ASSOC TION OF GOSPEL SIONS

7222 120 

IA RESCUE MIS

COMMERCE CENTER DRIVE, SUITE

COLORADO SPRINGS, CO 80919 

August 13, 2010 

 Plan Standards and Compliance Assistance 

y Administration 

Office of Health

Employee Benefits Securit

Room N‐5653 

r 

e, NW 

U.S. Department of Labo

200 Constitution Avenu

Washington, DC 20210 

Re: RIN 1210–AB42, The Interim Final Rules for Group Health Plans and Health 

Insurance Coverage Relating to Status as a Grandfathered Health Plan Under the 

Patient Protection and Affordable Care Act 

On behalf of the Association of Gospel Rescue Missions (AGRM), we appreciate the 

opportunity to comment on the Interim Final Rules regarding grandfathered health 

plans under the Patient Protection and Affordable Care Act. AGRM is North 

America’s oldest and largest association of independent crisis shelters and 

rehabilitation centers. Rescue missions have cared for the hungry, homeless, 

abused, and addicted in America since the 1870s. Today, our members provide 

shelter for 15 percent of America’s homeless every night and serve 48 million meals, 

provide 16 million nights of lodging, help thousands of abuse victims, and graduate 

more than 18,000 individuals from addiction‐recovery programs each year. 

All of our members are tax‐exempt organizations and most are considered small 

employers, but each one struggles to purchase health care coverage for employees. 

Even small cost increases or changes in benefits can mean the difference between 

providing coverage for employees and having no option but to limit or drop 

coverage altogether. Unfortunately, this trend will continue until more affordable 

health care options are available starting in 2014 under the Exchange system. That 

is why grandfathering their existing coverage for employees is so important, but the 

grandfather provisions in the Interim Final Rules are too restrictive and will likely 

price more of our members out of the market—an ironic result of attempts to make 

health care more affordable. 

Specifically, the subsidies for small employers meant to offset the cost of insurance 

are too limited and phase out if an employer has over ten employees and expire 

completely for rescue missions with 25 or more employees. In addition, the credits 

are phased out for employers with even modest compensation packages. As a result, 

hese subsides provide assistance for some small, tax‐exempt employers but the 

enefit is very limited. 

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In addition, many of our members have small numbers of employees and are unable 

to self‐insure, which places them at the mercy of health insurance plans sold by 

private carriers. That means rescue missions often have no control over co‐pays and 

cost sharing and simple changes to their plans can cause them to lose grandfather 

status. Until the Exchange is in place, finding new, affordable insurance that meets 

the requirements of the Patient Protection and Affordable Care Act will be a serious 

problem. Further, in order to control costs so that health insurance can be 

purchased for employees, our members need the ability to work with their current 

carriers to adjust co‐pays and cost sharing as much as possible in order to afford 

coverage, especially in the current economic and charitable giving environment. 

The Interim Final Rules, as currently drafted, will likely make a bad situation worse 

by forcing more of AGRM’s member organizations to limit or cancel health care 

coverage if grandfather status is revoked before the Exchange is in place. To remedy 

this problem until more affordable options are available in 2014, we suggest that 

small‐ and medium‐sized employers be allowed to 1) make cost saving changes to 

co‐payments and cost sharing, and 2) change insurance carriers prior to 2014 and 

have their plans treated as grandfathered plans, provided they do not reduce the 

per‐employee amount they pay for insurance. These changes will allow rescue 

missions to maintain the current level of coverage for employees, while reaping the 

benefit of a less expensive plan prior to the implementation of the Exchange in 2014.

The work that rescue missions perform is essential for the homeless and poor living 

in communities across America. We hope that you will consider our suggestions and 

elp us to continue providing the same level of support for our employees, who do 

e individuals in our communities who need help the most. 

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so much for th

With respect, 

John Ashm

President 

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