[Federal Register Volume 83, Number 18 (Friday, January 26, 2018)]
[Proposed Rules]
[Pages 3880-3931]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-01226]
[[Page 3879]]
Vol. 83
Friday,
No. 18
January 26, 2018
Part II
Department of Health and Human Services
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45 CFR Part 88
Protecting Statutory Conscience Rights in Health Care; Delegations of
Authority; Proposed Rule
Federal Register / Vol. 83 , No. 18 / Friday, January 26, 2018 /
Proposed Rules
[[Page 3880]]
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DEPARTMENT OF HEALTH AND HUMAN SERVICES
45 CFR Part 88
[Docket No.: HHS-OCR-2018-0002]
RIN 0945-ZA03
Protecting Statutory Conscience Rights in Health Care;
Delegations of Authority
AGENCY: Office for Civil Rights (OCR), Office of the Secretary, HHS.
ACTION: Proposed rule.
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SUMMARY: In the regulation of health care, the United States has a long
history of providing conscience-based protections for individuals and
entities with objections to certain activities based on religious
belief and moral convictions. Multiple such statutory protections apply
to the Department of Health and Human Services (HHS, or the Department)
and the programs or activities it funds or administers. The Department
proposes to revise regulations previously promulgated to ensure that
persons or entities are not subjected to certain practices or policies
that violate conscience, coerce, or discriminate, in violation of such
Federal laws. Through this rulemaking, the Department proposes to grant
overall responsibility to its Office for Civil Rights (OCR) for
ensuring that the Department, its components, HHS programs and
activities, and those who participate in HHS programs or activities
comply with Federal laws protecting the rights of conscience and
prohibiting associated discriminatory policies and practices in such
programs and activities. In addition to conducting outreach and
providing technical assistance, OCR will have the authority to initiate
compliance reviews, conduct investigations, supervise and coordinate
compliance by the Department and its components, and use enforcement
tools otherwise available in civil rights law to address violations and
resolve complaints. In order to ensure that recipients of Federal
financial assistance and other Department funds comply with their legal
obligations, the Department will require certain recipients to maintain
records; cooperate with OCR's investigations, reviews, or other
enforcement actions; submit written assurances and certifications of
compliance to the Department; and provide notice to individuals and
entities about their conscience and associated anti-discrimination
rights, as applicable.
DATES: Submit comments on or before March 27, 2018.
ADDRESSES: You may send comments, identified by RIN 0945-ZA03 or Docket
HHS-OCR-2018-0002, by any of the following methods:
Federal eRulemaking Portal. You may submit electronic
comments at http://www.regulations.gov by searching for the Docket ID
number HHS-OCR-2018-0002. Follow the instructions for sending comments.
Regular, Express, or Overnight Mail: U.S. Department of
Health and Human Services, Office for Civil Rights, Attention:
Conscience NPRM, RIN 0945-ZA03, Hubert H. Humphrey Building, Room 509F,
200 Independence Avenue SW, Washington, DC 20201.
Hand Delivery/Courier: Department of Health and Human
Services, Office for Civil Rights, Attention: Conscience NPRM, RIN
0945-ZA03, Hubert H. Humphrey Building, Room 509F, 200 Independence
Avenue SW, Washington, DC 20201.
Instructions: All submissions received must include ``Department of
Health and Human Services, Office for Civil Rights RIN 0945-ZA03'' for
this rulemaking. All comments received will be posted without change to
http://www.regulations.gov, including any personal information
provided. Further instructions are available under PUBLIC
PARTICIPATION.
Docket: For complete access to the docket to read background
documents or comments received, go to http://www.regulations.gov and
search for Docket ID number HHS-OCR-2018-0002.
FOR FURTHER INFORMATION CONTACT: Sarah Bayko Albrecht at (800) 368-1019
or (800) 537-7697 (TDD).
SUPPLEMENTARY INFORMATION:
I. Introduction
The freedoms of conscience and of religious exercise are
foundational rights protected by the First Amendment to the U.S.
Constitution and by Federal statutes. These laws ensure, for example,
that Americans are not compelled to speak, to salute the flag, to join
a national church, or to vote for a particular candidate.\1\ They also
ensure that, as a general matter, the Federal government may not
discriminate against its citizens for the views they hold.\2\ Congress
has passed laws protecting conscience and religious freedom with
particular force in the health care context, and it is these statutes
that are the subject of this proposed rule. Specifically, this proposed
rule concerns Federal laws that provide:
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\1\ U.S. Const., amend. I; see also, e.g., West Virginia State
Board of Education v. Barnette, 319 U.S. 624 (1943); 18 U.S.C. 594.
\2\ See e.g., Turner Broad. Sys. Inc. v. FCC, 512 U.S. 622
(1994); Rust v. Sullivan, 500 U.S. 173 (1991); Kingsley Int'l Corp.
v. Regents of the Univ. of N.Y., 360 U.S. 684 (1954).
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Conscience protections related to abortion, sterilization,
and certain other health services to participants in programs--and
their personnel--funded by the Department (the Church Amendments, 42
U.S.C. 300a-7);
Conscience protections for health care entities related to
abortion provision or training, referral for such abortion or training,
or accreditation standards related to abortion (the Coats-Snowe
Amendment, 42 U.S.C. 238n);
Protections from discrimination for health care entities
and individuals who object to furthering or participating in abortion
under programs funded by the Department's yearly appropriations acts
(e.g., Consolidated Appropriations Act, 2017, Pub. L. 115-31, Div. H,
Tit. V, sec. 507(d) (the Weldon Amendment) and at Div. H, Tit. II, sec.
209);
Conscience protections under the Patient Protection and
Affordable Care Act (ACA) related to assisted suicide (42 U.S.C.
18113), the ACA individual mandate (26 U.S.C. 5000A(d)(2)), and other
matters of conscience (42 U.S.C. 18023(c)(2)(A)(i)-(iii), (b)(1)(A) and
(b)(4));
Conscience protections for objections to counseling and
referral for certain services in Medicaid or Medicare Advantage (42
U.S.C. 1395w-22(j)(3)(B) and 1396u-2(b)(3)(B));
Conscience protections related to the performance of
advanced directives (42 U.S.C. 1395cc(f), 1396a(w)(3), and 14406);
Conscience protections related to Global Health Programs
to the extent administered by the Secretary (22 U.S.C. 7631(d);
Consolidated Appropriations Act, 2017, Pub. L. 115-31, Div. J, Tit.
VII, sec. 7018 (Helms Amendment));
Exemptions from compulsory health care or services
generally (42 U.S.C. 1396f & 5106i(a)(1)), and under specific programs
for hearing screening (42 U.S.C. 280g-1(d)), occupational illness
testing (29 U.S.C. 669(a)(5)); vaccination (42 U.S.C.
1396s(c)(2)(B)(ii)), and mental health treatment (42 U.S.C. 290bb-
36(f)); and
Protections for religious nonmedical health care (e.g., 42
U.S.C. 1320a-1, 1320c-11, 1395i-5 and 1397j-1(b)).
(These laws will be collectively referred to as ``Federal health
care conscience and associated anti-discrimination laws'' for purposes
of this Notice of Proposed Rulemaking.).
[[Page 3881]]
With this proposed regulation, the Department seeks to more
effectively and comprehensively enforce Federal health care conscience
and associated anti-discrimination laws. Specifically, the Department
proposes to grant its Office for Civil Rights (OCR) overall
responsibility for ensuring that the Department, its components, HHS
programs and activities, and those who participate in HHS programs or
activities comply with these Federal laws. In addition to conducting
outreach and providing technical assistance, OCR will have the
authority to initiate compliance reviews, conduct investigations,
supervise and coordinate compliance by the Department and its
component(s), and use enforcement tools comparable to those available
under other civil rights laws to more effectively address violations
and resolve complaints. In order to ensure that recipients of
Department funds comply with their legal obligations, as it does with
other civil rights laws within its purview, the Department will require
certain funding recipients to maintain records; cooperate with OCR's
investigations, reviews, or enforcement actions; submit written
assurances and certifications of compliance to the Department; and
provide notice to individuals and entities about conscience and
associated anti-discrimination rights (as applicable).
II. America's Tradition of Conscience Protection, Religious Freedom,
and the Right to be Free From Unlawful Discrimination
Congress has a long history of protecting conscience, religious
beliefs, and moral convictions in law in a variety of contexts. See,
e.g., 1864 Draft Act, 13 Stat. 9 (exempting religious objectors opposed
to bearing arms from military service); 50 U.S.C. 3806(j) (exempting
conscientious objectors from combat training or military service); 18
U.S.C. 3597(b) (exempting law enforcement employees from participating
in executions ``if such participation is contrary to the moral or
religious convictions of the employee''); 20 U.S.C. 1681(a)(3)
(exempting educational institutions from sex discrimination bans under
Title IX of the Education Amendments of 1972 where such ban ``would not
be consistent with the religious tenets'' of the institution); 42
U.S.C. 300a-8 (prohibiting the coercion of persons to undergo abortion
or sterilization procedures by threatening loss of benefits and
attaching a criminal punishment of a fine of not more than $1000,
imprisonment for not more than one year, or both, to violations of that
prohibition); see also the Religious Freedom Restoration Act, 42 U.S.C.
2000bb et seq. (preventing the Federal government from imposing
substantial burdens on religious exercise absent a compelling
government interest pursued in the manner least restrictive of that
exercise).
The need and justification for these types of laws was aptly
explained by the Supreme Court in 1965:
[B]oth morals and sound policy require that the State should not
violate the conscience of the individual. All our history gives
confirmation to the view that liberty of conscience has a moral and
social value which makes it worthy of preservation at the hands of
the state. So deep in its significance and vital, indeed, is it to
the integrity of man's moral and spiritual nature that nothing short
of the self-preservation of the state should warrant its violation;
and it may well be questioned whether the state which preserves its
life by a settled policy of violation of the conscience of the
individual will not in fact ultimately lose it by the process.
United States v. Seeger, 380 U.S. 163, 170 (1965), quoting Harlan Fiske
Stone, The Conscientious Objector, 21 Col. Univ. Q. 253, 269 (1919).
For decades,\3\ Congress has also respected the conscience of
taxpayers who object to paying for abortion by legislating prohibitions
on the Federal funding of abortion. Specifically, the Hyde Amendment,
which Congress has routinely attached to appropriations acts, generally
prohibits Federal funding of abortion.\4\ See, e.g., Consolidated
Appropriations Act, 2017, Public Law 115-31, Div. H, sec. 506, 507, 131
Stat. 562 (May 5, 2017). See also id. at Div. E, sec. 613, 131 Stat.
372 (using Hyde language to prohibit funding of abortions through
Federal employee health benefits or coverage); id. at Div. E, sec. 810,
131 Stat. 393 (applying Hyde language to the District of Columbia); and
20 U.S.C. 1688 (including language in Title IX to prohibit recipients
of Federal education funding from requiring any person, or public or
private entity, to pay for any benefit or service, including the use of
facilities, related to an abortion).\5\
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\3\ See E.O. 13535, 75 FR 15599 (Mar. 29, 2010) (establishing
enforcement mechanism to ``ensure that Federal funds are not used
for abortion services (except in cases of rape or incest, or when
the life of the woman would be endangered), consistent with a
longstanding Federal statutory restriction that is commonly known as
the Hyde Amendment'').
\4\ In Harris v. McRae, 448 U.S. 297, 315 (1980), the Supreme
Court held that Congress has the power to limit or prohibit the
funding of abortion. In Maher v. Roe, 432 U.S. 464, 474 (1977), the
court held that the Constitution empowers Congress to make a ``value
judgment favoring childbirth over abortion'' that it may implement
``by the allocation of public funds.'' See also Rust v. Sullivan,
500 U.S. 173, 192-193, 201 (1991).
\5\ See Mark L. Rienzi, The Constitutional Right Not to Kill, 62
Emory L.J. 121, 152 (2012) (``[L]egislators acted quickly,
decisively, and at times nearly unanimously to protect conscience
rights in the wake of Roe. . . . The speedy passage and near
ubiquity of these laws demonstrate that a great majority of
Americans at the time--regardless of their famously intense disputes
as to the merits of the underlying abortion question--agreed that
the government should not have the power to compel participation in
abortions by unwilling individuals and institutions.'').
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In a May 4, 2017, Executive Order entitled ``Promoting Free Speech
and Religious Liberty,'' the President declared that the Executive
Branch will ``vigorously enforce Federal law's robust protections for
religious freedom.'' E.O. 13798, 82 FR 21675 (May 8, 2017). Pursuant to
that Executive Order, the Attorney General of the United States issued
guidance on religious liberty clarifying that Federal law ``protects
not just the right to believe or the right to worship; it protects the
right to perform or abstain from performing certain physical acts in
accordance with one's beliefs.'' Memorandum from the Attorney General,
Federal Law Protections for Religious Liberty at 2 (Oct. 6, 2017)
(emphasis added). Pursuant to the President's Executive Order and
Executive Branch policy, and in keeping with the Attorney General's
religious liberty guidance, HHS proposes this rule to enhance the
awareness and enforcement of Federal health care conscience and
associated anti-discrimination laws, to further conscience and
religious freedom, and to protect the rights of individuals and
entities to abstain from certain activities related to health care
services without discrimination or retaliation.
III. The Federal Health Care Conscience and Associated Anti-
Discrimination Laws Applicable to Government, Providers, Patients,
Insurers, and Other Entities That Benefit From or Administer Federally
Funded Health Care Programs or Activities
As noted above, Congress has recognized that modern health care
practices may give rise to conflicts with the religious beliefs and
moral convictions of providers and patients alike. The existence of
moral and ethical qualms on the part of health care clinicians about
participating in, assisting, referring for, or otherwise being morally
complicit in certain procedures is well documented by ethicists.\6\
Religious institutions and
[[Page 3882]]
entities, too, have expressed qualms about the provision of,
participation in, or provision of insurance coverage for, certain
procedures or services. To address these problems, Congress has
repeatedly legislated conscience protections for the institutions and
individuals providing health care to the American public, as outlined
below.
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\6\ See, e.g., Stephen J. Genuis & Chris Lipp, Ethical Diversity
and the Role of Conscience in Clinical Medicine, 2013 Int'l. J.
Family Med. 1, 9 (2013); Armand H. Matheny Antommaria, Adjudicating
Rights or Analyzing Interests: Ethicists' Role in the Debate Over
Conscience in Clinical Practice, 29 Theor. Med. Bioeth. 201, 206
(2008); William W. Bassett, Private Religious Hospitals: Limitations
Upon Autonomous Moral Choices in Reproductive Medicine, 17 J.
Contemp. Health L. & Pol'y 455, 529 (2001); Peter A. Clark, Medical
Ethics at Guantanamo Bay and Abu Ghraib: The Problem of Dual
Loyalty, 34 J.L. Med. & Ethics 570 (2006).
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A. The Church Amendments
The Church Amendments were enacted at various times during the
1970s in response to debates over whether judicially recognized rights
to abortions or sterilizations might lead to the requirement that
individuals or entities participate in activities to which they have
religious or moral objections. The Church Amendments consist of five
provisions, codified at 42 U.S.C. 300a-7, that protect those who hold
religious beliefs or moral convictions respecting certain health care
procedures from discrimination by entities that receive Federal
funding.
First, subsection (b) of the Church Amendments provides that no
court, public official, or other public authority can use an
individual's receipt of certain Federal funding as grounds to require
the individual to perform, or assist in, sterilizations or abortions,
if doing so would be contrary to his or her religious beliefs or moral
convictions. 42 U.S.C. 300a-7(b)(1). Subsection (b) further prohibits
those public authorities from requiring an entity, based on the
entity's receipt of Federal funds under certain HHS programs, (1) to
permit sterilizations or abortions in the entity's facilities if the
entity otherwise prohibits the performance of such procedures on the
basis of religious beliefs or moral convictions, or (2) to make its
personnel available for such procedures if contrary to the personnel's
religious beliefs or moral convictions. 42 U.S.C. 300a-7(b)(2)(A) and
(b)(2)(B). The individuals and entities protected by this provision are
recipients of a grant, contract, loan, or loan guarantee under the
Public Health Service Act (42 U.S.C. 201 et seq.) and their
personnel.\7\
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\7\ The Community Mental Health Centers Act, Public Law 88-164,
77 Stat. 282 (1963), and the Developmental Disabilities Services and
Facilities Construction Amendments of 1970, Public Law 91-517, 84
Stat. 1316 (1970), were repealed by subsequent statute and
accordingly are not referenced here.
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Second, subsection (c)(1) of the Church Amendments applies to
decisions on employment, promotion, or termination of employment, as
well as extension of staff or other privileges with respect to
physicians and other health care personnel. 42 U.S.C. 300a-7(c)(1)(A)-
(B). This subsection prohibits certain entities from discriminating in
these decisions based on an individual's refusal to perform or assist
in an abortion or sterilization because of religious beliefs or moral
convictions. 42 U.S.C. 300a-7(c)(1). It also prohibits those entities
from discriminating in such decisions based on an individual's
performance of a lawful abortion or sterilization procedure, or on an
individual's religious beliefs or moral convictions about such
procedures more generally. Id. Like subsection (b), recipients of a
grant, contract, loan, or loan guarantee under the Public Health
Service Act must comply with subsection (c)(1).
Third, subsection (c)(2) of the Church Amendments applies to the
recipients of the Department's grants or contracts for biomedical or
behavioral research under any program administered by the Secretary of
Health and Human Services. 42 U.S.C. 300a-7(c)(2). This subsection
prohibits discrimination against physicians or other health care
personnel in employment, promotion, or termination of employment, as
well as discrimination in the extension of staff or other privileges
because of an individual's performance or assistance in any lawful
health service or research activity, refusal to perform or assist in
any such service or activity based on religious beliefs or moral
convictions, or the individual's religious beliefs or moral convictions
respecting such services or activities more generally. 42 U.S.C. 300a-
7(c)(2)(A)-(B).
Fourth, subsection (d) of the Church Amendments applies to any part
of a health service program or research activity funded in whole or in
part under a program administered by the Secretary. For these programs,
no individual shall be required to perform or assist in the performance
of part of the program or research activity if doing so would be
contrary to his or her religious beliefs or moral convictions. 42
U.S.C. 300a-7(d).
Fifth, subsection (e) of the Church Amendments applies to health
care training or study, such as internships and residencies. Subsection
(e) prohibits any entity receiving certain funds from denying admission
to, or otherwise discriminating against, applicants for training or
study based on the applicant's reluctance or willingness to counsel,
suggest, recommend, assist, or in any way participate in the
performance of abortions or sterilizations contrary to or consistent
with the applicant's religious beliefs or moral convictions. 42 U.S.C.
300a-7(e). Recipients of a grant, contract, loan, loan guarantee, or
interest subsidy under the Public Health Service Act or the
Developmental Disabilities Assistance and Bill of Rights Act of 2000
(42 U.S.C. 15001 et seq.) must comply with subsection (e). Notably, the
Church Amendments contain provisions protecting the rights of
individuals and entities explicitly.
B. The Coats-Snowe Amendment (Section 245 of the Public Health Service
Act)
Enacted in 1996, section 245 of the Public Health Service Act (also
known as the ``Coats-Snowe Amendment'' or ``Coats-Snowe'') applies
nondiscrimination requirements to Federal, State, or local governments
receiving Federal financial assistance. 42 U.S.C. 238n. As a condition
of receiving such funding, those governments may not discriminate
against ``health care entities,'' including individual physicians;
participants in programs of training in the health professions; and
postgraduate physician training programs, including residency training
programs, that refuse to undergo training in, require or provide
training in, or perform abortions; refer for abortions or abortion
training; or make arrangements for any of those activities. 42 U.S.C.
238n(a)(1)-(2). Furthermore, those governments may not discriminate
against a health care entity because the entity attends or attended a
health care training program that does not (or did not) perform
abortions; require, provide, or refer for training in the performance
of abortions; or make arrangements for any such training. 42 U.S.C.
238n(a)(3).
In addition, Coats-Snowe applies to accreditation of postgraduate
physician training programs. Therefore, governments receiving the
specified Federal funds may not deny a legal status (including a
license or certificate) or financial assistance, services, or other
benefits to a health care entity (which, as defined in 42 U.S.C.
238n(c)(2), includes individual physicians, postgraduate physician
training programs, and participants in programs of training in the
health professions) based on an applicable physician training program's
lack of accreditation due to the accrediting agency's requirements that
a health care entity perform induced abortions; require, provide, or
refer for training in the performance of induced abortions; or
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make arrangements for such training. 42 U.S.C. 238n(b)(1).
C. The Weldon Amendment
The Weldon Amendment (or ``Weldon'') was originally adopted in 2004
and has been readopted (or incorporated by reference) in each
subsequent appropriations act for the Departments of Labor, Health and
Human Services, and Education. See, e.g., Consolidated Appropriations
Act, 2017, Public Law 115-31, Div. H, sec. 507(d), 131 Stat. 135.
Weldon provides that ``[n]one of the funds made available in this Act
may be made available to a Federal agency or program, or to a State or
local government, if such agency, program, or government subjects any
institutional or individual health care entity to discrimination on the
basis that the health care entity does not provide, pay for, provide
coverage of, or refer for abortions.'' Consolidated Appropriations Act,
2017, Public Law 115-31, Div. H, sec. 507(d)(1), 131 Stat. 135. Weldon
defines ``health care entity'' to ``include[ ] an individual physician
or other health care professional, a hospital, a provider-sponsored
organization, a health maintenance organization, a health insurance
plan, or any other kind of health care facility, organization, or
plan.'' Id. at sec. 507(d)(2).
D. Conditions on Federally Appropriated Funds Requiring Compliance With
Federal Health Care Conscience and Associated Anti-Discrimination Laws
In addition to Weldon, the Consolidated Appropriations Act of 2017
includes other health care conscience protections. For example, a
provision, using the same language as the Weldon Amendment, prohibits
the Department from denying participation in Medicare Advantage to an
otherwise eligible health care entity, such as a provider-sponsored
organization, on the basis that the health care entity does not
provide, pay for, provide coverage of, or refer for abortion.
Consolidated Appropriations Act, 2017, Public Law 115-31, Div. H, sec.
209, 131 Stat. 135.
E. The Patient Protection and Affordable Care Act's Conscience and
Associated Anti-Discrimination Protections
Passed in 2010, the Patient Protection and Affordable Care Act
(ACA) also includes several conscience and associated anti-
discrimination protections.
Section 1553 of the ACA prohibits Federal, State, or local
governments; health care providers that receive Federal financial
assistance under the ACA; and ACA health plans from discriminating
against an individual or institutional health care entity because of
the individual or entity's objection to providing any health care items
or service for the purpose of causing or assisting in causing death,
such as by assisted suicide, euthanasia, or mercy killing. 42 U.S.C.
18113. Section 1553 designates the HHS Office for Civil Rights (OCR) to
receive complaints of discrimination on that basis. Id.
Section 1303 declares that the ACA does not require health plans to
provide coverage of abortion services as part of ``essential health
benefits for any plan year.'' 42 U.S.C. 18023(b)(1)(A). Furthermore, no
qualified health plan offered through an ACA exchange may discriminate
against any individual health care provider or health care facility
because of the facility or provider's unwillingness to provide, pay
for, provide coverage of, or refer for abortions. 42 U.S.C.
18023(b)(4). And section 1303 of the ACA makes clear that nothing in
that Act should be construed to undermine ``Federal laws regarding--(i)
conscience protection; (ii) willingness or refusal to provide abortion;
and (iii) discrimination on the basis of the willingness or refusal to
provide, pay for, cover, or refer for abortion or to provide or
participate in training to provide abortion.'' 42 U.S.C.
18023(c)(2)(A)(i)-(iii).
Finally, Internal Revenue Code sec. 5000A, as added by section 1501
of the ACA, provides a religious conscience exemption from the
individual mandate to maintain minimum essential coverage (and avoid
its corresponding tax penalty) for any member of an exempt religious
organization or division or for a ``health care sharing ministry.'' 26
U.S.C. 5000A(d)(2). Exempt religious organizations or individuals are
those who adhere to established tenets or teachings in opposition to
acceptance of the benefits of any private or public insurance. 26
U.S.C. 1402(g)(1). A ``health care sharing ministry'' is an
organization, described in section 501(c)(3) and taxed under section
501(a) of the Internal Revenue Code, comprising members who share a
common set of ethical or religious beliefs and who share medical
expenses among members in accordance with those beliefs without regard
to the State in which a member resides or is employed. 26 U.S.C.
5000A(d)(2)(B). Under Section 1411 of the ACA (42 U.S.C. 18081), HHS is
responsible for issuing certifications to individuals who are entitled
to an exemption from the individual responsibility requirement or the
associated tax penalties imposed under Internal Revenue Code sec.
5000A, including when such individuals are exempt by reason of
membership in an exempt religious organization or health care sharing
ministry. 42 U.S.C. 18081(a)(4), (b)(5).
F. Other Protections Related to the Performance of Advance Directives
or Assisted Suicide
Even before the ACA, Congress had passed conscience protections
related to assisting or causing death. Section 7 of the Assisted
Suicide Funding Restriction Act of 1997 (Pub. L. 105-12, 111 Stat. 23)
clarified that the Patient Self-Determination Act's provisions stating
that Medicare and Medicaid beneficiaries have certain self-
determination rights do not: (1) Require any provider, organization, or
any employee of such provider or organization participating in the
Medicare or Medicaid program to inform or counsel any individual about
a right to any item or service furnished for the purpose of causing or
assisting in death, such as assisted suicide, euthanasia, or mercy
killing; or (2) apply to or affect any requirement with respect to a
portion of an advance directive that directs the purposeful causing of,
or assistance in causing, the death of an individual, such as by
assisted suicide, euthanasia, or mercy killing. 42 U.S.C. 14406 (by
cross-reference to 42 U.S.C. 1395cc(f) (Medicare) and 1396a(w)
(Medicaid)); see also 42 U.S.C. 1396a(w)(3), 1396a(a)(57);
1396b(m)(1)(A); 1396r(c)(2)(E); and 1395cc(f)(4) (by cross-reference to
42 U.S.C. 14406).\8\ Those protections extend to Medicaid and Medicare
providers, such as hospitals, nursing facilities, home health or
personal care service providers, hospice programs, Medicaid managed
care organizations, health maintenance organizations, Medicare+Choice
(now Medicare Advantage) organizations, and prepaid organizations.
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\8\ Similar protections exist under the Department's regulations
applicable to hospitals, nursing facilities, and other medical
facilities, 42 CFR 489.102(c)(2); Medicare Advantage, 42 CFR
422.128(b)(2)(ii); and Medicare Health Maintenance Organizations and
Comprehensive Medical Plans, 42 CFR 417.436 (such organizations,
plans, and their agents are not required to implement advance
directives if the provider cannot do so ``as a matter of
conscience'' and State law allows such conscientious objection).
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G. Protections Related to Counseling and Referrals Under Medicare
Advantage Plans, Medicaid Plans, and Managed Care Organizations
Certain Federal protections extend beyond the context of advance
[[Page 3884]]
directives. For example, Federal law prohibits organizations offering
Medicare+Choice (now Medicare Advantage) plans and Medicaid managed
care organizations from being compelled to provide, reimburse for, or
cover any counseling or referral service in plans over an objection on
moral or religious grounds. 42 U.S.C. 1395w-22(j)(3)(B)
(Medicare+Choice); 42 U.S.C. 1396u-2(b)(3)(B) (Medicaid managed care
organization). Department regulations provide that this conscience
provision for managed care organizations also applies to prepaid
inpatient health plans and prepaid ambulatory health plans under the
Medicaid program. 42 CFR 438.102(a)(2).
H. Conscience and Associated Anti-Discrimination Protections Applying
to Global Health Programs
The Department administers certain programs under the President's
Emergency Program for AIDS Relief (PEPFAR), to which additional
conscience protections apply. Specifically, recipients of foreign
assistance funds for HIV/AIDS prevention, treatment, or care authorized
by section 104A of the Foreign Assistance Act of 1961 (22 U.S.C. 2151b-
2), 22 U.S.C. 7601-7682, or under any amendment made by the Tom Lantos
and Henry J. Hyde United States Global Leadership Against HIV/AIDS,
Tuberculosis, and Malaria Reauthorization Act of 2008 (Pub. L. 110-
293), cannot be required, as a condition of receiving such funds, (1)
to ``endorse or utilize a multisectoral or comprehensive approach to
combating HIV/AIDS,'' or (2) to ``endorse, utilize, make a referral to,
become integrated with, or otherwise participate in any program or
activity to which the organization has a religious or moral
objection.'' 22 U.S.C. 7631(d)(1)(B). The government also cannot
discriminate against such recipients in the solicitation or issuance of
grants, contracts, or agreements for the recipients' refusal to do any
such actions. 22 U.S.C. 7631(d)(2).
I. Exemptions From Compulsory Medical Screening, Examination,
Diagnosis, or Treatment
In addition to these provider protections, multiple Federal health
programs contain conscience protections for patients and parents of
children who have objections to certain tests or treatments. Congress
provided, for example, that neither Medicaid nor the Children's Health
Insurance Program (CHIP) should be interpreted to require any State
``to compel any person to undergo any medical screening, examination,
diagnosis, or treatment'' against their religious objection. 42 U.S.C.
1396f. Similarly, although Congress granted HHS authority to conduct
research, experiments, and demonstrations related to occupational
illnesses in the Occupational Safety and Health Act of 1970, such
authority did not include the power to require ``medical examination,
immunization, or treatment for those who object thereto on religious
grounds, except where such is necessary for the protection of the
health or safety of others.'' 29 U.S.C. 669(a)(5).
