Full opinion text
JILL PRYOR, Circuit Judge: The” plaintiffs in these consolidated appeals challenge the regulations implementing-what is known as the “contraceptive mandate” of the Affordable Care Act (“ACA”) — the requirement that employers provide health insurance coverage for preventive care (including contraception) to women. Specifically, the plaintiffs argue that the regulations’ accommodation for nonprofit organizations with a religious objection to providing contraceptive coverage violates the Religious Freedom Restoration Act (“RFRA”), 42 U.S.C. § 2000bb, el seq. They claim that the accommodation substantially burdens their religious exercise in violation of RFRA by forcing them to take actions that cause their health plan administrators to provide contraceptive coverage and to maintain a health plan that - serves as a conduit for contraceptive coverage. We reject the plaintiffs’ claims because we conclude that the regulations do not substantially burden their religious exercise and, alternatively, because (1) the government' has compelling interests to justify the accommodation, and (2) the accommodation is the least restrictive means of furthering those interests. Eternal Word Television Network (“EWTN”), the plaintiff in the first appeal, also raises several First Amendment challenges to the accommodation. Because the accommodation is a neutral, generally applicable law that does not discriminate based on religious denomination, we reject EWTN’s challenges under the Establishment and Free Exercise Clauses. We also reject EWTN’s challenge under the Free Speech Clause because, as' discussed below, any speech restrictions that may flow from the accommodation are justified by a compelling governmental interest and are thus constitutional. I. BACKGROUND A. The Affordable Care Act and the Contraceptive Mandate Enacted in 2010, the ACA requires group health insurance plans to provide a minimum floor of coverage without imposing cost sharing (such as deductibles, eo-payments, or co-insurance) on plan participants and beneficiaries. 42 U.S.C. § 300gg-13(a). If an employer fails to provide such coverage in its group employee health plan, it is subject to penalties in the form of a tax of $100 per day per affected person. 26 U.S.C. § 4980D(b)(1). The Women’s Health Amendment to the ACA added to the minimum coverage requirements a mandate that group health plans provide women with coverage for preventive care and screenings. 42 U.S.C. § 300gg-13(a)(4), The requirement was intended in part to “get[ ] rid of, or mini-miz[e], high copays and high deductibles that are often overwhelming hurdles for women to access screening programs.” 155 Cong. Rec. S11987 (Nov. 30, 2009) (statement of Sen. Mikulski). The ACA tasked the Health Resources and Services Administration (“HRSA”), an agency of the Department of Health and Human Services (“HHS”), with promulgating comprehensive guidelines determining which preventive services and screenings would be required. 42 U.S.C. § 300gg-13(a)(4). HHS commissioned the Institute of Medicine (“IOM”) to assist with HRSA’s development of the guidelines. The IOM released a full report in 2011 detailing its study-of various preventive services and its recommendations for coverage under the mandate. Inst, of Medicine, Clinical Preventive Services for Women: Closing the Gaps (2011) (“IOM Report”). The IOM Report discussed at length the positive public health outcomes associated with reducing unintended pregnancies and giving women more control over birth spacing. The United States has a much higher rate of unintended pregnancies — 49 percent of pregnancies in 2001— than other developed countries. Id. at 102. Unintended pregnancies correlate with health problems both for women who experience such pregnancies and for children born as a result of them. Id. at 103. And because women may not realize immediately that they are pregnant, “their entry into prenatal care may be delayed[;] they may not be motivated to discontinue behaviors that present risks for the developing fetus; and they may experience depression, anxiety, or other conditions.” Id. Unintended pregnancies also frequently end in abortion. Id. at 102. The IOM Report also noted the health consequences of pregnancies occurring too closely together in time. For infants, “[sjhort interpregnancy intervals in particular have been associated with low birth weight, prematurity, and small for gestational age births.” Id. at 103. For women, both pregnancy spacing and the ability to avoid pregnancy may significantly affect their health because, among other reasons, some “women with certain chronic medical conditions (e.g., diabetes and obesity) may need to postpone pregnancy until appropriate weight loss or glycemic control has been achieved.” Id. Pregnancy is also contraindicated for some women with serious medical conditions, for example, pulmonary hypertension or Marfan syndrome. Id. at 103-04. The IOM Report also found that “greater use of contraception within the population produces lower unintended pregnancy and abortion rates nationally.” Id. at 105. Pursuant to its statutory authority, HRSA released binding guidelines, based on the IOM Report, that require coverage for “[a]ll Food and Drug Administration approved contraceptive methods, sterilization procedures, and patient education and counseling for all women with reproductive capacity.” U.S. Dep’t of Health & Human Servs., Health Res. & Servs. Admin., Women’s Preventive Services Guidelines (“HRSA guidelines”), http://www.hrsa.gov/ womensguidelines (last visited Feb. 12, 2016); see also 77 Fed.Reg. 8725, 8725-26 (Feb. 15, 2012) (quoting the language in the HRSA guidelines regarding coverage). Implementing regulations developed by the Department of Labor, the Department of the Treasury, and HHS (collectively, the “Departments”) reiterate the contraceptive mandate’s requirement that health plans cover all services listed in the HRSA guidelines. 26 C.F.R. § 54.9815-2713(a)(1)(iv) (Treasury Regulation); 29 C.F.R. § 2590.715-2713(a)(1)(iv) (Labor Regulation); 45 C.F.R. § 147.130(a)(1)(iv) (HHS Regulation). Mindful of religious freedom and the importance of respect for “the unique relationship between a house of worship and its employees in ministerial positions,” the Departments promulgated interim regulations that gave HRSA discretion to exempt from the contraceptive mandate certain group health plans established or maintained by religious employers. See 76 Fed.Reg. 46621, 46623 (Aug. 3, 2011). The Departments defined “religious employer” by incorporating the Internal Revenue Service’s definition of a church or integrated auxiliary from 26 U.S.C. § 6033(a)(3)(A)(i) and (iii). 45 C.F.R. § 147.130(a)(1)(iv)(B) (2011). The definition also required a religious employer to have a religious purpose and to both serve and employ primarily persons who share the religious tenets of the organization. Id. Exercising the discretion the regulations provided, HRSA amended its guidelines to exempt religious employers from the contraceptive mandate. The guidelines, issued on August 1, 2011, required compliance beginning on August 1, 2012. See id. § 147.130(b)(1). The Departments finalized the implementing regulations in February 2012. See 77 Fed.Reg. 8725. At the same time, the Departments established a temporary safe harbor from the contraceptive mandate for nonprofit organizations with religious objections to providing contraceptive coverage. See Dep’t of Health & Human Servs., Guidance on the Temporary Enforcement Safe Harbor for Certain Employers, Health Plans & Group Health Insurance Issuers with Respect to the Requirement to Cover Contraceptive Services Without Cost Sharing (Feb., 10, 2012). The safe harbor remained in effect for the 2012 plan year, ending on August 1, 2013. See id. at 2. The Departments intended to use the safe harbor period to “expeditiously develop and propose changes to the final regulations implementing” the contraceptive mandate. 