Consumers Union submitted these comments to oppose the request for an adjustment to the medical loss ratio (MLR) requirement for the State of Florida submitted by the Florida Office of Insurance Regulation (FOIR) to the Center for Consumer Information and Insurance Oversight (CCIIO). The FOIR was seeking to phase in the MLR requirement using a 68% minimum standard in 2011, 72% in 2012, and 76% in 2013, and then reaching the Affordable Care Act (ACA) required minimum of 80% in 2014. Based upon estimates from the FOIR of rebates with and without the requested adjustment, consumers could lose as much as an estimated $144 million in rebates during the proposed three-year transition period if the adjustment is granted.