Commissioner Joel Ario
1209 Strawberry Square
Harrisburg, PA 17120
Dear Commissioner Ario:
In your approval of the trust to hold the Senior Health Insurance Company of Pennsylvania, you preempted any possibility of different opinions concerning the trust, through your decision to not hold a public hearing. Therefore, you, in effect, determined the validity of the trust by yourself. You may say, opinions were expressed within the comment period, but were they? considering ninety percent of policyholders hadn't a clue about the proposed trust to hold their LTC policies. To claim the comment period was announced in the Pennsylvania Bulletin was pure "Doublespeak." Would you reasonably suspect that a policyholder living in Florida would read the Pennsylvania Bulletin? You have in your possession the Milliman Actuarial 5 year projection for the trust, but have made it unavailable in the public domain, although it may give one a much clearer understanding of the future of the trust.
Bill Silverman
------------
Heidi B. Shakely
Eckert Seamans Cherin & Mellott
213 Market St., 8th floor
Harrisburg, PA 17101
RE: Senior Health Insurance Company of Pennsylvania: Milliman, Inc. Actuarial Report
In considering the approval of the above listed company in November, 2008, it appears to not be substantiated by anything other than the PA commissioner's order: no public hearing, no information to policyholders, other than the most vague allusion to change of company, vetting of interested parties during the comment period appearing as a mere formality with replies from the department vague and misdirected.
A darkness surrounds the Milliman document with the claim of privileged confidential information, making me dubious about the need for such secrecy.
That, combined with not being willing to hold an informational hearing, seems to further cloud the issue of motivation; of using authority improperly.
I request to have sent to me by letter, or email, the full Milliman Report. I feel the report will better enable me to understand the commissioner's justification for approving the trust.
Very Truly Yours,
Bill Silverman
Tuesday, March 10, 2009
Saturday, March 7, 2009
WHERE IS THE REPORT?
Robert Brackbill
Chief, Company Licensing Division
Insurance Department
1345 Strawberry Square
Harrisburg, Pennsylvania 17120
Dear Mr. Brackbill
I have seen the complete Form A Filing. However, it is missing a document that is essential to the rational for establishing the trust.. That is the Milliman Report. Only a small part of it has been released, specifically concerning the five rate increases needed to maintain the trust's solvency. The full document will, I'm sure, provide a wider prospective on the trust. I respectfully request an abstract of the Milliman. Please send it via email or letter.
(Since this report might provide concrete reasons for placing 170,000 senior long-term care policies
in a trust, it would be vitally important in determining whether the approval of the trust was warranted.)
Sincerely, Bill Silverman
Chief, Company Licensing Division
Insurance Department
1345 Strawberry Square
Harrisburg, Pennsylvania 17120
Dear Mr. Brackbill
I have seen the complete Form A Filing. However, it is missing a document that is essential to the rational for establishing the trust.. That is the Milliman Report. Only a small part of it has been released, specifically concerning the five rate increases needed to maintain the trust's solvency. The full document will, I'm sure, provide a wider prospective on the trust. I respectfully request an abstract of the Milliman. Please send it via email or letter.
(Since this report might provide concrete reasons for placing 170,000 senior long-term care policies
in a trust, it would be vitally important in determining whether the approval of the trust was warranted.)
Sincerely, Bill Silverman
Thursday, March 5, 2009
MR. LISI---ARE YOU THERE?
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
----------------
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
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
----------------
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
Saturday, February 28, 2009
A CASE FOR DISCRIMINATION
The "Patients' Bill of Rights" makes it illegal to discriminate against a patient via his treatment plan or his insurer.
142,000 seniors with Conseco Long-Term Care Insurance have, as of mid-November, 2008, been put in a precarious situation, by putting their policies in a stand-alone trust: The Senior Health Insurance Company of Pennsylvania. The problem of escalating rate increases threatens to drive the trust to insolvency and receivership by the commissioner of insurance of Pennsylvania.
The precarious nature of the trust constitutes discrimination against the elderly recipients of care according to the federally mandated "Patients' Bill of Rights" in that it threatens the viability of the ongoing care they paid for.
