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

[Scarberry, Mark]

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 individuals who aren't 
insured (or otherwise covered by some sort of negotiated rate program).
Could a negotiated rate network be set up without it being an insurance program 
that would be subject to ACA minimum standards? Then it might be possible for a 
decent-sized company to self insure.

But I don't know much about how this works.

If the only way to provide coverage consistent with faith commitments is to 
self-insure without having access to such a program, that would seem to create 
a large burden.

Mark S. Scarberry
Pepperdine University School of Law

Sent from my iPad

On Aug 22, 2014, at 4:54 PM, "Marty Lederman" 
mailto:lederman.ma...@gmail.com>> wrote:

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 accommodation imposes a burden because it 
allegedly requires them to "refrain from canceling an insurance arrangement 
with a third party authorized to provide the mandated coverage."  Similarly, at 
least one district judge ruled against the government in part on the ground 
that the regulations impose “a duty upon the religious organization to contract 
with a willing third-party administrator that will arrange for the payments for 
contraceptives.”  The court stated that, in its view, “the obligation to take 
affirmative steps to identify and contract with a willing third-party 
administrator if the existing third-party administrator declines forces the 
religious organization to do something to accomplish an end that is inimical to 
its beliefs.”

The government responded, quite reasonably, that the regulation does no such 
thing:  If you want to go it alone, without a TPA, you can go right ahead.  
There is no duty to contract with a third-party administrator that will arrange 
for the payments for contraceptives.

Second, the government has not adopted the view that going it alone would be 
"impracticable."  It merely noted that no employers do so.  And for good reason 
-- why would anyone choose that option, when employees are typically not as 
competent and trained as insurance company personnel at administering a plan?  
If it's marginally more efficient to hire a TPA, then presumably everyone would 
do so.

But this does not mean that it would be so extraordinarily burdensome to handle 
it in-house -- after all, employees often administer payroll and other unwieldy 
programs for organizations.  I can imagine that it's marginally more expensive 
or less efficient to do it in-house, which is why no one does so.  But if an 
employer truly cared about its alleged religious duties, and this was an easy 
way to avoid so-called "complicity," one would think that bearing a modest cost 
such as bringing the insurance administration in-house would not be such a 
prohibitive burden to bear.  Indeed, if an employer were more willing to 
violate its religious precepts than to train some employees to administer an 
insurance plan, that might well tell us something about the importance to the 
employer of those religious tenets.



On Fri, Aug 22, 2014 at 6:50 PM, Kniffin, Eric N. 
mailto:eknif...@lrrlaw.com>> wrote:
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 organizations that do not use the 
services of a third party administrator, no comments indicated that such plans 
actually exist. Accordingly, the Departments continue to believe that there are 
no self-insured group health plans in this circumstance.”

This is an option so unattractive, so expensive, so burdensome that nobody is 
doing it.

Eric

Eric N. Kniffin, Attorney
Admitted in Illinois & District of Columbia,
Not Admitted in ColoradoLewis Roca Rothgerber LLP | 90 S Cascade Ave Suite 1100 
| Colorado Springs, CO 80903-1662(T) 719.386.3017 | (F) 
719.386.3070eknif...@lrrlaw.com<mailto:719.386.3070eknif...@lrrlaw.com> | 
www.LRRLaw.comFrom:<http://www.LRRLaw.comFrom:> 
religionlaw-boun...@lists.ucla.edu<mailto:religionlaw-boun...@lists.ucla.edu> 
[mailto:religionlaw-boun...@lists.ucla.edu] On Behalf Of Marty Lederman
Sent: Friday, August 22, 2014 4:32 PM
To: Law & Religion issues for Law Academics
Subject: Re: "Administration t

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

[Marty Lederman]

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 accommodation imposes a
burden because it allegedly requires them to "refrain from canceling an
insurance arrangement with a third party authorized to provide the mandated
coverage."  Similarly, at least one district judge ruled against the
government in part on the ground that the regulations impose “a duty upon
the religious organization to contract with a willing third-party
administrator that will arrange for the payments for contraceptives.”  The
court stated that, in its view, “the obligation to take affirmative steps
to identify and contract with a willing third-party administrator if the
existing third-party administrator declines forces the religious
organization to *do* something to accomplish an end that is inimical to its
beliefs.”

The government responded, quite reasonably, that the regulation does no
such thing:  If you want to go it alone, without a TPA, you can go right
ahead.  There is no duty to contract with a third-party administrator that
will arrange for the payments for contraceptives.

Second, the government has *not *adopted the view that going it alone would
be "impracticable."  It merely noted that no employers do so.  And for good
reason -- why would anyone choose that option, when employees are typically
not as competent and trained as insurance company personnel at
administering a plan?  If it's marginally more efficient to hire a TPA,
then presumably everyone would do so.

