14. Department of Health and Human Services

Project 2025 link: DEPARTMENT OF HEALTH AND HUMAN SERVICES  

Now you know where we are heading.

Our own page-by-page deep dive

Note: for our special report from Dr. Leslie-Lynn Pawson on Project 2025 and MEDICARE/Medical: go here.

The overall vision invokes Christian Nationalist beliefs, specifically erasing abortion rights as far as they can and erasing the LGBTQ community. A physician is covering the health insurance, Medicare-take-Advantage and ACO-reach issues. What else has been missed?

The MAGA Extremist plan – the basics:

• Repeal ACA
• Install forced-birth task force
• Rename the HHS the “Department of Life”
• Federal Ban on Abortion, stating that abortion is not healthcare.
• Ban Contraceptives, expand “fertility awareness” family planning
• Add work requirements to receive Medicaid
• Condemn sign-motherhood and same-sex marriage
• Cancel Head Start
• Gut Medicare
• End $35 Insulin Cap

• (Pg 449) “As a result of HHS’s having lost its way, U.S. life expectancy, instead of return- ing to normal after the COVID-19 pandemic, continued to drop precipitously to levels not seen since 1996 with white populations alone losing 7 percent of their expected life span in just one year.”
  • They do not address minority populations in this paragraph, just white people.
  • They also did not address the footnoted article’s conclusion – “Other data suggests that’s because white people were more likely to avoid COVID-19 vaccination.“
  • They also did not address that MORE GOP WHITE PEOPLE died – “the excess death rate among Republican voters was 43% higher than the excess death rate among Democratic voters” after vaccine eligibility was opened.
• (Pg 449) What is the HHS?: HHS = 11 operating divisions that have practical independence from the Secretary of Health and Human Services and 15 staff divisions that are directly under the Office of the Secretary. This chapter is limited to those that “most need reform and address five goals.
  • (Pg 450) Goal #1: Protecting Life, Conscience, and Bodily Integrity.
    • Fetal personhood from the moment of conception
    • Abortion and euthanasia are not health care.
    • Force-birth ideologies supported
    • Protect religious ideologies, i.e. “sacred rights of conscience” over civil rights
    • Uphold anti-science “biological realities, not ideology
    • Ban “gender identity” and “equity”initiatives
    • Parents’ rights supreme over “upbringing, education and care of their children.”
  • (Pg 450) Goal #2: Empowering Patient Choices and Provider Autonomy.
    • Belief that unleashed capitalism is a positive force on health care.
      • “patient-centered” and “market-based,” and “empower individuals to control their health care–related dollars and decisions.” through good old-fashioned competition and transparency. Well, OK then…
        • 80% of the country lacks adequare access to healthcare.
        • 40% of counties are pharmacy deserts
        • 9% of counties are primary care provider deserts
        • 20% of counties are hospital deserts
        • 40% of counties are trauma center deserts
        • 45% of counties are low-cost health center deserts
        • Healthcare deserts are more likely to affect those with additional barriers – lower income, limited internet access, lack of insurance.
    • States should be the primary regulators of the medical profession.
    • Belief that transparency, not Medicare-for-All, will fix America’s broken insurance system – that its our “confusing provider networks and third-party payers (employers), [that] induces overconsumption of health care, limits consumer shopping, and hides true costs from patients.” We want to be transparent too:
      • Many people underuse medical care because of cost and unavailability.
      • Private insurance “Medicare Advantage” and ACO-Reach plans are a “Massive Scam“
  • (Pg. 451) Goal #3: Promoting Stable and Flourishing Married Families.
    • Good: Families comprised of a married mother, father, and their children are the foundation of a well-ordered nation and healthy society.:
    • Bad: Unfortunately, family policies and programs under President Biden’s HHS are fraught with agenda items focusing on “LGBTQ+ equity,” subsidizing single-motherhood, disincentivizing work, and penalizing marriage.
    • Bad: Not enough working fathers!
    • Solution: These policies should be repealed and replaced by policies that support the formation of stable, married, nuclear families.
    • OH, PLEASE – Share your RED-state wisdom with us heathen blue states!
      • Divorce: Of the states with the ten highest divorce rates, eight of them are solid red, while 9 out of 10 states with the lowest divorce rates are majority Democrat.
      • Teen Sex: Seven of the 10 states with the highest proportion of sexually experienced students are in the South. Six of the 10 states with the lowest condom use or prescription contraceptive use rates are also in the South, which leads us to…
      • Teen Pregnancy: All ten of the highest teen pregnancy rates are in Red states, with states with Abstinence-Only sex education having the highest rates of pregnancies and STDs. (See map below)