77 Fed.Reg. 16501, 16503 (Mar. 21, 2012). The changes to the regulations needed to “meet two goals — accommodating non-exempt, nonprofit religious organizations’ religious objections to covering contraceptive services and assuring that participants and beneficiaries covered under such organizations’ plans receive contraceptive coverage witbout cost sharing.” Id. In March 2012, the Departments began the rulemaking process and solicited comments on potential regulations that could achieve these, two goals. Id. at 16501. At the - conclusion of the rulemaking process in July 2013, the Departments promulgated revised regulations that'retained HRSA’s authority to exempt religious employers. See 78 Fed.Reg. 39870 (July 2, 2013). The same day, HRSA released revised guidelines that tracked the Departments’ changes to the religious employer. exemption. The final regulations simplified the definition of a “religious employer,” making the term coextensive with the IRS’s statutory definition and removing the additional qualifications regarding a religious employer’s mission, programs, and employees. 45 C.F.R. § 147.131(a) (2013); see also 78 Fed.Reg. at 39873-74. Religious employers remained categorically exempt from the contraceptive mandate out' of “respect [for] the religious interests of houses of worship and their integrated auxiliaries.” 78 Fed.Reg. at 39874. The Departments noted that the exemption did not undermine their goal of 'making contraceptive coverage available because religious employers and their integrated auxiliaries “are more likely than other employers to employ people of the same faith who share the same objection, and who would therefore be less likely than other people to use contraceptive services even if such services were covered under-their plan.” Id. The revised regulations, which took effect on Aug. 1, 2013, added an accommodation for organizations'that do not qualify as religious employers under the exemption. See 45 C.F.R. § 147.131(b) (2013). So long as an organization is a nonprofit entity holding itself out as a religious organization and has a religious objection to providing contraceptive coverage (we refer to such entities as “eligible organizations”), it may opt .out of the contraceptive mandate. Id. Eligible organizations can take advantage, of the accommodation via one of two procedures. The first procedure requires the organization to complete Employee Benefits Security Administration Form 700 (“Form: 700”). See EBSA Form 700-Certification (Aug. 2014), http://www.dol. gov/ebsa/preventiveserviceseligi bleorganizationcertificationform'.doc. To complete the two-page form, the eligible organization must provide its name and the . name, title, and contact-information of the individual signing the form on.behalf of the organization. The person signing the, form must certify that the organization “has a religious objection to providing coverage for some or all of any contraceptive services that would otherwise be required to be covered.” Id. The form’s recipient depends oh the type of health plan the eligible organization maintains. Employers can provide health benefits either through an -insured health plan or a self-insured health plan. See Cong. Budget Office/ Key Issues in Analyzing Major Health Insurance Pro-posáis 6 (2008). If the eligible organization has an insured plan, it gives Form "700 to the insurance company that provides its health plan (“plan provider”); "if the organization has a self-insured plan, it gives Form 700 to its third-party administrator (“TPA”). ' The plaintiffs in both cases before' us provide health benefits to their employees through self-insured group health plans, and- all employ TPAs to administer their plans. Alternatively, an eligible organization may directly notify HHS of its religious objection to complying with the contraceptive mandate. This more recently developed method of taking advantage of the accommodation arose from the United States Supreme Court’s order granting, a preliminary injunction in Wheaton College v. Burwell, — U.S. -, 134 S.Ct. 2806, 189 L.Ed.2d 856 (2014). After the regulations concerning the exemption and accommodation- procedures were finalized-, the Supreme Court in Burwell v. Hobby Lobby Stores, — U.S. -, 134 S.Ct. 2751, 2759-60, 189 L.Ed.2d 675 (2014), extended the accommodation for nonprofit religious organizations to closely held for-profit corporations whose owners have religious objections to complying with the contraceptive mandate. Three days after the Hobby Lobby decisión was íssúed, the Supreme Court in Wheaton College granted a request for a preliminary injunction pending appellate review to a plaintiff challenging the accommodation itself under RFRA, the same "challenge the plaintiffs mount here. Wheaton Coll., 134 S.Ct. at 2807. The Supreme' Court’s order enjoined HHS from enforcing the accommodation procedure against the college, so long as the college “informed] the ; Secretary of Health and Human Services in writing that it is a nonprofit organization that holds itself out as religious and has religious objections to providing coverage for contraceptive services.” Id. The Supreme Court warned, however, that the injunction order “should not be construed as an expression of the' Court’s views- on the merits.” Id. In response to the order in Wheaton College, the Departments issued interim final regulations in August 2014 "to allow an eligible organization to opt out by sending a letter to HHS, instead óf giving Form 700. to its plan provider or TPA, 79 Fed. Reg. 51092, 51094-95 (Aug. 27, 2014); see Ctr. for Medicare & Medicaid Servs., Model. Notice, https://www.cms.gov/CCIIO/ Resources/Regulations-and-Guidance/ Downloads/Model-Notice-8-22-14.pdf (last visited Feb. 12, 2016). There is no prescribed format for the letter, but it must include: the name of the eligible organization ánd the basis on which it qualifies for an accommodation; its objection based on its sincerely held religious beliefs to coverage of some or all contraceptive services, as applicable (including an identification of the subset of contraceptive services to which coverage the eligible organization objects, if applicable); the plan name and type ...; and the name and contact information for any of the plan’s third party - administrators and health insurance issuers. 45 C.F.R. § 147.131(c)(1)(ii). The regulations became final, without substantial changes, in a set of new rules effective, on September 14, 2015. 80 Fed. Reg. 41318. (July 14, 2015). Under the current rules, if an eligible organization directly notifies HHS of its intent to opt out of the contraceptive mandate, the government then alerts the organization’s health plan provider or TPA that the organization has opted out and describes the plan provider’s or TPA’s resulting obligations. See 26 C.F.R. § 54.9815-2713A(b)(1)(ii)(B), (c)(1)(ii). For insured plans, once an eligible organization avails itself of the accommodation, the plan provider must (1) “[e]xpressly exclude contraceptive coverage from the group health insurance coverage” and (2) “[pjrovide separate payments for any contraceptive services required to be covered” for the plan participants and beneficiaries. 