Re: CMS–9925–IFC; Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act

Dear Acting Secretary Hargan:
 
The American Congress of Obstetricians and Gynecologists (ACOG), the American Academy of Pediatrics, and the Society for Adolescent Health and Medicine, write in response to the Interim Final Rule (IFR) with request for comments for Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act published in the Federal Register on October 13, 2017 at 82 FR 47792 et seq. Section 2713 of the Public Health Service (PHS) Act, as passed by the Patient Protection and Affordable Care Act (ACA), requires all non-grandfathered individual and group health plans to offer coverage of women’s preventive services with no cost-sharing. Contraception and contraceptive counseling are a cornerstone of effective prevention in women’s health. Section 2713 of the PHS Act represents an agreement among policymakers and physicians that preventive care is critically important and helps avoid the use of costlier specialty care.

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Re: CMS–9940–IFC; Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act

Dear Acting Secretary Hargan:

The American Congress of Obstetricians and Gynecologists (ACOG), the American Academy of Pediatrics, and the Society for Adolescent Health and Medicine, write in response to the Interim Final Rule (IFR) with request for comments for Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act published in the Federal Register on October 13, 2017 at 82 Fed. Reg. 47838 et seq. Section 2713 of the Public Health Service (PHS) Act, as passed by the Patient Protection and Affordable Care Act (ACA), requires all non-grandfathered individual and group health plans to offer coverage of women’s preventive services with no cost-sharing. Contraception and contraceptive counseling are a cornerstone of effective prevention in women’s health. Section 2713 of the PHS Act represents an agreement among policymakers and physicians that preventive care is critically important and helps avoid the use of costlier specialty care.

Read the full letter

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