April 8 is the deadline to submit comments in response to the early-February “proposed rules” (Notice of Proposed Rulemaking–NPRM) about “accommodating” non-exempt religious organizations that have objections to the HHS contraceptives mandate. The proposed rules would: change the definition of an exempt religious employer; define which organizations are eligible for the accommodation; and detail the proposed accommodation. The NPRM offers ideas, though no actual proposed rules, for organizations that self-insure. The objectionable two-class scheme by which houses of worship, but not faith-based service organizations, are accorded full religious freedom respect, remains the framework for the government. (See this eNews story for details about the NPRM proposals.)

The accommodation is pretty much what was suggested in the March, 2012, Advance Notice of Proposed Rulemaking (ANPRM). Organizations and individuals who commented on the ANPRM might essentially resubmit their comments in response to the NPRM, noting that what has changed is not essential and what remains unchanged is not acceptable.

For the text of the NPRM and to comment electronically, go here, then type CMS-9968-P into the search box and select the top result.

April 21 is the deadline to submit comments to the US Commission on Civil Rights in connection with the briefing it has scheduled for March 22 to discuss the intersection between religious freedom and non-discrimination requirements. Comments need not be in response to the briefing itself but can discuss, in lesser or greater detail, the commentator’s convictions about how religious freedom should be respected even as other rights are being promoted. Organizations and individuals who consider their freedom of religious exercise to have been wrongly curtailed due to some legal requirement-e.g., to disregard their moral convictions when providing services-have an opportunity to comment on their concerns.

Submit comments here.

And proponents of religious freedom may want to line up early to get one of the limited number of seats before the briefing begins at 9:30 am on March 22 at 1331 Pennsylvania Avenue NW, Suite 1150, Washington, DC.

Notable comments to the Commission include:

Ed Whelan, Ethics and Public Policy Center, written testimony.

John Inazu, Washington University in St. Louis, comment.