"The group health plan requirements of the [ACA] apply to church plans ... The government has consistently taken the position, however, that, because church plans are exempt from ERISA, it has no means of compelling the third party administrators of self-insured church plans to comply with the ACA, or at least its preventive services requirement.... The leaked contraceptive rule would effectively extend the exceptions that have excused self-insured church plans -- and churches -- from complying with the contraceptive [coverage] requirement ... If the rule that emerges from HHS is significantly narrower than the leaked version, more entities might rely on the Advocate Health Care ruling to claim the protection of the church plan exemption."  MORE >>