Request for Information (RFI) on Contraceptive Services (September 20, 2016)

Health Care

The Church Alliance submitted comment in response to a request for information (RFI) from the Department of the Treasury, the Department of Labor and the Department of Health and Human Services (together, the “Departments”) regarding the Affordable Care Act (ACA) rule for coverage of contraceptive services. The Departments issued the RFI in response to the Supreme Court’s order in Zubik v Burwell earlier in 2016, in which the Supreme Court urged the parties (the Departments and the church-affiliated employers challenging the earlier regulatory accommodation) to negotiate a new approach. The letter supplements four previous Church Alliance comment letters on this line of regulations, and maintains the stance that most of the health plans in the Church Alliance cover these services, but that all members agree that the administrator of a church health plan should not have to choose between violating the beliefs of the denomination and paying a penalty.