As relevant here, four other statutory provisions protect parents
who conscientiously object to their children being forced to receive
certain treatments or health interventions. First, under the Public
Health Service Act, certain suicide prevention programs are not to be
construed to require ``suicide assessment, early intervention, or
treatment services for youth'' if their parents or legal guardians have
religious or moral objections to such services. 42 U.S.C. 290bb-36(f);
Section 3(c) of the Garrett Lee Smith Memorial Act (Pub. L. 108-355,
118 Stat. 1404, reauthorized by Pub. L. 114-255 at Sec. 9008). Second,
Health Resources and Services Administration (HRSA) grants may not be
used to preempt or prohibit State laws, including laws which do not
require hearing loss screening for newborn infants or young children
where their parents object to such screening based on religious belief.
42 U.S.C. 280g-1(d). Third, providers of pediatric vaccines funded by
Federal medical assistance programs must comply with any State laws
relating to any religious or other exemptions. 42 U.S.C.
1396s(c)(2)(B)(ii). Fourth, certain State and local child abuse
prevention and treatment programs funded by HHS are not to be construed
as creating a Federal requirement that a parent or legal guardian
provide a child any medical service or treatment against the religious
beliefs of that parent or legal guardian. 42 U.S.C. 5106i(a)(1).
J. Conscience Clauses Related to Religious Nonmedical Health Care
Since 1965, Congress has provided accommodations in Medicare and
Medicaid for persons and institutions objecting to the acceptance or
provision of medical care or services based on a belief in a religious
method of healing through approval of religious nonmedical health care
institutions (RNHCIs). RNHCIs object to providing many standard medical
items and services, such as screenings, examination, diagnosis,
prognosis, treatment, or the administration of medications. 42 U.S.C.
1395x(ss)(1). Instead, RNHCIs furnish nonmedical items and services
such as room and board, unmedicated wound dressings, and walkers,\9\
and they provide care exclusively through nonmedical nursing personnel
assisting with nutrition, comfort, support, moving, positioning,
ambulation, and other activities of daily living.\10\
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\9\ https://www.medicare.gov/coverage/rnhci-items-and-services.html].
\10\ https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/RNHCIs.html.
---------------------------------------------------------------------------
Congress has supported RNCHIs through several statutes. For
example, although such institutions would not otherwise meet the
medical criteria for Medicare providers, see 42 U.S.C. 1395x(e)
(definition of ``hospital''), 1395x(y)(1) (definition of ``skilled
nursing facility''), 1395x(k), and 1320cb-11 (exemptions from other
medical criteria and standards), Congress expressly included them
within the definition of designated Medicare providers. Congress
prohibited States from excluding RNCHIs from licensure through
implementation of State definitions of ``nursing home'' and ``nursing
home administrator,''42 U.S.C. 1396g(e), and Congress exempted RNHCIs
from certain Medicaid requirements for medical criteria and standards.
42 U.S.C. 1396a(a)(83) (exempting RNHCIs from 42 U.S.C. 1396a(a)(9)(A),
1396a(a)(31), 1396a(a)(33), and 1396b(i)(4)). Finally, Congress
permitted patients at RNHCIs to file an election with HHS stating that
they are ``conscientiously opposed to acceptance of'' medical treatment
on the basis of ``sincere religious beliefs'' (42 U.S.C. 1395ib-5) yet
will remain eligible for the nonmedical care and services ordinarily
covered under Medicare, Medicaid, and CHIP. 42 U.S.C. 1395x(e),
1395x(y), and 1396g(e). Federal courts have upheld the
constitutionality of such religious accommodations. See e.g.,
Children's Healthcare v. Min De Parle, 212 F.3d 1084 (8th Cir. 2000)
and Kong v. Min De Parle, No. C 00-4285 CRB, 2001 WL 1464549 (N.D.Cal.
Nov. 13, 2001).
Congress has also provided particular accommodations for persons
and institutions that object to medical services and items. Section
6703(a) of the Elder Justice Act of 2009 (Pub. L. 111-148, 124 Stat.
119) provides that Elder Justice and Social Services Block Grant
programs may not interfere with or abridge a person's ``right to
practice his or her religion through reliance on
[[Page 3885]]
prayer alone for healing,'' when the preference for such reliance is
contemporaneously expressed, previously set forth in a living will or
similar document, or unambiguously deduced from the elder's life
history. 42 U.S.C. 1397j-1(b). Additionally, the Child Abuse Prevention
and Treatment Act (CAPTA) specifies that it does not require (though it
also does not prevent) a State finding of child abuse or neglect in
cases in which a parent or legal guardian relies solely or partially
upon spiritual means rather than medical treatment, in accordance with
religious beliefs. 42 U.S.C. 5106i(a)(2).
IV. The Original Version and Current Version of the Rule
The Department has engaged in rulemaking to enforce some of these
Federal health care conscience and associated anti-discrimination
provisions on two previous occasions: in the 2008 Federal Health Care
Conscience Rule, and in the revocation and replacement of that Rule in
2011. This Part briefly summarizes each action.
A. 2008 Federal Health Care Conscience Rule
The Department issued a notice of proposed rulemaking in 2008 to
clarify and enforce the Church, Coats-Snowe, and Weldon Amendments. 73
FR 50274 (Aug. 26, 2008). That notice recognized: (1) The inconsistent
awareness of Federal health care nondiscrimination protections among
Federally funded recipients and protected persons and entities; and (2)
the unavailability of remedies for victims of discrimination under the
above-referenced Amendments.
The Department received a ``large volume'' of comments on the 2008
proposed rule. See 73 FR 78072, 78074 (2008 Rule). Comments came from a
wide variety of individuals and organizations, including private
citizens, individual and institutional health care providers, religious
organizations, patient advocacy groups, professional organizations,
universities and research institutions, consumer organizations, and
State and Federal agencies and representatives. Comments dealt with a
range of issues surrounding the proposed rule, including whether the
rule was needed, what individuals would be protected by the proposed
rule, what services would be covered by the proposed rule, whether
health care workers would use the regulation to discriminate against
patients, what significant implementation issues could be associated
with the rule, what legal arguments could be made for and against the
rule, and what cost impacts of the proposed rule could be anticipated.
Many comments confirmed the need to promulgate a regulation to raise
awareness of Federal nondiscrimination protections and provide for
their enforcement.
The Department responded to those substantive comments and issued a
final rule on December 19, 2008, 45 CFR part 88, consisting of six
sections:
Section 88.1 stated that the purpose of the 2008 Rule was ``to
provide for the implementation and enforcement'' of the Church, Coats-
Snowe, and Weldon Amendments. It specified that those Amendments and
the implementing regulations ``[we]re to be interpreted and implemented
broadly to effectuate their protective purposes.''
Section 88.2 of the 2008 Rule defined several terms used in Part 88
and applicable to various provider nondiscrimination protections,
namely, the terms ``Assist in the Performance,'' ``Entity,'' ``Health
Care Entity,'' ``Health Service Program,'' ``Individual,''
``Instrument,'' ``Recipient,'' ``Sub-recipient,'' and ``Workforce.''
Section 88.3 of the 2008 Rule set forth the scope of applicability
of the sections and subsections of Part 88 as they related to each
conscience law subject to the 2008 Rule.
Section 88.4 of the 2008 Rule set forth the substantive
requirements and applications of the Church Amendments, Coats-Snowe,
and the Weldon Amendment.
Section 88.5 of the 2008 Rule required covered Federally funded
entities to provide written certification of compliance with the laws
on conscience protection subject to the 2008 Rule.
Section 88.6 of the 2008 Rule designated HHS OCR to receive
complaints based on the provider conscience laws and directed OCR to
coordinate handling those complaints with the Departmental components
with respect to which the covered entity receives funding.
B. Proposed Changes in 2009 Resulting in New Final Rule in 2011
On March 10, 2009, with the advent of a new Administration, the
Department proposed to rescind, in its entirety, the 2008 Rule. 74 FR
10207 (Mar. 10, 2009) (2009 Proposed Rule). The Department declared
that certain comments on the August 2008 Proposed Rule raised a number
of questions warranting further review of the 2008 Rule to ensure its
consistency with that Administration's policy. The Department invited
further comments to reevaluate the necessity for regulations
implementing the conscience protection and provider nondiscrimination
laws. In response to the proposal to rescind the 2008 Rule, the
Department received comments stating that health care workers should
not be required to violate their religious or moral convictions;
expressing concern that health care providers would be coerced into
violating their consciences; and identifying the 2008 Rule as
protecting First Amendment religious freedom rights, the capacity to
uphold the tenets of the Hippocratic Oath, and the ethical integrity of
the medical profession. Numerous commenters identified concerns that
there would be no regulatory scheme to protect the rights afforded to
health care providers, including medical students. 76 FR 9968, 9971
(Feb. 23, 2011) (2011 Rule).
On February 23, 2011, the Department rescinded most of the 2008
Rule and finalized the present rule. 76 FR 9968 (Feb. 23, 2011) (2011
Rule). The 2011 Rule left in place section ``88.1 Purpose,'' but
removed the word ``implementation,'' describing the Rule's purpose as
``provid[ing] for the enforcement'' of the Church, Coats-Snowe, and
Weldon Amendments. It then removed the 2008 Rule's sections 88.2
through 88.5, redesignated the 2008 Rule's section 88.6 as section
88.2, and modified that section to read, in its entirety: ``The Office
for Civil Rights (OCR) of the Department of Health and Human Services
is designated to receive complaints based on the Federal health care
provider conscience protection statutes. OCR will coordinate the
handling of complaints with the Departmental funding component(s) from
which the entity, to which a complaint has been filed, receives
funding.''
The preamble to the 2011 Rule stated, ``The Department supports
clear and strong conscience protections for health care providers who
are opposed to performing abortions.'' 76 FR at 9969. The Department
recognized, ``The comments received suggested that there is a need to
increase outreach efforts to make sure providers and grantees are aware
of these statutory protections. It is also clear that the Department
needs to have a defined process for health care providers to seek
enforcement of these protections.'' 76 FR at 9969. Accordingly, the
summary of the 2011 Rule stated that ``enforcement of the Federal
statutory health care provider conscience protections will be handled
by the Department's Office for Civil Rights, in conjunction with the
Department's funding components.'' 76 FR at 9968. The Department
announced that OCR was beginning to lead ``an initiative designed to
increase the
[[Page 3886]]
awareness of health care providers about the protections provided by
the health care provider conscience statutes, and the resources
available to providers who believe their rights have been violated.''
76 FR at 9969. The 2011 Rule provided that OCR would ``collaborate with
the funding components of the Department to determine how best to
inform health care providers and grantees about health care conscience
protections, and the new process for enforcing those protections.'' Id.
V. History of OCR Enforcement of Federal Health Care Conscience Laws
Since the designation of OCR as the agency with authority to
enforce Federal health care conscience laws in 2008, OCR has received a
total of forty-four complaints, the large majority of which (thirty-
four) were filed since the November 2016 election.\11\ Of these forty-
four complaints, thirty-five currently remain open. OCR closed six of
the complaints after investigation and three on administrative grounds.
---------------------------------------------------------------------------
\11\ After OCR proposed rescission of the 2008 Rule, forty-six
members of Congress, including the Chairman of the House Energy and
Commerce Committee with oversight over HHS, raised concerns about
whether HHS was fully enforcing the Federal health care conscience
laws. See Rep. Mike Pence, House Energy and Commerce Committee
Chairman Joseph Pitts, et al., Letter to HHS Secretary Kathleen
Sebelius (Feb. 11, 2011).
---------------------------------------------------------------------------
The first of the closed complaints, filed on March 8, 2010,\12\ by
a nurse at a private hospital, alleged that the hospital had forced her
to assist in an abortion in 2009 in violation of the Church Amendments.
OCR conducted an investigation and closed the complaint less than a
year later after OCR determined that the hospital had agreed to
sufficient corrective action in a resolution agreement. The hospital
had agreed to: (1) Comply with the Church Amendments; (2) continue to
make best efforts to ensure that non-objecting health care personnel
are available to perform job duties with respect to abortion
procedures, including any abortion procedures that occur over the
weekend; (3) revise its human resources policy concerning
nondiscrimination as set forth in subsection (c)(1) of the Church
Amendments; (4) continue to post notices of that policy on the
hospital's intranet and on the operating room notice board; and (5)
train personnel about the hospital's obligations under the Church
Amendments to ensure proper recording of staff's objecting or non-
objecting status. In addition, the hospital incorporated technical
assistance from OCR regarding its process for identifying employees'
objection status and the hospital's grievance procedures. OCR directed
the hospital to ensure that no adverse action was taken against the
complainant or others for participating in the investigation.
---------------------------------------------------------------------------
\12\ OCR Complaint No. 10-109676.
---------------------------------------------------------------------------
In January 2011,\13\ OCR closed two other complaints alleging that
a university violated the Church Amendments by requiring applicants to
a nurse residency program to sign a form agreeing to assist in abortion
procedures. Specifically, the application form declared, ``If you are
chosen for the Nurse Residency Program in the Women's Health track, you
will be expected to care for women undergoing termination of pregnancy.
. . . If you feel you cannot provide care to women during this type of
event, we encourage you to apply to a different track of the Nurse
Residency Program to explore opportunities that may best fit your
skills and career goals.'' The form further provided, ``By signing this
letter, I acknowledge that I am aware that I may be providing nursing
care for women who are having the procedures listed above.'' OCR closed
these two complaints after it determined that the university had
engaged in adequate corrective action--which included a public
announcement that the university would no longer require an applicant
to the nursing program to sign the form if doing so would be
inconsistent with the applicant's religious or moral beliefs.
---------------------------------------------------------------------------
\13\ OCR Complaint No. 11-122388; OCR Complaint No. 11-122387.
---------------------------------------------------------------------------
Members of Congress raised concerns following OCR's closure of
three additional complaints filed on September 10, October 1, and
October 9, 2014,\14\ alleging that the State of California violated the
Weldon Amendment by requiring insurance plans to cover elective
abortions. Those complaints were filed by eighteen different
complainants: one religious organization, seven churches, one church
school, two religiously affiliated universities, and seven employees of
one of those universities who participated in the university's health
plan. Each complaint alleged that the California Department of Managed
Health Care (CDMHC) had contacted seven insurers offering plans without
abortion coverage on August 22, 2014, and stated that those insurers
were required to include abortion coverage in order to maintain
certification as insurance companies in California. All seven insurers
changed their policies in response to the letter. OCR closed the
complaints on the stated ground that the seven insurers did not object
to providing abortion coverage on religious or moral grounds and that
the Weldon Amendment required such objection.\15\
---------------------------------------------------------------------------
\14\ OCR Complaint No. 14-193604; OCR Complaint No. 15-193782;
OCR Complaint No. 15-195665.
\15\ Letter from OCR Director to Complainants (June 21, 2016),
http://www.adfmedia.org/files/CDMHCInvestigationClosureLetter.pdf.
---------------------------------------------------------------------------
OCR at that time took the view that a protected entity must assert
a religious or moral objection in order to merit protection under the
Weldon Amendment, although the express language of the law does not
require that a health care entity claim a religious or moral objection
to merit protection. OCR's closures prompted 133 Members of Congress to
express concern to the HHS Secretary that the Department failed to
enforce the Weldon Amendment.\16\ Senior leaders of the House of
Representatives also scheduled a meeting with the HHS Secretary and OCR
Director to request information from OCR about these closures.\17\
---------------------------------------------------------------------------
\16\ Letter from Reps. John Fleming, M.D., Diane Black, et al.
to HHS Secretary Kathleen Sebelius (Nov. 25, 2014).
\17\ House Majority Whip Kevin McCarthy, et al., Letter to
Secretary Sebelius (June 22, 2016).
---------------------------------------------------------------------------
Since that time, OCR has closed three more complaints on
administrative grounds. The first, filed on May 5, 2016, alleged that a
hospital center violated the Church Amendments by discriminating
against a health care professional who performed and supported the
performance of abortions,\18\ but the complainant withdrew that
complaint nine months later. The second, filed October 25, 2016,
alleged a covered entity discriminated against the complainant when it
refused to perform a sterilization procedure. Though technically not a
conscience complaint itself, the covered entity's answer, filed before
OCR undertook any investigation, raised conscience-based defenses,
specifically citing the Church Amendments. Following the complainant's
request to withdraw the complaint, OCR administratively closed the
case. The third, filed on January 17, 2017, concerned literature the
complainant received from his employer's pharmacy benefit management
company, and to which the employee had a religious or moral
objection.\19\ OCR determined that the complainant had failed to raise
sufficient facts to support a claim under the Federal health care
conscience and anti-discrimination laws.
---------------------------------------------------------------------------
\18\ OCR Complaint No. 15-238113.
\19\ OCR Complaint No. 17-259696.
---------------------------------------------------------------------------
Of the ten complaints filed before November 2016, two (one filed
August
[[Page 3887]]
15, 2014 and the other filed November 4, 2015) remain open. Although
OCR received on average only approximately 1.25 complaints per year
from the 2008 Rule until November 2016, OCR has received thirty-four
complaints between November 2016 and mid-January 2018.
VI. Reasons for the Proposed Rule
After reviewing the previous rulemakings, comments from the public,
and OCR's enforcement activities, the Department has concluded that
there is a significant need to amend the 2011 Rule to ensure knowledge,
compliance, and enforcement of the Federal health care conscience and
associated anti-discrimination laws. The 2011 Rule created confusion
over what is and is not required under Federal health care conscience
laws and narrowed OCR's enforcement authority. Since November 2016,
there has been a significant increase in complaints filed with OCR
alleging violations of these conscience and associated anti-
discrimination laws. The increase underscores the need for the
Department to have the proper enforcement tools available to
appropriately enforce Federal health care conscience and associated
anti-discrimination laws.\20\
---------------------------------------------------------------------------
\20\ Since 2011, conscience and coercion in health care have
been the subjects of significant litigation on the State and local
level. Recently, the Supreme Court agreed to determine whether
certain disclosures required by a state law violate the Free Speech
rights of pregnancy resource centers that do not refer for
abortions. See National Institute of Family and Life Advocates v.
Becerra, No. 16-1140 (certiorari granted November 13, 2017).
---------------------------------------------------------------------------
A. Allegations and Evidence of Discrimination and Coercion Have Existed
Since the 2008 Rule and Increased Over Time
The 2008 Rule sought to address an environment of discrimination
toward, and attempted coercion of, those who object to certain health
care procedures based on religious or moral convictions.\21\ Yet in
February 2009, the Department announced its intent to rescind the 2008
Rule just one month after its effective date.\22\ And it completed that
rescission in 2011 despite significant evidence of an environment of
discrimination and coercion, including thousands of public comments
during the 2008 and 2011 rulemakings describing the same. Indeed, a
2009 article in the New England Journal of Medicine argued, ``Qualms
about abortion, sterilization, and birth control? Do not practice
women's health.'' \23\ In a 2009 survey of 2,865 members of faith-based
medical associations, 39% reported having faced pressure or
discrimination from administrators or faculty based on their moral,
ethical, or religious beliefs.\24\ Additionally, 32% of survey
respondents reported having been pressured to refer a patient for a
procedure to which they had moral, ethical, or religious objections.
Some 20% of medical students in that poll said that they would not
pursue a career in obstetrics/gynecology because of perceived
discrimination and coercion in that specialty against their beliefs. In
total, 91% of respondents reported that they ``would rather stop
practicing medicine altogether than be forced to violate [their]
conscience.''
---------------------------------------------------------------------------
\21\ 73 FR 78072, 78073 (Dec. 19, 2008) (2008 Rule).
\22\ Rob Stein, Obama Plans to Roll Back `Conscience' Rule
Protecting Health Care Qf Workers Who Object to Some Types of Care,
The Washington Post (Feb. 28, 2009) http://www.washingtonpost.com/wp-dyn/content/article/2009/02/27/AR2009022701104.html (writing that
``The administration's plans, revealed quietly with a terse posting
on a Federal website, unleashed a flood of heated reaction'').
\23\ Julie D. Cantor, M.D., J.D., ``Conscientious Objection Gone
Awry--Restoring Selfless Professionalism in Medicine,'' 360 New
England J. Med. 1484-85 (April 9, 2009).
\24\ The Polling CompanyTM, Inc./WomanTrend, Highlights of The
Polling Company, Inc. Phone Survey of the American Public, fielded
March 31, 2009 through April 3, 2009), https://www.cmda.org/library/doclib/pollingsummaryhandout.pdf (last visited Jan. 18, 2018); see
also Memorandum from Jonathan Imbody, Christian Medical Association,
Vice President for Government Relations to Office of Public Health
and Science, Department of Health and Human Services (Apr. 9, 2009).
---------------------------------------------------------------------------
Comments received during the 2011 rulemaking were consistent with
this survey. Multiple commenters reported that some hospitals had
forced health care providers to sign affidavits agreeing to participate
in abortions if asked.\25\ One obstetrician/gynecologist commented
that, during his entire time in health care--from medical school,
through his residency, and to private practice--he had been pressured
to participate in abortions and abortion counseling.\26\ Medical and
nursing students, in twenty-five comments, expressed their reluctance
to enter the health care field as a whole, and particularly specialties
such as obstetrics, family medicine, and elder care, where their
objections to abortion or euthanasia might not be respected.\27\ At
least ninety commenters said that, if forced to choose between their
careers or violating their conscience, they would quit their jobs.\28\
Tens of thousands of comments to the proposed 2011 Rule expressed
concern that, without robust enforcement of Federal health care
conscience laws, individuals with conscientious objections simply would
not enter the health care field at all or would leave the profession,
and hospitals would shut down, contributing to the shortage of health
care providers or affecting the quality of care provided.\29\ Thousands
also feared
[[Page 3888]]
personnel with objections would be terminated or otherwise unable to
find employment, training, or opportunities to advance in their
field.\30\ Commenters identified a culture of hostility to conscience
concerns in health care.\31\ Some expressed concern that the rescission
of the 2008 Rule would contribute to these problems by inappropriately
politicizing, and interfering in, the practice of medicine and
individual providers' judgment.\32\ Thousands of comments from medical
personnel stated their disagreement with the rescission, often stating
that they had requested exemptions in the past and were concerned
rescission would make it harder to request exemptions in the
future.\33\ Hundreds of commenters expressed concern over the exclusion
and marginalization of health care entities and employees holding
religious or moral convictions, and fears that the moral agency of the
medical profession was eroding.\34\
---------------------------------------------------------------------------
\25\ Comment Nos. HHS-OPHS-2009-0001-0739, -52648, -52677.
\26\ Comment No. HHS-OPHS-2009-0001-0868.
\27\ Comment Nos. HHS-OPHS-2009-0001-0026, -1035, -10522, -
12117, -14427, -34439, -11404 (``future physician'' concerned about
shortages), -35236 (granddaughter entering the medical profession
will change career path), -11579 (son entering the medical
profession), -14435 (concerned mother of medical student), -18783
(spoke to student who is distraught and may leave), -5571, -41431
(sister is a medical student), -5638, -0068, -1791 (student would
quit job), -2750 (exacerbates healthcare issues), -5255 (opposed and
has used exemption), -7058, -7276, -7671, -5270 (has already seen
others leave the profession over pressure for their beliefs), -5638,
-5566 (nurse who chose not to specialize in obstetrics and
gynecology for fear of pressure), -5566 (nurse who chose not to
enter obstetrics and gynecology because of pressure to perform
abortions).
\28\ Almost 90 comments are cited here, but this is merely a
sample of the total. See comment Nos. HHS-OPHS-2009-0001-0540, -
0017, -0264, -0350, -0356, -0485, -0540, -0880, -0881, -0902, -0917,
-0932, -10154, -15148, -20381 (woman in California whose daughter is
a nurse), -23290 (already left the profession), -32951, -9188, -
47007 (patient's doctor said he would retire), -14287, -19128, -
9873, -29603 (physician stating many will retire), -50498 (patient's
doctor said he would retire), -27384, -44458, -18837, -14216, -
18015, -18015, -34140 (already retired but would have retired
earlier), -32593, -15341, -14837, -8582, -16541, -11579 (patient's
doctor said he would retire), -0229, -51896 (children would be
forced to leave), -32009 (other physicians will be driven out), -
10280 (physician with objections), -19029, -33116, -50663, -3675, -
24456, -11327, -19221, -34888 (nurse saying others will leave), -
14535 (daughter will leave the profession), -21679 (four members in
the family who may leave), -0283, -0340, -0905, -9272, -0055 (will
give up serving underserved population), -10862 (two sisters who are
nurses will leave, hospital shut down), -17401, -29674 (son who is a
physician will be forced out), -26795 (physician who says doctors
will be forced out), -25742, -49731, -15087, -13138, -17563, -0006
(refuse to accept violation of beliefs in practice), -0815, -7665, -
8091, -2598 (private family physician who intentionally avoided
obstetrics because it was made clear that ``pro-life candidates need
not apply.'' Also cites strong pressure in universities and
organizations in favor of abortion provision. Concerned physicians
will leave the practice more.), -3564, -0199, -5230 (discrimination
already present), -6603, -1397 (nurse who has been forced to do
things against her conscience in the past before the 2008 rule came
into effect, and who will quit if put in that scenario again), -1100
(nurse who says others will leave the practice), -6669, -0272, -
0925, -0125, -4668, -6709, -7900, -2544, -3535, -1852, -7684, -1381.
\29\ Comment Nos. HHS-OPHS-2009-0001-20613, -43039, -27699, -
42804, -6001, -10850, -27147, -50621, -52878, -19586, -40775, -4824,
-27384, -11138, -52997, -53001, -4460, -12878, -12575, -43364, -
27262, -42942, -26426, -38158, -43672, -52381, -32173, -16541, -
19751, -2697, -52935, -6369, -44571, -53022, -48387, -21990, -50837,
-42069, -14662, -51974, -45449, -17364, -5370, -2922, -15005, -
18783, -23376, -50685, -17401, -52946, -11206, -33828, -38997, -
3925, -21036, -50894, -27155, -10529, -47113, -7266, -22291, -4016,
-0204, -8788, -25608, -52932, -39199, -12340, -52950 (form letter
with 1,916 copies), -31897, -52984 (form letter with 62 copies), -
53081 (form letter with 22 copies), -52968 (form letter with 9,532
copies), -52961 (patients concerned about access to pro-life
doctors: Form letter with 3,272 copies), -53098 (patients concerned
effort to push people out: Form letter with 976 copies), -52977
(form letter with 3,516 copies), -53021 (form letter with 4,842
copies), -52949 (form letter with 688 copies), -53039 (form letter
with 742 copies), -0476.
\30\ Comment Nos. HHS-OPHS-2009-0001-0558, -10144, -53026
(claims documentation of unaddressed discrimination), -52985 (claims
documentation of unaddressed discrimination), -52960 (claims
documentation of unaddressed discrimination), -52735 (lack of
knowledge about rights), -53048 (evidence of discrimination), -53047
(evidence of discrimination: Form letter with 3,196 copies), -52960
(evidence of discrimination: Form letter with 1,685 copies), -53028
(evidence of discrimination: Form letter with 2,002 copies).
\31\ Comment Nos. HHS-OPHS-2009-0001-0739, -52677, -26812, -
53013 (form letter with 8,472 copies).
\32\ Comment No. HHS-OPHS-2009-0001-10280, -2486, -46903, -
19125, -36940, -12020, -41551.
\33\ Comment Nos. HHS-OPHS-2009-0001-3107, -15617, -19496, -
27506, -9586, -35721, -49748, -1650, -19965, -18365, -23095, -6332,
-3405, -1762, -4395, -4569, -6890, -0729, -0943, -1490, -2994, -
3248, -3419, -5341, -6479, -7079, -4525, -7093, -2486, -2039, -7750,
-6270, -1903, -3293, -3405, -1127, -5505, -1823, -4939, -5881, -
4529, -5829, -1773, -2220, -2345, -3089, -7163, -7471, -3840, -0389,
-1933, -3493, -3088, -5088, -5702.
\34\ Comment Nos. HHS-OPHS-2009-0001-52974 (form letter with 428
copies).
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According to news reports, in 2010, Nassau University Medical
Center disciplined eight nurses when they raised objections to
assisting in the performance of abortions.\35\ Nurses in Illinois and
New York filed lawsuits against private hospitals alleging they had
been coerced to participate in abortions. Mendoza v. Martell, No. 2016-
6-160 (Winnebago County Cir. Ill. June 8, 2016); Cenzon-DeCarlo v.
Mount Sinai Hospital, 626 F.3d 695 (2d Cir. 2010). A nurse-midwife in
Florida alleged she had been denied the ability to apply for a position
at a hospital due to her objections to prescribing certain medications.
Hellwege v. Tampa Family Health Centers, 103 F. Supp. 3d 1303 (M.D.
Fla. 2015). Twelve nurses in New Jersey sued a public hospital over a
policy allegedly requiring them to assist in abortions and for
disciplining one nurse who raised a conscientious objection to the
same. Danquah v. University of Medicine and Dentistry of New Jersey,
No. 2:11-cv-6377 (D.N.J. Oct. 31, 2011). Many religious health care
personnel and faith-based medical entities have further alleged that
health care personnel are being targeted for their religious
beliefs.\36\
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\35\ LI Hospital issues abortion apology to nurses, N.Y. Post
(Apr. 28, 2010), http://nypost.com/2010/04/28/li-hospital-issues-abortion-apology-to-nurses.
