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RE G-HS4I2-10

Pe SEP 07 2919

As of: September 07, 2010

PUBLIC Status: Posted

posted: Septere Or 2010
S U B M I SSIO N 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-2010-0010-0779
Comment on FR Doc # 2010-14488

Submitter Information

Name: Richard G. Walker
Address:

1827 Walden Office Square

Suite 550

Schaumburg, IL, 60173
Email: mknight@aamanet.org
Phone: 847-303-5859
Fax: 847-303-5774
Organization: American Architectural Manufacturers Association
— a

General Comment

See attached file(s)

Attachments

IRS-2010-0010-0779.1: Comment on FR Doc # 2010-14488

http://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=Pr... 9/7/2010


2] American
Architectural

M Al Manufacturers
Association

August 13, 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-LFC, 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 Architectural Manufacturers Association (AAMA), we appreciate the opportunity
to comment on the Interim Final Rules regarding grandfathered health plans under the Patient Protection and
Affordable Care Act. AAMA is a section 501(c)(6) trade association representing window, door, and skylight
manufacturers across the United States. As our membership is closely tied to the home construction and
renovation industries, they have been among the hardest hit industries resulting from the enduring econornic
crisis. Throughout this recession, our membership rolls have also declined, resulting in an unprecedentec.
reduction in our staffing level.

We currently employ 17 people and provide health care coverage to only the 15 individuals who work on a
full-time basis. As our workforce is considered small, we are not privy to lower-cost plans that are tailored to
benefit larger companies. As such, we pay higher premiums for the same or less coverage. In order to
continue to provide health care coverage, in 2009 we were forced to make a change to our coverage that
significantly increased the deductible each participant must pay.

Although, the current cost of coverage is a huge financial burden, we are dedicated to providing our employees
with sufficient, reliable coverage for themselves and their families.

Unfortunately, any proposed benefits of the Exchange will not be realized until its 2014 implementation. In the
interim, it will be imperative for our organization to retain the ability to negotiate policies that will benefit our
staff and their families while keeping our costs at a rate that will sustain our association through the current
economic downturn.

The Interim Final Rule unfairly ties the hands of small to mid-size employers by revoking grandfather status if
any necessary policy/premium adjustments are negotiated during the pre-implementation of the Exchange
Program.

At this time, we have no way of knowing what the insurance industry response to recent changes will be, or

how it will impact our policies for the next 36 months. We do, however, want to assure our staff that we will
continue to ensure that they and their families will maintain the benefit of quality health care coverage.

continued

1827 Waiden Office Sq. * Suite 550 + Schaumburg, IL 60173-4268 * 847 / 303-5664 * Fax 847 / 303-5774


Office of Consumer information and Ins
Department af Heals and Human Servic
Room 445-G Hubert Ho Humphrey Building
200 Independence Ave. SW
Washington, DC 20201

ise Oversight

Re: OCUO-991-6FC, the Futerim Fisai Rules for Group Health Plans and Health Insurance Coverage
Relating to Status as a Grandfathered Health Plan Under the Patient Protection and Affordable Cere
Aet

As such, we respectfully request a modification to the interim final rule which will allow for grandfathering
the health care plans of small to mid-size tax-exempt organizations, regardless of coverage/policy adjustments
made during the pre-implementation period of the Exchange program.

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

Veta

Richard G. Walker
President and CEO