Many comment letters were submitted with medical or personal health information. To preserve the substance of the comment letters, the Department did not redact the medical or personal health information, but instead removed personally identifiable information (such as name, address and other contact information) from these letters to protect the privacy of commenters and other named individuals. These comment letters are designated as "Name Withheld" on this web page. If you submitted one of these comment letters and would like your identity disclosed on this web page, you may make a request for its inclusion by contacting DOL at EBSA-Webmaster@dol.gov. "Name Withheld" comment letters are distinct from comment letters designated as "Anonymous," which generally were submitted by the commenter without identifying information.
Extension of Applicability Date
Other Letters on File with EBSA
- Letter from American Benefits Council, American Council of Life Insurers, America’s Health Insurance Plans, Cigna, The ERISA Industry Committee, Financial Services Roundtable, Sun Life Financial, Unum Group, Inc., to Gary Cohn, Director, National Economic Council, The White House, Andrew P. Bremberg, Director, Domestic Policy Council, The White House, Edward C. Hugler, Acting Secretary, U.S. Department of Labor (March 14, 2017)
- Letter from Matthew Eyles, Executive Vice President, Policy and Regulatory Affairs, America’s Health Insurance Plans, to The Honorable R. Alexander Acosta, Secretary of Labor, U.S. Department of Labor (May 10, 2017)
- Email from Michael Kreps, Principal, Groom Law Group, to John J. Canary and Jeffrey J. Turner, Office of Regulations and Interpretations, Employee Benefits Security Administration (July 13, 2017)
- Letter from Governor Dirk Kempthorne, President & Chief Executive Officer, American Council of Life Insurers, to The Honorable Alexander Acosta, Secretary, U.S. Department of Labor (July 17, 2017)
- Letter from David P. Roe, M.D., Member of Congress (and 27 other Members of Congress), to R. Alexander Acosta, Secretary, U.S. Department of Labor (July 28, 2017)
- Name Withheld
October 12, 2017 - Mark DeBofsky
October 18, 2017 - D. Seth Holliday
October 18, 2017 - Mel Crawford
October 25, 2017 - Richard Johnston
October 18, 2017 - Jonathan M. Feigenbaum
October 18, 2017 - Michael E. Quiat
October 18, 2017 - Kevin Koelbel
October 18, 2017 - CJ Henry Law Firm, PLLC
Claudeth J. Henry
October 19, 2017 - Robert Armand Perez Sr.
October 19, 2017 - Patrick Mause
October 19, 2017 - Tybe A. Brett
October 20, 2017 - Scott B. Elkind
October 20, 2017 - Cassie Springer Ayeni
October 20, 2017 - Michael S. Krieger
October 20, 2017 - John J. Spiegel
October 24, 2017 - Tony Merry
October 23, 2017 - Robert June
October 23, 2017 - Sarah Demers
October 24, 2017 - Brian H. Kim
October 24, 2017 - Frankel & Newfield, P.C.
Jason Newfield
October 18, 2017 - Mala M. Rafik
October 24, 2017 - Alicia Paulino-Grisham
October 24, 2017 - Shawn McDermott
October 24, 2017 - Matthew Davis
October 24, 2017 - Bridget O’Ryan
October 24, 2017 - Brad Wojno
October 24, 2017 - Carrie Feit
October 24, 2017 - David Martin
October 24, 2017 - David Bryant
October 25, 2017 - Kirk L. Wogelmuth
October 24, 2017 - Scott M. Riemer
October 24, 2017 - Paul Sullivan
October 24, 2017 - Michael Bartolic
October 24, 2017 - Bernard A. Guerrini
October 24, 2017 - Amar Raval
October 24, 2017 - Paulette Adams Bradham
October 24, 2017 - M. Katherine Sullivan
October 24, 2017 - Ron Dean
October 24, 2017 - Joseph P. McDonald
October 24, 2017 - Alan H. Casper
October 24, 2017 - Susan L. Horner
October 24, 2017 - Corinne Chandler
October 25, 2017 - Michelle Roberts Bartolic
October 25, 2017 - Jennifer Danish
October 25, 2017 - Beth Davis Perez
October 25, 2017 - Tracy Collins
October 25, 2017 - Elizabeth K. Green
October 25, 2017 - Bob Keehn
October 25, 2017 - Nancy L. Cavey
October 25, 2017 - Brent Dorian Brehm
October 25, 2017 - Andrew Kantor
October 25, 2017 - Mitchell Hefter
October 25, 2017 - Jeffrey S. Warncke
October 25, 2017 - Jeffrey S. Warncke
October 25, 2017 - John Walker Wood
October 25, 2017 - Thomas O. Sinclair
October 25, 2017 - Jim Keenley
October 25, 2017 - Glenn R. Kantor
October 25, 2017 - Cari M. Schwartz
October 25, 2017 - Richard Carter
October 25, 2017 - Bonny Rafel
October 25, 2017 - Mason Waring
October 25, 2017 - Samantha Lutt
October 25, 2017 - Sally Mermelstein
October 25, 2017 - P. Randall Noah
October 25, 2017 - Julian Baum
October 25, 2017 - Douglas Robinson
October 25, 2017 - Daniel Feinberg
October 25, 2017 - William Reynolds
October 25, 2017 - Thomas Hoff
October 25, 2017 - John Stennett
October 26, 2017 - Essex Richards, P.A.
