Notice of Proposed Rulemaking Regarding Preventive Services (April 8, 2013)

Health Care

The Church Alliance submitted comment in response to the notice of proposed rulemaking regarding preventive services (“NPRM”) issued jointly by the Internal Revenue Service, the Department of Labor and the Department of Health and Human Services (HHS) (together, the “Departments”). The Church Alliance commented twice previously on the topic of preventive services (below). In this letter, the Church Alliance expressed appreciation for the Departments’ responsiveness and attentiveness to the Church Alliance’s earlier comments, but continues to urge the Departments to abandon the employer-by-employer approach and adopt instead a broader plan-based exemption.