Further, this meeting has not been discussed in any meaningful way with the entire membership of the NAIC nor have we worked to build consensus among the members on what our positions will be in the meeting. As we all know, the NAIC is made up of a group of extremely knowledgeable insurance regulators with very diverse views on the Affordable Care Act. While we greatly appreciate the opportunity to meet with President Obama, briefing the membership and working to build consensus on a meeting of this importance needs to occur prior to sitting down with him.      

We hope that you all have a happy Thanksgiving with your families and we look forward to seeing you in a few weeks in Washington, D.C.      

Sincerely,      

Adam Hamm, Monica Lindeen, Michael Consedine, Kevin McCarty, Roger Sevigny, Sandy Praeger 

Donelon, Louisiana Insurance Commissioner, is the president of NAIC. Commissioners signing the letter are Hamm from North Dakota, Lindeen of Montana, Consedine of Pennsylvania, McCarty of Florida, and Preager of Kansas. Hamm is NAIC president-elect. Lindeen is vice president of the association and Consedine is NAIC's Secretary-Treasurer.

Donelon met with Obama Nov. 20 along with NAIC CEO Ben Nelson, Connecticut Insurance Commissioner Thomas B. Leonardi and North Carolina Insurance Commissioner Wayne Goodwin to primarily address issues with the Affordable Care Act

READ: Donelon Asks President to Hold Off Raising Flood Rates

Though the commissioners say the NAIC hasn't built a consensus for the meeting, the association on Nov. 14 released the following statement on Obama's proposal regarding ACA policy cancellations. 

We share the President's and Congress' concerns about policy cancellations and issues including gaps in coverage that may result from them, and fully understand the anxiety of the residents of our states who have received these notices. This anxiety is especially heightened given the issues with the federal exchange.

For three years, state insurance regulators have been working to adapt to the Affordable Care Act in a way that best meets the needs of consumers in each state.   We have been particularly concerned about the way the reforms would impact premiums, the solvency of insurance companies, and the overall health of the marketplace.  The NAIC has been clear from the beginning that allowing insurers to have different rules for different policies would be detrimental to the overall market and result in higher premiums.

We have expressed these concerns with the Administration and are concerned by the President's announcement today that the federal government would use its "enforcement discretion" to delay enforcement of the ACA's market reforms in 2014 for plans that are currently in effect.  This decision continues different rules for different policies and threatens to undermine the new market, and may lead to higher premiums and market disruptions in 2014 and beyond.

In addition, it is unclear how, as a practical matter, the changes proposed today by the President can be put into effect.  In many states, cancellation notices have already gone out to policyholders and rates and plans have already been approved for 2014. Changing the rules through administrative action at this late date creates uncertainty and may not address the underlying issues. We look forward to learning more details of this policy change and about how the administration proposes that regulators and insurers make this work for all consumers.