\36\ See, e.g., Roman Catholic Diocese of Albany v. Vullo, No.
02070-16 (N.Y. Albany County S. Ct. May 4, 2016); Means v. U.S.
Conference of Catholic Bishops, No. 1:15-CV-353, 2015 WL 3970046
(W.D. Mich. 2015); ACLU v. Trinity Health Corporation, 178 F.Supp.3d
614 (E.D. Mich. 2016); Minton v. Dignity Health, No. 17-558259
(Calif. Super. Ct. Apr. 19, 2017); Chamorro v. Dignity Health, No.
15-549626 (Calif. Super. Ct. Dec. 28, 2015). See also U.S.
Conference of Catholic Bishops, Ethical and Religious Directives for
Catholic Health Services (Nov. 17, 2009) (identifying Catholic
objections to performing abortions, tubal ligations, and
hysterectomies).
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In 2016, the American Congress of Obstetricians and Gynecologists
(ACOG) reaffirmed a prior ethics opinion that recommended, ``[i]n an
emergency in which referral is not possible or might negatively affect
a patient's physical or mental health, providers have an obligation to
provide medically indicated and requested care regardless of the
provider's personal moral objections.'' \37\
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\37\ https://www.acog.org/Clinical-Guidance-and-Publications/Committee-Opinions/Committee-on-Ethics/The-Limits-of-Conscientious-Refusal-in-Reproductive-Medicine (reaffirming ACOG, The Limits of
Conscientious Refusal in Medicine, Committee Opinion No. 385, 110
Obstet Gyn. 1479 (2007)) The 2007 ACOG opinion had, at least in
part, prompted the 2008 Rule. Then-HHS Secretary Leavitt wrote to
ACOG and the American Board of Obstetrics and Gynecology (ABOG) and
noted that the combination of the ACOG opinion and ABOG
certification requirements could constitute a violation of Federal
health care conscience laws.
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B. Recently Enacted State and Local Government Health Care Laws and
Policies Have Resulted in Numerous Lawsuits by Conscientious Objectors
The Department has witnessed an increase in lawsuits against State
and local laws that complainants allege violate conscience. For
example, many State and local governments have enacted legislation
requiring pregnancy resource centers to post notices related to
abortion that plaintiffs have objected to on First Amendment and
analogous grounds. Courts preliminarily or permanently enjoined
ordinances in New York City, Austin, Montgomery County, Baltimore, and
Illinois. Greater Baltimore Center for Pregnancy Concerns, Inc. v.
Mayor and City Council of Baltimore, No. 16-2325 (4th Cir. Jan. 5,
2018) (affirming freedom of speech claim to strike down Baltimore
ordinance requiring pregnancy resource center to state abortion
services are not available in their facilities); Evergreen Association,
Inc. v. City of New York, 740 F.3d 233 (2d Cir. 2014) (striking down
under the First Amendment ordinance provisions requiring disclosures
about whether pregnancy resource centers refer for abortion and
conveying city health department's recommendation to consult a licensed
medical provider); Austin LifeCare v. City of Austin, No. 1:11-cv-
00875-LY (W.D. Tex. Jun. 23, 2014) (permanently enjoining enforcement
of ordinance as void for vagueness); Centro Tepeyac v. Montgomery
County, 5 F.Supp.3d 745 (D. Md. Mar. 7, 2014) (applying strict scrutiny
in finding that ordinance violated pregnancy resource center's First
Amendment rights); Pregnancy Care Center of Rockford v. Rauner, No.
2016-MR-741 (Ill. 17th Jud. Cir. Dec. 20, 2016) (preliminary injunction
entered on free speech grounds); National Institute of Family and Life
Advocates v. Rauner, No. 3:16-cv-50310 (N.D. Ill. filed Sept. 29, 2016)
(preliminary injunction entered on free speech grounds). But litigation
continues in a case filed against Hawaii. See Calvary Chapel Pearl
Harbor v. Chin, No. 1:17-cv-00326-DKW-KSC (D. Haw., filed July 12,
2017) (stayed pending Supreme Court's review of NIFLA v. Becerra). And
several courts rejected challenges to California's law, see, e.g.,
Mountain Right to Life v. Harris, No. 5:16-cv-00119 (C.D. Calif. July
8, 2016) (denying preliminary injunction); A Woman's Friend Pregnancy
Resource Clinic v. Harris, 153 F.Supp.3d 1168 (E.D. Cal. Dec. 21,
2015); Livingwell Medical Clinic v. Harris, No. 3:15-cv-04939, 2015 WL
13187682 (N.D. Cal. Dec. 18, 2015).
Some of these ordinances also require that pregnancy resource
centers or medical professionals provide information about where
abortion services can be obtained or whether facilities have licensed
medical staff. The Supreme Court issued a writ of certiorari in one
such case challenging California's A.B. 775 on free speech grounds. See
NIFLA v. Becerra, No. 16-1140 (Nov. 13, 2017).
Some States have also sought to require health insurance plans to
cover abortions, triggering additional conscience-related lawsuits.
California, for example, sent a letter to seven
[[Page 3889]]
insurance companies requiring insurers to include abortion coverage in
plans used by persons who objected to such coverage. See Letter from
California Department of Managed Health Care, Re: Limitations or
Exclusions of Abortion Services (Aug. 22, 2014).\38\ The state of
California estimates that at least 28,000 individuals subsequently lost
their abortion-free health plans, and multiple churches have challenged
California's policy in court. See Foothill Church v. Rouillard, 2:15-
cv-02165-KJM-EFB, 2016 WL 3688422 (E.D. Calif. July 11, 2016); Skyline
Wesleyan Church v. California Department of Managed Health Care, No.
3:16-cv-00501-H-DHB (S.D. Calif. 2016). The New York State Department
of Financial Services required individual and small group employers,
irrespective of the number of employees or any religious affiliation,
to provide insurance coverage for abortions, see New York Department of
Financial Services, Outpatient and Professional Services Model
Language, Section IX[M], prompting additional lawsuits, see, e.g.,
Roman Catholic Diocese of Albany v. Vullo, No. 02070-16 (N.Y. Albany
County S. Ct. May 4, 2016).
---------------------------------------------------------------------------
\38\ https://www.dmhc.ca.gov/Portals/0/082214letters/abc082214.pdf.
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Over the past several years, an increasing number of jurisdictions
in the United States have also legalized assisted suicide. See District
of Columbia B21-0038 (Feb. 18, 2017), Colorado Prop. 106 (Dec. 16,
2016); California ABX2-15 (June 9, 2016); 18 Vermont Act 39 (May 20,
2013) (``Act 39''). Act 39 states that health care professionals must
inform patients ``of all available options related to terminal care.''
18 Vt. Stat. Ann. Sec. 5282. When the Vermont Department of Health
construed Act 39 to require all health care professionals to counsel
for assisted suicide, individual health care professionals and
associations of religious health care providers sued Vermont, alleging
a violation of their conscience rights. Vermont Alliance for Ethical
Health Care, Inc. v. Hoser, No. 5:16-cv-205 (D. Vt. Apr. 5, 2017)
(dismissed by consent agreement). More recently still, the family of a
California cancer patient sued UCSF Medical Center for elder abuse
because the cancer patient died after the oncologists on staff declined
to participate in assisted suicide and before she could obtain a new
physician.\39\
---------------------------------------------------------------------------
\39\ Bob Egelko, California's assisted-dying loophole: Some
doctors won't help patients die, San Francisco Chronicle (Aug. 12,
2017), http://www.sfchronicle.com/news/article/California-s-assisted-dying-loophole-Some-11761312.php.
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Finally, some States have passed laws requiring health care
professionals to provide referrals for implementation of advance
directives. See Iowa Code Ann. section 144D.3(5) (2012) (requiring that
provider take ``all reasonable steps to transfer the patient to another
health care provider, hospital, or health care facility'' even when
there is an objection based on ``religious beliefs, or moral
convictions''); Idaho Code Ann. 39-4513(2) (2012) (requiring that a
provider ``make[] a good faith effort to assist the person in obtaining
the services of another physician or other health care provider who is
willing to provide care for the person in accordance with the person's
expressed or documented wishes'').
The Department has not opined on or judged the legal merits or
sufficiency of any of the above-cited lawsuits or challenged laws. They
are discussed here only to illustrate that recent disputes alleging
violations of conscience, broadly understood, by state and local
governments exist to a notable degree, and to illustrate the need for
greater clarity concerning the scope and operation of the Federal
conscience and associated anti-discrimination laws that are the subject
of this regulation. The Department anticipates that the proposed
regulation will result in greater public familiarity with Federal
health care conscience and associated anti-discrimination protections
and may inform both potential plaintiffs and future State and local
legislators.
C. Confusion Exists About Conscience Laws' Scope and Applicability
Even though Federal health care conscience and associated anti-
discrimination laws are currently in effect, the public has sometimes
been confused about their applicability in relation to other Federal,
State, or local laws. One of the purposes of the 2008 Rule was to
address confusion about the interaction between Federal health care
conscience protections and other Federal statutes.
For instance, some advocacy organizations have filed lawsuits
claiming that Federal or State laws require private religious entities
to perform abortions and sterilizations despite the existence of
longstanding conscience and associated anti-discrimination protections
on this topic. See Means v. U.S. Conference of Catholic Bishops, No.
1:15-CV-353, 2015 WL 3970046 (W.D. Mich. 2015) (abortion); ACLU v.
Trinity Health Corporation, 178 F.Supp.3d 614 (E.D. Mich. 2016)
(abortion); Minton v. Dignity Health, No. 17-558259 (Calif. Super. Ct.
Apr. 19, 2017) (hysterectomy); Chamorro v. Dignity Health, No. 15-
549626 (Calif. Super. Ct. Dec. 28, 2015) (tubal ligation). A patient
also recently sued a secular public hospital for accommodating doctors'
and nurses' religious objections to abortion in alleged violation of a
State law, Washington's Reproductive Privacy Act. Coffey v. Public
Hospital Dist. No. 1, 20-15-2-00217-4 (Wash. 2015).
Congress has exercised the broad authority afforded to it under the
Spending Clause to attach conditions on Federal funds for respect of
conscience, and such conscience conditions supersede conflicting
provisions of State law and must be harmonized and given effect with
``cross-cutting'' anti-discrimination laws, as in many other contexts.
See e.g., Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et
seq. The Department seeks to clarify the scope and application of
Federal health care conscience and associated anti-discrimination laws
in the proposed rule.
D. Courts Have Found No Alternative Private Right of Action To Remedy
Violations
In lawsuits filed by health care providers for alleged violations
of certain Federal health care conscience and associated anti-
discrimination laws, courts have held that such laws do not contain an
implied private right of action to seek relief from such violations by
non-governmental covered entities. Adequate governmental enforcement
mechanisms are therefore critical to the enforcement of these laws.
The case of a New York nurse who alleged that a private hospital
forced her to assist in an abortion over her religious objections
illustrates the point. The nurse filed a lawsuit in Federal court in
2009, but her case was dismissed on the ground that she did not have a
private right to file a civil action against such a hospital under the
Church Amendments. Cenzon-DeCarlo v. Mount Sinai Hospital, 626 F.3d 695
(2d Cir. 2010). The Second Circuit affirmed the dismissal, holding that
the Church Amendments ``may be a statute in which Congress conferred an
individual right'' but that Congress had not implied a remedy to file
suit against private entities in Federal court. Id. at 698-699. After
the dismissal of the Federal lawsuit, the nurse then filed a case in
State court, but that case too was dismissed for lack of a private
right of action. Cenzon-DeCarlo v. Mount Sinai Hospital, 962 N.Y.S.2d
845 (S. Ct. Kings County 2010). The nurse then filed a complaint with
OCR on January 1, 2011, and, as discussed above, OCR resolved the
complaint when the hospital
[[Page 3890]]
changed its written policy for health care professionals going forward.
Similar results were obtained in a Federal lawsuit brought by a
nurse in 2014, alleging that a health center had violated subsection
(d) of the Church Amendments when it denied her the ability to apply
for a position as a nurse because she objected to prescribing
abortifacients. Hellwege v. Tampa Family Health Centers, 103 F. Supp.
3d 1303 (M.D. Fla. 2015). Like the court in New York, the court held
that the Church Amendments ``recognize important individual rights''
but did not confer a remedy to bring suit against a private entity in
Federal court. Id. at 1310. In July of this year, a Federal district
court in Illinois held that there is no private right of action for a
doctor who alleges that the State required her to refer for abortions
in violation of the Coats-Snowe Amendment. National Institute of Family
and Life Advocates, et al. v. Rauner, No. 3:16-cv-50310, at 4 (N.D.
Ill. July 19, 2017).
E. Addressing Confusion Caused by OCR Sub-Regulatory Guidance
In light of these decisions and the increase in conscience-based
challenges to State and local laws in the health care context, OCR has
a singular and critical responsibility to provide clear and appropriate
interpretation of Federal health care conscience and associated anti-
discrimination laws, to engage in outreach to protected parties and
covered entities, to conduct compliance reviews, to investigate alleged
violations, and to vigorously enforce those laws.
This proposed regulation intends to clear up confusion caused by
OCR sub-regulatory guidance issued through OCR's high-profile closing
of three Weldon Amendment complaints against the state of California
filed in 2014.\40\ On June 21, 2016, OCR declared it found no violation
stemming from California's policy requiring that health insurance plans
include coverage for abortion based on the facts alleged in the three
complaints it had received.\41\ OCR's closure letter concluded that the
Weldon Amendment's protection of health insurance plans included
issuers of health insurance plans but not institutions or individuals
who purchase or are insured by those plans. Even though California's
policy resulted in complainants losing abortion-free insurance that was
consistent with their beliefs, because none of the complainants were
insurance issuers, the letter concluded that none qualified as an
entity or person protected under the Weldon Amendment. Relying on
legislative history instead of the Weldon Amendment's text, OCR also
declared that health care entities are not protected under Weldon
unless they possess a ``religious or moral objection to abortion,'' as
opposed to some other reason for refusing to facilitate abortion, and
concluded that the insurance issuers at issue did not merit protection
because they had not raised any religious or moral objections. Finally,
OCR called into question its ability to enforce the Weldon Amendment
against a State at all because, according to the letter, to do so could
``potentially'' require the revocation of Federal funds to California
in such a magnitude as to violate the Constitution's prohibition on the
Federal government infringing State sovereignty through its Spending
Clause power.\42\
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\40\ OCR Complaint Nos. 14-193604, 15-193782, and 15-195665.
\41\ Letter from OCR Director to Complainants (June 21, 2016)
available at http://www.adfmedia.org/files/CDMHCInvestigationClosureLetter.pdf.
\42\ In reaching this conclusion, the letter cited advice from
``HHS' Office of General Counsel, after consulting with the
Department of Justice,'' but HHS believes this advice may have been
relayed orally as it has not located any written legal analysis from
either the HHS Office of the General Counsel or the Department of
Justice despite a diligent search.
---------------------------------------------------------------------------
The Department does not opine upon, and has not made a judgment on,
the compatibility of California's policy with the Weldon Amendment. But
clarifications are in order with respect to the general interpretations
of the Weldon Amendment offered in OCR's previous closure of complaints
against California's abortion coverage requirement. The Department has
engaged in further consideration of these general matters and has also
further reviewed the Federal health care conscience statutes, the
legislative history, and the record of rulemaking and public comments
under Part 88. Based on this review, the Department has concluded that
the above-mentioned sub-regulatory guidance issued by OCR with respect
to interpretation of the Weldon Amendment no longer reflects the
current position of HHS, OCR, or the HHS Office of the General Counsel.
Specifically, and first, HHS does not believe that the
``potential'' constitutional concerns cited in the letter relieve HHS
of the obligations Congress imposed on it to not make certain funding
available to covered entities that discriminate in violation of the
Weldon Amendment. Instead, HHS must diligently enforce the Weldon
Amendment according to its text and to the extent allowed by the
Constitution. It is a bedrock principle that the Federal government is
to presume that statutes passed by Congress are constitutional.
Additionally, if conflicts with the Constitution are clearly present,
saving constructions should be employed to avoid interpreting statutes
as dead letters. The Weldon Amendment's funding remedies in cases of
violation can and should be read and applied consistently with the
Constitution.
Second, in contrast to OCR's previous position, HHS concludes that
the Weldon Amendment's protection for health insurance and any other
kind of plans is not a protection that may only be invoked or
complained of by issuers.\43\ Per the amendment, ``the term `health
care entity' includes an individual physician or other health care
professional, a hospital, a provider-sponsored organization, a health
maintenance organization, a health insurance plan, or any other kind of
health care facility, organization, or plan.'' Consolidated
Appropriations Act, 2017, Public Law 115-31, Div. H, Tit. V, sec.
507(d) (emphasis added). The amendment's broad and non-exhaustive
definition indicates that the amendment takes an inclusive approach
with respect to the health care entities it protects and should not be
interpreted narrowly. Because the Weldon Amendment protects not only
the health insurance issuer, but also the health plan itself, it can
also be raised, at minimum, by the plan sponsor on behalf of the plan,
as well as by the issuer. Such an interpretation is not foreclosed by
either the statute or the regulation. Cf. Department of Justice Title
VI Legal Manual (``The financial assistance does not have to relate to
a program in which the complainant participates or seeks to participate
or [to a program] used for the complainant's benefit. Rather, an agency
only has to prove that the entity received Federal financial assistance
when the alleged discrimination occurred.'').
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\43\ HHS believes health insurance issuers are health care
entities by that term's plain meaning in the Weldon Amendment. But,
notably, while the Weldon Amendment explicitly protects plans, it
does not explicitly mention issuers. This further undermines OCR's
previous conclusion that the amendment protects issuers, but not
plans distinct from issuers.
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Finally, the plain text of the Weldon Amendment prohibits
discrimination against protected individuals and entities for being
unwilling to take certain actions or to provide certain support in
relation to abortion without requiring a specifically religious or
moral motive for that decision or position.\44\ The Weldon Amendment
[[Page 3891]]
states that funding shall not be available to an agency, program, or
government if that ``agency, program, or government subjects any
institutional or individual health care entity to discrimination on the
basis that the health care entity does not provide, pay for, provide
coverage of, or refer for abortions.'' See, e.g., Consolidated
Appropriations Act, 2017, Public Law 115-31, sec. 507(d). While Weldon
certainly protects objections based on conscience or religion, nothing
in the text limits its protection to those contexts. The legislative
history of the Weldon Amendment cannot be used to contradict or limit
the plain text of the statute. In any event, the legislative history in
the form of a floor statement from the Amendment's sponsor,
Representative Dave Weldon, reinforces the plain meaning of the
amendment. Representative Weldon stated that his amendment ``simply
states you cannot force the unwilling'' to participate in abortion, and
that it protects those ``who choose not to provide abortion services,''
including health professionals who say they are pro-choice and
supportive of Roe v. Wade, but would rather not perform abortions
themselves.\45\
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\44\ As seen by the compilation of the Federal health care
conscience and associated anti-discrimination laws that are the
subject of this proposed Rule, Congress uses the phrase ``religious
or moral convictions'' (or an equivalent) when it wants to exempt
only persons asserting those motivations, and does not include such
language when it wants to exempt persons and institutions without
any inquiry into their motivation. See, e.g., 42 U.S.C. 238n (Coats-
Snowe Amendment).
\45\ 150 Cong. Rec. H10090 (Statement of Rep. Weldon) (Nov. 20,
2004); 151 Cong. Rec. H177 (Statement of Rep. Weldon) (Jan. 25,
2005).
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The Department is concerned that segments of the public have been
dissuaded from complaining about religious discrimination in the health
care setting to OCR, at least in part, as the result of these previous
unduly narrow interpretations of the Weldon Amendment. For example,
Foothill Church in Glen Morrow, California, expressed concern that
filing a complaint with OCR about California's abortion-coverage
requirement was pointless because the Department had already closed
three similar complaints finding no violation of Federal health care
conscience laws. See Foothill Church v. Rouillard, No. 2:15-cv-02165-
KJM-EFB, 2016 WL 3688422 (E.D. Calif. July 11, 2016).
With the proposed rule, the Department seeks to educate protected
entities and covered entities as to their legal rights and obligations;
to encourage individuals and organizations with religious beliefs and
moral convictions to enter, or remain in, the health care industry;
and, by clarifying the Department's general views regarding the
operation and applicability of the Weldon Amendment, to prevent others
from being similarly dissuaded from filing complaints due to OCR sub-
regulatory guidance that is no longer reflective of the views of the
Department.
F. Additional Federal Health Care Conscience and Associated Anti-
Discrimination Laws
Finally, in addition to all of the concerns discussed above that
support the proposed rulemaking, the Department proposes to use this
rulemaking to address various other Federal health care conscience and
associated anti-discrimination laws not discussed in the 2008 and 2011
Rules. These provisions include the Consolidated Appropriations Act,
2017, Public Law 115-31, Div. H, sec. 209; Id., Div. E, sec. 726 and
808; 22 U.S.C. 7631(d); 29 U.S.C. 669(a)(5); 42 U.S.C. 1396f,
5106i(a)(1) and (2), 280g-1(d), 290bb-36(f), 1396s(c)(2)(B)(ii), 1395w-
22(j)(3)(B), 1396u-2(b)(3)(B), 1395cc(f), 1396a(w)(3), 1320a-1, 1320c-
11, 1395i-5, 1395x(e), 1395x(y)(1), 1396a(a), 1397j-1(b), and 14406.
Some of these provisions were enacted after 2008. All provide
additional protections for health care providers, patients,
beneficiaries of human services, or providers of human services from
coercion and discrimination because of moral convictions or religious
beliefs.
VII. Summary of the Proposed Rule
This proposed rule would generally reinstate the structure of the
2008 Rule, supplemented with further definition of Federal health care
conscience and associated anti-discrimination laws and robust notice
and enforcement provisions. Specifically, the proposed rule would
require certain recipients of Federal financial assistance from the
Department or of Federal funds from the Department to both notify
individuals and entities who are protected under the Federal health
care conscience and associated anti-discrimination laws (such as
employees, applicants, or students) of their rights and also to assure
and certify to the Department their compliance with the requirements of
these laws. It would also set forth in more detail the investigative
and enforcement responsibility of OCR, along with the tools at OCR's
disposal in carrying out its responsibility with respect to those
Federal health care conscience and associated anti-discrimination laws.
By virtue of Congress's enactment of all the Federal health care
conscience and associated anti-discrimination laws cited herein, the
Department is required to ensure its own compliance with those
statutes, and the compliance of its funding recipients. In 2008 and
2011, the Secretary delegated to OCR the authority to receive
complaints of discrimination under the Church, Coats-Snowe, and Weldon
Amendments, in coordination with Departmental components that provide
Federal financial assistance. Congress later designated OCR as having
enforcement authority under Section 1553 of the ACA. Many of the
remaining statutes that are the subject of the proposed rule do not
have any implementing regulations. With the publication of this
proposed rule in the Federal Register, the Secretary thus provides
notice of the delegation to OCR of full enforcement authority over a
significantly larger universe of Federal statutes compared to the 2008
and 2011 Rules.
The compliance and enforcement sections specify in much greater
detail than either the 2008 or 2011 Rule how OCR will enforce the
Federal health care and associated anti-discrimination laws beyond the
receipt and handling of complaints and the coordination with other
Department components. Implementation of the requirements set forth in
this proposed rule would be conducted in the same way that OCR
implements other civil rights requirements (such as the prohibition of
discrimination on the basis of race, color, or national origin), which
includes outreach, investigation, compliance, technical assistance, and
enforcement practices. Enforcement would be based on complaints,
referrals, news reports, and OCR-initiated compliance reviews and
communications activities. If OCR were to become aware of a potential
violation of Federal health care conscience and associated anti-
discrimination laws, OCR would assist or require such government or
entity to come into compliance. If, despite the Department's
assistance, compliance were not achieved, the Department would consider
all legal options available to overcome the effects of such
discrimination or violations. Enforcement mechanisms would include
termination of relevant funding in whole or in part, claw backs,
referral to the Department of Justice, or other measures. This proposed
rule clarifies that recipients are liable for their own compliance with
Federal health care conscience and associated anti-discrimination laws
and implementing regulations, as well as for ensuring their sub-
recipients comply with these laws. The rule also clarifies that parties
subject to OCR investigation have a duty to cooperate and preserve
documents
[[Page 3892]]
and to report that they if they are subject to an OCR enforcement
action or investigation to their funding agency. Finally, the rule
grants OCR authority to remedy claims of intimidation and retaliation
against those who file a complaint or assist in an OCR investigation.
VIII. Section-by-Section Descriptions of the Proposed Rule
Proposed Section 88.1 Purpose
The ``Purpose'' section of the regulation sets forth the objective
that the proposed regulation would, when finalized, provide for the
implementation and enforcement of Federal health care conscience and
associated anti-discrimination laws. It also states that the statutory
provisions and regulations contained in this part are to be interpreted
and implemented broadly to effectuate their protective purposes.
Proposed Section 88.2 Definitions
Administered by the Secretary: The Department proposes that a
Federally funded program or activity is ``administered by the
Secretary'' when it is ``subject to the responsibility of the Secretary
of the U.S. Department of Health and Human Services, as established via
statute or regulation.'' This term was used but not defined in the 2008
Rule, and is defined here in order to add clarity.
Assist in the Performance: The Department proposes that ``assist in
the performance'' means ``to participate in any activity with an
articulable connection to a procedure, health service or health service
program, or research activity, so long as the individual involved is a
part of the workforce of a Department-funded entity. This includes
counseling, referral, training, and other arrangements for the
procedure, health service, or research activity.'' This definition
mirrors the definition used for this term in the 2008 Rule.
In interpreting the term ``assist in the performance,'' the
Department seeks to provide broad protection for individuals,
consistent with the plain meaning of the statutes. The Department
believes that a more narrow definition of the statutory term ``assist
in the performance,'' such as a definition restricted to those
activities that constitute direct involvement with a procedure, health
service, or research activity, would fall short of implementing the
protections Congress provided. But the Department acknowledges that the
rights in the statutes are not unlimited, and it proposes to limit the
definition of ``assist in the performance'' to activities with an
articulable connection to the procedure, health service, health service
program, or research activity in question.
Department: The Department proposes to define ``the Department'' to
mean the U.S. Department of Health and Human Services and any component
thereof.
Discriminate or Discrimination: The Department proposes to define
``discriminate'' or ``discrimination'' to mean, as applicable and as
permitted by the applicable statute, (1) to withhold, reduce, exclude,
terminate, restrict, or otherwise make unavailable or deny any grant,
contract, subcontract, cooperative agreement, loan, license,
certification, accreditation, employment, title, or other similar
instrument, position, or status; (2) to withhold, reduce, exclude,
terminate, restrict, or otherwise make unavailable or deny any benefit
or privilege; (3) to utilize any criterion, method of administration,
or site selection, including the enactment, application, or enforcement
of laws, regulations, policies, or procedures directly or through
contractual or other arrangements, that tends to subject individuals or
entities protected under this part to any adverse effect described in
this definition, or to have the effect of defeating or substantially
impairing accomplishment of a health program or activity with respect
to individuals, entities, or conduct protected under this part; or (4)
to otherwise engage in any activity reasonably regarded as
discrimination, including intimidating or retaliatory action. The 2008
Rule did not define this term--it is defined here in order to provide
clearer notice to the public about what sort of conduct certain
provisions of this proposed rule would prohibit.
A functional concept of ``discrimination'' in this context must
account for the various forms that violations of the right of
conscience can take. One way Federal law prohibits such violations is
by requiring that religious individuals or institutions be allowed a
level playing field, and that their beliefs not be held to disqualify
them from participation in a program or benefit. For example, a medical
school that receives a grant under the Public Health Service Act may
not deny admission to an applicant based on that applicant's
conscientious objection to participating in an abortion. 42 U.S.C.
300a-7(e). This form of discrimination, broadly conceived--denial of
participation in a program, service, or benefit--parallels the type of
discrimination typically prohibited with respect to other protected
characteristics such as race, color, or national origin. See 45 CFR
80.3 (HHS regulations implementing Title VI nondiscrimination
requirements and prohibiting, inter alia, ``Deny[ing] an individual any
service . . .'', ``Subject[ing] an individual to segregation or
separate treatment . . .'', ``Treat[ing] an individual differently from
others in determining whether he satisfies any admission . . .
requirement . . .'', etc., on the basis of race, color, or national
origin). HHS believes it appropriate to apply the general principles of
nondiscrimination enshrined in Title VI with full force to
discrimination on the basis of religious belief or moral conviction.
Freedom from discrimination on the basis of religious belief or
moral conviction, however, does not just mean the right not to be
treated differently or adversely; it also means being free not to act
contrary to one's beliefs. To that end, Federal law carves out
exemptions based on religious and/or conscientious objection to
otherwise generally applicable requirements that compel certain
conduct. For instance, as discussed infra, although the ACA's
individual mandate compels, via force of a tax penalty, the purchase of
minimum essential health coverage, that mandate exempts certain
religious organizations and individuals who conscientiously oppose
acceptance of the benefits of any private or public insurance. 26
U.S.C. 1402(g)(1). OCR solicits comments regarding the impact on the
proposed regulation of the planned elimination of the penalty for
failure to carry ACA-mandated health insurance as set forth in the
major tax reform legislation passed at the end of 2017.