But this does not mean that it would be so extraordinarily burdensome to
handle it in-house -- after all, employees often administer payroll and
other unwieldy programs for organizations.  I can imagine that it's
marginally more expensive or less efficient to do it in-house, which is why
no one does so.  But if an employer truly cared about its alleged religious
duties, and this was an easy way to avoid so-called "complicity," one would
think that bearing a modest cost such as bringing the insurance
administration in-house would not be such a prohibitive burden to bear.
 Indeed, if an employer were more willing to violate its religious precepts
than to train some employees to administer an insurance plan, that might
well tell us something about the importance to the employer of those
religious tenets.



On Fri, Aug 22, 2014 at 6:50 PM, Kniffin, Eric N. 
wrote:

>  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 organizations that do not use
> the services of a third party administrator, no comments indicated that
> such plans actually exist. *Accordingly, the Departments continue to
> believe that there are no self-insured group health plans in this
> circumstance*.”
>
> This is an option so unattractive, so expensive, so burdensome that nobody
> is doing it.
>
> Eric
>
> Eric N. Kniffin, Attorney
> Admitted in Illinois & District of Columbia,
> Not Admitted in ColoradoLewis Roca Rothgerber LLP | 90 S Cascade Ave Suite
> 1100 | Colorado Springs, CO 80903-1662(T) 719.386.3017 | (F)
> 719.386.3070eknif...@lrrlaw.com | www.LRRLaw.comFrom:
> religionlaw-boun...@lists.ucla.edu [
> mailto:religionlaw-boun...@lists.ucla.edu
> ] On Behalf Of Marty Lederman
> Sent: Friday, August 22, 2014 4:32 PM
> To: Law & Religion issues for Law Academics
> Subject: 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 plan
>
> 3.  "self-insuring" without a TPA (this is mostly in response to several
> briefs that argued -- incorrectly -- that the government requires the
> organization to contract with a TPA, something the government has expressly
> rejected)
>
> 4.  invoking the accommodation
>
> 5.  offering contraception coverage in its plan
>
>
>
> On Fri, Aug 22, 2014 at 6:07 PM, Douglas Laycock 
> wrote:
> 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

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

[Kniffin, Eric N.]

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 organizations that do not use the 
services of a third party administrator, no comments indicated that such plans 
actually exist. Accordingly, the Departments continue to believe that there are 
no self-insured group health plans in this circumstance.”

This is an option so unattractive, so expensive, so burdensome that nobody is 
doing it.

Eric

Eric N. Kniffin, Attorney
Admitted in Illinois & District of Columbia,
Not Admitted in ColoradoLewis Roca Rothgerber LLP | 90 S Cascade Ave Suite 1100 
| Colorado Springs, CO 80903-1662(T) 719.386.3017 | (F) 
719.386.3070eknif...@lrrlaw.com | 
www.LRRLaw.comFrom:<http://www.LRRLaw.comFrom:> 
religionlaw-boun...@lists.ucla.edu [mailto:religionlaw-boun...@lists.ucla.edu] 
On Behalf Of Marty Lederman
Sent: Friday, August 22, 2014 4:32 PM
To: Law & Religion issues for Law Academics
Subject: 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 plan

3.  "self-insuring" without a TPA (this is mostly in response to several briefs 
that argued -- incorrectly -- that the government requires the organization to 
contract with a TPA, something the government has expressly rejected)

4.  invoking the accommodation

5.  offering contraception coverage in its plan



On Fri, Aug 22, 2014 at 6:07 PM, Douglas Laycock  wrote:
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 employers. I suppose that with sufficient determination, large 
employers could set up an internal claims-processing unit and hire folks from 
insurance companies to staff it.

And then the option of not providing insurance at all. Is this your 
longstanding position that employers can drop their insurance plans, pay the 
fines, an give their employees a pay increase to cover the cost of insurance on 
the exchanges? Or is it something different?



Douglas Laycock
Robert E. Scott Distinguished Professor of Law
University of Virginia Law School
580 Massie Road
Charlottesville, VA  22903
 434-243-8546





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

[Marty Lederman]

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 plan

3.  "self-insuring" without a TPA (this is mostly in response to several
briefs that argued -- incorrectly -- that the government *requires the
organization to contract with a TPA*, something the government has
expressly rejected)

4.  invoking the accommodation

5.  offering contraception coverage in its plan




On Fri, Aug 22, 2014 at 6:07 PM, Douglas Laycock 
wrote:

