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SEP 9

LEGAL PROCESSING DIVISION
PUBLICATION & REGULATIONS

BRANCH
[As of: September 09, 2010

Received: August 16, 2010
PUBLIC Set TS art, 201
SUBMISSION Comments Due: August 16, 2010

iSubmission Type: Web

REGU PHI2-/8

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-2010-0010-0929
Comment on FR Doc # 2010-14488

Submitter Information

Name: Lori L Bielinski
Address:
21400 International Blvd.
Suite 207
SeaTac, WA, 98198
Email: |bielinski@chirohealth.org
Phone: 206-878-6055
Fax: 206-878-8699
Organization: WA State Chiropractic Association

General Comment

Attached

Attachments

IRS-2010-0010-0929.1: Comment on FR Doc # 2010-14488

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



WSCA

WASHINGTON
§ T A T E
CHIROPRACTIC
ASSOCIATION

21400 International
Blvd.Ste.#207
SeaTac, WA 98198

206+°878 6055
1+800+824+4918
Fax 206°878-8699

www.chirohealth.org
wsca@chirohealth.org

August 16, 2010

Office of Consumer Information and Insurance Oversight
Department of Health and Human Services

Attention: OCIO-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.

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 (i.e. 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 J 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

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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.

for the opportunity to comment on this regulation.
Ce, ~

Lori L. Bielinski
WSCA Executive Director

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