The two proposals from HHS are out now:
http://www.ofr.gov/OFRUpload/OFRData/2014-20252_PI.pdf (interim final rules
allowing non-profits to notify HHS to claim the accommodation)
http://www.ofr.gov/OFRUpload/OFRData/2014-20254_PI.pdf (proposal to expand the
accommodation to closely held
Thanks, Tom. I cannot get either link to work. Have others been able to
access these documents?
May I ask if the expansion of the accommodation to for-profits is a
proposal put out for notice and comment over a prescribed number of days?
Chip
On Fri, Aug 22, 2014 at 3:46 PM, Berg, Thomas C.
Here are responses to my own questions:
*Interim Final Rule for Non-profits*
The administration is issuing interim final regulations that lay out an
additional way for organizations eligible for an accommodation to provide
notice of their religious objection to providing coverage for
Here’s another link that worked for me:
https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-20252.pdf
From: Ira Lupu icl...@law.gwu.edumailto:icl...@law.gwu.edu
Reply-To: Law Religion List
religionlaw@lists.ucla.edumailto:religionlaw@lists.ucla.edu
Date: Friday, August 22, 2014
The government links may be overloaded. The Amazon links below worked for
me.
Douglas Laycock
Robert E. Scott Distinguished Professor of Law
University of Virginia Law School
580 Massie Road
Charlottesville, VA 22903
434-243-8546
Interim Final Rule for Non-profits
Chip,
I was able to access the document. The proposed rule is open for comments,
which must be submitted by October 21.
Richard
Richard T. Foltin, Esq.
Director of National and Legislative Affairs
Office of Government and International Affairs
Washington, DC
P: (202) 785-5463, F: (202)
A preliminary explanation (and I reserve the right to edit it as I get
deeper into the regs!):
http://balkin.blogspot.com/2014/08/the-augmented-contraception-coverage.html
On Fri, Aug 22, 2014 at 4:05 PM, Richard Foltin folt...@ajc.org wrote:
Chip,
I was able to access the document. The
An updated version of my post (
http://balkin.blogspot.com/2014/08/the-augmented-contraception-coverage.html
):
*The Augmented Contraception Coverage Regulations (and an NPRM on extension
of the accommodation to some for-profit employers)*
Marty Lederman
As promised
Marty, could you elaborate on your point 6?
Not using an insurer or a third-party administrator presumably means not only
self insuring, but processing all the claims yourself. Is that right? That
would be expensive, difficult, and as a practical matter, probably impossible
for most
You've got those basically correct, Doug:
In order to prevail, an employer with a self-insured plan would have to
demonstrate a substantial burden on religious exercise as to *each* of the
following, all of which are legally available options:
1. Declining to provide a plan
2. Using an
Marty,
The government does not believe that your third option is practicable. See 78
Fed Reg 39880:
“Although some commenters addressed the solicitation for comments on whether
and how to provide an accommodation for self-insured group health plans
established or maintained by eligible
Two points in response:
First, perhaps I should have been clearer: This is merely a responsive, or
defensive, point on behalf of the government. In several cases, such as
the *Priests for Life *case currently pending in the DC Circuit, it has
been some of the *plaintiffs* who complain that the
I don't know exactly how this works, but if you can't in some way be part of a
negotiated rate group, medical costs would be very high. I'll get a $300 bill
for lab work that Anthem cuts down to $20. We've all seen the stories about the
outrageous sticker prices charged by hospitals to
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