Interim Final Rule Regarding Coverage of Certain Preventive Services Under the Affordable Care Act (October 27, 2014)
The Church Alliance submitted comment in response to the interim final rule (IFR) regarding coverage of preventive services under the Affordable Care Act (“ACA”) issued jointly by the Internal Revenue Service, the Department of Labor and the Department of Health and Human Services (HHS) (together, the “Departments”). The Church Alliance commented three times previously on the topic of preventive services (below). In this letter, the Church Alliance acknowledges the Departments’ attempt to amend the “accommodation” for “eligible organizations” (religious employers that are not churches or integrated auxiliaries), but respectfully submits that the “accommodation” nonetheless continues to cause some religious employers to violate their beliefs. The Church Alliance continues to urge the Departments to abandon the employer-by-employer approach and adopt instead a broader plan-based exemption, among other adjustments.