Comment on FR Doc # E9-22504

Document ID: IRS-2008-0103-0027
Document Type: Public Submission
Agency: Internal Revenue Service
Received Date: November 24 2009, at 12:00 AM Eastern Standard Time
Date Posted: November 25 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: October 7 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: January 5 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80a5e532
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Timothy Geithner Secretary U.S. Department of Treasury 1500 Pennsylvania Avenue NW Washington, DC 20220 RE: Title I of the Genetic Information Nondiscrimination Act (GINA) Dear Mr. Geithner: The Texas Association of Business is committed to the health and well being of our member’s employees whether they are multi-national corporations or small businesses. Most of these understand the importance of offering wellness programs as a way to maintain the health status of their employees as well as to restrain health care costs. The recent interim final regulation issued by the U.S. Department of Treasury, the U.S. Department of Health and Human Services and the U.S. Department of Labor seeking to implement Title I of the Genetic Information Nondiscrimination Act (GINA) will greatly reduce the effectiveness of these programs. The rule eliminates family medical history questions from a health risk assessment (HRA) and limits the ability to match individuals with appropriate wellness and disease management services. The result will be a rise in chronic conditions with employers experiencing increased health care costs and productivity losses. In the current economic climate, employers are looking for ways to keep health care costs down. Title I of GINA, though well intended, will seriously derail these efforts. Therefore, TAB joins with the U.S. Chamber and thousands of Texas businesses in respectfully requesting an immediate moratorium on the implementation and enforcement of these regulations. Respectfully, Bill Hammond CEO

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