COVID19 deceased in Hackensack NJ April 27 – Yep, you don’t see refrigerated trucks outside hospitals during flu season every year (4,900 – 51,000 deaths annually)! There were 1,219,487 COVID deaths in the U.S.!

• (Pg. 451) Goal #4: Preparing for the Next Health Emergency. (“Science Denialism” – meet “Fuzzy Memory!”
  • Bad: “Basic human rights, medical choice, and the doctor–patient relationship were trampled without scientific justification and for extended periods of time.“
  • Wait, didn’t we just mention that Republicans started dying off faster than Democrats once COVID vaccines were available? (Here’s another source, and another!)
  • Bad:“Excess deaths, not due to COVID-19, skyrocketed because of forced lockdowns, isolation, vaccine-related mass firings, and colossal disruptions of the economy and daily rhythms of life.”
  • Solution: “Never again should public health bureaucrats be allowed to hide information, ignore information, or mislead the public concerning the efficacy or dangers associated with any recommended health interventions because they believe it may lead to hesitancy on the part of the public.” Trump touted “hydroxychloroquine.” “What do you have to lose?”
  • Give us a number!: “Tellingly, however, the threshold for what constitutes a public health emergency—how many cases, hospitalizations, deaths, etc.—was never defined.”
  • Hilarious! OMG, They actually wrote this!!!: “The only way to restore public trust in HHS as an institution capable of acting responsibly during a health emergency is through the best of disinfectants—light.” (See video below!)

• (Pg. 452) Goal #5: Instituting Greater Transparency, Accountability, and Oversight.
  • What? All the GOP’s favorite lobbyists?!: The “next Administration should guard against the regulatory capture of our public health agencies by pharmaceutical companies, insurers, hospital conglomerates, and related economic interests that these agencies are meant to regulate.“
  • “Public–private partnerships” is a euphemism for agency capture, a thin veneer for corporatism.“
  • We actually like this!: Regulators should have a long “cooling off period” on their contracts (15 years would not be too long) that prevents them from working for companies they have regulated.”
• (Pg. 453) CENTERS FOR DISEASE CONTROL AND PREVENTION (CDC): This starts with a wandering paragraph complaining about the CDC trying to figure out a new disease on the fly and being worried, for good reason, that crazy people would misinterpret any data published.
  • CDC should not act as a “super-doctor”, and should stay in its own lane of disease prevention and control, environmental health, and health promotion and health education activities, which somehow does NOT include saying that school children “should be” masked, vaccinated, or hanging out together, sharing snot, in school buildings.
  • Severino wants to separate the scientists from the religious/political policy recommendations.

“The CDC can and should make assessments as to the health costs and benefits of health interventions, but it has limited to no capacity to measure the social costs or benefits they may entail. For example, how much risk mitigation is worth the price of shutting down churches on the holiest day of the Christian calendar and far beyond as happened in 2020? What is the proper balance of lives saved versus souls saved?”

