Comment on FR Doc # 2010-18043

The Community Service Society (CSS) of New York writes to comment on the interim final rules implementing the Patient Protection and Affordable Care Act (ACA) provisions regarding preexisting conditions, lifetime and annual limits on benefits, rescissions, and patient protections. CSS is a 160 year-old organization that seeks to address the root causes of economic disparity. The organization’s mission is to promote policies that advance the economic security of working low-and moderate-income New Yorkers by bringing their perspectives to the policy conversation. We work to expand access to affordable, quality care for all New Yorkers, through advocacy and consumer assistance. Overall, we commend the Departments for the progress these interim final rules make in implementing the consumer protections of the ACA. However, we have concerns regarding four sections of the new regulations: the rules prohibiting preexisting conditions exclusions; the rules restricting annual limits; the rules limiting rescissions; and the rules regarding coverage of emergency services (patient protections). Please see attached document for details.