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Melissa Rogers

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Honoring Religious Objections and Access to Contraceptive Coverage

Posted: 02/17/2012 10:03 am

At the heart of President Obama's announcement last week on the contraceptive coverage mandate are two goals: ensuring that religious organizations will not have to pay for or provide coverage for services that are objectionable to them and that employees of objecting religious organizations will have access to these benefits on the same basis as other employees.

These are the right goals. As the administration moves forward to implement them, it should carefully consider legitimate free exercise concerns and distinguish them from broader grievances about the contraceptive mandate and the Affordable Care Act as a whole.

In his Feb. 10 remarks, President Obama offered a specific proposal about how to reach the goals of honoring religious objections and access to contraceptive coverage. Drawing on the provisions of certain state laws, the president proposed requiring insurers to provide these benefits to employees of objecting religious organizations via insurance contracts that are separate from the contracts between the insurers and objecting religious employers, with no referrals by these employers. The aim is to take objecting religious organizations out of the equation, while ensuring employee access to important health benefits. Many Catholics and other people of faith have said this proposal works well for them, and it makes good sense to me.

Since the announcement, however, some other Catholics and religious people have said even this accommodation would substantially burden the free exercise of their institutions. Some religious employers would like, for example, to be able to purchase insurance from insurers that do not offer contraceptive coverage so that none of their money supports such coverage in even the most remote way. Likewise, some nonprofit religious insurers have said they would object to a requirement that forced them to provide contraceptive coverage. The administration should address legitimate concerns like these in the upcoming rulemaking process. It has already pledged that religious employers with self-insured group health plans will not be required to pay for or provide coverage for services to which they object, while employees of those organizations will be guaranteed such coverage by other means. The solution the administration formulates for self-insured health plans may suggest fixes for these other cases as well.

Why should the administration address concerns like these? As UCLA Law Professor Eugene Volokh recently noted, free exercise burdens turn on the subjective understanding of the religious practitioner or body. One person or body's understanding of their faith can differ from another's. It is not the government's job to try to determine what is the "right" understanding of a faith; instead, its job is to assess whether the faith practice is sincere and the burden on it is substantial. Having already demonstrated an interest in accommodating spiritual obligations, the administration can and should consider different understandings of those obligations.

Another key part of the administration's proposed rule will be minimizing differences between what its current rule calls "non-exempted" religious employers (such as religious hospitals, universities and social ministries) and "exempted" religious employers (basically, churches and other houses of worship). The ideal approach -- rather than unnecessarily carving out distinct regulatory regimes for two different sorts of employers -- is simply to include a single modified exemption, while still ensuring that employees of exempted organizations could access contraceptive coverage. The administration chose not to do this, but in his remarks last week President Obama treated these two sets of organizations the same way and announced a policy that has the practical effect of broadening the exemption. In other words, the current exemption is a faulty one that should not be extended to other areas of federal law; but, with care, the administration should be able to address the problem here in a workable way.

At the same time, the Obama administration should distinguish between legitimate religious liberty concerns about the exemption and broader grievances about the contraceptive mandate and the Affordable Care Act as a whole. For example, those who say the only way to remedy the free exercise problem is to scrap the contraceptive mandate -- or the entire Affordable Care Act -- are wrong. They are also badly mistaken when they suggest it somehow violates the free exercise rights of a religiously affiliated hospital, social service agency or university for an insurer or the government to offer their employees contraceptive coverage. Further, there is certainly no free exercise obligation to exempt all employers from an obligation to provide contraceptive coverage due to their CEOs' personal religious convictions.

There's a balance to be struck here because this debate involves more than simply the interests of religious objectors. In 2005 a unanimous U.S. Supreme Court said that when considering free exercise accommodations, "courts must take adequate account of the burdens a requested accommodation may impose on nonbeneficiaries." This constitutional principle deserves attention here, too. Also, some legal scholars have suggested employees of objecting religious employers may have Religious Freedom Restoration Act claims of their own if they are denied these federal benefits. In any case, a policy that would operate to allow employers' religious convictions to deny hundreds of thousands of Americans federal benefits would be disturbing. It's also worth noting that expanding contraceptive coverage will help greatly to reduce the number of abortions, a goal with strong support in both the pro-choice and pro-life ranks.