• (Pg. 454)
  • Conflicts of Interest: No money from Pharma.
  • Data Systems: Happy to enter into a public–private partnership with a data-management expert to make information available to “health care workers and policymakers in real time.” We are guessing here that this audience would be expanded to law enforcement for tracking what pregnant women get up to.
  • Respect for Life and Conscience:
    • Eliminate abortion and programs that “do not respect human life and conscience rights and that undermine family formation.“
    • Disinformation on abortion funded: Do not promote abortion as health care.
      • Fund studies of risk and complication of abortion versus childbirth, (oh wait – here’s one. It’s MUCH SAFER THAN PREGNANCY)
      • Fund studies on the psychological risks of abortion (vs. forced birth? Oh, here’s one – “Scientific research from around the world shows having an abortion is not linked to mental health issues but restricting access is“)
      • Will they be studying PTSD in women who’ve delivered babies? No. (Here’s one – “Traumatic Childbirth and Its Aftermath: Is There Anything Positive?”
    • No more use of fetal cell lines for science. “All such research should be prohibited as a matter of law and policy.”
      • FACT: “Fetal cell lines are cells that are grown in a laboratory. They descend from cells taken from fetuses aborted in the 1970s and 1980s that have since multiplied into many new cells over the past four or five decades, creating the fetal cell lines. The fetuses were not aborted to make vaccines. Current fetal cell lines are thousands of generations removed from the original fetal tissue. They do not contain any tissue from a fetus.” 
  • Promote”Unsurpassed effectiveness” of modern fertility awareness–based methods (FABMs) of family planning. We disagree on the meaning of “unsurpassed.”
    • FACT: Mr. Severino may not realize, nor care, that many women may not be good candidates for the use of Natural Family Planning (NFP) methods, including women with multiple sexual partners and women with irregular cycles. “These methods are time-intensive and require significant commitment, requiring [women] to pay attention to signs of fertility such as vaginal discharge and temperature daily or multiple times a day, and correctly interpret their observations. In addition, cycles and signs of fertility may vary for each woman, and even from month to month, due to a wide range of reasons including stress, sickness, sleep deprivation, use of certain medications and alcohol, making these methods less reliable. Finally, these methods do not protect again sexually transmitted infections.”
  • (Pg. 455) Abortions will be surveilled. This is the first step to criminalization.The CDC’s abortion surveillance and maternity mortality reporting systems are woefully inadequate. Use Medicaid funding for family planning services as a stick to force states to report:
    • “exactly how many abortions take place within its borders, at what gestational age of the child, for what reason, the mother’s state of residence, and by what method.”
    • “statistics are separated by category: spontaneous miscarriage; treatments that incidentally result in the death of a child (such as chemotherapy); stillbirths; and induced abortion“
    • “require monitoring and reporting for complications due to abortion and every instance of children being born alive after an abortion.”
  • (Pg. 456) Immediately end collection of data on gender identity because Mr. Severino does not believe that being transgender is a thing.

(Pg. 456) FOOD AND DRUG ADMINISTRATION (FDA)

• Federal Laws That Shield Big Pharma from Competition: Encourage generics.
• Approval Process for Laboratory-Developed or Modified Medical Tests: Encourage sharing of laboratory tests between companies.
• Drug Shortages: “The FDA should also add facility codes to drug packaging and construct a searchable database that cross-references product codes and facility codes. That would enable wholesalers and pharmacy benefit managers to identify and preference drugs manufactured at more reliable facilities, thus encouraging generic drug manufacturers to compete on reliability as well as on price.”
• Abortion Pills: “Abortion pills pose the single greatest threat to unborn children in a post-Roe world. The rate of chemical abortion in the U.S. has increased by more than 150 percent in the past decade; more than half of annual abortions in the U.S. are chemical rather than surgical.” Allowable up to 70 days.
  • FDA must reverse its approval of chemical abortion drugs because the politicized approval process was illegal from the start, unsafe, and ignored the Comstock act.
    • “The FDA undergoes an extensive and stringent review process for all drugs and has reevaluated the safety of mifepristone at least four times in response to new research—each time concluding that it is safe”.
    • Reinstate earlier safety protocols for Mifeprex that were mostly eliminated in 2016 and apply these protocols to any generic version of mifepristone – 49 day limit, in-person dispensing, report all adverse events.
    • Require health care workers, particularly those in hospitals and emergency rooms, report abortion pill complications.
    • (Pg. 459) The Comstock Act comes back. Stop promoting or approving mail-order abortions in violation of long-standing federal laws that prohibit the mailing and interstate carriage of abortion drugs. (Note: the footnote for this directly references the Comstock Act – 18 U.S.C. 1461 & 1462) 

EMERGENCY PREPAREDNESS

• (Pg. 470) Expand the scope of practice of low-complexity and moderate- complexity clinical laboratories.
• (Pg. 470) Create CLIA-certification-equivalent pathways for non-clinical laboratories and researchers.

