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LEGAL PROCESSINGDIVISION 


PUBLICATION & REGULATIONS 


BRANCH 
 As of: August 20, 2010 

Received: August 09, 2010 PUBLIC Status: Posted

Posted: August 20, 2010 

Tracking No. 80b2c673 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-201O-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-2010-0010-0207 

Comment on FR Doc # 2010-14488 

Submitter Information 

Name: jason a lazaroff 

Address: 

phila, PA, 


Submitter's Representative: Dr. Jason Lazaroff 


Organization: Maxcare 


General Comment 

8/9/10 

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. 

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. 

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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 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 beginning to make it work and 

delivering on its promises to retain their support. 

Thank you for the opportunity to comment on this regulation. 

Dr. Jason Lazaroff 

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