Edward G. Connette, Norris A. Adams, II, Caitlin H. Walton
October 25, 2017 - Katherine L. MacKinnon
October 25, 2017 - Stephen R. Bruce
October 25, 2017 - Rhonda Harris Buckner
October 25, 2017 - DarrasLaw
Frank N. Darras, Susan B. Grabarsky, Phillip S. Bather, Heather Gardner
October 25, 2017 - Nolan, Thompson & Leighton, PLC
Robert J. Leighton, Jr.
October 26, 2017
- AARP
David Certner
October 26, 2017 - Robert J. Rosati
October 26, 2017 - John P. Murray
October 26, 2017 - Lisa Serebin
October 26, 2017 - Brian S. King
October 26, 2017 - Jeremy L. Bordelon
October 26, 2017 - Julia Campins
October 26, 2017 - ReedGroup
Megan Holstein
October 26, 2017 - Peter Sessions
October 26, 2017 - Benjamin Glass
October 26, 2017 - Socorra DeCelle
October 27, 2017 - Sarah Burns
October 27, 2017 - Phillip G. Fairbanks
October 27, 2017 - U.S. Chamber of Commerce
Randal Johnson, Aliya Wong
October 27, 2017 - UnitedHealthcare
Gavin G. Galimi
October 27, 2017 - Unum Group
Gregory J. Breter
October 27, 2017 - Sun Life Financial
Debra A. Conner
October 27, 2017 - Cigna Corporation
David Schwartz
October 27, 2017 - National Business Group on Health
Brian Marcotte
October 27, 2017 - American Council of Life Insurers
Steven Clayburn
October 27, 2017 - Michael A. McKuin
October 27, 2017 - Scott E. Davis
October 27, 2017 - American Federation of Labor and Congress of Industrial Organizations (AFL-CIO)
Shaun C. O’Brien
October 27, 2017 - National Coordinating Committee for Multiemployer Plans
Michael D. Scott
October 27, 2017 - Michael James Quirk
October 27, 2017 - American Benefits Council, American Council of Life Insurers, America’s Health Plans, Cigna, The ERISA Industry Committee, Financial Services Roundtable, The Guardian Life Insurance Company of America, The Hartford, MetLife, Mutual of Omaha, National Association of Insurance and Financial Advisors, National Business Group on Health, NFL Player Disability and Neurocognitive Benefit Plan, Sun Life Financial, Unum Group, Inc., U.S. Chamber of Commerce
October 27, 2017 - America’s Health Insurance Plans
Matthew Eyles
October 27, 2017 - Ralph E. Wiser
October 27, 2017 - David M. Lilienstein
October 17, 2017 - NFL Player Disability & Neurocognitive Benefit Plan
Alvaro I. Anillo
October 25, 2017 - W. Miller
November 6, 2017 - Carl Perkins
November 10, 2017 - Anonymous
November 21, 2017 - Kirk L. Woglemuth
December 4, 2017 - Scott B. Elkind
December 4, 2017 - Roberts Bartolic LLP
Michelle Roberts Bartolic
December 4, 2017 - Howard L. Bolter
December 6, 2017 - D. Seth Holliday
December 6, 2017 - Mark DeBofsky
December 6, 2017 - Feinberg, Jackson, Worthman & Wasow LLP
Dan Feinberg
December 6, 2017 - David P. Martin
December 6, 2017 - Steven P. Krafchick
December 6, 2017 - Steven P. Krafchick
December 6, 2017 - Scott M. Riemer
December 6, 2017 - Cari M. Schwartz
December 7, 2017 - James P. Keenley
December 7, 2017 - Bonny G. Rafel
December 7, 2017 - Berg Plummer Johnson & Raval
Amar Raval
December 7, 2017 - Corrine Chandler
December 7, 2017 - J. David Oswalt
December 7, 2017 - Beth D. Perez
December 7, 2017 - Mitchell O. Hefter
December 7, 2017 - Glenn R. Kantor
December 7, 2017 - Massachusetts Employment Lawyers Association
Jonathan M. Feigenbaum
December 7, 2017 - Brian H. Kim
December 7, 2017 - Alan H. Casper
December 7, 2017 - Bob Keehn
December 7, 2017 - Campins Benham-Baker, PC
Julia Campins
December 8, 2017 - Tybe A. Brett
December 8, 2017 - Kevin Koelbel
December 8, 2017 - Mel Crawford
December 8, 2017 - John J. Spiegel
December 8, 2017
- Robert J. Rosati
December 8, 2017 - Sally Mermelstein
December 8, 2017 - Michael A. McKuin
December 8, 2017 - Randy Noah
December 8, 2017 - Ron Dean
December 8, 2017 - Stephen R. Bruce
December 8, 2017 - Robert Armand Perez Sr.
