Brief for HHS et al. Thus, contrary to the dissent’s protestations, it was Congress, not the Departments, that declined to expressly require contraceptive coverage in the ACA itself. 82 Fed. See supra, at 8–9. It is not enough to ask whether noncompliance entails “substantial adverse practical consequences.” One must also ask whether compliance substantially burdens religious exercise. of Ind. Reg. See Tr. 39871 (2013). Among the first was the state of Pennsylvania and later joined by New Jersey, which challenged the Government in the United States District Court for the Eastern District of Pennsylvania, asserting that the process violated the Administrative Procedure Act (APA), Title VII of the Civil Rights Act of 1964, and the Equal Protection Clause of the Fourteenth Amendment and the Establishment Clause of the First Amendment of the Constitution. Thus, it is Congress, not the Departments, that has failed to provide the protection for contraceptive coverage that the dissent seeks.8,  No party has pressed a constitutional challenge to the breadth of the delegation involved here.  The position advocated by the Government and endorsed by the Court and the opinion concurring in the judgment encounters further obstacles. See 45 CFR §147.132. In fact, HHS has already devised and implemented a system that seeks to respect the religious liberty of religious nonprofit corporations while ensuring that the employees of these entities have precisely the same access to all FDA-approved contraceptives as employees of [other] companies.”). The request for comments in the 2017 IFRs readily satisfies these requirements. Additionally, this Court stated in Hobby Lobby that the mandate violated RFRA as applied to entities with complicity-based objections. See Gitlitz v. Commissioner, 531 U. S. 206, 220 (2001). The second created a similar “moral exemption” for employers with sincerely held moral objections to providing some or all forms of contraceptive coverage. ), that extension, as just explained, cannot be extracted from the ACA’s text.16. Those Guidelines mandate that health plans provide coverage for all Food and Drug Administration approved contraceptive methods. 25  Religious organizations have observed that, under the self-certification accommodation, insurers need not, and do not, provide contraceptive coverage under a separate policy number. See supra, at 8–9. 7734 (2019).  In these cases, the Court of Appeals held, among other things, (1) that the Little Sisters of the Poor lacked standing to appeal, (2) that the Affordable Care Act (ACA) does not permit any exemptions from the so-called contraceptive mandate, (3) that the Departments responsible for issuing the challenged rule1 violated the Administrative Procedure  Act (APA) by failing to provide notice of proposed rulemaking, and (4) that the final rule creating the current exemptions is invalid because the Departments did not have an open mind when they considered comments to the rule. That reading of the ACA would create serious tension with Hobby Lobby, which pointed to the self-certification accommodation as an example of a less restrictive means available to the Government, 573 U. S., at 730–731, and Zubik, which expressly directed the Departments to “accommodat[e]” petitioners’ religious exercise, 578 U. S., at ___ (slip op., at 4). 57592, codified at 45 CFR pt. See Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U. S. 837, 842–843 (1984); see also Arlington v. FCC, 569 U. S. 290, 301 (2013) (holding that Chevron applies to questions about the scope of an agency’s statutory authority). 57592; see also id., at 57537–57538. The dissent also does not—as it cannot—dispute our directive in Zubik. 77 Fed. Reg. Since the ACA’s passage, “[gainfully employed] [w]omen, particularly in lower-income groups, have reported greater affordability of coverage, access to health  care, and receipt of preventive services.” Brief for 186 Members of Congress 21.  Religious employers, including petitioner Little Sisters of the Poor Saints Peter and Paul Home (Little Sisters), nonetheless urge that the self-certification accommodation renders them “complicit in providing [contraceptive] coverage to which they sincerely object.” Brief for Little Sisters 35. As relevant, the States—respondents here—once again challenged the rules as substantively and procedurally invalid under the APA.  “Our analysis begins and ends with the text.” Octane Fitness, LLC v. ICON Health & Fitness, Inc., 572 U. S. 545, 553 (2014). 83 Fed. Ibid. Ante, at 15. Co., 463 U. S. 29, 43 (1983) (internal quotation marks omitted).  Under RFRA, the Federal Government may not “substantially burden a person’s exercise of religion even if the burden results from a rule of general applicability,” unless it  “demonstrates that application of the burden to the person—(1) is in furtherance of a compelling governmental interest; and (2) is the least restrictive means of furthering that compelling governmental interest.” §§2000bb–1(a)–(b). Reg. §553(b)(3)(B). Particularly in the context of these cases, it was appropriate for the Departments to consider RFRA. See Webster’s Third New International Dictionary 1827 (2002) (Webster’s Third); American Heritage Dictionary 1411 (4th ed. Moreover, the nationwide reach of the injunction “was ‘necessary to provide complete relief to the plaintiffs.’ ” Trump v. Hawaii, 585 U. S. ___, ___, n. 15 (2018) (Sotomayor, J., dissenting) (slip op., at 25, n. 13) (quoting Madsen v. Women's Health Center, Inc., 512 U. S. 753, 765 (1994)). The District Court subsequently granted a temporary injunction on the new HHS rulings,[6] which the Third Circuit upheld, stating that the new rules violated the APA and were unnecessary by both the ACA and the RFRA making them arbitrary and capricious, and ordering a nationwide injunction on their use.  The same principle applies here. The District Court issued a preliminary nationwide injunction against the implementation of the final rules, and the Third Circuit affirmed. 930 F. 3d 543, 576 (CA3 2019). Finally, obtaining care from a government- funded program instead of one’s regular care provider creates a continuity-of-care problem, “forc[ing those] who lose coverage away from trusted providers who know their medical histories.” NWLC Brief 18.  The second option for women losing insurance coverage for contraceptives is to pay for contraceptive counseling and devices out of their own pockets.  Even assuming that the APA requires an agency to publish a document entitled “notice of proposed rulemaking” when the agency moves from an IFR to a final rule, there was no “prejudicial error” here. That issue is now ready for resolution, unaffected by today’s decision. Reg.  Justice Thomas delivered the opinion of the Court. Respondents present two arguments on this score. See 83 Fed. “[O]ne person’s right to free exercise must be kept in harmony with the rights of her fellow citizens.” Hobby Lobby, 573 U. S., at 765, n. 25 (Ginsburg, J., dissenting).  “Under th[e] accommodation, [an employer] can self-certify that it opposes providing coverage for particular contraceptive services. The Departments requested post-promulgation comments on both IFRs. The first IFR significantly broadened the definition of an exempt religious employer to encompass an employer that “objects . . .   1. The Departments had the authority under the ACA to promulgate the religious and moral exemptions. We now send these cases back to the lower courts, where the Commonwealth of Pennsylvania and the State of New Jersey are all but certain to pursue their argument that the current rule is flawed on yet another ground, namely, that it is arbitrary and capricious and thus violates the APA. I would bring the Little Sisters’ legal odyssey to an end.  For years, religious organizations have challenged the self-certification accommodation as insufficiently protective of their religious rights. (emphasis added). Reg.  Fourth, the Court’s recognition in today’s decision that the ACA authorizes the creation of exemptions that go beyond anything required by the Constitution provides further evidence that Congress did not regard the provision of cost-free contraceptives to all women as a compelling interest. (I will call this the “church exemption.”) This narrow exemption was met with strong objections on the ground that it furnished insufficient protection for religious groups opposed to the use of some or all of the listed contraceptives. Reg. I would therefore affirm the judgment of the Court of Appeals.28. The Free Exercise Clause simply cannot be understood to require the Government to conduct its own internal affairs in ways that comport with the religious  beliefs of particular citizens.” Id., at 699.22,  Roy signals a critical distinction in the Court’s religious exercise jurisprudence: A religious adherent may be entitled to religious accommodation with regard to her own conduct, but she is not entitled to “insist that . . .  In these consolidated cases, we decide whether the Government created lawful exemptions from a regulatory requirement implementing the Patient Protection and Affordable Care Act of 2010 (ACA), 124 Stat. Likewise, though we did not decide whether the self-certification accommodation ran afoul of RFRA in Zubik, we directed the parties on remand to “accommodat[e]” the free exercise rights of those with complicity-based objections to the self-certification accommodation.  None of this is to say that the Departments could not issue a valid rule expanding exemptions from the contraceptive mandate. 932, 957 (1919))). Reg. Some of these women may have a greater need for free contraceptives than do women in the work force. We have had a history of accommodation, of tolerance. See Ali v. Federal Bureau of Prisons, 552 U. S. 214, 227 (2008); see also Rotkiske v. Klemm, 589 U. S. ___, ___ (2019) (slip op., at 6); Husted v. A. Philip Randolph Institute, 584 U. S. ___, ___ (2018) (slip op., at 16). Accordingly, respondents’ second procedural challenge also fails.14. Once it is recognized that the prior accommodation violated RFRA in some of its applications, it was incumbent on the Departments to eliminate those violations, and they had discretion in crafting what they regarded as the best solution. Pp. The ACA does not explicitly exempt RFRA, and the regulations implementing the contraceptive mandate qualify as “Federal law” or “the implementation of [Federal] law” under RFRA. This means that HRSA has virtually unbridled discretion to decide what counts as preventive care and screenings. See 78 Fed. 13  We note as well that the Departments promulgated many other IFRs in addition to the three related to the contraceptive mandate. This provision was designed “to promote equality in women’s access to health care,” countering gender-based discrimination and disparities in such access. Nothing in RFRA requires that a violation be remedied by the narrowest permissible corrective.  