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As you may be aware, the federal government’s Department of Health and human Services (HHS) has proposed a morally bankrupt new regulation that, if implemented, will go into effect in 2012. It would require that all insurance programs nationwide cover all forms of contraception – including abortifacient drugs such as Plan B and Ella – and sterilization as “preventive services for women.” The regulation includes a so-called “religious employer exemption.” But it is so extremely narrow that it protects almost no one. As the chair of the U.S. Conference of Catholic Bishops Committee on Pro-Life Activities, Cardinal Daniel DiNardo, put it, “Jesus himself, or the Good Samaritan of his famous parable, would not qualify as ‘religious enough’ for the exemption, since they insisted on helping people who did not share their view of God.”
US law requires that regulators allow the public, people who are affected by regulation, to weigh in before the regulation goes into effect. Below is the comment that the St. Paul Center for Biblical Theology submitted. If you would like to comment as well, just click on this link and fill in the form.
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http://www.regulations.gov/#!documentDetail;D=IRS-2010-0040-0006
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To Whom it May Concern,
I am writing on behalf of the St. Paul Center for Biblical Theology in regard to the proposed Requirements for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services under Patient Protection and Affordable Care Act (Document ID IRS-2010-0040-0006).
This regulation needs to be withdrawn or significantly modified from its proposed form. Making this insurance coverage mandatory will violate the consciences of people of faith and infringe on our first amendment right to the free exercise of our religion. The St. Paul Center is a Catholic institution. For the government to mandate contraception and sterilization coverage in our insurance plans directly undermines our mission.
Our Catholic faith teaches us to care for the whole person, including their bodily health and well-being. Accordingly, we have always provided full health coverage for our employees. However, we firmly believe that normal human fertility and the new life that it brings are not sicknesses to be “treated” with contraception, sterilization, and abortifacient drugs. These things are no part of ethical health care and this unprecedented federal mandate is an outrage against men and women of faith.
The religious exemption language in the current proposed regulation is wholly inadequate to protect the conscience rights of institutions like ours.
In assessing the likely effects of this regulation, we would ask regulators to consider whether it might be at odds with both of the primary stated goals of the underlying legislation. The Patient Protection and Affordable Care Act sought both to control the growth of health care costs nationally and to reduce the number of the uninsured. This regulation imposes additional costs and gives strong incentives to institutions of faith, however reluctantly, to drop their employer-provided health coverage.