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Saperstein: "...we also believe that women of all faiths and no faith are entitled to access to contraception as a matter of basic rights and fundamental dignity - and that for some women, access to birth control is an extension of their own religious liberty which deserves to be protected just as aggressively as that of the employer. We commend the Administrations commitment to this principle."
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Washington, D.C., April 8, 2013 - Today, Rabbi David Saperstein, Director of the Religious Action Center of Reform Judaism, submitted public comments on the Obama Administrations Notice of Proposed Rulemaking regarding preventative care and contraceptive coverage under the Affordable Care Act. The proposed rule improves upon an earlier iteration by ensuring that the definition of religious employers reflects that found elsewhere in federal code. The proposed rule also upholds the values of both religious liberty and a womans right to access contraception.
The full text of Rabbi Sapersteins comments follow:
April 8, 2013
Dear Secretary Sebelius,
On behalf of the Union for Reform Judaism whose nearly 900 congregations across North America encompass 1.3 million Reform Jews, and the Central Conference of American Rabbis, with membership of over 1800 Reform rabbis, I am pleased to submit comments in response to the Notice of Proposed Rulemaking on womens preventative services and contraception coverage under the Affordable Care Act.
As a religious organization dedicated both to maintaining the separation of church and state and to ensuring equal access to health care for all, we recognize and respect the tension between contraception access and religious liberty. We appreciate that the problematic definition of religious employers included in the initial proposed rule has been clarified and now reflects that found elsewhere in federal code. In particular, we are encouraged that the Administration concurred with the position we have espoused from the beginning - that whatever exemption religious organizations are entitled to should not depend on the faith of the people to whom they provide social services nor that of those who they hire to provide such services.
However, we also believe that women of all faiths and no faith are entitled to access to contraception as a matter of basic rights and fundamental dignity _ and that for some women, access to birth control is an extension of their own religious liberty which deserves to be protected just as aggressively as that of the employer. We commend the Administrations commitment to this principle. Employees receiving insurance through organizations covered by the accommodation must continue to have seamless access to birth control and other preventative services through their third party insurer or administrator. This must include employees of self-insured accommodated organizations. We recognize that with self-insured parties, the tension between competing claims of religious liberty and womens rights is more complicated, but in the end female employees in these organizations are still entitled to receive seamless access to contraception. Under one of the options outlined in the current proposal, "a third party administrator...would have an economic incentive to voluntarily arrange for the separate individual health insurance policies for contraceptive coverage for plan participants and beneficiaries." By merely incentivizing - not requiring - insurers to contract with third party administrators to provide contraception plans to employees of accommodated organizations, the proposed rule could potentially leave women without coverage, should the third party administrator not be able to secure a willing insurer. We support the incorporation in the final rule of the other two proposed options that instead legally require third party providers to contract with an insurance company to provide contraception access, thereby guaranteeing that all women can acquire the medicines they need.
Additionally, the NPRM establishes a system by which an accommodated organization that chooses to not provide contraception to its employees can simply rely upon the third party insurer or administrator to relay this information to the employees. This too is a complex issue in which many competing claims are at stake. Yet we hope that the final rule will require objecting entities, at a minimum, to direct their employees to where they can receive information about their contraception coverage . Seamless access for employees of accommodated organizations needs to be addressed, secured and protected - all women must have knowledge, awareness and coverage.
The Reform Movement has long been a staunch supporter of womens reproductive rights and strongly advocated for the inclusion of contraception coverage in the Affordable Care Act. Our Jewish texts and teachings inform our understanding that every woman is entitled to access and make her own decisions about reproductive health care. At the same time, we have worked tirelessly to ensure that the Constitutions assurance of religious freedom is upheld. We thank the Administration for its continued commitment to both of these principles in the Notice of Proposed Rulemaking.
Rabbi David Saperstein
Director, Religious Action Center