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. REG NPd/2 70

LEGAL PROCESSING DIVISION
PUBLICATION & REGULATIONS [as of: September 01, 2010
BRANCH Received: August 11, 2010

P U B LIC Status: Posted

Posted: September 01, 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-2010-0010-0556
Comment on FR Doc # 2010-14488

Submitter Information

Name: Serge Nerli
Address:
59-11 161 Street
Fresh Meadows, NY, 11365-1414
Email: docserge@aol.com
Phone: 718-961-1253
Submitter's Representative: Dr. Serge Nerli
Organization: Dr. Serge Nerli
Government Agency Type: Local
Government Agency: None

General Comment

See attached file(s)

Attachments

IRS-2010-0010-0556.1: Comment on FR Doc # 2010-14488

https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=P..._ 9/1/2010



August 11, 2010

Office of Consumer Information and Insurance Oversight
Department of Health and Human Services

Attention: OCHO-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 Urider
the Patient Protection and Affordable Care Act (PPACA).

| 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 |
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.

Dr. Serge Nerli