Comment on FR Doc # 2011-16834

I am 100% behind the data standardization of records process and would like to see this integrate with the administrative responsibilities at the plan sponsor level. In the identification of the covered individual record (i.e. 834 file INS02), there are codes for a spouse (code 01) and a life partner who acts like a spouse without a legal marriage commitment (code 53). At the employer and payroll level, this does not address members of Civil Unions (same or opposite sex), individuals in same-sex marriages, the children of each of the above or children required to be covered by NMSNs/QDROs (alternate recipients). While each of the above exceptions can be forced into another category such as alternate recipients under a NMSN can be coded as a child, this can easily lead to administrative failures for the plan sponsor. For example, the coding of an alternate recipient as a child in and of itself will not give the plan sponsor and COBRA Administrator enough information as to what to do at annual enrollment or in the event of a COBRA qualifying event. Finally it should be noted that the members of Civil Unions, domestic partners and same-sex spouses may or may not be dependents (per IRC 152) which would also impact their treatment on a payroll basis and at the time of a qualifying event. Bottom line: It would be extremely useful to add standard codes to the types of covered individuals noted above (along with their 152 status) so that all employer systems can move towards standardization. Currently everything an employer touches has different coding and content. jeffreyz@msn.com