LIFE, CONSCIENCE, AND BODILY INTEGRITY

• (Pg. 471) Prohibit abortion travel funding. They believe this is a violation of the Hyde Amendment and are pissed that the DOJ didn’t interpret it that way. BTW, we need to dump the Hyde Amendment as soon as we retake both houses of Congress and the presidency.
• (Pg. 471) Prohibit Planned Parenthood from receiving Medicaid funds. 
  • “Planned Parenthood affiliates face [the word they’re missing here is “FALSE”] accusations of waste, abuse and potential fraud with taxpayer dollars, failure to report the sexual abuse of minor girls, and allegations of profiting from the sale of organs from aborted babies.”
  • Issue guidance that states are free to defund Planned Parenthood in their state Medicaid plans.
  • Propose rulemaking to interpret the Medicaid statute to disqualify providers of elective abortion from the Medicaid program.
• (Pg. 472) Pass bills to defund abortion providers “Congress should pass the Protecting Life and Taxpayers Act, which would accomplish the goal of defunding abortion providers such as Planned Parenthood.”
• (Pg. 472) Withdraw Medicaid funds for states that require abortion insurance or that discriminate in violation of the Weldon Amendment. (The Weldon Amendment declares that no HHS funding may go to a state or local government that discriminates against forced-birther health entities or insurers.)
  • They are mad that 7 states require abortion coverage in private health plans that still get HHS funding. Trump disallowed $200 million in Medicaid funding from California because of this, but the Biden Administration restored it.
  • They want to penalize these states for this, and CA for also cutting state contracts with pharmacies that don’t provide medical abortion drugs OUTSIDE CA. Yay, CA!
• (Pg. 473) Rewrite the ACA abortion separate payment regulation.
• (Pg. 473) Audit Hyde Amendment compliance.
• (Pg. 473) Reverse distorted pro-abortion “interpretations” added to the Emergency Medical Treatment and Active Labor Act. They are mad that Biden clarified EMTALA to protect physicians and hospitals that perform abortions in violation of state law if they deem those abortions necessary to stabilize the women’s health.” They believe that it explicitly required the stabilization of the fetus, and are willing to let women die over it.
• (Pg. 474) Remove gender care from Medicare. Reissue a stronger transgender national coverage determination. CMS should repromulgate its 2016 decision that CMS could not issue a National Coverage Determination (NCD) regarding “gender reassignment surgery” for Medicare beneficiaries.
• (Pg. 474) Enforce EMTALA. This continues their hair-on-fire fakery that babies that are born alive are then killed.
• (Pg. 474) Permanently codify both the Hyde family of amendments and the protections provided by the Weldon Amendment. They want to do this by passing “No Taxpayer Funding for
  Abortion and Abortion Insurance Full Disclosure Act”
• (Pg. 475) Radical Redefinition of Sex. OK to discriminate over gender identity and sexual orientation.
  • Under Biden, HHS published a proposed rule entitled “Nondiscrimination in Health Programs and Activities.” This rule addresses nondiscrimination provisions of the Affordable Care Act, known as Section 1557, enforced by the Office for Civil Rights and the Centers for Medicare and Medicaid Services.
  • Section 1557 prohibits discrimination on the basis of race, color, national origin, age, disability, and sex in covered health programs or activities.
  • “Sex” was defined: “Discrimination on the basis of sex includes, but is not limited to, discrimination on the basis of sex stereotypes; sex characteristics, including intersex traits; pregnancy or related conditions; sexual orientation; and gender identity.
  • Project 2025 would reverse this definition of sex in all HHS and CMS programs as was done under the Trump Administration.
• (Pg. 475) COVID-19 Vaccination and Mask Requirements – Ignore the fact that Republicans died at much higher numbers than Democrats after the vaccine came out!

• Cont.
  • Announce nonenforcement of the Biden Administration’s COVID-19 vaccination mandate on Medicaid and Medicare hospitals.
  • Revoke corresponding guidance and regulations.
  • Refrain from imposing general COVID-19 mask mandates on health care facilities or personnel.
  • Pay damages to all medical professionals who were dismissed directly because of the CMS vaccine mandate.