The intersection of religion and health care may also create the
more unusual and insidious circumstance in which governmental
authorities unlawfully seek to target religious organizations or
individuals for additional legal or regulatory burdens, precisely
because of their exercise of a particular religious belief or moral
conviction. See Church of the Lukumi Babalu Aye, Inc. v. Hialeah, 508
U.S. 520 (1993) (striking down facially neutral ordinance gerrymandered
to apply only to religiously motivated conduct). The Supreme Court has
made clear that governmental burdens on speech targeting particular
viewpoints are presumptively unconstitutional. Matal v. Tam, 137 S.Ct.
1744, 1766 (2017) (``A law found to discriminate based on viewpoint is
an egregious form of content discrimination, which is presumptively
unconstitutional.''
[[Page 3893]]
(internal citations and quotations omitted)). Thus, within OCR's
regulatory ambit, and to the extent permitted by law, OCR will regard
as presumptively discriminatory any law, regulation, policy, or other
such exercise of authority that has as its purpose, or explicit or
otherwise clear application, the targeting of religious or conscience-
motivated conduct. In determining the purpose or justification of such
an exercise of authority, OCR will consider all relevant factors and
proposes to include in that analysis, when supported by the applicable
statute, whether or not the exercise of authority has a disparate
impact on religious believers or those who share a particular religious
belief or moral conviction. The Department solicits comment on whether
disparate impact analysis is appropriate, as a policy or legal matter,
to apply to any of the statutes implemented by this rule; whether it is
appropriately included in the definition of discrimination, and, if so,
how disparate impact analysis would be best performed in the context of
applicable Federal health care conscience and associated anti-
discrimination laws (e.g., how groups suffering the disparate impact
can be described under the various statutes).
Entity: The Department proposes to define the term ``entity''
consistent with the definition of ``person'' in 1 U.S.C. 1 and also to
include any State, political subdivision of any State, instrumentality
of any State or political subdivision thereof, and any public agency,
public institution, public organization, or other public entity in any
State or political subdivision of any State. The 2008 Rule provided
identical definitions for both ``entity'' and ``health care entity.''
Here, the Department proposes this definition of ``entity,'' distinct
from the definition of ``health care entity'' set out infra, to better
fit the use of these terms in the statutes at issue in this proposed
rule.
Federal Financial Assistance: The Department proposes to define the
term ``Federal financial assistance'' to include ``(1) the grant or
loan of Federal funds; (2) the grant or donation of Federal property
and interests in property; (3) the detail of Federal personnel; (4) the
sale or lease of, and the permission to use (on other than a casual or
transient basis), Federal property or any interest in such property
without consideration or at a nominal consideration, or at a
consideration which is reduced for the purpose of assisting the
recipient or in recognition of the public interest to be served by such
sale or lease to the recipient; and (5) any Federal agreement,
arrangement, or other contract which has as one of its purposes the
provision of assistance.'' Note that Federal financial assistance
includes forms of non-cash assistance. The 2008 Rule did not use the
term ``Federal financial assistance.'' It is employed here to provide
greater clarity about what sort of Federal assistance triggers
obligations under this part. The Department notes that this term will
likely be familiar to much of the health care industry, and is intended
in the proposed rule to carry its traditional meaning, such as that
provided in the Department's regulations implementing Title VI of the
Civil Rights Act of 1964. See 45 CFR 80.13.
Not all of the statutes that the proposed rule would enforce use
the term ``Federal financial assistance.'' This is reflected in the
text of the various provisions in Sec. 88.3 of the proposed rule,
which set out the proposed rule's terms regarding the applicability of
the statutes being enforced. However, the proposed rule would establish
separate requirements regarding assurance and certification of
compliance with applicable Federal health care conscience and
associated antidiscrimination laws, and regarding the posting of
notices regarding those laws. The proposed rule employs the term
``Federal financial assistance'' in order to help define who must
comply with those separate requirements regarding assurance and
certification of compliance and notices.
Health Care Entity: The Department proposes to define the term
``health care entity'' to include an individual physician or other
health care professional, health care personnel, a participant in a
program of training in the health professions, an applicant or
participant for training or study in the health professions, a
postgraduate physician training program, a hospital, a laboratory, an
entity engaging in biomedical or behavioral research, a provider-
sponsored organization, a health maintenance organization, a health
insurance plan (including group or individual plans), a plan sponsor,
issuer, or third-party administrator, or any other kind of health care
organization, facility, or plan. It may also include components of
State or local governments.
The Department's proposed definition is an illustrative, not
exhaustive, list. Like the statutory definitions in the Weldon
Amendment and Public Health Service Act, the Department uses the words
``include'' and ``any other kind'' to indicate that the list is
illustrative. Thus, the Department's proposed inclusion of the terms
``health care professional'' and ``health care personnel'' is intended,
for example, to cover pharmacists, nurses, occupational therapists,
public-health workers, and technicians, as well as psychiatrists,
psychologists, counselors, and other mental health providers, but the
definition does not enumerate these health care job categories because
they are reasonably included in such terms. To attempt to employ an
exhaustive list would run the risk of inadvertently omitting certain
types of health care professionals or health care personnel.
With regard to the term ``health insurance plan,'' the Department
proposes that it include the sponsors, issuers, and third-party
administrators of health care plans or insurance. The Weldon Amendment
specifically includes in its definition of the term ``health care
entity'' ``a provider-sponsored organization, a health maintenance
organization, a health insurance plan, or any other kind of . . .
plan'' and protects such health care entities from being subject to
discrimination on the basis that they do not provide, pay for, cover,
or refer for abortions. Thus, to ensure that Congress's explicit
protection for health insurance plans and health care organizations is
fully enforced, the Department considers it appropriate to include plan
sponsors not primarily engaged in the business of health care as
``health care entities'' for purposes of the proposed regulation.
We ask for comment on this proposed approach. We also ask for
comment on whether the terms ``entity'' and ``health care entity,'' as
we propose to employ them in relation to the various statutes that this
rule implements, clearly and accurately reflect the intent and scope of
each of those statutes.
Health Program or Activity: The Department proposes to define
``health program or activity'' to include the provision or
administration of any health-related services, health service programs
and research activities, health-related insurance coverage, health
studies, or any other service related to health or wellness whether
directly, through payments, grants, contracts, or other instruments,
through insurance, or otherwise. In developing an appropriate
definition for ``health program or activity,'' HHS looked at Section
1128B(f)(1) of the Social Security Act, 42 U.S.C. 1320a-7b(f)(1), which
defines a similar term, ``Federal health care program,'' as ``any plan
or program that provides health benefits, whether directly, through
insurance, or otherwise, which is funded directly, in whole or in part,
by the United States Government.'' This term was not used
[[Page 3894]]
in the 2008 Rule, and is added here in order that this proposed rule
may correspond more precisely to the intended application of the
statutes at issue, where the term ``health service program'' may not
suffice.
Health Service Program: For the purposes of this part, the
Department proposes to define ``health service program'' to include any
plan or program that provides health benefits, whether directly,
through insurance, or otherwise, and is funded, in whole or part, by
the Department. It may also include components of State or local
programs. This definition mirrors the definition used for this term in
the 2008 Rule.
Because subsection (d) of the Church Amendments covers health
service programs or research activities administered by the Secretary,
these programs include those where the Department provides care or
health services directly (e.g., Indian Health Service, NIH Clinical
Center); programs administered by the Secretary that provide health
services through grants, cooperative agreements, or otherwise (e.g.,
Administration for Children and Families programs such as the
Unaccompanied Alien Children program, and HRSA programs such as
community health centers); programs where the Department reimburses
another entity that provides care (e.g., Medicare); and health
insurance programs where Federal funds are used to provide access to
health coverage (e.g., CHIP, Medicaid, and Medicare Advantage). It may
also include components of State or local governments. The Department
believes this definition would appropriately effectuate Congress's
intent to protect health service programs and research activities
funded in whole or in part by, and/or administered by the Secretary.
We have proposed definitions for both ``health program or
activity'' and ``health service program'' because the phrases are used
in different statutes that are the subject of this proposed rule. We
ask for comment on whether the terms mean the same thing and should or
could be defined interchangeably for purposes of this regulation.
Individual: For purposes of this part, the Department proposes to
define ``individual'' as a member of the workforce of an entity or
health care entity. The Department adopts the concept of ``workforce''
from the Health Insurance Portability and Accountability Act Rules,
where it includes volunteers, trainees, or other members or agents of a
covered entity, broadly defined, when the conduct of the person is
under the control of such entity. This definition mirrors the
definition used for this term in the 2008 Rule.
Instrument: The Department proposes to define ``instrument'' to be
the means by which Federal funds are conveyed to a recipient, and to
include grants, cooperative agreements, contracts, grants under a
contract, memoranda of understanding, loans, loan guarantees, stipends,
and any other funding or employment instrument or contract. There are a
variety of means by which the Department conveys Federal financial
assistance or other Federal funds from the Department to organizations,
including: Grants, cooperative agreements, contracts, grants under a
contract, and memoranda of understanding. The definition of
``instrument'' is intended to include all means by which the Department
conveys funding and resources. Save for the addition of the phrase
``loans, loan guarantees, stipends,'' this definition mirrors the
definition used for this term in the 2008 Rule.
OCR: The Department proposes to define OCR to signify the Office
for Civil Rights of the Department of Health and Human Services.
Recipient: The Department proposes to define ``recipient'' to mean
``any State, political subdivision of any State, instrumentality of any
State or political subdivision thereof, and any person or any public or
private agency, institution, organization, or other entity in any State
including any successor, assign, or transferee thereof, to whom Federal
financial assistance is extended directly from the Department or a
component of the Department, or who otherwise receives Federal funds
directly from the Department or a component of the Department, but such
term does not include any ultimate beneficiary.'' The term would
include State and local governments, public and private institutions of
higher education, public and private hospitals, commercial
organizations, and other quasi-public and private nonprofit
organizations such as, but not limited to, community action agencies,
research institutes, educational associations, and health centers. The
term may include foreign or international organizations (such as
agencies of the United Nations). This definition differs from the
definition used for this term in the 2008 Rule in part because this
proposed rule employs the term ``Federal financial assistance,''
whereas the 2008 Rule did not. Other changes made in this definition
are intended to provide clarity about the types of entities that may
qualify as recipients.
As discussed elsewhere in this notice of proposed rulemaking,
recipients would be subject to this part's requirements regarding
assurances and certifications of compliance. The Department seeks to
minimize the financial and administrative burdens of the proposed rule
by accomplishing the assurances and certifications required of
recipients through the forms that recipients are already filing to
assure or certify compliance with other applicable nondiscrimination
laws. The Department anticipates that the vast majority, if not all, of
recipients will be able to fulfill their assurance and certification
requirements by using the modified versions of the forms already in
use. Accordingly, if an entity is currently required to file an HHS-690
Form, HHS-5161-1 Form, or another similar form assuring or certifying
compliance with nondiscrimination requirements in connection with
Federal financial assistance from or through the Department, that
entity can reliably assume that it is a ``recipient'' for the purposes
of this part.
Referral or Refer for: The Department proposes to define
``referral'' \46\ or ``refer for'' as including the provision of any
information (including but not limited to name, address, phone number,
email, or website) by any method (including but not limited to notices,
books, disclaimers, or pamphlets online or in print) pertaining to a
service, activity, or procedure, including related to availability,
location, training, information resources, private or public funding or
financing, or direction that could provide any assistance in a person
obtaining, assisting, training in, funding, financing, or performing a
particular health care service, activity, or procedure, when the entity
or health care entity making the referral sincerely understands that
particular health care
[[Page 3895]]
service, activity, or procedure to be a purpose or possible outcome of
the referral. This term was not used in the 2008 Rule. It is added here
to address confusion the Department perceives among the public about
what sorts of actions may be properly regarded as referrals for the
purposes of protecting rights of conscience under the statutes at issue
in this proposed rule.
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\46\ Various ethicists have discussed how referral constitutes
moral cooperation with a conscientiously objected activity. See,
e.g., William W. Bassett, Private Religious Hospitals: Limitations
Upon Autonomous Moral Choices in Reproductive Medicine, 17 J.
Contemp. Health L. & Pol'y 455, 529 (2001) (``The moral principle
involved in the cooperation and referral situations is called the
principle of moral cooperation''); Armand H. Matheny Antommaria,
Adjudicating Rights or Analyzing Interests: Ethicists' Role in the
Debate Over Conscience in Clinical Practice, 29 Theor. Med. Bioeth.
201, 206 (2008) (``not contravening one's conscience through illicit
cooperation is a significant interest that may obligate one to
forego other important interests, such as one's job or even
career''); Stephen J. Genuis & Chris Lipp, Ethical Diversity and the
Role of Conscience in Clinical Medicine, 2013 Int'l. J. Family Med.
1, 9 (2013) (``Facilitating a clinical course of action that the
health provider sincerely deems to be ill-advised, unethical, or
against the patient's best interests may compromise the integrity of
the professional role and may violate fundamental tenets of such
ethical codes'').
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The Weldon Amendment prohibits discrimination on the basis that a
health care entity does not ``refer for abortions.'' The Coats-Snowe
Amendment prohibits discrimination on the basis that an entity refuses
to ``provide referrals for [induced abortions],'' ``refuses to make
arrangements for'' such referrals, or attends a health profession
training program that does not ``refer for training in the performance
of induced abortions.'' Section 1303 of the ACA prohibits qualified
health plans offered through an exchange from discriminating against
any individual health care provider or health care facility because of
its unwillingness to refer for abortions. 42 U.S.C. 18023(b)(4).
Medicare Advantage contains a protection for entities that inform HHS
that they will not provide referrals for abortions. Consolidated
Appropriations Act of 2017, Public Law 115-31, 131 Stat. 502, Div. H,
sec. 209 (2017). Certain recipients of funds administered by Secretary
under the Foreign Assistance Act cannot be required to make a referral
to a program or activity to which the recipient has a religious or
moral objection. 22 U.S.C. 7631(d). Medicare Advantage plans and
Medicaid managed care organizations are protected from being required
to provide certain referral services. 42 U.S.C. 1395w-22(j)(3); 42
U.S.C. 1396u-2.
The Department believes that Congress provided, in these Federal
health care statutes, protections for entities from discrimination in a
broad way related to referring for abortions or abortion training, or,
as specified in applicable statutes, for other kinds of services. In
the Coats-Snowe Amendment, for example, Congress protected not only the
refusal to provide referrals for abortion, but also the refusal to make
arrangements to provide referrals for abortion. This protects entities
that object not just to making referrals, but to rendering aid to
anyone else who is reasonably likely to make an abortion referral.
Likewise, in the Weldon Amendment and Section 1303 of the ACA, Congress
specified that it did not merely protect the action of declining to
refer to an abortion provider, but of declining to refer ``for''
abortions generally. This more broadly protects a decision not to
provide contact information or guidance likely to assist a patient in
obtaining an abortion elsewhere.
Under the proposed definition, to provide an abortion referral,
refer for abortion, or make arrangements for an abortion referral,
would include such activities as providing to a patient seeking
abortion contact information of a physician or clinic that may provide
an abortion, or telling a patient that funding is available for
abortion and providing a phone number where she can be referred to
abortion services or funding. It would include such activities by any
method, such as orally, in writing, digitally, or through the posting
of notices. The Department believes defining referral or refer in a
more narrow way, for example to only mean an endorsement,
recommendation, facilitated referral to a physician, or transfer of
records to a specific provider, would fail to implement Congress's
broad protection for entities unwilling to be complicit in the
provision of items or services they cannot in good conscience
themselves provide.
State: The Department proposes to define ``State'' to include, in
addition to the several States, the District of Columbia. For those
provisions in this part related to or relying upon the Public Health
Service Act, the term ``State'' is proposed to include the several
States, the District of Columbia, the Commonwealth of Puerto Rico,
Guam, the Northern Mariana Islands, the Virgin Islands, American Samoa,
and the Trust Territory of the Pacific Islands. For those provisions in
this part related to or relying upon the Social Security Act, the term
``State'' is proposed to incorporate the definition of ``State'' found
at 42 U.S.C. 1301. This term was not defined in the 2008 Rule but is
added here to reflect that the term carries different meanings in
certain statutes at issue in this proposed rule. The Department seeks
comment on whether this definition fully and accurately implements the
scope of the statutes that are the subject of this proposed rule,
especially with regard to statutes that cover State and local
government or other public authorities.
Sub-recipient: The Department proposes to define ``sub-recipient''
to mean ``any political subdivision of any State, any instrumentality
of any State or political subdivision thereof, and any person or any
public or private agency, institution, organization, or other entity in
any State, including any successor, assign, or transferee thereof, to
whom Federal financial assistance is extended through another recipient
or another sub-recipient, or who otherwise receives Federal funds from
the Department or a component of the Department indirectly through a
recipient or another sub-recipient, but such term does not include any
ultimate beneficiary.'' The term includes State and local governments,
public and private institutions of higher education, public and private
hospitals, commercial organizations, and other quasi-public and private
nonprofit organizations such as, but not limited to, community action
agencies, research institutes, educational associations, and health
centers. The term may include foreign or international organizations
(such as agencies of the United Nations). As with the definition of
``recipient,'' this definition differs from the 2008 Rule's definition
of this term in part because of the use of the term ``Federal financial
assistance,'' and also in order to provide greater clarity about the
types of potentially covered entities.
Workforce: The Department proposes to define ``workforce'' to
consist of employees, volunteers, trainees, contractors, and other
persons whose conduct in the performance of work for an entity or
health care entity is under the direct control of such entity or health
care entity, whether or not they are paid by the entity or health care
entity, as well as health care providers holding privileges with the
entity or health care entity. This definition substantially mirrors the
definition used for this term in the 2008 Rule.
Proposed Section 88.3 Applicable Requirements and Prohibitions
The proposed ``Applicability'' section outlines the specific
requirements of the Federal health care conscience and associated anti-
discrimination laws that apply to various persons and entities. These
provisions are taken from the relevant statutory language and would
direct covered entities to the appropriate sections that contain the
relevant requirements that form the basis of this regulation.
The ``Requirements and Prohibitions'' section explains the
obligations that the Federal health care conscience and associated
anti-discrimination statutes impose on the Department and on entities
that receive applicable Federal financial assistance and other Federal
funding from the Department. These provisions are taken from the
relevant statutory language.
We intend for the proposed requirements and prohibitions to be
interpreted using the definitions proposed in section 88.2.
[[Page 3896]]
Proposed Section 88.4 Assurance and Certification of Compliance
Requirements
In the ``Assurance and Certification of Compliance'' section, the
Department would require certain recipients to submit written
assurances and certifications of compliance with the Federal health
care conscience and associated anti-discrimination laws, as applicable,
as a condition of the terms of acceptance of the Federal financial
assistance or other Federal funding from the Department. While the 2008
Rule required only the submission of a certification of compliance, the
Department believes that both an assurance and certification provide
important protections to persons and entities under these laws and
would be consistent with requirements under other civil rights laws. We
are concerned that there is a lack of knowledge on the part of States,
local governments, and the health care industry of the rights of
protected persons and entities, and the corresponding obligations on
covered entities provided by the Federal health care conscience and
associated anti-discrimination laws. Certifications provide a
demonstrable way of ensuring that applicants for such funding know of,
and attest that they will comply with, applicable Federal health care
conscience and associated anti-discrimination laws.
Applicants for Department grants, loans, contracts, Federal
financial assistance, or other Federal funds from the Department are
currently required to sign assurances and certifications of compliance
with several specific civil rights laws, such as Title VI of the Civil
Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973,
Title IX of the Education Amendments of 1972, the Age Discrimination
Act of 1975. See HHS-690 Form, OMB No. 0945-0006 (Medicare Part A);
HHS-5161-1 Form, OMB No. 0930-0367 (HHS Grant Applications). The
assurances and certifications of compliance required by this part would
be accomplished via submission of modified versions of the applicable
civil rights clearance forms, such as the HHS-5161-1 Form, HHS-690
Form, or similar forms that may be developed and implemented in the
future.
The HHS-690 Form (Assurance of Compliance) briefly identifies the
prohibited discriminatory conduct covered by each civil rights law.
Although many Federal health care conscience and associated anti-
discrimination laws were enacted at approximately the same time as
those other civil rights laws, such conscience laws are not
specifically mentioned in Form HHS-690 Form or HHS-5161-1 Form. Adding
the above-referenced laws to these forms would increase awareness of
the Federal health care conscience and associated anti-discrimination
laws and demonstrate the Department's commitment to consistently
enforcing all civil rights protections on an equal basis. The
certification form serves to provide a formal statement by the
recipient, generally subsequent to the submission of the assurance that
the recipient actually is currently in compliance with the referenced
requirements.
Given this backdrop, section 88.4 proposes to require certain
applicants for Federal financial assistance or other Federal funds from
the Department to which this part applies to submit assurances and
certifications of compliance with Federal health care conscience and
associated anti-discrimination provisions and this part. Consistent
with current practice, we propose covered applicants file the HHS-690
Form once per year and incorporate such filing by reference in all
other applications submitted that year, rather than for every
application that year. To this end, and as consistent with other civil
rights regulations, proposed Sec. 88.4(b)(6) permits an applicant to
incorporate the assurance by reference in subsequent applications to
the Department. The proposed rule explains that both the assurance and
certification shall constitute a condition of continued receipt of
Federal financial assistance or other Federal funds from the
Department. With respect to the certification required in proposed
Sec. 88.4(a)(2), proposed Sec. 88.4(b)(7) clarifies that a violation
of the requirements of the certification may result in enforcement by
the Department, as provided in section 88.7 of this part.
The Department believes that requiring assurances and
certifications of compliance by applicants for and recipients of
Federal financial assistance and other Federal funds from the
Department would provide an important vehicle for increasing awareness
of Federal health care conscience and associated anti-discrimination
laws and thereby increasing compliance. While many people in the health
care field may have general knowledge that Federal health care
conscience and associated anti-discrimination protections exist for
persons and health care providers, the scope of these protections is
not always widely understood. Because Congress has enacted several
different protections, a person or entity may be aware that, for
instance, a physician may not be compelled to perform abortions, but
may not be aware of other aspects of the statutes providing Federal
health care conscience and associated anti-discrimination protections.
Others may become aware of these laws, at least in detail, only when a
dispute arises and a person, provider, or entity attempts to assert
their Federal health care conscience rights, and there may be
subsequent disagreement over the nature of the rights asserted.
The Department recognizes that it needs to undertake significant
outreach efforts in order for the rule to be maximally effective. Thus,
the Department will consider all avenues available for increasing
public awareness of Federal health care conscience laws. The Department
welcomes public comment on the various options available for public
education and outreach.
Paragraph (b) identifies specific requirements for the proposed
assurance and compliance requirements: (b)(1) Addresses the timing to
submit the assurance for current applicants or recipients as of the
effective date of this part; (b)(2) addresses the form and manner of
such submittals; and (b)(3) addresses the duration of obligations for
both the assurance and certification. In regard to the form and manner
of the submission, the Department is committed to leveraging existing
grant, contract, and other Departmental forms where possible rather
than creating additional, separate forms for recipients to sign. To
this end, Sec. 88.5(4)(2) explains that applicants shall submit
assurance and certification forms in an efficient manner specified by
OCR, in coordination with the relevant Department component, or
alternatively in a separate writing. Such certifications should be
clearly written so that applicants and recipients know, by means of the
certification, which provisions they must comply with based on the
nature of the recipient or the funding mechanism through which it
receives funds.
Department components will be given discretion to phase in the
written assurance and certification requirement by no later than the
beginning of the next fiscal year following the effective date of the
regulation. The Department intends to work with recipients of Federal
financial assistance or other Federal funds from the Department to
ensure compliance with the requirements or prohibitions promulgated in
this regulation. If the applicant or recipient fails or refuses to
furnish a required assurance or
[[Page 3897]]
certification, OCR, in coordination with the relevant Department
component, may effect compliance by any of the remedies provided in
Sec. 88.7.
While both recipients and sub-recipients, as defined herein, must
comply with the substantive requirements of Federal health care
conscience and associated anti-discrimination laws, as applicable, sub-
recipients are not subject to the requirements of section 88.4
regarding assurance and certifications of compliance. This approach
departs from the 2008 Rule, which required certifications of compliance
to be submitted by both recipients and sub-recipients. By exempting
sub-recipients from this requirement, the Department seeks to cut down
on administrative burdens. The Department invites comment on whether
this approach strikes the appropriate balance between achievement of
this rulemaking's policy objectives and avoidance of undue burden on
the health care industry.
Section 88.4(c) also contains several important exceptions from the
proposed requirements for written assurance and certification of
compliance, including: (1) Physicians, physician offices, and other
health care practitioners participating in Part B of the Medicare
program; (2) recipients of Federal financial assistance or other
Federal funds from the Department awarded under certain grant programs
currently administered by the Administration for Children and Families,
whose purpose is unrelated to health care provision as specified; (3)
recipients of Federal financial assistance or other Federal funds from
the Department awarded under certain grant programs currently
administered by the Administration on Community Living, whose purpose
is unrelated to health care provision as specified; and (4) Indian
Tribes and Tribal Organizations when contracting with the Indian Health
Service under the Indian Self-Determination and Education Assistance
Act.
Requiring the large number of entities in these four categories to
submit assurance and certification requirements would pose significant
implementation hurdles for Departmental components, programs, and
services. Furthermore, the Department believes that, due primarily to
their generally smaller size, several of the excepted categories of
recipients of Federal financial assistance or other Federal funds from
the Department are less likely to encounter the types of issues sought
to be addressed in this regulation. For example, State Medicaid
programs are already responsible for ensuring the compliance of their
sub-recipients as part of ensuring that the State Medicaid program is
operated consistently with applicable nondiscrimination provisions.
Similarly, certain programs currently administered by the
Administration for Children and Families and the Administration on
Community Living involve the provision of grants to States and other
governments, or cash assistance or vouchers rather than direct
services, and they are not likely to involve medical research, the
participation of health care providers, or referral to health care
providers.
Excepted providers, however, may become subject to the assurance
and certification requirement if they receive Federal financial
assistance or Federal funds from the Department through a mechanism or
in a manner not excepted by this section. For example, a physician
office participating in Medicare Part B may become subject to the
written certification requirement by receiving Department funds to
conduct clinical research. And it is important to emphasize that no
exemption from the requirements of this regulation regarding notice,
assurances, or certifications relieves the Department, recipients, or
sub-recipients, and State and local governments, of their obligations
to comply with these longstanding Federal health care conscience laws.
The Department seeks public comment on whether further exceptions
should be made to the requirements of Sec. 88.4 in contexts where the
requirements would be unduly burdensome or in contexts unrelated to
health care or medical research.
Proposed Section 88.5 Notice Requirement
The proposed rule adds a ``Notice'' section that was not contained
in the 2008 Rule. This section requires the Department and recipients
to notify the public, patients, and employees, which may include
students or applicants for employment or training, of their protections
under the Federal health care conscience and associated anti-
discrimination statutes and this regulation.
For consistency with other notice requirements in civil rights
regulations, paragraph (a) of Sec. 88.5 proposes to require the
Department and recipients to post the notice in Appendix A within 90
days of the effective date of this part. This notice advises persons
and entities about their rights and the Department's and recipients'
obligations under Federal health care conscience and associated anti-
discrimination laws. The notice provides information about how to file
a complaint with OCR. We seek comment on whether there are categories
of recipients that should be exempted from this requirement to post
such notices.
The proposed rule requires all Department components and recipients
to use the notice text in Appendix A. This approach maximizes
efficiency and economies of scale by enabling recipients to leverage
the text of an HHS-authored notice. We invite comment on whether the
proposed rule should permit recipients to draft their own notices for
which the content meets certain criteria and does not compromise the
intent of Sec. 88.5.
Proposed paragraph (b) sets forth two categories of locations where
the notice must appear: On the Department's and recipient's website(s),
and in a physical location of each Department and recipient
establishment where notices to the public and notices to their
workforce are customarily posted. With regard to the physical posting,
paragraph (b)(2) imposes readability requirements without identifying
prescriptive font-size or other display requirements. The proposed
readability specifications advance the goal for the notice content to
appear sufficiently conspicuous and visible that persons observing it
could reasonably be expected to see and be able to read the
information.
Proposed paragraph (c) incentivizes recipients to display the
notice in locations other than their websites and physical
establishments. In the event that the OCR Director, pursuant to the
proposed enforcement authority in section 88.7 of this part,
investigates or initiates a compliance review of a recipient, the OCR
Director will consider as one of many factors in compliance whether the
recipient posted the notice in the documents described in paragraphs
(c)(1)-(3), as applicable. Because this part regulates a diverse range
of recipients, we identified three categories of documents most common
across all recipients. We seek comment on the proposed approach of
paragraph (c) and on the categories of documents identified in
paragraphs (c)(1)-(3).
Finally, we recognize that recipients may be subject to other
notice requirements under Federal and State law. Paragraph (d) of Sec.
88.5 proposes to permit recipients to combine the text of the notice
required in paragraph (a) with other notices under the condition that
the recipient retains all of the language provided in Appendix A of
this part in an unaltered state. Instead of regulating the manner of
compliance, we considered permitting recipients to
[[Page 3898]]
integrate and revise the text of the notice required in paragraph (a)
with other notices. Although this approach permits greater flexibility,
it invites potential unintentional misrepresentation of Federal health
care conscience and associated anti-discrimination rights. We request
comment on whether paragraph (d) strikes the best balance based on
recipients' experiences.
