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i 3 DIVISION DITA SCY O-
{LEGAL PROCESS GULATIONS PECHEUS-1 0
BRANCH:

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AUG 5 2019

As of: August 05, 2010

PUBLIC Status: Posted,

Posted: August 05, 2010
SUBMISSION 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 Grandfathe-ed
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 Pian under the Patient Protection and Affordable Care Act

Document: IRS-2010-0010-0021
Comment on FR Doc # 2010-14488

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Submitter Information

Name: Mary Margaret Collins
Address:

C/O Media Financial Management Association

550 West Frontage Road, Ste. 3600

Northfield, IL, 60091
Email: mary.collins@mediafinance.org
Submitter's Representative: President & CEO
Organization: Media Financial Management Association

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General Comment

On behalf of Media Financial Management Association (MFM), we appreciate the opportunity to
comment on the Interim Final Rules regarding grandfathered health plans under the Patient
Protection and Affordable Care Act. MFM is a section 501(c)(6) individual membership
organization with four full-time employees. Our for-profit subsidiary employs another four people.
We face the same obstacles to obtaining good, affordable health insurance coverage confronting
small businesses in general. We are captive to a small number of health insurance providers, and
do not have the economic clout of larger enterprises.

We purchase heath insurance for our employees that is fully insured; we do not have the
resources or ability to self-insure as a means to control our health insurance costs and benefits.
MFM will greatly benefit from the expanded options for health insurance that will be available
beginning in 2014 through the Exchange. The Exchange will allow the small and medium-sized
organizations that our members represent to benefit from the economics of pooling that is not
currently available.

We are concerned that Interim Final Rules as currently drafted may force us to make the difficult

and undesirable choice of canceling health care coverage if grandfather status is revoked,
especially before the Exchange is in place.

https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=P... 8/5/2010


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We would suggest for the transition period before the Exchange is established, that small and
medium sized employers be allowed to make cost saving changes to copayments and cost
sharing provided they do not reduce the per-employee amount they pay for insurance. This could
help us and other organizations 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 be allowed to change insurance carriers prior to 2014 and have their plans treated as
grandfathered plans provided that provided they do not reduce the per-employee amount they
pay for insurance. This would allow them to maintain the level of coverage for employees, but
reap the benefit of a less expensive plan prior to the implementation of the Exchange.

Thank you for allowing us to express our views.

https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=P... 8/5/2010