If all of this sounds complicated, that's because it is. Indeed, my hope is this episode will prompt us to re-consider our employer-based health insurance system. It is right to honor the religious objections of faith-based employers, but it is also right to ask why we retain a system where the health coverage employees receive may be limited by those objections.

While the employer-based system endures, however, we must confront the dilemmas it presents. President Obama's commitment to the twin goals of honoring objections and access and to opening a new rulemaking process provides the framework necessary to address these issues in constructive ways. The administration should continue to fast-track this policy-making process, even though obligations on religious institutions will not kick in until August 2013. It's in everyone's interest to try to find an agreeable solution to this problem. No one can be certain how lawsuits and legislation will fare, and no one can safely predict the outcome of the next election.

These matters are complex, but our debate over them need not be caustic. May cool heads and fair-mindedness prevail as we move forward.

 
 
 
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HUFFPOST SUPER USER
wak84
05:26 PM on 02/21/2012
Thank you!!! I have voiced this opinion many times--one's employer should not be able to dictate what healthcare you "deserve." What concerns me is that the religious exemption could be made so broad as to include "moral objections." So what if Chick-Fil-A, an organization that has fundamentalist Christian executives who use company money for donations to anti-gay groups that espouse "family values," decides that giving anti-AIDS drugs to HIV-positive gay men in their employment (assuming they hire gay men) is against God's will because the men should suffer the consequences of their "immoral" behavior? This example seems extreme now, but, like giving Constitutional civil rights to fertilized eggs, giving employers an exemption on moral or religious grounds could have strange, unforeseen circumstances.
This is why we need universal coverage, that is not supplied by one's employer.
04:42 PM on 02/20/2012
Money is blind to one's beliefs. The government tries to create a level field for beliefs in a secular society. Its power is expressed in money and laws. Obama, as the executive of the US, can choose to be blind to the belief's of groups or to give some more value than others. He, in a secular society, must be blind. A rule is a rule.

We are allowed to practice our personal religious beliefs that don't infringe upon the law and the reach of the US dollar, that is up to us. But if we want to use the government dollars (specially exclusive subsidies) and want to stay within the reach of the law, we must also adopt a universalist perspective.

Further, if I choose to not deliver care to women, to the elderly, to very sick children because it is against my idea of morality - while I have the power to deliver that care - it is my egocentric construct that makes me inhumane. To allow groups to exercise values against the freedom of individuals is to allow an exclusion from the social contract of our society. I don't want doctors saying, "you're over 70, you're going to die soon anyway, you don't deserve health care, I'm ethically opposed to delivering it to you, too bad for you there is no one else in the ER." In a secular society the church has power over its own voluntary followers, it should not have power over others.

hariaum
12:27 AM on 02/20/2012
I've never seen someone talk about the first amendment so much w/o mentioning the first amendment.
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HUFFPOST SUPER USER
Aslow
QUALITY CONTINUUM
05:18 PM on 02/19/2012
It would be too lengthy to address all the errors in the thinking of this article. Let me just comment on one. The reference to "some Catholics and religious people" are the American Bishops, who are the most important leaders of the Church. One cannot refer to Obama's statement as a compromise without their agreement. They haven't. Also, as of now no one in this country has an obligation to pay for someone elses contraception devices or abortions. Obama is in the process of creating this obligation.
04:37 PM on 02/19/2012
Don't Christian Scientists reject any medical intervention?
So providing ANY healthcare coverage would be morally objectionable....
I predict mass conversions.
iridium53
Semper Fi
11:51 AM on 02/19/2012
I don't see it as complex at all.
The issue is whether religious-based businesses will have to pay for all of their employee healthcare - or if they can transfer those costs onto other, non-religious businesses.