***
The recent actions of Conseco Co, an Indiana based insurance holding company, appears to have seriously put in jeopardy thousands of senior long-term care policyholders (both on benefit, and premium paying.) These policies are spread throughout the states and subject to varying regulatory agendas.
The policies have been transferred from Conseco Senior Health to a trust (The Senior Health Care Company of Pennsylvania) which is no longer a part of Conseco, but a stand-alone entity solely dependent for necessary reserve capitol, on the policyholders. Milliman Actuarial Company, hired by Conseco prior to the trust's approval, (in their partially released projections,) envision a series of five rate increases to make the trust solvent. the first of the rate increases is happening much sooner than anticipated. According Martin McBirney, an insurance consultant with 20 years experience in the insurance field, these rate hikes will likely drive the average annual premium to 20,000, boding for many lapsed policies. Since the necessary reserve capitol to pay policy benefits is seriously impaired, no longer having Conseco's backing, the trust is swiftly headed for insolvency and receivership.
This jeopardizing of senior ongoing care in nursing homes, assisted living homes, questions the fairness of this deal between Conseco and the Pennsylvania insurance commissioner (Conseco is licensed in Pennsylvania for this block of LTC business.) In spite of serious misgivings concerning this trust on the part of three insurance commissioners, and their pleas to hold an open hearing to discuss this matter, they were turned down citing Pennsylvania statutes not requiring a hearing.
The trust was approved in mid November, 2008.
The Patients' Bill of Rights, mandated by the President's Advisory Commission on Consumer Protection and Quality in the Health Care Industry has been violated with the creation of a company held by a trust dependent on elderly policyholders for its financial support. It makes folly of the LTC policies they signed to guarantee peace of mind in their senior years.
142,000 seniors with Conseco Long-Term Care Insurance have, as of mid-November, 2008, been put in a precarious situation, by putting their policies in a stand-alone trust: The Senior Health Insurance Company of Pennsylvania. The problem of escalating rate increases threatens to drive the trust to insolvency and receivership by the commissioner of insurance of Pennsylvania.
The precarious nature of the trust constitutes discrimination against the elderly recipients of care according to the federally mandated "Patients' Bill of Rights" in that it threatens the viability of the ongoing care they paid for.
***
The recent actions of Conseco Co, an Indiana based insurance holding company, appears to have seriously put in jeopardy thousands of senior long-term care policyholders (both on benefit, and premium paying.) These policies are spread throughout the states and subject to varying regulatory agendas.
The policies have been transferred from Conseco Senior Health to a trust (The Senior Health Care Company of Pennsylvania) which is no longer a part of Conseco, but a stand-alone entity solely dependent for necessary reserve capitol, on the policyholders. Milliman Actuarial Company, hired by Conseco prior to the trust's approval, (in their partially released projections,) envision a series of five rate increases to make the trust solvent. the first of the rate increases is happening much sooner than anticipated. According Martin McBirney, an insurance consultant with 20 years experience in the insurance field, these rate hikes will likely drive the average annual premium to 20,000, boding for many lapsed policies. Since the necessary reserve capitol to pay policy benefits is seriously impaired, no longer having Conseco's backing, the trust is swiftly headed for insolvency and receivership.
This jeopardizing of senior ongoing care in nursing homes, assisted living homes, questions the fairness of this deal between Conseco and the Pennsylvania insurance commissioner (Conseco is licensed in Pennsylvania for this block of LTC business.) In spite of serious misgivings concerning this trust on the part of three insurance commissioners, and their pleas to hold an open hearing to discuss this matter, they were turned down citing Pennsylvania statutes not requiring a hearing.
The trust was approved in mid November, 2008.
The Patients' Bill of Rights, mandated by the President's Advisory Commission on Consumer Protection and Quality in the Health Care Industry has been violated with the creation of a company held by a trust dependent on elderly policyholders for its financial support. It makes folly of the LTC policies they signed to guarantee peace of mind in their senior years.
