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.LEOAL PROCESSING DIVISION 


PUBLICATION & REGULATIONS 


BRANCH As of: August 20{ 2010 

Received: August 09{ 2010 

Status: Posted 

Posted: August 20{ 2010 

Tracking No. 80b2cc43 

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-2010-001O-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-2010-001O-0257 

Comment on FR Doc # 2010-14488 

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Submitter Information 

Address: l"1A 

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General Comment 

See attached file(s) 

Attachments 

IRS-2010-0010-0257.1: Comment on FR Doc # 2010-14488 

https:/Ifdrns.erulernaking.netlfdrns-web-agency IcornponentlsubrnitterInfoCoverPage?Call= ... 8/20/2010 
August 9, 2010 

Office ofConsumer Information and Insurance Oversight 

Department of Health and Human Services 

Attention: OCII0-9991-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 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 p::an 

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 visii:s, 

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 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, increase 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 ,~reate 

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 ;md 

delivering on its promises to retain their support. 

Thank you for the opportunity to comment on this regulation. 

Matthew J. Schirmer, D.C.