A new set of tri-agency FAQs has clarified several issues related to the preventive care mandate. Among the highlights:
- BRCA Testing. A plan subject to the preventive care mandate must cover (without cost-sharing) BRCA genetic testing for women who have had a prior non-BRCA-related breast cancer or ovarian cancer diagnosis, even if those women are currently asymptomatic and cancer-free and even if there is no family history of BRCA-related cancer.
- Contraception. A plan subject to the preventive care mandate must cover (without cost-sharing) at least one form of contraception in each of the 18 distinct categories of contraceptive methods identified by the FDA. A plan may use reasonable medical management techniques to encourage use of specific services or FDA-approved items within a particular category (such as steering individuals toward generic prescription drugs), so long as the plan maintains an accessible and expedient exceptions process to allow for coverage (without cost-sharing) of a particular service or item determined by an individual's attending provider to be medically necessary for that individual.
- Well-Woman Preventive Care for Dependents. If a plan subject to the preventive care mandate covers dependent children, such children must be provided (without cost-sharing) the full range of recommended preventive services applicable to them based on their age group and health condition. This may include, for example, covering services for prenatal care of a pregnant dependent child.
- Colonoscopy and Anesthesia Services. If a colonoscopy is performed as a preventive screening procedure, a plan subject to the preventive care mandate may not impose cost sharing with respect to anesthesia services performed in connection with the colonoscopy if the attending provider determines that anesthesia would be medically appropriate for the individual. (And don't we all hope that most providers would deem anesthesia services to be medically appropriate when administering a colonoscopy?)
The FAQs can be accessed here: www.dol.gov/ebsa/faqs/faq-aca26.html