers to look at to validate the issues already on the table. There was a discussion on the appropriate level of reserves, since the answer to that seems to drive all other discussions. At the current time, actuarial standards of practice talk about `moderately adverse deviations. A requirement for Prudent Best Estimate Assumptions for lapses, mortality, policyholder behavior, etc. It is also important to look at reserve levels in the context of total minimum capital requirement. To be consistent, reserve levels should bear a reasonable relationship with total capital requirement and, when both capital and reserves are determined on the same date, the reserve level should be less. This is clearly an area where model results should be relied upon, and is a significant focus of our data call. The current exposure draft includes an Option Pricing calculation as part of the Standard Scenario. We discussed the purpose, goals, and problems with the current proposal and raised the following issues: Should the market value of a liability as expressed by the cost to take that risk off the balance sheet constitute a floor value to reserves? New York expressed a belief that the current standard scenario proposal works better at capturing some risks than others. Industry believes that the answer to multiple risks is modeling that looks at results under different environments. Complicating the standard scenario to capture different risks will only work until the next product variation is introduced. There is debate between industry and regulators on the degree of efficiency that should be assumed in the exercise of contractholder options. Industry believes that consumers have shown that they do not exercise options with complete efficiency. Prudent margins are clearly necessary in modeling, but we must also recognize that contractholders have significantly more influences on their decisions than the pure economics of the contract. Influence such as taxation, health, ability to access other assets or sources of funds, and opinions of advisors including agents also contribute to the decision of whether or not to exercise an option. The revenue sharing is part of an agreement between the insurer and a service provider. In this case, the revenue sharing arises because the insurer is performing some of the functions that the service provider normally performs and the revenue sharing is a way for the insurer to cover some or its administrative or distribution expenses. The insurer can take that business to another provider if that is advantageous, and in the event of a receivership situation, the insurer still owns the assets and will still hire a service provider. While a strong governance and peer review process will help control any abuses, the oversight work for state regulators will increase dramatically. Industry does not want to implement a process where the controls are exercised by a formulaic minimum that is conservative enough to produce a de facto formulaic reserve with the stochastic modeling serving as an enhanced asset adequacy test. In addition, it is adaptable to new products and changes to assumptions as additional experience with policyholder behavior emerges. We also recognize there are varying opinions about many of the provisions in the draft guideline. Second, our recommended changes for the Standard Scenario contains a component called the Surrender Charge Amortization Period. Attached to this letter is a document describing the provision and an example of how it is determined. Because of this amortization, we believe there is potential for double-counting of benefits in the current Standard Scenario calculation.

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Assumptions Assumptions that should be included in claim reserves calculations include high cholesterol levels chart australia cheap 10mg rosuvastatin with mastercard, but are not limited to: seasonality cholesterol levels per country discount rosuvastatin 10mg free shipping, experience blending with tabular reserves cholesterol test at walgreens purchase rosuvastatin 10 mg line, use of disability cause for tabular reserves cholesterol calculator generic 10 mg rosuvastatin amex, other disability income benefit provisions, disability income offsets, and cost of living adjustments. Seasonal Effects Some types of coverage experience seasonal variations in claim costs. Multiple years of data are required to reasonably estimate the impact of seasonal effects, and changes in the levels of benefits, plan provisions, and enrollment as well as trend, can mask the impact of these effects. Blending of Carrier Experience for Tabular Reserves For tabular reserves it is often desirable to blend carrier experience with industry tables in order to reflect an increased level of carrier experience credibility at early durations where claims are more frequent. For example, for disability insurance, some carriers make no modifications to the valuation table, some modify the first two years, and very few © 2006 National Association of Insurance Commissioners 11 1747 Attachment Forty-A Life and Health Actuarial Task Force 6/8-9/06 modify the first five years. The ultimate test for the appropriateness of the modifications of the table is reserve adequacy testing. A few go into even further detail in setting termination assumptions by cause (musculoskeletal, circulatory, etc. Termination rates varying by cause of claim are usually only made in the early claim durations when an insurer is using its own experience. Claim reserves utilizing termination rates that vary by cause of claim are generally more responsive to changes in the mix of claims. They are, therefore, less likely to result in redundancies or inadequacies due solely to changes in the mix of claims. However, if an adjustment to tabular rates is made to reflect cause of disability, it is important for the actuary to also make adjustments to the tabular rates for all other disabilities to reflect the differing characteristics of that remaining subgroup. It remains the responsibility of the actuary, however, to ensure that the reserve is appropriate and adequate to provide for future liabilities. There are lower termination rates and greater claim durations associated with longer own occupation periods. However, companies generally do not adjust statutory minimum claim reserves to recognize the higher costs associated with longer own occupation periods in the definition of disability. With regard to residual benefits Health Practice Note 1995-5, "Individual Disability Income Insurance," states that, "theoretically a different continuance table and approach from that used for base (totally disabled) claims could be appropriate (for residual claims). One common approach is to multiply the base claim reserve by the ratio of the current benefit to the maximum (or basic) benefit. Although this approach may not be theoretically precise, the error may be small and covered by the overall margin in the reserve. By overlooking these additional costs, the