Health Care Reform: Women's Preventive Care Services
On August 1, 2011, in an amendment to the Patient Protection and Affordable Care Act (PPACA) Interim Final Regulations, the Department of Health and Human Services (HHS) specified the women's preventive care services that will be required under non-grandfathered insured and self-insured group health plans and individual policies. This list of services adopted the recently released recommendations of the Institute of Medicine.
The amendment requires that all defined women's preventive care services be covered without co-payments, coinsurance or deductibles. Plans will be required to come into compliance effective as of the next plan year beginning on or after August 1, 2012. Women's preventive care services will include:
- Annual "well woman" visits;
- Gestational diabetes screening;
- For women 30 years of age and older, genital human papillomavirus (HPV) DNA testing;
- Counseling on sexually transmitted infectious diseases;
- Screening and counseling for human immunodeficiency virus (HIV);
- Contraception methods approved by the Food and Drug Administration (FDA);
- Contraceptive counseling;
- Domestic violence screening and counseling; and
- Breastfeeding support, counseling and supplies
While contraceptive drugs (including intrauterine devices, the "morning after" pill, and implantable hormone contraceptives) must be covered without any cost-sharing, plans may require cost-sharing for brand name drugs if an approved generic of the brand name drug is available.
There is a contraceptive services exemption in the law for religious employers. The regulations give the Health Resources and Services Administration (HRSA) the responsibility to develop the exemption rules. Any employer seeking a religious exemption should consult with their plan counsel before proceeding to ensure that they are eligible for the exemption and in compliance with the final plan design guidelines.
We are, as always, available to you for any questions relating to this notice, or any other employee benefit issues or concerns.
Bollinger offers the above information for the education of our clients. It is not intended to be legal or actuarial advice. If such advice is required, we strongly recommend that you consult with your current professional advisor or engage a licensed professional.