;.­ ~~--;.."'~; 

7IZi chUdireds cause 

cancer advocacy 

Board of Directors 

Lynn Bayard, Chair 

Ellen Coleman 

Elizabeth Goss 

Maureen Lilly 

Jennifer Niedermeyer 

Leonard Rosen 

Susan Scherr 

Steven Shak 

Beth Silber 

Robyn Sterling 

John Stewart 

Susan L. Weiner 

Professional Advis01Y Board 

David Poplack, MD, Chai!!J1an,.. , - - Baylor College of Medicine 

Robert Arceci, MD, PhD 


Johns Hopkins Medical Center 


Mark Bernstein, MD 


Sl Justine Hospital, Montreal . 


Archie Sleyer, MD 


Robert Castleberry, MD 


U. of Alabama at Birmingham 

Henry Friedman, MD 

Duke University Medical Center 

Daniel M. Green, MD 

Roswell Park Cancer Institute 

Mark D. Krieger, MD 

University of Southern California 

Michael Link, MD 

Stanford University Medical Center 

Sharon Murphy, MD 

Institute of Medicine 

Gregory Rearnan, MD 

Chairman, Children's Oncology Group 

Charles Sklar, MD 

Memorial Sloan.Kettering Cancer Center 

Sta.ff 

--=-~~i~~::t(5r'·-- .. ---­

Rebecca Gurvich 

Development Manager 

Jess Reamy 

Program Associate 

August 11, 2010 " 

Office of Consumer Information and Insurance Oversight 


Department of Health and Human Services 


Attention: OCII0-4150-IFC 


PO Box 8016 


Baltimore, MD 21244-1850 


RE: OCIIO- 4150-IFC 

-~Dear.SirworMadam:.;;.;:.-- ....-.-. - -- --- ­

The Children'S Cause for Cancer Advocacy respectfully submits 

these comments regarding the Interim Final Rules for Group Health 

Plans and Health Insurance Issuers Related to Dependent Coverage 

of Children to Age 26. This provision of the Patient Protection and 

Affordable Care Act is important to young adult cancer survivors who 

all too often find themselves with limited or no options for health 

insurance coverage. Therefore, we appreciate the Administration's • 

work to develop rational rules to implement the provisions of the new .. 

law related to coverage of dependents to age 26, as well as your 

efforts to encourage voluntary action by insurers to offer dependent 

coverage in advance of the effective date of September 23, 2010. 

Cancer strikes an estimated 12,500 children under age 15 each 

year. The good news is that, due to significant progress in the past 

30 years, many children do survive. However, two thirds of the 

270,000 childhood cancer survivors among us will experience at 

least one serious late health effect caused by their disease and the 

toxic treatments they endured. As a result, their quality of life is 

-~impaired7"'afld1:heidife'span"is-stlOrtenetf:-'- .,--- -- ~ . .~ 

Clearly, childhood cancer survivors have significant and unique 

health care needs. For many young adults who are survivors, the 

option of securing coverage through a parent's health insurance plan 

is critical to their ability to receive affordable, appropriate follow up 

care . 

. Straightforward implementation of the Dependent Care Coverage 


provision, as outlined by the Interim Final Rules, will assist these 


individuals as they seek to improve their health care coverage under 


a parent's plan beginning September 23, 2010. We appreciate that 


the rules: 

• 	 Clarify that eligibility for coverage of a dependent under age 26 depe~ds s~lely 

on the relationship between the child and participant in the plan, not financial 


dependency or other qualifiers currently used in the marketplace; 


• 	 Require plans to provide young adult children with the same benefits provided to 


similarly situated individuals at the same price, thereby promoting access to 


quality, affordable coverage; 


• 	 Require that insurers and employers notify young adults of their continued 


eligibility and provide them 30 days to take advantage of the coverage 


opportunity, allowing adequate time to enroll; and 


• 	 Allow a parent to switch their benefit package to another available option so that 

the child has access to the most appropriate benefit package for which they are 

eligible. 

Ag~in,_\ye.believe .thatthis opportunity for.young.adultsurvivors of. childhood" cancer to~~ ----­

secure quality health benefits is significant. Implementation of the new law in a manner 

that gives those individuals who are eligible a fair chance to access this coverage will 

make the provision meaningful and help more childhood cancer survivors secure 

appropriate care that meets their needs. If we could recommend one improvement in 

the rules, it would be to address the issue of providing adequate notification when 

dependent care coverage will be terminated to allow for transition to a new plan. 

We appreciate your hard work, and will monitor the impact of this new law with great 

interest and concern for how it affects the health care needs of childhood cancer 

survivors. Thank you for the opportunity to share our perspective. 

" Sincerely, 

I

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