Proposed Section 88.6 Compliance Requirements
This section identifies specific requirements for compliance with
the Federal health care conscience and associated anti-discrimination
laws. Recipients and other agency components must maintain records
evidencing compliance with these laws and the proposed regulation and
are required to cooperate with OCR in the enforcement process. If a
recipient or sub-recipient is subject to an OCR compliance review,
investigation, or complaint filed with OCR regarding the recipient's or
sub-recipient's compliance with Federal health care conscience and
associated anti-discrimination laws, the recipient or sub-recipient
must inform any Departmental funding component of such review,
investigation, or complaint. The recipient or sub-recipient must also,
in any application for new or renewed Federal financial assistance or
Departmental funding, disclose the existence of such compliance review
or investigation, and must also report on such applications the
existence of any complaints filed with OCR if a complaint had been
filed in the previous five years before the recipient's or sub-
recipient's application. This section also addresses claims in the
event a covered entity intimidates or retaliates against those who
complain to OCR or participate in or assist in an OCR enforcement
action.
Proposed Section 88.7 Enforcement Authority
This section reaffirms the delegation to OCR of the Department's
authority to enforce the Federal health care conscience laws, in
collaboration with the relevant Department components. OCR has been
expressly delegated the authority to enforce the Church, Coats-Snowe,
and Weldon Amendments since the 2008 Rule. Enforcement of section 1553
is expressly delegated to OCR in the ACA. Each of the Federal health
care conscience laws, by virtue of Congressional enactment, requires
compliance by the Department and covered entities. This NPRM provides
notice that the Secretary has delegated to OCR the authority to enforce
all Federal health care conscience and associated anti-discrimination
laws that are the subject of the proposed rule. This section also
includes retaliation claims in the event a covered entity takes any
such retaliatory actions against those who participate in or assist an
OCR enforcement action.
This section also specifies that OCR's enforcement authority
includes the authority to handle complaints, perform compliance
reviews, investigate, and seek appropriate action (in coordination with
the leadership of any relevant HHS component) that the Director deems
necessary to remedy the violation of Federal health care conscience and
associated anti-discrimination laws and the proposed regulation, as
allowed by law. The current text of Sec. 88.7 of this part grants OCR
discretion in choosing the means of enforcement, from informal
resolution to more rigorous enforcement leading to, for example,
funding termination, as appropriate to the particular facts, law, and
availability of resources. The Director may, in coordination with a
relevant Department component, restrict funds for noncompliant entities
in whole or in part, including by limiting funds to certain programs
and particular covered entities, or by restricting a broader range of
funds or broader categories of covered entities, as allowed by law to
effectuate the Federal health care conscience laws. In addition to
withdrawal of funding, possible corrective actions include settlements
or voluntary resolution agreements where allowed. OCR can also refer
cases to the Department of Justice for additional enforcement, and in
coordination with the relevant Department component.
The proposed rule would also make explicit the Department's
authority to investigate and handle violations and conduct compliance
reviews whether or not a formal complaint has been filed. That language
is consistent with OCR's enforcement practices under other civil rights
laws, and with the Department's obligation to enforce Federal health
care conscience and associated anti-discrimination laws. Under the
proposed rule, OCR would also be explicitly authorized to investigate
``whistleblower'' complaints, or complaints made on behalf of others,
whether or not the particular complainant is a person or entity
protected by conscience and associated antidiscrimination laws.
This section adopts the enforcement procedures for other civil
rights laws, such as Title VI and Section 504 of the Rehabilitation
Act. See, e.g., 45 CFR 80.8 through 80.10 and 84.7. If the Department
becomes aware that a State or local government or an entity may have
undertaken activities in violation of statutory conscience and
associated antidiscrimination laws, the Department will work with such
government or entity to provide assistance and guidance to recipients
to help them comply voluntarily with the law and this part. For
compliance, recommended best practices (as identified in the
Department's other civil rights regulations) include such procedures
as: (1) The designation of at least one employee responsible for
compliance, (2) the adoption of internal grievance procedures to
provide for prompt and equitable resolution of complaints, and (3) the
preparation of internal compliance reports by recipients, sub-
recipients, participants, and beneficiaries.
If, despite the Department's assistance, compliance is not
achieved, the Department will consider all legal options, up to and
including termination of funding and return of funds, as applicable.
Remedial measures include the temporary withholding of cash payments in
whole or part, pending correction of the deficiency, the denial of
funds and any applicable matching credit in whole or in part, the
suspension or termination of the Federal award in whole or in part, the
withholding of new Federal financial assistance or other Federal funds
from the Department, referral of the matter to the Attorney General for
enforcement proceedings, and any other remedies that may be legally
available.
The Department solicits comments on what administrative procedures
or opportunities for due process the Department should, as a matter of
policy, or must, as a matter of law, provide, (1) with respect to the
remedial and enforcement measures that the Department may consider
imposing or utilizing in response to a failure or threatened failure to
comply with Federal health care conscience and associated
antidiscrimination laws or this part, (2) before the Department may
terminate Federal financial assistance or other Federal funds from the
Department, or (3) before the Department may implement any or all of
the remedial measures identified in Sec. 88.7(j)(3) of the proposed
rule. For example, comment is requested on whether the proposed rule
should establish notice, hearing, and appeal procedures similar to
those established in the Department's regulations implementing Title VI
of the Civil Rights Act of 1964, at 45 CFR 80.8-80.10. We also request
comment on whether and in what circumstances it is
[[Page 3899]]
appropriate to require remedies against a recipient for the violations
of a sub-recipient, or against entities whose subsidiaries are found to
be in violation of any Federal health care conscience and associated
antidiscrimination law or the proposed regulation.
Proposed Section 88.8 Relationship to Other Laws
This section clarifies the relationship between this part and other
Federal, State, and local laws that protect religious freedom and moral
convictions. Many State laws provide additional conscience protections
for providers who have objections to abortion, fertility treatments,
sterilization, capital punishment, assisted suicide, and
euthanasia.\47\ The Department proposes to uphold the maximum
protection for the rights of conscience and the broadest prohibition on
discrimination provided by Federal, State, or local law, as consistent
with the Constitution. Where a State or local law provides as much or
greater protection than Federal law for religious freedom and moral
convictions, the Department will not construe Federal law to preempt or
impair the application of that law, unless expressly provided.
---------------------------------------------------------------------------
\47\ See, e.g., Ala. Code 15-18-82.1(i) (2017); Alaska Stat.
18.16.010(b), 13.52.060(e) (2017); Ariz. Rev. Stat. Ann. 20-826(Z),
20-1057.08(B), 20-1402(M), 20-1404(V), 20-2329(B), 20-2329(C), 36-
3205(C)(1), 36-2154 (2017); Ark. Code Ann. 20-13-1403(b), 20-16-
304(4)-(5), 20-16-601, 23-79-1103(b), 23-79-1104(b)(3) (2017); Cal.
Prob. Code 4734 (West 2017); Cal. Penal Code 3605(c) (West 2017);
Cal. Bus. & Prof. Code 733(b)(3) (West 2017); Cal. Health & Safety
Code 443.14(b), (e), 443.15, 1367.25(c), 1374.55(e)-(f), 123420
(West 2017); Cal. Ins. Code 10119.6(d)-(e), 10123.196(e) (West
2017); Colo. Rev. Stat. 25-6-102(9), 25-6-207, 25-3-110(3) (2017);
Conn. Gen. Stat. 38a-503e(b), (e), 38a-536(c), 38a-509(c), 38a-
530e(b), (e), (2017); Del. Code Ann. tit. 24, 1791, tit. 18, Sec.
3559(d) (2017); Fla. Stat. 381.0051(5), 390.0111(8), 409.973(1)(h),
765.1105, 922.105(9) (2017); Ga. Code Ann. 16-12-142, 17-10-38(d),
31-20-6, 49-7-6 (2017); Haw. Rev. Stat. 431:10A-116.7, 453-16(e),
327E-7(e) (2017); Idaho Code Ann. 18-611, 18-612, 39-3915 (2017);
745 Ill. Comp. Stat. 70/1-70/14 (2017); 215 Ill. Comp. Stat. Sec.
5/356m(b)(2) (2017); 720 Ill. Comp. Stat. Sec. 510/13 (2017); 745
Ill. Comp. Stat. Sec. 30/1 (2017); Ind. Code 16-34-1-3 to -7
(2017); Iowa Code 146.1-.2 (2017); Kan. Stat. Ann. 65-443, -444, 65-
446, -447, 65-1637(n), 65-6737 (2017); Ky. Rev. Stat. Ann. Sec.
311.800(3)-(5) (West 2017); La. Rev. Stat. Ann. 15:569(C),
15:570(C), 40:1061.2-.3, 40:1061.4(C), 40:1061.20 (2017); Me. Rev.
Stat. tit. 18-A, 5-807(e), tit. 32, 13795(2-3), tit. 22, 1591-1592,
1903(4), tit. 24, 2332-J(2), tit. 24-A, 2756(2), 2847-G(2), 4247(2),
tit. 34-B, Sec. 7016 (2017); Md. Code Ann., Health-Gen. 20-214
(West 2017); Md. Code Ann., Ins. 15-810(i), 15-826(c) (West 2017);
Mass. Gen. Laws ch. 112, 12I, ch. 272, 21B, ch. 175, 47W(f), ch.
176A, 8W(f), ch. 176B, 4W(f), ch. 176G, 4O(c) (2017); Mich. Comp.
Laws Serv. 333.20181 to 333.20184 (2017); Minn. Stat. 145.414,
145.42, 145.925(6) (2017); Miss. Code Ann. 41-41-215(5), 41-107-5 to
-9 (2017); Mo. Rev. Stat. 188.105-.110, 191.724, 197.032, 338.255
(2017); Mont. Code Ann. Sec. 50-20-111, 50-5-502 to -505 (2017);
Neb. Rev. Stat. 28-337 to -341 (2017); Nev. Rev. Stat. 449.191,
632.475, 689A.0415(5), 689A.0417(5), 689B.0376(5), 689B.0377(5),
695B.1916(5), 695B.1918(5), 695C.1694(5), 695C.1695(5) (2017); N.J.
Stat. Ann. 2A:65A-1, to -3, 17B:27-46.1x(b), 17:48A-7w(b), 17:48-
6x(b), 17:48E-35.22(b), 26:2J-4.23(b), 17:48-6ee, 17:48A-7bb,
17:48E-35.29, 17B:27-46.1ee, 17B:26-2.1y, 26:2J-4.30, 17B:27A-19.15,
17:48F-13.2, 17B:27A-7.12 (West 2017); N.M. Stat. Ann. 24-8-6(A)(2),
24-7A-7(E), 30-5-2, 59A-22-42(D), 59A-46-44(C) (2017); N.Y. Civ.
Rights Law Sec. 79-i (McKinney 2017); N.Y. Ins. Law 3221(l)(16)(A),
4303(cc)(1) (McKinney 2017); N.C. Gen. Stat. Sec. 14-45.1(e)-(f),
58-3-178(e) (2017); N.D. Cent. Code Sec. 23-16-14 (2017); Ohio Rev.
Code Ann. Sec. 4731.91 (West 2017); Okla. Stat. tit. 63, 1-568, 1-
728c to -728f, 1-741 (2017); Or. Rev. Stat. 127.625, 127.885,
435.225, 435.475, 435.485 (2017); 43 Pa. Cons. Stat. 955.2 (2017);
18 Pa. Cons. Stat. 3213(d) (2017); R.I. Gen. Laws 23-17-11, 27-18-
57, 27-19-48, 27-20-43, 27-41-59 (2017); S.C. Code Ann. 44-41-40,
44-41-50 (2017); S.D. Codified Laws 34-23A-11 to -14, 36-11-70
(2017); Tenn. Code Ann. 39-15-204 to -205, 68-34-104(5) (2017); Tex.
Ins. Code Ann. 1271.007, 1366.006, 1369.108 (West 2017); Tex. Occ.
Code Ann. 103.001-.004 (West 2017); Utah Code Ann. sec. 76-7-306
(West 2017); Vt. Stat. Ann. tit. 18, 5285-5286 (2017); Va. Code Ann.
sec. 32.1-134, 18.2-75, 54.1-2957.21 (2017); Wash. Rev. Code Ann.
9.02.150, 48.43.065(2), 70.47.160(2), 70.245.190 (2017); W. Va. Code
16-2B-4, 16-11-1, 16-30-12 (2017); Wis. Stat. 253.07(3)(b), 253.09,
441.06(6), 448.03(5)(A) (2017); Wyo. Stat. Ann. 42-5-101(d)-102, 35-
6-105 to-106 (2017).
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This section is new to this proposed rule with no analog in the
2008 Rule.
The proposed rule does not relieve OCR of its obligation to enforce
other civil rights authorities, such as Title VI of the Civil Rights
Act of 1964, Title IX of the Education Amendments of 1972, the Age
Discrimination Act of 1975, Section 504 of the Rehabilitation Act of
1973, and the Americans with Disabilities Act of 1990. OCR will enforce
all civil rights laws consistent with the Constitution and the
statutory language.
Proposed Section 88.9 Rule of Construction
This section ensures that the protections for religious freedom and
moral conviction provided by this part shall be construed broadly and
to the maximum extent permitted by law and the Constitution.
Proposed Section 88.10 Severability
This section is a ``severability clause'' for the proposed
regulation that provides that, if any provision or part of a provision
of the proposed regulation is held to be invalid or unenforceable,
either facially or as applied, the provision in question will be
construed in a manner that allows it to remain in force to the maximum
extent permitted by law. Furthermore, if a provision of the proposed
regulation is held to be invalid or unenforceable, that provision is
severable from the rest of the proposed regulation, which remains in
full force and effect to the maximum extent permitted by law. A severed
provision shall not affect the remainder of the proposed regulation,
and where possible the severed provision remains in effect as applied
to other persons or situations not similarly situated, or to other
dissimilar circumstances.
IX. Request for Comment
In addition to the requests for comments mentioned elsewhere in
this notice of proposed rulemaking, the Department, in order to draft
its final rule to best reflect the experiences and concerns of those
most impacted, seeks comment on this Proposed Rule. In particular, the
Department seeks the following:
Comment on all issues raised by the proposed regulation.
Information, including any facts, surveys, audits, or
reports, about the occurrence or nature of coercion, discriminatory
conduct, or other violations of the Federal health care conscience and
associated anti-discrimination laws.
Information, including any facts, surveys, audits, or
reports, with regard to the general knowledge, or lack thereof, of the
protections established by the Federal health care conscience and
associated anti-discrimination provisions among the general public, as
well as within the health care field, health care insurance industry,
and employment law field.
Information, including any facts, surveys, audits, or
reports, on whether public authorities continue to claim that the
receipt of Federal funds is a sufficient basis for entities to be
required to participate in abortions or sterilizations. If so, comment
on how the Department should address this problem.
Information, including any facts, surveys, audits, or
reports, about whether parents or legal guardians are discriminated
against based on objections to testing or treatment of their minor
children.
Information, including any facts, surveys, audits, or
reports, about whether individuals or entities have been coerced or
discriminated against based on their religious or moral objection to
counseling or referral.
Information, including any facts, surveys, audits, or
reports, about whether health care insurers, health plan sponsors, and
health plan participants have religious or moral objections to certain
health insurance coverage.
Information, including any facts, surveys, audits, or
reports, about whether applicants for Federal financial assistance from
the Department, who
[[Page 3900]]
would otherwise been eligible for such assistance, have been
discriminated against based on their religious or moral objections.
Information, including any facts, surveys, audits, or
reports, about whether individuals did not enter a health care field or
a certain specialty because of concerns that their conscientious
objections would not be accommodated.
Information, including any facts, surveys, audits, or
reports, about whether certain populations in the health care field,
such as students or nurses, face or are vulnerable to discrimination in
violation of the Federal health care conscience and associated anti-
discrimination laws, and how outreach and enforcement might be tailored
to respond to those needs.
Information, including any facts, surveys, audits, or
reports, about the occurrence of coercion or discrimination against
health care practitioners or professionals related to the
implementation of advance directives.
Information, including any facts, surveys, audits, or
reports, about coercion or discrimination against religious nonmedical
health care institutions and their patients.
Information, including any facts, surveys, audits, or
reports, about whether the existence or expansion of rights to exercise
religious beliefs or moral convictions in health care improves or
worsens patient outcomes and access to health care.
Comment on whether particular circumstances might exist
that present a higher risk of undetected unlawful discrimination, such
as the medical residency application process, and how the rule might
address such problems.
Comment on whether the voicing of health care conscience
and associated anti-discrimination objections protected by Federal law
is chilled by State laws, State agency action, lack of perceived
remedies, threat of litigation, or threat of losing legal status, such
as a medical license.
Comment on whether the definition of ``individual'' in
relation to ``workforce'' artificially circumscribes the scope of
protections afforded by the Church Amendments that protect individuals
and individual rights.
Comment on whether the definition of ``recipient''
appropriately defines the scope of entities that should be subject to
the rule's requirements regarding notice and assurances or
certifications, including whether those requirements should be extended
to sub-recipients.
Comment on whether the definition of ``referral or refer
for'' appropriately defines the scope of activities that should be
encompassed by the rule's protections.
Comment on whether the definition of ``assist in the
performance'' appropriately defines the scope of activities that should
be encompassed by the rule's protections.
Comment on whether written certifications of compliance
with nondiscrimination laws should contain additional language.
Comment on the appropriateness of exceptions to the
certification requirements.
Comment on what constitutes the most effective method of
educating recipients of Department funds and their employees about the
protections of the Federal health care conscience and associated anti-
discrimination laws.
Comment on what constitutes the most effective method for
recipients of Department funds to provide notice about the requirements
and prohibitions in the Federal health care conscience and associated
anti-discrimination laws to employees, students, applicants, and sub-
recipients.
Comment on whether State or local government laws,
policies, or enforcement activities conflict with or make it difficult
to ensure compliance with Federal health care conscience and associated
anti-discrimination laws.
Comment on whether policies and practices at covered
entities appear to conflict with the health care conscience and
associated anti-discrimination laws or make it difficult to ensure
compliance with those laws.
Comment on whether the rule provides adequate clarity
regarding the respective obligations of recipients and sub-recipients,
and regarding the potential consequences of noncompliance with those
obligations.
Comment on whether the exemptions in section 88.4(c) for
certain grant programs currently administered by the Administration for
Children and Families and the Administration for Community Living are
meaningful given the requirement that the grant program involve no
significant likelihood of referral for the provision of health care.
Comment on whether, and how, the proposed rule should
address the scheduled elimination of the penalty under the Patient
Protection and Affordable Care Act for an individual's failure to carry
minimum essential health coverage.
Comment on whether alternate remedies, such as lawsuits,
have been sufficient to protect individuals and entities from
discrimination, coercion, or other treatment prohibited by the health
care conscience and associated anti-discrimination laws.
Comment on whether any provisions in the proposed rule
would result in an unjustified limitation on access to health care or
treatments.
Comment on which enforcement tools OCR, as a policy
matter, ought to employ, such as compliance reviews, investigations,
and alternate disbursal of funds.
Comment on whether the proposed rule avoids ``tribal
implications'' and does not ``impose substantial direct compliance
costs on Indian tribal governments'' as stated in Executive Order
13175, Consultation and Coordination with Indian Tribal Governments,
sec. 5(b) (Nov. 9, 2000), and whether the rule clearly and
appropriately addresses its application to Federal funds that are
contracted or compacted out to tribal nations.
Comment on whether Urban Indian organizations, as defined
by 25 U.S.C. 1603(29), operating a Title V Urban Indian Health Program
that currently has a grant or contract with the IHS under Title V of
the Indian Health Care Improvement Act, (Pub. L. 93-437), should be
exempted from the proposed rule's requirements regarding assurances and
certifications of compliance.
Comment on whether the proposed rule should apply to
Tribes, which are recipients of Federal financial assistance through
compact agreements or are awarded Federal contracts. Furthermore, the
Department requests comment on exemptions for any Indian Tribes under
the notice and certification requirements. Additionally, the Department
solicits comment on the rule's impact on Tribal sovereignty.
Comment on whether the notice text provided in Appendix A
to this rule strikes the appropriate balance between, on the one hand,
affirming rights of conscience in a simple and reader-friendly manner,
in general terms suitable for use by all recipients; and on the other,
reflecting the complexities and variations in the application of
Federal health care conscience and associated anti-discrimination laws
to different covered entities and protected parties in different
contexts.
Consistent with the Paperwork Reduction Act, comments
regarding the burden of the requirement for covered entities to report
if they are the subject of an OCR investigation the Department in any
requests for new or renewed Federal financial assistance or Federal
funds in the five years subsequent to the filing of the relevant OCR
complaint.
Consistent with the Paperwork Reduction Act, comments
regarding the
[[Page 3901]]
burden and cost estimates, or regarding any other aspect of the
collection of information proposed in this rule as discussed below.
X. Public Participation
Because of the large number of public comments we normally receive
on Federal Register documents, we are not able to acknowledge or
respond to them individually. We will consider all comments that are
received by the date and time specified in the DATES section of the
Preamble.
Written comments mailed or hand delivered must include one original
and two copies. Mailed comments may be subject to security delays due
to security procedures. Please allow sufficient time for mailed
comments to be timely received in the event of delivery delays. Because
access to the interior of the Hubert H. Humphrey Building is not
readily available to persons without Federal government identification,
commenters are encouraged to leave their comments in the mail drop
slots located in the lobby of the building. Electronic comments with
attachments should be in Microsoft Word or Excel; however, we prefer
Microsoft Word. Please note that comments submitted by fax or email and
those submitted after the comment period will not be accepted.
XI. Delegations of Authority
Notice is hereby given that I have delegated to the Director of the
Office for Civil Rights (OCR), with authority to redelegate, the
authority to enforce the following Federal health care conscience and
associated anti-discrimination laws:
Conscience protections related to abortion, sterilization,
and other lawful health services among recipients of funds and
participants in programs, and their personnel, where funded by the
Department (the Church Amendments, 42 U.S.C. 300a-7);
Conscience protections for health care entities related to
abortion, training, or accreditation (the Coats-Snowe Amendment,
section 245 of the Public Health Service Act, 42 U.S.C. 238n);
Provisions protecting health care entities and individuals
that do not act to further abortion or other practices from
discrimination by recipients of funding under the Department's annual
appropriations acts (e.g., Consolidated Appropriations Act, 2017, Pub.
L. 115-31, Div. H, sec. 507(d) (the Weldon Amendment); Div. H, sec.
209);
Patient Protection and Affordable Care Act protections
related to assisted suicide (42 U.S.C. 18113), the requirement to issue
certifications of exemption from the individual mandate with respect to
membership in exempt religious sects or divisions or health care
sharing ministries (26 U.S.C. 5000A(d)(2)), and the conscience
provisions with respect to abortion (42 U.S.C. 18023(c)(2)(A),
(b)(1)(A), and (b)(4));
Protections for objections to counseling and referral for
certain services in Medicaid or Medicare Advantage (42 U.S.C. 1395w-
22(j)(3)(B) and 1396u-2(b)(3)(B));
Protections related to the performance of advanced
directives in Medicare and Medicaid (42 U.S.C. 1395cc(f), 1396a(w)(3),
and 14406);
Protections related to Global Health Programs to the
extent administered by the Secretary (22 U.S.C. 7631(d); Consolidated
Appropriations Act, 2017, Pub. L. 115-31, Div. J, sec. 7018 (Helms
Amendment));
Exemptions from compulsory health care or services
generally (42 U.S.C. 1396f & 5106i(a)(1)), and under specific programs
for hearing screening (42 U.S.C. 280g-1(d)), occupational illness
testing (29 U.S.C. 669(a)(5)); vaccination (42 U.S.C.
1396s(c)(2)(B)(ii)), and mental health treatment (42 U.S.C. 290bb-
36(f)); and
Protections for religious nonmedical care in the Medicare,
Medicaid, and CHIP programs (42 U.S.C. 1320a-1; 1320c-11; 1395i-5;
1395x(e); 1395x(y)(1); 1396a(a); 1396b(i)(4); 1397j-1(b); and
5106i(a)(2)).
Pursuant to these delegations, the OCR Director shall have the
authority:
To receive and handle complaints of discrimination or any other
potential violation of the Federal health care conscience and
associated anti-discrimination laws and/or these regulations at 45 CFR
part 88 by recipients, sub-recipients, or Department components;
To initiate and conduct compliance reviews and investigate
incidents of discrimination or any other potential violation of the
Federal health care conscience and associated anti-discrimination laws
and/or these regulations by recipients, sub-recipients, or Department
components;
To supervise and coordinate OCR's investigations or compliance
reviews with the relevant Department components;
To delegate responsibilities to other officials of the Department
in connection with the effectuation of Federal health care conscience
and associated anti-discrimination laws and these regulations,
including the achievement of effective coordination and maximum
uniformity within the Department; and
To take remedial action as the Director of OCR deems necessary and
as allowed by law to overcome the effects of violations of Federal
health care conscience and associated anti-discrimination laws and this
part, in coordination with the relevant component or components of the
Department.
If there appears to be a failure or threatened failure to comply
with Federal health care conscience and associated anti-discrimination
laws or this part, compliance with these laws and this part may be
effected by the following actions, taken in coordination with the
funding component:
Temporarily withholding cash payments, in whole or in part, pending
correction of the deficiency;
Denying use of Federal financial assistance or other Federal funds
from the Department, including any applicable matching credit, in whole
or in part;
Wholly or partly suspending award activities;
Terminating Federal financial assistance or other Federal funds
from the Department, in whole or in part;
Withholding new Federal financial assistance or other Federal funds
from the Department, in whole or in part, administered by or through
the Secretary for which an application or approval is required,
including renewal or continuation of existing programs or activities or
authorization of new activities;
Referring the matter to the Attorney General for proceedings to
enforce any rights of the United States, or obligations of the
recipient or sub-recipient, created by Federal law; and
Taking any other remedies that may be legally available.
This delegation is effective upon signature. I hereby affirm and
ratify any actions taken by the OCR Director or the Director's
subordinates which involved the exercise of the authorities delegated
herein from April 1, 2017, to the effective date of this delegation.
XII. Regulatory Impact Analysis
A. Introduction and Summary
The Department has examined the impacts of the proposed rule as
required under Executive Order 12866 on Regulatory Planning and Review
(September 30, 1993), Executive Order 13563 on Improving Regulation and
Regulatory Review (January 18, 2011), Executive Order 13771 on Reducing
Regulation and Controlling Regulatory Costs (January 30, 2017), the
Regulatory
[[Page 3902]]
Flexibility Act (September 19, 1980, Pub. L. 96-354, 5 U.S.C. 601-612),
section 202 of the Unfunded Mandates Reform Act of 1995 (March 22,
1995, Pub. L. 104-04), Executive Order 13132 on Federalism (August 4,
1999), the Congressional Review Act (5 U.S.C. 804(2)), the Assessment
of Federal Regulation and Policies on Families (Pub. L. 105-277,
section 654, 5 U.S.C. 601 (note)), and the Paperwork Reduction Act of
1995 (44 U.S.C. 3501-3520).
This rule proposes to revise the regulation that allows OCR to
accept and coordinate the handling of complaints alleging violations of
the Weldon, Church, and Coats-Snowe Amendments that collectively
protect conscience, prohibit coercion, and require nondiscrimination in
certain programs and activities operated by recipients or sub-
recipients or that are administered by the Secretary. Specifically, the
proposed rule:
(1) Aligns the regulation's scope to comport with the full panoply
of Federal health care conscience and associated anti-discrimination
laws that exist across the Department and that the Secretary has
delegated to OCR to enforce,
(2) Expands the scope of enforcement mechanisms available to OCR to
be consistent with mechanisms used by OCR to enforce similar civil
rights laws, as appropriate,
(3) Requires certain persons and entities covered by this proposed
rule to adhere to certain procedural and administrative requirements
that aim to elevate awareness of Federal health care conscience and
associated anti-discrimination rights and certain obligations of
persons and entities.
Table 1--Accounting Table of Benefits and Costs of All Proposed Changes
----------------------------------------------------------------------------------------------------------------
Present value over 5 years by Annualized value over 5 years
discount rate (millions of by discount rate (millions of
2016 dollars) 2016 dollars)
---------------------------------------------------------------
3 Percent 7 Percent 3 Percent 7 Percent
----------------------------------------------------------------------------------------------------------------
Benefits:
Quantified Benefits......................... .............. .............. .............. ..............
----------------------------------------------------------------------------------------------------------------
Non-quantified Benefits: Balance of personal freedom and moral commitment; more diverse and inclusive
workforces; improved provider patient relationships; equity, fairness, nondiscrimination.
----------------------------------------------------------------------------------------------------------------
Costs:
Quantified Costs............................ 692.1 562.7 165.1 168.1
----------------------------------------------------------------------------------------------------------------
Non-quantified Costs: Any ancillary costs resulting from a protection of conscience rights......................
----------------------------------------------------------------------------------------------------------------
The Department estimates that the benefits of this rule, although
not quantifiable or monetized, justify the burdens of the regulatory
action. The Department estimates that implementation of this rule will,
on average, cost $312.3 million in year one and $125.5 million annually
in years two through five. Considering the number of entities affected
and excluding the costs to OCR, this rule is estimated to cost each
affected person, entity, and health care entity, on average, $665 in
year one, which drops by 60% to about $266 annually in years two
through five.
Analysis of Economic Impacts: Executive Orders 12866 and 13563
HHS has examined the economic implications of this proposed rule as
required by Executive Orders 12866 and 13563. Executive Orders 12866
and 13563 direct agencies to assess all costs and benefits of available
regulatory alternatives and, when regulation is necessary, to select
regulatory approaches that maximize net benefits (including potential
economic, environmental, public health and safety effects; distributive
impacts; and equity).