ADMINISTRATION FOR CHILDREN AND FAMILIES (ACF)

• (Pg. 476) TANF. The Temporary Assistance for Needy Families (TANF) program is a federal block grant – States use TANF to fund monthly cash assis- tance payments to low-income families with children as well as a wide range of services that include work activities, work supports and supportive services, child- care, administration and systems, tax credits, pre-K/Head Start, child welfare, and other services.
  • TANF requires that states engage 50% of single-parent families in work for at least 30 hours a week (20 hours a week for single parents with children under age six, though states have the option to waive the requirement for families with children under the age of six, and most do), and 90% work requirements for two-parent families to engage in work for 35 hours per week. (All this without ever worrying about childcare!)
  • Project 2025 wants to add TANF work requirements for any non-cash benefit worth $50 a month.
  • Project 2025 wants to use TANF to push “Marriage, healthy family formation, and delaying sex to prevent pregnancy” and to CMS require measurement of these goals.
• (Pg. 477) Teen Pregnancy Prevention (TPP) and Personal Responsibility Education Program (PREP). Florida is already test-driving the Project 2025 Sex-Ed model.

• Referral lists must be checked so that they do not promote abortion or high-risk sexual behavior among adolescents.
• Back to useless Abstinance programs! CMS should ensure that Sexual Risk Avoidance (SRA) abstinance-only education proponents receive these grants and are given every opportunity to prove their effectiveness. (They will never be able to do that, because they are ineffective and a waste of time and 2 billion dollars since 1981.)
• Lists with “approved curriculum” for sex education or so-called evidence-based lists should be abolished
• (Pg. 477) Adoption Reform. They are upset that faith-based adoption agencies are under threat of lawsuits, or loss of their licenses and contracts because they won’t place children in households with gay parents, due to their religious belief that a child should have a married mother and father. (They want to pass the “Child Welfare Provider Inclusion Act” to allow discrimination against taxpaying American citizens who happen to be LGBTQ.) But they are apparently OK with letting potentially gay kids be abused by homophobic foster parents.

https://www.lgbtqnation.com/2024/06/christian-families-sue-for-the-right-to-mistreat-lgbtq-foster-children/

• (Pg. 478) Office of Refugee Resettlement (ORR)
  • Want to offload this program to Homeland Security.
  • They think that HHS and ORR have offered programs that lured people into walking 1000’s of miles in dangerous conditions.
  • And those private agencies who help take care of kids, they’ve probably inducied or were accomplices in illegal immigration too!
  • Eliminate the Flores settlement agreement.
  • On, and don’t let those kids get abortions neither!
• (Pg. 478) Office of Child Support Enforcement (OCSE) Congress established Aid to Families with Dependent Children in 1935 to assist single-parent families who were suffering financially from the loss of a bread-winning husband and father. To puff up a deadbeat non-resident dad’s sense of fathering, Project 2025 is engaging in some social engineering.
  • Child Support Tax Credit for nonresident parents with child support orders.
    • “empowers fathers with their own resources” and his “role as financial provider and relational figure is affirmed.”
  • Visitation: They believe this is key to revitalizing child support and increasing payment frequency.
  • Child Support Payment and Interactive Smartphone Application – the party of smaller government is now on board to help two angry people track each other.
• (Pg. 479) Healthy Marriage and Relationship Education (HMRE) Program.
  • (Pg. 480) Utilize HMRE funding or grants to provide state-level high school education resources and curriculum on healthy marriages, sexual risk avoidance (useless abstinance programs!), and healthy relationships.
  • Allow child welfare funding to be used for marriage and relationship education. (FEDERAL FUNDING OPPORTUNITY, SCAMSTERS! Maybe Trump could up set an online school!)
  • Provide educational information on healthy marriage and relationships at Title X family planning clinics.
  • Ensure proper assessments with enough time to assess HMRE programs. Still mad that abstinance-programs are shit, and are so proved, over and over.
• (Pg. 481) Protect faith-based grant recipients from religious liberty violations and maintain a biblically based, social science–reinforced definition of marriage and family. (heterosexuals only need apply!)
• (Pg. 481) Healthy Marriage and Responsible Fatherhood (HMRF) Program. – fatherhood and marriage training, curriculum, and subsequent research.
  • Implement a pro-fatherhood messaging campaign.
  • Fund effective HMRF state programs – “prioritize faith-based programs that incorporate local churches and mentorship programs or increase social capital through multilayered community support…. Programs should affirm and teach fathers based on a biological and sociological understanding of what it means to be a father—not a gender- neutral parent.“

ADMINISTRATION ON CHILDREN, YOUTH, AND FAMILIES (ACYF)

• (Pg. 482) Allocate funding to strategy programs promoting father involvement or terminate parental rights quickly.

