Health Actuarial Insights
September 2012
Advisory
The value of actuarial analysis in
clinically integrated organizations
Contents
The value of actuarial
analysis in clinically
integrated organizations
By Mark Jamilkowski, FSA, and Alisa Widmer, FSA
Healthcare service delivery and the associated financing of that
care are undergoing a revolution, prompted by healthcare reform
initiatives and what KPMG believes to be a nonsustainable
U.S. healthcare ecosystem. At the same time, technology
advancements, including enhanced data storage and manipulation
capabilities, allow for the gathering, recording, storing, and
analysis of vast amounts of medical data. This combination of
events presents a unique opportunity for actuaries, who have
historically focused on reconciling and validating information.
Conditions arising from healthcare transformation are now
favorable for actuaries to change course in working with industry
data.
If actuaries begin teaming with healthcare providers in
both collecting and analyzing data, there is an opportunity for
improvements in which data items are gathered and monitored,
as well as an opportunity to create new clinical intelligence with
value-added actuarial and statistical analyses. The expectation is
that these analyses could help elevate the quality and efficiency
of patient care and treatment. Additionally, such analyses will be
instrumental in managing patient populations in the future.
© 2012 KPMG LLP a Delaware limited liability partnership and the U.S.
member firm of the
,
KPMG network of independent member firms affiliated with KPMG International Cooperative
(“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A.
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Page 1
Managed Medicaid
long-term care
Page 4
Challenges of new data
and data analytics
requirements for
health actuaries
Page 6
Health Actuarial Insights September 2012 | 1
. Historically, actuaries analyze large, normative data sets to
create metrics, such as utilization and cost per unit trends.
As we point forward, however, what is needed is a better
understanding of both treatment success rates and wellness
attribution, which result in the creation of statistically driven
medical care guidelines or protocols. We believe that actuarial
analytical techniques and business knowledge are critical
elements to understanding the business and consumer
aspects associated with clinical effectiveness. Furthermore,
these skills can help physicians manage the volatility or
randomness associated with population health dynamics, and
help find the predictive indicators that we need as an industry
to target root causes behind care delivery variances.
A substantial amount of medical treatment data exists today
in the form of electronic medical records, claims data, and
other clinical data sources, but this electronic data mostly
describe disease conditions, while the treatment details are
not standardized and do not provide insight to overall effective
treatment or help develop medical practice guidelines.
There is a growing need for analytics that go beyond relatively
rudimentary medical treatment trends and give insight to
population or patient-centric treatments or protocols, outcomes
measurement, and disease management. Actuaries have
statistical and analytical skill sets that, when applied in
collaboration with the clinical knowledge of healthcare providers,
can yield greater understanding and more proactive medical
metrics.
Actuaries are already integrally involved in designing
reimbursement methodologies that require performance
attribution, and are called upon to develop and price new benefit
plan designs. Integrating these principles with clinical analytics
can also help providers manage the care-delivery risk associated
with the accelerated emergence of value-based reimbursement
and can help physicians increase transparency with their
patients regarding diagnosis and treatment options. Ultimately,
the application of actuarial capabilities to the sophisticated
analytics suggested here will enable the data-driven platform for
overall population management.
While there are numerous examples to choose from,
the discussion below focuses on four diseases to illustrate
how actuarial analytics could be leveraged to support
the transformation of the healthcare industry.
The diseases
covered here are obesity, diabetes, heart-related diseases,
and dementia.
Obesity
There is ample healthcare treatment data available for
obesity. It includes graphs, trend analytics, charts, tables,
and analyses of results over time. Trending and observations
of the path of service demand are well-documented; however,
information on causes as well as the “cure, defined as weight
”
loss continuously maintained for 12 consecutive months
after treatment, is not as well-structured.
Current treatment
protocols for obesity include combinations of diet, exercise,
and/or surgical procedures. Due to the long time horizon for
both the treatment and the cure, clinical studies have to adopt
a longitudinal approach, with results recorded and analyzed
2 | Health Actuarial Insights September 2012
consistently for an extended period of time. These studies can
be combined by actuaries with demographic and other patient
background information to create robust predictive models
to evaluate treatment compliance and clinical success rates,
as well as assist providers in evaluating treatment options and
protocols.
