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LEGAL PROCESSING DIVISION 


PUBLICATION" & REGULATIONS 


As of: August 20, 2010 BRANCH Received: August 09, 2010 

Status: Posted 

Posted: August 20, 2010 

Tracking No. 80b2cb7f 

PUBLIC 

SUBMISSION Comments Due: August 16, :2010 

Submission Type: Web 

Docket: IRS-2010-001O 

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-2010-001O-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-2010-001O-0196 


Comment on FR Doc # 2010-14488 


Submitter Information 

Name: Dr Ezekiel Bruce Brimhall DC 


Address: 


6610 E Main ST 

Farmington, NM, 87402 


Email: drzekechiro@yahoo.com 


Phone: 505-324-1111 


Fax: 505-324-8091 


Organization: Brimhall ChiropractiC 


General Comment 

08-09-2010 

Office of Consumer Information and Insurance Oversight 


Department of Health and Human Services 


Attention: OCIIO-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. 

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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 irl 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 anci 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 I 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 crei3te 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. 

Have enough honor and integrity to include chiropractic medicine into primary care, DC's have 

earned the right to treat the public the same as any other provider. Traditional medicine needs 

chiropractic help, the medical model is not complete, only an aliance by health insurance equality 

will ensure a preventative and well future for Americans. 

Ezekiel Brimhall, DC 

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