It’s hard to believe that it’s been almost a year since the HHS’ Health Resources and Services Administration adopted additional Guidelines for Women’s Preventive Services that must be covered without cost sharing under the Affordable Care Act (ACA). These new preventive care requirements were recommended by the independent Institute of Medicine (IOM). Additional women’s preventive services that must be included in health plans (unless grandfathered) without cost sharing for plan years beginning on or after August 1, 2012 (e.g., January 1, 2013 for calendar year plans) are:
· Well-woman visits: This includes an annual well-woman preventive care visit for adult women to obtain the recommended preventive services, and additional visits if women and their providers determine they are necessary.
· Gestational diabetes screening: This screening is for women 24 to 28 weeks pregnant, and those at high risk of developing gestational diabetes.
· HPV DNA testing: Women 30 or older will have access to high-risk human papillomavirus (HPV) DNA testing every three years, regardless of pap smear results.
· STI counseling, and HIV screening and counseling: Women will have access to annual counseling on HIV and sexually transmitted infections (STIs).
· Contraception and contraceptive counseling: Women will have access to all Food and Drug Administration-approved contraceptive methods, sterilization procedures, and patient education and counseling (not including abortifacient drugs).
· Breastfeeding support, supplies, and counseling: Pregnant and postpartum women will have access to comprehensive lactation support and counseling from trained providers, as well as breastfeeding equipment.
· Domestic violence screening: Screening and counseling for interpersonal and domestic violence will be provided for all women.
The rules governing coverage of preventive services generally, which allow plans to use reasonable medical management to help define the nature of the covered service, apply to the new women’s preventive services requirements. Plans do retain the flexibility to control costs and promote efficient delivery of care by, for example, continuing to charge cost-sharing for branded drugs if a generic version is available and is just as effective and safe for patients to use.
These new required preventive services for women should be automatically baked into any fully insured group plan purchased on or after August 1, 2012. Regardless of the funding method (insured or self-insured) this topic should be raised with the vendor at renewal time to make certain the new requirements are met and that the resulting costs to the plan are understood