The Trump administration is getting more creative with its attacks on reproductive rights. This time the strategy involves more stamps, invoices, checks, and confusion. The administration issued a proposed regulation that would require insurers on the Affordable Care Act (ACA) Marketplace to bill abortion coverage separately from all other health services. If the proposed rule is implemented, consumers will have to pay two different bills every month: one for abortion coverage, and one for everything else.

This is clearly the Trump administration’s latest attempt to make it more difficult for women to get an abortion. The administration claims to be changing the rule in order to “better implement” the ACA requirement of separating private dollars and government-funded subsidies for plans that cover abortion services. This requirement is already problematic because it treats abortion care differently from all other health services.  But, up until now, it has been implemented in ways that minimize burdens on consumers and insurers. If the proposed rule moves forward, “better implementation” will lead to confusion, loss of coverage, and ultimately insurers choosing to drop abortion coverage altogether.

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This confusion is intentional. It would be perplexing enough for people with the capacity to become pregnant to get a separate bill every month, for as little as a dollar, just for abortion coverage. It will be downright mystifying for men and women who are not of reproductive age. I know I’d be confused if I received a bill for vasectomy coverage every month.

Creating cumbersome obstacles will discourage insurance companies from offering abortion coverage. It will also likely lead to individuals losing their health coverage when bills are inevitably paid incorrectly. The Trump administration has routinely supported policies that would result in reduced health coverage, from attempting to repeal the ACA, which would have taken health care away from millions, to making it more difficult to sign up for health insurance on the Marketplace through shorter enrollment periods and reduced marketing and outreach support. This proposed regulation kills two birds with one stone – it attacks abortion access while simultaneously adding to this administration’s laundry list of efforts to weaken the ACA.

Not everyone who gets their insurance on the Marketplace will be impacted. Thirty-four states have outright bans on abortion coverage in Marketplace plans or don’t have any insurers currently offering it.  But that still leaves millions of people’s coverage in jeopardy. The Kaiser Family Foundation found that 3.1 million people could be impacted, including the 2 million people currently enrolled in the four states that require abortion coverage in all Marketplace plans. The Department of Health and Human Services estimates consumer costs for this policy change will total $30.8 million, but this estimate fails to account for expenses like educating consumers about the policy change and sending separate mailings. These additional costs will also likely be passed along to enrollees through higher premiums.

Women who want to terminate a pregnancy and find themselves with a health plan that revoked abortion coverage will pay the highest price. In 2014, a study found the average cost of first-trimester abortion care was $461. A second-trimester abortion, which becomes more likely when women don’t have immediate access to funds, can cost $2,000. Bans on abortion coverage disproportionately impact low income people and people of color who often have a more difficult time paying for and accessing an abortion due to structural and economic inequities.

The costs of losing abortion access are not just monetary. Studies have found there are negative physical and mental health consequences to women denied abortions, including increased likelihood of experiencing anxiety as well as serious medical complications toward the end of pregnancy. Women denied an abortion are also more likely to experience economic hardship and insecurity compared to women able to access one. Not only does this policy further stigmatize abortion, it puts women’s health and livelihood at risk.

We need policies that incentivize more insurers to cover abortion, not less. Now is the time to make sure the administration hears that message. You can publicly oppose this rule by submitting comments directly or through an organization like the National Women’s Law Center through Jan. 8. This isn’t about avoiding more stamps and paperwork, it’s about protecting our fundamental reproductive rights. 

Sarah Wulf is a Project Manager with the Person-Centered Reproductive Health Program at University of California, San Francisco. Previously, she helped people enroll in health insurance at Planned Parenthood and advocated to protect the ACA from repeal with Raising Women’s Voices.