HHS Conscience Rule Enforcement and Medical Training Restrictions
Project 2025's reproductive health agenda is already partially in motion: HHS has announced comprehensive enforcement of conscience rights (Jan 2026), while new requirements for state compliance with the Coats-Snowe Amendment, ACGME accreditation, and opt-in abortion training for medical students remain proposed but signal a coordinated effort to restrict abortion access through medical education regulation.
The partial implementation of Project 2025's conscience rights enforcement at HHS represents a coordinated attempt to weaponize existing federal law against abortion access. On January 21, 2026, HHS announced 'comprehensive action' to enforce conscience protections, aligning with Project 2025's call to investigate state medical school compliance with the Coats-Snowe Amendment. This amendment, enacted as Section 245 of the Public Health Service Act, prohibits discrimination against health care entities that refuse to provide or undergo training for abortion. While the law itself is not new, Project 2025's interpretation goes far beyond its text: it would require states receiving HHS funds to issue compliance regulations, mandate that ACGME accreditation standards not require any abortion training, and communicate to medical schools that all abortion-related training must be opt-in rather than opt-out. The mechanism for enforcement would likely build on the 2019 HHS conscience rule, which established enforcement procedures and required recipients of federal funds to certify compliance.
The stakes are profound for medical education, reproductive rights, and patient access. The proposed requirement that abortion training be opt-in rather than opt-out would effectively eliminate exposure to abortion care for most medical students and residents, creating a workforce pipeline crisis. Currently, about one in four U.S. medical schools already do not offer any abortion training; under Project 2025's framework, even schools that currently provide opt-out training would be forced to change. This threatens the basic competence of new physicians — even those who never intend to provide abortions must understand the procedure to manage complications, counsel patients, and recognize ectopic pregnancies. The Guttmacher Institute's tracking report confirms that the administration has already implemented multiple Project 2025 reproductive health actions, making this a present-tense fight.
There is a better path. Instead of using conscience law as a cudgel, we should invest in comprehensive reproductive health training that respects all providers' beliefs while ensuring every patient can access care. The 2019 conscience rule was already struck down in part by courts for overreach; a new administration could rescind any enforcement policy that expands beyond the narrow statutory text. Congress could also codify protections for patients' right to timely care, so that no hospital can refuse to provide emergency abortion care even if its staff has individual objectors. Meanwhile, the proposed expansion of doula funding for low-income mothers — one provision in this section — is actually a sensible step that should be preserved and separated from the rest of the agenda.
The humanitarian alternative
Congress should pass legislation clarifying that Coats-Snowe protects individual conscientious objectors without requiring states to mandate opt-in training or penalize accreditors. HHS should issue guidance affirming that institutions may offer opt-out training as long as objecting individuals are accommodated. Doula funding should be expanded unconditionally, and the SUNSET rule should not be reinstated because it creates regulatory instability that harms patient safety.
Rollback path — how this gets undone
This action has already been implemented. These are the concrete levers that could reverse it.
- Rescind any new HHS OCR enforcement policy targeting medical schools HHS Secretary should withdraw the January 2026 press release and any accompanying investigation directives, and issue guidance clarifying that Coats-Snowe does not require states to police medical curricula or opt-in training.
- Withdraw proposed rule requiring states to issue Coats-Snowe compliance regulations If the rule has been proposed, HHS should withdraw it and instead issue non-binding guidance that protects individual objectors without conditioning federal funds on state policing of medical education.
- Issue HHS guidance that ACGME accreditation may include opt-out training HHS should clarify that federal conscience statutes do not prohibit ACGME from requiring abortion training, as long as individual residents can opt out without consequence.
- Reverse any grant conditions that exclude abortion-related care from doula funding If doula funding has been conditioned on not providing abortion-related support, HHS should amend the grant terms to allow comprehensive care, consistent with medical evidence.
- If SUNSET rule is reinstated via rulemaking, supersede it with a new rule requiring periodic review without automatic expiration HHS should propose and finalize a rule that mandates retrospective review of regulations but does not cause automatic expiration, preserving agency accountability without jeopardizing public health protections.
Reversing it is step one. The forward agenda — what we build so it can’t recur — is in Answers to this entry →
Grounded in
- HHS Takes Comprehensive Action to Enforce Conscience Rights
- Protecting Statutory Conscience Rights in Health Care; Delegations of Authority
- Attorney General Opinion No. KP-0395
- Your Protections Against Discrimination Based on Conscience and Religion
- HHS Acts to Protect Health Care Workers' Conscience Rights
- Year One of Project 2025: Tracking the Trump Administration's Campaign Against SRHR
- HRSA Announces New Funding, Policy Action, and Report to Mark Enhancing Maternal Health Initiative
- State of Maternal Health 2025 - The Century Foundation
Original source — excerpted
project2025 Project 2025 ch. 16: Department of the Interior (pp 519-521)"— 486 — Mandate for Leadership: The Conservative Promise 1. Investigate state medical school compliance with the Coats–Snowe Amendment,71 which prohibits discrimination against health care entities that do not provide or undergo training for abortion. 2. Ensure that the Accreditation Council for Graduate Medical Education (ACGME) complies with all relevant conscience statutes and regulations and that states have taken the affirmative steps (for example, by issuing regulations) to assure compliance with Coats–Snowe. 3. Communicate to medical schools that any abortion-related training must be on an opt-in rather than opt-out basis. 4. Require states that receive HHS funds to issue regulations or enter into arrangements with accrediting bodies to comply with the Coats–Snowe Amendment’s prohibition of mandatory abortion training by individuals or institutions. The Coats–Snowe Amendment specifically requires such state regulations or arrangements. l Prioritize funding for home-based childcare, not universal day care. As HRSA’s Early Childhood Health page outlines, “Currently, only about half of U.S. preschoolers are on-track with their development and ready for school. A…"