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LEGAL PROCESSING DMSION 

PUBLICATION & REGULATIONS As of: August 25, 2010 

Received: August 10, 2010 pUBtlt Status: Posted

Posted: August 25, 2010 

Tracking No. 80b2d24a 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-2010-0010-0399 

Comment on FR Doc # 2010-14488 

Submitter Information 

Name: THOMAS PAUL MONTGOMERY 

Address: 

148 W MAIN STREET 

CORTLAND, OH, 44410 

Email: MONTYDC@AOL.COM 

Submitter's Representative: MYSELF 

Organization: INTEGRATIVE MEDICAL 

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General Comment 

See attached file(s) 

Attachments 

IRS-2010-0010-0399.1: Comment on FR Doc # 2010-14488 

https:llfdms.erulemaking.net/fdms-web-agency1component/submitter InfoCover Page?Call=... 8/25/2010 
August 10, 2010 

Office of Consumer Information and Insurance Oversight 

Department of Health and Human Services 

Attention: OCII0-9991-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 coven~d 

by PPACA, especially as of January 1,2014 when most ofthe 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 co payment 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 ofthe 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 subpopulation of excluded individuals will only add to costs, increase 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 mah~s 

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. 

Dr. Thomas P. Montgomery