adequacy of the claim reserves could be reduced. In establishing claim reserves, companies should reduce the monthly benefit for currently payable offsets, whether their reserves are based on their own experience or on the prescribed industry morbidity table. Companies may also consider reducing the offset by assigning a probability for the potential of losing current offsets or modifying termination rates on claims where Social Security benefits are currently being paid. With regard to future potential offsets, the most common offsets are the following: Social Security (Primary and Family), Public Employee and Railroad retirement benefits, Canadian and Quebec Plans (Primary and Family), Workers Compensation Benefits, State Disability Benefits, and Short Term Disability Benefits For reserving purposes the key contingencies are: the probability of obtaining an offset, the probability of losing a current offset, the estimated amount of the offset, and the estimated duration of payment for the offset Group disability claim reserves are significantly impacted by the adjustments made and assumptions set with regard to Social Security and other offsets. By setting proper assumptions for benefit offsets the appropriateness of the calculated reserve is greatly enhanced. The approval process for many offsets is subject to the political process where approval requirements can change quite quickly. It is, therefore, important that the actuary consider the future changes rather than to rely solely on past experience. In all cases, however, it is incumbent upon the actuary to ensure that the calculated claim reserves, net of offsets are adequate and reasonable and meet the minimum regulatory standards. However, there is no statutory minimum standard to define the inflation assumption. A reasonable approach is to use an inflation assumption equal to the discount rate less an estimate of a real interest rate. Once the inflation assumption is chosen, many actuaries project the exact annual increases in benefits due to the cost of living rider, given the underlying continuance table, and calculate exact claim reserves.

Shirley Kerns (Service Contract Industry Council) suggested that Blanks should only reflect a definition for premium reported by insurers cholesterol test blood fasting generic rosuvastatin 10 mg overnight delivery. Barclay said the reason for requiring a two-year triangle versus a 10-year triangle was because the reporting for this business takes place quickly after occurrence cholesterol journal pdf rosuvastatin 10mg mastercard. While there would be a significant time delay between the date the policy would be written and the occurrence cholesterol lowering foods 2015 purchase rosuvastatin 10 mg otc, a 10-year reporting horizon would not generate much data streefwaarde cholesterol ratio discount rosuvastatin 10mg mastercard. He added that accident year reporting for this line would not make much sense because there would be little time period between the accident date and payment date. If the triangle used the policy issue date of the service contract, then there would be a long triangle. Germani said that there was a company in Texas reporting the 10-year home warranty by the issue date. Barclay said that all of this business would be recommended to be part of the new line. If contractual liability was included with Other Liability, then the triangle data for Other Liability could be distorted. Discuss Referral Concerning Defense Only Coverage and the Coding of Claims as Loss or Loss Adjustment Expense the Emerging Accounting Issues (E) Working Group referred a question about the Coding of Claims as Loss or Loss Adjustment Expense for Defense-Only-Coverage (Attachments Eight-E and Eight-F). The Task Force discussed that, unlike typical indemnity where there was coverage for loss plus legal proceedings, the only insured peril for these policies was legal cost. Initial reaction was that defense costs would be reported as loss adjustment expense in the Defense and Cost Containment category, although there was some question in this case when the loss is the only peril. Some questioned the appropriateness of recording defense cost as loss adjustment expense without a loss component for the policy. Status of the Extra Contractual Proposal the Task Force met jointly with the Statutory Accounting Principles Working Group April 4, 2006, to discuss the Extra Contractual disclosure proposal. The previous disclosure to modify Schedule P would be withdrawn and replaced with a Note to include only the total paid amount and total number of those claims. The changes mirrored the previously proposed changes to the Property/Casualty Instructions, including the electronic filing of data and additional information required in the Exhibits. The proposal would maintain the desired consistency between the Title and Property/Casualty instructions. Germani asked if the instructions should be modified to require opining on gross reserves in addition to net reserves. Marcks said that change would be a more significant change than what is in the proposal and recommended postponing discussion as a separate issue. Miller suggested that the Task Force have a separate call on the issue to discuss potential responses and to determine whether to supply comments individually or from the Task Force. Discuss International Activities the Task Force was charged to monitor international casualty actuarial developments and consider regulatory implications. The Task Force had commented on some International Actuarial Association papers, but there were some additional papers for the Task Force to review. Miller said that she recognizes the high volume of these papers, but believed that the Task Force should provide input on some of the actuarial issues, especially as they relate to regulation. Taylor said that the property and casualty issues did not seem as developed as the life issues. She said there were numerous issues related to financial reporting, accounting, reserving, and ratemaking. For financial reporting, the current reported amounts might not be reasonably consistent between companies and the Subgroup was not sure how regulators are using the current reporting. The accounting issue was that this reserve was really a forward-looking reserve and some believed it was questionable whether the reserve was still needed. For reserving, there was no generally accepted method in how reserves should be calculated and tested for reasonableness. Appointed Actuaries must disclose these amounts in their opinions, but there were no detailed comments on the reasonability of those reserves. A ratemaking issue was that some companies have an explicit risk load so there is a charge to current policyholders to fund this future-looking reserve. Purple said that it seemed the Subgroup would want to address all of the issues and that the charge should be expanded. Greiner agreed but said the Subgroup wanted to discuss the issues, but were not necessarily going to have all of the answers.

