Re: "Administration to ‘Augment’ ACA Contraceptive Rules"

I don't know exactly how this works, but if you can't in some way be part of a negotiated rate group, medical costs would be very high. I'll get a $300 bill for lab work that Anthem cuts down to $20. We've all seen the stories about the outrageous "sticker" prices charged by hospitals to individ

Re: "Administration to ‘Augment’ ACA Contraceptive Rules"

Two points in response: First, perhaps I should have been clearer: This is merely a responsive, or defensive, point on behalf of the government. In several cases, such as the *Priests for Life *case currently pending in the DC Circuit, it has been some of the *plaintiffs* who complain that the a

RE: "Administration to ‘Augment’ ACA Contraceptive Rules"

Marty, The government does not believe that your third option is practicable. See 78 Fed Reg 39880: “Although some commenters addressed the solicitation for comments on whether and how to provide an accommodation for self-insured group health plans established or maintained by eligible organiz

Re: "Administration to ‘Augment’ ACA Contraceptive Rules"

You've got those basically correct, Doug: In order to prevail, an employer with a self-insured plan would have to demonstrate a substantial burden on religious exercise as to *each* of the following, all of which are legally available options: 1. Declining to provide a plan 2. Using an insured

RE: "Administration to ‘Augment’ ACA Contraceptive Rules"

Marty, could you elaborate on your point 6? Not using an insurer or a third-party administrator presumably means not only self insuring, but processing all the claims yourself. Is that right? That would be expensive, difficult, and as a practical matter, probably impossible for most employer

Re: "Administration to ‘Augment’ ACA Contraceptive Rules"

An updated version of my post ( http://balkin.blogspot.com/2014/08/the-augmented-contraception-coverage.html ): *The Augmented Contraception Coverage Regulations (and an NPRM on extension of the accommodation to some for-profit employers)* Marty Lederman As promised

Re: "Administration to ‘Augment’ ACA Contraceptive Rules"

A preliminary explanation (and I reserve the right to edit it as I get deeper into the regs!): http://balkin.blogspot.com/2014/08/the-augmented-contraception-coverage.html On Fri, Aug 22, 2014 at 4:05 PM, Richard Foltin wrote: > Chip, > > I was able to access the document. The proposed rule i

RE: "Administration to ‘Augment’ ACA Contraceptive Rules"

Chip, I was able to access the document. The proposed rule is open for comments, which must be submitted by October 21. Richard Richard T. Foltin, Esq. Director of National and Legislative Affairs Office of Government and International Affairs Washington, DC P: (202) 785-5463, F: (202) 659-9896

FW: Update on Preventive Services Regulations

The government links may be overloaded. The Amazon links below worked for me. Douglas Laycock Robert E. Scott Distinguished Professor of Law University of Virginia Law School 580 Massie Road Charlottesville, VA 22903 434-243-8546 Interim Final Rule for Non-profits Th

Re: "Administration to ŒAugment¹ ACA Contraceptive Rules"

Here’s another link that worked for me: https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-20252.pdf From: Ira Lupu mailto:icl...@law.gwu.edu>> Reply-To: Law & Religion List mailto:religionlaw@lists.ucla.edu>> Date: Friday, August 22, 2014 at 3:59 PM To: Law & Religion List mai

Re: "Administration to ‘Augment’ ACA Contraceptive Rules"

Here are responses to my own questions: *Interim Final Rule for Non-profits* The administration is issuing interim final regulations that lay out an additional way for organizations eligible for an accommodation to provide notice of their religious objection to providing coverage for contracept

Re: "Administration to ‘Augment’ ACA Contraceptive Rules"

Thanks, Tom. I cannot get either link to work. Have others been able to access these documents? May I ask if the expansion of the accommodation to for-profits is a proposal put out for notice and comment over a prescribed number of days? Chip On Fri, Aug 22, 2014 at 3:46 PM, Berg, Thomas C.

RE: "Administration to ‘Augment’ ACA Contraceptive Rules"

The two proposals from HHS are out now: http://www.ofr.gov/OFRUpload/OFRData/2014-20252_PI.pdf (interim final rules allowing non-profits to notify HHS to claim the accommodation) http://www.ofr.gov/OFRUpload/OFRData/2014-20254_PI.pdf (proposal to expand the accommodation to closely held for-prof