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	<title>Comments on: Provision, Payment, and Prevarication: A Response to Grant Gallicho</title>
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	<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/</link>
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		<title>By: N.D.</title>
		<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/comment-page-1/#comment-91216</link>
		<dc:creator>N.D.</dc:creator>
		<pubDate>Thu, 21 Feb 2013 21:21:04 +0000</pubDate>
		<guid isPermaLink="false">http://www.firstthings.com/blogs/firstthoughts/?p=57702#comment-91216</guid>
		<description><![CDATA[What we do know, is that it is not unjust discrimination, nor is it gender discrimination, to suggest that members of Religious Groups, which consist of Religious individuals, have a right to purchase Health Insurance from an Insurance Company that does not condone the contraception mentality.]]></description>
		<content:encoded><![CDATA[<p>What we do know, is that it is not unjust discrimination, nor is it gender discrimination, to suggest that members of Religious Groups, which consist of Religious individuals, have a right to purchase Health Insurance from an Insurance Company that does not condone the contraception mentality.</p>
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		<title>By: N.D.</title>
		<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/comment-page-1/#comment-91215</link>
		<dc:creator>N.D.</dc:creator>
		<pubDate>Thu, 21 Feb 2013 21:17:55 +0000</pubDate>
		<guid isPermaLink="false">http://www.firstthings.com/blogs/firstthoughts/?p=57702#comment-91215</guid>
		<description><![CDATA[What we do know, is that it is not unjust discrimination, nor is it gender discrimination, to suggest that members of Religious Groups, which consist of Religious individuals, have a right to purchase Health Insurance that is Life-affirming and Life-sustaining from an Insurance Company that does not provide contraception coverage and thus does not condone the use of contraception, which is not Life-affirming or Life-sustaining, and in some cases, destroys Human Life, promotes promiscuity and the sexual objectification of the Human Person, &quot;violates the Gift of Self, while closing off the Gift of Life&quot;, does not serve the Common Good, and is thus not Good for our posterity or the  prosperity of this Nation or The World.]]></description>
		<content:encoded><![CDATA[<p>What we do know, is that it is not unjust discrimination, nor is it gender discrimination, to suggest that members of Religious Groups, which consist of Religious individuals, have a right to purchase Health Insurance that is Life-affirming and Life-sustaining from an Insurance Company that does not provide contraception coverage and thus does not condone the use of contraception, which is not Life-affirming or Life-sustaining, and in some cases, destroys Human Life, promotes promiscuity and the sexual objectification of the Human Person, &#8220;violates the Gift of Self, while closing off the Gift of Life&#8221;, does not serve the Common Good, and is thus not Good for our posterity or the  prosperity of this Nation or The World.</p>
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		<title>By: Josh DeCuir</title>
		<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/comment-page-1/#comment-91178</link>
		<dc:creator>Josh DeCuir</dc:creator>
		<pubDate>Thu, 21 Feb 2013 18:07:32 +0000</pubDate>
		<guid isPermaLink="false">http://www.firstthings.com/blogs/firstthoughts/?p=57702#comment-91178</guid>
		<description><![CDATA[&quot;It is not possible to draw the conclusion you do from what Drum said.&quot;

It&#039;s Drum&#039;s conclusion, not mine.  Drum is saying IF contraceptives were proven to be the cost-saver they are purported by the Administration to be, THEN one would expect them to be a more regular feature of coverage.  Indeed, the very fact that Administration is mandating such coverage as part of the ACA belies that they are not a regular feature.

Indeed, he updates his post to state that, whatever the frequency of the coverage, the claim that these are huge cost-savers that pays for itself is not warranted by the existing evidence.  So Drum&#039;s (and my) claim is that there is no evidence that warrants the suggestion being made that people are not paying for this coverage because they pay for themselves.  So we have distinct issues: whether they are included routinely in coverage, and whether, if they are, they prove to pay for themselves.  Drum is addressing the second part, but mentions the first.  You have staked your flag in the first to warrant the second. 