45 C.F.R. § 147.131(c)(2)(i). For self-insured plans, the regulations provide that when an eligible organization invokes the accommodation, its TPA is designated as the plan administrator under the Employee Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1002(16), with respect to contraceptive services. Under the regulations, the TPA is designated as the- plan administrator in one of two ways. If the eligible organization provides a copy of Form 700 to its TPA, then the regulations treat the form “as a designation of the [TPA] as the plan administrator” for ERISA purposes. 29 C.F.R. § 2510.3-16(b). If the eligible organization instead notifies HHS of its intent to opt out, then the Department of Labor notifies the TPA that it shall be the plan administrator with respect to contraceptive services for ERISA purposes. Id. Upon receiving notification, the TPA has the option of terminating its contractual relationship with the eligible organization. See 26 C.F.R. § 54.9815-2713A(b)(2). If it remains as the TPA, then it must provide (or arrange for another insurer to provide) contraceptive benefits to participants and beneficiaries of the self-insured plan. Id.; 29 C.F.R. § 2510.3-16(c). Significantly, plan providers and TPAs “may not impose any cost-sharing requirements (such as a copayment, coinsurance, or a deductible), or impose any premium, fee, or other charge, or any portion thereof, directly or- indirectly, on the eligible organization, the group health plan, or plan participants or beneficiaries.” 26 C.F.R. § 54.9815-2713A(c)(2)(i); 45 C.F.R. § 147.131(c)(2)(ii). Plan providers “must segregate premium revenue collected from the eligible organization from the monies used to provide payments for contraceptive services:” 45 C.F.R. § 147.131(c)(2)(h). A plan provider or TPA also must notify plan participants and beneficiaries (contemporaneously with the delivery of other plan materials, if possible) “that the eligible organization does not administer or fund contraceptive benefits,” but that the plan provider or TPA instead “provides separate payments for contraceptive services.” 26 C.F.R. § 54.9815-2713A(d); 45 C.F.R. § 147.131(d). B. The Parties and Procedural History This opinion addresses two cases: one brought by EWTN and one brought by two Catholic Dioceses and a group of related persons and entities.. Below, we briefly discuss the plaintiffs and the procedural history of each case in turn. 1. Eternal Word Television Network Plaintiff-appellant EWTN is a non-profit worldwide Catholic media network founded in 1981 by Mother Mary Angelica, a Catholic -nun. EWTN, based in Irondale, Alabama, has approximately 350 employees. The network consists of 11 television feeds and two radio- stations that reach 230 million homes in 144 countries and territories. Its programming includes daily Mass, Catholic devotions, coverage of Catholic Church events, documentaries, children’s programs, educational series, and other television and radio shows that support EWTN’s mission of “servpng] the orthodox belief and teaching of the Church as proclaimed by the Supreme Pontiff and his predecessors.” Compl. at 5, No. 1:13-cv-00521-CG-C, Doc. 1. EWTN has a self-insured group health plan to provide health insurance benefits to its employees. Blue Cross Blue Shield of Alabama serves as the TPA for the plan. EWTN, together with the State of Alabama, filed a complaint challenging the contraceptive mandate and accompanying regulations under RFRA, the First Amendment, the Due Process Clause of the Fifth Amendment, and the Administrative Procedure Act' (“APA”), 5 U.S.C. § 701 et seq. The complaint alleged that “EWTN cannot facilitate access to health care insurance ... that covers artificial contraception, sterilization, or abortion, or related education and counseling, without violating its deeply held religious beliefs.” Compl., at 7, No. 1:13-cv-00521-CG-C, Doc. 1. To EWTN, this means that its religious beliefs prevent it both from providing contraceptive coverage in its health plan and from using the accommodation. As a result, EWTN alleged, the contraceptive mandate “imposes government pressure and coercion on EWTN to change or violate its religious beliefs” because,if it does not provide coverage or use the accommodation, it faces fines for non-compliance with the mandate. Id at 27. ' EWTN and Alabama moved for partial summary judgment on five of the 17 counts in the complaint, including: Count One, alleging a violation of RFRA based on the regulations’ burden on religious exercise; Count Two, alleging a violation of the Free Exercise Clause based oh the same burden; Count Three, alleging a violation of the Free Exercise Clause based on intentional discrimination among religious organizations; Count Five, alleging a violation of the Establishment Clause based on the selective imposition of a burden on some religious organizations; and Count Nine, alleging a violation of the Free Speech Clause based on compelled speech. Alabama joined in EWTN’s motion and additionally moved for summary judgment on Count Seventeen, which sought a. declaration that the contraceptive mandate does not preempt Alabama law. The defendants-appellees — the Departments and Their Secretaries — filed a motion to ■ dismiss the complaint or, in the alternative, for summary judgment on all of the plaintiffs’ claims. The district court denied EWTN’s and Alabama’s motions for summary judgment and granted the defendants’ motion for summary judgment as to Counts One, Two, Five, and Nine. On a motion by the plaintiffs, the district court entered a final judgment on those four counts pursuant to Federal Rule of Civil Procedure 54(b) and stayed litigation of the remaining claims pending appeal. EWTN timely appealed. On EWTN’s motion, we issued an injunction pending appeal, preventing the defendants from enforcing the mandate or the accommodation against EWTN. Eternal Word Television Network, Inc. v. Sec’y, U.S. Hep’t of Health & Human Servs., 756 F.3d 1339 (11th Cir.2014). 2. The Diocesan Plaintiffs, CENGI, and Catholic Charities A group of Catholic entities — the Roman Catholic Archdiocese of Atlanta, the Archbishop of Atlanta, Christ the King Catholic School, Catholic Charities of the Archdiocese of Atlanta (“Catholic Charities”), the Roman Catholic Diocese of Savannah, and the Bishop of Savannah — filed a lawsuit against the Departments and their Secretaries. Both the Archdiocese of Atlanta and the Diocese of Savannah (collectively with the Bishop and' Archbishop, ■ “the Dioceses”) are associations of Catholic parishes' and organizations, including Catholic schools. Catholic Charities is a nonprofit organization that provides social services, including immigration counseling, mental health counseling, marriage counseling, and pregnancy support services. The second amended complaint added as a plaintiff Catholic Education of North Georgia (“CENGI”) and removed Christ the King Catholic School. - CENGI- is a nonprofit organization that oversees- five Catholic schools-in the Atlanta area. . The Atlanta Archdiocese operates a self-insured health plan, which covers employees of the Archdiocese, Catholic Charities, and