> 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 employers. I suppose that with sufficient
> determination, large employers could set up an internal claims-processing
> unit and hire folks from insurance companies to staff it.
>
>
>
> And then the option of not providing insurance at all. Is this your
> longstanding position that employers can drop their insurance plans, pay
> the fines, an give their employees a pay increase to cover the cost of
> insurance on the exchanges? Or is it something different?
>
>
>
>
>
>
>
> Douglas Laycock
>
> Robert E. Scott Distinguished Professor of Law
>
> University of Virginia Law School
>
> 580 Massie Road
>
> Charlottesville, VA  22903
>
>  434-243-8546
>
>
>
> *From:* religionlaw-boun...@lists.ucla.edu [mailto:
> religionlaw-boun...@lists.ucla.edu] *On Behalf Of *Marty Lederman
> *Sent:* Friday, August 22, 2014 5:45 PM
>
> *To:* Law & Religion issues for Law Academics
> *Subject:* 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
> <http://balkin.blogspot.com/2014/07/confirmation-that-supreme-courts.html>,
> the federal government today issued an an interim final rule
> <http://www.ofr.gov/OFRUpload/OFRData/2014-20252_PI.pdf> in which it has
> augmented the secondary accommodation for nonprofit religious employers
> that have religious objections to including contraceptive coverage in their
> employee (or student) insurance plans.  The augmented regulation responds
> directly to the Supreme Court's suggestion in its *Wheaton College *order
> <http://www.supremecourt.gov/opinions/13pdf/13a1284_ap6c.pdf> that the
> Government might "rely[] on [a nonprofit employer's] notice [to HHS of its
> religious objection] . . . to facilitate the provision of full
> contraceptive coverage under the Act,” and in so doing guarantee that the
> employees of that objecting organization would continue to receive
> cost-free access to contraceptive services while at the same time
> eliminating any religious objection that such organizations might have had
> to the requirement that they file "Form 700
> <http://cms.gov/CCIIO/Resources/Forms-Reports-and-Other-Resources/Downloads/cms-10459-certification.pdf>"
> in order to opt out.
>
> The government has simultaneously issued a *proposed* rule
> <https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-20254.pdf>,
> as to which it is soliciting comments for 60 days (until October 21), on
> how it might extend to certain closely held *for-profit *entities, such
> as Hobby Lobby, the same accommodation that is available to non-profit
> religious organizations--something that the Court in *Hobby Lobby *described
> as a less-restrictive means of advancing the government's compelling
> interests *without *any significant harm to the employees and students of
> objecting employers and schools.  Under the proposed rule, covered
> companies would not have to contract, arrange, pay or refer for
> contraceptive coverage to which they object on religious grounds, even if
> they retain employee health plans.  The proposal offers two possible
> definitions of covered, closely held for-profit companies, and seeks
> comments on those and other possible definitions, and whether other steps
> might be appropriate to implement this policy.
>
>
>
> * * * *
>
>
>
> *The new interim final rule for nonprofit organizations*
>
> This is, in sum, how

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

[Douglas Laycock]

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 employers. I suppose that with sufficient determination, large 
employers could set up an internal claims-processing unit and hire folks from 
insurance companies to staff it. 

 

And then the option of not providing insurance at all. Is this your 
longstanding position that employers can drop their insurance plans, pay the 
fines, an give their employees a pay increase to cover the cost of insurance on 
the exchanges? Or is it something different?

 

 

 

Douglas Laycock

Robert E. Scott Distinguished Professor of Law

University of Virginia Law School

580 Massie Road

Charlottesville, VA  22903

 434-243-8546

 

From: religionlaw-boun...@lists.ucla.edu 
[mailto:religionlaw-boun...@lists.ucla.edu] On Behalf Of Marty Lederman
Sent: Friday, August 22, 2014 5:45 PM
To: Law & Religion issues for Law Academics
Subject: 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

 <http://balkin.blogspot.com/2014/07/confirmation-that-supreme-courts.html> As 
promised, the federal government today issued an an  
<http://www.ofr.gov/OFRUpload/OFRData/2014-20252_PI.pdf> interim final rule in 
which it has augmented the secondary accommodation for nonprofit religious 
employers that have religious objections to including contraceptive coverage in 
their employee (or student) insurance plans.  The augmented regulation responds 
directly to the Supreme Court's suggestion in its  
<http://www.supremecourt.gov/opinions/13pdf/13a1284_ap6c.pdf> Wheaton College 
order that the Government might "rely[] on [a nonprofit employer's] notice [to 
HHS of its religious objection] . . . to facilitate the provision of full 
contraceptive coverage under the Act,” and in so doing guarantee that the 
employees of that objecting organization would continue to receive cost-free 
access to contraceptive services while at the same time eliminating any 
religious objection that such organizations might have had to the requirement 
that they file " 
<http://cms.gov/CCIIO/Resources/Forms-Reports-and-Other-Resources/Downloads/cms-10459-certification.pdf>
 Form 700" in order to opt out.

The government has simultaneously issued  
<https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-20254.pdf> 
a proposed rule, as to which it is soliciting comments for 60 days (until 
October 21), on how it might extend to certain closely held for-profit 
entities, such as Hobby Lobby, the same accommodation that is available to 
non-profit religious organizations--something that the Court in Hobby Lobby 
described as a less-restrictive means of advancing the government's compelling 
interests without any significant harm to the employees and students of 
objecting employers and schools.  Under the proposed rule, covered companies 
would not have to contract, arrange, pay or refer for contraceptive coverage to 
which they object on religious grounds, even if they retain employee health 
plans.  The proposal offers two possible definitions of covered, closely held 
for-profit companies, and seeks comments on those and other possible 
definitions, and whether other steps might be appropriate to implement this 
policy. 

