AFFORDABLE CARE ACT AND WOMEN’S PREVENTIVE SERVICES

Beginning on January 1, 2013, calendar year, non-grandfathered group health plans must provide coverage of certain women’s preventive services without cost sharing – that is, no co-pay or deductible.  The Health Resources and Services Administration of the Department of Health and Human Services (HHS) has issued guidelines on this subject which were developed by the Institute of Medicine.

The guidelines require plans to provide coverage for the following preventive services without cost sharing if the services are provided in-network: 

  • Well-woman visits – Annually, with additional visits as necessary.
  • Screening for gestational diabetes – Between weeks 24 and 28 of gestation, and at the first prenatal visit for high-risk women.
  • Testing for high-risk human papillomavirus (HPV) – Every three years beginning at age 30.
  • Counseling for sexually transmitted infections – Annually.
  • Counseling and screening for HIV – Annually.
  • Contraceptive methods and counseling – Annually, subject to certain religious employer exemptions.
  • Breastfeeding support, supplies, and counseling – In conjunction with each birth.
  • Screening and counseling for interpersonal and domestic violence – Annually.

Cost sharing is permitted if these services are performed by out-of-network providers.

These eight categories of services are in addition to numerous other preventive services for women covered under the Affordable Care Act.  More complete information is available at HHS’s website, www.hrsa.gov/womensguidelines.  That site also provides links to additional resources on the subject.

Additional guidance is expected to address these matters in greater detail, so plan sponsors should be watching for those publications.

With an emphasis on litigation, Sara Hauptfuehrer’s practice focuses on Title I of the Employee Retirement Income Security Act of 1974 (ERISA). She also handles employment discrimination litigation and counsels on a number of employee benefits-related issues.
 
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