The U.S. Conference of Catholic Bishops yesterday submitted its formal comments on the Department of Health and Human Services Advance Notice of Proposed Rulemaking relating to health insurance coverage of contraceptive services. The Advance Notice includes the Administration's proposal for insurance companies to furnish contraceptive coverage directly, at no additional cost, for employees of non-profit religious institutions that have religious objections to financing such coverage. In its 21-page letter of comment (full text), the Catholic bishops set out numerous objections. In an accompanying press release, USCCB outlined its 6 main points:
- Contraceptive services are still included in the list of mandated preventive services.
- Religious employers fully exempted from the mandate are defined too narrowly.
- Many with conscientious objections, such as religious and secular insurance companies, religious and secular for-profit employers, and individual policy-holders, are ineligible for the exemption.
- Even under the Administration's expanded accommodation of non-profit religious organizations, secular employers are still fully under the coverage mandate.
- Non-exempt religious organizations will still be required to provide plans that serve as a conduit for contraceptives and sterilization procedures to their own employees, and their premiums will help pay for those items.
- The proposals raise questions of whether employers must be independently exempt for their employees to participate in an exempt plan, whether religious objection to some, but not all, contraceptives should be accommodated and whether a past practice of mistakenly or unknowingly covering contraceptives should disqualify one from accommodation.