Public Comment on Female Contraception Mandate

I submitted my public comment on this issue as included below and encourage all concerned to do the same. Click here to offer your comments on these proposed regulations.


February 8, 2013

TO: US Department of Health and Human Services

I offer the following as a public comment concerning RIN 0938-AR42: Coverage of Certain Preventive Services Under the Affordable Care Act.

The proposed regulations attempt to selectively address faith and conscience based objections to a government mandate that organizations offering health insurance plans be required to pay for free contraceptives for their female employees.

After considering the regulations and the government’s arguments in support of a mandate any reasoned citizen might ask whether those praying at the altar of government should be entitled under our Constitution to impose their will upon those who pray at a religious altar, or upon those unaffiliated with a recognized religion having conscientious objections to paying to socialize the cost of female contraception.

Chiquita Brooks-LaSure, Deputy Director of Policy and Regulation at the Center for Consumer Information and Insurance Oversight at the U.S. Department of Health and Human Services held a conference call on February 1, 2013 to announce revised proposed rules for socializing the cost of female contraceptives as those rules impact religious organizations.

Of particular note in the conference call was a question by an NPR reporter and the response of Chiquita Brooks-LaSure. The reporter asks whether it isn’t really the insurance companies who will be paying the cost of free contraceptives given to employees of religious organizations who request such coverage under the proposed rules, or won’t the Federal government really be paying the cost for those employees under self-funded health insurance plans offered by religious organizations?

In response, Ms. Brooks-LaSure notes that since “studies have shown” overall health costs are reduced when female contraceptives are provided free, insurance companies will realize an overall cost savings by paying for those costs. If this were true, in an open and competitive market, insurance companies would voluntarily include free contraceptives within coverages as doing so will save both the companies and the employees money while improving health care, and there would be no need for us to pay Ms. Brooks-LaSure’s salary let alone have to deal with a new 80 page proposed rule or any free contraception mandate at all. If free contraceptives actually reduce overall health care costs as claimed by the government, a competitive insurance industry would be foolish not to offer such coverage in all health plans, and those women declining free contraceptives would then rationally be subject to a higher, rather than lower premium payment.

Again, in response to the question as directed to self-insured organizations, Ms. Brooks-LaSure notes that the user fees under the Affordable Care Act paid by health plan administrators would be credited for the cost of providing the contraceptive coverage. While Ms. Brooks-LaSure doesn’t think that means the Federal government is paying for that credit, the reality is that we would be paying, as user fees supporting the government’s over site of Obamacare are reduced through such credits, which dollars will necessarily be made up from another Federal bucket.

The emptiness of the government’s reasoning in proposing religious exceptions reveals that those same flaws exist in the reasoning underlying socialization of the cost of female reproductive health services in the first place. What we really have here are competing belief systems, the Obama administration/HHS versus personally held religious beliefs and individual conscientious objections. No religion is entitled to impose its moral views on American citizens and no government is entitled to impose its moral views on any religion or individual.

The American solution to increasing access to female contraception is to make such products available over-the-counter and to provide Federal regulation requiring state laws to assure open competition in the health insurance markets.

Regulations such as those proposed here legitimately incite the resentment of millions of Americans who cherish their personal freedoms. Such regulations are completely unnecessary to the end of increasing access to female contraception and constitute an unacceptable intrusion into our private lives and pocketbooks, and an unacceptable challenge to our right to act in ways consistent with our individual moral beliefs.


Regards, Pete Weldon

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