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AUG 2 5 2010 

LEGAL PROCESSING DIVISION 

~BUCAnON &. REGULATIONS BRANCH 

As of: August 25, 2010 

Received: August 10, 2010 

Status: Posted 

Posted: August 25, 2010 

Tracking No. 80b2dOf4 

PUBLIC 

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-2010-0010-0363 

Comment on FR Doc # 2010-14488 

-------------------------------------------------------------,---­

Submitter Information 

Name: Toby A Harmon 

Address: 

Jasper, IN, 

Organization: Harmon Family Chiropracic 

General Comment 

See attached file(s) 

Attachments 

IRS-2010-0010-0363.1: Comment on FR Doc # 2010-14488 

https :llfdms.erulemaking.netlfdms-web-agencyl componentlsubmitterInfoCoverPage?Call=... 8/25/2010 
Office ofConsumer 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 (PP ACA). 


I believe that every effort should be made to increase the number of individuals covered by PP ACA, 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 ofJanuary 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, incrt:ase confusion, 


and mitigate the potential impact ofthe 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 syst<,m 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. 


Whether an insurance plan has grandfathered status is very important because this status will 

determine whether or not an insurance plan will have to comply with certain provisions of the Patient 

Protection and Affordable Care Act (PPACA), including the non-discrimination provision. The nondiscrimination provision is very important to the chiropractic profession as it ensures that insurance 

plans cannot discriminate against providers with respect to partiCipation and coverage, when the 

provider is acting within their scope of practice. 

Thank you for the opportunity to comment on this regulation. 

Drs. Toby and Sheila Harmon