Thursday, February 26, 2009
VIEW FROM THE BOX
BY Bill Silverman
Have we ever honored our aged, given them high status in our families? Perhaps, somewhere in the past, the years before the shift in the older population to greater age and population. That's where it seemed to have occured, the culture of farming elders out to extra-family facilities, to be cared for by custodians; and, of course to loose that most precious sense of usefullness; eventually orientation to life itself.
Thus the culture of caring for seniors with profit in mind. Institutionalizing euphemized in the Nursing Home. As health care lowered to the questionable level of Health Maintenance Organizations, the fifteen-minute medical appointment, the Balance Sheet centered approvals of medical testing, so Society places the Old Ones in linoleum-sheened corridors, rooms with bed and television set, begrudged care by people who are underpaid and under incentivised to care.
This is called non-medical custodial care. I am discovering that it's no longer them, out there, but we in here! It's hard to get into peoples' minds unless you find yourself in their shoes. We are by virtue of being here, that much closer to the precipice, that unknown slide! Our days are either dull and mindless, or bingo and movies!
Moreover, we are wounded game, vulnerable to the hunter's arrow. Peering into the Custodial Care System, you may find the unexpected! the corporate board more interested in their stock valuation, than fairness to the vulnerable existent on their corporate label. Not unlike schemes hatched to physically intimidate elders by cruel landlords, quick deals from a phone bank to glad-mouth the susceptible, insurance companies dedicated to fatten profits rather than dispense manna to those in need, we allow shred attorney-banks to snake around compassion. We allow corporate Bailouts on the backs of the Weak to be crushed to their knees.
It seems more newsworthy to banner-headline the shocking nudity of a film star, than to report on blatant, and covert disenfranchisement of the Elderly.
I keep fantasizing about the congressional panel pointing fingers at Long-Term Care execs who remonstrate with innocent sincerity about how their main concern is to provide quality care. And "Why are you raising rates to astronomical heights, and denying benefits based on contrived premises?" We intend to take a careful look at that, senator! Yes, yes, and where the heck is your state regulator? Here, sir! We've not been aware of unfair practices, but we'll look into it! Bailout on the backs of policyholders? I actually see your point. We'll look into it.
Where is justice, a question as age old as the layers of civilizations unearthed by anthropologists.
Have we ever honored our aged, given them high status in our families? Perhaps, somewhere in the past, the years before the shift in the older population to greater age and population. That's where it seemed to have occured, the culture of farming elders out to extra-family facilities, to be cared for by custodians; and, of course to loose that most precious sense of usefullness; eventually orientation to life itself.
Thus the culture of caring for seniors with profit in mind. Institutionalizing euphemized in the Nursing Home. As health care lowered to the questionable level of Health Maintenance Organizations, the fifteen-minute medical appointment, the Balance Sheet centered approvals of medical testing, so Society places the Old Ones in linoleum-sheened corridors, rooms with bed and television set, begrudged care by people who are underpaid and under incentivised to care.
This is called non-medical custodial care. I am discovering that it's no longer them, out there, but we in here! It's hard to get into peoples' minds unless you find yourself in their shoes. We are by virtue of being here, that much closer to the precipice, that unknown slide! Our days are either dull and mindless, or bingo and movies!
Moreover, we are wounded game, vulnerable to the hunter's arrow. Peering into the Custodial Care System, you may find the unexpected! the corporate board more interested in their stock valuation, than fairness to the vulnerable existent on their corporate label. Not unlike schemes hatched to physically intimidate elders by cruel landlords, quick deals from a phone bank to glad-mouth the susceptible, insurance companies dedicated to fatten profits rather than dispense manna to those in need, we allow shred attorney-banks to snake around compassion. We allow corporate Bailouts on the backs of the Weak to be crushed to their knees.
It seems more newsworthy to banner-headline the shocking nudity of a film star, than to report on blatant, and covert disenfranchisement of the Elderly.
I keep fantasizing about the congressional panel pointing fingers at Long-Term Care execs who remonstrate with innocent sincerity about how their main concern is to provide quality care. And "Why are you raising rates to astronomical heights, and denying benefits based on contrived premises?" We intend to take a careful look at that, senator! Yes, yes, and where the heck is your state regulator? Here, sir! We've not been aware of unfair practices, but we'll look into it! Bailout on the backs of policyholders? I actually see your point. We'll look into it.
