D.W.
Unfortunately, exclusion or denial of coverage for previous cesarean sections is legal in most states (maybe even all states). See this article in the Times http://www.nytimes.com/2008/06/01/health/01insure.html
As soon as I saw this new trend in the insurance industry, I sent off a blistering letter to the chair of the OB/GYN department at UIC Medical Center. Moms are left in a catch-22 situation when it comes to c-sections. OBs have incentive to perform them and avoid any unfavorable outcomes and potential malpractice suits. But, VBAC bans have been growing thanks to ACOG and now many women who want to have a VBAC are not allowed.
Clearly, many OBs aren't even considering this much longer-lasting implication of doing any c-section. The topic of potential future denial of health insurance coverage in the individual market certainly didn't come up in my "informed" (or was it "uninformed") consent discussion with my OB before the c-section for breech position.