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LEGAL PROCESSING DIVISION AEC UEYRVO SEP 0 12010

PUBLICATION & REGULATIONS
BRANCH

As of: August 31, 2010

PUBLIC Status Posteg

Posted: August 31, 2010
SUBMISSION 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-2010-0010-0500
Comment on FR Doc # 2010-14488

Submitter Information

Name: Desi Michael Menendez
Address:

20 Gilbert Avenue

Suite 203

Smithtown, 11787
Email: dmdc2@optonline.net
Phone: 631-265-8915
Fax: 631-265-8917

General Comment

See attached file(s)

Attachments

IRS-2010-0010-0500.1: Comment on FR Doc # 2010-14488

http://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=... 8/31/2010


August 11, 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

Below are my comments regarding the Interim Final Rute 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 PPACA, 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 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 (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.

Even by the most optimistic estimates, a substantial portion of the employee
population will remain outside the PPACA as of January 2014 based on the current
rules. While | 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 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.

DESI M. MENENDEZ, DC