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\{BGAL PROCESSING DIVISION
PUBLICATION & REGULATIONS
BRANCH As of: September 03, 2010

.
PUBLIC Statuse Posted,

reins iia
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-2010-0010-0707
Comment on FR Doc # 2010-14488

Submitter Information

Name: Paul N Morin
Address:

148 Sawyer Road

New Gloucester, ME, 04260
Email: pmorini @maine.rr.com
Phone: 207-926-5496

General Comment

See attached file(s)

Attachments

IRS-2010-0010-0707.1: Comment on FR Doc # 2010-14488

https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=P... 9/3/2010



August 12, 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

To Whom It May Concern:

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 feel 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.) will 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 leve) 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 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 dilute the potential
impact of the law.

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.

J appreciate the opportunity to comment on this regulation.

Sincerely,

Paul N. Morin