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AUG 1 8 2010 

LEGAL PROCESSING DIVISION 


PUBLICATION & REGULATIONS 


BRANCH 
 As of: August 1S, 2010 

Received: August 09, 2010 

Status: Posted 

Posted: August 18, 2010 

Tracking No. 80b2cbOb 

PUBLIC 

SUBMISSION Comments Due: August 16, ;W 10 

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-2010-0010-0155 

Comment on FR Doc # 2010-14488 

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Submitter Information 

Name: Robert E Klein 

Address: 

2070 Kilauea Av 

Hilo, HI, 96720 

Email: kleinchiro@gmail.com 

Phone: 808-959-4588 

Fax: 8089594580 

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General Comment 

Please minimize "Grandfathered" health plans and maximize the good effects of Health Care 

Reform legislation. My complete message is attached in a Word document. 

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Attachments 

IRS-2010-0010-01SS.1: Comment on FR Doc # 2010-14488 

http://fdms.erulemaking.netlfdms-web-agency 1componentlsubmitterInfoCoverPage?Call=... 8/18/2010 
KLEIN CHIROPRACTIC CENTER 


Robert E. Klein, D.C., F.A.C.O. 


2070 Kilauea Avenue Hila, Hawaii 96720 : Fax (808) 959-4580 : Phone (808) 959-4588 

August 9, 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 

Dear Sirs: 


I am commenting on 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 (PP ACA). 


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


as ofJanuary 1,2014 when most ofthe reform components (Insurance Exchanges, Subsidies, Tax Credits, etc.) 


come into play. Rules for "Grand fathered" status should be extremely strict. 


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 ofgrandfather 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, incn:ase 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 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. 


Diplomate of the American Board of Chiropractic Orthopedists 


Member of the International College of Applied Kinesiology