CENGI. The Savannah Diocese operates two self-insured health plans for its employees. Meritain Health serves as the TPA for all three plans. « -- The second amended complaint alleged that the contraceptive mandate and accompanying regulations violate RFRA, the First Amendment, the non-delegation doctrine, and the APA. The plaintiffs alleged that the regulations require them “to provide, pay for, and/or facilitate insurance coverage for abortion-inducing drugs, sterilization, 'and contraception, in violation of their religious beliefs.” Second ' Am. Compl. at 6, No. l:12-cv-03489-WSD, Doc. 56. They alleged that the regulations further burden religious exercise “by driving a wedge between religious organizations, like the Atlanta Archdiocese, and their equally religious charitable -arms,- such as Plaintiffs Catholic Charities and CENGI.” Id. Because the charitable arms do not qualify, as “religious employers,” the Dioceses'alleged they must expel the charities’ employees from their health plans if the Dioceses'wish to take advantage of the religious exemption; The Departments filed a motion to dismiss the second amended complaint or, alternatively, for surrimary judgment' on all counts. *The plaintiffs cross-moved for summary judgment as to seven of their eight counts, which alleged that the mandate and accompanying regulations: burden religious exercise in violation of RFRA (Count One); violate the Free Exercisé Clause, based bn the same burden (Count Two); compel speech in violation of the Free Speech Clause (Count Three); prohibit speech in violation of the Free 'Speech Clause (Count Four); favor certain religious groups and entangle the government in religion in violation of the Establishment Clause (Count Five); interfere with internal church governance in violation of both the Free Exercise and Establishment Clauses (Count Six); and involve an impermissible delegation of unchecked legislative authority to the Departments (Count Seven). The district- court granted summary judgment to Catholic Charities and CEN-GI on their RFRA claims, holding that the contraceptive mandate and accommodation substantially burden the organizations’ religious exercise and are not the least restrictive means to accomplish a compelling governmental interest. The court enjoined the Departments from enforcing the mandate or the accommodation against Catholic Charities and CENGI. In addition, the court granted the plaintiffs’ motion for summary judgment on their claim that the noninterference provision created a content-based speech restriction in violation of the First Amendment. As to the Dioceses’ RFRA claim, the court granted summary judgment to the Departments. The Dioceses had argued first that they might at some point have to pay more in premiums to help cover their plan providers’ cost of contraceptive coverage, in violation of their religious beliefs, and second that the ’distinction between religious employers and organizations eligible for the accommodation would force the Dioceses to remove unaffiliated Catholic schools from their insurance plans. Rejecting both arguments, the district court ruled that the'first argument was merely speculative (and the outcome on which the Dioceses speculated would, in any event, be prohibited by law) and the second argument failed to assert a legitimate religious exercise. The district court granted the Departments summary judgment motion as to all of the plaintiffs’ remaining claims based on the First Amendment, the non-delegation doctrine, and the APA. Despite the split judgment, only the Departments appealed the district court’s decision. Because revisions to the regulations have rendered the plaintiffs’ compelled speech- claim based on the non-interference provision moot, the appeal in this case concerns only the district court’s grant of summary-judgment to Catholic Charities and CENGI on . their RFRA claim. • - II. STANDARD OF REVIEW “This court reviews the district court’s disposition of cross-motions for summary judgment de novo, applying the same legal standards used by the district court, viewing the evidence and all factual inferences therefrom in the light most favorable to the non-movant, and resolving all reasonable doubts about the facts in favor of the non-moving party.” Am. Bankers Ins. Group v. United States, 408 F.3d 1328 (11th Cir.2005). Summary judgment is proper if the movant can show “that there is no genuine dispute as to any material fact and the movant is entitled to judgment as- a matter of law.” Fed. R.Civ.P. 56(a). Where the material' facts are undisputed and all that remains are questions of law, summary judgment may be granted. See Saregama India Ltd. v. Mosley, 635 F.3d 1284, 1290 (11th Cir.2011). III. DISCUSSION A. RFRA Claims 1. Legal Background a. RFRA RFRA provides that the federal government “shall not substantially burden a person’s exercise of religion” unless it demonstrates that the burden “is in furtherance of a compelling governmental interest” and “is the least restrictive means of furthering that compelling governmental .interest.” 42 U.S.C. § 2000bb-1(a)-(b). Congress passed RFRA in 1993 in response to the Supreme Court’s decision in Employment Division, Department of Human Resources of Oregon v. Smith, 494 U.S. 872, 110 S.Ct. 1595, 108 L.Ed.2d 876 (1990), which held that “a law that is' neutral and of general applicability need not be justified by a compelling governmental interest even if the law has the incidental effect of burdening a particular religious practice.” Church of Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520, 531, 113 S.Ct. 2217, 124 L.Ed.2d 472 (1993) (characterizing Smith). In Smith, the Supreme Court reasoned that “[t]o make an individual’s obligation to obey [a neutral'and generally applicable]' law contingent upon the law’s coincidence with his religious beliefs, except where the State’s interest is ‘compelling[,]’ ... contradicts both constitutional tradition and common sense.” Smith, 494 U.S. at 885, 110 S.Ct. 1595 (internal quotation marks and citation omitted). Congress' stated that the.purpose of RFRA was “to restore, the compelling interest test as set forth in Sherbert v. Verner, 374 U.S. 398 (1963) and Wisconsin v. Yoder, 406 U.S. 205 (1972).” 42 U.S.C. § 2000bb(b)(1). Congress declared the strict scrutiny standard provided “a workable test for striking sensible balances between religious liberty and competing pri- or governmental interests.” Id. § 2000bb(a)(5). Indeed, RFRA “pro-, vide[s] even broader protection for religious liberty than was available under” Sherbert or Yoder because the government must also show that it used the least restrictive means to achieve its compelling interest. Hobby Lobby, 134 S.Ct. at 2761 n. 3. b. Hobby Lobby In Hobby Lobby, the Supreme Court held that enforcing the contraceptive mandate without an accommodation against closely held for-profit corporations that objected on religious grounds to providing contraceptive coverage violated RFRA. The corporations and their owners challenged the mandate as substantially burdening. their religious exercise. Id. at 2764-66. The owners of the corporations sincerely believed that life begins at conception and that it is a sin to facilitate access to contraceptive drugs or devices that could destroy an embryo. Id. It was undisputed that the mandate required the plaintiffs to provide health insurance that covered methods of contraception that could résult in the