CANCER LEADERSHIP COUNCIL 

A PATIENT-CENTERED FORUM OF NATIONAL ADVOCACY ORGANIZATIONS 

 ADDRESSING PUBLIC POLICY ISSUES IN CANCER 

August 27, 2010 

Office of Health Plan Standards and Compliance Assistance 

Employee Benefits Security Administration 

Room N-5653 

United States Department of Labor 

200 Constitution Avenue, NW 

Washington, DC 20210 

ATTENTION: RIN 1210-AB43 

The undersigned organizations, which represent cancer patients, providers, and 

researchers, commend the Departments of Health and Human Services, Labor, and 

Treasury for the interim final rules regarding preexisting condition limits, rescissions, 

annual and lifetime limits, and patient protections. These rules, as the departments 

acknowledge, are of special benefit to those who have been diagnosed with illness, 

injury, or disability. These individuals need adequate insurance coverage so that they can 

obtain timely and appropriate access to care of high quality, and the interim final rules 

will help them obtain such coverage and care. 

Cancer survivors, who have frequently been targets for rescissions of coverage, meet 

annual and lifetime limits at a disproportionate rate compared to other insured 

individuals, and experience significant obstacles to obtaining insurance after their initial 

cancer diagnosis, may benefit significantly from these rules. 

Our recommendation related to the interim final rules is technically outside the scope of 

the rules but is essential to realizing their potential benefits. We propose an aggressive 

and targeted public awareness and educational campaign that would provide consumers 

with detailed information about the protections that are included in the rules. In the 

preamble to the rules, the departments describe strategies that will assist consumers in 

optimizing the rules and their protections. For example, the regulations include advice to 

consumers to avoid the possibility of rescission and also alert individuals under age 19 to 

strategies to capitalize on the preexisting condition protections that will go into effect in 

advance of 2014. By offering this advice, the departments provide valuable information 

to consumers but also impliedly acknowledge the complexity of the rules. The 

information in the preamble to the regulations and additional guidance about the rules 

and their effects should be made available to consumers in a wide range of formats. 

CONTACT: 2446 39TH STREET NW · WASHINGTON, D.C. 20007 

Phone: 202-333-4041 · www.cancerleadership.org 
CONTACT: 2446 39TH STREET NW · WASHINGTON, D.C. 20007 

Phone: 202-333-4041 · www.cancerleadership.org 

Because those who will benefit from the rules are individuals who have already been 

diagnosed with an illness or disability, there is great promise in partnering with the 

patient advocacy and consumer organizations representing these individuals to undertake 

specially designed educational efforts that could be effectively disseminated to the likely 

beneficiaries of the rule. There are many valuable and efficient strategies for 

communicating with these special populations so that they are aware of provisions of the 

Affordable Care Act, as implemented by these rules, which might improve their access to 

insurance and health care. 

We appreciate the opportunity to comment on the interim final rules, which represent an 

appropriate balance of the needs of those with serious illnesses for access to high quality 

care and the necessity to restrain premiums for all who are currently insured. 

Sincerely, 

CANCER LEADERSHIP COUNCIL 

American Society for Radiation Oncology 

Bladder Cancer Advocacy Network 

C3: Colorectal Cancer Coalition 

Cancer Support Community 

The Children's Cause for Cancer Advocacy 

Coalition of Cancer Cooperative Groups 

International Myeloma Foundation 

The Leukemia & Lymphoma Society 

Lymphoma Research Foundation 

National Coalition for Cancer Survivorship 

National Lung Cancer Partnership 

National Patient Advocate Foundation 

Ovarian Cancer National Alliance 

Pancreatic Cancer Action Network 

Prevent Cancer Foundation 

Sarcoma Foundation of America 

Susan G. Komen for the Cure Advocacy Alliance 

Us TOO International Prostate Cancer Education and Support Network