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M~L}Lc· PR.OCEsSING DIVISION 

ATJON & REGULATIONS As of: August 25, 2010 PUBLIC Received: August 10, 2010 BRANCH Status: Posted 

Posted: August 25, 2010 

Tracking No. 80b2dOa4 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 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-2010-0010-0355 


Comment on FR Doc # 2010-14488 


Submitter Information 

Name: Michael Joseph Tancredi 


Address: 


600 Reed Rd 


Suite 101 


Broomall, PA, 19008 


Email: mtancredi@tancredichiropractic.com 


Phone: 610-353-9400 


Fax: 610-353-280 


Submitter's Representative: Michael Tancredi 


Organization: Tancredi Chiropractic and Physical Therapy 


General Comment 

August 10, 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 St21tus 

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. 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 t!1e 

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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 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 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 beginnin9 to 

make it work and delivering on its promises to retain their support. 

Thank you for the opportunity to comment on this regulation. 

Dr. Michael Tancredi 

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