One Blogger’s New Departure Point — Advice To HR And Benefits Professionals, Nationwide: ACA of 2010 Implementation Edition

I don’t usually feature HR specific guidance, but this one caught my eye. It also happens that I am just a lil’ vexed by the small handful of public carrier insurers trying to cash federal checks, while pretending not to know that “free” really means. . . free. And so, Mr. Obama is quite right, here: the law simply requires complete coverage for truly free birth control, one product in each category of drug or device — at a minimum. So do take heed.

Here is the great resource provided by EBN.com — do go read it all:

. . . .For example, health plans must cover – without cost-sharing – at least one form of contraception in each of the 18 method categories defined by Federal Drug Administration. “For the hormonal contraceptive methods, coverage therefore must include (but is not limited to) all 3 oral contraceptive methods (combined, progestin-only, and extended/continuous use), injectables, implants, the vaginal contraceptive ring, the contraceptive patch, emergency contraception (Plan B/Plan B One Step/Next Choice), emergency contraception (Ella), and IUDs with progestin. Accordingly, a plan or issuer may not impose cost sharing on the ring or the patch,” according to the FAQ. . . .

Moreover, plans cannot limit sex-specific recommended preventive services based on an individual’s assigned sex at birth or recorded gender. The FAQ notes that where a health care provider determines that a recommended preventive service is medically appropriate for an individual – “such as, for example, providing a mammogram or pap smear for a transgender man who has residual breast tissue or an intact cervix” – the plan or issuer must provide coverage for the recommended preventive service without cost-sharing.

“That’s a level of detail I don’t think we’ve seen elsewhere either in the preventive services guidance under ACA or the other ACA guidance,” notes Bergner.

The FAQ also notes that plans must implement an exceptions process so that if a patient’s medical provider recommends a different contraceptive based on medical necessity within a certain category, that contraceptive must also be covered without cost-sharing. . . .

Savvy HR professionals will take note — and make sure that their employers, and their plans, and those from whom they buy coverage, provide this truly free coverage. There are now rather substantial penalties for even negligent non-compliance. It is the law, folks — and it is important to preserve a woman’s meaningful right. . . to choose. Onward.

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