1010 Wayne Avenue • Suite 770 • Silver Spring, Maryland 20910-5600 • Phone: 301.650.9127 • Fax: 301.565.9670 • www.canceradvocacy.org

August 11, 2010 

The Honorable Kathleen Sebelius 

Secretary 

Department of Health and Human Services 

200 Independence Avenue, SW 

Washington, DC 20201 

RE: OCIIO- 4150-IFC 

Dear Secretary Sebelius: 

The National Coalition for Cancer Survivorship (NCCS) appreciates this opportunity to comment 

on the interim final rules related to coverage of dependents to age 26. We commend the efforts of 

the Departments of Health and Human Services, Labor, and Treasury to develop implementing 

rules that will ensure that these insurance protections for young adults go into effect on September 

23, 2010, without controversy or confusion. In addition, we applaud your efforts encouraging 

voluntary insurer compliance with the Patient Protection and Affordable Care Act dependent 

coverage provisions in advance of the implementation deadline. 

Young adult cancer survivors are at risk of late and long-term effects of their cancer and cancer 

treatment, and at the time when they may be in greatest need of health care for these treatment side 

effects, they are also at significant exposure for having no health insurance. Research has concluded

that as many as two-thirds of childhood cancer survivors will experience at least one late effect, with 

one-quarter experiencing a late effect that is severe or life-threatening. For these young adults, the 

extension of coverage through their parents’ health insurance is a critically important interim 

solution to their inability to obtain insurance. 

In the regulations implementing the dependent coverage provisions, the departments have addressed 

the few issues in the statute that required clarification. We support the language in the regulations

that would: 1) require the same benefits at the same price for similarly situated individuals, 

preventing young adult dependents from being offered inferior coverage, 2) mandate that employers 

and issuers inform young adults of their eligibility for coverage to age 26, 3) require a 30-day 

enrollment period, after notification of eligibility for continued coverage, 4) confirm that married 

adult children are eligible through their parents’ plans (while their spouses and children are not), 5) 

establish that residence with parents, student status, and inclusion as a dependent on parents’ tax 

returns are not issues that may be considered in determining a young adult’s eligibility for dependent

insurance coverage, and 5) clarify that those who have lost coverage through their parents’ plans 

prior to enactment of the Affordable Care Act but are still under age 26 may be eligible for coverage.
National Coalition for Cancer Survivorship

1010 Wayne Avenue • Suite 770 • Silver Spring, Maryland 20910-5600 • Phone: 301.650.9127 • Fax: 301.565.9670 • www.canceradvocacy.org 

We understand that the statute and implementing regulations do not require employers and insurers 

to offer dependent coverage. However, because the vast majority does offer such coverage, the 

extension of eligibility to age 26 will be a valuable benefit for cancer survivors. The projected cost 

of the provision, as measured by the impact on average family premiums, is limited. For those 

families that obtain their coverage in the individual market, the impact on premiums may be more 

significant. The statute does not address this issue or provide the opportunity for the departments 

to do so, and it is important to note that some may find the continuation of dependent coverage – 

especially if obtained through the individual market -- to be prohibitively expensive. 

NCCS supports the efforts of the Obama Administration to ensure the smooth implementation of 

the dependent coverage provisions beginning September 23, 2010. We also applaud the willingness 

of dozens of insurers to make such coverage available to thousands of young people in advance of 

the effective date. 

Sincerely, 

Thomas P. Sellers, MPA 

President and CEO 

11-year Cancer Survivor 

TPS/vb