Comment on FR Doc # 2010-08599

Senator Rockfeller has issued a report demonstrating concerns that private insurers are reclassifying administrative costs as medical costs in order to meet the required ratios. I do not believe that items such as health coaching should be considered medical costs. The regulations should strictly refer to the costs of actually treating patients. I would like to bring up an example from the University of California employee health plans. During 2007-2008 the university provided employees with gift cards for stores and restaurants if they completed an online health survey. The expenditure of premium money on such cards was a diversion of premium payments to department store profits and away from the health care employees are paying for. The labor union refused to participate in this program, but non-union employees were offered this plan. This is an example of a type of plan which should be excluded by law from reclassification as a medical expense, since employees' premium payments should not fund the purchase of department store gift cards in a rewards program.