For example, for a treatment option such as bariatric
surgery, an analytical tool could be developed to help determine
eligibility, risk factors, and likely effectiveness. Analytics such
as this will be required as more provider reimbursement is
tied to outcomes, and providers are at risk for the quality and
effectiveness of care provided.
Diabetes
Recently, the incidence of diabetes has been increasing at
a rate similar to the incidence of obesity, and similar to obesity,
a variety of potential medical treatments can be pursued.
Medical records and test results over time are required to
track a patient’s progress when evaluating these treatment
options. Currently, because of the general nature of the subject
population, health records may be missing or hard to retrieve or
access, which create difficulties in analyzing treatment efficacy.
Similar to obesity, there is a need to structure the actuarial
analysis over these longer time periods to better understand
the drivers of the disease onset as well as the drivers behind
patient behavior regarding treatment compliance.
Obesity and
diabetes are chronic diagnoses, requiring a physician to operate
in a clinically integrated care management environment
because of longer term treatment protocols and the need to
work over a more extended care continuum. The transformation
of the industry toward outcome-based reimbursement
depends on effectively addressing community health issues
such as these.
Heart-related diseases
While collecting data is critical, the form and content of the
data being collected are also critical. Heart-related diseases,
for example, have many forms and related treatment options,
and while electronic medical records help codify some of this
information, much of the treatment protocols being followed
are recorded on a case-by-case basis.
The information can
be situational and inconsistent as a result, with detailed
data regarding the patient’s medical history but text-based
description of specific protocols followed. As a result,
it is difficult to determine success rates, failure rates, and
complication rates by treatment option. Actuaries can team
with providers to standardize data items to be collected in order
to create a more robust data set that enables population health
management and protocol variance analytics.
Advanced data
techniques, such as work-mapping and social media
applications, that turn unstructured data into statistical values
may also be required applications in building this data set.
The aggregated data findings can then be used by the provider
as a guide to better manage the risks associated with bundled
payments or accountable care reimbursement arrangements,
as well as create a more transparent decision-making process
with the patient.
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,
KPMG network of independent member firms affiliated with KPMG International Cooperative
(“KPMG International”), a Swiss entity. All rights reserved.
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Dementia
In the United States, increased life expectancy and the growing
population of those over age 65 are leading to projections
that dementia will become another population health
issue, consuming healthcare resources. Thus, dementia is
projected to increase in incidence, not as a result of things
we are doing wrong, but mostly as a result of things we are
doing right. Improvements in medical technology and care
management initiatives already in evidence, and the additional
quality improvements expected to materialize from reformbased initiatives, can be expected to continue lengthening
life expectancy and, therefore, to increase the incidence of
dementia. This disease is progressive and long term, and has
important implications for the long-term care, nursing and
home health industries from a care delivery, and demand
perspective.
It also has important consequences for the longterm care insurance industry. Actuaries can take the lead in
understanding the care demand drivers and population risk
factors, as well as in helping the broader healthcare sector
find a sustainable way to finance the cost of this emerging
health risk. Organizing consistent data-gathering techniques
with providers is important, but is only in the early stages
© 2012 KPMG LLP a Delaware limited liability partnership and the U.S.
member firm of the
,
KPMG network of independent member firms affiliated with KPMG International Cooperative
(“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A.
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of adoption. Tracking disease state progression, reactions
to treatment protocols, and statistical analysis that helps
determine where managed care techniques are applicable
are also important.
Actuarial analytics and the involvement of actuaries in clinical
analysis are at different stages of maturity across the healthcare
sector, depending on the organization and the awareness of
management to the emerging need to understand care delivery
variances and population-driven volatility.
As more complex
and technology-enabled data opportunities emerge in the
transition from fee-for-service to value-based payment, actuarial
capabilities will be highly leverageable in optimizing business
in the new environment. Actuaries should take advantage of
this opportunity to illustrate how value-added analytics can
enable and support improvements in healthcare quality and
economic attribution and, therefore, support the accelerating
transformation to a more sustainable care management system.
For a broader view of the changing role of the healthcare
actuary in a post-reform world, see the KPMG Health Actuarial
Benchmarking Survey 2011.
Health Actuarial Insights September 2012 | 3
. Managed Medicaid long-term care
By Tiffany Caufield, FSA
Despite the existence of Medicaid managed care for years, most regulatory activity has
been concentrated in the acute care realm, with organizations contracting with state
governments to manage the primary and acute services of those eligible for Medicaid.