This is about the religion-based businesses not wanting to PAY. For their employees.
There is no requirement for the employees to use the particular healthcare services.

Let's assume that government projections of overall healthcare savings are correct and that if all women are covered then healthcare costs will go down. Shouldn't all businesses that pay participate in those savings?
http://aspe.hhs.gov/health/reports/2012/contraceptives/ib.shtml

Healthcare insurance oligopoly companies are, already, guaranteed a 20% margin by ACA.
Healthcare insurance companies do not "pay" for costs, they aggregate costs and pass them on in a parimutuel scheme and take their vig (20%). To discuss these insurance companies as paying is a flimflam, a con.

The math is simple. If one group does not pay, then another group will have to pay for their costs.

This scheme creates a religion-based preference on some businesses. It makes non-religionists pay for what religionist won't. It is an unconscionable, religion-based TAX to support particular religions.
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HUFFPOST SUPER USER
Aslow
QUALITY CONTINUUM
05:20 PM on 02/19/2012
If these savings were real iridium53, the insurance companies would already be giving contraceptives out free.
09:52 AM on 02/19/2012
The system reflects our schizophrenic approach. We do not believe that health care is a right, or something that the government should provide, yet we want to mandate that everyone have it.
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HUFFPOST SUPER USER
Aslow
QUALITY CONTINUUM
05:25 PM on 02/19/2012
Healthcare is not a right. But it is a want. Everyone seems to agree that all should have it. The manner in which it is delvered to the people is the problem. My main concern is that when the Government has this enormous power over our lives that Obamacare gives it, then the delivery and the cost will not matter. The cost will go up and the Quality of care will go way down. Why? Who does this behometh answer to? No one.
08:38 PM on 02/18/2012
This article is too easy on the hypocrisy of the objecting employers. The real issue is equal protection under the law for all women. There is no cogent reason why the scruples of an institution should override individual liberty, it is just appalling that we let these church's lobby with impunity while they enjoy tax immunity.
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HUFFPOST SUPER USER
Aslow
QUALITY CONTINUUM
05:34 PM on 02/19/2012
Stephen Sottile I think you're mixing a few things up here. There is no denial of equal treatment for women who work at a Catholic institution. The Chursh doesn't pay for contraception or abortion for any women. If the women want that coverage they are free to work somewhere else. For example, if business A provides a TV in the workers lunch area and business B does not is business B in violation of equal protection? Or does that worker have the right to work elsewhere? And these are not "scruples". Bans on Contraception and abortion are important dogma of the Church. And You may not know this but lobbying is not illegal. The Church and many charties are exempt from taxation which Obama wants to remove so that people will become even more dependent upon Government.
06:55 PM on 02/19/2012
Thank you Stephen. This is the point that so many discussions on this issue have been missing. Providing healthcare for your employees is not a religious issue, it is an employment issue. Provide coverage and your employees get healthcare. They should not get religious ideology along with the healthcare. Separation of religion and healthcare. (Please). Let;s have the government provide healthcare and stop all this nonsense.
06:07 PM on 02/18/2012
There is more to this than meets the eye. Firstly, does the employer pay more for a plan that includes contraception coverage than one that does not? I don't think my employer's plan differentiates, and I don't think contraceptive costs really increase health care costs that much.

Next, most employers pass some of the premium costs on to their employees. One might argue that an employee who is contributing some % to the cost of her health care benefits has a right to receive the coverage she prefers.

Thirdly, if the health insurance company actually charges more for contraceptive coverage, the employee should have the right to elect and pay for that out of pocket if the organization prefers not to spend money in this direction.

