Missouri contributes the remaining portion of the health care insurance premiums as a benefit of Mr. Wieland’s employment.8.
Between January 2011, when the Wielands’ coverage under the plan began, andAugust 1, 2013, the plan did not include coverage for contraceptives, sterilization or abortifacients, because the Wielands had opted out of such coverage. On July 18, 2013, MCHCPsent the Wielands a letter stating that because of federal law MCHCP must provide contraceptionand sterilization coverage in all medical plans it offers. MCHCP stated that “[e]ffective August1, 2013, you will be placed in the corresponding medical plan that includes contraception andsterilization coverage in accordance with federal law.”9.
Plaintiffs’ premiums increased in conjunction with and because of the addition of contraception and sterilization coverage.10.
The Plaintiffs do not believe that contraceptives, sterilization, or abortifacientsconstitute medicine, health care, or a means of providing for the well being of persons. Rather,Plaintiffs believe contraceptives, sterilization, and abortifacients involve gravely immoral practices and that abortion in particular involves the intentional destruction of innocent humanlife.11.
The Defendants have issued an administrative rule (“Mandate” or “Final Rule”) pursuant to authority created by the Act requiring that group health plans cover, without costsharing, “all Food and Drug Administration-approved contraceptive methods, sterilization procedures and patient education and counseling for all women with reproductive capacity.”Such contraceptive methods include certain drugs and devices such as the “Plan B” and “ella” pills and copper IUDs, all of which are widely known as abortifacients in that they frequentlyfunction to destroy fertilized eggs, which Plaintiffs consider to be abortion. This not only forces
Case: 4:13-cv-01577 Doc. #: 1 Filed: 08/14/13 Page: 3 of 22 PageID #: 3