Justice Alito, with whom Justice Gorsuch joins, concurring. CBO, Federal Subsidies for Health Insurance for People Under Age 65: 2019 to 2029, pp. 15–16 (2019). 22–24. 28844 (statement of Sen. Hagan) (“When . . . See supra, at 13. “To correct this oversight, Senator Barbara Mikulski introduced the Women’s Health Amendment,” now codified at §300gg–13(a)(4). For other nonprofit and closely held for-profit organizations opposed to contraception on religious grounds, the agencies made available an accommodation rather than an exemption. The Supreme Court issued a ruling today upholding a pro-life order from President Donald Trump that protected the Little Sisters of the Poor from being force to pay for abortion-causing drugs under their health insurance plan. Moreover, that same rule forced 1,041 health providers, serving more than 41% of Title X patients, out of the Title X provider network due to their affiliation with abortion providers. Reg. Litigation surrounding that requirement has lasted nearly as long.  Our remand in Zubik put these two conflicting interpretations to the test.  Thus, as the Departments began the task of reformulating rules related to the contraceptive mandate, they did so not only under Zubik’s direction to accommodate religious exercise, but also against the backdrop of Hobby Lobby’s pronouncement that the mandate, standing alone, violated RFRA as applied to religious entities with complicity-based objections. It is hard to see how the Departments could promulgate rules consistent with these decisions if they did not overtly consider these entities’ rights under RFRA. 16–17. 57536 (2018); id., at 57592. I therefore dissent from the Court’s judgment, under which, as the Government estimates, between 70,500 and 126,400 women would immediately lose access to no-cost contraceptive services. As Justice Alito acknowledges, however, the critical inquiry has two parts. Brief for Petitioners in No.  The first option—the one suggested by the Government in its most recent rulemaking, 82 Fed. In the Departments’ view, the exemption was “necessary to expand the protections” for “certain entities and individuals” with “religious objections” to contraception. Until that rulemaking occurred, the 2012 rule also provided a temporary safe harbor to protect such employers. 47813, 47854. serve[d] people of different religious faiths.” 78 Fed. as Amici Curiae 22. Section 300gg–13(a)(4) includes no such exemption. 2  The ACA exempts “grandfathered” plans from 42 U. S. C. The safe harbor covered nonprofits “whose plans have consistently not covered all or the same subset of contraceptive services for religious reasons.”3 Thus, the nonprofits who availed themselves of this safe harbor were not subject to the contraceptive mandate when it first became effective. See supra, at 18–19.26  But that use originated from the ACA and its once-implementing regulation, not from religious employers’ self- certification or alternative notice. Chrysler Corp. v. Brown, 441 U. S. 281, 297–298 (1979).  The States also object to the new rule because it makes exemptions available to publicly traded corporations, but the Government is “not aware” of any publicly traded corporations that object to compliance with the mandate. The Government next points to the modifier “evidence-informed” placed in (a)(3), but absent in (a)(4). Brief for HHS et al. Even if the mandate served a compelling interest, the accommodation still would not satisfy the “exceptionally demanding” least-restrictive-means standard. The statute does not, as Congress has done in other statutes, provide an exhaustive or illustrative list of the preventive care and screenings that must be included. 41324 (final rule explaining that “[t]he Departments believe that the definition adopted in these regulations complies with and goes beyond what is required by RFRA and Hobby Lobby”). 578 U. S., at ___ (slip op., at 4). Based on this analysis, the Court of Appeals affirmed the nationwide injunction issued by the District Court. contraceptives . . . 41325 (2015) (the exemption “recogni[zes] [the] particular sphere of autonomy [afforded to] houses of worship . . .  Under the ACA, an employer-sponsored “group health plan” must cover specified “preventive health services” without “cost sharing,” 42 U. S. C. §300gg–13, i.e., without  such out-of-pocket costs as copays or deductibles.2 Those enumerated services did not, in the original draft bill, include preventive care specific to women. Little Sisters of the Poor Saints Peter and Paul Home v. Pennsylvania, 591 U.S. ___ (2020), was a United States Supreme Court case involving ongoing conflicts between the Patient Protection and Affordable Care Act (ACA) and the Religious Freedom Restoration Act (RFRA) over the ACA's contraceptive mandate. Cf. §2000bb–3(b). But the dissent points to no case, brief, or rule in the nine years since the church exemption’s implementation in which the Departments defended its validity on that ground.  Second, if Congress thought that there was a compelling need to provide cost-free contraceptives for all working  women, why didn’t Congress mandate that coverage in the ACA itself? It strikes a balance between women’s health and religious opposition to contraception, preserving women’s access to seamless, no-cost contraceptive coverage, but imposing the obligation to provide such coverage directly on insurers, rather than on the objecting employer. Then, in Wheaton College v.  