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Smart Benefits: Two Regs Issued on Contraceptive Coverage

Monday, September 01, 2014

 

Two regulations on contraceptive coverage were recently issued by the Department of Health and Human Services (HHS), the Department of Labor (DOL) and the Treasury that impact closely held for-profits and religious non-profits.

• Proposed regulations on how certain closely held for-profit organizations can exclude some or all contraceptive coverage. Following the June 20 Supreme Court decision in the Hobby Lobby case that ruled closely-held, for-profit corporations can’t be required to cover contraceptives that violate the owners’ religious beliefs, the proposed regulations would allow certain closely held for-profit organizations to opt out of providing contraceptive coverage. In these situations, insurers or TPAs would provide contraceptive coverage at no cost, the same way they currently do for religious non-profit organizations that opt out of contraceptive coverage.

The proposed regulations also seek input on how to define a closely held for-profit organization that would be eligible to opt out. Two alternative proposed definitions are:

• Not publicly traded, and ownership is limited to a certain number of owners; or

• Not publicly traded, and a minimum percentage of ownership is concentrated among a certain number of owners

A 60-day comment period for input on the proposed regulations is now open.

• Interim final regulations about eligible organizations’ communication for opting out of contraceptive coverage. Since some religious non-profit organizations such as charities, hospitals and schools have objected to signing the current self-certification form required to opt out of providing contraceptive coverage, the interim final regulations allow eligible organizations to notify HHS in writing of their objection to contraceptive coverage rather than using the form. Once HHS receives this information, HHS (or the DOL for self-funded plans) will notify the insurer or TPA.

Eligible organizations can still choose to use the self-certification form.

Amy Gallagher has over 21 years of healthcare industry experience guiding employers and employees. As Vice President at Cornerstone Group, she advises large employers on all aspects of healthcare reform, benefit solutions, cost-containment strategies and results-driven wellness programs. Amy speaks regularly on a variety of healthcare-related topics, and is often quoted by national publications on the subject matter. Locally, Amy is a member of SHRM-RI, the Rhode Island Business Group on Health, and the Rhode Island Business Healthcare Advisory Council.

 

Related Slideshow: New England’s Healthiest States 2013

The United Health Foundation recently released its 2013 annual reoprt: America's Health Rankings, which provides a comparative state by state analysis of several health measures to provide a comprehensive perspective of our nation's health issues. See how the New England states rank in the slides below.

 

Definitions

All Outcomes Rank: Outcomes represent what has already occurred, either through death, disease or missed days due to illness. In America's Health Rankings, outcomes include prevalence of diabetes, number of poor mental or physical health days in last 30 days, health disparity, infant mortality rate, cardiovascular death rate, cancer death rate and premature death. Outcomes account for 25% of the final ranking.

Determinants Rank: Determinants represent those actions that can affect the future health of the population. For clarity, determinants are divided into four groups: Behaviors, Community and Environment, Public and Health Policies, and Clinical Care. These four groups of measures influence the health outcomes of the population in a state, and improving these inputs will improve outcomes over time. Most measures are actually a combination of activities in all four groups. 

Diabetes Rank: Based on percent of adults who responded yes to the question "Have you ever been told by a doctor that you have diabetes?" Does not include pre-diabetes or diabetes during pregnancy.

Smoking Rank: Based on percentage of adults who are current smokers (self-report smoking at least 100 cigarettes in their lifetime and currently smoke).

Obesity Rank: Based on percentage of adults who are obese, with a body mass index (BMI) of 30.0 or higher.

Source: http://www.americashealthrankings.org/

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6. Rhode Island

Overall Rank: 19

Outcomes Rank: 30

Determinants Rank: 13

Diabetes Rank: 26

Smoking Rank: 14

Obesity Rank: 13

 

Strengths:

1. Low prevalence of obesity

2. High immunization coverage among adolescents

3. Ready availability of primary care physicians  

Challenges:

1.High rate of drug deaths

2. High rate of preventable hospitalizations

3. Large disparity in heath status by educational attainment

Source: http://www.americashealthrankings.org/RI

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5. Maine

Overall Rank: 16

Outcomes Rank: 25

Determinants Rank: 12

Diabetes Rank: 23

Smoking Rank: 29

Obesity Rank: 28

 

Strengths:

1. Low violent crime rate

2. Low percentage of uninsured population

3. Low prevalence of low birthweight  

Challenges:

1. High prevalence of binge drinking

2.High rate of cancer deaths

3. Limited availability of dentists

Source: http://www.americashealthrankings.org/ME

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4. Connecticut

Overall Rank: 7

Outcomes Rank: 15

Determinants Rank: 4

Diabetes Rank: 16

Smoking Rank: 4

Obesity Rank: 12

 

Strengths:

1. Low prevalence of smoking

2. Low incidence of infectious diseases

3. High immunization coverage among children & adolescents  

Challenges:

1. Moderate prevalence of binge drinking

2. Low high school graduation rate

3. Large disparity in health status by educational attainment

Source: http://www.americashealthrankings.org/CT

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3. New Hampshire

Overall Rank: 5

Outcomes Rank: 7

Determinants Rank: 5

Diabetes Rank: 16

Smoking Rank: 11

Obesity Rank: 22

 

Strengths:

1. Low percentage of children in poverty

2. High immunization coverage among children

3. Low infant mortality rate  

Challenges:

1. High prevalence of binge drinking

2.High incidence of pertussis infections

3. Low per capita public health funding

Source: http://www.americashealthrankings.org/NH

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2. Massachusetts

Overall Rank: 4

Outcomes Rank: 14

Determinants Rank: 3

Diabetes Rank: 10

Smoking Rank: 7

Obesity Rank: 2

 

Strengths:

1. Low prevalence of obesity

2. Low percentage of uninsured population

3. Ready availability of primary care physicians & dentists  

Challenges:

1. High prevalence of binge drinking

2. High rate of preventable hospitalizations

3. Large disparity in health status by educational attainment

Source: http://www.americashealthrankings.org/MA

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1. Vermont

Overall Rank: 2

Outcomes Rank: 12

Determinants Rank: 1

Diabetes Rank: 4

Smoking Rank: 9

Obesity Rank: 5

 

Strengths:

1. High rate of high school graduation

2. Low violent crime rate

3. Low percentage of uninsured population  

Challenges:

1. High prevalence of binge drinking

2. Low immunization coverage among children

3. High incidence of pertussis infections

Source: http://www.americashealthrankings.org/VT

 
 

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