destruction of an embryo. Id. at 2775. The plaintiffs asserted that the mandate left them with only two options: (1) provide coverage for contraception in violation of their religious beliefs or (2) pay significant penalties. Given these choices, the Supreme Court held that the mandate “impose[d] a substantial burden.” Id. at 2779. The government argued there was no substantial burden because the connection between what the mandate required the plaintiffs ,to do (provide health insurance that covered contraception) and the end that they found morally wrong (the destruction of an embryo) was too attenuated. Id. at 2777. The premise of the government’s attenuation argument was that “providing the coverage would not itself result in the destruction of an embryo; that would occur only if an employee chose to take advantage of the coverage and to use one of the four [contraceptive] methods at issue.” Id. In other words, the government asserted that the plaintiffs’ belief — that providing insurance coverage for contraception facilitated the destruction of embryos — was unreasonable. The Supreme Court rejected this argument, which would have required the Court to determine the “circumstances under which it is wrong for a person to perform an act that is innocent in itself but that has the effect of enabling or facilitating the commission of an immoral act by another.” Id. at 2778. The Supreme Court cautioned that “federal courts have no business addressing” such questions of religion and moral philosophy. Id. Instead, the Supreme Court deferred to the plaintiffs’ religious belief that the coverage' “is connected to the destruction of embryo in a way that is sufficient to make it immoral for them to provide the coverage.” Id. The Court then considered whether the mandate survived strict scrutiny. The majority assumed that the mandate furthered a compelling governmental interest but held that it was not the least restrictive means- of doing so. Id, at 2779-80. The Court pointed to the accommodation, which at the time applied only to nonprofit organizations with religious objections, as a less restrictive alternative. The Court explained that after an organization opts out, the plan provider (for insured plans) or TPA (for self-insured plans) must exclude contraceptive coverage, from the group health plan, and provide separate payments- for. contraceptive coverage without-imposing cost sharing requirements on the organization, plan, or plan participants or beneficiaries. Id. at 2782. Although the Court declined to answer whether the accommodation complied with RFRA, it lauded the accommodation as “seek[ing] 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 companies whose owners have no religious objections to providing such coverage.” Id. at 2759. The Court further recognized that “[t]he effect of the HHS-created accommodation on the women employed by Hobby Lobby and the other companies involved in these cases would be precisely zero.” Id. at 2760. c. Wheaton College After Hobby Lobby, the Court considered the accommodation itself in the context of an injunction sought under RFRA in Wheaton College. The Court enjoined the government from enforcing the mandate but required, the. plaintiff to inform HHS in writing that it had religious objections to providing coverage for contraceptive services. 134 S.Ct. at 2807. The Court explained that the government could “rely[ ] on this notice ... to facilitate the provision of full contraceptive coverage.” Id. The practical effect of the Wheaton College decision was twofold: the plaintiff received an accommodation, and HHS could rely on the notification to provide contraceptive coverage to the participants and beneficiaries of the plaintiffs plan. d. Other RFRA Challenges to the Accommodation After Hobby Lobby and' Wheaton College, federal courts around the country considered RFRA challengés to the, accommodation. Applying these two Supreme Court decisions, seven of the eight circuits to review these cases held that the accommodation does not violate RFRA. See Mich. Catholic Conf. & Catholic Family Servs. v. Burwell, 807 F.3d 738 (6th Cir.2015); Catholic Health Care Sys. v. Burwell, 796 F.3d 207 (2d Cir.2015); Little Sisters of the Poor Home for the Aged v. Burwell, 794 F.3d 1151 (10th Cir.), cert. granted sub nom., S. Nazarene Univ. v. Burwell, — U.S. -, 136 S.Ct. 445, 193 L.Ed.2d 346, and cert. granted, — U.S. -, 136 S.Ct. 446, 193 L.Ed.2d 346 (2015); E. Tex. Baptist Univ. v. Burwell, 793 F.3d 449 (5th Cir.), cert. granted, — U.S. —, 136 S.Ct. 444, 193 L.Ed.2d 345 (2015); Univ. of Notre Dame v. Burwell (“Notre Dame II”), 786 F.3d 606 (7th Cir.2015); Geneva Coll. v. Sec’y U.S. Dep’t of Health & Human Servs., 778 F.3d 422 (3d Cir.), cert. granted sub nom., Zubik v. Burwell, — U.S. -, 136 S.Ct. 444, 193 L.Ed.2d 345, and cert. granted, — U.S. -, 136 S.Ct. 445, 193 L.Ed.2d 346 (2015); Priests for Life v. U.S. Dep’t of Health & Human Servs. (“Priests for Life I ”), 772 F.3d 229 (D.C.Cir.2014), reh’g en banc denied, (“Priests for Life II”), 808 F.3d 1 (D.C.Cir.2015), cert. granted, sub nom., Roman Catholic Archbishop of Wash. v. Burwell, — U.S. -, 136 S.Ct. 444, 193 L.Ed.2d 345 (2015), and cert. granted, — U.S. -, 136 S.Ct. 446, 193 L.Ed.2d 345 (2015). These circuits concluded that the accommodation does not substantially burden religious exercise. The Eighth Circuit disagreed, holding that the accommodation' substantially burdens 'religious exercise arid cannot survive strict scrutiny. Sharpe Holdings, Inc. v. U.S. Dep’t of Health & Human Servs., 801 F.3d 927 (8th Cir.2015), petition for cert. filed, 84 U.S.L.W. 3350 (U.S. Dec. 15, 2015) (No. 15-775). Recently, the Supreme Court granted certiorari in several of these cases. The seven circuits that upheld the accommodation recognized that the RFRA claim in Hobby Lobby was fundamentally different from challenges to the accommodation itself. In Hobby Lobby, the plaintiffs challenged the mandate — that is, the requirement that they provide contraceptive coverage — when their only options were to provide the coverage or pay significant penalties. But in the accommodation cases, the plaintiffs have challenged the regulatory scheme that allows them to opt out of the mandate without penalty. Put another way, the plaintiffs in the accommodation cases “do not challenge the general obligation under the ACA to provide contraceptive coverage. They instead challenge the process they must follow to get out of complying with that obligation.” Little Sisters of the Poor, 794 F.3d at 1160. Because they assert that “the exemption process itself imposes a substantial burden on their religious faiths,” their challenges are somewhat “paradoxical and virtually unprecedented.” Priests for Life I, 772 F.3d at 246 (internal quotation marks omitted). The circuits upholding the accommodation recognized that the question of whether there is a substantial burden involves an objective inquiry. After interpreting the ACA arid 'its regulations, they held that the act of opting out does not trigger contraceptive coverage. See, e.g., Notre Dame II, 786 F.3d at 614 (explaining that “[i]t is federal law, rather than the religious organization’s signing and mailing the form, that requires ... third-party administrators of self-insured health plans[ ] to cover contraceptive services”). Although the eligible organizations asserted that the act of opting out makes them complicit in providing coverage, these