According to a press release, USCCB president Cardinal Timothy Dolan of New York listed three areas of concern with the proposed changes: the narrow understanding of a religious ministry; compelling church ministries to fund and facilitate services such as contraceptives, including abortion-inducing drugs, and sterilization that violate Catholic teaching; and disregard of the conscience rights of for-profit business owners.
Cardinal Dolan said the new proposal seemed to address one part of the church's concern over the definition of a church ministry but stressed that "the Administration's proposal maintains its inaccurate distinction among religious ministries.
"It appears to offer second-class status to our first-class institutions in Catholic health care, Catholic education and Catholic charities. HHS offers what it calls an 'accommodation' rather than accepting the fact that these ministries are integral to our church and worthy of the same exemption as our Catholic churches."
Cardinal Dolan highlighted problems with the proposed "accommodation."
"It appears that the government would require all employees in our 'accommodated' ministries to have the illicit coverage—they may not opt out, nor even opt out for their children—under a separate policy," he said.
He also noted that "because of gaps in the proposed regulations, it is still unclear how directly these separate policies would be funded by objecting ministries, and what precise role those ministries would have in arranging for these separate policies. Thus, there remains the possibility that ministries may yet be forced to fund and facilitate such morally illicit activities."
Cardinal Dolan also said the proposal refuses to acknowledge conscience rights of business owners who operate their businesses according to their faith and moral values.
"In obedience to our Judeo-Christian heritage, we have consistently taught our people to live their lives during the week to reflect the same beliefs that they proclaim on the Sabbath," Cardinal Dolan said. "We cannot now abandon them to be forced to violate their morally well-informed consciences."
Cardinal Dolan expressed his hope that additional changes might be made to the mandate as a result of the feedback that will be given during the public comment period.
"Throughout the past year, we have been assured by the Administration that we will not have to refer, pay for, or negotiate for the mandated coverage. We remain eager for the Administration to fulfill that pledge and to find acceptable solutions—we will affirm any genuine progress that is made, and we will redouble our efforts to overcome obstacles or setbacks," Cardinal Dolan said.
"Thus, we welcome and will take seriously the Administration's invitation to submit our concerns through formal comments, and we will do so in the hope that an acceptable solution can be found that respects the consciences of all. At the same time, we will continue to stand united with brother bishops, religious institutions, and individual citizens who seek redress in the courts for as long as this is necessary."
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