"The Court appears to be seeking a method by which religious employers can themselves not finance or be implicated in the provision of birth control while, at the same time, such contraception is provided through the insurance companies the employers engage to furnish health care coverage to their employees.... [T]here is such an approach: Any religious employer objecting to contraception should have the right to instead fund an independently-administered health savings account (HSA) or health reimbursement arrangement (HRA) for each of its employees.... Under this approach, an employee of a religious employer who desires extra prescription eyeglasses could use her HRA or HSA for that purpose -- while her co-worker could use that account to obtain birth control. In neither case would the religious employer participate in the employee's decision how to expend her health care account dollars."

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