I would think a bit more humility in the face of not-knowing would be a welcome addition to this dialgoue.]]></description>
		<content:encoded><![CDATA[<p>&#8220;It is not possible to draw the conclusion you do from what Drum said.&#8221;</p>
<p>It&#8217;s Drum&#8217;s conclusion, not mine.  Drum is saying IF contraceptives were proven to be the cost-saver they are purported by the Administration to be, THEN one would expect them to be a more regular feature of coverage.  Indeed, the very fact that Administration is mandating such coverage as part of the ACA belies that they are not a regular feature.</p>
<p>Indeed, he updates his post to state that, whatever the frequency of the coverage, the claim that these are huge cost-savers that pays for itself is not warranted by the existing evidence.  So Drum&#8217;s (and my) claim is that there is no evidence that warrants the suggestion being made that people are not paying for this coverage because they pay for themselves.  So we have distinct issues: whether they are included routinely in coverage, and whether, if they are, they prove to pay for themselves.  Drum is addressing the second part, but mentions the first.  You have staked your flag in the first to warrant the second. </p>
<p>I would think a bit more humility in the face of not-knowing would be a welcome addition to this dialgoue.</p>
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		<title>By: David Nickol</title>
		<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/comment-page-1/#comment-91057</link>
		<dc:creator>David Nickol</dc:creator>
		<pubDate>Wed, 20 Feb 2013 19:33:50 +0000</pubDate>
		<guid isPermaLink="false">http://www.firstthings.com/blogs/firstthoughts/?p=57702#comment-91057</guid>
		<description><![CDATA[&lt;i&gt;If this were true, insurance companies would routinely make contraceptive coverage a feature of all their group policies without even being asked. But they don’t. &lt;/i&gt;

Josh DeCuir,

Your statement was, &quot;Drum states that most policies do not provide such coverage [contraception and abortion].&quot; What Drum says above is that they do not make such coverage a feature of &lt;i&gt;all&lt;/i&gt; their group policies &lt;i&gt;without even being asked.&lt;/i&gt; It is not possible to draw the conclusion you do from what Drum said. Just because they do not provide the coverage in &lt;i&gt;all&lt;/i&gt; their policies does not mean they do not supply it in &lt;i&gt;most.&lt;/i&gt; And just because they do not supply it &lt;i&gt;without being asked&lt;/i&gt; does not mean they don&#039;t supply it.   

&lt;i&gt;I would hesitate before I uniformly dismiss his claim as “certainly wrong.”&lt;/i&gt;

Drum&#039;s claim is no doubt true. It&#039;s true if only, say, 5% of group policies don&#039;t have contraceptive coverage unless it is requested. But saying &quot;not all do&quot; is quite different from saying &quot;most don&#039;t.&quot; The information I gave above from the National Conference of State Legislators is much more suggestive of what insurance companies actually do &lt;i&gt;most&lt;/i&gt; of the time than Drum&#039;s statement, from which no significant conclusions can be drawn.]]></description>
		<content:encoded><![CDATA[<p><i>If this were true, insurance companies would routinely make contraceptive coverage a feature of all their group policies without even being asked. But they don’t. </i></p>
<p>Josh DeCuir,</p>
<p>Your statement was, &#8220;Drum states that most policies do not provide such coverage [contraception and abortion].&#8221; What Drum says above is that they do not make such coverage a feature of <i>all</i> their group policies <i>without even being asked.</i> It is not possible to draw the conclusion you do from what Drum said. Just because they do not provide the coverage in <i>all</i> their policies does not mean they do not supply it in <i>most.</i> And just because they do not supply it <i>without being asked</i> does not mean they don&#8217;t supply it.   </p>
<p><i>I would hesitate before I uniformly dismiss his claim as “certainly wrong.”</i></p>
<p>Drum&#8217;s claim is no doubt true. It&#8217;s true if only, say, 5% of group policies don&#8217;t have contraceptive coverage unless it is requested. But saying &#8220;not all do&#8221; is quite different from saying &#8220;most don&#8217;t.&#8221; The information I gave above from the National Conference of State Legislators is much more suggestive of what insurance companies actually do <i>most</i> of the time than Drum&#8217;s statement, from which no significant conclusions can be drawn.</p>
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		<title>By: Josh DeCuir</title>
		<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/comment-page-1/#comment-91047</link>
		<dc:creator>Josh DeCuir</dc:creator>
		<pubDate>Wed, 20 Feb 2013 18:09:30 +0000</pubDate>
		<guid isPermaLink="false">http://www.firstthings.com/blogs/firstthoughts/?p=57702#comment-91047</guid>
		<description><![CDATA[Happily:

&quot;Unfortunately, I&#039;m not sure I believe it. The main reason is simple: If this were true, insurance companies would routinely make contraceptive coverage a feature of all their group policies without even being asked. But they don&#039;t. And since insurance companies tend to be fairly good at actuarial calculations, this suggests that contraceptive coverage isn&#039;t, in fact, a freebie.&quot;

http://www.motherjones.com/kevin-drum/2013/02/contraceptive-coverage-probably-not-freebie-insurance-companies

He clarifies certain things in the comment thread.  I hardly agree with Drum on anything; but I would hesitate before I uniformly dismiss his claim as &quot;certainly wrong.&quot;]]></description>
		<content:encoded><![CDATA[<p>Happily:</p>
<p>&#8220;Unfortunately, I&#8217;m not sure I believe it. The main reason is simple: If this were true, insurance companies would routinely make contraceptive coverage a feature of all their group policies without even being asked. But they don&#8217;t. And since insurance companies tend to be fairly good at actuarial calculations, this suggests that contraceptive coverage isn&#8217;t, in fact, a freebie.&#8221;</p>
<p><a href="http://www.motherjones.com/kevin-drum/2013/02/contraceptive-coverage-probably-not-freebie-insurance-companies" rel="nofollow">http://www.motherjones.com/kevin-drum/2013/02/contraceptive-coverage-probably-not-freebie-insurance-companies</a></p>
<p>He clarifies certain things in the comment thread.  I hardly agree with Drum on anything; but I would hesitate before I uniformly dismiss his claim as &#8220;certainly wrong.&#8221;</p>
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		<title>By: Boonton</title>
		<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/comment-page-1/#comment-91044</link>
		<dc:creator>Boonton</dc:creator>
		<pubDate>Wed, 20 Feb 2013 17:56:33 +0000</pubDate>
		<guid isPermaLink="false">http://www.firstthings.com/blogs/firstthoughts/?p=57702#comment-91044</guid>
		<description><![CDATA[Yea I&#039;m going to say that most insurance policies cover contraception.  Remember two questions:

1.  Health insurance covers doctors&#039; visits.  I&#039;m going to say that NO health policy declines contraception here as to do so you&#039;d have to dig into what people actually do in their visit and pro-rate.  

2.  Drug insurance.  I grant here that there no doubt are policies that exclude contraception.  I don&#039;t think they are standard policies but ones tailored to special requests by employers.  The &#039;norm&#039; I believe is coverage.  Ancedotally I can confirm that but those with hard data are free to present it.]]></description>
		<content:encoded><![CDATA[<p>Yea I&#8217;m going to say that most insurance policies cover contraception.  Remember two questions:</p>
<p>1.  Health insurance covers doctors&#8217; visits.  I&#8217;m going to say that NO health policy declines contraception here as to do so you&#8217;d have to dig into what people actually do in their visit and pro-rate.  </p>
<p>2.  Drug insurance.  I grant here that there no doubt are policies that exclude contraception.  I don&#8217;t think they are standard policies but ones tailored to special requests by employers.  The &#8216;norm&#8217; I believe is coverage.  Ancedotally I can confirm that but those with hard data are free to present it.</p>
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		<title>By: David Nickol</title>
		<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/comment-page-1/#comment-90971</link>
		<dc:creator>David Nickol</dc:creator>
		<pubDate>Wed, 20 Feb 2013 01:07:29 +0000</pubDate>
		<guid isPermaLink="false">http://www.firstthings.com/blogs/firstthoughts/?p=57702#comment-90971</guid>
		<description><![CDATA[&lt;i&gt;Drum states that most policies do not provide such coverage.&lt;/i&gt;

Josh DeCuir,

You need to provide a quote or a link. I think you are misinterpreting something Drum wrote. And if he said what you claim he said, he&#039;s almost certainly wrong. This is from the &lt;a href=&quot;http://www.ncsl.org/issues-research/health/insurance-coverage-for-contraception-state-laws.aspx&quot; rel=&quot;nofollow&quot;&gt;National Conference of State Legislatures:&lt;/a&gt;

