12650 Riverside Drive Suite 206, North Hollywood, CA 91607 

800-452-CURE (2873) 

818-487-7455 telephone 818-487-7454 fax 

www.myeloma.org

August 27, 2010 

Office of Health Plan Standards and Compliance Assistance 

Employee Benefits Security Administration 

Room N-5653 

U.S. Department of Labor 

200 Constitution Avenue, NW 

Washington, DC 20210 

Attention: RIN 1210-AB43 

Office of Consumer Information and Insurance Oversight 

Department of Health and Human Services 

Attention: OCIIO-9994-IFC 

P.O. Box 8016 

Baltimore, MD 21244-1850 

Internal Revenue Service 

CC:PA:LPD:PR (REG-120399-10) 

Room 5205 

P.O. Box 7604 

Ben Franklin Station 

Washington, DC 20004 

RE: Draft comments on interim final rules on preexisting condition protections, rescissions, 

annual limits, and patient protections 

To Whom It May Concern: 

On behalf of the International Myeloma Foundation (IMF), the oldest and largest myeloma 

foundation dedicated to improving the quality of life of myeloma patients while working toward 

prevention and a cure, I am writing to submit comments on the interim final rules on preexisting 

condition protections, rescissions, annual limits, and patient protections. The IMF commends the 

Departments of Health and Human Services, Labor, and Treasury for the interim final rules as 

myeloma patients need adequate insurance coverage so that they can obtain timely and 

appropriate access to quality cancer care. 

Myeloma is a cancer in the bone marrow affecting production of red cells, white cells, and stem 

cells. It is also called “multiple myeloma” because multiple areas of bone marrow may be 

involved. Myeloma is the second most common blood cancer after lymphomas. Each year, 

approximately 20,000 Americans are diagnosed with myeloma and 10,000 lose their battle with 

this disease. At any one time there are over 100,000 myeloma patients undergoing treatment for 

their disease in the U.S. Although incidence of many of cancers are decreasing, myeloma cases 

are increasing in incidence. Once a disease of the elderly, it is now being found in increasing 

numbers in people under 65 and it is not uncommon to find patients in their thirties. Even while 

they live with the disease, myeloma patients can suffer debilitating fractures and other bone 
12650 Riverside Drive Suite 206, North Hollywood, CA 91607 

800-452-CURE (2873) 

818-487-7455 telephone 818-487-7454 fax 

www.myeloma.org

disorders, severe side effects of their treatment, and other problems that profoundly affect their 

quality of life, and significantly impact the cost of their health care. 

According to a National Survey of Households Affected by Cancer conducted USA Today; the 

Kaiser Family Foundation; and the Harvard School of Public Health; one in ten reached the limit 

of what their insurance would pay for cancer treatment; and one in twelve were turned away or 

unable to get a specific type of treatment because of insurance issues. Additionally, cancer can 

also be an issue that makes it difficult for people to get and keep insurance. This survey also 

found that one in ten say they were unable to buy health insurance because of having cancer, and 

6% say they lost their health insurance as a result of having cancer. 

These interim rules will go a long way, when fully implemented in 2014, to help myeloma 

patients obtain high quality cancer care without fear of forgoing treatment due to reaching 

coverage limits or worse losing or being unable to obtain insurance coverage entirely. We do, 

however, remain concerned that many myeloma patients could potentially forgo or postpone 

treatment due to reaching the annual limit of what their insurance covers prior to 2014. 

Additionally, IMF would like to propose that the agencies put together an aggressive and targeted 

public awareness and educational campaign which would provide consumers with detailed 

information about the protections that are included in the final rules. IMF has received many 

questions and requests for more information about the specific provisions related to health care 

reform. Due to the complexity of health reform and confusion of the general public about 

provisions in the new law, we remain concerned that myeloma patients will not know how these 

final rules could benefit them. We strongly advise the agencies to provide information to 

consumers in a wide range of formats. IMF stands ready to work with you to promote awareness 

of these important provisions, which will improve access to insurance and health care. 

We applaud your efforts and thank you for the opportunity to provide comments. Please do not 

hesitate to contact us should you have any questions or need more information. 

Sincerely, 

David Girard 

Executive Director