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7/23/2019 Zubik, et al. v. Burwell - Appendix C
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POHL_OS-0019368
7/23/2019 Zubik, et al. v. Burwell - Appendix C
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POHL_OS-0019369
7/23/2019 Zubik, et al. v. Burwell - Appendix C
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POHL_OS-0019370
This is what I sent to the Cardinals:
As the accommodation seems to be working out, it appears that there will be two kinds ofexemptions. One for
religious entities that are primarily evangelical and one for religious entities that are primarily apostolic. The
evangelical being the ones that meet the four part test and the others, works that the Church considers
ministries, such as CC, CRS and hospitals among others. The Church is
the recognizing authority, there would
be no test or certification by a government agency required. The first type ofexemption would have no
obligation to provide contraception or sterilization and their employees would not be offered it. The second
would have no obligation to provide or refer for contraception or sterilization but their employees would be
offered it by another mechanism at no cost to the employer. This would be done for those who have traditional
insurance or who are self- insured, although the mechanism might be different.
n some ways this resembles the IRS regulations and distinctions ofdifferent types of Church organizations.
Churches, for instance meet one test and do not have to file a 990 and other Catholic organizations like hospitals
do have to file a 990 even though the IRS considers them as Church ministries.
I hope this is some help. I am in the office today until 2:30 then on my cell until about 3 30 then fly to Chicago
but available there after 6:30 pm and all day tomorrow on my cell. Thanks for all you work on this.
f l
hear
anything, I will let you know. Sr Carol
Sr. Carol Keehan,D.C.
President/CEO
The Catholic Health Association
of
he United States
1875 Eye St. NW, Ste. 1000
Washington DC, 20006-5409
202-721-6015
~ r c a r o l k @ c h a u s a o r g