Wolf responded that the antimoney laundering requirements are requirements that are placed upon companies and not producers measuring cholesterol in eggs 10 mg rosuvastatin mastercard. Schafer then questioned if there are uniform training programs for producers since a producer who is appointed to multiple companies might be subject to varying programs cholesterol levels normal range chart australia generic rosuvastatin 10 mg with visa. John Fielding (Council of Insurance Agents & Brokers) said the American Council of Life Insurers has developed uniform training programs for producers cholesterol test malaysia generic rosuvastatin 10mg online. Wickman said the suggested revisions also add stop loss insurance (excess health insurance) total cholesterol test definition cheap rosuvastatin 10mg free shipping. The Working Group then discussed the coordination of the Large Deductible Implementation (C) Working Group with the Producer Licensing (D) Working Group and the need for the Market Regulation and Consumer Affairs (D) Committee to approve and adopt the proposed changes. Wickman then requested that all comments on the draft be submitted to the Large Deductible Implementation (C) Working Group by the end of May. Wolf noted that any changes made to one application, where applicable, would be made to the renewal and reinstatement applications as well. Seward suggested the dates of those authorized to work in the United States be captured. Seward said the change will alleviate the burden of the verification process by the nonresident state and should clarify what the applicant expects. Reed explained that individuals could be eligible for an extension of dates after the submission of the application. Wolf said she does not think this information is needed and indicated the Working Group would not adopt this change unless other members of the Working Group believe this change is needed. There was no other member of the Working Group that indicated this change is needed. At the same time, the electronic application will be changed to read the same as the paper application. The electronic application currently asks for "nationality" rather than citizenship. The electronic application will be changed to read, "Are you a Citizen of the United States? Sam Meyer (Sircon Corporation) said the addition of this field would result in the need to make 250 changes on various forms for the states and result in a substantial coding effort. Kuzmich suggested the deletion of the phrases "to do business" and "currently doing business or intend to do business. Kuzmich said it is important to know all the past names used by someone, whether used in the course of business or not, for purposes of discovering other convictions, disciplinary actions by other entities, or even past actions by a state insurance department. The Working Group agreed to change this question to read as follows: "List any other assumed, fictitious, alias, maiden, or trade names which you have used in the past. Maldonado said this is needed because a producer may be applying to more than one state. Wilson said the same problem exists for Question 25 of the business entity application. After a brief discussion, the Working Group agreed to retain question 37 in its current format. Tordjman said applicants will answer this question 39(1) in error, when their adjudication was withheld, because they do not understand what "adjudication was withheld," means. Brunette then questioned how states classify driving with a suspended/revoked license. With this, the Working Group agreed to change this question to read as follows: "Crime" includes a misdemeanor, felony or a military offense. Vourvopoulos said she would like to see the question expanded to include the capture of a "charging document. Finally, the Working Group agreed to move the 1033 questions to the end of question 39(1). Question 39(1) now reads as follows: Have you ever been convicted of a crime, had a judgment withheld or deferred, or are you currently charged with committing a crime? Chaskey requested the phrase "registration or professional designation" be inserted after the word "license. Chaskey said New York receives notices for suspension of use of a professional designation from the society/institute where the underlying conduct falls within the grounds for revocation.

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