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SEP 8 Zii0 REC NPY 2-/8

LEGAL PROCESSING DIVISION

PUBLICATION & REGULATIONS As of: September 09, 2010
Bi Received: August 16, 2010
Pp Cc Status: Posted

Posted: September 09, 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-2010-0010-0913
Comment on FR Doc # 2010-14488

Submitter Information

Name: Glenn Czulada DC
Address:

1201 Wheeler Ave

Dunmore, PA, 18510
Email: glenncz@cs.com
Phone: 570-343-0400
Fax: 5703425877
Submitter's Representative: Glenn Czulada DC
Organization: Pennsylvania Chiropractic Association
Government Agency Type: Federal
Government Agency: HHS

General Comment

See attached file(s)

Attachments

IRS-2010-0010-0913.1: Comment on FR Doc # 2010-14488

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


August 16, 2010

Office of Consumer Information and Insurance Oversight
Department of Health and Human Services

Attention: OCIIO-9991~1FC

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

The Pennsylvania Chiropractic Association (PCA) represents the interest of over 3,500 licensed
Chiropractors and the 20 million people who reside in the commonwealth of Pennsylvania. On behalf
of those we represent, we are very concerned with “Grandfather” regulations which will determine
whether many of those insured will have access to Chiropractic services under their health care plans.
The non-discrimination provision is very important to our patients as it ensures that insurance plans
cannot discriminate against providers with respect to participation and coverage if the providers are
acting within their scope of practice.

As our country moves forward with the Patient Protection and Affordable Care Act (PPACA), we believe
that effective national health care reform will only achieve maximum benefit to the American public
when coupled with a broad transformational paradigm shift to a forward thinking and progressive
health system that focuses on comprehensive wellness care, healthful lifestyle choices and disease
prevention. We believe that such reform is urgent in the face of the looming provider shortage and
the unprecedented demands our aging population will place on the system.

All patients should have the right to choose and be reimbursed for all health care

services from doctors of Chiropractic without barriers and limitations that unfairly

restrict their freedom of choice. Arbitrary anti-competitive barriers only serve to drive
1335 NORTH up costs, limit patient choice and erode the quality and timeliness of care by steering
FRONT STREET _ Patients to more expensive hospital, surgical and pharmaceutical care.

HARRISBURG,
PENNSYLVANIA

in a properly reoriented health delivery system — one that places an appropriate
emphasis on wellness and preventive care ~ Chiropractic care would rightly be viewed
17102 as an essential element of any health plan seeking to provide an adequate range of basic

VOICE! health care services.

717.232.5762

FAX!
717.232.8368
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www.peanchiro.org


Pennsylvania Chiropractic Association
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

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To limit the growth in the cost of health care, it is vital that the Department of Health and Human
Services (HHS) encourages the utilization of cost effective health care, such as Chiropractic. Scientific
evidence powerfully supports the safety, effectiveness and cost savings of Chiropractic care. Studies
published in peer-reviewed scientific journals suggest that Chiropractic care for the treatment of low
back and neck pain is likely to achieve equal or better health outcomes at a lower cost then other
modes of treatment.

Chiropractic improves clinical outcomes while reducing total spending for common
neuromusculoskeletal conditions such as neck and back pain. A number of studies document that
lower back pain is one of the most common conditions for which individuals seek professional care. It
is estimated that between 40 to 85 percent of people with lower back pain consult health care
professionals. According to an article in the Journal of the American Medical Association, lower back
pain is the sixth most expensive health condition. It is important that policy makers look to reduce
societal costs for treatment of lower back pain by utilizing the particular cost effective expertise that
Chiropractic provides.

The PCA strongly recommends that HHS develop strict criteria for obtaining Grandfathered Status to
ensure the majority of Americans can benefit from the Non-Discrimination Provision and other
important provisions of the PPACA.

Sincerely,

Bn Qc.

é Glenn Czuféda, DC
President Chairman

PCA Board of Directors PCA Summit Relations Task Force