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2401 N. Glassell Street, Orange, California 92865
714 921 8800714 921 7490 vo LT

www.volt.com workforce

May 21, 2010

The Honorable Kathleen Sebelius
Secretary

Department of Health & Human Services
Hubert Humphrey Building

200 Independence Avenue, SW
Washington, DC 20201

The Honorable Hilda Solis
Secretary

Department of Labor

Frances Perkins Building

200 Constitution Avenue, NW
Washington, DC 20210

Dear Secretary Sebelius and Secretary Solis:

We are writing to alert you to the negative impact that the Patient Protection & Affordable Care Act
(PPACA) threatens to have on employees and dependents currently covered by group Limited Medical
Benefit plan insurance coverage. We seek your assistance in providing transitional regulatory guidance
that would ensure those currently covered by these plans could remain covered until 2014 when better
options will first become available through the Exchanges. To make matters worse, this population does
not appear eligible for the high-risk poo! because with Limited Medical Benefit coverage, they have
“creditable coverage, “ but the risk pool rules under PPACA demand that they not have creditable
coverage (Sec. 1101 (d) (2)).

Prior to 2014, PPACA directs the Secretary to establish approved annual dollar limit rules. If these limits
are too high or don't provide an exception for Limited Medical Benefit plans, insurance coverage would
abruptly end for covered employees and their families beginning later this year. This population would
be left with no coverage until 2014. While it surely was not the intent of Congress or the Administration
to increase the number of uninsured, this provision will produce exactly this result for some of the most
vulnerable of our population, e.g., lower-wage, part-time, seasonal and temporary workers who can only
obtain and afford limited benefit medical insurance coverage.

Unless you provide guidance allowing these plans to continue till 2014, this provision will have the effect
of undermining coverage for the 1.4 million citizens enrolled in group Limited Medical Benefit plans as of
the first plan year after September 23, 2010. We ask that you consider temporarily excluding
grandfathered group Limited Medical Benefit Plans from the annual benefit limit provision until other
provisions of the PPACA increasing the availability of coverage (such as the tax credits through state
exchanges) take effect in 2014.


2401 N. Glassell Street, Orange, California 92865

Page Two
May 21, 2010

While this coverage is limited in nature, it does cover the majority of medical issues facing this population
and at an extremely affordable price point. By allowing employees and their families to remain in these
plans for the time being, they will be able to transition to other health insurance when it becomes

available without experiencing a loss of coverage.

We thank you in advance for listening to our concerns. Let's not disenfranchise this currently insured

group during the transition period.

Sincerely yours,

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President

Volt Workforce Solutions

CC: Phyllis C. Borzi
Assistant Secretary
Employee Benefits Security Administration
Department of Labor
Frances Perkins Building
200 Constitution Avenue, NW
Washington, DC 20210

714921 8800 714 921 7490

www.volt.com

VOLT

workforce