HHS: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections (HHS-OS-2010-0014)

The Food Marketing Institute (FMI) appreciates the opportunity to respond to the interim final regulation (IFR) implementing the prohibition of lifetime limits and restrictions on annual limits that apply to group health plans and health insurance coverage in the group market under provisions of the Patient Protection and Affordable Care Act1 (PPACA). In particular, FMI wishes to comment on the program to waive the restricted annual limits in certain circumstances, including in the case of limited benefit or "mini-med" plans, that the Department of Health and Human Services (HHS) intends to establish. FMI is submitting these comments to HHS with the understanding that they will be shared with the Department of Labor (DOL) and the Department of the Treasury (Treasury).