courts explained that this objection could not constitute a substantial burden because individuals “have no RFRA right to be free from the unease, or even anguish, of knowing that third parties áre legally privileged or obligated to act in ways their religion abhors.” Priests for Life I, 772 F.3d at 246. In Sharpe Holdings, the Eighth Circuit reached the opposite conclusion, holding that the accommodation substantially burdened religious exercise, and enjoined the government from enforcing the accommodation. Relying on Hobby Lobby, the Eighth. Circuit held that it was bound to accept the plaintiffs’ “assertion that self-certification under the accommodation process — using either Form 700 or HHS Notice — -would violate their sincerely held religious beliefs.” Sharpe Holdings, 801 F.3d at 941. Because the plaintiffs faced a substantial penalty if they failed to seek an accommodation or provide contraceptive coverage, the Eighth Circuit concluded there was a .substantial burden. Id. at 942. The Eighth Circuit then applied strict scrutiny. The court assumed that the government had a compelling interest but held that the government, had failed to carry its burden to show that it lacked other means to achieve its interest without imposing a substantial burden on religion. Id. at 943. The Eighth Circuit concluded that less restrictive alternatives included the government: (1) requiring less information from eligible organizations seeking an accommodation; (2) assuming the cost of providing contraceptives through subsidies, reimbursements, tax credits, or tax deductions to employees; (3) paying for distribution of. contraceptives at community health centers, public clinics, and hospitals; or (4) making contraceptive coverage available through the healthcare exchanges. Id. at 944-45. Given these alternatives, the Eighth Circuit concluded that the accommodation failed to survive strict scrutiny. 2. RFRA Analysis With this legal landscape in mind, we now consider the plaintiffs’ RFRA challenge. We hold that their challenge fails because (1) the accommodation does not substantially burden- their religious exercise, and (2) in the alternative, even if there is a substantial burden, the, accommodation survives strict scrutiny. a. The Plaintiffs Allege a Sincere Religious Belief. A threshold question we must ask is whether the plaintiffs’ religious beliefs on which their RFRA claims are based are sincere. See Hobby Lobby, 134 S.Ct. at 2774 n. 28 (“To qualify for RFRA’s protection, an asserted belief must be ‘sincere’ — ”). It is well established that we defer to a plaintiff’s statement of its own belief, so long as the plaintiff actually holds that belief. See id. at 2779 (“[I]t is not for [courts] to say that [the plaintiffs’] religious beliefs are mistaken or insubstantial.”); Davila v. Gladden, 777 F.3d 1198, 1204 (11th Cir.) (“[W]e look pnly to see whether the, claimant ... actually holds the beliefs, he claims ..to hold.” (internal quotation marks omitted)), cert. denied sub nom., Davila v. Haynes, — U.S. -, 136 S.Ct. 78, 193 L.Ed.2d 32 (2015). Each plaintiff states that its religious beliefs prevent it from paying for, providing, or facilitating the distribution of contraceptives. Each plaintiff also asserts that it cannot be complicit in the provision of contraception. The» government does not contest the sincerity of these religious beliefs, nor is there, any indication whatsoever in the record -that the stated beliefs are insincere. We thus conclude that the plaintiffs’ religious beliefs at issue are sincere. '' b. The Accommodation Does Not Substantially Burden the Plaintiffs’ Religious Exercise. We now consider whether, accepting the plaintiffs’ sincere religious beliefs, the accommodation substantially burdens their religious exercise. The plaintiffs assert that’ the act of notifying HHS or their TPAs of their religious objection will either trigger contraceptive coverage or make them complicit in a system that provides such coverage. Due to the significance they attach to opting out, the plaintiffs contend that the accommodation itself imposes a substantial burden because it puts them to the choice of violating their sincerely held religious beliefs or paying a substantial penalty. We accept the plaintiffs’ sincere belief that triggering coverage or being complicit in coverage violates their religious beliefs and that the accommodation puts them to a choice between honoring their religious beliefs and facing significant penalties. We nonetheless conclude that the accommodation imposes no substantial burden. (i) The Substantial Burden Analysis Involves an Objective Inquiry. “[A] ‘substantial burden’ must place more than an inconvenience on religious exercise.” Midrash Sephardi Inc. v. Town of Surfside, 366 F.3d 1214, 1227 (11th Cir.2004). A law is substantially burdensome when it places “significant pressure” on an adherent to act contrary to her religious beliefs, meaning- that it “directly coerces the religious adherent to conform ... her behavior.” Id. Thus, the government imposes a substantial burden when it places “pressure that tends to force- adherents to forego -religious precepts.” Id. This inquiry involves both subjective and objective dimensions. Hobby Lobby made clear that there is a subjective aspect to this inquiry: courts must accept a religious adherent’s assertion that his religious beliefs require him to. take or abstain from taking a ,specified action. See 134 S.Ct. at 2779. But the substantial burden analysis does not end there. We agree with our seven sister circuits that the question of substantial burden also presents “a question of law for courts to decide.” Priests for Life I, 772 F.3d at 247. The objective inquiry- requires courts to consider whether the government actually “puts” the religious adherent to the “choice” of incurring a “serious” penalty or “engaging] in conduct that seriously violates [his] religious beliefs.” Holt v. Hobbs, — U.S. -, 135 S.Ct. 853, 862, 190 L.Ed.2d 747 (2015) (second alteration in original, and internal quotation marks omitted). Put another way, courts must determine what the challenged law actually requires of the plaintiff. For example, in Holt,- a-Muslim inmate-asserted that prison grooming policy substantially burdened his religious exercise because' it prohibited him from growing a' beard,'which his religion required. The Supreme Court explained that because the “grooming, policy requires petitioner to shave his beard,” the policy “put['j” him to the choice of violating his religious beliefs or facing serious disciplinary action. Id. In Holt, as in many RFRA cases, this'' inquiry was straightforward because there was no dispute about what the government’s policy objectively requiréd' of the religious adherent. But when there is a dispute about what a law or governmental policy objectively requires, it is for the courts to construe the law or policy. The plaintiffs here contend that under Hobby Lobby no such objective inquiry is required. In their view, a religious adherent’s mere assertion that she is being compelled to violate her sincerely held religious belief means that - the government has put her to such a choice, regardless of what the law objectively requires. We disagree. In Hobby Lobby, the plaintiffs challenged the contraceptive mandate. It was undisputed that the mandate gave the plaintiffs just two options: provide contraceptive coverage or pay a substantial