Project 2025's War on Reproductive Health Data and Medication Abortion Access
Project 2025 targets medication abortion as the 'single greatest threat' to anti-abortion goals and seeks to restrict mifepristone through FDA action, enforce the 19th-century Comstock Act, and eliminate federal collection of gender identity data—moves that undermine evidence-based public health, reproductive rights, and scientific integrity.
Project 2025 treats medication abortion—the method used in over half of U.S. abortions—as an existential threat, calling mifepristone 'the single greatest threat to unborn children in a post-Roe world.' The playbook urges the FDA to remove mifepristone from the market based on a reinterpretation of safety data, despite the FDA's own finding that the drug's REMS are safe and effective. The Supreme Court temporarily restored mail-order access in June 2025 after a lower court effectively banned it. Meanwhile, H.R.679, introduced in the 119th Congress, would nullify the FDA's 2023 REMS changes that expanded telemedicine and pharmacy dispensing of mifepristone, and Project 2025 explicitly calls for enforcing the 1873 Comstock Act to criminalize mailing abortion pills. These actions would create a patchwork of access where some states protect medication abortion while others ban it, leading to delayed care and forcing pregnant people to travel long distances or self-manage abortions without medical oversight.
Project 2025 also targets federal data collection on gender identity, calling it 'unscientific' and claiming it 'encourages the phenomenon of ever-multiplying subjective identities.' The administration has already acted: in January 2025, OPM directed agencies to remove gender identity questions from federal surveys, and the CDC has begun deleting related datasets from online portals. In February 2025, HHS rescinded guidance protecting the privacy of gender-affirming care data under HIPAA, and the administration has eliminated SOGI variables from multiple federal surveys, delaying or removing data releases. KFF has documented these deletions, warning that without adequate data on sexual orientation and gender identity, health disparities remain invisible, policy impacts are unmeasurable, and public trust erodes. An alternative approach—restoring SOGI data collection, protecting privacy, and funding equity research—would ensure that public health programs are evidence-based and that marginalized communities receive the care they need.
The humanitarian alternative
Congress should pass the Reproductive Health Access Act, which codifies FDA's 2023 REMS changes, prohibits enforcement of the Comstock Act against abortion medications, and protects the mailing of mifepristone. Simultaneously, the HHS should issue a rule requiring all federally funded surveys to include sexual orientation and gender identity questions, and restore deleted datasets. The CDC must be directed to collect and publish abortion data voluntarily, with strong privacy protections and no penalties for non-compliance.
Rollback path — how this gets undone
This action has already been implemented. These are the concrete levers that could reverse it.
- Rescind HHS order directing FDA to restrict mifepristone The HHS Secretary should rescind the May 2025 order, restoring FDA's ability to implement the 2023 REMS without political interference.
- Defeat H.R.679 and S.178 Congress should reject H.R.679, which would roll back mifepristone access, and S.178, the coercive abortion reporting bill, through filibuster or floor votes.
- Reverse OPM directive on gender identity data removal The OPM should rescind the January 2025 directive, restoring SOGI questions and datasets, and the HHS should reissue guidance protecting gender-affirming care data.
- Issue new HHS guidance on HIPAA privacy for gender-affirming care The HHS Secretary should issue a new guidance reversing the February 2025 rescission, explicitly protecting the privacy of gender-affirming care data under HIPAA.
Original source — excerpted
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