Where is justice, a question as age old as the layers of civilizations unearthed by anthropologists.
Sunday, February 22, 2009
THE GLORY ROAD
The old people drift about like lost lambs seeking the succor of their youth. They know full well it will never again come to them. There's Stella, and Joe who's wheelchair bound; they are both survivors of Nazi Concentration Camps. There's Mildred who was a navy test pilot during the Second World War. Mildred has difficulty locating her apartment and figuring out what she's to do when in the dining room. Most walk with walkers with painstakingly careful strides about the assisted living facility which is their home. Most wonder, in a secret place in their minds, when the ambulance will come to greet them.
These are our grandparents, delicate, unable to manage their lives without help; the very people deserving of our compassion, and gratefulness for our survival in the world.
Still, they are treated with unconscious dismissal by the insurance companies they believed would be their saviors. Marginalized carelessly, they live their lives in blyth ignorance of the dark corporate web determining their fate.
There's a host of insurance companies lacking in scruples, but one currently reins above them all. That is Conseco. Acquisitions of companies burgeoning with poorly written long-term care policies propelled Conseco to the heights of stuffed balance sheets, nine-figure salaries, two million dollar weddings, the zenith of Conseco's heyday. When the country's economy suddenly went South Conseco found themselves with LTC policies reflecting increased lifespans, increased applications for benefits, shrinkage of premiums paid, and the nose dive their stock took.
Conseco, the insurance commissioner of Pennsylvania, and a bevy of high-priced attorneys effectuated a solution: An independent trust to serve as a stand-alone, non insurance company, entity to hold and service some 142,000 LTC policies. Furthermore, the elderly policyholders were not to be given a voice in this decision, and not even to be informed of the trust's existance. It would be called, misleadingly, The Senior Health Insurance Company of Pennsylvania, sounding very much like an insurance company.
Once again in the current lexicon this misinformation about the trust's supposed balance and transparancy puts forth a cleverly constructed myth about the long-term care of the American elderly.
Will it ever come to the attention of our congressional representatives? Probably not. To quote a famous phrase: Let 'em eat cake!
Bill Silverman
These are our grandparents, delicate, unable to manage their lives without help; the very people deserving of our compassion, and gratefulness for our survival in the world.
Still, they are treated with unconscious dismissal by the insurance companies they believed would be their saviors. Marginalized carelessly, they live their lives in blyth ignorance of the dark corporate web determining their fate.
There's a host of insurance companies lacking in scruples, but one currently reins above them all. That is Conseco. Acquisitions of companies burgeoning with poorly written long-term care policies propelled Conseco to the heights of stuffed balance sheets, nine-figure salaries, two million dollar weddings, the zenith of Conseco's heyday. When the country's economy suddenly went South Conseco found themselves with LTC policies reflecting increased lifespans, increased applications for benefits, shrinkage of premiums paid, and the nose dive their stock took.
Conseco, the insurance commissioner of Pennsylvania, and a bevy of high-priced attorneys effectuated a solution: An independent trust to serve as a stand-alone, non insurance company, entity to hold and service some 142,000 LTC policies. Furthermore, the elderly policyholders were not to be given a voice in this decision, and not even to be informed of the trust's existance. It would be called, misleadingly, The Senior Health Insurance Company of Pennsylvania, sounding very much like an insurance company.
Once again in the current lexicon this misinformation about the trust's supposed balance and transparancy puts forth a cleverly constructed myth about the long-term care of the American elderly.
Will it ever come to the attention of our congressional representatives? Probably not. To quote a famous phrase: Let 'em eat cake!
Bill Silverman
Saturday, February 21, 2009
CHECK BACK TO THE BEGINNING
THE PERSON READING THIS BLOG FOR THE FIRST TIME IS ADVISED TO CHECK IN WITH THE BACKGROUND OF THIS SITUATION. AND THE SITUATION IS SPELLED OUT IN FULL IN AN ARTICLE ON THE GUERILLA ORGANIZING WEB SITE.
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