Roger Lisi, Harrisburg Regional Manager
Pennsylvania Insurance Department
Bureau Of Consumer Services
1209 Strawberry Square, Harrisburg, PA 17120
rlisi@state.pa.us
Dear Mr. Lisi
A. M. Best warns in its press release, Nov. 20, 2008, after The
Senior Health Insurance Company of Pennsylvania (the trust) was approved by Mr. Ario, Commissioner of Insurance of PA, that a combination of rate increases, reduced benefits, and policyholder forfeitures may be the necessary ingredients for sufficient capitalization over the long run for the trust.
Perhaps a similar five-year financial projection is contained in in Exhibit N of the Form A filing. And perhaps this is the reason for the confidentiality.
By not requiring Conseco to take responsibility for the long-term care policies it underwrote, perhaps by adjusting its business plan accordingly, perhaps by again filing for Chapter 11, the trust to hold thousands of LTC policies does not sail in calm waters. Elderly senior citizens face a very real danger of policy liquidation when the trust fails. Thereafter, the outcome is anything but secure for them given a hodgepodge of different state guarantee procedures. This trust fragility is occuring much sooner then anticipated, if the current request for a 40 percent rate increase, which is needed to sustain sufficient capital, is not approved by the various state regulators involved.
Seniors are protected from practices harmful to their well being by federal law, through The Patients Bill of Rights adopted by The U. S.. Advisory Commission on Consumer Protection and Quality in the Health Care Industry, 1998.
This bill assures fairness and meeting the patient's needs, which surely cannot be honored if these seniors find their insurance compromised. Where is the fairness in this set-up where their opinions were not required, or solicited.The reason they took out long-term care insurance was not have to draw down their assets to qualify for state assistence.
By any standards of decency and respect, especially for our grandparents' welfare, this trust was neither a fair nor useful road to take. You might ask Commissioner Ario why he turned a deaf ear to repeated requests for an open hearing to vett the concerns of all concerned. What was he afraid of?
Sincerely, Bill Silverman
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Dear Mr. Lisi
In reviewing the Form A Filing, I notice that Exhibit F is not available to see. I know it contains a five year projection for SHIP. I think this document would be crucial for an attorney who might be interested in pursuing SHIP's legal justification. SHIP's creation, as I'm sure you know, is without precedent in the long-term care insurance industry. Therefore, one can only guess at its chances for ultimate survival. If Form F is an actuarial analysis and projection for SHIP this would be an important document to place within the public domain.
I would appreciate your response to this email.
Sincerely,
Bill Silverman
Thursday, March 5, 2009
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