December 8, 2017 - Alan E. Kassan
December 8, 2017 - Elizabeth K. Green
December 8, 2017 - Philip G. Fairbanks
December 9, 2017 - Law Office of Patrick Mause, PLLC
December 10, 2017 - David Lilienstein
December 11, 2017 - Jeremy L. Bordelon
December 9, 2017 - Mason Waring
December 9, 2017 - Alicia Paulino-Grisham
December 10, 2017 - Tony Merry
December 11, 2017 - William Reynolds
December 11, 2017 - M. Katherine Sullivan
December 11, 2017 - M. Clayborn Williams
December 11, 2017 - Bernard A. Guerrini
December 11, 2017 - Katherine L. MacKinnon
December 11, 2017 - Uscher, Quiat, Uscher & Russo A Professional Corporation
Michael E. Quiat
December 11, 2017 - Matthew R. Davis
December 11, 2017 - Sarah Demers
December 11, 2017 - UnitedHealthcare
Gavin Galimi
December 11, 2017 - Martina B. Sherman
December 11, 2017 - Fusco, Brandenstein & Rada, P.C.
Aba Heiman
December 11, 2017 - Essex Richards, P.A.
Edward G. Connette, Norris A. Adams, II, Caitlin H. Walton
December 11, 2017 - Robert B. June
December 11, 2017 - Cigna
David Schwartz
December 11, 2017 - National Business Group on Health
Brian Marcotte
December 11, 2017 - U.S. Chamber of Commerce
Randel K. Johnson, Aliya Wong
December 11, 2017 - ReedGroup
Megan Holstein
December 11, 2017 - The NFL Player Disability & Neurocognitive Benefit Plan
Douglas W. Ell, Alvaro I. Anillo
December 11, 2017 - Bridget O’Ryan
December 11, 2017 - Thomas O. Sinclair
December 11, 2017 - Kantor & Kantor, LLP
Lisa S. Kantor
December 11, 2017 - Peter S. Sessions
December 11, 2017 - Joseph P. McDonald
December 11, 2017 - Andrew M. Kantor
December 11, 2017 - Robert Lessin
December 11, 2017 - Unum Group
Gregory J. Breter
December 11, 2017 - Mala M. Rafik, Sarah E. Burns, Socorra A. DeCelle
December 11, 2017 - AARP
David Certner
December 11, 2017 - John Walker Wood
December 11, 2017 - The American Council of Life Insurers
Steven Clayburn
December 11, 2017 - America’s Health Insurance Plans
Matthew Eyles
December 11, 2017 - John P. Murray
December 11, 2017 - Sun Life Financial
Debra Conner
December 11, 2017 - Charles March
December 11, 2017 - American Benefits Council
Kathryn Wilber
December 11, 2017 - Julian M. Baum
December 11, 2017 - Terrence J. Coleman
December 11, 2017 - John P. Stennett (Jack)
December 11, 2017 - Miller Monson Peshel Polacek & Hoshaw
Susan L. Horner
December 11, 2017 - Michael P. Williamson
December 11, 2017 - Jeffrey C. Metzger, A Law Corporation
December 11, 2017 - Michael James Quirk
December 11, 2017 - Jennifer Danish
December 11, 2017 - Paul Sullivan
December 11, 2017 - Richard Johnston
December 11, 2017 - Lisa Serebin
December 11, 2017 - DarrasLaw
December 11, 2017 - Brian S. King
December 11, 2017 - Disability Rights Education and Defense Fund
Silvia Yee
December 11, 2017 - Frankel & Newfield, P.C.