B. Executive Order 12866
Section 6(3)(C) of Executive Order 12866 requires agencies to
prepare a regulatory impact analysis (RIA) for major rules that are
significant. Section 3(f) of Executive Order 12866 defines a regulatory
action as significant if it is likely to result in a rule that meets
one of four conditions: (1) Is economically significant, (2) creates a
serious inconsistency or otherwise interferes with an action taken or
planned by another agency, (3) materially alters the budgetary impacts
of entitlement grants, user fees, or loan programs or the rights and
obligations of the recipients of these grants and programs, or (4)
raises novel legal or policy issues arising out of legal mandates, the
President's priorities, or the principles set forth in Executive Order
12866. A rule is likely to be economically significant where the agency
estimates that it will (a) have an annual effect on the economy of $100
million or more in any one year, or (b) adversely and materially affect
the economy, a sector of the economy, productivity, competition, jobs,
the environment, public health or safety, or State, local or tribal
governments or communities. The Department has determined that this
rule will have an annual effect on the economy of $100 million or more
in one year and, thus, is economically significant.
C. Executive Order 13563
Executive Order 13563 supplements and reaffirms the principles of
Executive Order 12866. Section 1(b) of Executive Order 13563 requires
agencies to:
``propose or adopt a regulation only upon a reasoned
determination that its benefits justify its costs,''
``tailor its regulations to impose the least burden on
society,''
``select . . . regulatory approaches that maximize net
benefits,''
``[as] feasible, specify performance objectives, rather
than specifying the behavior or manner of compliance that regulated
entities must adopt,'' and
``identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior . . . or providing information upon which the public
can make choices.''
Executive Order 13563 encourages agencies to promote innovation;
avoid creating redundant, inconsistent, or overlapping requirements
applicable to already highly-regulated industries and sectors; and
consider approaches that maintain flexibility and freedom of choice for
the public.
[[Page 3903]]
Finally, Executive Order 13563 requires that agencies use the best
reasonably obtainable scientific, technical and economic information
available in evaluating the burdens and benefits of a regulatory
action.
As discussed throughout this impact analysis, the Department
considered these objectives in its analyses of this proposed rule. In
doing so, the Department used the best reasonably obtainable technical
and economic information to determine that this proposed rule: Creates
net benefits, is tailored to impose the least burden on society,
incentivizes the desired behavior, and maximizes flexibility. This
impact analysis also strives to promote transparency in how the
Department derived the estimates. To this end, this RIA notes the
extent to which key uncertainties in the data and assumptions affect
the Department's analytic conclusions.
1. Need for the Proposed Rule
(i) Problems That the Proposed Rule Seeks To Address
In developing regulatory actions, ``[e]ach agency shall identify
the problem that it intends to address (including . . . the failures of
private markets or public institutions . . .) as well as assess the
significance of the problem.'' E.O. 12866, sec. 1(b)(1). In identifying
the problem warranting agency regulatory action, ``[e]ach agency shall
examine whether existing regulations (or other law) have created, or
contributed to, the problem . . .'' E.O. 12866, sec. 1(b)(2).
This proposed rule seeks to address two categories of problems: (1)
Inadequate enforcement tools to address discrimination and coercion
associated with conscience objections by persons, entities, or health
care entities, and (2) intolerance for certain Federal health care
conscience and associated anti-discrimination rights, in part due to
confusion about the law, leading to possible violations of law and
increased complaints. The array of issues described supra in Parts IV
(The Original Version and Current Version of the Rule) and Part VI
(Reasons for the Proposed Rule) fall into one or both of these two
overarching categories.
Protection of religious beliefs and moral convictions not only
serves individual rights, it serves society as a whole. Protections for
conscience help ensure a society free from discrimination and more
respectful of personal freedom. Although the boundaries of protection
for conscience may be tested when that protection appears to impede
other public goods, it is in those cases where fidelity to the law
becomes paramount.\48\
---------------------------------------------------------------------------
\48\ See Kevin Theriot & Ken Connelly, Free to Do No Harm:
Conscience Protections for Healthcare Professionals, 49 Ariz. St.
L.J. 549, 550-51 (2017).
---------------------------------------------------------------------------
Despite the longstanding nature of the Federal health care
conscience and associated anti-discrimination laws that this rule
proposes to enforce, discrimination and coercion continue to occur.
Relevant situations where persons, entities, and health care entities
with religious beliefs or moral convictions may be coerced or suffer
discrimination include:
Being asked to perform, participate in, pay for, counsel
or refer for abortion, sterilization, euthanasia, or other health
services;
engaging in health professions training that pressures
students, residents, fellows, etc., to perform, assist in the
performance of, or counsel for abortion;
considering a career in obstetrics, family medicine, or
elder care, when one has a religious or moral objection to abortion,
sterilization, or euthanasia;
raising religious or moral objections to participating in
certain services within the scope of one's employment; and,
being required to administer or receive certain
vaccinations derived from aborted fetal tissues as a condition of work
or receipt of educational services.
Discrimination, coercion, and intolerance for religious beliefs or
moral convictions continue to occur due to (1) the poor functioning of
Federal government frameworks to enforce Federal health care conscience
and associated anti-discrimination laws and (2) inadequate information
and understanding about the obligations of persons and entities and the
rights of persons, entities, and health care entities under these laws.
These deficiencies in Federal governing frameworks include:
An inadequate, minimalistic regulatory scheme at part 88 of 45 CFR
due to the Department's 2011 Rule that rescinded the comprehensive 2008
Rule, see supra Part IV.A-B (describing content of the existing and
prior versions of the rule) and Part VI.C (identifying confusion about
conscience laws' scope and applicability);
An unduly narrow Departmental interpretation of the Weldon
Amendment adopted by OCR in connection with the 2011 Rule that limited
the scope of discrimination contrary to the language that Congress
passed, see supra Part VI.E (addressing confusion caused by OCR sub-
regulatory guidance); and
A lack of strategic coordination across the Department to address
the enforcement of Federal health care conscience and associated anti-
discrimination laws set forth in authorizing statutes of programs that
the Department's components conduct, see supra Part III.F (identifying
additional Federal health care conscience and associated anti-
discrimination laws).
The absence of adequate Federal governing frameworks to remedy
discrimination may have undermined incentives for covered persons and
entities proactively to institute measures to protect conscience,
prohibit coercion, and promote nondiscrimination.
OCR is aware that persons who are unlawfully coerced to violate
their consciences or otherwise discriminated against because they have
acted in accord with their moral convictions or religious beliefs
experience real harm that is significant psychologically, emotionally,
and financially. Such persons claim that their harm amounts to an
actionable violation of the Federal health care conscience and
associated anti-discrimination laws that OCR can remedy through
administrative enforcement.\49\ Indeed, since November of 2016, OCR has
received thirty-four complaints concerning Federal health care
conscience and associated anti-discrimination laws. See supra Part V
(identifying when OCR complaints were received).
---------------------------------------------------------------------------
\49\ As discussed earlier, several courts have declined to
recognize a private right of action for persons protected under
certain Federal health care conscience and associated anti-
discrimination laws. In such cases, persons must rely on OCR for
enforcement.
---------------------------------------------------------------------------
(ii) How the Proposed Rule Seeks To Address Those Problems
This proposed regulatory action corrects those problems. First, the
Department proposes to revise 45 CFR part 88 from a minimal regulatory
scheme to one comparable to the regulatory schemes implementing other
civil rights laws. Such schemes typically include a dozen provisions,
addressing a range of conduct. These provisions typically restate the
substantive requirements and obligations of the laws and often impose
procedural requirements (e.g., assurances of compliance, notices to the
public) to further compliance with those substantive rights and
obligations. In addition, such schemes outline the enforcement
procedures to provide regulated entities notice of the enforcement
tools available to OCR and the type of remedies OCR may seek. Part 88,
by contrast, is currently only three sentences long and therefore
provides
[[Page 3904]]
considerably less notice and clarity about the conduct prohibited under
Federal law and the enforcement mechanisms available to OCR.
Department components, recipients, and sub-recipients must comply
with the Federal laws that are the subject of this proposed rulemaking.
In addition to conducting outreach and providing technical assistance,
OCR would have the authority to initiate compliance reviews, conduct
investigations, and supervise and coordinate appropriate action with
the relevant Department component to assure compliance.
To assist OCR in ensuring compliance with and enforcement of the
Federal health care conscience and associated anti-discrimination laws,
the proposed rule would require certain persons and entities: To
maintain records; cooperate with OCR investigations, reviews,
interviews, or other parts of OCR's enforcement process; submit written
assurances and certifications of compliance to the Department; and
provide notice to persons, entities, and health care entities about
Federal health care conscience and associated anti-discrimination
protections, as applicable. These procedural and administrative
requirements are similar to those in other civil rights regulations and
have a proven record of improving compliance with, and enforcement of,
other Federal civil rights laws. Together, these requirements would
support the Department's renewed effort for strategic coordination with
respect to the compliance and enforcement of the Federal health care
conscience and associated anti-discrimination laws that exist across
the Department.
Second, this proposed rule seeks to promote voluntary compliance
with laws governing the ability of persons, entities, and health care
entities to act in accord with their religious beliefs or moral
convictions by ensuring that persons and entities are aware of and
understand Federal health care conscience and associated anti-
discrimination laws. Persons and entities would be more likely to
accommodate conscience and associated anti-discrimination rights if
persons and entities understand that they are legally obligated to do
so. Persons and entities would also be in a better position to
accommodate these rights if they understand these rights to be akin to
other civil rights to be free from discrimination on the basis of race,
national origin, disability, etc.--rights that recipients and sub-
recipients are already familiar with respecting.
The Department anticipates, as anticipated with the 2008 Rule, that
this proposed rule would promote accommodation of protected persons,
entities, and health care entities. See e.g., 73 FR 78074, 78081 (2008
Rule). Greater transparency of practices through open communication of
recipient and sub-recipient policies ``should strengthen relationships
between patients and providers, as well as those between entities and
their . . . [workforce members].'' Id. at 78074. The Department intends
that OCR's outreach and guidance, investigations, compliance reviews,
and enforcement actions, would provide institutions with an incentive
to review their compliance with Federal health care conscience and
associated anti-discrimination laws, as applicable, resulting in
increased voluntary compliance.
2. Affected Persons and Entities
The proposed rule affects: (1) Persons and entities obligated to
comply with 45 CFR part 88 because they are subject to the Weldon
Amendment, Coats-Snowe Amendment, or Church Amendments (or a
combination thereof); and (2) persons and entities obligated to comply
with at least one of the nearly two dozen Federal laws that this
revision of part 88 proposes to enforce.
(i) Scope of Persons and Entities That 45 CFR Part 88 Covers
This proposed rule affects persons and entities obligated to comply
with the Weldon, Church, and Coats-Snowe Amendments of which 45 CFR
part 88 provides for the enforcement.
Current part 88 extends:
To almost every program and activity administered by the
Secretary;
To all State and local governments that receive Federal
financial assistance as recipients or sub-recipients; and
To recipients that operate a health service program or
research activity or biomedical or behavioral research administered by
the Secretary, or for the implementation of programs or activities
authorized in the Public Health Service Act (``PHS Act'') or the
Developmental Disabilities Assistance and Bill of Rights Act of 2000
(``DD Act'') through specified instruments. As described in the
following paragraphs, the current part 88 thus covers a synthesis of
actors subject to the Church, Coats-Snowe, and Weldon Amendments.
(A) The Department
Part 88 applies to the Department because the Weldon and Coats-
Snowe Amendments, as well as specific paragraphs of the Church
Amendments, apply to the Department.
The Weldon Amendment states that ``[n]one of the funds made
available in this Act may be made available to a Federal agency or
program . . . if such agency [or] program . . . subjects any
institutional or individual health care entity to discrimination . . .
.'' \50\ The Department is a Federal agency that receives substantial
funds made available in the Departments of Labor, Health and Human
Services, and Education, and Related Agencies Appropriations Act
(``Labor/HHS/Education Appropriation''), which are the funds addressed
in Weldon.\51\ To continue to receive those funds, the Department
cannot discriminate on a basis prohibited by Weldon.
---------------------------------------------------------------------------
\50\ E.g., Consolidated Appropriations Act, 2017, Public Law
115-31, Div. H, Tit. V, sec. 507(d), 131 Stat. 135, 562 (May 5,
2017).
\51\ See id.
---------------------------------------------------------------------------
The Coats-Snowe Amendment states that ``[t]he Federal Government .
. . may not subject any health care entity to discrimination on the
[bases]'' listed in paragraphs (a)(1)-(3) of 42 U.S.C. 238n. The
Department, as part of the Federal Government, must comply with the
Coats-Snowe Amendment in all of the Department's operations.
Paragraphs (d) and (c)(2) of the Church Amendments apply to certain
programs administered by the Secretary. Paragraph (d) applies to all
health service programs or research activities funded in whole or part
under programs administered by the Secretary regardless of the source
of funding. Paragraph (c)(2) applies to entities that receive grants or
contracts ``for biomedical or behavioral research under any program
administered by the Secretary.'' \52\ The Department administers many
such programs, either directly or through its components. Examples
include:
---------------------------------------------------------------------------
\52\ 42 U.S.C. 300a-7(c)(2) and (d).
---------------------------------------------------------------------------
The Health Resources and Services Administration (HRSA)
administers grant programs, such as the operation of a grant program
for community health centers,
The National Institute of Health operates grant programs
to fund research,
The Centers for Medicare & Medicaid Services (CMS)
administers Medicare and Federally-facilitated Health Insurance
Marketplaces,\53\ and CMS jointly administers Medicaid with States,\54\
and
---------------------------------------------------------------------------
\53\ https://www.cms.gov/CCIIO/Resources/Fact-Sheets-and-FAQs/ffe.html.
\54\ https://www.medicare.gov/.
---------------------------------------------------------------------------
The Indian Health Service (IHS) operates a system of direct health
care for certain Tribes and Tribal organizations and also administers
contracts and self-governance compacts under the Indian Self-
Determination and Education Assistance Act
[[Page 3905]]
(ISDEAA),\55\ as amended, which allows Tribes and Tribal Organizations
to assume control and management of health care that IHS would
otherwise provide.\56\
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\55\ Public Law 93-638, 88 Stat. 2203 (Jan. 4, 1975).
\56\ IHS FY 2018 Congressional Justification of Estimates to the
Appropriations Committees 199, 203 (2017), https://www.ihs.gov/budgetformulation/includes/themes/responsive2017/display_objects/documents/FY2018CongressionalJustification.pdf
---------------------------------------------------------------------------
(B) State and Local Governments
Part 88 applies to all State and local governments that receive HHS
Federal financial assistance by virtue of several statutory provisions.
First, the Weldon Amendment applies to State and local governments that
receive funds made available in the Labor/HHS/Education
Appropriation.\57\ Second, the Coats-Snowe Amendment applies to State
and local governments that receive HHS Federal financial assistance
(regardless of funding source), ``includ[ing] governmental payments
provided as reimbursement for carrying out health-related activities.''
\58\
---------------------------------------------------------------------------
\57\ Public Law 115-31, Div. H, Tit. V, sec. 507(d), 131 Stat.
at 562 (``None of the funds made available in this Act may be made
available to a . . . State or local government[] if such . . .
government . . . .'').
\58\ 42 U.S.C. 238n(a), (c)(1).
---------------------------------------------------------------------------
Third, several paragraphs of the Church Amendments apply to State
and local governments. Paragraph (b) of the Church Amendments prohibits
coercion by a ``public authority,'' and thereby includes States and
local governments. Paragraphs (c) and (e) of the Church Amendments
apply to State and local governments to the extent that such
governments receive funds to implement programs authorized in the
public laws cited in such paragraphs.
Finally, paragraph (d) of the Church Amendments applies to a State
or local government to the extent that such State or local government
receives partial or full funding for a health service program or
research activity under a program administered by the Secretary.\59\
---------------------------------------------------------------------------
\59\ Id. at Sec. 300a-7(d) (``No individual shall be required
to perform or assist in the performance of any part of a health
service program or research activity funded in whole or in part
under a program administered by the Secretary of Health and Human
Services . . . .'').
---------------------------------------------------------------------------
State and local governments (such as counties or cities) and
instrumentalities of governments (such as State health and human
services agencies) subject to current part 88 receive Federal financial
assistance or Federal funds from the Department from a variety of
financing streams as recipients or sub-recipients. Examples of these
financing streams, which include reimbursement for health-related
activities, include:
Medicaid and the Children's Health Insurance Program,
public health and prevention programs, HIV/AIDS and STD
prevention and education, and substance abuse screening,
biomedical and behavioral research at State institutions
of higher-education,
services for older Americans,
medical assistance to refugees, and
adult protection services to combat elder justice abuse.
(C) Persons and Entities
Part 88 applies to recipients and sub-recipients that operate ``any
part of a health service program or research activity funded in whole
or in part under a program administered by the Secretary;'' \60\
receive a grant, contract, loan, or loan guarantee under the PHS Act or
the DD Act; or receive an interest subsidy under the DD Act. Several
statutory provisions support this application. First, paragraphs
(c)(1)-(2) of the Church Amendments apply to entities that receive a
``grant, contract, loan, or loan guarantee under the [PHS Act],'' or a
``grant or contract for biomedical or behavioral research.'' Second,
paragraph (e) of the Church Amendments applies to entities that receive
a ``grant, contract, loan, or loan guarantee, or interest subsidy''
under the [PHS Act] or the DD Act.\61\ Third, paragraph (d) of the
Church Amendments applies to ``any part of a health service program or
research activity funded in whole or in part under a program
administered by the Secretary of Health and Human Services.'' \62\
---------------------------------------------------------------------------
\60\ 42 U.S.C. 300a-7(d).
\61\ 42 U.S.C. 300a-7(c)(1)(B) (``No entity which receives a
grant, contract, loan, or loan guarantee under the Public Health
Service Act . . . .''), 300a-7(e) (``No entity which receives . . .
any grant, contract, loan, [or] loan guarantee . . . under the
Public Health Service Act . . . or the Developmental Disabilities
Assistance and Bill of Rights Act of 2000 may . . . .''). In
addition to the PHS Act, paragraphs (c)(1) and (e) of the Church
Amendments apply to entities that receive funding under the
Community Mental Health Centers Act, 42 U.S.C. 2689 et seq.
Paragraph (c)(1) of the Church Amendments additionally applies to
entities that receive funding under the Developmental Disabilities
Services and Facilities Construction Act, 42 U.S.C. 6000 et seq.
Congress repealed both of these laws; thus, there are no entities
receiving funds under programs authorized by these statutes to
consider in this RIA. See Omnibus Reconciliation Act of 1981, Public
Law 97-35, Title IX, sec. 902(e)(2)(B), 95 Stat. 560 (1981);
Developmental Disabilities Assistance and Bill of Rights Act of
2000, Public Law 106-402, Title IV, sec. 401(a), 114 Stat. 1737
(2000).
\62\ Id. at 300a-7(d) (``No individual shall be required to
perform or assist in the performance of any part of a health service
program or research activity funded in whole or in part under a
program administered by the Secretary of Health and Human Services .
. . .'').
---------------------------------------------------------------------------
The broad array of recipients and sub-recipients in this category
is a function of two statutory features. First, paragraph (d) of the
Church Amendment does not tie the funding source to a particular
appropriation, instrument, or authorizing statute. Second, the PHS Act
contains thirty titles and authorizes dozens of programs. Examples of
entities that receive funds under programs authorized by the PHS Act
include:
Health facilities, including hospitals, Federally
qualified health centers, community health centers, and mental health
clinics;
Health-related schools and other education entities that
provide health professions training for medicine, oral health,
behavioral health, geriatric care, nursing, etc.;
Community-based organizations that provide substance abuse
screening, HIV/AIDS prevention and treatment, and domestic violence
screening;
Private non-profit and for-profit agencies that provide
medical care to unaccompanied minors;
Interdisciplinary university centers or public or
nonprofit entities associated with universities that receive financial
assistance to implement the DD Act; \63\ and
---------------------------------------------------------------------------
\63\ E.g., https://www.acl.gov/node/466.
---------------------------------------------------------------------------
State Councils on Developmental Disabilities \64\ and
States' Protection and Advocacy Systems that receive funds to implement
the DD Act.\65\
---------------------------------------------------------------------------
\64\ E.g., https://www.acl.gov/node/110. https://www.acl.gov/sites/default/files/about-acl/2017-12/DDC-2017.pdf.
\65\ E.g., https://www.acl.gov/sites/default/files/about-acl/2017-06/PADD-2017.pdf.
---------------------------------------------------------------------------
(ii) Persons and Entities Obligated To Comply With Additional Federal
Laws That This NPRM Proposes To Enforce
This proposed rule would affect persons and entities obligated to
comply with at least one of the approximately two dozen Federal laws
that this revision of part 88 proposes to enforce. There is substantial
overlap between persons and entities obligated to comply with the
current part 88 and persons and entities subject to at least one of the
additional Federal laws that this revision of part 88 proposes to
enforce. This overlap occurs because such persons and entities should
already be subject to 45 CFR part 88 by virtue of their coverage by the
Weldon Amendment, Coats-Snowe Amendment, or Church Amendments (or a
combination thereof), the coverage of which the Department explained in
the immediately preceding part--Part XI.C.2.i. Because of this overlap,
the Department estimates that the proposed
[[Page 3906]]
delegation of authority to OCR to enforce the following laws would not
add any new persons and entities to the coverage of part 88:
Provider conscience laws related to abortion (the Weldon Amendment
for Medicare Advantage, e.g. Public Law 115-31, Div. H, sec. 209, 131
Stat. 135, 539 (2017));
Certain provisions of the Affordable Care Act applying Federal
conscience protections of providers with respect to abortion (42 U.S.C.
18023(b)(4)), regarding assisted suicide (42 U.S.C. 18113), and
providing a conscience exemption to the individual mandate (26 U.S.C.
5000A(d)(2));
Certain laws governing provider counseling, referral, and
implementation of directives (counseling and referral in Medicare
Advantage ((42 U.S.C. 1395w-22(j)(3)(B)), counseling and referral in
Medicaid (42 U.S.C. 1396u-2(b)(3)(B)), and performance of advanced
directives in the Medicare and Medicaid programs (42 U.S.C.
1396a(w)(3), and 14406));
Laws providing for patient objections to receiving health care
services, including medical screening, examination, diagnosis,
treatment, or other health care (42 U.S.C. 1396f), occupational illness
testing (29 U.S.C. 669(a)(5)), pediatric vaccination (42 U.S.C.
1396s(c)(2)(B)(ii)), youth suicide prevention and treatment (42 U.S.C.
290bb-36(f)), and newborn health screening (42 U.S.C. 280g-1(d)); and
Laws protecting religious nonmedical health care, by exempting
religious non-medical institutions from health facility review (42
U.S.C. 1320a-1), peer review (42 U.S.C. 1320c-11), certain health
standards (42 U.S.C. 1396a(a)(9)(A)), medical evaluation (42 U.S.C.
1396a(a)(31)), medical licensing review (42 U.S.C. 1396a(a)(33)), and
utilization review plan requirements (42 U.S.C. 1396b(i)(4)), and by
protecting the exercise of religious nonmedical health care in the
Elder Justice Block Grant Program (42 U.S.C. 1397j-1(b)) and in the
Child Abuse Prevention and Treatment Act (42 U.S.C. 5106i(a)(2)).
The Department estimates that the proposed delegation of authority
to OCR to enforce the following laws would probably add new persons and
entities to the coverage of part 88:
Global Health Programs for HIV/AIDS Prevention, Treatment,
or Care (22 U.S.C. 7631(d)), and
The Helms Amendment (e.g., Consolidated Appropriations
Act, 2017, Pub. L. 115-31, Div. J, sec. 7018).
The persons and entities subject to 22 U.S.C. 7631(d) and the Helms
Amendment may not be currently subject to part 88 because the persons
and entities are recipients and sub-recipients of funds that HHS
administers for Global Health programs where those funds are
appropriated to the U.S. Department of State and USAID but awarded from
HHS. Thus, the financing streams to which these laws apply likely do
not overlap with the financial streams to which the Weldon, Coats-
Snowe, and Church Amendments apply. However, paragraph (d) of the
Church Amendments applies to a ``health service program or research
activity funded in whole or in part under a program administered by the
Secretary.'' Paragraph (d) does not require that the funding for the
health service program or research activity be appropriated to HHS, but
only that it be ``funded in whole or part under a program administered
by the Secretary.'' Consequently, paragraph (d) of the Church
Amendments (and, thus, part 88) would arguably apply to recipients and
sub-recipients of Federal funds from (or administered by) the
Department with respect to such Global Health programs because if the
Department administers the funds, it administers the program.
(iii) Methodology
Although the Department has qualitatively summarized the new
persons and entities covered by this proposed rule, the Department has
also quantitatively estimated those persons and entities to understand
the likely impact of the proposed rule. To do so, the Department
primarily relied on the latest data available from the U.S. Census
Bureau's Statistics of U.S. Businesses,\66\ supplemented with other
sources. The Department determined that no one data source could supply
an unduplicated count of the persons or entities that receive an award
through an instrument covered within the scope of this proposed rule.
But in assessing the available methodologies, the Department concluded
that the U.S. Census Bureau data, supplemented with other sources, was
the most reasonable way to estimate the number of persons and entities
that this proposed rule would affect.
---------------------------------------------------------------------------
\66\ https://www.census.gov/data/datasets/2015/econ/susb/2015-susb.html. The Department relied on the data file titled ``U.S. &
State, NAICS, detailed employment sizes (U.S., 6-digit and states,
NAICS sectors).'' The latest data available is from 2015 that the
Bureau made available in September of 2017, and this data relied on
the 2012 NAICS codes. Id.
---------------------------------------------------------------------------
The U.S. Census Bureau's Statistics of U.S. Businesses is based on
the North American Industry Classification System (NAICS).\67\ The
NAICS classifies all economic activity into 20 sectors and breaks that
information down into sub-sectors and industries.\68\ Essentially, the
NAICS groups physical business establishments together based on how
similar the locations' processes are for producing goods or
services.\69\ The NAICS provides information on how many singular
physical locations exist for a particular business or industry (called
an ``establishment''),\70\ how many of those establishments are under
common ownership or control of a business organization or entity
(called a ``firm''),\71\ and the number of people who work in a
particular business or industry, among other types of information. For
instance, a hospital system that has common ownership and control over
multiple hospital facilities is a firm, and each hospital facility is
an establishment.
---------------------------------------------------------------------------
\67\ https://www.census.gov/programs-surveys/susb/technical-documentation/methodology.html.
\68\ FAQ 5, https://www.census.gov/eos/www/naics/faqs/faqs.html#q5.
\69\ FAQ 1, https://www.census.gov/eos/www/naics/faqs/faqs.html#q1.
\70\ https://www.census.gov/eos/www/naics/faqs/faqs.html#q2.
\71\ https://www.census.gov/glossary/#term_Firm.
---------------------------------------------------------------------------
For the vast majority of the recipient and sub-recipient types, the
Department assumes that only a portion of the industry captured in the
Statistics of U.S. Businesses receives Federal funds. For instance, not
all physician offices accept Medicare, Medicaid, or both. In fact,
about 68.9% of physician offices accepted new Medicaid patients based
on 2013 data from the National Electronic Health Records Survey.\72\
Approximately 83.7% of physicians accepted new Medicare patients based
on the same data.\73\ Because current part 88 applies to physicians
receiving reimbursement for Medicare Part B and to physicians
participating in Medicaid, the Department assumed that the lower of
these two percentages (69%) represents the lower-bound of physicians
nationwide subject to current part 88. In the absence of evidence with
which to generate a refined upper-bound estimate, the Department
assumed that current part 88 covers all physicians nationwide as the
upper-bound.
---------------------------------------------------------------------------
\72\ Esther Hing et al., Nat'l Ctr. For Health Statistics,
Centers for Disease Control and Prevention, U.S. Dep't of Health and
Human Servs., Acceptance of New Patience with Public and Private
Insurance by Office-Based Physicians: United States, 2013, Data
Brief No. 195, 1 (Mar. 2015).
\73\ Id.
---------------------------------------------------------------------------
The Department used this same percentage range (69% to 100%) in
estimating the coverage for other health care industry sector types,
such as hospitals and various outpatient care facilities. For the
social services and
[[Page 3907]]
education industries, which generally have principal purposes other
than health and patient care, the Department adopted ranges more
appropriate for those industries. For the social services industries,
the Department adopted a range with 25% as the lower-bound and 100% as
the upper-bound to cover 62.5% of the industry on average).
To estimate the number of local governments and educational
institutions, the Department supplemented its use of data from the U.S.
Census Bureau's Statistics of U.S. Businesses with Census data from
other statistical programs or with available award data available
through the HHS Tracking Accountability in Government Grants System
(TAGGS).\74\ For instance, in estimating the number of counties
nationwide, the Department relied on U.S. Census Bureau's 2010 Census
Geographic Entity Tallies by State and Type to identify the total
counties and equivalent areas for the U.S., Puerto Rico, the U.S.
Territories, and the Island Areas.\75\
---------------------------------------------------------------------------
\74\ http://taggs.hhs.gov (last visited Aug. 24, 2017).
\75\ https://www.census.gov/geo/maps-data/data/tallies/all_tallies.html.
