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Dre. a
SEP 2 2010 REG \}pdi2-/6
LEGAL PROCESSING DIVISION

PUBLICATION & REGULATIONS
BRANCH As of: September 01, 2010

PUBLIC Status: Posted

Posted: September 01, 2010

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-2010-0010-0548
Comment on FR Doc # 2010-14488

Submitter Information

Name: Michael T. Walsh
Address:
1926 Northlake Parkway
Suite 201
Tucker, GA, 30084-7069
Email: mwalsh@gachiro.org
Phone: 770-723-1100
Fax: 770-723-1722
Submitter's Representative: Michael T. Walsh, CAE
Organization: Georgia Chiropractic Association, Inc.

General Comment

Please see the attached comment.

Attachments

IRS-2010-0010-0548.1: Comment on FR Doc # 2010-14488

https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=P... 9/1/2010



Georgia
Chiropractic
Association

August 11, 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 é
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 insuranc2 Coverage
Relating to Status as a Grandfathered Health Plan Under the Patient Protection and Affordable Care Act
(PPACA).

| 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.

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 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 of the employee population will remain ouside the
PPACA as of January 2014 based on the current rules. While | 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 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.

Sincerely,

o _—
Trchalh TF Water
Michael T. Walsh, CAE
Executive Director

1926 Northlake Parkway © Suite 201 Tucker, GA 30084-70609 wewegachiro.org Ps 700.723.1100 © Fs 710.723.1722