penalty. Although • the Supreme Court engaged in no objective analysis about what the mandate required, such analysis was unnecessary because the parties agreed that the government, through the mandate, put the plaintiffs to the choice of providing contraceptive coverage or paying a hefty fine. See Hobby Lobby, 134 S.Ct. at 2777-79; see also Priests for Life II, 808 F.3d at 2 (Pillard, J.) (concurring in denial of reh’g en banc) (“The parties in Hobby Lobby did not dispute what the law required, nor its practical effects...:”). Here, the parties agree that the plaintiffs have at least three options: provide contraceptive coverage, pay a penalty,, or use the accommodation to opt- out of providing contraceptive coverage. But they disagree about whether opting out puts the plaintiffs to the choice of violating their religious beliefs or paying a substantial fine. The plaintiffs contend that because an eligible organization’s TPA only becomes obligated to provide coverage when the organization opts out, by opting out they will be triggering coverage. The government argues to the contrary that plan participants and beneficiaries are entitled to contraceptive .coverage under the ACA regardless of any opt out. We conclude that it is for the courts to determine objectively what the regulations require • and whether the government has,' in fact, put plaintiffs to the choice of violating their religious beliefs by seeking the accommodation or incurring a substantial penalty. We reject a framework that takes away from courts the responsibility to decide what action the government requires and leaves that answer entirely to the religious adherent Such á framework improperly substitutes religious belief for legal analysis regarding the operation of federal law. Indeed,-the plaintiffs have identified nothing in RFRA or case law that allows a religious adherent to dictate to the courts what the law requires. The plain language of RFRA simply does not support reducing thé role of federal' courts to “rubber stamps” ‘ that automatically recognize a substantial burden whenever á religious adherent asserts there is one. Catholic Health Care Sys., 796 F.3d at 218. If Congress had intended strict scrutiny to be triggered in all circumstances by a religious adherent’s claim that there is a burden, it would have said so. Instead, it required that the federal government “substantially burden” the adherent's religious exercise. Our, dissenting, colleague concedes that the question of substantial, burden involves •an objective inquiry but asserts that the inquiry should be limited to whether the government .has imposed a substantial penalty. See Dissent at 1179-80. This analysis would require courts to defer to a religious adherent’s sincere belief that the government is forcing her to choose between her .religious belief and paying a substantial fine, even when the religious adherent is objectively wrong about how the law operates and what action the government requires her to take. The dissent’s view is flawed because any burden (even an objectively insubstantial one) becomes a substantial burden if the penalty is heavy enough. We acknowledge that in Hobby Lobby tjie Supreme Court cautioned courts against dictating to religious adherents “the circumstances under which it is immoral for a person to perform an act that is innocent in itself but that has the effect of enabling or facilitating the .commission of an immoral act by another.” 134 S.Ct. at 2778. In some cases, a court’s objective analysis interpreting a statute or regulation may contradict a religious adherent’s sincerely held belief about what that law requires. .But such questions about what a law means are not the type of “difficult and important question of religion and moral philosophy” for which courts must defer to religious adherents. Id; see Notre Dame II, 786 F.3d at 623 (Hamilton, J., concurring) (explaining that the interpretation of the regulations that give rise to the accommodation' “is an issue not of moral philosophy'but of federal law”). Deciding how the law functions is not the only objective part of the substantial burden inquiry. The Supreme Court’s free exercise cases (prior to Smith) distinguished between substantial burdens on religious exercise, which are protected, and de minimis burdens, which are not. For example, a religious adherent may not “require the Government to conduct its own internal affairs in ways that comport” with the person’s religious beliefs, even if the government action interferes with that person’s religious exercise. Bowen v. Roy, 476 U.S. 693, 699-700, 106 S.Ct. 2147, 90 L.Ed.2d 735 (1986); see Lyng v. Nw. Indian Cemetery Protective Ass’n, 485 U.S. 439, 451, 108 S.Ct. 1319, 99 L.Ed.2d 534 (1988) (recognizing that government’s decision to log and.build roads would “have severe adverse effects” on practice of Native American religion but concluding this burden was not “heavy enough” to trigger strict scrutiny under the Free Exercise Clause). ■In Bowen, Nativé American parents challenged federal statutes requiring them to provide- their daughter’s social security number to state welfare agencies as a condition of seeking benefits on the- ground that it impinged upon their free exercise of religion. They sought an accommodation to keep the government from using her social security number in administering benefits, which they believed would rob their daughter of her spirit. 476 U.S. at 695-96, 106 S.Ct. 2147. Even recognizing that the parents had a sincere belief that by using'her social security number the government would be stealing their daughter’s spirit, the Supreme Court rejected their claim, holding that the government’s “use of a Social Security number ... does not itself in any degreé impair [the parents’] freedom to believe, express, and exercfise their] religion.’ ” Id. at 700,106 S.Ct. 2147 (internal quotation marks omitted). The Court rejected the parents’ attempt to use the Free Exercise Clause to “demand that the Government join in their chosen religious practices.” Id at 699-700, 106 S.Ct. 2147. The Court explained that “[t]he Free Exercise Clause affords an individual protection from certain forms of governmental compulsion,” yet.does not extend so far to “afford an individual a right to dictate the conduct of the Government’s internal procedures.” Id. at 700, 106 S.Ct. 2147. The Court acknowledged that the parents’ “religious views may not accept” the line that the Court drew “between individual and governmental conduct,” but it drew a line nonetheless. Id. at 701 n. 6, 106 S.Ct. 2147. Likewise, under RFRA courts must determine whether the burden on a religious adherent is, in fact, substantial. As we alluded to above, the plain language of RFRA supports our conclusion that there is a distinction between a burden. and a substantial burden. RFRA requires strict scrutiny only when the government “substantially burden[s] a person’s exercise of religion.” 