---------------------------------------------------------------------------
As another example, the Department relied on data from TAGGS to
derive a lower-bound percentage of colleges and universities that are
recipients. (The upper-bound assumes all educational institutions
industry-wide are recipients.) Although most colleges and universities
receive Federal financial assistance from the U.S. Department of
Education, not all universities are recipients of HHS funds; thus, the
Department wanted a lower-bound estimate to reflect that assumption.
Using the ``Advanced Search'' function in TAGGS, HHS identified all
awards to Junior Colleges, Colleges, and Universities for FY 2016 and
de-duplicated the results to obtain a singular list of unique awardees
from the Department, which totaled 615. Because these awardees included
satellite campuses of college or university systems, the total awardee
number was akin to the number of ``establishments'' rather than
``firms'' as those terms are used in the U.S. Census Bureau's
Statistics of U.S. Businesses. Similar to how an ``establishment'' is a
location of a ``firm'' that has common ownership and control, a
satellite campus is one location of a university system with common
ownership and control of multiple campus locations.
To derive an estimate of educational institutions at the ``firm''
level, the Department computed the ratio between firms and
establishments from the U.S. Census Bureau's Statistics of U.S.
Businesses.\76\ This ratio is 51.32% (2,457 firms/4,788
establishments). The Department applied that ratio to the total number
of Junior Colleges, Colleges, and Universities that received HHS
funding as ``establishments'' (0.5132 x 615 awardee establishments) to
get an estimate of 316 firms. Despite this method's potential
complexity, the Department found it the most reasonable method for
estimating the lower-bound number of colleges and universities that are
Department recipients.
---------------------------------------------------------------------------
\76\ U.S. Census Bureau, Statistics of U.S. Businesses, 2015,
NAICS code 611310 (Colleges, Universities, and Professional
Schools).
---------------------------------------------------------------------------
The Department considered other methodologies for estimating the
number of impacted persons and entities. For instance, the Department
considered primarily relying on award data from TAGGS in lieu of using
it as a supplemental data source. In addition, the Department also
considered adding together the number of awards to States, local
governments, private entities, nonprofit entities, etc., that
Department components commonly report on a program-by-program basis on
the Web, in ad hoc reports on topic-specific matters, and in their
annual Justifications of Estimates to the Appropriations Committees as
part of the President's annual budget request to Congress.
The Department rejected those methodological approaches. In
particular, the Department was concerned that those approaches would
double-count a substantial number of persons and entities that receive
an award from more than one Department component or that receive
multiple awards from the same component. Primarily relying on TAGGS
would not only double-count some persons and entities but would under-
count others because TAGGS does not capture the number of sub-
recipients receiving awards from a recipient. Given these
considerations, NAICS information, supplemented with Census data from
other statistical programs or with publicly available award data from
TAGGS, was the best reasonably obtainable source of economic and
technical information on which the Department could rely.
The Department seeks comment on the methodology used and whether
there are other methodologies that the Department could consider to
refine the scope of persons and entities affected by this proposed
rule.
(iv) Quantitative Estimate of Persons and Entities Covered by NPRM
Table 1 lists each type of recipient and the estimated number of
recipients that this proposed rule covers. Because there is uncertainty
as to the universe of persons and entities currently covered by 45 CFR
part 88 and the incremental number of new persons and entities that the
Department expects this proposed rule will cover, Table 1 captures this
uncertainty by reflecting estimated recipients as a range with a lower
and an upper-bound. The footnotes detail the assumptions and
calculations for each line of the table.
Table 1--Estimated Number of Persons and Entities Covered by NPRM
----------------------------------------------------------------------------------------------------------------
Covered by current Estimated Estimated
Type 45 CFR 88? Covered by NPRM? number (low) number (high)
----------------------------------------------------------------------------------------------------------------
1................. State and Yes............... Yes............... 58 58
Territorial
Governments \77\.
2................. Federally recognized Yes............... Yes............... 567 567
Tribes \78\.
3................. Counties \79\....... Yes............... Yes............... 3,234 3,234
----------------------------------------------------------------------------------------------------------------
Hospitals:
----------------------------------------------------------------------------------------------------------------
4................. General and Medical Yes............... Yes............... 1,859 2,694
Surgical Hospitals
\80\.
5................. Specialty Hospitals Yes............... Yes............... 553 801
(e.g., psychiatric,
substance abuse,
rehabilitation,
cancer, maternity)
\81\.
----------------------------------------------------------------------------------------------------------------
Nursing and Residential Care Facilities:
----------------------------------------------------------------------------------------------------------------
[[Page 3908]]
6................. Skilled Nursing Yes............... Yes............... 6,316 9,153
Facilities \82\.
7................. Residential Yes............... Yes............... 4,310 6,246
Intellectual and
Developmental
Disability
Facilities \83\.
8................. Continuing Care Yes............... Yes............... 2,605 3,775
Retirement
Communities \84\.
9................. Other Residential Yes............... Yes............... 2,247 3,256
Care Facilities
(e.g., group homes)
\85\.
10................ Entities providing Yes............... Yes............... 15,062 21,829
Home Health Care
Services \86\.
----------------------------------------------------------------------------------------------------------------
Entities Providing Ambulatory Health Care Services:
----------------------------------------------------------------------------------------------------------------
11................ Offices of Yes............... Yes............... 115,673 167,642
Physicians (except
Mental Health
Specialists) \87\.
12................ Offices of Yes............... Yes............... 7,324 10,614
Physicians (Mental
Health Specialists)
\88\.
13................ Offices of Mental Yes............... Yes............... 14,340 20,782
Health
Practitioners
(except Physicians)
\89\.
14................ Offices of Dentists Yes............... Yes............... 86,874 125,904
\90\.
15................ Offices of Yes............... Yes............... 26,725 32,535
Chiropractors \91\.
16................ Offices of Yes............... Yes............... 13,775 19,964
Optometrists \92\.
17................ Offices of Physical, Yes............... Yes............... 17,623 25,540
Occupational and
Speech Therapists,
and Audiologists
\93\.
18................ Offices of Yes............... Yes............... 5,314 7,701
Podiatrists \94\.
19................ Family Planning Yes............... Yes............... 999 1,448
Centers \95\.
20................ Freestanding Yes............... Yes............... 2,908 4,214
Ambulatory Surgical
and Emergency
Centers \96\.
21................ HMO Medical Centers Yes............... Yes............... 78 113
\97\.
22................ Kidney Dialysis Yes............... Yes............... 305 442
Centers \98\.
23................ Outpatient Mental Yes............... Yes............... 3,776 5,472
Health and
Substance Abuse
Centers \99\.
24................ Diagnostic Imaging Yes............... Yes............... 3,209 4,651
Centers \100\.
25................ Medical Laboratories Yes............... Yes............... 2,278 3,302
\101\.
26................ Ambulance Services Yes............... Yes............... 2,185 3,167
\102\.
27................ All Other Outpatient Yes............... Yes............... 3,880 5,623
Care Centers (e.g.,
centers and clinics
for pain therapy,
community health,
and sleep
disorders) \103\.
28................ Entities providing Yes............... Yes............... 2,391 3,465
All Other
Ambulatory Health
Care Services
(health screening,
smoking cessation,
hearing testing,
blood banks) \104\
----------------------------------------------------------------------------------------------------------------
Insurance Carriers:
----------------------------------------------------------------------------------------------------------------
29................ Direct Health and Yes............... Yes............... 607 880
Medical Insurance
Carriers \105\.
----------------------------------------------------------------------------------------------------------------
Entities Providing Social Assistance Services:
----------------------------------------------------------------------------------------------------------------
30................ Entities Serving the Yes............... Yes............... 9,051 36,205
Elderly and Persons
with Disabilities
(provision of
nonresidential
social assistance
services to improve
quality of life)
\106\
31................ Entities providing Yes............... Yes............... 5,310 21,240
Other Individual
Family Services
(e.g., marriage
counseling, crisis
intervention
centers, suicide
crisis centers)
\107\
32................ Entities providing Yes............... Yes............... 2,169 8,674
Child and Youth
Services (e.g.,
adoption agencies,
foster care
placement services)
\108\
33................ Temporary Shelters Yes............... Yes............... 805 3,219
(e.g., short term
emergency shelters
for victims of
domestic violence,
sexual assault, or
child abuse;
runaway youth; and
families caught in
medical crises)
\109\.
34................ Emergency and Other Yes............... Yes............... 169 675
Relief Services
(e.g., medical
relief,
resettlement, and
counseling to
victims of domestic
or international
disasters or
conflicts) \110\
----------------------------------------------------------------------------------------------------------------
Other Entities:
----------------------------------------------------------------------------------------------------------------
35................ Pharmacies and Drug Yes............... Yes............... 13,490 19,550
Stores \111\.
36................ Research and Yes............... Yes............... 2,347 3,402
Development in
Biotechnology \112\.
37................ Colleges, Yes............... Yes............... 316 2,457
Universities, and
Professional
Schools \113\.
----------------------------------------------------------------------------------------------------------------
Subtotal, subject to current part 88........................................ 364,575 571,282
----------------------------------------------------------------------------------------------------------------
38................ HHS awarded funds No................ Yes............... 65 130
appropriated to the
U.S. Department of
State & USAID \114\.
----------------------------------------------------------------------------------------------------------------
Subtotal, incremental increase in entities.................................. 65 130
----------------------------------------------------------------------------------------------------------------
[[Page 3909]]
Total, estimated entities subject to NPRM............................... 364,640 571,412
----------------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------
\77\ Assumes coverage of the 50 States, DC, Puerto Rico, 6 U.S.
Territories, and the Island Areas.
\78\ Assumes all Federally-recognized Tribes get HHS funds.
Indian Health Service, FY 2018 Justification of Estimates to the
Appropriations Committees CJ-1 (2017), https://www.ihs.gov/budgetformulation/includes/themes/responsive2017/display_objects/documents/FY2018CongressionalJustification.pdf.
\79\ U.S. Census Bureau, 2010 Census Geographic Entity Tallies
by State and Type, https://www.census.gov/geo/maps-data/data/tallies/all_tallies.html (total counties and equivalent areas for
the U.S., Puerto Rico, the U.S. Territories, and the Island Areas).
The Department assumed that every county receives Federal funds as a
recipient or sub-recipient.
\80\ U.S. Census Bureau, Statistics of U.S. Businesses, 2015
(released Sept. 2017), https://www.census.gov/data/datasets/2015/econ/susb/2015-susb.html (nationwide count of firms for NAICS Code
622110). Assumes coverage for 69%-100% of the industry.
\81\ Id. (sum of the nationwide count of firms for NAICS Codes
622210 and 622310). Assumes 69%-100% of industry is covered.
\82\ Id. (relying on the nationwide count of firms for NAICS
Code 623110). Assumes 69%-100% of industry is covered.
\83\ Id. (nationwide count of firms for NAICS Code 623210).
Assumes 69%-100% of industry is covered.
\84\ Id. (nationwide count of firms for NAICS Code 623311).
Assumes 69%-100% of industry is covered.
\85\ Id. (nationwide count of firms for NAICS Code 623990).
Assumes 69%-100% of industry is covered.
\86\ Id. (nationwide count of firms for NAICS Code 621610).
Assumes 69%-100% of industry is covered.
\87\ Id. (nationwide count of firms for NAICS Code 621111).
Assumes 69%-100% of industry is covered.
\88\ Id. (nationwide count of firms for NAICS Code 621112).
Assumes 69%-100% of industry is covered.
\89\ Id. (nationwide count of firms for NAICS Code 621330).
Assumes 69%-100% of industry is covered.
\90\ Id. (nationwide count of firms for NAICS Code 621210).
Assumes 69%-100% of industry is covered.
\91\ Id. (nationwide count of firms for NAICS Code 621310).
Assumes 69%-100% of industry is covered.
\92\ Id. (nationwide count of firms for NAICS Code 621320).
Assumes 69%-100% of industry is covered.
\93\ Id. (nationwide count of firms for NAICS Code 621340).
Assumes 69%-100% of industry is covered.
\94\ Id. (nationwide count of firms for NAICS Code 621391).
Assumes 69%-100% of industry is covered.
\95\ Id. (nationwide count of firms for NAICS Code 621410).
Assumes 69%-100% of industry is covered.
\96\ Id. (nationwide count of firms for NAICS Code 621493).
Assumes 69%-100% of industry is covered.
\97\ Id. (nationwide count of firms for NAICS Code 621491).
Assumes 69%-100% of industry is covered.
\98\ Id. (nationwide count of firms for NAICS Code 621492).
Assumes 69%-100% of industry is covered.
\99\ Id. (nationwide count of firms for NAICS Code 621420).
Assumes 69%-100% of industry is covered.
\100\ Id. (nationwide count of firms for NAICS Code 621512).
Assumes 69%-100% of industry is covered.
\101\ Id. (nationwide count of firms for NAICS Code 621511).
Assumes 69%-100% of industry is covered.
\102\ Id. (nationwide count of firms for NAICS Code 621910).
Assumes 69%-100% of industry is covered.
\103\ Id. (nationwide count of firms for NAICS Code 621498).
Assumes 69%-100% of industry is covered.
\104\ Id. (nationwide count of firms for NAICS Code 62199).
Assumes 69%-100% of the industry is covered.
\105\ Id. (nationwide count of firms for NAICS Code 524114).
Assumes 69%-100% of industry is covered.
\106\ Id. (nationwide count of firms for NAICS Code 624120).
Assumes 69%-100% of industry is covered.
\107\ Id. (nationwide count of firms for NAICS Code 624190).
Assumes 69%-100% of industry is covered.
\108\ Id. (nationwide count of firms for NAICS Code 624110). As
described supra Part XI.C.2.iii (methodology), for entities whose
principal purpose is not health care, the Department assumes 25%-
100% of industry is covered.
\109\ Id. (nationwide count of firms for NAICS Code 624221). As
described supra Part XI.C.2.iii (methodology), for entities whose
principal purpose is not health care, the Department assumes 25%-
100% of industry is covered.
\110\ Id. (nationwide count of firms for NAICS Code 624230). As
described supra Part XI.C.2.iii (methodology), for entities whose
principal purpose is not health care, the Department assumes 25%-
100% of industry is covered.
\111\ Id. (nationwide count of firms for NAICS Code 44610).
Assumes 69%-100% of industry is covered.
\112\ Id. (nationwide count of firms for NAICS Code 541711).
Assumes 69%-100% of industry is covered.
\113\ Id. (nationwide count of firms for NAICS Code 611310). As
described supra Part XI.C.2.iii (methodology), the Department
assumes 13%-100% of institutions of higher-education are covered.
See supra XI.C.2.iii for a detailed explanation for how the
Department supplemented Statistics of U.S. Businesses data with
award data from the Department's Tracking Accountability in
Government Grants System.
\114\ U.S. Dep't of Health & Human Servs., Tracking
Accountability in Government Grants System (TAGGS) http://taggs.hhs.gov (last visited Dec. 19, 2017). HHS identified unique
awardees for FY 2017 from HHS PEPFAR implementing agencies (CDC,
HRSA, SAMHSA, NIH, FDA) to foreign nonprofits, foreign governments,
and international organizations and used this number as a lower-
bound. Because the Department also receives funds appropriated to
USAID through one or more reimbursable agreements, the Department
assumed that there could be twice as many recipients and sub-
recipients after considering the awardees from these reimbursable
agreements and thus multiplied and lower-bound by two.
---------------------------------------------------------------------------
Approximately 364,575 to 571,282 persons and entities are currently
subject to part 88 by virtue of the Weldon Amendment, the Coats-Snowe
Amendment, and the Church Amendments. The Department estimated that the
universe of incremental new persons and entities subject to 22 U.S.C.
7631(d) and the Helms Amendment that this proposed rule would cover is
small and, possibly, non-existent. This proposed rule may add 65 to 130
new persons and entities to part 88's coverage.\115\ With this
incremental increase, this proposed rule would cover a total of 364,640
to 571,412 entities.
---------------------------------------------------------------------------
\115\ But see supra Part XI.C.2.ii (discussing the application
of paragraph (d) of the Church Amendments to such grantees).
---------------------------------------------------------------------------
(A) Estimated Persons and Entities Required To Sign an Assurance and
Certification of Compliance
Relative to the persons and entities shown in Table 1, a smaller
subset will be subject to proposed 88.4, which requires certain
recipients to submit an assurance and certification of compliance. The
Department began calculating that subset by removing sub-recipients
from the total because proposed 88.4 would apply only to recipients,
not sub-recipients. OCR has not found a reliable way to estimate the
total number of sub-recipients. For purposes of this calculation, the
Department assumed that every county is a sub-recipient but not a
recipient and accordingly excluded all 3,234 counties from the total
number that must comply with the assurance and certification of
compliance requirement. The Department requests information, data
sources, studies, or reports that could assist in identifying the
number of sub-recipients under this proposed regulation excluded from
Sec. 88.4.
The Department next sought to estimate and remove exempted entities
from the total. The Department assumed that all physicians would meet
the proposed criteria for exemption from the requirement in proposed
[[Page 3910]]
Sec. 88.4(c)(1).\116\ Consequently, the Department excluded 255,684 to
370,557 entities, representing the lower and upper-bounds, from the
estimate. To the degree that some physicians are recipients of the
Department through an instrument other than reimbursement for their
participation in Medicare Part B, then the Department overestimated the
impact of the exemption.
---------------------------------------------------------------------------
\116\ Sum of rows 11, 12, 14-18 of Table 1.
---------------------------------------------------------------------------
The Department removed 11,220 to 44,879 persons and entities that
provide child and youth services and services for the elderly and
persons with disabilities based on the proposed exemption for
recipients awarded under grant programs administered by the
Administration for Children and Families or the Administration for
Community Living. The exemption applies if the program meets certain
regulatory criteria indicating that its purpose is unrelated to health
care and certain types of research, does not involve health care
providers, and does not involve referral for the provision of health
care. See proposed Sec. 88.4(c)(2)-(3).
The Department reasonably anticipated that all persons and entities
that provide child and youth services (such as adoption and foster
care) would fall into this exemption. The Department also reasonably
anticipated that all entities providing services for the elderly and
persons with disabilities (by providing nonresidential social
assistance services to improve quality of life) would fall within this
exemption. The Department considered exempting entities providing Other
Individual Family Services (e.g., marriage counseling, crisis
intervention centers, suicide crisis centers), but decided not to do
so. Although the provision of these services may not involve health
care providers, there is a significant likelihood of referral for the
provision of health care at crisis intervention centers and suicide
crisis centers.
Finally, the Department excluded 223 Tribes and Tribal
Organizations from the total. The number reflects the proposed Tribal
exemption. See proposed Sec. 88.4(c)(4). The Department has identified
223 Tribes and Tribal Organizations that operate Title contracts under
Title I of the ISDEA Act.
The Department seeks comment on the methods used to estimate the
scope of exempted recipients under proposed Sec. 88.4(c)(1)-(4).
Table 2--Range of Recipients Subject to the Proposed Assurance and
Certification Requirements (Sec. 88.4)
------------------------------------------------------------------------
Low-end Upper- bound
estimate estimate
------------------------------------------------------------------------
Range of Persons or Entities Subject to 364,640 571,412
the NPRM...............................
Range of Recipients Excepted from -270,361 -418,893
Proposed Sec. 88.4...................
-------------------------------
Total, Recipients Subject to the 94,279 152,519
Assurance and Certification
Requirements.......................
------------------------------------------------------------------------
(B) Estimated Number of Recipients Required to Provide Notice (Sec.
88.5)
More persons and entities would be subject to the notice
requirement than to the assurance and certification requirements under
the proposed rule. Although the Department proposes to exclude certain
recipients from the assurance and certification requirements, the
Department proposes to require all recipients and the Department to
comply with the notice requirement. The Department proposes this policy
approach because persons, entities, and health care entities who do not
know their rights may not exercise them. The notice is designed to be
seen by workforce members of the Department or recipients,
beneficiaries of covered programs and activities, and the public. In
contrast, assurance and certification documents are internal facing
documents that certain recipients would sign and the public would
likely never see.
In an effort to reduce the burden on sub-recipients, proposed Sec.
88.5, similar to proposed Sec. 88.4, does not require sub-recipients
to post a notice. The Department requests comment on whether its
proposed policy strikes the right balance between reducing the burden
on sub-recipients and providing notice of important rights. OCR
employed the methods from supra Part XI.C.2.iv.A to estimate the total
number of sub-recipients (3,234 counties) to exclude from the total
count of persons and entities subject to the notice requirement.
The Department counted the number of establishments associated with
each recipient type. Unlike the assurance and certification
requirements, which will be implemented at the ``firm'' level, the
Department expects that the notice requirement will be implemented at
the ``establishment'' level because proposed Sec. 88.5 requires
recipients to post the notice in all physical locations where notices
are commonly posted for members of the workforce or for the public. For
instance, a hospital system that has common ownership and control over
multiple hospital facilities (a firm) would implement Sec. 88.4 but
each hospital facility (an establishment) would implement Sec. 88.5 to
display physical notices.
Table 3 employs the same methodology for calculating the number of
entities but uses the U.S. Census Bureau's Statistics of U.S.
Businesses data for establishments rather than firms.
Table 3--Number of Physical Establishments of Each Recipient Type Required To Provide Notice (Sec. 88.5)
----------------------------------------------------------------------------------------------------------------
Estimated Estimated
Type number (Low) number (High)
----------------------------------------------------------------------------------------------------------------
1.......................................... State and Territorial Governments 58 58
\117\.
2.......................................... Federally recognized Tribes \118\.. 567 567
3.......................................... Counties \119\ (assumed sub- n/a n/a
recipient category to which the
notice requirement does not apply).
4.......................................... General and Medical Surgical 3,699 5,361
Hospitals \120\.
[[Page 3911]]
5.......................................... Specialty Hospitals (e.g. 1,139 1,651
psychiatric, substance abuse,
rehabilitation, cancer, maternity)
\121\.
6.......................................... Skilled Nursing Facilities \122\... 11,789 17,085
7.......................................... Residential Intellectual and 22,611 32,770
Developmental Disability
Facilities \123\.
8.......................................... Continuing Care Retirement 3,668 5,316
Communities \124\.
9.......................................... Other Residential Care Facilities 3,627 5,256
(e.g., group homes) \125\.
10......................................... Entities providing Home Health Care 21,377 30,981
Services \126\.
11......................................... Offices of Physicians (except 147,817 214,228
Mental Health Specialists) \127\.
12......................................... Offices of Physicians (Mental 7,498 10,867
Health Specialists) \128\.
13......................................... Offices of Mental Health 15,022 21,771
Practitioners (except Physicians)
\129\.
14......................................... Offices of Dentists \130\.......... 92,895 134,631
15......................................... Offices of Chiropractors \131\..... 26,999 39,129
16......................................... Offices of Optometrists \132\...... 15,101 21,885
17......................................... Offices of Physical, Occupational 25,213 36,541
and Speech Therapists, and
Audiologists \133\.
18......................................... Offices of Podiatrists \134\....... 5,769 8,361
19......................................... Family Planning Centers \135\...... 1,584 2,295
20......................................... Freestanding Ambulatory Surgical 4,609 6,679
and Emergency Centers \136\.
21......................................... HMO Medical Centers \137\.......... 560 812
22......................................... Kidney Dialysis Centers \138\...... 5,144 7,455
23......................................... Outpatient Mental Health and 7,227 10,474
Substance Abuse Centers \139\.
24......................................... Diagnostic Imaging Centers \140\... 4,553 6,598
25......................................... Medical Laboratories \141\......... 7,360 10,667
26......................................... Ambulance Services \142\........... 3,271 4,740
27......................................... All Other Outpatient Care Centers 8,054 11,672
(e.g., centers and clinics for
pain therapy, community health,
and sleep disorders) \143\.
28......................................... Entities providing All Other 3,670 5,319
Ambulatory Health Care Services
(health screening, smoking
cessation, hearing testing, blood
banks) \144\.
29......................................... Direct Health and Medical Insurance 3,712 5,379
Carriers \145\.
30......................................... Entities Serving the Elderly and 10,475 41,899
Persons with Disabilities
(provision of nonresidential
social assistance services to
improve quality of life) \146\.
31......................................... Entities providing Other Individual 7,184 28,736
Family Services (e.g., marriage
counseling, crisis intervention
centers, suicide crisis centers)
\147\.
32......................................... Entities providing Child and Youth 2,901 11,604
Services (e.g., adoption agencies,
foster care placement services)
\148\.
33......................................... Temporary Shelters (e.g., short 1,013 4,053
term emergency shelters for
victims of domestic violence,
sexual assault, or child abuse;
runaway youth; and families caught
in medical crises) \149\.
34......................................... Emergency and Other Relief Services 309 1,236
(e.g., medical relief,
resettlement, and counseling to
victims of domestic or
international disasters or
conflicts) \150\.
35......................................... Pharmacies and Drug Stores \151\... 30,450 44,130
36......................................... Research and Development in 2,505 3,631
Biotechnology \152\.
37......................................... Colleges, Universities, and 615 4,788
Professional Schools \153\.
38......................................... HHS awarded funds appropriated to 65 130
the U.S. Department of State &
USAID \154\.
rrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr
Total, Subject to the Notice ................................... 476,539 746,206
Requirement.
----------------------------------------------------------------------------------------------------------------
Public Comment Requested on Scope of Entities
Given the uncertainty as to the number of recipients covered by
this
[[Page 3912]]
NPRM, the Department in particular seeks public comment on ways that
HHS could improve the accuracy of the estimates contained in this RIA.
Please specifically provide data, studies, reports, or other
documentation to support your comments.
---------------------------------------------------------------------------
\117\ Assumes coverage of the 50 States, DC, Puerto Rico, 6 U.S.
Territories, and the Island Areas.
\118\ Assumes all Federally-recognized Tribes get HHS funds.
Indian Health Service, FY 2018 Justification of Estimates to the
Appropriations Committees CJ-1 (2017), https://www.ihs.gov/budgetformulation/includes/themes/responsive2017/display_objects/documents/FY2018CongressionalJustification.pdf.
\119\ U.S. Census Bureau, 2010 Census Geographic Entity Tallies
by State and Type, https://www.census.gov/geo/maps-data/data/tallies/all_tallies.html (total counties and equivalent areas for
the U.S., Puerto Rico, the U.S. Territories, and the Island Areas).
The Department assumed that every county is a recipient or a sub-
recipient.
\120\ U.S. Census Bureau, Statistics of U.S. Businesses, 2015
(released Sept. 2017), https://www.census.gov/data/datasets/2015/econ/susb/2015-susb.html (nationwide count of firms for NAICS Code
622110). Assumes coverage for 69%-100% of the industry.
\121\ Id. (sum of the nationwide count of firms for NAICS Codes
622210 and 622310). Assumes 69%-100% of industry is covered.
\122\ Id. (relying on the nationwide count of firms for NAICS
Code 623110). Assumes 69%-100% of industry is covered.
\123\ Id. (nationwide count of firms for NAICS Code 623210).
Assumes 69%-100% of industry is covered.
\124\ Id. (nationwide count of firms for NAICS Code 623311).
Assumes 69%-100% of industry is covered.
\125\ Id. (nationwide count of firms for NAICS Code 623990).
Assumes 69%-100% of industry is covered.
\126\ Id. (nationwide count of firms for NAICS Code 621610).
Assumes 69%-100% of industry is covered.
\127\ Id. (nationwide count of firms for NAICS Code 621111).
Assumes 69%-100% of industry is covered.
\128\ Id. (nationwide count of firms for NAICS Code 621112).
Assumes 69%-100% of industry is covered.
\129\ Id. (nationwide count of firms for NAICS Code 621330).
Assumes 69%-100% of industry is covered.
\130\ Id. (nationwide count of firms for NAICS Code 621210).
Assumes 69%-100% of industry is covered.
\131\ Id. (nationwide count of firms for NAICS Code 621310).
Assumes 69%-100% of industry is covered.
\132\ Id. (nationwide count of firms for NAICS Code 621320).
Assumes 69%-100% of industry is covered.
\133\ Id. (nationwide count of firms for NAICS Code 621340).
Assumes 69%-100% of industry is covered.
\134\ Id. (nationwide count of firms for NAICS Code 621391).
Assumes 69%-100% of industry is covered.
\135\ Id. (nationwide count of firms for NAICS Code 621410).
Assumes 69%-100% of industry is covered.
\136\ Id. (nationwide count of firms for NAICS Code 621493).
Assumes 69%-100% of industry is covered.
\137\ Id. (nationwide count of firms for NAICS Code 621491).
Assumes 69%-100% of industry is covered.
\138\ Id. (nationwide count of firms for NAICS Code 621492).
Assumes 69%-100% of industry is covered.
\139\ Id. (nationwide count of firms for NAICS Code 621420).
Assumes 69%-100% of industry is covered.
\140\ Id. (nationwide count of firms for NAICS Code 621512).
Assumes 69%-100% of industry is covered.
\141\ Id. (nationwide count of firms for NAICS Code 621511).
Assumes 69%-100% of industry is covered.
\142\ Id. (nationwide count of firms for NAICS Code 621910).
Assumes 69%-100% of industry is covered.
\143\ Id. (nationwide count of firms for NAICS Code 621498).
Assumes 69%-100% of industry is covered.
\144\ Id. (nationwide count of firms for NAICS Code 62199).
Assumes 69%-100% of the industry is covered.
\145\ Id. (nationwide count of firms for NAICS Code 524114).
Assumes 69%-100% of industry is covered.
\146\ Id. (nationwide count of firms for NAICS Code 624120).
Assumes 69%-100% of industry is covered.
