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LEGAL PROCESSING DIVISION 

PUBLICATION & REGULATIONS 

BRANCH As of: August 25, 2010 

Received: August 10, 2010 

Status: Posted 

Posted: August 25, 2010 

Tracking No. 80b2d227 

PUBLIC 

SUBMISSION Comments Due: August 16, 2010 

Submission Tvpe: 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-2010-00l0-0001 

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-201O-001O-0391 


Comment on FR Doc # 2010-14488 


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Submitter Information 

Name: ROBERT T HOWELL 


Address: 


1170 EMERALD SOUND BLVD 

OAK POIKNT, TX, 75068 


Email: MEDCORPS@GMAILCOM 


Submitter's Representative: NONE 


Organization: SELF 


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General Comment 

'Obama' care is far to communistic for me. Attached letter 

-------------------------------------------------------------.... 

Attachments 

IRS-2010-0010-0391.1: Comment on FR Doc # 2010-14488 

https:llfdms.erulemaking.netlfdms-web-agency/componentlsubmitterlnfoCoverPage?Call= ... 8/25/2010 
Dr. Robert T. Howell 

400 N. Loop 288 STE: 120 

Denton, TX 76209 

Diplomate & Fellow: 

American Board of Chiropractic Orthopedists 

Telephone: 940-5H6-0000 

Facsimile: 940-565-6655 

August 10, 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 

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 (PPACA). 

I believe that every effort should be made to increase the number ofindividuals covered by PP ACA, 

especially as ofJanuary 1,2014 when most ofthe 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 (Le. 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 ofthe employee population will remain outside 

the PP ACA as ofJanuary 2014 based on the current rules. While I understand the difficulty invclved 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. Robert T. Howell