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LEGAL PROCESSING DIVIS!
(PUBLICATION & REGULA ns
BRANCH TONS

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As of: september % ater
Received: August 12,

PUBLIC Fe on: 200

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
Heaith 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-2010-0010-0712
Comment on FR Doc # 2010-14488

Submitter Information

Name: James Stewart Scoville
Address:
150 South 700 East
Price, UT, 84501
Email: dr.scov@gmail.com
Phone: 435-637-4822
Fax: 435-637-4828
Submitter's Representative: Dr. Scoville
Organization: Scoville Chiropractic Family Health Clinic

General Comment

See attached file(s)

Attachments

IRS-2010-0010-0712.1: Comment on FR Doc # 2010-14488

https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=P... 9/3/2010


Thursday, August 12, 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 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.

Itis 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.c.
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 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 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.

Furthermore, I believe the legislators wanted to allow patients the ability to get their own choice in
Healthcare providers by providing this regulation. If many carriers are granted this grandfathering, |
believe the original intent of this law will be thwarted.

Thank you for the opportunity to comment on this regulation.

Sincerely,

J. S. Scoville, D.C.