March of Dimes Foundation 

 Office of Government Affairs 

 1146 19th Street, NW, 6th Floor 

 Washington, DC 20036 

 Telephone (202) 659-1800 

 Fax (202) 296-2964 

 marchofdimes.com 

 nacersano.org 

Amy Turner 

Office of Health Plan Standards and Compliance Assistance 

Employee Benefits Security Administration 

US Department of Labor 

200 Constitution Avenue, NW, Room N-5653 

Washington, DC 20210 

Attention: RIN 1210-AB41 

July 30, 2010 

Dear Ms. Turner: 

The March of Dimes Foundation submits the following comments in response to the Interim 

Final Rule (IFR) regarding “Group Health Plans and Health Insurance Issuers Relating to 

Dependent Coverage of Children to Age 26 Under the Patient Protection and Affordable Care 

Act” published by the Department of Health and Human Services (HHS). The March of Dimes is 

a unique collaboration of scientists, clinicians, parents, members of the business community, and 

other volunteers affiliated with 51 chapters in every state, the District of Columbia and Puerto 

Rico. The Foundation’s mission is to improve the health of women of childbearing age, infants 

and children by preventing preterm birth, birth defects and infant mortality. The March of 

Dimes is pleased to express support for the provision in law and the regulation permitting young 

adults to remain on their parents’ health insurance until age 26, and the Foundation requests one 

clarification on the policy stipulated in the IFR. 

The March of Dimes has supported the policy to extend dependent coverage throughout the 

process to develop and enact federal health reform as a way to increase access to health 

insurance for women of childbearing age, approximately one in five of whom are uninsured 

according to Census Bureau data. Lack of health insurance is a barrier in accessing health 

services. The Centers for Disease Control (CDC) recommends that women of childbearing age 

receive preconception care services not only for their own health but also to help ensure better 

outcomes for future pregnancies. Preconception care allows providers to identify conditions or 

behaviors that can impact a future pregnancy and provide appropriate intervention. Examples 

include tobacco cessation services, nutrition counseling, and controlling chronic conditions such 

as hypertension or diabetes. This IFR will help more women obtain health insurance coverage 

and thus access to these important health services. 
The March of Dimes is pleased that the IFR specifies that an insurer may not discriminate 

against a young adult eligible for coverage under this provision based upon student status, tax 

dependent status, residence with parents, or marital status. The Foundation is also glad to see 

that this IFR applies to all insurance plans regardless of grandfather status, and that dependents 

eligible for coverage under this provision must be offered the same benefits at the same cost as 

traditional dependents. All of these policies will make it easier for young adults to obtain health 

insurance through this new option. 

With regard to how this option will work and exactly which young adults are eligible, the IFR 

states that grandfathered group health plans will not be required to offer coverage to young 

adults who currently have their own employer-sponsored health insurance or an offer of 

employer-sponsored health insurance. While the Foundation recognizes the common sense 

approach of this policy, we wish to point out that many employers offer new employees health 

insurance, but require the employee to be on staff for waiting period (for example, three months) 

before permitting the new employee to enroll in health insurance coverage. To help prohibit 

gaps in coverage, which can lead to gaps in access to needed health care, the Foundation urges 

HHS to make clear in the final regulation that young adults who gain access to their own 

employer-sponsored health insurance plan will be eligible to remain on their parents’ health 

plans during such a waiting or probationary period. 

Once again, the March of Dimes thanks you for working quickly to implement this new 

provision, which is estimated to provide coverage to up to 1.5 million young adults in 2011. 

Although it is estimated that this provision will raise the Foundation’s health insurance premium 

costs by 1-3 percent next year, the March of Dimes remains steadfast in our support of this 

provision to help expand insurance coverage. All of us at the Foundation look forward to 

continuing to work with you on continued efforts to implement the Patient Protection and 

Affordable Care Act. 

Sincerely, 

Marina L. Weiss, Ph.D. 

Senior Vice President, Public Policy 

 and Government Affairs