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LEGAL PROCESSING DIVISION
PUBLICATION & REGULATIONS
BRANCH

As of: September 02, 2010

PUBLIC Status: Posted

Posted: September 9 2010
5 1
SUBMISSION Lr ora 6, 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-2010-0010-0616
Comment on FR Doc # 2010-14488

Submitter Information

Name: Anthony Jay Ebel
Address:

Crystal Lake, IL,
Email: drtony@pwchiros.com
Phone: 815-455-8213

Organization: Premier-Wellness Chiropractic
—

General Comment

See attached.

Attachments

IRS-2010-0010-0616.1: Comment on FR Doc # 2010-14488

https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=P... 9/2/2010


August 11, 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

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.

Rather than using the generic comments provided me via my state organization, I have decided
to give you my honest opinion on this topic. I see the positives and the negatives of our current
health care system in my job every day, caring for patients in my pediatric and family wellness
practice. My practice goes way beyond typical symptom-based care that our current system
subsists of, and instead provides greatly improved health outcomes, measures, and creates true
health and wellness in my patients lives. In summary, my practice makes incredible change, and
does so very affordably through empowerment and prevention, saving the system thousands and
thousands of dollars.

I strongly feel that if change is made, it must be uniform throughout. The “grandfather” clause
would generate massive confusion and frustration on all ends... providers, employers, members,
etc. Most patients are already confused greatly by their health insurance plans. In reality, even
the people (me and my staff) who work with them daily are confused.

If you are going to make change, you must do so across the board, You must make it clearly
defined, clearly understood, and clearly applicable to all persons.

When used appropriately, and for true health and wellness services that create health rather than
sickness, insurance can be incredible for patients... saving them so much money, rewarding
them for meeting good health measures, and so much more. When change is made, the “old”
must be deleted, discarded, destroyed. The system we have now works about as well as the
Chicago Cubs world series hopes, do not keep any of it around. Make the change, move forward
and let’s fix this thing.

My last tip... make the plans pay for true results, not symptoms. RCTs show nothing about
health outcomes, just symptoms... base our new system around something that actually creates
health, rather than simply trying to treat sickness. We deserve it, and there are people out there


who can deliver it. Chiropractors should lead that charge and work in unison with others who
can as well. It may sound crazy, but nothing could ever be as crazy as continuing to do what is
currently being done.

Thank you for the opportunity to comment on this regulation.

Anthony J. Ebel, DC, CACCP
Pediatric & Wellness Certified Chiropractor