Most saliently, the language in §300gg–13(a)(4) mirrors  that in §300gg–13(a)(3), the provision addressing children’s preventive health services. Automobile Ins. Together with a diverse network of collaborators, we serve the elderly poor in … 10  This opinion uses “Brief for HHS et al.” to refer to the Brief for Petitioners in No. That statute instructs that the “Government shall not substantially burden a person’s exercise of religion even if the burden results from a  rule of general applicability,” unless doing so “is the least restrictive means of furthering [a] compelling governmental interest.” 42 U. S. C. §2000bb–1(a), (b). Burwell v. Hobby Lobby Stores, Inc., 573 U. S. 682, 717 (2014) (noting the oddity of “a publicly traded corporation asserting RFRA rights”). First, they took strong exception to the requirement that they maintain and pay for a plan under which coverage for contraceptives would be provided. The Little Sisters, among others, maintained that the accommodation itself made them complicit in providing contraception. But  RFRA cast a long shadow over the Departments’ rulemaking, see ante, at 19–22, and that statute does not apply to those with only moral scruples. Unlike the earlier church exemption, the accommodation did not exempt these religious employers from the contraceptive mandate, but the Departments construed invocation of the accommodation as compliance with the mandate. Foundation, 454 U. S. 151, 168 (1981). Here, the pivotal phrase is “as provided for.” To “provide” means to supply, furnish, or make available. is simply too attenuated.” Hobby Lobby, 573 U. S., at 723–724. When the 2010 IFR was originally published, the Departments began receiving comments from numerous religious employers expressing concern that the Guidelines would “impinge upon their religious freedom” if they included contraception. 75  Fed. 83 Fed. 57576–57577 (“Of course, some of the[ ] religious” institutions that “do not conscientiously oppose participating” in the accommodation “may opt for the expanded exemption[,] but others might not”); id., at 57561 (“[I]t is not clear to the Departments” how many of the religious employers who had used the accommodation without objection “will choose to use the expanded exemption instead”). After seven years of unending legal conflict to save their ministry, the Supreme Court has ruled in favor of the Little Sisters of the Poor 7-2, allowing them to continue serving the elderly poor and dying without threat of millions of dollars in fines. The District Court answered “no,” and preliminarily enjoined the blanket exemption nationwide. Unless otherwise noted, this opinion refers to the religious and moral exemptions together as “the exemption” or “the blanket exemption.”. The Departments stated that the accommodation aimed to “protec[t]” religious organizations “from having to contract, arrange, pay, or refer for [contraceptive] coverage” in a way that was consistent with and did not violate the Religious Freedom Restoration Act of 1993 (RFRA), 107 Stat. Reg. But  the same capacious grant of authority that empowers HRSA to make these determinations leaves its discretion equally unchecked in other areas, including the ability to identify and create exemptions from its own Guidelines. The Little Sisters of the Poor are headed back to the Supreme Court to protect themselves from being force to fund abortions under Obamacare. Automobile Ins. §300gg–13(a)(4)—i.e., “those [plans] that existed prior to March 23, 2010, and that have not made specified changes after that date.” Burwell v. Hobby Lobby Stores, Inc., 573 U. S. 682, 699 (2014). 19  Title X “is the only federal grant program dedicated solely to providing individuals with comprehensive family planning and related preventive health services.” HHS, About Title X Grants, www.hhs.gov/opa/ title-x-family-planning/about-title-x-grants/index.html. See Zubik v. Burwell, 578 U. S. ___, ___ (2016) (per curiam) (slip op., at 4)  (“[T]he parties on remand should be afforded an opportunity to arrive at an approach . . . On that question, all the two opinions have in common is equal certainty they are right. Zubik v. Burwell, 578 U. S. ___, ___ (2016) (per curiam). of Oral Arg.  Compelling interest. Id., at 47850, 47861–47862. One hundred nine of those plans covering 727,000 people, the Government estimates, will use the religious exemption, while 100 plans covering more than 2.1 million people will continue to use the self-certification accommodation. That “ ‘absent provision[s] cannot be supplied by the courts,’ ” ante, at 16 (quoting Rotkiske v. Klemm, 589 U. S. ___, ___ (2019) (slip op., at 5), militates against the Court’s conclusion, not in favor of it. Reg. See Dept. Ultimately, however, we opted to remand the cases without deciding that question. 10  The dissent claims that “all agree” that the exemption is not supported by the Free Exercise Clause. We have repeatedly stated that the text of the APA provides the “ ‘maximum procedural requirements’ ” that an agency must follow in order to promulgate a rule. In Hobby Lobby, the Government asserted and we assumed for the sake of argument that the Government had a compelling interest in “ensuring that all women have access to all FDA-approved contraceptives without cost sharing.” 573 U. S., at 727. And Affordable care Act Implementation part 36, p. 4 ( 2017 ) providing contraceptives! 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