Little activity has gone into the establishment of managed care for long-term care (LTC)
services. A few states have pioneered a variety of LTC programs with varying levels of
risk bearing by the managed care organization and all manner of benefit packages.
However, budgetary restrictions in most states have heightened the interest in
finding viable options to reduce healthcare spending on Medicaid beneficiaries.
Nursing home stays account for more than two-thirds of Medicaid spending,
even though nursing facility residents only account for 25 percent of the Medicaid
population.1 Given the large percentage of the Medicaid spend dedicated to such
custodial care, it is not surprising that states are beginning to consider managed
LTC as an option to manage costs.
How does managed Medicaid long-term care work?
Publicly funded long-term care is paid for by two governmental
organizations: Medicare and Medicaid. Medicare coverage
includes specific short-term stays in a nursing home and some
home healthcare after an inpatient hospital discharge. Medicaid
coverage includes long-term, custodial stays, home health, and
a variety of home and community-based services (HCBS) such
as adult day health, Meals on Wheels programs, personal care
attendants, and nonemergency transportation.
While many
nursing home certifiable patients end up in a nursing home,
with the appropriate set of services, many can stay at home.
This is where managed care can add value.
A typical managed Medicaid long-term care (MMLTC)
program works in the following manner. A healthcare provider/
organization—typically a health maintenance organization
(HMO)—contracts with the state to assume the risk of
providing LTC services. The state pays the contractor a flat
premium amount on behalf of each beneficiary, and the
contractor agrees to cover the contractual LTC costs for that
beneficiary.
The set of services covered varies from program
to program. Some states require that a carrier cover just
long-term care needs (nursing home and HCBS), while others
will contract with the provider for the spectrum of Medicaid
services, including acute and primary healthcare services and
prescription drugs. Still other arrangements cover all Medicaid
services as well as Medicare services for those beneficiaries
that are eligible for both (the so-called “dual-eligibles”).
Because a plan is responsible for all long-term care costs, plans
have the ability to redistribute services between care settings:
in the nursing home, in an assisted living facility or at a patient’s
home.
Under many plans, services can be arranged so that
patients can stay in their homes longer before moving to a
nursing home, if that becomes necessary. In almost all cases,
receiving benefits at home is much less expensive than
receiving benefits in a nursing home.
Consider the Senior Care Options (SCO) program in
Massachusetts. This program covers Medicare and Medicaid
services for dual-eligibles and emphasizes home healthcare
services and care plans to keep beneficiaries out of a nursing
home as long as possible.
A study of this program by
JEN associates found that enrollees were less likely to go into
a nursing home, spent more time at home before entering the
nursing home, and spent less time there when they eventually
did enter a facility for treatment.2
Benefits and concerns of MMLTC
Studies have yet to conclude that there are identifiable cost
savings from implementing a MMLTC program despite the
shift to lower cost services. Still, MMLTC has several benefits,
not the least of which is predictability of Medicaid program
costs for state agencies. Medicaid programs can transfer risk
to managed care organizations, thereby making their budget
much more predictable.
In an environment of increasing
budgetary constraints, this aspect is quite attractive.
http://www.kaiserhealthnews.org/stories/2011/february/21/medicaid-managed-long-term-care.aspx
1
2
h
ttp://www.dhcs.ca.gov/provgovpart/Documents/Waiver%20Renewal/SCO%20Program%20Evaluation%209jun08%20(2).pdf
4 | Health Actuarial Insights September 2012
© 2012 KPMG LLP a Delaware limited liability partnership and the U.S. member firm of the
,
KPMG network of independent member firms affiliated with KPMG International Cooperative
(“KPMG International”), a Swiss entity. All rights reserved.
Printed in the U.S.A. The KPMG name,
logo and “cutting through complexity” are registered trademarks or trademarks of KPMG
International. NDPPS 105347
.