&lt;blockquote&gt;Most women in the United States receive health insurance coverage through private plans, and a Kaiser Family Foundation 2010 survey of employers reports that 85 percent of large firms cover prescription contraceptives in their largest health plans.  Federal law requires insurance coverage of contraceptives for federal employees and their dependents, allowing a few religious insurers exemption from the requirements.&lt;/blockquote&gt;

Also note the following, from the same source:

&lt;blockquote&gt;At least 26 states have laws requiring insurers that cover prescription drugs also provide coverage for any Food and Drug Administration (FDA)-approved contraceptive. . . .  An additional two states . . . require insurance coverage of contraceptives as a result of administrative ruling or an Attorney General opinion. &lt;/blockquote&gt;

So most big companies include contraceptive coverage, and most states (28 out of 50) require it of insurance companies by law. Now, we don&#039;t know how many of those large companies self-insure, so it is difficult to say for certain what &lt;i&gt;insurance companies&lt;/i&gt; do, but I think it&#039;s a safe bet (especially given the state mandates) that most insurers do cover contraception.]]></description>
		<content:encoded><![CDATA[<p><i>Drum states that most policies do not provide such coverage.</i></p>
<p>Josh DeCuir,</p>
<p>You need to provide a quote or a link. I think you are misinterpreting something Drum wrote. And if he said what you claim he said, he&#8217;s almost certainly wrong. This is from the <a href="http://www.ncsl.org/issues-research/health/insurance-coverage-for-contraception-state-laws.aspx" rel="nofollow">National Conference of State Legislatures:</a></p>
<blockquote><p>Most women in the United States receive health insurance coverage through private plans, and a Kaiser Family Foundation 2010 survey of employers reports that 85 percent of large firms cover prescription contraceptives in their largest health plans.  Federal law requires insurance coverage of contraceptives for federal employees and their dependents, allowing a few religious insurers exemption from the requirements.</p></blockquote>
<p>Also note the following, from the same source:</p>
<blockquote><p>At least 26 states have laws requiring insurers that cover prescription drugs also provide coverage for any Food and Drug Administration (FDA)-approved contraceptive. . . .  An additional two states . . . require insurance coverage of contraceptives as a result of administrative ruling or an Attorney General opinion. </p></blockquote>
<p>So most big companies include contraceptive coverage, and most states (28 out of 50) require it of insurance companies by law. Now, we don&#8217;t know how many of those large companies self-insure, so it is difficult to say for certain what <i>insurance companies</i> do, but I think it&#8217;s a safe bet (especially given the state mandates) that most insurers do cover contraception.</p>
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		<title>By: Josh DeCuir</title>
		<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/comment-page-1/#comment-90952</link>
		<dc:creator>Josh DeCuir</dc:creator>
		<pubDate>Tue, 19 Feb 2013 20:41:39 +0000</pubDate>
		<guid isPermaLink="false">http://www.firstthings.com/blogs/firstthoughts/?p=57702#comment-90952</guid>
		<description><![CDATA[&quot;Granted I don’t work in insurance but I have never seen private corporate coverage that does not include contraception and even abortion.&quot;

Drum states that most policies do not provide such coverage.]]></description>
		<content:encoded><![CDATA[<p>&#8220;Granted I don’t work in insurance but I have never seen private corporate coverage that does not include contraception and even abortion.&#8221;</p>
<p>Drum states that most policies do not provide such coverage.</p>
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		<title>By: David Nickol</title>
		<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/comment-page-1/#comment-90946</link>
		<dc:creator>David Nickol</dc:creator>
		<pubDate>Tue, 19 Feb 2013 19:53:33 +0000</pubDate>
		<guid isPermaLink="false">http://www.firstthings.com/blogs/firstthoughts/?p=57702#comment-90946</guid>
		<description><![CDATA[&lt;i&gt;A proposal to propose is not exactly a policy&lt;/i&gt;

Mm,

In this case, the &quot;proposal to propose&quot; is a Notice of Proposed Rulemaking. Wikipedia says: 

&lt;blockquote&gt;A notice of proposed rulemaking (NPR) is a public notice issued by law when one of the independent agencies of the United States government wishes to add, remove, or change a rule or regulation as part of the rulemaking process. It is an important part of United States administrative law which facilitates government by typically creating a process of taking of public comment. &lt;/blockquote&gt;

