NAHMA


NATIONAL AFFORDABLE HOUSING MANAGEMENT ASSOCIATION 

August 4, 2010 

Office of Consumer Information and Insurance Oversight 

Department of Health and Human Services 

Room 445-G Hubert H. Humphrey Building 

200 Independence Ave. SW 

Washington, DC 20201 

Re: OCIIO-9991-IFC, The Interim Final Rules for Group Health Plans and Health 

Insurance Coverage Relating to Status as a Grandfathered Health Plan Under the 

Patient Protection and Affordable Care Act 

On behalf of the National Affordable Housing Management Association (NAHMA). we 

appreciate the opportunity to comment on the Interim Final Rules regarding 

grandfathered health plans under the Patient Protection and Affordable Care Act. 

NAHMA is a section 501 (c)(6) individual membership organization whose mission is to 

advocate for quality affordable multifamily housing. 

NAHMA has six full-time employees, and an annual operating budget of about $1.4 

million. Currently, we provide health insurance to our employees as a benefit of 

employment. In 2010 the cost to provide this benefit is about $60,000, or 4.3 percent of 

our annual expenses. In 2011, we expect the cost to rise to about $65,000, or 4.5 

percent of our annual expenses. This is a high cost to a small association, and it is 

unknown how long we will be able to continue offering the same current level of benefit, 

through the same provider, to our staff. 

The plan is a high-deductible plan, with health savings accounts provided to our 

employees. We have used a broker to thoroughly research the types of plans available 

to us, and we know we have the best rate that we are able to get at this time. 

We believe that many organizations, including NAHMA, will greatly benefit from the 

expanded options for health insurance that will be available beginning in 2014 through . 

the Exchange. However, because the benefits of the Exchange will not be realized until 

2014, we will likely continue to experience annual cost increases and lack of control 
over actual coverage until 2014. As such, the grandfathering of our existing coverage is 

extremely important, especially prior to the establishment of a working Exchange .... 

system. 

We are greatly concerned that the grandfather provisions outlined in the Interim Final 

Rules are too restrictive and may cause us to lose the grandfathering we need. If 

NAHMA is forced through budget constraints to consider options of a non-grandfathered 

plan before we have the benefit of an Exchange, we are concerned that we may be 

priced out of the market and may even have to drop coverage - something we do not 

want to do. 

We would suggest for the transition period before the Exchange is established, that 

small and medium sized employers such as NAHMA be allowed to make cost saving 

changes to copayments and cost sharing provided we do not reduce the per-employee 

amount we pay for insurance. This could help us adjust and preserve coverage in 

anticipation of greater reform and options that will occur beginning in 2014. 

We also suggest that small and medium sized employers such as NAHMA be allowed 

to change insurance carriers prior to 2014 and have our plans treated as grandfath,ered 

plans provided we do not reduce the per-employee amount we pay for insurance. This 

would allow us to maintain the level of coverage for our employees, but reap the benefit 

of a less expensive plan prior to the implementation of the Exchange. 

Thank you for this opportunity to express our views on this important issue. 

Sincerely, 

/'

Kristina Cook, CAE 

Executive Director, NAHMA