Page 1 of 1

o

cea
3 eulC

LEGAL PROCESSIN

PUBLICATION & REGULON,
: GUL

han BRANCH *TONS.

REG |VUIa-10

on

[As of: September oe ono
Received: August 16, 201

PUBLIC siti oy 210

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-2010-0010-0920
Comment on FR Doc # 2010-14488

Submitter Information

Name: William H Daley
Address:
3518 Edumuds St
Seattle, WA, 98118
Email: bill@nwfco.org
Phone: 360-970-1639
Submitter's Representative: William Daley
Organization: Health Rights Organizingh Project

General Comment

Thank you for the chance to comment. Please see attached.

Attachments

IRS-2010-0010-0920.1: Comment on FR Doc # 2010-14488

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


Health Rights
Organizing Project

Se ee ere

From: Health Rights Organizing Project
Community Organizations in Action
The Northwest Federation of Community Organizations

To: Department of the Treasury -- Internal Revenue Service
Department of Labor -- Employee Benefits Security Administration
Department of Health and Human Services

Re: 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 JD: HHS-OS-2010-0015-0001

Docket ID HHS-05-2010-0015

Thank you for the opportunity to comment on these proposed rules.

Because Grandfathered Health Plans will not have to meet many of the regulatory
protections required of other plans under the Patient Protection and Affordable Care Act,
it is critical that consumers be given a clear understanding of what their status is under
these plans. In order to give this information the widest possible exposure, we
recommend that your rules do the following:

e Establish a registry of all grandfathered plans.

¢ Maintain and make available to the public consumer-oriented information
detailing federally-based and state-based consumer protections that are available
for those with grandfathered plans.

For individuals who continue to receive their health care coverage through Grandfathered
Health Plans, it is important that these consumers have a clear understanding of their
status and rights. We recommend that the rules:

e Require insurance companies and employers to notify policyholders that their
coverage is grandfathered with an explanation of what health reform benefits do
not apply because of the plan’s grandfathered status.

The Health Rights Organizing Project - A joint project between the Northwest Federation of Community
Organizations
and the Center for Community Change
3518 S. Edmunds, Seattle, WA 98118 (206)568-5400 www.nwfco.org
1536 U Street, NW Washington, DC 20009 (202) 339-9359 | www.communitychange.org


Health Rights
Organizing Project ...__

weno

Unless there are clear and well enforced limits on what changes Grandfathered Health
Plans can make in policies, consumers will be trapped in plans that decline in value to
them, leaving many underinsured. We urge that the rules:

e Establish clear criteria for determining when changes to health plans are
significant enough to terminate grandfather status.

Because we regard it as problematic that Grandfathered Health Plans are not required to
comply with the same consumer protections and insurance regulation standards applied to
other plans under the Patient Protection and Affordable Care Act, we recommend

¢ That these rules not interfere with the right of states to impose added consumer
protection and insurance regulation as their laws allow.

Contact our organizations via:

Northwest Federation of Community Organizations
3518 Edmunds Street

Seattle, Washington 98118

(206) 568-5400

The Health Rights Organizing Project - A joint project between the Northwest Federation of Community
Organizations
and the Center for Community Change
3518 S. Edmunds, Seattle, WA 98118 (206)568-5400 www.nwfco.org
1536 U Street, NW Washington, DC 20009 (202) 339-9359 1 www.communitychange.org