December 11, 2017 - The Grey Law Firm PC
Rebecca Grey
December 11, 2017
Final Regulation
Historical Information
The comments will be made available in alternative format to persons with disabilities upon request.
- Jeffrey Delott
November 19, 2015 - Name Withheld
November 19, 2015 - Name Withheld
November 22, 2015 - Name Withheld
November 29, 2015 - Miriam DiNicholas
November 30, 2015 - Name Withheld
December 08, 2016 - Cindy Siebrecht
December 16, 2015 - Name Withheld
December 17, 2015 - Mark D. DeBofsky
December 17, 2015 - Name Withheld
December 28, 2015 - Amar Raval
December 30, 2015 - L. Stirling
December 31, 2015 - Name Withheld
December 31, 2015 - Name Withheld
December 31, 2015 - Name Withheld
December 31, 2015 - Anonymous
December 31, 2015 - Connie Faast
December 31, 2015 - Name Withheld
December 31, 2015 - Anonymous
December 31, 2015 - Anonymous
January 01, 2016 - Marilyn Lemmon
January 01, 2016 - Name Withheld
January 02, 2016 - Name Withheld
January 02, 2016 - Name Withheld
January 02, 0106 - Nancy Wood
January 03, 2016 - William T. Allison
January 03, 2016 - Name Withheld
January 03, 2016 - Patrick W. Mause
January 11, 2016 - Stuart Koford
January 11, 2016 - Mary Ellen Lister
January 11, 2016 - Barry Kirschner
January 11, 2016 - Cheryl House
January 12, 2016 - Denise Boehner
January 12, 2016 - Patrick Derkacz
January 13, 2016 - Name Withheld
January 10, 2016 - D. Seth Holliday
January 12, 2016 - Michelle L. Roberts
January 14, 2016 - Kirk L. Wolgemuth
January 14, 2016 - Anonymous
January 14, 2016 - Bonny G. Rafel
January 14, 2016 - Name Withheld
January 14, 2016 - Name Withheld
January 14, 2016 - Name Withheld
January 15, 2016 - Tybe Ann Brett
January 15, 2016 - Name Withheld
January 15, 2016 - Name Withheld
January 16, 2016 - David P. Martin
January 15, 2016 - American Federation of State, County and Municipal Employee
Steve Kreisberg
January 15, 2016 - Kevin Koelbel
January 15, 2016 - DRI - The Voice of the Defense Bar
Laura E. Proctor
January 15, 2016 - Anonymous
January 16, 2016 - Phil Fairbanks
January 16, 2016 - Name Withheld
January 16, 2016 - Tony C. Merry
January 16, 2016 - Anonymous
January 17, 2016 - Dan Hall
January 17, 2016
- Name Withheld
January 17, 2016 - Hudson T. Ellis
January 18, 2016 - Name Withheld
January 18, 2016 - Eric L. Buchanan
January 18, 2016 - Name Withheld
January 18, 2016 - Joseph P. McDonald
January 18, 2016 - Katherine L. MacKinnon
January 18, 2016 - Feinberg, Jackson, Worthman & Wasow LLP
Dan Feinberg
January 18, 2016 - Jennifer M. Danish
January 18, 2016 - MEadvocacy.org
Colleen Steckel Joni Comstock
January 18, 2016 - Robert B. June
January 18, 2016 - Health Law Advocates
Matthew Selig
January 19, 2016 - United Cerebral Palsy
Jennifer McCue
January 19, 2016 - Essex Richards
Edward G. Connette
Norris A. Adams, II
Caitlin H. Walton
January 19, 2016 - Name Withheld
January 19, 2016 - Name Withheld
January 19, 2016 - Massachusetts Employment Lawyers Association
Jonathan M. Feigenbaum
January 19, 2016 - Sara Kaplan-Khodorovsky
January 19, 2016 - AARP
David Certner
January 19, 2016 - Unum Group
Gregory J. Breter
January 19, 2016 - Name Withheld
January 18, 2016 - Denise Lopez-Majano
January 18, 2016 - Anonymous
January 18, 2016 - Name Withheld
January 18, 2016 - Name Withheld
January 19, 2016 - Sally Mermelstein
January 18, 2016 - Name Withheld
