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SEP 2 2010 REGIS 412-10

LEGAL PROCESSING DIVISION
PUBLICATION & REGULATION:
~ BRANCH s

As of: September 02, 2010

PUBLIC Status: Posted

Posted: September 02, 2010
SU B M ISSIO N 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-2010-0010-0621
Comment on FR Doc # 2010-14488

SS :

Submitter Information

Name: Robert A King
Address:

208 Pine Valley Rd

Locust Grove, VA, 22508
Phone: 540-972-1076
Submitter's Representative: N/A
Organization: Self

General Comment

See attached file(s)

Attachments

IRS-2010-0010-0621.1: Comment on FR Doc # 2010-14488

https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=P... 9/2/2010


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

August 12, 2010

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

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.

Below are my concerns 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):

1) 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. The Rule may still result in some confusion to consumers 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.

2) Even by the most optimistic estimates, a substantial portion of the employee population
will reportedly remain outside the PPACA as of January 2014 based on the current rules.
While I understand the difficulty involved in making changes, creating another large sub-
population of excluded individuals may very well add to costs, increase confusion, and
mitigate the potential impact of the legislation.

My I suggest as others have, that the Rule be made more clear and without 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 additional
difficult decisions in creating a sustainable health care system that is able to 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,
Dr. Robert King

208 Pine Valley Road
Locust Grove, VA 22508