Paying For Contraceptive Coverage under Healthcare Reform
If you want to get into the weeds regarding the Administration’s Advanced Notice of Proposed Rulemaking on contraceptive coverage for religious institutions, this is the place for you.
In general, even women employed by religious institution will have access to “free” contraceptives under the Administration’s rule. The administration’s proposed rule passes these costs to various parties, depending on what market the religious institution is purchasing health-insurance coverage in. It has been widely reported in the press that the insurer will pay for this coverage, but this conclusion is not supported by the details of the proposed rule.
This series of posts will analyze each market segment separately, and then will discuss the administration’s surprising suggestion to make contraceptive coverage in such cases an “excepted” benefit. Lastly, there will be a summary post [here] with the main conclusions.
* Large group, fully-insured. The administration appears to suggest that the religious institution itself will bear the cost of the contraceptive coverage in this instance, despite declarations to the contrary.
* Small group, fully-insured. The administration appears to suggest that other small, non-religious employers should bear the cost of contraceptive coverage in this case. It is also possible that they are suggesting that the small, religiously affiliated employer should bear the entire cost of the coverage, albeit indirectly.
* Self-insured. The administration appears to suggest that the cost of coverage can be split between the religious institution itself and the federal taxpayers, again, despite declarations to the contary. This example is quite complex but worth working through.
* Should Contraceptive Coverage be a HIPAA-excepted Benefit? The administration almost cavalierly suggests this in their ANPRM, but this carries with it significant downstream implications for rate review and medical loss ratio testing. Strangely, the administration’s proposed rule doesn’t acknowledge these rather straightforward implications.
* Conclusions and Summary.
[Note: this post is still in progress; links will be added as the work gets finished]