 

* * * * 

 

The new interim final rule for nonprofit organizations

This is, in sum, how the accommodation would now work as to a nonprofit 
employer (or school) that offers its employees (or students) a "self-insured" 
insurance plan.  (See  
<http://balkin.blogspot.com/2014/07/unpacking-forthcoming-rfra-challenges.html> 
this postfor explanation of the distinction between insured and self-insured 
plans.)  Under the augmented rule, such an employer or school would have two, 
alternative means of opting out of coverage.  It can continue to use Form 700, 
as many organizations have done.  Or, in the alternative:


1.  An objecting organization that has an objection to submitting Form 700 to 
the plan's third-party administrator need only inform the Department of Health 
and Human Services that it has a religious objection to offering contraception 
coverage.  The organization must also provide HHS with the name and contact 
information for any of the plan’s third party administrators and health 
insurance issuers.  HHS has provided a " 
<http://www.cms.gov/cciio/resources/Regulations-and-Guidance/index.html#Prevention>
 model notice" that eligible organiza

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

[Marty Lederman]

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
,
the federal government today issued an an interim final rule
 in which it has
augmented the secondary accommodation for nonprofit religious employers
that have religious objections to including contraceptive coverage in their
employee (or student) insurance plans.  The augmented regulation responds
directly to the Supreme Court's suggestion in its *Wheaton College *order
 that the
Government might "rely[] on [a nonprofit employer's] notice [to HHS of its
religious objection] . . . to facilitate the provision of full
contraceptive coverage under the Act,” and in so doing guarantee that the
employees of that objecting organization would continue to receive
cost-free access to contraceptive services while at the same time
eliminating any religious objection that such organizations might have had
to the requirement that they file "Form 700
"
in order to opt out.

The government has simultaneously issued a *proposed* rule
,
as to which it is soliciting comments for 60 days (until October 21), on
how it might extend to certain closely held *for-profit *entities, such as
Hobby Lobby, the same accommodation that is available to non-profit
religious organizations--something that the Court in *Hobby Lobby *described
as a less-restrictive means of advancing the government's compelling
interests *without *any significant harm to the employees and students of
objecting employers and schools.  Under the proposed rule, covered
companies would not have to contract, arrange, pay or refer for
contraceptive coverage to which they object on religious grounds, even if
they retain employee health plans.  The proposal offers two possible
definitions of covered, closely held for-profit companies, and seeks
comments on those and other possible definitions, and whether other steps
might be appropriate to implement this policy.

* * * *

*The new interim final rule for nonprofit organizations*

This is, in sum, how the accommodation would now work as to a nonprofit
employer (or school) that offers its employees (or students) a
"self-insured" insurance plan.  (See this post
for
explanation of the distinction between insured and self-insured plans.)
 Under the augmented rule, such an employer or school would have two,
alternative means of opting out of coverage.  It can continue to use Form
700, as many organizations have done.  Or, in the alternative:

1.  An objecting organization that has an objection to submitting Form 700
to the plan's third-party administrator need only inform the Department of
Health and Human Services that it has a religious objection to offering
contraception coverage.  The organization must also provide HHS with the
name and contact information for any of the plan’s third party
administrators and health insurance issuers.  HHS has provided a "model
notice
"
that eligible organizations may, but are not required to, use.

2.  At that point, HHS would inform the Department of Labor of the
organization's opt-out.

3.  DOL would, in turn, inform the plan's third-party administrator (TPA),
if any, that it is obliged to offer contraceptive coverage--initially from
its own resources--to the organization's employees (and/or
students) without imposing any cost-sharing requirements on the eligible
organization, its insurance plan, or its employee beneficiaries.
 (Moreover, the TPA must provide notice of this separate treatment to the
plan beneficiaries, and do so separate from materials distributed in
connection with the eligible organization’s group health coverage.  The
notice to employees must make clear that the objecting organization is
neither administering nor funding the contraceptive benefits.)

4.  The notice from DOL to the TPA -- rather than any form signed or
submitted by the objecting organization -- will then become a "plan
instrument" that designates the TPA as an ERISA "plan administrator" for
purposes of contraception coverage.*

5.  The federal government would then reimburse the TPA for its payments in
the form of an adjustment to the TPA’s assessed user fees for the ACA
exchanges.  In other words, the cost of the contraceptive coverage in the
self-insured setting is ultimately borne by the government itsel

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

[Marty Lederman]

