Letter to John Fritz on Proposed RBC Risk 12-03-05

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V. Future Considerations. Ultimately, the RBC factors applicable to Medicare Part D should be based on an analysis of actual experience for the coverage. However, it will be several years before a credible body of experience can be accumulated, and the analysis of that experience and the recommendation and adoption of RBC factors will require additional time. Accordingly, it will not yet be possible for the Academy to use this approach for a recommendation for the 2008 RBC formulas. The reporting entities’ additional experience with Medicare Part D should improve their ability to price the coverage, thereby reducing the potential for material deviations from expected levels of benefit costs. We therefore recommend that a study somewhat similar to the study undertaken for this recommendation be performed in 2007, modified as deemed appropriate from experience gained for Medicare Part D to that time, in order to develop appropriately modified factors for the four-year period, 2008-2011. To facilitate further analysis for later year recommendations, we suggest that the NAIC adopt a standardized format for collecting Medicare Part D experience from the participating legal entities on an annual basis.

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