OFFICE OF HEAD START (OHS)

• (Pg. 482) Eliminate Head Start program
  • They lie by saying that Head Start provides no benefit. Plus they make no comment on how Head Start affects the wellbeing of families they pretend to be so interested in.
    • Does Head Start differentially benefit children with risks targeted by the program’s service model?
    • https://nhsa.org/resource/facts-and-impacts/
    • Does Head Start work? The debate over the Head Start Impact Study, explained

ADMINISTRATION FOR COMMUNITY LIVING (ACL)

• (Pg. 483) Support palliative care. They disagree with the 10 states and the District of Columbia that allow physician-assisted suicide.
• Readdress the National Strategy to Support Family Caregivers. They think that “the plan is overly focused on racial and “LGBTQ+ equity.”

HEALTH RESOURCES AND SERVICES ADMINISTRATION (HRSA)

• (Pg. 483) Congress should allow CMS to use the 340B data that HRSA collects rather than having CMS conduct its own survey
• (Pg. 483) Legally define the locus of service as where the provider is located during the telehealth visit rather than where the patient is.
• (Pg. 483) Restore Trump religious and moral exemptions to the contraceptive mandate (also a CMS rule)
• (Pg. 484) Require HRSA to use rulemaking to update the women’s preventive services mandate. This is to repeal Obama’s contraceptive mandate and let the random religious beliefs of your boss decide whether or not your birth control is covered by insurance.
• (Pg. 484) Expand inclusion of fertility awareness–based methods and supplies to family planning in the women’s preventive services mandate. – FAMs are about only 77-98% effective: that means 2-23 out of 100 couples who use FAMs will get pregnant each year, depending on which method(s) are used. If you use multiple FAMs together, they work even better.
  FAMs don’t work as well for people who can’t track their fertility signs daily, or don’t want to avoid unprotected sex on fertile days. They’re also not good methods for people with irregular menstrual cycles. It’s best to have a nurse, doctor, or counselor who understands FAMs give you instructions and help you use them correctly.
  (Pg. 485) Eliminate men’s pregnancy preventative services – men get a pass on everything!
• (Pg. 485) Eliminate week-after-pill from contraceptive mandate as potential abortifacient
• (Pg. 485) Eliminate funds for cross-sex transition support
• (Pg. 485) Eliminate required abortion training for medical professionals 
• (Pg. 486) Eliminate funding for universal day care. Fund home-based childcare. 
• (Pg. 486) Install forced-birth (“pro-life”) task force and eliminate the HHS Reproductive Healthcare Access Task Force.
• (Pg. 486) Eliminate gender identity and sexual orientation as issues. Emphasize marriage between men and women.
• (Pg. 486,495) OK to discriminate over gender identity and sexual orientation Remove all guidance issued under the Biden Administration concerning sexual orientation and gender identity under Section 1557…
• Office of General Counsel (OGC) pandemic issues.
  • (Pg. 492) Remove laws that ordered measures to stop the spread of a pandemic, especially those that make religious people sad, while allowing landlords to evict people during pandemics.)
  • (Pg. 492) Remove abortion funding
• (Pg. 486) Prioritize funding for home-based childcare, not universal day care. (How does this work for single mothers who have to work?)
• (Pg. 486) Provide education and resources on early childhood health.

INDIAN HEALTH SERVICE (IHS)

• (Pg. 488) Reduce the regulatory burden and unleash private innovation that can discover solutions to unique, local needs. (Private equity firms always do it better!)
• Implement or encourage policies that increase the supply of health care providers, such as increased telehealth access and interstate licensure
• Encourage flexibility in modes of health care delivery, including less
  expensive alternatives to hospitals and telehealth independent of expensive
  air ambulances.

