Office of the President

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Room 445-G
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201

Re: Notice of Proposed Rulemaking on Preventive Services File Code No. CMS-9968-P

Dear Sir or Madam:

Franciscan University of Steubenville finds the U.S. Department of Health and Human Services’ current proposed revision to the HHS mandate unsatisfactory for several reasons.

The newest proposed regulation continues to require mandated coverage of abortion-inducing drugs, contraceptives, and sterilization procedures.

As a faithfully Catholic university, Franciscan University cannot facilitate this mandated coverage without violating Catholic Church teaching on the sanctity of human life and the purpose of marriage. The February 1 proposal would require Franciscan University’s simple act of contracting with an insurer to trigger automatic coverage for pills and procedures that we, as a Catholic university, find morally objectionable. Further, our employees cannot opt out of this automatic coverage, even when it deeply offends their religious beliefs.

Far from alleviating our serious moral problem with the HHS mandate, the proposed accommodation thus would force us to play a key role in facilitating contraceptive coverage. From a moral standpoint, the proposed accommodation is no different than directly providing such coverage in our employee healthcare plan.

The proposed regulation will deny Franciscan University the freedom to exclude items that violate Church teaching and the consciences of our employees, the majority of whom choose to work at Franciscan specifically because of our faithfulness to the Catholic Church.

The proposed regulation also does not even attempt to protect the rights of the numerous conscientiously objecting individuals, for-profit or non-profit employers, insurers, and third-party administrators. Franciscan University has heard from alumni business owners and individuals who integrate their religious faith into their business practices and daily life and now find their heartfelt values dismissed out of hand by the HHS mandate’s contraceptive requirements.

Franciscan University asks that the Obama administration protect our rights of conscience and religious liberty as a Catholic institution—and, indeed, the rights of all Americans—instead of picking and choosing whose exercise of religion is protected and whose is not. We ask that it return to the long tradition in federal law of generous protection for moral or religious objectors, and restore our First Amendment right to religious liberty. If not, Franciscan University will have no choice but to continue our fight to live the faith we believe.

As a Catholic university, Franciscan University not only has a responsibility to teach what the Church teaches about the dignity of human life and the right to life from conception to natural death, we must live out that teaching to the best of our ability. We cannot and will not allow the HHS mandate to compromise our witness and our Catholic educational mission.

Respectfully Submitted,

Father Terence Henry, TOR
Franciscan University of Steubenville
1235 University Blvd.
Steubenville, OH 43952

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