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 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
> folt...@ajc.org
>
> ajc.org <http://www.ajc.org/>
>
> facebook.com/AJCGlobal <http://www.facebook.com/AJCGlobal>
>
> twitter.com/AJCGlobal <http://www.twitter.com/ajcglobal>
>
> twitter.com/AJCGov
> <http://../../../Local%20Settings/Temporary%20Internet%20Files/Content.IE5/HGJ5LOVR/www.twitter.com/AJCGov>
>
> follow me at www.Twitter.com/rfoltin
>
>
>
>  [image: Linkedin-ajc-logo] <http://www.ajc.org/>
> Take Action with AJC by visiting the *Action Center
> <http://www.ajc.org/advocacy>*
>
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>
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>
> *From:* religionlaw-boun...@lists.ucla.edu [mailto:
> religionlaw-boun...@lists.ucla.edu] *On Behalf Of *Ira Lupu
> *Sent:* Friday, August 22, 2014 3:59 PM
>
> *To:* Law & Religion issues for Law Academics
> *Subject:* 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. 
> wrote:
>
> 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-profits)
>
>
>
> -
>
> Thomas C. Berg
>
> James L. Oberstar Professor of Law and Public Policy
>
> University of St. Thomas School of Law
>
> MSL 400, 1000 LaSalle Avenue
>
> Minneapolis, MN   55403-2015
>
> Phone: 651 962 4918
>
> Fax: 651 962 4881
>
> E-mail: tcb...@stthomas.edu
>
> SSRN: http://ssrn.com/author='261564
>
> Weblog: http://www.mirrorofjustice.blogs.com
>
>
> ------------
>  --
>
> *From:* religionlaw-boun...@lists.ucla.edu [
> religionlaw-boun...@lists.ucla.edu] on behalf of Marty Lederman [
> lederman.ma...@gmail.com]
> *Sent:* Friday, August 15, 2014 11:05 AM
> *To:* Law & Religion issues for Law Academics
> *Subject:* Re: "Administration to ‘Augment’ ACA Contraceptive Rules"
>
> I blogged about it here:
>
>
>
> http://balkin.blogspot.com/2014/07/confirmation-that-supreme-courts.html
>
>
>
> DOJ has now told the 10th Circuit that the new reg will be issued no later
> than a week from today (Aug. 22).
>
>
>
> On Fri, Aug 15, 2014 at 11:54 AM, Conkle, Daniel O. 
> wrote:
>
> This is old news, but I hadn’t seen it and so pass it along in case others
> missed it as well.
>
>
>
> Administration to ‘Augment’ ACA Contraceptive Rules
>
>
>
> July 24 — The Obama administration intends to issue interim final rules
> within a month regarding the “accommodations” granted to religious
> nonprofit organizations that object to providing contraceptive coverage
> under the Affordable Care Act, according to a government brief
> <http://www.bloomberglaw.com/public/document/Little_Sisters_of_the_Poor_et_al_v_Burwell_et_al_Docket_No_

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

[Richard Foltin]

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
folt...@ajc.org<mailto:folt...@ajc.org>
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follow me at www.Twitter.com/rfoltin

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From: religionlaw-boun...@lists.ucla.edu 
[mailto:religionlaw-boun...@lists.ucla.edu] On Behalf Of Ira Lupu
Sent: Friday, August 22, 2014 3:59 PM
To: Law & Religion issues for Law Academics
Subject: 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. 
mailto:tcb...@stthomas.edu>> wrote:
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-profits)

-
Thomas C. Berg
James L. Oberstar Professor of Law and Public Policy
University of St. Thomas School of Law
MSL 400, 1000 LaSalle Avenue
Minneapolis, MN   55403-2015
Phone: 651 962 4918
Fax: 651 962 4881
E-mail: tcb...@stthomas.edu<mailto:tcb...@stthomas.edu>
SSRN: http://ssrn.com/author='261564
Weblog: http://www.mirrorofjustice.blogs.com


From: 
religionlaw-boun...@lists.ucla.edu<mailto:religionlaw-boun...@lists.ucla.edu> 
[religionlaw-boun...@lists.ucla.edu<mailto:religionlaw-boun...@lists.ucla.edu>] 
on behalf of Marty Lederman 
[lederman.ma...@gmail.com<mailto:lederman.ma...@gmail.com>]
Sent: Friday, August 15, 2014 11:05 AM
To: Law & Religion issues for Law Academics
Subject: Re: "Administration to ‘Augment’ ACA Contraceptive Rules"
I blogged about it here:

http://balkin.blogspot.com/2014/07/confirmation-that-supreme-courts.html

DOJ has now told the 10th Circuit that the new reg will be issued no later than 
a week from today (Aug. 22).

On Fri, Aug 15, 2014 at 11:54 AM, Conkle, Daniel O. 
mailto:con...@indiana.edu>> wrote:
This is old news, but I hadn’t seen it and so pass it along in case others 
missed it as well.

Administration to ‘Augment’ ACA Contraceptive Rules

July 24 — The Obama administration intends to issue interim final rules within 
a month regarding the “accommodations” granted to religious nonprofit 
organizations that object to providing contraceptive coverage under the 
Affordable Care Act, according to a government 
brief<http://www.bloomberglaw.com/public/document/Little_Sisters_of_the_Poor_et_al_v_Burwell_et_al_Docket_No_130154>
 filed July 22 (Little Sisters of the Poor v. Burwell, 10th Cir., No. 13-1540, 
brief filed 7/22/14).

. . . . .

