BALTIMORE — The Little Sisters of the Poor have submitted comments to the Health and Human Services Department explaining why proposed changes to the contraception mandate continue to imperil their religious freedom.

“The federal government should not force us to counteract through the health benefits that we arrange for our employees the very same gospel of life that we attempt to live in communion and solidarity with the needy elderly,” the Little Sisters said in an April 8 comment signed by the superiors of three U.S. provinces.

The Little Sisters of the Poor serve the elderly poor nationwide, providing them with shelter, food and care. The sisters take a vow of hospitality, promising God that they will dedicate themselves to serve the elderly.

The group has 30 homes in the U.S., where they serve some 2,500 impoverished elderly persons.

They made their remarks in the wake of the Obama administration’s mandate that requires employers to provide coverage for sterilization and contraception, including some abortion-causing drugs.

The mandate includes a limited religious exemption that only applies to nonprofit organizations that exist to inculcate religious values and that serve and employ primarily members of their own faith. It is so narrow that most religious groups, as well as some churches, fail to qualify for it.

On March 16, the Obama administration announced a 90-day comment period on possible ways to implement it’s proposed rules on implementing its “accommodations” and “exemptions.”

The Little Sisters’ letter is in response to the HHS’ request for comment.

They explained that the mandate “threatens the operation” of their homes for the elderly poor and that they “may be subjected to steep financial penalties for not changing our health-coverage arrangements at these homes.”

The administration’s “religious employer” exemption does not cover the homes operated by the Little Sisters because of the way they are set up for tax purposes. They explained that “each of our homes is a separate corporate entity” and is considered a “large employer” under the Affordable Care Act.

Just because each home is “separately incorporated,” they argued, this “does not deprive our order’s religious exercise of its religious nature.”

To comply with federal tax law, each home files a Form 990, which provides financial accountability for nonprofit and tax-exempt organizations.

“We have always done our best to comply with all government regulations that apply to our homes and to the highest standards of nonprofit financial stewardship,” wrote the Little Sisters.

“The Form 990 is an important tool for financial accountability in our religious charitable work, but it makes no sense to use the requirement to file it as a disqualifier for the religious-employer exemption.”

“The Little Sisters of the Poor should receive a religious exemption because of what we believe and do rather than the corporate forms through which we carry out our ministry.”

They pointed out that the administration’s proposal itself says that a church should not lose its exemption just because it provides free meals to the poor through a soup kitchen.

The Little Sisters wrote that “we agree,” saying this should apply also to their religious order. “We should not be deprived of an exemption because we maintain homes to provide shelter and loving care to the elderly poor.”

They explained that the employees at their homes are aware that their work is part of the religious ministry of the Little Sisters of the Poor, and they understand the sisters’ commitment to Catholic teaching.

The health insurance offered to the Little Sisters’ employees has always excluded the mandated services which are repugnant to a Catholic conscience, they explained, and this has “never been a matter of controversy in our homes,” they said.

If the exemption is not expanded to include the Little Sister’s homes, they will face “steep financial penalties” for refusing to change their health-coverage arrangements.

Employers who do not comply with the mandate will be fined by the federal government. Violators face fines of $100 per employee per day.

Each of the Little Sister’s 30 American homes employee roughly 100 persons.

The sisters noted that there are numerous ways for the government to advance its interests in public health, while also respecting religious freedom, and that they support the U.S. bishops’ conference’s proposal for an expanded exemption from the HHS mandate.

The lack of religious freedom and conscience protections in the contraception mandate have made it the subject of numerous lawsuits.

There are currently at least 50 lawsuits over the mandate and its proposed modifications, levied by some 150 entities, including dioceses around the country, religious nonprofit organizations such as universities, hospitals and charities, and for-profit companies that reflect their owners’ religious beliefs through their operation.

“We hope that it is unnecessary for us to join the scores of employers that have already resorted to the federal courts for protection,” wrote the sisters.

“But we are only one group among hundreds who will be adversely affected by the HHS mandate, and we respectfully request the department to reach a just resolution that respects the religious freedom and conscience rights of all.”