Does "Closed" mean "Approvable"?
I have written before about the confusion over the post-approval review ("PAR") process - more recently, about the process of getting a form revised via the PAR approved. This week, some of my concerns came to fruition when I received an objection letter from the actuarial unit on a policy that was submitted at the NYSID's request for full prior approval upon completion of a PAR.
This form is very similar to the one that was approved on a CL-6 basis but has the usual minor language tweaks that result from a post-approval review. Both the Department actuaries and lawyers reviewed those revisions and the legal unit issued a letter indicating the PAR file was being closed and the revised form should be submitted for full prior approval. The company and I (mistakenly) thought that meant the NYSID had signed off on the changes we made during the PAR. It seems to defy logic that they would review changes but be dissatisfied and yet still close the file. But now the actuarial objection letter asks for further revisions to the exact language that was the subject of revision in the PAR.
In addition, a brand new issue was raised that is more significant to the product design than any that was raised in the PAR. As we continue to make our way through this process looking for some finality at some point, it seems there must be a better way!
