It remains to be seen whether this basic idea will persuade the courts to dismiss the objections that have been raised to all this. It also remains to be seen whether the idea is practical; it seems to me complex and anything but straightforward.

Will objections mostly come from insurance companies? Maybe, but I think they will also arise from TPA’s including insurance companies acting solely as TPA’s for their self-insured customers. For one thing, TPA’s won’t want to accept liability for placing any insurance. That will impose on them not simply new administrative costs, but potentially new insurance costs, which may also need to include protection from liability for being sued by insured persons just like with any other insurance. It also remains to be seen how large the insurance premiums for contraceptive coverage will be. The unit cost is low but as the units are “free” to insured persons there is no restraint to utilization – so the premiums may well be consequential. [For such low-cost units, it still seems to me more efficient and not at all obstructive, simply to continue with direct purchase or with the freebies presently handed out by organizations such as Planned Parenthood - and avoid the entire Rube-Goldberg contraption of "insurance" dreamed up by HHS in this case]. Also – do FFE’s already exist or would their presence mean another bureaucracy must be created?

A lot, it seems to me, remains to be seen.