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REG-NP4I2 10

LEGAL PROCESSING DIVISION
PUBLICATION & REGULATIONS

BRANCH
As of: September 02, 2010

Received: August 11, 2010
PUBLIC Site Ps 210
SUBMISSION precking Wo, OOneeefe 6, 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 Fina! Rules for Relating to Status as
a Grandfathered Health Plan under the Patient Protection and Affordable Care Act

Document: IRS-2010-0010-0611
Comment on FR Doc # 2010-14488

Submitter Information

Name: Cynthia V Edwards
Address:

10312 Van Winkle Ct.

Austin, TX,
Submitter's Representative: Self
Organization: American Chiropractic Association
Government Agency Type: Federal
Government Agency: HRSA

General Comment

See attached file(s)

Attachments

IRS-2010-0010-0611.1: 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: OCIIO-9991-IFC

P.O. Box 8016

Baltimore, MD 21244-1850

Re: 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

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).

| believe that 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.
It is my opinion that 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 economy 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.

Respectfully submitted,

Cynthia V. Edwards