On August 1, 2011, Health and Human Services (HHS) released an interim final rule adopting additional guidelines for women's preventive services, including contraception, well-woman visits, support for breastfeeding equipment and domestic violence screening. These items, explained more fully below, must be covered by non-grandfathered plans and insurers without cost-sharing in the first plan year that begins on or after August 1, 2012.

HHS took the recommendation of the Institute of Medicine (IOM) report issued on July 19, 2011 in developing their guidelines. PPACA specifically directed the agencies to mandate the coverage of items and services recommended by certain advisory bodies. Since PPACA did not specifically mention the IOM as one of the advisory bodies, the guidelines had to be simultaneously adopted by one of the groups mentioned in the law - the Health Resources and Services Administration. This is a sneaky way of skirting around a statutory obstacle.

Group health plans sponsored by certain religious employers are exempt from the requirement to cover contraceptive services.

The new guidelines include coverage for the following services:

Contraception and contraceptive counseling - All Food and Drug Administration-approved contraceptive methods, sterilization procedures, and patient education and counseling for all women with reproductive capacity. These recommendations do not include abortifacient drugs.

Breastfeeding support, supplies and counseling - Comprehensive lactation support and counseling, by a trained provider during pregnancy and/or in the postpartum period, and costs for renting breastfeeding equipment.

Screening and counseling for interpersonal and domestic violence - Annual screening and counseling for interpersonal and domestic violence.

Counseling and screening for human immune-deficiency virus - Annual counseling and screening for human immune-deficiency virus infection for all sexually active women.

Counseling for sexually transmitted infections - Annual counseling on sexually transmitted infections for all sexually active women.

HPV DNA testing - Human papillomavirus DNA testing in women with normal cytology results. Screening should begin at 30 years of age and should occur no more frequently than every 3 years.

Screening for gestational diabetes - In pregnant women between 24 and 28 weeks of gestation and at the first prenatal visit for pregnant women identified to be at high risk for diabetes.

Well-woman visits - Annual well-woman visit for adult women to obtain the recommended preventive services that are age and developmentally appropriate, including preconception and prenatal care.

For compliance related questions, contact David Follansbee, Director of Operations/Compliance at dfollansbee@dgb-online.com