August 9, 2012
On PPACA Preventive Care Services
~ written by Charlene Bigelow, Client Advocate, Human Capital Practice - Willis of Ohio, Inc.
The Patient Protection and Affordable Care Act requires non-grandfathered health plans to cover certain preventive care services without any cost-sharing. On August 1, 2011, the Health Resources and Services Administration, an agency of HHS, released an expanded list of preventive coverage that must be offered to women under group health plans and individual health plans. The expanded list includes many items, but specifically makes provision for contraceptive methods and counseling. The new list of preventive services applies to plan years beginning on or after August 1, 2012 (January 1, 2013 for calendar-year plans).
Group health plans and group health insurance coverage sponsored by certain religious employers are exempt from having to provide contraceptive coverage. Other non-exempt religious-affiliated employers, such as religious schools and hospitals, that provide health coverage to their employees have been given an additional year to comply with the requirement that their plans include such coverage.
In March 2012, the agencies involved in implementing the health care reform law (Depts of Labor, Health and Human Services, and the Treasury) issued an advance notice of proposed rulemaking (ANPR) asking for comments on the issue of religious affiliated employers and the requirement to offer contraceptive coverage. The proposed rule for which the agencies sought input is intended to provide accommodations to non-exempt religious organizations as a means of allowing employees working for religious affiliates to have access to contraceptive services but still protect employers who object to such coverage based on their religious beliefs from having to pay for it.