Furthermore, MMLTC programs increase the access to home
and community-based services, while reducing the utilization
of high-cost services, particularly emergency room, hospital,
and nursing home services.3 For example, a managed care
plan was able to move a 32-year old with severe brain damage
due to a motorcycle accident from a nursing home into her
own home. To make this possible, a chairlift was installed, and
an aide comes to visit every day to assist with activities of
daily living. In this case, this arrangement saves approximately
$18,000 per year in long-term care costs.4
Additionally, there is evidence of improvements in patient
outcomes, including improved quality of life and functional
status.5 This is not surprising since many managed care
beneficiaries have access to HCBS programs that may have
been unknown to them prior to joining the HMO, allowing
them to stay in their own homes. This is likely a result of
the increased accountability associated with MMLTC.
In these
programs, and unlike fee-for-service Medicaid, the risk is
transferred to HMOs, which have an incentive to manage
resources efficiently.
MMLTC must still overcome the managed care backlash that
occurred during the 1990s. Some opponents are concerned
that a managed care plan may limit services to beneficiaries,
or that large insurance companies will decrease nursing facility
rates, putting additional strain on the nursing home industry,
which already operates on small profit margins. For example,
in Tennessee, the nursing home industry has encouraged the
state legislature to enact a law that prohibits managed care
plans from decreasing payments to nursing facilities rates or
cutting facilities from their networks.6
Operational considerations for plans
Managing long-term care costs is a major change for many
HMOs.
Carriers new to covering LTC will likely have to expand
their networks to include long-term care facilities or alter
existing contracts to include custodial care. This poses new
opportunities for creative contracting arrangements such as
bundled payments (where systems operate hospitals and
nursing facilities), capitation, and value-based purchasing.
Additionally, plans will have to contract with agencies they
may have not considered before in order to ensure that
nursing home certifiable patients living at home have access
to necessary services, such as visiting nurses, home-delivered
meals, adult day health, and so on.
such as elder affairs organizations and small, local HMOs are
generally more accustomed to managing the care of those that
are nursing home certifiable. However, assuming the financial
risk of an MMLTC plan is more difficult for these agencies,
but easier for large managed care organizations.
Small and
large organizations can potentially partner, allowing each to take
advantage of the other’s qualifications.
Policy considerations for states
Since Medicaid long-term care is funded largely through state
budgets, states have the most at stake when designing a
MMLTC program. And the decisions they must consider cover
a wide range of options around enrollment, benefits, and
payment methods.
Depending on a state’s objective, the selection of benefits
can vary widely. States may opt to include only community
and institutional long-term care services in the benefit
package, while others may include the entire spectrum of
Medicaid benefits, including acute and primary care services.
The selection of benefits is closely related to the selection of
a target population.
If the list of covered benefits only includes
long-term care services, then it is likely that a beneficiary
must be nursing home certifiable to be eligible for the MMLTC
program. However, if the benefits include all Medicaid services,
then it is possible that all Medicaid beneficiaries are eligible.
Alternatively, states may select a population without regard
for the benefits available and focus on an area that has the
most potential for savings, such as a particular age group or
geographic area.
The dual-eligibles represent a unique situation. MMLTC
programs will likely include dual-eligible beneficiaries.
However, given their additional Medicare eligibility, there are
many more opportunities for managed care in this healthcare
segment, which we will cover in a subsequent article.
Conclusion
We can expect to see growth in managed Medicaid long-term
care programs as state budgets continue to be constrained.
To date, six states already require enrollment in MMLTC
programs and ten more are growing their managed care
programs.
Large managed care organizations capable of taking
on the risk of these programs should begin to consider how
they can accommodate this growing need or team with others
to do so.
Besides the new agencies, plans will need to consider how
well-equipped they are to meet the care management needs
of a long-term care population. Smaller community agencies,
http://assets.aarp.org/rgcenter/il/ib79_mmltc.pdf, pg 8
3
4
h
ttp://www.kaiserhealthnews.org/stories/2011/february/21/medicaid-managed-long-term-care.aspx
5
h
ttp://assets.aarp.org/rgcenter/il/ib79_mmltc.pdf, pg 10
6
h
ttp://www.kaiserhealthnews.org/stories/2011/february/21/medicaid-managed-long-term-care.aspx
© 2012 KPMG LLP a Delaware limited liability partnership and the U.S. member firm of the
,
KPMG network of independent member firms affiliated with KPMG International Cooperative
(“KPMG International”), a Swiss entity.
All rights reserved. Printed in the U.S.A. The KPMG name,
logo and “cutting through complexity” are registered trademarks or trademarks of KPMG
International.
