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
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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
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