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Regulatory Resource for Actuaries: Long-Term Care (LTC)

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Table of Contents



Last reviewed: 11/21/2019

Recent Updates

Actuarial Professionalism

Actuarial Standards Board - ASOPs  
Adopted Standards, Exposure and Discussion Drafts

Actuarial Standard of Practice No. 5 - Incurred Health and Disability Claims
This revision of ASOP No. 5 reflects a number of changes to other standards that have been made since the 2000 revision, including updating the ASOP. (Posted 4/2018)

Actuarial Standard of Practice No. 18, Long-Term Care Insurance  
The revised edition of Actuarial Standard of Practice (ASOP) No. 18, Long-Term Care Insurance. (Posted 2/1999)

Actuarial Standard of Practice No. 22, Statements of Opinion Based on Asset Adequacy Analysis by Actuaries for Life or Health Insurers
This, along with a revision of ASOP No. 7, now titled Analysis of Life, Health, or Property/Casualty Insurer Cash Flows, supersedes ASOP No. 14, When to Do Cash Flow Testing for Life and Health Insurance Companies, which has been repealed, all effective April 15, 2002. (Posted 4/2018)

Actuarial Standard of Practice No. 23, Data Quality
This ASOP sets the generally accepted practice with respect to data quality, and to provide guidance concerning other information relevant to the use of data. (Posted 4/2018)

Actuarial Standard of Practice No. 23, Credibility Procedures
This document is the final version of a revision of ASOP No. 25 now titled, Credibility Procedures. (Posted 4/2018)

Actuarial Standard of Practice No. 41, Actuarial Communications
The current version of ASOP No. 41 has been in effect for eight years, and applies to all U.S. actuaries in all areas of practice. During that time, the ASB has received comments regarding a lack of clarity in the document and confusion in respect to its wording and structural arrangement. One of the ASB’s priorities is to make sure that all ASOPs are clear and unambiguous. (Posted 4/2018)

Actuarial Standard of Practice No. 46, Risk Evaluation in Enterprise Risk Management Standard of Practice   
This link is to a “discussion draft” dated March 2011 and a transmittal memorandum dated September 2012 and includes the final version of ASOP No. 46, Risk Evaluation in Enterprise Risk Management (Posted 2/2017). 

Adopted ASOPs  
ASOP exposure drafts. Exposure drafts are released by AAA for feedback from actuarial community after obtaining Actuarial Standards Board (ASB) and legal reviews.

ASB Adopts ASOP 55 on Capital Adequacy Assessment for Insurers 
The ASB has adopted Actuarial Standard of Practice 55 regarding Capital Adequacy Assessment for Insurers. The effective date is November 1, 2019. (Posted 7/2019)

ASOP Discussion Drafts 
This link is to ASOP Discussion drafts. Discussion Drafts are released as an initial step in seeking comments on changes to existing or creation of new standards of practice. (Adopted 1/1999)

Proposed Actuarial Standard of Practice (ASOP) on Assumption Setting
This document contains the second exposure draft of a proposed ASOP, Setting Assumptions. The deadline for receipt of comments ended July 31, 2019. (Posted May 2019)

Proposed Actuarial Standard of Practice on Modeling
Changes made:

  1. Clearer accommodation of forms of modeling other than financial projection modeling (such as predictive and statistical modeling);
  2. A revision of Scope; 
  3. Addition of Reasonable Model in the Aggregate, and related disclosure;
  4. Inclusion of Reliance on Experts; and
  5. Elimination of the Presentation of Results section.

The comment deadline for the fourth exposure draft, which can be viewed under the “Drafts” tab in “Current Exposure Drafts,” closed on May 15, 2019. (Posted 7/2019)

Code of Professional Conduct
The Code identifies the professional and ethical standards required of actuaries who belong to the Academy.  It sets forth what it means for an actuary to act as a professional.  It identifies the responsibilities that actuaries have to the public, to their clients and employers, and to the actuarial profession.



Actuarial Guideline LI - Application of Asset Adequacy Testing to Long-Term Care Insurance Reserves  
The NAIC adopted Actuarial Guideline LI to provide regulators comfort in connection with the reserve adequacy of companies with material blocks of LTC business. The Guideline has been added to Appendix C of the Accounting Practices and Procedures Manual (APPM). The Guideline has been added to Appendix C of the Accounting Practices and Procedures Manual (APPM), which is available for purchase from the NAIC website.

