NAIFA-NYS Working Committee on Healthcare

Document ID: CMS-2011-0179-0005
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: December 08 2011, at 12:00 AM Eastern Standard Time
Date Posted: January 18 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: December 7 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: February 6 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 80f7e1c5
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Returning the premium for payment over the MLR should be done though Pre-Tax bank accounts and the funds directed into these accounts to be used for contributions, cobra payments, co-pays, deductibles and all IRS approved FSA expenses. If the funds go in pre-tax, they should be returned to the contributor on a pre-tax basis into these accounts. To suggest that an employer could use these funds in the future is potentially taking a terminated employees contribution and applying it towards a new hire's premium, which should be illegal. The employer would not have to allocate this in any way but back into this side account that each individual would have via payroll. This is fair and just and less confusing than what has been offered as a suggestion. Lastly, please read my comments on Essential Beneifts, which explains the idea of 6 different plans (A-F) so individuals do not have to purchase covered for EVERYTHING, but only what they believe they need and can afford. Also features a chart with financial incentives for Health lifestyles and Preventive Well Visits reducing premium. There is also a document on Safe Harbor and the most important, a document submitted at the Federal Plaza meeting in NYC on The Role of the Agent and Broker, with many issues addressed under the PPACA. Thank you, Gail HIller-Lee

Related Comments

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Total: 6
Gail Hiller-Lee
Public Submission    Posted: 12/19/2011     ID: CMS-2011-0179-0003

Feb 06,2012 11:59 PM ET
NAIFA-NYS Working Committee on Healthcare
Public Submission    Posted: 01/18/2012     ID: CMS-2011-0179-0005

Feb 06,2012 11:59 PM ET
UnitedHealth Group
Public Submission    Posted: 01/25/2012     ID: CMS-2011-0179-0047

Feb 06,2012 11:59 PM ET
Blue Cross Blue Shield Association
Public Submission    Posted: 01/25/2012     ID: CMS-2011-0179-0048

Feb 06,2012 11:59 PM ET
America's Health Insurance Plans
Public Submission    Posted: 02/07/2012     ID: CMS-2011-0179-0050

Feb 06,2012 11:59 PM ET