So please, take some time to read The Center's assessment, composed and researched by our director of Bioethics and Public Policy, Dr. Marie Hilliard, HERE. Then ACT and write to our government. Lend your strength to the voices of Faith, Justice, and the Good.
And most of all, pray for the outcome of these proceedings. May God's will be done.
Here is an excerpt from Marie's writing:
The NPRM [Notice of Proposed Rule Making] seeks public comment on the Proposed Rule, the “Summary” of which states:
The proposed rules would amend the authorization to exempt group health plans established or maintained by certain religious employers (and group health insurance coverage provided in connection with such plans) with respect to the requirement to cover contraceptive services. The proposed rules would also
establish accommodations for group health plans established or maintained by eligible organizations (and group health insurance coverage offered in connection with such plans), including student health insurance coverage arranged by eligible organizations that are religious institutions of higher
In fact, the Proposed Rule itself asserts that “The Departments believe that this Proposed Rule would not expand the universe of employer plans that would qualify for the exemption beyond that which was intended in the 2012 final rules.”7 Thus, pursuant to this Proposed Rule, most, if not all, of our membership will not be exempt and will be subject to the violations of their religious freedom and their conscientious objections to these methods by the mandates contained in the Proposed Rule.
6 78 Fed. Reg. 8456-8476 (February 6, 2013), at 8456-8457.
7 Ibid, 8461.
The Center wishes to comment on the following concerns pertaining to the Proposed
Rule in the NPRM:
1. The Proposed Rule continues to create new law by narrowly defining which organizations the federal government arbitrarily will recognize as exempt: “Religious employers,” which basically include only “churches, their integrated auxiliaries, and conventions or associations of churches,” or “the exclusively religious activities of any religious order.”8
The Proposed Rule violates the Establishment Clause of the First Amendment9 of the U.S. Constitution in that de facto the Proposed Rule is establishing what the administration considers to be a religious organization. It is creating an arbitrary definition and legal recognition of some religious organizations, inconsistent with federal law, deeming some, but not others, to have an equal protection under the First Amendment of the U.S. Constitution and the Religious Freedom Restoration Act.10 Specifically, despite the fact that thousands of other religious organizations are recognized under a federal Group Ruling11 as being organized and operating as non-profit religious organizations, they are being deemed, under this legally
inaccurate and arbitrary delineation, as not religious enough to be exempt from the mandated
8 Internal Revenue Code section 6033(a)(3)(A)(i) and (iii), as cited in 78 Fed. Reg. 8458.
9 U.S. Constitution: First Amendment.
10 42 U.S.C. § 2000bb through 42 U.S.C. § 2000bb-4.
11 In 1946 the Internal Revenue Service (IRS) issued to the United States Conference of Catholic Bishops and its predecessor organization, a group tax exemption ruling to Catholic organizations listed in The Official Catholic Directory (OCD). This is updated annually. The Group Ruling establishes (1) that organizations included in the OCD are exempt from federal income tax under section 501(c)(3) of the Code and from federal unemployment tax; and (2) that contributions to such organizations are deductible for federal income, gift, and estate tax purposes. See: http://www.usccb.org/about/general-counsel/upload/group-ruling-memo.pdf.