Lastly, this is nothing more than a thinly veiled attempt for the organization to control the personal choice of the woman in matters that should remain highly personal.
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HUFFPOST SUPER USER
Aslow
QUALITY CONTINUUM
05:40 PM on 02/19/2012
You've got it a little wrong DeweyJ. Obama says it must be FREE! Insurance companies are not allowed to charge more for contraceptive and abortion coverage. But the Church pays the insurance company. And if they hand out contraceptives and abortions, the Church does not want to have them as their insurance company. But Obama says they must! The Church is not controlling women at all. Women can buy their own or they can get a job where contraception and abortion are given freely.Premium costs are not passed on. Obama says contraception and abortion must be FREE!
10:57 PM on 02/20/2012
Splendid, since it MUST be offered (and unwanted children cost the country and the taxpayers far, far more), then let the women have access and depend upon them to make the choice their conscience dictates. It is still about the Church controlling women.

You know, there are things of which I do not approve (certain war expenditures) that my tax $$$ go toward whether i like it or not. Let the insurance companies offer contraception and let women decide. Surely, good Catholic women know what choice to make.
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HUFFPOST SUPER USER
Cecelia Nunn Haack
Art saves lives
01:49 PM on 02/18/2012
If we had universal healthcare, Medicare for all, or another single payer system, we would not be having this debate. The time has come for America to let go of employer paid health insurance and find a more equitable and affordable way to cover everyone -- everyone in no one out.
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HUFFPOST SUPER USER
GretchenMann
02:58 AM on 02/19/2012
Exactly, Cecelia. And I think that the author alluded to this as well. Employer-based health care coverage is a very odd concept for those in many parts of the world.
09:56 AM on 02/19/2012
Or, in contrast, if we don't want to have the government provide health benefits, we should stop mandating that employers provide it. It is not the government's job to mandate what benefits employers should offer their employees.
01:39 PM on 02/19/2012
When health care coverage is employer-based, it becomes an area of legitimate concern for employment law... particularly when workplace discrimination, in the form unequal pay & benefits, is widespread and systemic. That's where this whole issue started... with the EEOC ruling of 12 years ago.
10:30 AM on 02/21/2012
"They have authority to interpret federal statutory law within their sphere of operation, and in doing so, in effect regulate."

Law Enforcement... not "regulation."

Enforcement.

"...the Commission receives, investigat­es, and resolves charges of employment discrimina­tion filed..."

Law Enforcement.... think employment discrimination police.

What law was violated?

Workplace gender discrimination -- non-parity -- in prescription drug coverage.

Discriminatory non-parity in employer-based prescription drug coverage violates the law... meaning that IT IS the government­'s job to mandate what prescription drug coverage that employers -- must provide-- their employees.
HUFFPOST SUPER USER
Robert Petrocelli
11:21 AM on 02/18/2012
A few facts:

The Centers for Disease Control and Prevention have selected Family Planning as 8th on the
list of the top 10 public health achievements of the last century (most notably access to the pill)

Catholic Charities receives over 60% of its income from the federal government.

Inclusion of contraception in the baseline of women's healthcare is good policy period.
if you want to opt out don't use the coverage.
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HUFFPOST SUPER USER
Aslow
QUALITY CONTINUUM
06:10 AM on 02/18/2012
Free is the problem. Why does it have to be free? Why do I have to pay for other people to enjoy sex? Lberals think everything should be free. It's a great idea. Look how well it.s working in Greeece.
08:17 AM on 02/18/2012
The greek government does not fund contraception at all. They are not particularly liberal either with limited sex education in schools and the most often used methods of contraception are withdrawal or repeated abortions.

Why don't you look at really liberal countries like Norway, Sweden and Denmark or better yet get a grip on why contraception is so important.
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HUFFPOST SUPER USER
Aslow
QUALITY CONTINUUM
04:37 PM on 02/19/2012
Missing my point gazbo. When government provides most of a person's needs, they always end up broke and have to stop and then the people get down right ornery.
11:34 AM on 02/18/2012
Then i am guessing you also object to paying for viagra for men. If you do, I would love to hear your objection on that.

