Executive Summary
  1. US Department of Labor: Employee Benefits Security Administration “FAQs about Affordable Care Act Implementation Part XII” February 20, 2013.

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  2. Affordable Care Act Implementation Frequently Asked Questions (FAQs) 12, Departments of Treasury, Labor, and Health and Humans Services, February 20, 2013.

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Introduction
  1. Kaiser Family Foundation and Health Research Educational Trust, 2014 Employer Health Benefits Survey.

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  2. Institute Of Medicine (“IOM”), Clinical Preventive Services for Women: Closing the Gaps, page 105 (2011).

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  3. Institute Of Medicine (“IOM”), Clinical Preventive Services for Women: Closing the Gaps, page 105 (2011).

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  4. U.S. Department of Health & Human Services, Women’s Preventive Services: Required Health Plan Coverage Guidelines.

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  5. Grandfathered plans are those that were in existence on March 23, 2010 and have stayed basically the same. If you buy coverage on your own and you first purchased your policy prior to March 23, 2010, it may be a grandfathered plan. See Kaiser Family Foundation, Health Reform FAQs, “What is a grandfathered plan? How do I know if I have one?

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  6. 45 CFR § 147.130(a)(4).

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  7. US Department of Labor: Employee Benefits Security Administration “FAQs about Affordable Care Act Implementation Part XII” February 20, 2013; US Department of Labor: Employee Benefits Security Administration “FAQs about Affordable Care Act Implementation Part II” May 13, 2010.

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  8. US Department of Labor: Employee Benefits Security Administration “FAQs about Affordable Care Act Implementation Part II” May 13, 2010.

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  9. Andrews, M. Insurers Refuse to Cover some Contraceptives, Despite Health Law, NPR Shots Blog; Sonfield A. 2013. “Implementing the Federal Contraceptive Coverage Guarantee: Progress and Prospects.” Guttmacher Policy Review. 16(4).

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Methodology
  1. In September 2014, California Governor Brown signed SB-1053 into law, requiring health insurance policies in California to cover all FDA-approved contraceptives drugs, devices, and products, as well as voluntary sterilization procedures, contraceptive education and counseling, and related follow-up services by 2016, with no cost-sharing. The California law limits the use of reasonable medical management, and goes beyond the Federal requirements by prohibiting non-grandfathered and Medi-Cal plans from imposing cost-sharing requirements or other restrictions or delays in provision of contraceptive benefits. This law was not effective at the time of this study.

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Defining “Reasonable” Medical Management
  1. Garner. IT Glossary- Medical Management.

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  2. Gavin L et al., 2014. Providing Quality Family Planning Services: Recommendations of CDC and the U.S. Office of Population Affairs, Morbidity and Mortality Weekly Report. 63(RR04); 1-29.

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Coverage of Select Contraceptive Methods
  1. CDC, Reproductive Health – Contraception; Zieman M, Guillebaud J, Weisberg E, Shangold G, Fisher A, Creasy G. Contraceptive efficacy and cycle control with the Ortho Evra/Evra transdermal system: the analysis of pooled data. Fertility and Sterility 2002;77: S13–18.

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  2. Glasier A, Cameron ST, Blithe D, Scherrer B, Mathe H, Levy D, Gainer E, Ulmann A. Can we identify women at risk of pregnancy despite using emergency contraception? Data from randomized trials of ulipristal acetate and levonorgestrel. Contraception. 2011;84:363-7; Zhang, L., et al., Pregnancy Outcome After Levonorgestrel-only Emergency Contraception Failure: A Prospective Cohort Study, Human Reproduction, 2009; Food and Drug Administration, Prescription Drug Products; Certain Combined Oral Contraceptives for Use as Postcoital Emergency Contraception, Federal Registrar 1997; 62: 8610-2; Office of Population Research at Princeton University, Efficacy, May 2013.

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  3. Moreau C, Trussell J. Results from pooled Phase III studies of ulipristal acetate for emergency contraception. Contraception. 2012;86:673-680.

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Related Coverage Issues
  1. US Department of Labor: Employee Benefits Security Administration “FAQs about Affordable Care Act Implementation Part XII” February 20, 2013.

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  2. US Department of Labor: Employee Benefits Security Administration “FAQs about Affordable Care Act Implementation Part XII” February 20, 2013.

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  3. Center for Consumer Information & Insurance Oversight Affordable Care Act: Working with States to Protect Consumers, May 22, 2014.

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  4. US Department of Labor: Employee Benefits Security Administration “FAQs about Affordable Care Act Implementation Part XII” February 20, 2013.

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