The agencies have kicked off August with headline-grabbing guidance detailing the first-dollar preventive services that non-grandfathered group health plans must provide for women. The list of women’s preventive services was developed by the Institute of Medicine and adopted by the Health Resources and Services Administration. In brief, the preventive services and frequency are as follows:
- Well-Woman Visits – Annually (with additional visits as necessary)
- Screening for Gestational Diabetes – Between 24-28 weeks of gestation, and at first prenatal visit for high-risk women
- Human papillomavirus (HPV) DNA Testing – Every three years starting at age 30
- Sexually-Transmitted Infections Counseling – Annually
- HIV Counseling and Screening – Annually
- FDA-Approved Contraception, Sterilization Procedures, and Counseling – As prescribed
- Breastfeeding Support, Supplies, and Counseling – Each birth
- Domestic Violence Screening and Counseling – Annually
Non-grandfathered group health plans must provide these preventive services to women with no cost-sharing, starting with the first plan year beginning on or after August 1, 2012 (January 1, 2013 for calendar-year plans). Grandfathered plans are not subject to the preventive services rules under health care reform.
These new guidelines for women’s preventive services add to the initial list of preventive services that were covered in the agencies’ July 2010 interim final regulations, which we discussed in a previous post.
In addition to the new guidelines, the agencies also released a new interim final rule on August 1 that would exempt “religious employers” from covering contraceptive services for women. An organization may be considered a “religious employer” if the organization’s purpose is inculcation of religious values, and the organization primarily employs and serves persons who share the organization’s religious tenets.
The latest guidance helpfully clarifies the scope of what preventive services means for women, but many questions still remain about preventive care under health care reform. Comments on the interim final rule are due within 60 days of publication in the Federal Register, which is currently scheduled for August 3.