NDPPS 105347
Health Actuarial Insights September 2012 | 5
. Challenges of new data and data analytics
requirements for health actuaries
By Mark Jamilkowski, FSA, MAAA
The Affordable Care Act (ACA) contains several provisions that are focused on the cost,
quality, and access-related issues associated with healthcare delivery and financing.
These provisions or initiatives include Benefits Exchanges, value-based or outcome-based
care delivery purchasing, risk adjustment concepts, revised/restricted underwriting
rules, and increased transparency with additional regulatory reporting requirements such
as the Minimum Loss Ratio requirement. Spurred by these initiatives, employers are
seeking to establish their own private exchanges, and providers are looking to establish
meaningful partnerships that enable better management of care and quality across
the care delivery continuum.
These combined initiatives are expected to have a significant positive impact on healthcare
delivery and the associated financing of that care. The provisions create a marketplace
more focused on the individual, with greater accountability for individual outcomes given to
the providers and greater individual consumer purchasing options. The transition away from
the employer- or group-focused business model implies insurers will need new competencies
and will have to define new roles and responsibilities for themselves that are more
retail-oriented.
New strategies will be needed, redefining what market segments are being
targeted, what strategies can be deployed for market penetration, and what network design
and care management strategies they will be required to support.
6 | Health Actuarial Insights September 2012
© 2012 KPMG LLP a Delaware limited liability partnership and the U.S. member firm of the
,
KPMG network of independent member firms affiliated with KPMG International Cooperative
(“KPMG International”), a Swiss entity. All rights reserved.
Printed in the U.S.A. The KPMG name,
logo and “cutting through complexity” are registered trademarks or trademarks of KPMG
International. NDPPS 105347
.
Why new data now
The implication for payors of the reform provisions and other
initiatives is a fundamental shift in the healthcare marketplace.
This shift toward a newly defined consumer-focused market is
also creating new risk parameters and challenging the historic
value proposition for success for insurers. The new strategic
direction that a payor ultimately chooses must be carefully
evaluated and vetted, supported by deeper and more broadly
defined data analytics. Greater levels of risk management will
be needed to adequately measure and monitor value-based
purchasing effectiveness, which in turn, rely on an integrated
care delivery model with shared financial responsibility
between payor and provider, payor and consumer, etc.
Actuarial analysis of reinsurance schemes, risk adjustment/
pooling setups, models of alternative network design and care
management, and product portfolio modeling/optimization
will depend on new sources of data. These new data sources
can be from exchange portals, consumer interfaces, business
partners, and/or clinical data amalgamation, in addition to
existing traditional claims data.
It is primarily an actuarial role to analyze this data and provide
management with insights.
As insurers begin taking on a more
collaborative role in the refinement of care delivery protocols,
these insights may help isolate the variability in clinical care
delivery that often leads to inefficiencies.
Similarly, analysis of the data is needed to help identify
the volatility of the cost of care and predict the drivers of
cost changes year to year, subpopulation to subpopulation,
etc. The population-based healthcare dynamics, such as
the interrelationships between income levels, nutrition,
and frequency of do-it-yourself home repairs, that drive
© 2012 KPMG LLP a Delaware limited liability partnership and the U.S. member firm of the
,
KPMG network of independent member firms affiliated with KPMG International Cooperative
(“KPMG International”), a Swiss entity.
All rights reserved. Printed in the U.S.A. The KPMG name,
logo and “cutting through complexity” are registered trademarks or trademarks of KPMG
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healthcare demand and consumer action present new risks and
uncertainties, particularly with regard to the current uninsured.
Insurers will need to use data to estimate the impacts of
the various drivers of healthcare demand as well as interpolate
and extrapolate that data in more creative and complex ways in
order to better understand the emerging experience.
These analyses opens the door for applications, such as
consumer behavior modeling, that banks and other insurers
have used to better understand the value principles of the
health consumer and their healthcare purchasing decisions.
Improved insights into consumer-healthcare decision-making
and insurance purchasing drivers can assist insurers in making
more effective decisions. These decisions include market
segmentation strategies, which are based upon the clinical care
needs and the purchasing patterns of these micropopulations,
and which also enhance the insurer’s relative strengths at
managing those co-morbidity risks.
