Updated: Will self-funded plans have to offer contraception?

I'm reposting this 2/10 post, shortened somewhat, to highlight a couple of updates tacked on this week:
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I have a really basic question about the just-announced compromise regarding insurance coverage for contraception. Under the compromise,

• Religious organizations will not be required to subsidize the cost of contraception.

• Contraception coverage will be offered to women by their employers’ insurance companies directly [and free of charge], with no role for religious employers who oppose contraception.

Question: more than half of Americans who get their health coverage from their employers are in self-funded plans -- that is, plans in which the employer sets aside funds to cover the cost of health care, usually hiring a third party administrator (TPA) to handle the claims process, as well as a stop-loss insurer to cover costs above a certain level.  So: who will "provide contraception coverage" in self-funded plans?   If it's the self-funded entity, then the employer is paying for it. Would the TPA somehow absorb the cost -- or a stop-loss insurer under some special rider? If so, surely either would find a way to pass the cost back?


UPDATE 2/14: At Business Insurance, Jerry Geisel relays this clarification-to-come notice:

In regulations issued Friday [Feb. 10], the administration said it will develop a comparable rule that would apply to employers affiliated with religious organizations that self-fund their health care plans.

“The departments intend to develop policies to achieve the same goals for self-insured group health plans sponsored by nonexempted, nonprofit religious organizations with religious objections to contraceptive coverage” according to regulations released by the Internal Revenue Service and the Departments of Labor and Health and Human Services.

For now, “I see a gaping hole” on the self-insurance issue, said Andy Anderson, a partner with Morgan, Lewis & Bockius L.L.P. in Chicago.

UPDATE 2/15:  NPR's Jim Zarroli cites an industry expert who assumes that for self-funded plans, "the insurance company" footing the bill would be the third party administrator (TPA):

Self-funded employers against the public option

Last week, Matt Miller expressed incredulity that the major business lobbies would help shoot down the Wyden Free Choice Amendment to the Baucus bill, which would enable all employees to opt out of their employer's health care plan and buy insurance on the insurance exchanges that the various health care reform bills will establish for the uninsured. Miller forecast:

Big business thinks that giving employees this choice would be a calamity. To which one can only ask: Have these business lobbies lost their minds?

When the post-mortems on the health-care reform debate are written, the biggest mystery will be why big business fought so hard to stay in the health-care business even as soaring health costs surpassed corporate profits and diverted executive time better devoted to actually running companies.

Excellent question. Miller can only speculate that corporate human resources chiefs have sold their companies a bill of goods. And that seems to be the case on another health care reform front: employers apparently also don't want their self-funded plans to be subject to competition from a public option, i.e. a government-administered plan offered on the new insurance exchanges.

More than half of Americans who get their health coverage through their employers work for companies that self-fund their own health plans, usually hiring an outside company to administer the plan. The organization representing such plans and the companies servicing them, the Self Insurance Institute of America, is dead-set against the public option, apparently fearing it would trigger a stampede out of employer-funded plans.

Why? As reported by Matt Brodsky of Risk & Insurance, Cliff Roberti, chief lobbyist for the group, recently issued a warning at the group's annual meeting:

Not to be "overly dramatic," said Roberti, addressing an audience of SIIA members, but if healthcare reform take a partisan turn (meaning the passage of government-run insurance plans), a lot of people at the conference could be in another business in two years.

Who might lose their jobs if employees stampeded out of employers' health plans? SIIA members include company executives who oversee self-funded plans (as well as at captive insurance companies, generally used for property/casualty insurance); Third Party Administrators (TPAs), the entities that run these plans, which include both subsidiaries of major health insurers and stand-alone companies specializing in this service; and stop-loss insurers, which offer coverage for big losses to self-funded plans. The SIIA website defines its constituency as follows:

If your company is a self-insured employer, group fund (SIF), third party administrator, stop-loss/excess insurance carrier or provider network, SIIA' s government relations services are a tremendous membership benefit.

Are corporate America's interests really aligned with those of TPAs and stop-loss insurers? Is corporate policy on this front really driven by HR executives, as Matt Miler suggests? Why is the prospect of reduced employer responsibility for employees' health care so threatening to employers?