Response to 60-day comments

Appendix I: Comment & Response Summary
Limited Wraparound Coverage Reporting
(CMS- 10571/OMB control number 0938-NEW)
We sought comments on the content of the proposed collection form. We also sought comments
on the impact that an extension of the limited wraparound pilot program would have on the
number of employers/sponsors participating in the limited wraparound pilot program. In
addition, if HHS extends the limited wraparound pilot program, we sought comments on when
the limited wraparound pilot program should sunset, or whether the limited wraparound pilot
program should be made permanent. We received 13 comments.
Comment: Commenters did not express any concerns about the information collection and the
form. Two commenters had suggestions regarding two specific fields in the reporting form. They
suggested adding clarifications to the instructions for entering the plan identification number
when the plan sponsor is not subject to ERISA and is not assigned such a number. They also
suggested clarifying how to report the employer’s name when the plan covers multiple
employers.
Response: We made revisions to the form to address the comments, as detailed in Appendix II.
Comment: All Commenters expressed support for the limited wraparound pilot program and
recommended extending it. Some commenters shared positive experiences and interest in limited
wraparound coverage. All commenters stated that short time period for the pilot program has
resulted in limited participation in the program.
All commenters also stated that extending the program would allow more plan sponsors to create
limited wraparound programs, continue benefits of current programs and better evaluate the
impact of such programs. Commenters recommended that the program be made permanent or
extended for a minimum of 10 years.
Response: We thank the commenters for providing us with their perspectives on the program.
The Department of Treasury, the Department of Labor and the Department of Health and Human
Services are taking these recommendations under consideration.