And just to put things in perspective, you are not paying for their health coverage, they and their employers are paying. And if their employers hold back those benefits, they will loose workers to other hospitals or organizations that give such benefits. Benefits are pat of pay, and i'm sorry, you cannot tell someone how to use their salary, you may be paying, but you are paying for work done, ervices rendered, it is not your money anymore
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HUFFPOST SUPER USER
Aslow
QUALITY CONTINUUM
04:43 PM on 02/19/2012
Zosky7 you're a little confused. Viagra is related to any Catholic religious dogma, contraception is. The hospitals are completely owned and operatred by the Catholic church. Right now they nor their insurance companies pay for contraception or abortion. Obama wants them to pay the insurance companies who will then pay for contraception and abortion. The Church has a right in the Constituion of religious freedom. Women do not have a right inthe Constituion for FREE contraception or abortion.
11:19 PM on 02/17/2012
Wow. This is the longest article about the 1st amendment that has not mention the 1st amendment I ever read.
HUFFPOST SUPER USER
vikingway2deal
Progressive Liberal Flexing Muscle
03:48 PM on 02/18/2012
The first amendment does not state that it should impinge on the right of women and rape them with a Virginia probe.
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phal4875
The world is run by cats; we just feed them.
02:53 PM on 02/19/2012
Rick would probably read it that way.
HUFFPOST SUPER USER
charlesrfd2003
Proud American who believes in the Bill of Rights
10:21 PM on 02/17/2012
I don't think it is right to honor the religious objection of a particular employer. The health benefits are provided in a package that is revised as medicine changes. things are added, removed or done differently. I am almost 70 and have seen many changes. These are based on good medical practice. The health benefit is part of the pay package. The employer is not the doctor and not the medical establishment that makes these decisions. Further, the employer's objections are not relevant. Some people need to get over the paternalistic attitude. The plan belongs to the worker. not the employer.

Sometimes there is room only for one person on the top a hill and this case that person is the employee and not an employer. The Ministerial Exemption should apply only to the ministers and not the janitors, secretaries, nurses, etc. If the bishops don't like it sell their schools and hospitals. Others will be glad to run them.
09:25 AM on 02/18/2012
I worry about the death of charity hospitals, which are mostly Catholic. I lost the one in my neighborhood and have been saddened and enraged since then. It died because it offered free services to the poor, so will any plan that attempts to provide free services ad infinitum.
HUFFPOST SUPER USER
vikingway2deal
Progressive Liberal Flexing Muscle
03:36 PM on 02/18/2012
It not free the cost is built into the insurance premium, currently it is an additional cost.
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HUFFPOST SUPER USER
David Weidner
Ask me about my narcissism!
12:33 AM on 02/19/2012
If you ever been treated at a catholic hospital, the word "free" does not come to mind.
HUFFPOST SUPER USER
vikingway2deal
Progressive Liberal Flexing Muscle
03:33 PM on 02/18/2012
Awesome!!!
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09:32 PM on 02/17/2012
One of the many false statements making the rounds over this issue is, that the insurance is more expensive if it covers contraceptives. This is false. It is cheaper than the obvious alternative, which is why it is normally covered in almost all insurance plans.

Once that argument is laid to rest, there is no rational argument against having the option of free contraceptives. None whatsoever.
09:28 AM on 02/18/2012
The problem here is that insurance is being looked on as prepayment for services rather than coverage for unexpected health issues requiring us as a society to pool our resources to take the bite off something that could happen to anyone yet cannot be paid for by most alone. When you throw in things that can be purchased with knowledge that maybe you won't be able to get the high priced tv you want, all hell breaks loose.
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02:14 PM on 02/18/2012
Yes, nothing worse than health insurance paying for preventative medication...? I assume you're equally mad that they pay for pap smears and mammograms?
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HUFFPOST SUPER USER
xenubarb
Nebulon V
07:09 PM on 02/18/2012
"Unexpected health issues..."

Like pregnancy?
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HUFFPOST SUPER USER
xenubarb
Nebulon V
07:08 PM on 02/18/2012
Nobody ever accused religions of being rational.
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phal4875
The world is run by cats; we just feed them.
02:56 PM on 02/19/2012
Fanned. At least one would hope not.