Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the ACA (December 5, 2017)

Health Care

The Church Alliance submitted comment in response to the interim final rules (the “Rules”) regarding religious exemptions and accommodations for coverage of certain preventive services under the Patient Protection and Affordable Care Act (“ACA”) issued jointly by the Department of the Treasury, the Department of Labor, and the Department of Health and Human Services (together, the “Departments”). The Church Alliance letter expresses gratitude for the expansion of the religious exemption in the Rules, which is responsive to the Church Alliance’s comment letters regarding earlier versions of the Rules. The letter also requests (1) clarification that employers adopting an exempt plan cannot be penalized, (2) clarification regarding how organizations may revoke its use of the accommodation, and (3) that the Departments refrain from specifying forms of certification to claim or maintain an exemption.