42 U.S.C. § 2000bb-l(a). Congress chose to modify “burden” with “substantial[ ],” and we must of course interpret RFRA to give full effect to its every word. See TRW Inc. v. Andrews, 534 U.S. 19, 31, 122 S.Ct. 441, 151 L.Ed.2d 339 (2001) (recognizing that statutes should be construed whenever possible so that “no clause, sentence, or word shall be superfluous, void, or insignificant” (internal quotation marks omitted)). We recognize that the distinction between burden and substantial burden is not implicated in every RFRA case. Nonetheless, there are cases brought under RFRA in which the purported burden is too slight to trigger strict scrutiny. For example, in Kaemmerling v. Lappin, an inmate challenged under RFRA the Bureau of Prison’s collection and analysis of his DNA. 553, F.3d 669, 673-74 (D.C.Cir.2008). He claimed that the government’s sampling, collection, and analysis of his DNA violated his sincerely held religious beliefs about the proper use of DNA. The D.C. Circuit concluded there was no substantial burden.. .Importantly, the inmate had no religious objection to the collection of his bodily material; he challenged only how the government would subsequently use that specimen to extract his DNA information. Id. at 678-79, There was-no question that the Bureau, of Prisons required the inmate to submit a bodily specimen that would be used for an end to which he had a strong religious objection (that is, the collection and analysis of his DNA). But the D.C. Circuit held there was no substantial burden because the inmate “suggested] no way in which these government acts pressure[d] him to modify his own behavior in any way that would violate his beliefs.” Id. at 679.. Kaemmer-ling reinforces that a religious adherent cannot use RFRA to stop the government or third parties from taking subsequent actions to which he objects when the acts required of him impose a de minimis burden. (ii) No Substantial Burden Exists. To determine whether the accommodation objectively puts plaintiffs to the choice of violating their religious beliefs or paying a significant finé, we must understand how the accommodation functions and what it requires of these plaintiffs. The only act that the regulations require the plaintiffs to take is to seek the accommodation — that'is, filling out and sending Form 700 to their TPAs or writing a letter to HHS letting it know of their objections; The plaintiffs do not contend that notifying HHS or their TPAs itself constitutes a substantial burden because of- the time or effort involved. ' Rather, them objection is based on the significance they attribute to this act. They contend that the act - of opting out triggers contraceptive coverage-for plan participants and beneficiaries or makes them complicit in a system that provides contraceptive coverage. We accept that the plaintiffs truly believe that triggering contraceptive coverage or being complicit in a system providing contraceptive coverage violates their religious beliefs. But our objective inquiry leads us to conclude that the government has not put plaintiffs to the choice of violating their religious beliefs or facing a significant penalty. We hold there is no substantial burden. Here’s why: the ACA and HRSA guidelines are what entitle plan participants and beneficiaries to contraceptive coverage. The ACA provides that the plaintiffs’ self-insured plans “shall, at a minimum provide coverage for and shall not impose any cost sharing requirements for ... with respect to women, such additional preventative care and screenings ... as provided for in” the HRSA guidelines. 42 U.S.C. § 300gg-13(a)(4). The HRSA Guidelines, in turn, “require coverage, without cost sharing, for *[a]11 ... [FDA] approved contraceptive methods, sterilization procedures, and patient education and counseling for all women with reproductive capacity.’ ” 77 Fed. Reg. at 8725 (alterations in original) (quoting HRSA guidelines). The plaintiffs and the dissent take a different view of the statutory and regulatory scheme, contending that an eligible organization’s act of opting out triggers the TPA’s designation as plan administrator and, without it, plan participants- or-beneficiaries would not receive contraceptive coverage. Indeed, the dissent asserts that opting out requires an eligible organization’s “affirmative participation” because the act of opting out is the “linchpin on which the contraceptive mandate rests.” Dissent at 1187. We disagree. The ACA and the HRSA guidelines— not the opt out — are, to borrow the dissent’s term, the “linchpins” of the contraceptive mandate because they entitle women who are plan participants and beneficiaries covered by group health insurance plans' tó contraceptive coverage without cost sharing. In other words, women are entitled to contraceptive coverage regardless of their employers’ action (or lack of action) with respect to seeking an accommodation. Because a woman’s entitlement to contraceptive benefits does not turn on whether her eligible organization employer chooses , to comply with the law (by providing contraceptive coverage or seeking an accommodation) or pay a substantial penalty (in the form of a tax) for noncompliance, we cannot say that the act of opting out imposes a substantial burden. We do not mean to imply that the act of opting out plays no causal role in the ultimate provision of contraceptive coverage. We acknowledge that an eligible organization’s act of notifying HHS or its TPA of its objection results in the TPA’s designation as the plan administrator and gives rise to the TPA’s obligation to provide contraceptive coverage. See 29 C.F.R. § 2510.3-16(b). But we view an’ eligible organization’s act of opting out as, at most, an incidental cause of plan participants and beneficiaries receiving contraceptive coverage because these wom’en are-entitled to contraceptive coverage under the ACA and HRSA guidelines regardless of whether the eligible organization opts out: Accordingly, even if the act of opting out in some way leads to ’women receiving the contraceptive coverage to which they were entitled under-federal law, the plaintiffs have failed'to establish 'that thé act of Opting out substantially burdens their religious exercise. Importantly, the government does not force an eligible organization to provide contraceptive coverage, pay costs related to contfaceptive coverage, notify plan participants and beneficiaries of the existence o’f such coverage, or even include the availability of such coverage from a separate source in information the plan provides to plan participants and beneficiaries. Instead, all of these responsibilities fall' upon the TPA. Rather, the only action required of the eligible organization is opting Out: literally, the organization’s notification of its objection. Such an opt out requirement is “typical of religious objection accommodations that shift responsibility to non-objecting entities only after an objector declines to perform a task on religious grounds.” Little Sisters of the Poor, 794 F.3d at 1183. The plaintiffs’ challenge is in substance indistinguishable from an objection to the government’s requiring another entity to provide coverage in their stead. See Catholic Health Care Sys., 796 F.3d at 224 (characterizing an identical challenge as seeking a “blanket religious veto over the government’s interactions with others”). Put differently, the plaintiffs’ opposition to opting out is an objection to their inability to keep the TPA with which they have contracted to provide services in connection with healthcare coverage from complying with the relevant regulations. The plaintiffs point to a but-for causal .relationship between their opting out and the conduct that they find religiously objectionable. But, as the Supreme Court has explained, a religious adherent cannot claim a substantial burden based on the subsequent conduct of another party. See Bowen, 476 U.S. at 699-700, 106 S.Ct. 2147 (“Ju