https://fdms.erulemaking.net/...component/submitterInfoCoverPage?Call=Print&PrintId=0900006480b2e679&Comment=true[8/12/2010 11:47:43 AM]

PUBLIC SUBMISSION

As of: August 12, 2010

Received: August 11, 2010

Status: Pending_Post

Tracking No. 80b2e679

Comments Due: August 11, 2010

Submission Type: Web

Docket: HHS-OS-2010-0012

Group Health Plans and Health Insurance Issuers Relating to Dependent Coverage of Children to Age 26, etc.

Comment On: HHS-OS-2010-0012-0001

Group Health Plans and Health Insurance Issuers Relating to Dependent Coverage of Children to Age 26, etc.

Document: HHS-OS-2010-0012-DRAFT-0031

Comment on FR Doc # 2010-11391

Submitter Information

Name: Robert Beall

Organization: Cystic Fibrosis Foundation

General Comment

Please find attached comments from the Cystic Fibrosis Foundation regarding Interim Final Rules for Group Health

Plans and Insurance Issuers Related to Dependent Coverage of Children to Age 26.

Thank you for the opportunity to submit these comments. Questions may be directed to Mary Dwight, Vice

President of Government Affairs, at (301) 841-2639 or mdwight@cff.org.

Attachments

HHS-OS-2010-0012-DRAFT-0031.1: Comment on FR Doc # 2010-11391
_________________________________________________

August 11, 2010 

Office of Consumer Information 

 And Insurance Oversight 

Department of Health and Human Services 

Attention: OCIIO–4150-IFC 

PO Box 8016 

Baltimore, MD 21244-1850 

RE: OCIIO- 4150-IFC 

Dear Sir or Madam: 

The Cystic Fibrosis Foundation is pleased to submit these comments regarding the 

Interim Final Rules for Group Health Plans and Health Insurance Issuers Related to 

Dependent Coverage of Children to Age 26. We applaud your efforts to set forth 

straightforward regulations to implement the provisions of the Patient Protection and 

Affordable Care Act related to coverage of dependents to age 26, as well as your 

aggressive encouragement of voluntary action by insurers to offer dependent coverage in 

advance of the effective date of September 23, 2010. Both efforts are critically important 

to young adults with cystic fibrosis (CF), who all too often find themselves with limited 

or no options for health insurance coverage. 

Cystic fibrosis is a rare genetic disease affecting approximately 30,000 Americans. 

Infants diagnosed with the disease 30 years ago were not expected to live to start school. 

Improvements in available treatments and the management of the disease have 

contributed to an increase in the mean age of survival to the mid-30’s. Obtaining health 

insurance coverage is a struggle for families from the birth of their children with CF, and 

for young adults with CF the challenges of finding and purchasing health insurance are 

often overwhelming. Although some young adults with CF have employer-sponsored 

insurance, Medicaid, or coverage through a state-high-risk pool, others are left with no 

insurance coverage and as a result must make difficult choices about their CF treatment. 

For many young adults, the ability to retain coverage through a parent’s health insurance 

plan will help them receive and pay for the health care they need on a daily basis. By 

addressing the following issues with clarity, the new rules will ensure smooth 

implementation of dependent coverage beginning September 23, 2010. 

• By preventing plans and issuers from considering whether an adult child is a 

dependent on the parents’ tax return, is no longer a student, or lives with his or her 

National Office 

6931 Arlington Road Bethesda, Maryland 20814 

(301) 951-4422 (800) FIGHT CF Fax: (301) 951-6378 Internet: www.cff.org E-mail: info@cff.org
parents, the rules will guarantee that eligible adult children obtain coverage 

without delay that might have been caused by eligibility determination. 

• Requiring that plans provide young adult children with the same benefits provided 

to similarly situated individuals at the same price will increase the likelihood that 

young adults will have adequate insurance coverage. 

• Implementing a requirement that insurers and employers notify young adults of 

their continued eligibility and provide them 30 days to take advantage of the 

coverage opportunity will ensure that young adults have an adequate time to 

enroll. 

Although an analysis of the dependent coverage provision found that family premiums 

would increase by a limited percentage, the potential increase in cost could be much 

greater for those families that are purchasing coverage in the individual market. We 

realize that it is beyond the scope of the rule to address that situation. We also note that 

the availability of any insurance – even at high rates in the individual market – will 

provide relief to some adult children with CF and their families. However, it is important 

to recognize the heavy financial burden that health care creates for those with CF and 

their families, a burden that is of course not addressed by the extension of dependent 

coverage. 

Young adults with CF often face serious job lock and encounter barriers to their 

professional development as they make work and life choices that are dictated by their 

ability to secure and pay for their health care. The dependent coverage provision, as 

implemented by the interim final rule, helps to address that situation for those with CF. 

We applaud the Obama Administration for seeking the early implementation of 

dependent coverage and many insurers for accepting the challenge of early 

implementation. We also commend the efforts to simplify the process for full 

implementation of this Affordable Care Act provision on September 23, 2010. 

Sincerely, 

 

Robert J. Beall, Ph.D. 

President and Chief Executive Officer