In a low key announcement Friday afternoon, HHS added a new wrinkle to the preventive care requirements for birth control coverage. Last summer, HHS published a rule that required non-grandfathered health plans to cover all FDA-approved birth control under the preventive care regulations. The new rule, which takes effect January 1, 2013 for calendar year plans, requires all FDA-approved birth control to be covered with no out-of-pocket cost. It still remains unclear what exact type of services are included within this rule.
On Friday afternoon, HHS announced that nonprofit employers who are affiliated with religious employers and who do not currently cover birth control in their plans will have an extra year to comply. The extension would cover nonprofits such as schools, daycare centers and potentially colleges and universities, if they are affiliated with religious organizations. At the same time, direct religious organizations, such as churches, remain totally exempt from the requirement. HHS has promised to release the updated guidance within the coming days. Currently, the only public announcement is posted to the HHS website here: http://www.hhs.gov/news/press/2012pres/01/20120120a.htmlDisclaimer
While we are pleased to have you contact us by telephone, surface mail, electronic mail, or by facsimile transmission, contacting Kilpatrick Townsend & Stockton LLP or any of its attorneys does not create an attorney-client relationship. The formation of an attorney-client relationship requires consideration of multiple factors, including possible conflicts of interest. An attorney-client relationship is formed only when both you and the Firm have agreed to proceed with a defined engagement.
DO NOT CONVEY TO US ANY INFORMATION YOU REGARD AS CONFIDENTIAL UNTIL A FORMAL CLIENT-ATTORNEY RELATIONSHIP HAS BEEN ESTABLISHED.
If you do convey information, you recognize that we may review and disclose the information, and you agree that even if you regard the information as highly confidential and even if it is transmitted in a good faith effort to retain us, such a review does not preclude us from representing another client directly adverse to you, even in a matter where that information could be used against you.