January 18, 2016 - Anonymous
January 18, 2016 - Richard Johnston
January 19, 2016 - Yonatan Ben-Shalom
David C. Stapleton
January 19, 2016 - Scott M. Reimer
January 19, 2016 - Gisele M. Nadeau
January 19, 2016 - Brian H. Kim
January 19, 2016 - Bridget O'Ryan
January 19, 2016 - Stephen R. Bruce
January 19, 2016 - The NFL Player Disability & Neurocognitive Benefit Plan
Douglas W. Ell
Alvaro I. Anillo
January 19, 2016 - Pension Rights Center
Jane T. Smith
January 19, 2016 - Plan Sponsor Council of America
Richard P. McHugh
January 19, 2016 - Howard L. Bolter
January 19, 2016 - Kantor & Kantor, LLP
Glenn Kantor
January 19, 2016 - Marcus A. Castillo
January 19, 2016 - United Policyholders
Glenn R. Kantor
January 19, 2016 - John V. Tucker
January 19, 2016 - The American Federation of Labor and Congress of Industrial States
Karin S. Feldman
January 19, 2016 - National Multiple Sclerosis Society
Scott M. Riemer
January 19, 2016 - R. Scott Wilson
January 19, 2016
- DI Law Group
Alicia Paulino-Grisham
Maggie M. Smith
Mindy L. Chmielarz
January 19, 2016 - Terrence J. Coleman
January 19, 2016 - Anonymous
January 19, 2016 - Jamie L. Harris
January 19, 2016 - Taylor Shallenburg
January 19, 2016 - Eric E. Ludin
January 19, 2016 - Lauren M. Pulido
January 19, 2016 - Amy Ray
January 19, 2016 - National Alliance on Mental Illness of Massachusetts
Laurie Martinelli
January 19, 2016 - Rosenfeld Rafik & Sullivan, P.C.
Mala M. Rafik
January 19, 2016 - Martina B. Sherman
January 19, 2016 - American Council of Life Insurers
January 19, 2016 - American Benefits Council
Jan Jacobson
Kathryn Wilber
January 19, 2016 - Anonymous
January 19, 2016 - Thomas O. Sinclair
January 19, 2016 - UnitedHealthcare
Jennifer Lundgren Lewis-David
January 19, 2016 - John J. Spiegel
January 19, 2016 - Robert J. Rosati
January 19, 2016 - Erin Rose Ronstadt
January 19, 2016 - Sedgwick Claims Management Services, Inc.
Stephanie Simpson
January 19, 2016 - Name Withheld
January 19, 2016 - Susan Martin, Daniel Bonnett, Jennifer Kroll, Evan Schlack
January 19, 2016 - The National Coordinating Committee for Multiemployer Plans
Randy G. DeFrehn
January 19, 2016 - Elliott Andalman and Peter Casciano
January 19, 2016 - Paul Sullivan
January 19, 2016 - The American Association for Justice
Larry A. Tawwater
January 19, 2016 - America's Health Insurance Plans
Wintrop S. Cashdollar
Thomas J. Wilder
January 19, 2016 - Anonymous
January 19, 2016 - Jeff Warncke
January 19, 2016 - Rhonda Harris Buckner
January 19, 2016 - Reed Group, Ltd. of the Guardian Life Insurance Company of America
January 19, 2016 - Consortium for Citizens with Disabilities; American Association of People with Disabilities; American Association on Health and Welfare; American Council of the Blind; American Foundation for the Blind; Association of University Centers on Disabilities; A
January 19, 2016 - John P. Murray
January 19, 2016 - National Business Group on Health
Brian Marcotte
January 19, 2016 - Anonymous
January 19, 2016 - Name Withheld
January 19, 2016 - Chisholm, Chisholm & Kirkpatrick Ltd
J. Scott Kirkpatrick
Mason J. Waring
January 19, 2016 - Stephen L. Raymond
January 19, 2016 - Anonymous
January 19, 2016 - George Thompson
January 19, 2016 - Sun Life Financial
Debra A. Conner
January 19, 2016 - Frankel & Newfield, P.C.
Jason Newfield
January 19, 2016 - Lawrence R. Chaban
January 19, 2016