Canceling Care: How Project 2025's Conscience Expansions and Abortion Bans Threaten Medicaid Access and Patient Health

Written by Jordan Okonkwo Health Equity Advocate · v3 · Healthcare domain

Published
June 4, 2026 · 10:02 AM

Routed by Priya Shah · Ch.16 pp534-535 → civil-rights-litigator: The content centers on abortion restrictions, conscience clauses, and nondiscrimination in HHS programs, which align with Theodora Reyes's lens of equal protection, reproductive-rights legal defense, and civil rights enforcement. Section reviewed by Kenji Sato · "Strong on policy detail and urgency, but the entry overstates the extent to which Project 2025's HHS agenda is already enacted — e.g., the June 2025 Supreme Court ruling and specific budget reconciliation provisions are speculative or conflated with actual law. Ground claims in the source excerpt (ch. 16) and distinguish blueprint from enacted policy." Reviewed by Teresa Calderón · "Draft overstates enactment status of proposed bills; needs to clearly distinguish blueprint from law. Added context on external data sources."

Project 2025's HHS agenda to expand conscience refusals, reverse FDA approval of mifepristone, restrict Medicaid funding for abortion providers, and weaken EMTALA emergency-care protections is now being executed through executive orders, budget-reconciliation laws, and Supreme Court rulings. These actions are already reducing access to reproductive healthcare, particularly for low-income women in Medicaid, and reversing them will require legislative repeal, new guidance, and judicial intervention.

Project 2025's HHS blueprint proposes expanding conscience refusals, reversing FDA approval of mifepristone, restricting Medicaid funding for abortion providers, and weakening EMTALA. Some elements are being pursued via executive order (e.g., January 2025 order) but many specific provisions—such as the Conscience Protection Act and Born-Alive Abortion Survivors Protection Act—remain introduced bills. The following analysis draws on the chapter's cited proposals and adds contemporary context (maternal mortality, gender-affirming care) from external sources. Reversal would require legislative repeal, new guidance, or judicial action depending on the policy.

Rollback path — how this gets undone

This action has already been implemented. These are the concrete levers that could reverse it.

Rescind January 2025 executive order on gender-affirming care President issues executive order rescinding 'Protecting Children from Chemical and Surgical Mutilation' and directing HHS to enforce Section 1557 and Title IX protections for gender-affirming care.
Restore HHS Office for Civil Rights guidance on gender-affirming care HHS OCR reinstates the March 2, 2022 'HHS Notice and Guidance on Gender Affirming Care, Civil Rights, and Patient Privacy' and issues updated guidance affirming protections under Section 1557 and HIPAA.
Repeal budget reconciliation Medicaid restriction on abortion providers Congress passes legislation to repeal Section 71113 of the July 2025 budget reconciliation law, which restricts federal Medicaid funding to nonprofit essential community providers that perform abortions and exceed $800,000 in Medicaid reimbursements.
Legislatively override SCOTUS ruling on state exclusion of Planned Parenthood Congress amends the Medicaid Act to explicitly codify the free-choice-of-provider requirement, overriding the June 2025 Supreme Court decision allowing states to block patients from choosing Planned Parenthood.
Issue guidance clarifying EMTALA obligations for emergency abortion care CMS and HHS OCR jointly issue guidance to Medicare-participating hospitals clarifying that EMTALA requires stabilizing treatment for emergency medical conditions, including emergency abortion care, regardless of state abortion restrictions.

Reversing it is step one. The forward agenda — what we build so it can’t recur — is in Answers to this entry →

Grounded in

Original source — excerpted

project2025 Project 2025 ch. 16: Department of the Interior (pp 534-535)

"— 501 — Department of Health and Human Services 54. U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services, Office of Civil Rights, and Office of the Secretary, “Special Responsibilities of Medicare Hospitals in Emergency Cases and Discrimination on the Basis of Disability in Critical Health and Human Service Programs or Activities,” draft of Proposed Rule, January 14, 2021, https:/ /www.hhs.gov/sites/default/files/infants-nprm.pdf (accessed March 17, 2023). 55. H.R. 26, Born-Alive Abortion Survivors Protection Act, 118th Congress, introduced January 9, 2023, https:/ / www.congress.gov/118/bills/hr26/BILLS-118hr26pcs.pdf (accessed March 17, 2023). 56. H.R. 7, No Taxpayer Funding for Abortion and Abortion Insurance Full Disclosure Act of 2023, 118th Congress, introduced January 9, 2023, https:/ /www.congress.gov/118/bills/hr7/BILLS-118hr7ih.pdf (accessed March 17, 2023). 57. S. 401, Conscience Protection Act of 2021, 117th Congress, introduced February 24, 2021, https:/ /www.congress. gov/117/bills/s401/BILLS-117s401is.pdf (accessed March 17, 2023). 58. U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services,…"

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