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LEGAL PROCESSING DI
VISIO)
PUBLICATION & REGULAT! TONS

As of: Septem! 7 2010

PUBLIC Status: Posted

Posted: beets 02, 2010
SUBMISSION racking No. 20bze0%4 sg 2010

Submission Type: Web

Docket: IRS-2010-0010
Group Health Plans and Health Insurance Coverage Rules Relating to Status as a Grandfathered
Health Plan Under the Patient Protection and Afforable Care Act

Comment On: IRS-2010-0010-0001
Group Health Plans and Health Insurance Coverage: Interim Final Rules for Relating to Status as
a Grandfathered Health Plan under the Patient Protection and Affordable Care Act

Document: IRS-2010-0010-0597
Comment on FR Doc # 2010-14488

LS TS

Submitter Information

Name: William J. Koppari
Address:
po Box 888
5290 Williams Dr
Roscoe, IL,
Submitter's Representative: Durbin / Burris
Organization: Chiropractic
Government Agency Type: Federal

General Comment

Office of Consumer Information and Insurance Oversight
Department of Health and Human Services

Attachments

IRS-2010-0010-0597.1: Comment on FR Doc # 2010-14488

https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=P... 9/2/2010



August 11, 2010

Office of Consumer Information and Insurance Oversight
Department of Health and Human Services

Attention: OCHO-9991-IFC

P.O. Box 8016

Baltimore, MD 21244-1850

Re: Status as a Grandfathered Health Plan Under the Patient Protection and Affordable
Care Act

Below are my comments regarding the Interim Final Rule for Group Health Plans and
Health Insurance Coverage Relating to Status as a Grandfathered Health Plan Under the
Patient Protection and Affordable Care Act (PPACA).

Every effort should be made to increase the number of individuals covered by PPACA,
especially as of January 1, 2014 when most of the reform components (Insurance
Exchanges, Subsidies, Tax Credits, etc.) come into play.

The average consumer has a broad definition of “benefits.” Consumers view their health
plan beyond the covered benefits, cost sharing, and the contribution levels associated
with the plan.

The Rule may still result in some confusion to the marketplace in its application. For
example, if an employer raised the copayment level beyond the maximum in one area
(i.e. outpatient services) but retained the copayment level for primary care doctor visits,
does that mean a loss of grandfather status? Clarity will be critical both for the employer
and the employee.

Even by the most optimistic estimates, a substantial portion of the employee population
will remain outside the PPACA as of January 2014 based on the current rules. While ]
understand the difficulty involved in making change, creating another large sub-
population of excluded individuals will only add to costs, increase confusion, and
mitigate the potential impact of the legislation.

The Rule needs to be clear, reasonable, and with no ambiguities involved in determining
whether a group health plan is “in or out.” The decisions the federal government makes
today will determine the outcomes for tomorrow. We may need to make some difficult
decisions to create a sustainable health care system that will support a growing econorny
in the future. That means getting as many citizens across the country participating at the
beginning to make it work and delivering on its promises to retain their support.

Thank you for the opportunity to comment on this regulation.

Wm. J. Koppari, D.C.