Year-End 2019 Guidance Published for Actuarial Guideline
The link contains a request for information related to companies’ LTC asset adequacy testing that is being sent to each company filing an AG 51 Memorandum.  The request is related to a Valuation Analysis Review Group of the NAIC project to review AG 51 reserve analysis.

Life and Health Valuation Law Manual
The Life and Health Valuation Law Manual is designed to help appointed actuaries know the requirements of the NAIC model Standard Valuation Law and the Model Actuarial Opinion and Memorandum Regulation. (Subscription required –Posted 4/2018)

Standard Valuation Law 
The Commissioner's Reserve Valuation Method was itself established by the Standard Valuation Law (SVL). The effect of the law is to set the amount of the reserves which life insurance companies are legally required to hold.


Federal Resources

2017 Instructions for Form 1099-LTC Long-Term Care and Accelerated Death Benefits
Form 1099-LTC should be filed by payers of any long-term care benefits, including accelerated death benefits. Payers include insurance companies, governmental units, and viatical settlement providers. (2 pages) (8/2016)

Office of Disability, Aging and Long-Term Care Policy (Office of Assistant Secretary for Planning and Evaluation, U.S. Department of Health and Human Services)  
Information on public policy research and studies regarding long-term services and support. (One web page)


Form Filings

System for Electronic Rate and Form Filing (SERFF)
SERFF Filing Access is an interface to provide the ability to access filings that the participating state has marked available. (One web page)


Interstate Compact

Interstate Compact Form Filing Search

Information on LTC rate and form filings submitted to Interstate Compact for review. (One web page)


Peter DiRito v. MetLife, No. 1-17-3202 (Ill. App. 2018)
The Illinois Appellate Court affirmed the lower court’s holding in favor of the insurer, that an LTCi insured failed to allege circumstances under which the insurer (which expressly disclosed that premiums could increase), had a duty to disclose any additional information about the likelihood or amount of future increases.  (Posted 6/2019)

Mike Howisey, et al. v. Transamerica Life Insurance Co., No. 17-36045 (9th Cir.)
The Ninth Circuit Court of Appeals affirmed a summary judgment in favor of the insurer, holding that an LTCi policy’s nursing home benefit did not cover the insured’s stay at an assisted living facility because the policy clearly distinguished between coverage for nursing homes and coverage for assisted living facilities. (Posted 6/2019) 

NAIC Committees, Task Forces & Working Groups

Long-Term Care Valuation (B) Subgroup
The Subgroup's goal is to assist the Health Actuarial (B) Task Force on topics related to LTC valuation.  (One web page)

LTC B/E Task Force
The Joint Long Term Care Insurance Task Force of the Health Insurance (B) Committee and the Financial Condition (E) Committee is charged with coordinating all aspects of the NAIC's work regarding the long term care insurance market.

NAIC Creates LTC Insurance (EX) Task Force
The Task Force was formed to deal with the threat posed by the current long-term care insurance environment. The Task Force is to develop a consistent national approach for reviewing rates that result in actuarially appropriate increases granted by the states in a timely manner, eliminate cross-state rate subsidization, to identify options to provide consumers choice regarding modifications to long-term care insurance (LTCI) contract benefits where policies are no longer affordable due to rate increases. A proposal to is to be delivered to the Executive Committee by the 2020 Fall National Meeting and the Task Force will provide periodic reporting to the LTCI (B/E) Task Force. The Task Force and its charges will expire January 31, 2021. A list of the members of the Task Force can be found here. (Posted May 2019)

NAIC Heath Actuarial Task Force
The mission of the Health Actuarial (B) Task Force is to identify, investigate and develop solutions to actuarial problems in the health insurance industry. (One web page)

NAIC Health Insurance and Managed Care (B) Committee
The mission of the Health Insurance and Managed Care (B) Committee is to consider issues relating to all aspects of health insurance. (One web page)

NAIC Long-Term Care Actuarial (B) Work Group
Two subgroups, Pricing and Valuation, deal with various rating and reserving issues. (One web page)

NAIC Long-Term Care Pricing (B) Subgroup
The Subgroup's goal is to assist the Health Actuarial (B) Task Force to provide recommendations as appropriate and to address issues and provide actuarial assistance and commentary with respect to model rules for appropriate long-term care insurance rates, rating practices and rate changes. (One web page)

NAIC Senior Issue (B) Task Force
Task force is responsible for NAIC LTC model act and regulations, guidance manual and, recently, formed a LTC innovation subcommittee. (One web page)

Short Duration Long-Term Care Policies Subgroup
The subgroup will create a model to address long-term care products of short duration that are excluded from other existing model acts and regulations.


