Wednesday, August 14, 2013

So, about those convenience items

Via email, UHC has informed us that Ms Shecantbeserious has (finally) settled on rules for the birth control convenience item mandate, which include four (4) substantive changes:
1.Modification of the Religious Employer Exemption (REE) definition.
2.Extension of the current Temporary Enforcement Safe Harbor (TESH) through Dec. 31, 2013.
3.Replacement of the TESH with an Eligible Organization designation for plan years starting on or after Jan. 1, 2014, including a new self-certification form for Eligible Organizations.
4.Requires that a health insurance issuer providing fully insured coverage or a third-party administrator that receives certification from an Eligible Organization provide direct payment for contraceptives services at no cost to the plan or its members.
With regard to the religious exemption issue, instead of having to meet 4 criteria to be eligible, an organization must meet only one:

"A “religious employer” now must only be organized and operated as a non-profit organization and referred to under Code section 6033(a)(3)(A)(i) or (iii), which refers to churches, other houses of worship, their integrated auxiliaries and conventions or association of churches, as well"

And if that's not clear enough for you, The Fair Kathleen has also introduced the "Eligible Organization Designation," which seems simple enough:

"An Eligible Organization is a non-profit religious organization with religious objections to covering contraceptive services. Those organizations that self-certify as an Eligible Organization may exclude coverage for some or all contraceptive services."

There's even a handy self-certification form that needs to be submitted by the end of the year.

You just knew there'd be a "but" in here somewhere, didn't you?

Well, here 'tis:

"Under the final rules, a health insurance issuer providing fully insured coverage that receives an Eligible Organization certification form must provide direct  payment for contraceptives services at no cost to the plan or  its members."

Why is it so difficult for the folks in Capital City to understand that nothing is "free?" All that happens here is the usual sleight of hand as insurers pad everyone else's premiums to pay this tax (and that's what this is, whether Ms Shecantbeserious calls it that or not). Or do they truly believe that pills and condoms grow on trees?

Wouldn't surprise me if they did, at that.
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