Page 1 of 1

7% REG- JIS 42-16
ange; NG DIVISION
LEGAL PROS REGULATIONS

CATH
PUBLICAT' BRANCH las of: September 07, 2010

PUBLIC Status Posted

posted: Ranaeacs 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 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-2010-0010-0764
Comment on FR Doc # 2010-14488

Submitter Information

Name: Cynthia Johnson Kricko
Address:
510 Justis Dr
Greeneville, TN, 37745
Email: appalchiro@embarqmail.com
Phone: 423-639-4440
Fax: 423-639-0023
Organization: Appalachian Chiropractic Center PC

General Comment

Please see attached

Attachments

IRS-2010-0010-0764.1: Comment on FR Doc # 2010-14488

https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=P... 9/7/2010


Appalachian Chiropractic Center Cindy Johnson Kricko, D.C.
510 Justis Dr. ¢ Greeneville, TN 37745 423-639-4440

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

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).

I 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 I 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.

Cynthia Johnson Kricko, DC