“The Wheaton College injunction does not reflect a final Supreme Court 
determination that RFRA requires the government to apply the accommodations in 
this manner,” the July 22 DOJ brief said. “Nevertheless, the Departments 
responsible for implementing the accommodations have informed us that they have 
determined to augment the regulatory accommodation process in light of the 
Wheaton College injunction and that they plan to issue interim final rules 
within a month. . . .”
“The administration believes the accommodation is legall

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

[Ira Lupu]

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 contraceptive
services. The rule allows these eligible organizations to notify the
Department of Health and Human Services in writing of their religious
objection to providing contraception coverage.  HHS and the Department of
Labor will then notify insurers and third party administrators so that
enrollees in plans of such organizations receive separate coverage for
contraceptive services, with no additional cost to the enrollee or the
employer.  The interim final rule solicits comments, but goes into effect
upon publication.



The interim final rule is here:
https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-20252.pdf



*NPRM on Closely Held For-Profit Entities*

The administration is also issuing a proposed rule soliciting comments on
how it might extend to certain closely held for-profit entities, like Hobby
Lobby, the same accommodation that is available to non-profit religious
organizations. Under the proposal, these companies would not have to
contract, arrange, pay or refer for contraceptive coverage to which they
object on religious grounds. The proposal seeks comment on how to define a
closely held for-profit company and whether other steps might be
appropriate to implement this policy.



The notice of proposed rulemaking is here:
https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-20254.pdf




On Fri, Aug 22, 2014 at 3:46 PM, Berg, Thomas C. 
wrote:

>  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-profits)
>
> -
>
> Thomas C. Berg
>
> James L. Oberstar Professor of Law and Public Policy
>
> University of St. Thomas School of Law
>
> MSL 400, 1000 LaSalle Avenue
>
> Minneapolis, MN   55403-2015
>
> Phone: 651 962 4918
>
> Fax: 651 962 4881
>
> E-mail: tcb...@stthomas.edu
>
> SSRN: http://ssrn.com/author='261564
>
> Weblog: http://www.mirrorofjustice.blogs.com
>
>
> 
> --
> *From:* religionlaw-boun...@lists.ucla.edu [
> religionlaw-boun...@lists.ucla.edu] on behalf of Marty Lederman [
> lederman.ma...@gmail.com]
> *Sent:* Friday, August 15, 2014 11:05 AM
> *To:* Law & Religion issues for Law Academics
> *Subject:* Re: "Administration to ‘Augment’ ACA Contraceptive Rules"
>
>   I blogged about it here:
>
>  http://balkin.blogspot.com/2014/07/confirmation-that-supreme-courts.html
>
>  DOJ has now told the 10th Circuit that the new reg will be issued no
> later than a week from today (Aug. 22).
>
>
> On Fri, Aug 15, 2014 at 11:54 AM, Conkle, Daniel O. 
> wrote:
>
>>  This is old news, but I hadn’t seen it and so pass it along in case
>> others missed it as well.
>>
>>
>>
>> Administration to ‘Augment’ ACA Contraceptive Rules
>>
>>
>>
>> July 24 — The Obama administration intends to issue interim final rules
>> within a month regarding the “accommodations” granted to religious
>> nonprofit organizations that object to providing contraceptive coverage
>> under the Affordable Care Act, according to a government brief
>> <http://www.bloomberglaw.com/public/document/Little_Sisters_of_the_Poor_et_al_v_Burwell_et_al_Docket_No_130154>
>> filed July 22 (Little Sisters of the Poor v. Burwell, 10th Cir., No.
>> 13-1540, brief filed 7/22/14).
>>
>>
>>
>> . . . . .
>>
>>
>>
>> “The Wheaton College injunction does not reflect a final Supreme Court
>> determination that RFRA requires the government to apply the accommodations
>> in this manner,” the July 22 DOJ brief said. “Nevertheless, the Departments
>> responsible for implementing the accommodations have informed us that they
>> have determined to augment the regulatory accommodation process in light of
>> the Wheaton College injunction and that they plan to issue interim final
>> rules within a month. . . .”
>>
>> “The administration believes the accommodation is legally sound, but in
>> light of the Supreme Court order regarding Wheaton College, the departments
>> intend to augment their regulations to provide an alternativ

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

[Ira Lupu]

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. 
wrote:

>  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-profits)
>
> -
>
> Thomas C. Berg
>
> James L. Oberstar Professor of Law and Public Policy
>
> University of St. Thomas School of Law
>
> MSL 400, 1000 LaSalle Avenue
>
> Minneapolis, MN   55403-2015
>
> Phone: 651 962 4918
>
> Fax: 651 962 4881
>
> E-mail: tcb...@stthomas.edu
>
> SSRN: http://ssrn.com/author='261564
>
> Weblog: http://www.mirrorofjustice.blogs.com
>
>
> 
> --
> *From:* religionlaw-boun...@lists.ucla.edu [
> religionlaw-boun...@lists.ucla.edu] on behalf of Marty Lederman [
> lederman.ma...@gmail.com]
> *Sent:* Friday, August 15, 2014 11:05 AM
> *To:* Law & Religion issues for Law Academics
> *Subject:* Re: "Administration to ‘Augment’ ACA Contraceptive Rules"
>
>   I blogged about it here:
>
>  http://balkin.blogspot.com/2014/07/confirmation-that-supreme-courts.html
>
>  DOJ has now told the 10th Circuit that the new reg will be issued no
> later than a week from today (Aug. 22).
>
>
> On Fri, Aug 15, 2014 at 11:54 AM, Conkle, Daniel O. 
> wrote:
>
>>  This is old news, but I hadn’t seen it and so pass it along in case
>> others missed it as well.
>>
>>
>>
>> Administration to ‘Augment’ ACA Contraceptive Rules
>>
>>
>>
>> July 24 — The Obama administration intends to issue interim final rules
>> within a month regarding the “accommodations” granted to religious
>> nonprofit organizations that object to providing contraceptive coverage
>> under the Affordable Care Act, according to a government brief
>> <http://www.bloomberglaw.com/public/document/Little_Sisters_of_the_Poor_et_al_v_Burwell_et_al_Docket_No_130154>
>> filed July 22 (Little Sisters of the Poor v. Burwell, 10th Cir., No.
>> 13-1540, brief filed 7/22/14).
>>
>>
>>
>> . . . . .
>>
>>
>>
>> “The Wheaton College injunction does not reflect a final Supreme Court
>> determination that RFRA requires the government to apply the accommodations
>> in this manner,” the July 22 DOJ brief said. “Nevertheless, the Departments
>> responsible for implementing the accommodations have informed us that they
>> have determined to augment the regulatory accommodation process in light of
>> the Wheaton College injunction and that they plan to issue interim final
>> rules within a month. . . .”
>>
>> “The administration believes the accommodation is legally sound, but in
>> light of the Supreme Court order regarding Wheaton College, the departments
>> intend to augment their regulations to provide an alternative way for
>> objecting non-profit religious organizations to provide notification, while
>> ensuring that enrollees in plans of such organizations receive separate
>> coverage of contraceptive services without cost sharing,” a senior
>> administration official told reporters in a briefing July 22. The official
>> spoke on condition of anonymity.
>>
>>
>>
>>
>>
>> Bloomberg BNA, U.S. Law Week (subscription required)
>>
>>
>>
>>
>> http://news.bna.com/lwln/LWLNWB/split_display.adp?fedfid=50879221&vname=lw1notallissues&fcn=56&wsn=49832&fn=50879221&split=0
>>
>>
>>
>>
>>
>> Daniel O. Conkle
>> 
>> Daniel O. Conkle
>> Robert H. McKinney Professor of Law
>> Indiana University Maurer School of Law
>> Bloomington, Indiana  47405
>> (812) 855-4331
>> fax (812) 855-0555
>> e-mail con...@indiana.edu
>> 
>>
>>
>>
>> ___
>> To post, send message to Religionlaw@lists.ucla.edu
>> To subscribe, unsubscribe, change options, or get password, see
>> http://lists.ucla.edu/cgi-bin/mailman/listinfo/religionlaw
>>
>> Please note that m

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

[Berg, Thomas C.]

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-profits)

-
Thomas C. Berg
James L. Oberstar Professor of Law and Public Policy
University of St. Thomas School of Law
MSL 400, 1000 LaSalle Avenue
Minneapolis, MN   55403-2015
Phone: 651 962 4918
Fax: 651 962 4881
E-mail: tcb...@stthomas.edu<mailto:tcb...@stthomas.edu>
SSRN: http://ssrn.com/author='261564
Weblog: http://www.mirrorofjustice.blogs.com


From: religionlaw-boun...@lists.ucla.edu [religionlaw-boun...@lists.ucla.edu] 
on behalf of Marty Lederman [lederman.ma...@gmail.com]
Sent: Friday, August 15, 2014 11:05 AM
To: Law & Religion issues for Law Academics
Subject: Re: "Administration to ‘Augment’ ACA Contraceptive Rules"

I blogged about it here:

http://balkin.blogspot.com/2014/07/confirmation-that-supreme-courts.html

DOJ has now told the 10th Circuit that the new reg will be issued no later than 
a week from today (Aug. 22).


On Fri, Aug 15, 2014 at 11:54 AM, Conkle, Daniel O. 
mailto:con...@indiana.edu>> wrote:
This is old news, but I hadn’t seen it and so pass it along in case others 
missed it as well.

Administration to ‘Augment’ ACA Contraceptive Rules

July 24 — The Obama administration intends to issue interim final rules within 
a month regarding the “accommodations” granted to religious nonprofit 
organizations that object to providing contraceptive coverage under the 
Affordable Care Act, according to a government 
brief<http://www.bloomberglaw.com/public/document/Little_Sisters_of_the_Poor_et_al_v_Burwell_et_al_Docket_No_130154>
 filed July 22 (Little Sisters of the Poor v. Burwell, 10th Cir., No. 13-1540, 
brief filed 7/22/14).

. . . . .