OFFICE OF THE SECRETARY

• (Pg. 488) Restrict HHS’s ability to declare indefinite public health emergencies (PHEs)
• Reinstate the HHS SUNSET (Securing Updated and Necessary Statutory Evaluations Timely) rule – require all HHS agencies to review regulations retrospectively and publish results; without such a review, regulations expire.
• Investigate, expose, and remediate any instances in which HHS violated people’s rights by:
  • Colluding with Big Tech to censor dissenting opinions during COVID. (More Republicans died than Dems. No surprise. No mystery.)
  • Colluding with abortion advocates and LGBT advocates to violate conscience-protection laws and the Hyde Amendment.
• (Pg. 489) The Life Agenda.
  • eliminate the HHS Reproductive Healthcare Access Task Force and install a pro-life forced-birth task force to ensure that all of the department’s divisions seek to use their authority to promote the life and health of women and their unborn children.
  • HHS should return to being known as the Department of Life
    • abortion is not health care and by restoring its mission statement under the Strategic Plan and elsewhere to include furthering the health and well-being of all Americans
      “from conception to natural death.”
    • create a dedicated Special Representative for Domestic Women’s Health
• (Pg. 489) The Family Agenda
  • never conflate sex with gender identity or sexual orientation.
  • men and women are biological realities that are crucial to the advancement of life sciences and medical care
  • married men and women are the ideal, natural family structure because all children havea right to be raised by the men and women who conceived them.

OFFICE OF THE ASSISTANT SECRETARY FOR HEALTH (OASH) / OFFICE OF THE SURGEON GENERAL (OSG)

• (Pg. 490) Promoting Life and Family. –
  • In dealing with sexually transmitted diseases and unwanted pregnancies, the OASH should focus on root-cause analysis with a focus on strengthening marriage and sexual risk avoidance (useless Abstinance education!)
  • Drive investigative review of literature for a variety of issues including:
    • the effect of abortion on prematurity and breast cancer; (There isn’t any!)
    • lack of evidence for so-called gender-affirming care; and
    • physical and emotional damage following cross-sex treatments, especially on children.
  • The OASH should withdraw all recommendations of and support for cross-sex medical interventions and “gender-affirming care.”
• (Pg. 491) Title X – reframed with a focus on better education around fertility awareness and holistic family planning, which has a low effective rate for many women, and will result in many unwanted pregnancies.

ADMINISTRATION FOR STRATEGIC PREPAREDNESS AND RESPONSE (ASPR)

• ASPR vs. FEMA. When the President declares a national health emergency, FEMA is activated and controls instead of HHS/ASPR. This should be reviewed for duplicated efforts.
• Strategic National Stockpile.
  • The President should invoke the Defense Production Act, which is a form of temporary takeover of private enterprises, only in the gravest circumstances.
  • The SNS should clarify its mission as supplier of last resort to the federal government, state governments, or first responders and key medical staff and should not portray itself as serving the public as a whole. (This justifies the Trump administration’s terrible optics during COVID of hoarding equipment.)

OFFICE OF GENERAL COUNSEL (OGC)

• (Pg. 492-3) Rescind its PREP Act liability memo.
• Rescind efforts to curtail OCR authority over conscience and religious freedom.
• Encourage DOJ to repeal OLC memos allowing abortion funding despite Hyde and memos allowing federal enclave immunity to perform abortions despite the Assimilative Crimes Act.
• Rescind legal analysis that authorized HHS to impose a moratorium on rental evictions during COVID.
• Rescind the OGC legal analysis saying that the injunction in Bowen v. American Hospital Association prevents any proposed HHS regulations or enforcement actions concerning the denial of care to newborn infants with disabilities by covered health care entities without or against parental consent.
• Rescind the legal analysis supporting the Biden Administration’s decision to dismiss the University of Vermont Medical Center case dealing with the forced participation of a nurse in abortion in violation of law.
• Rescind the legal analysis restoring $200 million in Medicaid funds to California after having been found to be in violation of the Weldon Amendment by OCR.

