August, 6, 2011
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 54
TD 9541
RIN 1545-BJ60
DEPARTMENT OF LABOR
Employee Benefits Security Administration
29 CFR Part 2590
RIN 1210-AB44
DEPARTMENT OF HEALTH AND HUMAN SERVICES
CMS-9992-IFC2
45 CFR Part 147
RIN 0938-AQ07
Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive
Services under the Patient Protection and Affordable Care Act
We applaud HHS’ regulations accepting the Institute of Medicine’s well-grounded recommendations for adding 8 new preventive services for women to be covered without additional co-payments and deductibles. The scientific recognition of these important services, including contraception and screening for domestic violence, and easing the economic burden to access them, will enormously improve the lives of all women and their partners and families.
We regret however the amendment offering certain religious employers the option not to include contraception as a preventive service. We appreciate that the religious employers in question are narrowly defined, in accordance with earlier court cases; in essence, church employees could be affected, but not church-affiliated hospitals or health plans.
Nevertheless, many women who work for and attend the Catholic Church, for example, do not necessarily agree with the Church’s position banning all but one method of contraception. Virtually all sexually active Catholic women have used a banned method of birth control, and 63% support covering contraception through insurance. It is unfortunate that some of these women would be asked to choose among their faith, their families, and the opinions of their employers.
We request that HHS reconsider and reverse this amendment.
Ellen R. Shaffer, PhD MPH, Trust Women/Silver Ribbon Campaign