“The Wheaton College injunction does not reflect a final Supreme Court 
determination that RFRA requires the government to apply the accommodations in 
this manner,” the July 22 DOJ brief said. “Nevertheless, the Departments 
responsible for implementing the accommodations have informed us that they have 
determined to augment the regulatory accommodation process in light of the 
Wheaton College injunction and that they plan to issue interim final rules 
within a month. . . .”
“The administration believes the accommodation is legally sound, but in light 
of the Supreme Court order regarding Wheaton College, the departments intend to 
augment their regulations to provide an alternative way for objecting 
non-profit religious organizations to provide notification, while ensuring that 
enrollees in plans of such organizations receive separate coverage of 
contraceptive services without cost sharing,” a senior administration official 
told reporters in a briefing July 22. The official spoke on condition of 
anonymity.


Bloomberg BNA, U.S. Law Week (subscription required)

http://news.bna.com/lwln/LWLNWB/split_display.adp?fedfid=50879221&vname=lw1notallissues&fcn=56&wsn=49832&fn=50879221&split=0


Daniel O. Conkle

Daniel O. Conkle
Robert H. McKinney Professor of Law
Indiana University Maurer School of Law
Bloomington, Indiana  47405
(812) 855-4331
fax (812) 855-0555
e-mail con...@indiana.edu<mailto:con...@indiana.edu>



___
To post, send message to 
Religionlaw@lists.ucla.edu<mailto:Religionlaw@lists.ucla.edu>
To subscribe, unsubscribe, change options, or get password, see 
http://lists.ucla.edu/cgi-bin/mailman/listinfo/religionlaw

Please note that messages sent to this large list cannot be viewed as private.  
Anyone can subscribe to the list and read messages that are posted; people can 
read the Web archives; and list members can (rightly or wrongly) forward the 
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___
To post, send message to Religionlaw@lists.ucla.edu
To subscribe, unsubscribe, change options, or get password, see 
http://lists.ucla.edu/cgi-bin/mailman/listinfo/religionlaw

Please note that messages sent to this large list cannot be viewed as private.  
Anyone can subscribe to the list and read messages that are posted; people can 
read the Web archives; and list members can (rightly or wrongly) forward the 
messages to others.

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

[Marty Lederman]

I blogged about it here:

http://balkin.blogspot.com/2014/07/confirmation-that-supreme-courts.html

DOJ has now told the 10th Circuit that the new reg will be issued no later
than a week from today (Aug. 22).


On Fri, Aug 15, 2014 at 11:54 AM, Conkle, Daniel O. 
wrote:

>  This is old news, but I hadn’t seen it and so pass it along in case
> others missed it as well.
>
>
>
> Administration to ‘Augment’ ACA Contraceptive Rules
>
>
>
> July 24 — The Obama administration intends to issue interim final rules
> within a month regarding the “accommodations” granted to religious
> nonprofit organizations that object to providing contraceptive coverage
> under the Affordable Care Act, according to a government brief
> 
> filed July 22 (Little Sisters of the Poor v. Burwell, 10th Cir., No.
> 13-1540, brief filed 7/22/14).
>
>
>
> . . . . .
>
>
>
> “The Wheaton College injunction does not reflect a final Supreme Court
> determination that RFRA requires the government to apply the accommodations
> in this manner,” the July 22 DOJ brief said. “Nevertheless, the Departments
> responsible for implementing the accommodations have informed us that they
> have determined to augment the regulatory accommodation process in light of
> the Wheaton College injunction and that they plan to issue interim final
> rules within a month. . . .”
>
> “The administration believes the accommodation is legally sound, but in
> light of the Supreme Court order regarding Wheaton College, the departments
> intend to augment their regulations to provide an alternative way for
> objecting non-profit religious organizations to provide notification, while
> ensuring that enrollees in plans of such organizations receive separate
> coverage of contraceptive services without cost sharing,” a senior
> administration official told reporters in a briefing July 22. The official
> spoke on condition of anonymity.
>
>
>
>
>
> Bloomberg BNA, U.S. Law Week (subscription required)
>
>
>
>
> http://news.bna.com/lwln/LWLNWB/split_display.adp?fedfid=50879221&vname=lw1notallissues&fcn=56&wsn=49832&fn=50879221&split=0
>
>
>
>
>
> Daniel O. Conkle
> 
> Daniel O. Conkle
> Robert H. McKinney Professor of Law
> Indiana University Maurer School of Law
> Bloomington, Indiana  47405
> (812) 855-4331
> fax (812) 855-0555
> e-mail con...@indiana.edu
> 
>
>
>
> ___
> To post, send message to Religionlaw@lists.ucla.edu
> To subscribe, unsubscribe, change options, or get password, see
> http://lists.ucla.edu/cgi-bin/mailman/listinfo/religionlaw
>
> Please note that messages sent to this large list cannot be viewed as
> private.  Anyone can subscribe to the list and read messages that are
> posted; people can read the Web archives; and list members can (rightly or
> wrongly) forward the messages to others.
>
___
To post, send message to Religionlaw@lists.ucla.edu
To subscribe, unsubscribe, change options, or get password, see 
http://lists.ucla.edu/cgi-bin/mailman/listinfo/religionlaw

Please note that messages sent to this large list cannot be viewed as private.  
Anyone can subscribe to the list and read messages that are posted; people can 
read the Web archives; and list members can (rightly or wrongly) forward the 
messages to others.