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EG NGDIVISION —op-_ //@i//-/\ _
SUBLICRRION & REGULATIONS PLCS 4/216 AUS 5 200
BRANCH,

As of: August 05, 2010

PUBLIC Status: Posted

SUBMISSION Tracking No. S0b2ea4e.
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 Grandfathe~ed
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-2010-0010-0022
Comment on FR Doc # 2010-14488

Submitter Information

Name: Philip G Rahrig
Address:
6881 S Holly Circle
Ste. 108
Centennial, CO, 80112
Email: prahrig@galvanizeit.org
Phone: 720-554-0900
Fax: 720-554-0909
Submitter's Representative: Philip G Rahrig
Organization: American Galvanizers Association

General Comment

August 4, 2010

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

Room 445-G Hubert H. Humphrey Building

200 Independence Ave, SW

Washington, DC 20201

Re: OCIIO-991-IFC, The Interim Final Rules for Group Health Plans and Health Insurance
Coverage Relating to Status as a Grandfathered Health Plan Under the Patient Protection and
Affordable Care Act

On behalf of the American Galvanizers Association (AGA) members, I appreciate the opportunity
to comment on the Interim Final Rules regarding grandfathered health plans under the Patient

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Protection and Affordable Care Act. AGA is a section 501({c)(6) company membership organization
with more than 10,000 employees amongst the companies. Our members provide an invaluable
service to the public and private sector, applying zinc to steel to prevent corrosion, a preventable
event that costs our economy over $300 billion per year.

We are a small, tax-exempt organization with 9 employees and have the same obstacles to
obtaining good, affordable health insurance coverage confronting small businesses in genera’. We
do not have the resources or ability to self-insure as a means to control our health insurance
costs and benefits. We will greatly benefit from the expanded options for health insurance that
will be available beginning in 2014 through the Exchange.

However, because the benefits of the Exchange will not be realized until 2014, we will continue to
experience annual cost increases and lack of control over actual coverage until 2014. As such, the
grandfathering of our existing coverage is extremely important, especially prior to the
establishment of a working Exchange system.

We are greatly concerned that the grandfather provisions outlined in the Interim Final Rules are
too restrictive and will cause many tax-exempt organizations like us to lose the grandfathering
they and we expected. If forced to consider options of a non-grandfathered plan before we have
the benefit of an Exchange, we are concerned that we may be priced out of the market and may
even have to drop coverage - something we do not want to do and a bizarre result given the
intent of health care reform.

There are subsidies available for small employers to help offset the costs of providing insurance,
but these credits are very limited and start to be phased out if an employer has over 10
employees and is completely phased out if there are 25 or more employees. The credits are also
phased out for employers with even modest-sized compensation packages. So while these
subsidies do provide assistance for some small tax-exempt employers, their benefit is very
limited.

We are concerned that Interim Final Rules as currently drafted may force some organizations like
us to make the difficult and undesirable choice of canceling health care coverage if grandfather
status is revoked, especially before the Exchange is in place. This is a very real concern, and in
recent years significant modifications and cancellations have occurred due to rising health care
costs.

We would suggest for the transition period before the Exchange is established, that small and
medium sized employers be allowed to make cost saving changes to copayments and cost
sharing provided they do not reduce the per-employee amount they pay for insurance. This could
help us adjust and preserve coverage in anticipation of greater reform and options that will occur
beginning in 2014. We also suggest that small and medium sized employers be allowed to change
insurance carriers prior to 2014 and have their plans treated as grandfathers plans provided they
do not reduce the per-employee amount they pay for insurance. This would allow us to maintain
the level of coverage for employees, but reap the benefit of a less expensive plan prior to the
implementation of the Exchange,

Thank you for this opportunity to express our views on this important issue.

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