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sep 8 2010
LEGAL PROCESSING DIVISION As of: September 08, 2010
PUBLICATION & REGULATIONS Received: August 13, 2010

Status: Posted

PUBLIC SUBMISSION Posted: September 08, 2010

Tracking No. 80b3067b
‘Comments Due: August 16, 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-2010-0010-0810
Comment on FR Doc # 2010-14488

Submitter Information

Name: William Howe III
Address:
1451 River Park Drive
Sacramento, CA, 95815
Email: bhowe@calchiro.org
Phone: 916-648-2727
Submitter's Representative: William Howe IIT
Organization: California Chiropractic Association

General Comment

See attached file(s)

Attachments

TRS-2010-0010-0810.1: Comment on FR Doc # 2010-14488

https://fdms.erulemaking .net/fdms-web-agency/ContentV iewer?objectId=0900006480b306... 9/8/2010


August 13, 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

To Whom It May Concern:

On behalf of the California Chiropractic Association (CCA), I am pleased to submit 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).

Given the variety of consumer protections afforded the public and a primary goal of PPACA to
provide expanded health insurance coverage opportunities for the public, CCA believes 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.) become effective.

As proposed, the interim final rule may result in marketplace confusion 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. While CCA does not underestimate the difficulty
involved in making change, the negative trade-off of creating another large sub-population of
excluded individuals and its related added costs, increased confusion and mitigation of the intent
of the legislation seem to warrant additional efforts to prevent.

CCA believes that for the benefit of all — consumers/employees, employers, health care insurers
and payers, health care providers and government enforcement agencies - the final rule needs to
be clear, reasonable and with no ambiguities involved in determining whether a group health
plan is excluded or not from the provisions of PPACA. Obviously, 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.
Cordially,

William A. Howe III
Executive Director