https://fdms.erulemaking.net/...eb-agency/Download?operation=CoverPage&ObjectId=0900006480b2c16d&Comment=true[8/12/2010 11:15:54 AM]

PUBLIC SUBMISSION

As of: August 12, 2010

Received: August 09, 2010

Status: Pending_Post

Tracking No. 80b2c16d

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-0020

Comment on FR Doc # 2010-11391

Submitter Information

Name: Aimee Ossman

Organization: National Association of Children's Hospitals

General Comment

On behalf of children’s hospitals across the country, the National Association of Children’s Hospitals

(N.A.C.H.) appreciates the opportunity to provide comments on the interim final rule entitled, “Group

Health Plans and Health Insurance Issuers Relating to Dependent Coverage of Children to Age 26

Under the Patient Protection and Affordable Care Act,” published in the Federal Register on May 13,

2010. We appreciate your broad interpretation of the statute that will allow many young adults to

obtain needed health insurance coverage. 

Children’s hospitals provide health care to many young adults who age out of health insurance

coverage. This regulation will allow many of these individuals to have a more continuous source of

coverage. This should assist young adults access the care they need sooner than if they had no

coverage at all. 

Please see attached file for specific comments.

Attachments

HHS-OS-2010-0012-DRAFT-0020.1: Comment on FR Doc # 2010-11391
August 9, 2010

The Honorable Kathleen Sebelius

Secretary

US Department of Health and Human Services

Hubert H. Humphrey Building

200 Independence Avenue, SW

Washington, DC 20201

RE: File Code OCIIO-4150-IFC

Dear Secretary Sebelius:

On behalf of children’s hospitals across the country, the National Association 

of Children’s Hospitals (N.A.C.H.) appreciates the opportunity to provide 

comments on the interim final rule entitled, “Group Health Plans and Health 

Insurance Issuers Relating to Dependent Coverage of Children to Age 26 

Under the Patient Protection and Affordable Care Act,” published in the 

Federal Register on May 13, 2010. We appreciate your broad interpretation of 

the statute that will allow many young adults to obtain needed health 

insurance coverage. 

Children’s hospitals provide health care to many young adults who age out of 

health insurance coverage. This regulation will allow many of these 

individuals to have a more continuous source of coverage. This should assist 

young adults access the care they need sooner than if they had no coverage at 

all. 

We strongly support the provisions of the rule that would:

 Define a “dependent” only in terms of the relationship between a child 

and the health plan participant. We strongly support the provision that 

prohibits plans from conditioning dependent coverage on factors such 

as student or marital status, residency, financial support or other 

factors. 

 Establish a process to allow those who had previously lost dependent 

status because of age of change of circumstances (i.e. no longer a 

student) to enroll in coverage if they have not yet attained the age of 
26. Plans and issuers must provide written notice to dependents, or 

the health plan participant on behalf of the dependent.

 Require the terms of coverage –benefits, premiums and cost-sharing –

to be the same for older and younger dependents. 

We would like to suggest one change to the regulation. The regulation states 

that grandfathered health plans are not required to provide coverage for 

dependents who have their own employer-sponsored insurance or an offer of 

employer-sponsored insurance. We would like to suggest that the regulation 

allow a dependent who is subject to a waiting period for their own employersponsored insurance to be covered during that time by the parent’s insurance. 

This will ensure that these individuals will not have a gap in coverage as they 

are waiting to be enrolled in their own employer-sponsored insurance. 

We appreciate the opportunity to comment. We look forward to working with 

you as you continue to develop new policies and regulation that will ensure 

all children have health insurance coverage, but also access to needed health 

care. If you have any questions on our comments, please contact Aimee 

Ossman, Director, Policy Analysis at 703/797-6023 or aossman@nachri.org.

Sincerely,

Lawrence A. McAndrews

President & CEO