The Florida Office of Insurance Regulation held a public hearing on the medical loss ratio on Sept. 24, 2010, and used testimony from that hearing to buttress its waiver request. But Rome's letter argues that "event was not a public hearing in any sense of the term."
"It was held with less than one day's notice," Rome writes. "There was no 'unanimity of all interested parties' since consumers were not even allowed to speak. Four representatives of insurance companies and one representative of agents and brokers testified at the invitation of the Florida Office of Insurance Regulation (FLOIR). No consumers were invited and the record was closed before the consumers who did attend were given the opportunity to speak."
Public comments on Florida's waiver request, as well as Michigan's, are due to HHS today.