Coats-Snowe enforcement: weaponizing conscience to erode abortion access
Project 2025 directs HHS to investigate medical schools and force states receiving federal funds to comply with the Coats-Snowe Amendment, which prohibits discrimination against entities that refuse to provide or train for abortion. The Trump administration has partially implemented this through HHS Office for Civil Rights enforcement actions, signaling a broader campaign to make abortion training opt-in and to penalize institutions that do not accommodate refusal.
The Coats-Snowe Amendment was written to protect genuine conscientious objection — a doctor who personally opposes abortion should not be forced to perform one. Project 2025 weaponizes that protection by turning it into an affirmative mandate: states must prove they are policing medical schools and accreditors on behalf of refusal, and any training must be opt-in rather than opt-out. This flips the default from ensuring patients can get care to ensuring providers can deny it.
The practical effect is stark. Fewer graduating physicians will have abortion training, which directly worsens the maternal mortality crisis — especially in rural and low-income communities where OB-GYNs are already scarce. A Trump administration HHS press release from January 2026, cited in public reporting as announcing 'comprehensive action' on conscience enforcement, signals this approach. If states are required to issue regulations under threat of losing HHS funds, the chilling effect on medical education and on patients' access to legal care will be immediate and geographically uneven.
There is a better path. Instead of forcing states to police refusal, HHS should enforce conscience protections narrowly — protecting individual clinicians who object — while ensuring that institutions do not use those protections to eliminate access entirely. Congress should clarify that Coats-Snowe does not require opt-in training, and that states accepting federal health dollars must guarantee both conscientious objection and patient access. The goal is not to force anyone to participate in care they oppose; it is to prevent refusal from becoming a backdoor ban.
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…"