Proud to serve New York State’s 

Not-For-Profit Hospitals, Health Systems, 

and Continuing Care Providers

Daniel Sisto, President

2010 BOARD OF TRUSTEES

OFFICERS

Chairman 

JOSEPH QUAGLIATA  Oceanside 

Chairman-Elect 

HERBERT PARDES, M.D.  New York 

Secretary 

JOSEPH MCDONALD  Buffalo 

Treasurer 

LINDA BRADY, M.D.  Buffalo 

Immediate Past Chairman 

DAVID KRUCZLNICKI  Glens Falls 

Past Chairmen 

MICHAEL DOWLING  Great Neck 

STEVEN GOLDSTEIN  Rochester 

STANLEY BREZENOFF  New York 

. 

FORMER CHAIRS

GLADYS GEORGE, ESQ.  New York 

JON SCHANDLER  White Plains 

JOHN SPICER  New Rochelle

CLASS OF 2010

C. WILLIAM BROWN  Rochester 

THOMAS CARMAN  Watertown 

JOAN CONBOY  Little Falls 

SAMUEL DANIEL, M.D.  New York 

WENDY GOLDSTEIN  Brooklyn 

JAMES HARDEN  Rockville Centre 

ANNETTE LEAHY  Newark 

JOEL SELIGMAN  Mount Kisco 

WILLIAM STRECK, M.D.  Cooperstown 

BETSY WRIGHT  Jamestown

CLASS OF 2011

ALLAN ATZROTT  Newburgh 

JAMES BARBA, J.D.  Albany 

CHARLES FAHD II  Massena 

LINDA FARCHIONE  Canandaigua 

ELI FELDMAN  Brooklyn 

DAVID FELTON  Hamilton 

RICHARD HAWKS  Canandaigua 

RONALD KRAWIEC  Warsaw 

D. ROBERT MACKENZIE, M.D.  Ithaca 

JEFFREY MENKES  New York 

STEPHEN MILLS  Flushing 

GINO PAZZAGLINI  Troy 

JAMES REED, M.D.  Troy 

CLASS OF 2012

PAMELA BRIER  Brooklyn 

SCOTT COOPER, M.D.  Bronx 

ANDREW LITT, M.D.  New York 

ALAN MORSE, J.D.,Ph.D.  New York 

STEPHENS MUNDY  New York 

THOMAS OCKERS  Patchogue 

THEODORE PASINSKI  Syracuse 

DAVID ROSEN  Jamaica 

SARAH SCHERMERHORN  Schenectady 

July 12, 2010 

The Honorable Kathleen Sebelius 

Secretary Secretary 

U.S. Department of Health and Human Services 

200 Independence Avenue, SW 

Washington, DC 20201 

Re: Interim Final Rules for Group Health Plans and Health Insurance Issuers 

Relating to Dependent Coverage of Children to Age 26 Under the Patient 

Protection and Affordable Care Act 

Dear Secretary Sebelius: 

The Healthcare Association of New York State (HANYS), the only statewide 

hospital and continuing care association in New York State, representing more than 

550 non-profit and public hospitals, nursing homes, home care agencies, and other 

health care organizations, submits these comments in response to the Department of 

Health and Human Services’ (HHS) publication of Interim Final Rules for Group 

Health Plans and Health Insurance Issuers Relating to Dependent Coverage of 

Children to Age 26 Under the Patient Protection and Affordable Care Act and related 

request for comments. 

The Healthcare Association of New York State (HANYS), the only statewide 

hospital and continuing care association in New York State, representing more than 

550 non-profit and public hospitals, nursing homes, home care agencies, and other 

health care organizations, submits these comments in response to the Department of 

Health and Human Services’ (HHS) publication of Interim Final Rules for Group 

Health Plans and Health Insurance Issuers Relating to Dependent Coverage of 

Children to Age 26 Under the Patient Protection and Affordable Care Act and related 

request for comments. 

The Interim Final Rules were published to implement Section 2714 of the Public 

Health Service (PHS) Act, which extends group health insurance coverage to 

children until they reach age 26. HANYS is pleased that Section 2714 of the PHS 

Act will enable young adults under the age of 26 to remain on a parent’s group health 

plan, and New York’s own age extender law will help adult children ages 26 through 

29 to continue their health insurance coverage under the Consolidated Omnibus 

Budget Reconciliation Act. Together, these rules will improve access to health 

insurance coverage for young adults in New York and across the nation. 

The Interim Final Rules were published to implement Section 2714 of the Public 

Health Service (PHS) Act, which extends group health insurance coverage to 

children until they reach age 26. HANYS is pleased that Section 2714 of the PHS 

Act will enable young adults under the age of 26 to remain on a parent’s group health 

plan, and New York’s own age extender law will help adult children ages 26 through 

29 to continue their health insurance coverage under the Consolidated Omnibus 

Budget Reconciliation Act. Together, these rules will improve access to health 

insurance coverage for young adults in New York and across the nation. 

HANYS applauds HHS for designing the Interim Final Rules to restrict insurance 

plans’ ability to define “dependent” for eligibility purposes to the relationship 

between a child and the plan participant or primary subscriber. The elimination of 

categorical distinctions such as financial dependence, residency, student status, and 

employment in defining dependent is an important step toward increasing 

participation in the health insurance market. 

HANYS applauds HHS for designing the Interim Final Rules to restrict insurance 

plans’ ability to define “dependent” for eligibility purposes to the relationship 

between a child and the plan participant or primary subscriber. The elimination of 

categorical distinctions such as financial dependence, residency, student status, and 

employment in defining dependent is an important step toward increasing 

participation in the health insurance market. 

MAIN HEADQUARTERS: One Empire Drive / Rensselaer, New York 12144 / (518) 431-7600 / fax (518) 431-7915 / www.hanys.org

WASHINGTON, D.C. OFFICE: 499 South Capitol Street SW, Suite 405 / Washington, D.C. 20003 / (202) 488-1272 / fax (202) 488-1274 
The Honorable Kathleen Sebelius Page 2 

July 12, 2010 

Moreover, the broad application of the Interim Final Rules to both fully insured and self-insured 

group health plans, and to grandfathered plans after January 1, 2014, will help bring coverage to 

more young adults, reducing the overall cost of health care to state and federal governments. 

HANYS supports the Interim Final Rules and appreciates this opportunity to submit comments. 

Extending group health insurance to children until the attainment of age 26 may help to reduce the 

financial burden that our member hospitals shoulder after rendering services to young adults who 

have become uninsured. HANYS believes that enhanced access to group health insurance will 

benefit patients and providers alike. 

If you have questions about our comments, please contact Jeffrey Gold, Vice President, Managed 

Care and Special Counsel, at (518) 431-7730. 

Sincerely, 

Daniel Sisto 

President 

DS:dd 

MAIN HEADQUARTERS: One Empire Drive / Rensselaer, New York 12144 / (518) 431-7600 / fax (518) 431-7915 / www.hanys.org

WASHINGTON, D.C. OFFICE: 499 South Capitol Street SW, Suite 405 / Washington, D.C. 20003 / (202) 488-1272 / fax (202) 488-1274