NAIC Model Regulation & Legislation

Approaches to Long-Term Care Rate Increases
The Long-Term Care Actuarial (B) Working Group has released a document discussing Approaches to LTC Rate Increases (Posted 12/2018)

Long-Term Care Innovation (B) Subgroup: Federal Policy Options to Present to Congress
This document is the approved proposal from the LTC Innovation Subgroup regarding options for increasing LTC coverage. 

Long-Term Care Insurance Compliance with the NAIC LTCI Model Regulation Relating to Rate Stability
Update by the Long-Term Care Practice Note Work Group of the 2003 Long-Term Care Practice Note relating to long-term care rate stability. (6/2012)

Long-Term Care Draft Rate Review Checklist Commonly Asked Question
The draft checklist identifies common elements for achieving better transparency and predictability in long-term care rate increase requests. Please see the Commonly Asked Questions document. (Posted 12/2018) 

NAIC Accounting Practices and Procedures Manual
The following link is to the NAIC page which contains the information and links to forms and includes all statutory accounting guidance that has been adopted by the NAIC annually as of March (Posted 2/2017).  

NAIC Financial Statement Filing & Step Through Guide
The following link is to the NAIC page which contains the information and links to forms that must be filed in connection with financial statement filings. Please note that separate charges may apply to use of the forms (Posted 2/2017).

Revised Stand-Alone LTC Asset Adequacy Actuarial Guideline (AG 51) Guidance Document
The NAIC Long-Term Care Valuation (B) Subgroup adopted the revised draft Actuarial Guideline for stand-alone long-term care asset adequacy analysis. An additional Guidance document has been released. (Posted 12/2018)

Statutory Accounting Principles (E) Working Group Maintenance Agenda Submission Form A
The document concerns Discounting of Long-Term Care Guaranty Fund Assessments (See pages 9-17).

Rate Filings

Interstate Insurance Product Regulation Commission  
LTC State Specific Information including modified rate schedule permitted and daily minimum requirements. (3 pages) (7/2014)


State Resources

California 2018 Actuarial Memorandum and Regulatory Asset Adequacy Issues Summary
Virtually all Life and Disability Insurance Companies and Fraternal Benefit Societies licensed in California (“companies”) are required to submit an Actuarial Opinion based on Asset Adequacy Analysis. The Letter provides details (12/2018)

California Department of Insurance Long-Term Care Insurance Rate and History Guide
Information on nationwide LTC rate increase history of companies with LTC business in California. (One web page)

Costs of Care in Your State
Click on a state to view cost details, to compare costs across locations and to estimate projected long-term care costs. (One web page) (Source: Genworth Cost of Care Study 2016) (Posted 4/2017)

Florida Office of Insurance Regulation (FLOIR) Form Filings Search
Information on Florida LTC rate and form filings. (One web page)

Maryland Insurance Administration LTC Insurance Information Resource
This page provides information regarding LTC rate hearings, decisions on LTC rate filings, and other general LTC information.

Montana Adopts New Rules on LTC Loss Recoupment, Appeals and Independent Review Organizations
The Commissioner of Securities and Insurance, Montana State Auditor (CSI) has adopted the rules as proposed. (Posted 2/2019)

New York Special Considerations Relating to December 31, 2018 Reserves and Other Solvency Issues
The considerations pertain to life insurance companies and fraternal benefit societies doing business in New York, and insurers accredited for the reinsurance of life insurance, annuities, or accident and health insurance, with the exception of non-New York domestic companies that meet the definition of “reinsurers” under the Federal Dodd-Frank Act. (11/2018)

Oregon: Filing Requirements - Long Term Care  
Information on Oregon LTC rate and form filings. (4 pages) (12/2014)

Pennsylvania Long-Term Care Insurance Rate Increase Filings
The listings include the posted Pennsylvania Bulletin, Filing Information and any Final Rate Decision. Rate filings are listed in alphabetical order by company name. Please note that companies may have multiple filings.

Washington State LTC ProgramThe State of Washington has enacted a program to fund a long-term care insurance benefit leveraging payroll tax on employees. Employee contributions start in 2022, and benefits start in 2025. (Posted 7/2019)

State Filing Requirements - Long Term Care
Information on LTC state rate and form filings are available through SERFF (Subscription Required). (Posted 4/2019)