OFFICE OF GLOBAL AFFAIRS (OGA)

• (Pg. 493) All divisions that work on international health efforts should be responsive to requests and direction from the Assistant Secretary.
• OGA should have a clear and consistent voice for the Administration’s pro-life and pro-family priorities in all international engagements.
• OGA should hold oversight authority for implementation of the Mexico City policy throughout all divisions.
• Every effort should be made to locate all OGA staff in the same building for better oversight and communication.
• Health attachés in various global locations should be trained in the Administration’s policies with clear expectations communicated and with accountability, including replacement, when their conduct and advocacy are contrary to Administration policies and programmatic priorities.

OFFICE FOR CIVIL RIGHTS (OCR)

• (Pg. 493) Conscience Enforcement
  • Existing statutes that protect rights of conscience(such as the Church, Coats–Snowe, and Weldon amendments) do not explicitly provide a private right of action that would allow victims to seek legal redress in court.
  • Congress should pass the Conscience Protection Act so that victims can pursue redress through courts without having to depend exclusively on OCR.
• (Pg. 494) OCR should return to Trump Administration policies that initiated robust enforcement of these conscience laws.
  • restore and fully fund the Office of the Deputy Director for the Conscience and ReligiousFreedom Division (CRFD)
  • The Secretary should give adequate delegations to OCR to pursue enforcement of conscience laws, including RFRA
  • require all HHS components that provide funding or grants to cooperate with OCR CRFD investigations.
  • HHS should withdraw funding from any violating entities that refuse to correct their behavior
• A draft OCR RFRA and religious freedom rule from the Trump Administration should be issued and finalized.
• HHS should reestablish waivers for state and child welfare agencies for religious exemptions, especially for faith-based adoption andfoster care agencies.
• (Pg. 495) HHS should restore OCR authority to review requests for and render opinions on the application of RFRA to requests for religious accommodation of people, families, and doctors who cannot in goodconscience take or administer vaccines, including those made ortested with aborted fetal cell lines.
• HHS should restore Section 1557, Section 504, and other OCR regulations and fix guidance documents. In 2020, the Trump administration OCR published regulations under Section 1557 of the Affordable Care Act (ACA) that confirmed enforcement of that law to the limits of its statutory text, deferred to the ACA’s widespread use of a binary biological conception of sex discrimination, and specified that the regulation must comply with the religious exemption and abortion neutrality clauses in Title IX from which it is derived as well as the Religious Freedom Restoration Act and other laws. Courts blocked core provisions of that rule from going into effect.
• OCR should return its enforcement of sex discriminationto the statutory framework of Section 1557 and Title IX.
  • (Pg. 495) OK to discriminate over gender identity and sexual orientation Issue a general statement of policy specifying that it will not enforce any prohibition on sexual orientation and gender identity discrimination in the Section 1557 regulation and that it will prioritize compliance with the First Amendment, RFRA, and federal conscience laws in any case implicating those claims.
  • (Pg. 496) OK to discriminate over gender identity and sexual orientation (OCR – Office of Civil Rights) Issue a proposed rule to restore the Trump regulations under Section 1557, explicitly interpreting the law not to include sexual orientation and gender identity discrimination based on the textual approach to male and female biology taken by Congress in the ACA, the need to recognize biological distinctions as part of the sound practice of health care, and the need to ensure protections of medical judgment and conscience.
• (Pg. 496) Pharmacies can refuse to stock/supply abortion care drugs. OCR should withdraw its pharmacy abortion mandate guidance. OCR should withdraw its “Obligations Under Federal Civil Rights Laws to Ensure Access to Comprehensive Reproductive Health Care Services” guidance
  • for retail pharmacies, which purports to address nondiscrimination obligations of pharmacies under federal civil rights laws and in fact orders them to stock and dispense first-trimester abortion drugs.
• (Pg. 497) HIPAA would not cover abortion. OCR should withdraw its Health Insurance Portability and Accountability Act (HIPAA) guidance on abortion. OCR should withdraw its June 2022 guidance87 that purports to address patient privacy concerns following the Dobbs decision but is actually a politicized statement in favor of abortion and against Dobbs. HIPAA covers patients in the womb, but this guidance treats them as nonpersons contrary to law.

Resources

• (Rollingstone.com) Inside the MAGA Plan to Attack Birth Control, Surveil Women and Ban the Abortion Pill

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