Keehan Responds to HHS Final Rules

Attached is an overview of the final rules governing the HHS contraception mandate. The document issued on June 28, 2013, is 110 pages. The first 82 pages are responses to the comments received during the official comment period. 

Since the original rule was issued over a year ago, there has been considerable concern raised by many parties including CHA. CHA had two principal concerns. The first was the four-part definition of what constituted a “religious employer.” That concern has been eliminated. CHA’s second concern was establishing a federal precedent that mandated our members would have to include in their health plans, services they had well-established moral objections to.

HHS has now established an accommodation that will allow our ministries to continue offering health insurance plans for their employees as they have always done.

We have prepared this explanation for members to help them understand the accommodation and how to implement it. Throughout this process, CHA has been in dialogue with the leadership of the Bishops’ Conference, the Administration and HHS. We are pleased that our members now have an accommodation that will not require them to contract, provide, pay or refer for contraceptive coverage.

We also recognize that this resolution has not been what some organizations, including the Bishops’ Conference, asked for on behalf of a wider group. Our contribution to the process has been to work for the protection of religious organizations, especially our members. We recognize the broader issues will continue to be debated and litigated by others.

CHA is grateful for the respect and concern demonstrated by all parties in this dialogue. We will work with our members to implement this accommodation.