In other words, what you call a &quot;proposal to propose&quot; is not a vague statement about what might be done, but rather, a formal step putting forth a planned regulation and inviting public comment. If one wishes to discuss the issues of the so-called &quot;contraceptive mandate,&quot; then the current Notice of Proposed Rulemaking is the only thing there really is to discuss. It is, in effect, HHS saying, &quot;Here&#039;s an outline of what we propose to do, and once we get all of your comments, we&#039;ll take them into account and formulate the actual rule.&quot;]]></description>
		<content:encoded><![CDATA[<p><i>A proposal to propose is not exactly a policy</i></p>
<p>Mm,</p>
<p>In this case, the &#8220;proposal to propose&#8221; is a Notice of Proposed Rulemaking. Wikipedia says: </p>
<blockquote><p>A notice of proposed rulemaking (NPR) is a public notice issued by law when one of the independent agencies of the United States government wishes to add, remove, or change a rule or regulation as part of the rulemaking process. It is an important part of United States administrative law which facilitates government by typically creating a process of taking of public comment. </p></blockquote>
<p>In other words, what you call a &#8220;proposal to propose&#8221; is not a vague statement about what might be done, but rather, a formal step putting forth a planned regulation and inviting public comment. If one wishes to discuss the issues of the so-called &#8220;contraceptive mandate,&#8221; then the current Notice of Proposed Rulemaking is the only thing there really is to discuss. It is, in effect, HHS saying, &#8220;Here&#8217;s an outline of what we propose to do, and once we get all of your comments, we&#8217;ll take them into account and formulate the actual rule.&#8221;</p>
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		<title>By: Boonton</title>
		<link>http://www.firstthings.com/blogs/firstthoughts/2013/02/17/provision-payment-and-prevarication-a-response-to-grant-gallicho/comment-page-1/#comment-90905</link>
		<dc:creator>Boonton</dc:creator>
		<pubDate>Tue, 19 Feb 2013 16:34:30 +0000</pubDate>
		<guid isPermaLink="false">http://www.firstthings.com/blogs/firstthoughts/?p=57702#comment-90905</guid>
		<description><![CDATA[&lt;i&gt;Mainly, Drum points out, if contraception were, in fact, such a homerun cost-savings, wouldn’t the insurance companies ALREADY be offering this coverage? Frum’s argument is dated 2.3.13.&lt;/i&gt;

Granted I don&#039;t work in  insurance but I have never seen private corporate coverage that does not include contraception and even abortion.  Remember contraception includes two things, there&#039;s the drugs (covered or not under drug plan) and the doctor&#039;s visit which is covered by the health plan.  If one were to seriously say insurance should not cover contraception, then that would require the insurance company to examine every doctor&#039;s appointment, find out if contraception was discussed and then demand the woman be billed a pro-rated portion of that visit.  I would be very shocked if any health insurance plan did anything like that.

&lt;i&gt;Until the proponents admit that they believe these institutions SHOULD be providing birth control, they will not convince those of us who doubt that the accomodation is sufficient&lt;/i&gt;

Whose providing birth control?  EWTN?  Are they keeping pills locked in a closet with an on site pharmacist?  That&#039;s kind of like saying I&#039;m running a printing press if I give you a Amazon.com gift card.]]></description>
		<content:encoded><![CDATA[<p><i>Mainly, Drum points out, if contraception were, in fact, such a homerun cost-savings, wouldn’t the insurance companies ALREADY be offering this coverage? Frum’s argument is dated 2.3.13.</i></p>
<p>Granted I don&#8217;t work in  insurance but I have never seen private corporate coverage that does not include contraception and even abortion.  Remember contraception includes two things, there&#8217;s the drugs (covered or not under drug plan) and the doctor&#8217;s visit which is covered by the health plan.  If one were to seriously say insurance should not cover contraception, then that would require the insurance company to examine every doctor&#8217;s appointment, find out if contraception was discussed and then demand the woman be billed a pro-rated portion of that visit.  I would be very shocked if any health insurance plan did anything like that.</p>
<p><i>Until the proponents admit that they believe these institutions SHOULD be providing birth control, they will not convince those of us who doubt that the accomodation is sufficient</i></p>
<p>Whose providing birth control?  EWTN?  Are they keeping pills locked in a closet with an on site pharmacist?  That&#8217;s kind of like saying I&#8217;m running a printing press if I give you a Amazon.com gift card.</p>
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