The Food Marketing Institute (FMI) appreciates the opportunity to respond to the interim final rules (IFRs) implementing the regulations for group health plans and health insurance coverage in the group market under provisions of the Patient Protection and Affordable Care Act1 (PPACA) regarding status as a grandfathered health plan. FMI is submitting these comments to the Department of Labor (DOL) with the understanding that they will be shared with the Department of Health and Human Services (HHS) and the Department of the Treasury (Treasury).

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