------------------------------------------------------------------------

Page 1 of2 ~[G--l J rL/ JJ.. -/0 

/!,UG 2 0 zmo 

GDIVlSION 

(LEGAL PR~S~GUL;\tIONS PUBLICATl BRANCH 


As of: August 20, 2010 

Received: August 09, 2010 PUBLIC Status: Posted

Posted: August 20, 2010 

Tracking No. 80b2c62c SUBMISSION Comments Due: August 16, :WlO 

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-2010-0010-0178 

Comment on FR Doc # 2010-14488 

Submitter Information 

Name: Richard R Clymore 

Address: 

2416 W. Shaw Avenue 


Suite 107 


Fresno, CA, 93711 


Email: rickcly@sbcglobal.net 

Phone: 559-439-4439 

Fax: 5594394448 

Government Agency Type: Federal 

Government Agency: AHRQ 

--------------------------------------------------------------------.... 


General Comment 

Group Health Plans and Health Insurance Coverage: 


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 plem. 


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 


https:llfdms.erulemaking.netlfdms-web-agency1componentisubmitterInfoCoverPage?Call=... 8/20/2010 
Page 20f2 

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 whE:ther 

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 arid 

delivering on its promises to retain their support. 

Thank you for the opportunity to comment on this regulation. 

Ricard R. Clymore, D.C. 

https;1Ifdms.erulemaking.netlfdms-web-agencyl componentlsubmitterInfoCoverPage ?Call =... 8/20/2010