Taking the next step
The healthcare industry is currently facing a variety of
questions as it tackles the data analytics challenges
described above. What data and data sources (or data
partners) are needed, and what are the external and internal
interdependencies between providers, payors, regulators,
and employers in the use of that data? What are the priority
considerations, and how will the decisions made by payors
affect or influence other stakeholders’ priorities? How will
the data sync with the technology and architecture currently in
use? Will sourcing, retaining, and storing the data be feasible,
and readily accessible? How can nontraditional data, such as
word searches of text messages, be structured to be usable
and transparent?
Health Actuarial Insights September 2012 | 7
.
The analyzed data must have a purposeful relationship to
the overall strategy of the company, and be flexible enough to
enable operating-model evaluation. Due to the general lack of
enabling technology or tools that could automate data collection
and standardize disparate data forms, multiple systems and/
or tools may be needed. In situations like this, a dedicated
resource, a “data steward, may be needed to oversee the
”
collaboration of the data needs and uses for all stakeholders,
internal and external, and to oversee the development of an
integrated reporting tool set across financial, risk, and business
intelligence platforms.
Conclusion
In order to influence strategic decision making, the actuarial
team and other analytical resources must be liberated from
their traditional roles of reconciling and validating claims data.
The analytics being contemplated can include, but are not
limited to, complex number theory, multivariate regression,
predictive modeling, etc. The analysis must be translatable to
strategic key performance indicators and give transparency
in the analysis to emerging risks and opportunities.
Having a corporate-wide strategic vision specific to data can
help drive the associated data collection, storage, and analysis
development action steps, as well as the metrics needed to
monitor performance.
Transforming the business model is a daunting but necessary
task.
Having the right data and analytics at hand to support
those strategic decisions will be critical. It is a challenge to
the payor’s senior management and the actuaries to address
how this will be accomplished. KPMG has been assisting
its clients identify the data strategies and analytics to be
considered in meeting this challenge.
Contact us
KPMG’s Health Actuarial practice
Laura Hay, FSA, MAAA
Principal, National Industry Leader –
Insurance
T: 212-872-3383
E: ljhay@kpmg.com
David White, FSA, MAAA
Principal, National Leader –
Actuarial Services
T: 404-222-3006
E: dlwhite@kpmg.com
Steve Mahan, FSA, MAAA
Principal, National Leader –
Health Actuarial Services
T: 214-840-2371
E: smahan@kpmg.com
Robert Hanes, FSA, MAAA
Director – Health Actuarial Services
T: 610-341-4806
E: rhanes@kpmg.com
Mark Jamilkowski, FSA, MAAA
Director – Health Actuarial Services
T: 212-954-7410
E: mjamilkowski@kpmg.com
Laurel Kastrup, FSA, MAAA
Director – Health Actuarial Services
T: 214-840-2461
E: lkastrup@kpmg.com
Tiffany Caufield, FSA, MAAA
Manager – Health Actuarial Services
T: 404-979-2124
E: tcaufield@kpmg.com
Al Raws, FSA, ACAS, MAAA
Manager – Health Actuarial Services
T: 610-341-4807
E: arawsiii@kpmg.com
Alisa Widmer, FSA, MAAA
Manager – Health Actuarial Services
T: 214-840-2559
E: awidmer@kpmg.com
Authors
Tiffany Caufield, FSA, MAAA
Manager – Health Actuarial Services
T: 404-979-2124
E: tcaufield@kpmg.com
Mark Jamilkowski, FSA, MAAA
Director – Health Actuarial Services
T: 212-954-7410
E: mjamilkowski@kpmg.com
Alisa Widmer, FSA, MAAA
Manager – Health Actuarial Services
T: 214-840-2559
E: awidmer@kpmg.com
Editor
Robert Hanes, FSA, MAAA
Director – Health Actuarial Services
T: 610-341-4806
E: rhanes@kpmg.com
Margaret Hermann, FSA, MAAA
Director – Health Actuarial Services
T: 610-341-4821
E: mhermann@kpmg.com
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity.
Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date
it is received or that it will continue to be accurate in the future.
No one should act upon such information without appropriate professional
advice after a thorough examination of the particular situation.
kpmg.com
© 2012 KPMG LLP a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms
,
affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Printed in the U.S.A. The KPMG
name, logo and “cutting through complexity” are registered trademarks or trademarks of KPMG International. NDPPS 105347
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