\147\ Id. (nationwide count of firms for NAICS Code 624190).
Assumes 69%-100% of industry is covered.
\148\ Id. (nationwide count of firms for NAICS Code 624110). As
described supra Part XI.C.2.iii (methodology), for entities whose
principal purpose is not health care, the Department assumes 25%-
100% of industry is covered.
\149\ Id. (nationwide count of firms for NAICS Code 624221). As
described supra Part XI.C.2.iii (methodology), for entities whose
principal purpose is not health care, the Department assumes 25%-
100% of industry is covered.
\150\ Id. (nationwide count of firms for NAICS Code 624230). As
described supra Part XI.C.2.iii (methodology), for entities whose
principal purpose is not health care, the Department assumes 25%-
100% of industry is covered.
\151\ Id. (nationwide count of firms for NAICS Code 44610).
Assumes 69%-100% of industry is covered.
\152\ Id. (nationwide count of firms for NAICS Code 541711).
Assumes 69%-100% of industry is covered.
\153\ Id. (nationwide count of firms for NAICS Code 611310). As
described supra Part XI.C.2.iii (methodology), the Department
assumes 13%-100% of institutions of higher-education are covered.
\154\ U.S. Dep't of Health & Human Servs., Tracking
Accountability in Government Grants System (TAGGS) http://taggs.hhs.gov (last visited Dec. 19, 2017).
---------------------------------------------------------------------------
Estimated Burdens
There are six categories of estimated burdens for this proposed
rule, as summarized in Table 4.
Table 4--Summary of Costs
----------------------------------------------------------------------------------------------------------------
Year 1: Initial costs Years 2 to 5: Annual recurring
-------------------------------- costs
Cost category -------------------------------
Total cost (in Affected (%) Total cost (in
millions) millions) Affected (%)
----------------------------------------------------------------------------------------------------------------
1..................... Familiarization (one- $62.9 100 .............. ..............
time burden).
2..................... Assurance and
Certification.
Signing Documents..... 72.8 26 $72.8 26
Reviewing Policies and 36.4 13 36.4 13
Procedures.
Update Policies, 13.8 5 1.4 0.5
Procedures, Training.
----------------------------------------------------------------------------------------------------------------
Subtotal, Assurance and Cert................ 123.0 .............. 110.6 ..............
----------------------------------------------------------------------------------------------------------------
3..................... Notice requirement......
Mandatory, one-time, 92.9 99
posting.
Voluntary Posting..... 25.2 50 6.7 24.9
----------------------------------------------------------------------------------------------------------------
Subtotal, Notice............................ 118.1 .............. 6.7 ..............
----------------------------------------------------------------------------------------------------------------
4..................... Compliance Procedures... 0.6 0.01 0.6 .01
5..................... Voluntary Remedial 6.8 0.5 6.8 0.5
Efforts.
----------------------------------------------------------------------------------------------------------------
Subtotal, Non-HHS Costs..................... 311.4 .............. 124.6 ..............
----------------------------------------------------------------------------------------------------------------
6..................... OCR Enforcement......... 0.9 N/A 0.9 N/A
----------------------------------------------------------------------------------------------------------------
Total................................... 312.3 .............. 125.5 ..............
----------------------------------------------------------------------------------------------------------------
Familiarization Costs
The Department estimates that all persons and entities subject to
the proposed rule would spend approximately one hour on average
familiarizing themselves with the content of the proposed rule and its
requirements. One fundamental reason that the Department publishes this
proposed rule is the lack of awareness of obligations under Federal
health care conscience and associated anti-discrimination laws and
individuals' rights. This burden is a one-time opportunity cost of
staff time to review the proposed rule. The mean hourly wage (including
benefits and overhead) for a lawyer (occupation code 23-1011) is
$134.50 per hour ($67.25 per hour x 2).\155\ The labor cost is
approximately $62.9 million in the first year ($134.50 per hour x 1
hour x 468,123 entities) and zero dollars in the out-years.
---------------------------------------------------------------------------
\155\ Bureau of Labor Statistics, Occupational and Employment
Statistics, Occupational Employment and Wages, May 2016, https://www.bls.gov/oes/current/oes_nat.htm.
---------------------------------------------------------------------------
Assurance and Certification (Proposed Sec. 88.4)
The burden for the assurance and certification is the opportunity
cost of
[[Page 3913]]
recipient staff time (1) to review the HHS-690 Form (assurance), and
HHS-5161-1 Form (certification language) as well as the requirements of
the underlying Federal health care conscience and associated anti-
discrimination laws referenced or incorporated, (2) to review
recipient-wide policies and procedures or take other actions to self-
assess compliance with applicable Federal health care conscience and
associated anti-discrimination laws, and (3) to implement any actions
necessary to come into compliance. Examples of actions a recipient may
need to take to come into compliance include updating policies and
procedures, implementing staffing or scheduling practices that respect
an exercise of conscience rights under Federal law, and training staff
on relevant Federal laws or the recipient's policies and procedures.
Table 5 infra summarizes these costs.
The Department estimates that each recipient not excepted will
spend an average of 4 hours reviewing the assurance and certification
language as well as the requirements of the underlying Federal health
care conscience and associated anti-discrimination laws referenced or
incorporated through a Web link. In the 2008 Rule, the Department
estimated that it would take 30 minutes to certify compliance with
three laws: The Church, Weldon, and Coats-Snowe Amendments. 73 FR
78072, 78095 (2008 Rule). In this proposed rule, there are almost two
dozen additional laws included. Using the rough guide of 10 minutes per
law, the Department estimates that it would take an additional 3.5
hours on average to review the applicability of the additional laws
that this rule proposes to enforce, for a total burden of 4 hours per
recipient, per year, for the first five years. Some recipients may
spend considerably less time; others may spend considerably more time.
The labor cost is a function of a lawyer spending 3 hours reviewing
the assurance and certification and a chief executive spending one hour
to review and sign, as proposed Sec. 88.4(b)(2) requires a signature
by an individual authorized to bind the recipient. The mean hourly wage
(including benefits and overhead) for these occupations is $134.50 per
hour for the lawyer (occupation code 23-1011) ($67.25 per hour x 2) and
$186.88 for the chief executive (occupation code 11-1011) ($93.44 per
hour x 2).\156\ The weighted mean hourly wage (including benefits and
overhead) of these two occupations is $147.60 per hour ((134.50 x .75)
+ (186.88 x .25)). The labor cost is $72.8 million each year for the
first five years ($147.60 per hour x 4 hours x 123,302 entities).
---------------------------------------------------------------------------
\156\ Bureau of Labor Statistics, Occupational and Employment
Statistics, Occupational Employment and Wages, May 2016, https://www.bls.gov/oes/current/oes_nat.htm.
---------------------------------------------------------------------------
The Department estimates that 61,652 recipients, which is half of
all recipients required to assure and certify compliance (123,302
entities/2) will review policies and procedures or take other actions
to self-assess compliance with applicable Federal health care
conscience and associated anti-discrimination laws each year for the
first five years of publication. The Department reasonably estimates
such action because Sec. 88.4(c)(4) states that the submission of an
assurance and certification will not relieve a recipient of the
obligation to take and complete actions to come into compliance prior
to or after submission of such assurance or certification. The first
step to such actions is reviewing organization-wide safeguards that
are, or should be, in place.
The Department estimates that recipients that review policies and
procedures or otherwise self-assess compliance will spend an average of
4 hours doing so. Some entities will spend more time and others will
spend less time. The labor cost is a function of a lawyer spending 3
hours and a chief executive spending one hour, which produces the
weighted mean hourly wage of $147.60 per hour. The labor cost for self-
assessing compliance, such as reviewing policies and procedures, is a
total of $36.4 million each year for the first five years ($147.60 per
hour x 4 hours x 61,652 entities).
The Department estimates that approximately 5% of entities will
take an organization-wide action to improve compliance in the first
year and 0.5% will take a similar action annually each year in years
two through five. This percentage equates to 23,406 recipients in year
1 and 2,341 recipients annually in years two through five. The
Department estimates that these recipients would spend 4 hours
annually, on average, to take remedial efforts. The Department
estimates that recipients will spend an average of 4 hours to update
policies and procedures, implement staffing or scheduling practices
that respect an exercise of conscience rights under Federal law, or
train staff on relevant Federal law or the recipient's policies and
procedures. The labor cost is a function of a lawyer spending 3 hours
and a chief executive spending one hour, which produces a weighted mean
hourly wage of $147.60 per hour. The labor cost is $13.8 million in
year one ($147.60 per hour x 4 hours x 23,406 entities) and
approximately $1.4 million annually for years two through five ($147.60
per hour x 4 hours x 2,341 entities).
The Department is committed to leveraging existing grant, contract,
and other Departmental forms where possible rather than creating
additional, separate forms for recipients to sign. Sub-recipients are
not subject to this requirement; as described in the preamble, the
Department seeks comment on this approach taken to reduce burden on
small entities.
Table 5--Summary of Assurance and Certification Costs
----------------------------------------------------------------------------------------------------------------
Year 1: Initial costs Years 2-5: recurring costs
---------------------------------------------------------------
Cost categories Total cost Per entity Total cost Per entity
---------------------------------------------------------------
(in millions) (dollars) (in millions) (dollars)
----------------------------------------------------------------------------------------------------------------
Review and Sign................................. $72.8 $590 $72.8 $590
Review Policies and Procedures.................. 36.4 590 36.4 590
Update Policies and Procedures; Train Workforce. 13.8 590 1.4 590
---------------------------------------------------------------
Total Costs................................. 123.0 998 110.6 897
----------------------------------------------------------------------------------------------------------------
[[Page 3914]]
Notice Requirement (Proposed Sec. 88.5)
Proposed Sec. 88.5 requires recipients and the Department to
provide notice. Section 88.5 includes a mandatory posting requirement
and incentives additional posting. The mandatory posting requirement is
a one-time burden with no recurring costs. The Department does not
intend for recipients to incur any costs in developing the notice;
indeed, proposed Sec. 88.5 would require recipients to post the text
of the notice in appendix A to this proposed part. This approach
leverages economies of scale by requiring recipients to post the exact
text from the notice in Appendix A. The Department is mindful that
Executive Order 13562 asks agencies, if feasible, to specify
performance objectives for persons and entities rather than the
behavior or manner of compliance. The Department has determined that
providing a pre-written notice is the most efficient and effective way
to provide information to persons, entities, and health care entities
while reducing the burden on a recipient. The Department acknowledges
that the trade-off regarding this approach is that it limits a
recipient's flexibility. On the other hand, the decreased flexibility
may be a worthwhile trade-off because, with a pre-written notice from
OCR, a recipient need not spend time with counsel or executives in
developing the text.
The Department estimates that the burden for the notice is
represented in terms of opportunity costs of staff time to download,
print, and post the notice, combined with material costs for paper and
ink. These costs are a one-time, upfront burden in the first year of
implementation. The Department estimates that it will take \1/3\ of an
hour for an administrative assistant to download the notice, print
notice(s) and post them in physical locations of the establishment
where notices are commonly posted. To post the notice on the Web, the
Department estimates that it will take 2 hours for a Web developer to
execute the design and technical elements to post the notice online.
For some establishments, it may take an administrative assistant or Web
developer longer to perform this function; for other establishments, it
may take less time. The mean hourly wage (including benefits and
overhead) for an administrative assistant is $38.78 per hour
(occupation code 43-6010) ($19.39 per hour x 2).\157\ The mean hourly
wage (including benefits and overhead) for a Web developer is $69.38
per hour (occupation code 15-11134) ($34.69 per hour x 2).\158\ This
labor cost is approximately $92.7 million ((\1/3\ hr. x $38.78 per hour
x 611,372 establishments) + (2 hours x $63.38 per hour x 611,372
establishments)).
---------------------------------------------------------------------------
\157\ Bureau of Labor Statistics, Occupational and Employment
Statistics, Occupational Employment and Wages, May 2016, https://www.bls.gov/oes/current/oes_nat.htm.
\158\ Id.
---------------------------------------------------------------------------
A key uncertainty with respect to this labor cost is the degree to
which each establishment maintains its own website and thus would bear
the labor cost for a Web developer to post the notice on the
establishment's website. For the purpose of this RIA, the Department
has erred on the side of overestimating the burden. Therefore, the
Department assumed that a Web developer at each physical location will
spend 2 hours to post the notice.
If, however, recipients maintain one website for all of its
establishments, a Web developer at the firm-level, rather than Web
developers at each establishment, would bear the labor costs to post
the notice online. In contrast to 611,372 establishments bearing the
labor costs of the Web developer, about 464,792 recipients at the firm-
level would bear this cost. This number results from subtracting 3,324
counties from the total number of entities on average subject to the
NPRM (468,026 entities). For the purpose of this calculation, the
Department assumed all counties are sub-recipients.
The labor costs are the sum of (1) the costs for an administrative
assistant at each establishment to post the notice in physical
locations (\1/3\ hr. x $38.78 per hour x 611,372 establishments) and
(2) the costs for a Web developer at each firm to post the notice on
the entity's website (2 hours x $63.38 per hour x 464,792), which
equals $72.4 million. This labor cost is $20 million less, or
approximately 22% less, than the labor cost of a Web developer at each
establishment of a recipient, rather than at the firm-level, to post
the notice on the websites of each recipient establishment.
Another key uncertainty with respect to the estimated burden of the
notice requirement is the number of locations where notices are
commonly posted in an establishment; the number will vary based on
multiple factors. These factors may include the type of recipient,
floor plans of the building, the square footage of the common areas,
the square footage of the building, the number of floors, the size of
the workforce, and the number of ultimate beneficiaries, among other
variables. The Department assumes that the average establishment will
print and post five notices; larger entities might post more and
smaller entities post fewer. The Department also assumes that the cost
of materials (paper and ink) is $0.05 per page. Based on this
assumption, the first-year cost to post 5 notices across all
establishments would be $152,843 (611,372 establishments x $.05 per
page x 5 pages). Because the Department assumes that this cost is a
one-time cost during the first year of this proposed rule's
implementation, the cost will not recur in years 2 through 5. The total
labor and materials costs for implementing the mandatory component of
the notice requirement is $8 million ($7.9 million in labor costs and
$152,843 for materials) in year one with zero recurring costs.
Because societal goals for assuring nondiscrimination are often
realized through individuals' persistent exercise of protected rights,
this proposed rule's notice requirement serves as a gateway to achieve
those goals. Section 88.5 intends to incentivize recipients to include
the OCR-drafted notice in certain types of documents or publications by
rendering such posting as a factor that the OCR Director would consider
if the Director investigates or initiates a compliance review of a
recipient.
For instance, OCR would take into account whether a recipient has
provided the notice in a personnel manual for the recipient's
workforce, in applications for membership in the recipient's workforce
or to receive a service or benefit, or in a student handbook for
students participating in a program for training or study. Because this
provision is permissive, the Department assumes that 305,686
establishments will undertake such action in the first year, which is
half of all establishments subject to the notice requirement (611,372
establishments x 50%). Approximately 152,843 establishments (305,686
establishments/2) will annually undertake such voluntary posting in
years 2 through 5. The Department assumes that an administrative
assistant paid at $19.39/hour would identify documents in which to
include the notice, revising the documents or their layouts to include
the notice, or otherwise printing an insert to include with paper
documents. The assistant may spend a total of 2 hours in year one and 1
hour annually in years 2 through 5. The labor cost, adjusted upward for
benefits and overhead is $23.7 million (2 x $19.39 per hour x 2 hours x
305,686 establishments) in year one and $5.9 million annually in years
2 through 5 (2 x $19.39 x 1 x 152,843 establishments).
The Department anticipates that there may be some additional
printing costs
[[Page 3915]]
where inclusion of the notice adds a page to the underlying document.
There is a high degree of uncertainty as to the average number of
documents in which a recipient may proactively include the notice.
There is also uncertainty as to whether a recipient would provide hard-
copy publications or house them online.
A recipient that voluntarily includes the notice in certain
publications probably would provide some in hard-copy and others
online. On balance, a recipient might print approximately 100 extra
pages. Given these assumptions, the cost of voluntarily included
notices, as proposed Sec. 88.5(c) incentivizes, will cost
approximately $1.5 million in the first year (305,686 entities x 100
pages x $.05 per page) and $764,215 annually in years two through five.
In sum, total first-year costs to implement the mandatory and
voluntary components of the notice requirement is estimated at $118.1
million and $6.7 million annually in years 2 through 5, which is a 94%
decrease in cost from the one-time cost to implement the notice
requirement in year 1.
Compliance Procedures (Sec. 88.6(d))
The information promptly informs applicable Departmental components
of OCR's pending investigation to ensure appropriate coordination
within the Department during the pendency of the investigation and the
obligation to report complaints if the Department modifies existing
applications for grants, or in a separate writing with the
applications, for five years. OCR estimates that there are 30
recipients on average per year that OCR may investigate and
investigate. Thirty recipients is the average between the lower-bound
estimate (10 recipients) and the upper-bound estimate (50 recipients).
The Department estimates that the burden is the opportunity cost
that recipients and sub-recipients would incur to email the appropriate
grants management official(s). The Department assumes that this email
would inform the Department component and could also be used as the
separate writing to accompany new or renewed applications. This burden
is the labor cost associated with an administrative assistant spending
approximately 15 minutes to draft and transmit the email. The mean
hourly wage for the administrative assistant (occupation code 43-6010)
($19.39 per hour) (adjusted for benefits and overhead) is $38.78 per
hour. The Department estimates that the administrative assistant would
incur this labor cost for each award action for which the recipients
applied, including new funding opportunities, supplemental funding, and
non-competing continuations, among others.
Because OCR had no publicly available and reliable data source to
know how many total applications for new or renewed funding in a fiscal
year a recipient might make to the Department or its component, OCR
used actual award data from HHS TAGGS as a proxy. The Department looked
at the number of award actions the Department and its components made
to State agencies and State universities in FY 2017 to inform the
estimate. Award data in HHS TAGGS for FY 2017 indicated that some State
universities receive less than 100 awards per fiscal year and others
receive nearly 2,000 awards. Some State agencies receive a couple of
awards per fiscal year and others receive 80 awards per fiscal year.
The Department erred on the side of overestimating the burden and
assumed that each of the 30 recipients would apply for new or renewed
funding 2,000 times per year. The annual labor cost is $0.6 million
across all 30 entities (30 recipients x $39.78 per hour x 0.25 hours x
2,000).
Voluntary Remedial Efforts
The Department anticipates that some recipients will institute a
grievance or similar process to handle internal complaints raised to
the recipient's or sub-recipient's attention. The proposed rule does
not require such a process, but in HHS OCR's enforcement experience,
informal resolution of matters at the recipient or sub-recipient level
may effectively resolve a beneficiary's or employee's concern. The
Department anticipates 0.5% of entities, or 2,340 recipients or sub-
recipients, (0.005 x 468,026 recipients), would conduct such internal
investigations should complaints come to the recipient's or sub-
recipient's attention or undertake remedial efforts.
The burden is the opportunity cost of staff time to handle internal
investigations and take remedial action. Uncertainty exists as to how
many hours annually a recipient or sub-recipient would devote to this
effort per year. On average, the Department anticipates entities
spending 20 hours annually: 16 hours of a lawyer's time and 4 hours of
a chief executive's time. The mean hourly wage (including benefits and
overhead) for these occupations is $134.50 per hour for the lawyer
(occupation code 23-1011) ($67.25 per hour x 2 to adjust upward for
benefits and overhead) and $186.88 for the chief executive (occupation
code 11-1011) ($93.44 per hour x 2 to adjust upward for benefits and
overhead).\159\ The weighted mean hourly wage (including benefits and
overhead) is $72.49 per hour (($67.25 x .80) + ($93.44 x .20)). The
labor cost is $6.8 million ($144.98 per hour x 20 hours x 2,341
entities).
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\159\ Bureau of Labor Statistics, Occupational and Employment
Statistics, Occupational Employment and Wages, May 2016, https://www.bls.gov/oes/current/oes_nat.htm.
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Some recipients may spend more than 20 hours, and if this is the
case, the labor cost will be greater. Other recipients may spend less
than 20 hours, and if this is the case, the labor cost will be lower.
OCR Enforcement
The Department anticipates a temporary increase in investigation
and enforcement costs to OCR over the five years immediately following
publication of the final rule. The Department expects this increase
from the synergistic impact of persons' increased awareness of rights;
increased confidence in the Department to address those rights through
the administrative complaint process; and an increase in the number of
Federal health care conscience and associated anti-discrimination laws
for which the rule proposes to enforce. The Department expects that
after 5 years following publication of the final rule, the number of
complaints probably will plateau, but uncertainty exists in this
estimated timeframe. The Department hopes that over time, recipients'
awareness of their obligations will equate to fewer violations of law
and consequently fewer complaints to OCR to address such violations.
OCR will bear the increased cost in the form of the opportunity
cost of staff resources for enforcement. In the first five years
following publication of the rule, the Department anticipates that the
impact of this proposed rule on enforcement is equivalent to an
additional 4.5 FTE. The fully loaded labor cost (which includes
benefits and overhead) is about $201,000 per FTE. With these variables,
the Department expects OCR's staff costs would increase by
$904,500annually in years one through five (4.5 FTE x $201,000/FTE).
Request for Comment on Burden Analysis
The Department seeks public comment on improving the accuracy of
the best estimates contained in this RIA. To the extent that more
entities are covered or an entity spends more staff time executing or
implementing required and/or voluntary actions, the costs will be
higher than estimated.
[[Page 3916]]
Similarly, to the extent that fewer persons and entities are covered,
or an entity spends less staff time executing or implementing required
and/or voluntary actions, the costs will be lower than estimated.
In particular, the Department would appreciate comment on areas
where the public has documentation, data, or other information to
support a belief that this RIA over-estimates or under-estimates the
implementation costs. For instance, the Department assumes that
recipients and sub-recipients maintain records in the course of
evidencing compliance with the terms and conditions of a Federal award,
which would include not only financial requirements but all applicable
Federal laws, including Federal health care conscience and associated
anti-discrimination laws. Consequently, the Department has not
identified record keeping as a separate burden resulting from this
proposed rule because the Department understands that recipients and
sub-recipients must document such compliance in the course of receiving
a Federal award. To the extent that this assumption does not represent
the existing record keeping requirements or practices, please provide
comments to inform this assumption.
Moreover, the Department would appreciate information, data,
studies, reports, or other documentation to that support what costs, if
any, result from ancillary effects of this proposed rule, such as the
monetary impact of certain health outcomes that may arise from the
increase protection of conscience of medical providers as set forth in
the proposed rule.
Estimated Benefits
This proposed rule is expected to remove barriers to the entry of
certain health professionals, and to delay the exit of certain types of
health professionals from the field, due to discrimination or coercion
anticipated or experienced. Second, in supporting a more diverse
medical field, the proposed rule would create ancillary benefits for
patients. Third, the Department expects that the proposed rule would
generate benefits by securing a public good--a society free from
discrimination, which permits more personal freedom and removes
unfairness. The proposed rule would promote protection of religious
beliefs and moral convictions, which is a societal good based on
fundamental rights.
Historical Support for Conscience Protections
The people of the United States of America have valued conscience
protections since the country's founding. James Madison, the fourth
President of the United States and often hailed as the ``father of the
Constitution'' said, ``[c]onscience is the most sacred of all property;
. . . the exercise of that, being a natural and unalienable right. To
guard a man's house as his castle, to pay public and enforce private
debts with the most exact faith, can give no title to invade a man's
conscience which is more sacred than his castle.'' \160\ George
Washington wrote, ``Government being, among other purposes, instituted
to protect the Persons and Consciences of men from oppression, it
certainly is the duty of Rulers, not only to abstain from it
themselves, but according to their Stations, to prevent it in others.''
\161\ Some scholars have argued that ``[p]rotection for individual
exercise of rights of conscience was one of the essential purposes for
the founding of the United States of America and one of the great
motivations for the drafting of the Bill of Rights.'' \162\
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\160\ James Madison, Property, The Founders' Constitution (March
29, 1792), http://press-pubs.uchicago.edu/founders/documents/v1ch16s23.html.
\161\ Letter from George Washington, to The Society of Quakers
(October 13, 1789), https://founders.archives.gov/documents/Washington/05-04-02-0188.
\162\ Kevin Theriot & Ken Connelly, Free to Do No Harm:
Conscience Protections for Healthcare Professionals, 49 Ariz. St.
L.J. 549, 561 (2017).
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Recruitment and Maintenance of Health Care Professionals
This proposed rule is expected to remove barriers to the entry of
certain health professionals, and to delay the exit of certain types of
health professionals from the field, due to discrimination or coercion
anticipated or experienced. The Department has a significant interest
in removing unlawful barriers to careers in the health care field. As
numerous studies and comments establish, failure to protect conscience
is one such barrier.
A 2011 study released by the American College of Obstetrics and
Gynecology revealed that, ``while 97% of ob-gyns reported having
encountered women seeking an abortion, only 14% said they were willing
to perform the service.'' \163\ Only 1.2% of Evangelical Protestant, 9%
of Catholic or Eastern Orthodox, 10.1% of Non-Evangelical Protestant,
20% of Hindu, 26.5% with no religious affiliation, and 40.2% of Jewish
doctors said they would provide abortion.\164\ Yet one in six patients
is cared for in Catholic hospitals, and Catholic Hospitals employed
523,040 full-time and 216,487 part-time workers in 2015.\165\ Another
pro-life organization, the Christian Medical & Dental Associations
(``CMDA''), boasts 19,000 members.\166\ And the American Association of
Pro-Life Obstetricians and Gynecologists (``AAPLOG''), which boasts
2,500 members and associates,\167\ wrote in 2009, ``Like pro-life
physicians generally, AAPLOG members overwhelmingly would leave the
medical profession--or relocate to a more conscience-friendly
jurisdiction--before they would accept coercion to participate or
assist in procedures that violate their consciences.'' \168\
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\163\ Abortion is Legal, but What Percentage of Ob-Gyns Will
Provide One?, Freakonomics (August 24, 2011, 1:57 p.m.), http://freakonomics.com/2011/08/24/abortion-is-legal-but-what-percentage-of-ob-gyns-will-provide-one/.
\164\ Id.
\165\ U.S. Catholic Health Care: The Nation's Largest Group of
Not-for-Profit Health Care Providers, Catholic Health Association of
the United States (2017), available at https://www.chausa.org/docs/default-source/default-document-library/cha_2017_miniprofile.pdf?sfvrsn=0.
\166\ History of Our Ministry, Christian Medical & Dental
Associations, https://www.cmda.org/library/doclib/history-of-cmda.pdf.
\167\ About Us, American Association of Pro-Life Obstetricians
and Gynecologists, http://aaplog.org/about-us.
\168\ Letter from Lawrence J. Joseph, on behalf of the American
Association of Pro-Life Obstetricians and Gynecologists, to the
Office of Public Health & Science, Department of Health & Human
Services 2 (April 9, 2009), available at http://downloads.frc.org/EF/EF09D50.pdf.
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Protecting the conscience rights of persons, entities, and health
care entities is expected to result in the recruitment of diverse
health care professionals and the maintenance of such professionals in
the field. The medical community and American people as a whole might
also benefit from the willing and enthusiastic participation in the
field of people with a variety of moral, religious, and philosophical
backgrounds. The Department expects that its proposed rule will protect
existing participants in the profession and promote more diverse
participation over time as the institutional culture at health
facilities, and in health-professions training programs, changes.
Patient Benefits From Conscience Protections
In supporting a more diverse medical field, the proposed rule would
create ancillary benefits for patients. The proposed rule would assist
patients in seeking counselors and other health-care providers who
share their deepest
[[Page 3917]]
held convictions. Some patients will appreciate the ability to speak
frankly about their own convictions concerning questions that touch
upon life and death and treatment preferences with a doctor best suited
to provide such treatment. A pro-life woman may seek a pro-life ob-gyn
to advise her on decisions relating to her fertility and reproductive
choices. A pro-vaccination parent may seek a pediatrician who shares
his views. Open communication in the doctor-patient relationship will
foster better over-all care for patients.
The benefit of open and honest communication between a patient and
her doctor is difficult to quantify. One study showed that even ``the
quality of communication [between the physician and patient] affects
outcomes . . . [and] influences how often, and if at all, a patient
will return to that same physician.'' \169\ But poor communication
negatively affects continuity of care and undermines the patient's
health goals. When conscience protections are robust, both patients and
their physicians can communicate openly and honestly with one-another
at the outset of their relationship.
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\169\ Fallon E. Chipidza, et al., Impact of the Doctor-Patient
Relationship, 17(5) The Primary Care Companion for CNS Disorders
(2015), available at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4732308/.
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Facilitating open communication between providers and their
patients also helps to eliminate barriers to care, particularly for
minorities. Because positions of conscience are often grounded in
religious influence, ``[d]enying the aspect of spirituality and
religion for some patients can act as a barrier. These influences can
greatly affect the well-being of people. These influences were reported
to be an essential element in the lives of certain migrant women which
enabled them to face life with a sense of equality.'' \170\ It is
important for patients seeking care to feel assured that their faith,
and the principles of conscience grounded in their faith, will be
honored. This will ensure that they feel they are being treated
fairly.\171\ And for some, being able to find health care providers
that share the same moral convictions can be a source of personal
healing. See Gonzales v. Carhart, 550 U.S. 124, 159 (2007) (``Respect
for human life finds an ultimate expression in the bond of love the
mother has for her child. . . . it seems unexceptionable to conclude
some women come to regret their choice to abort the infant life they
once created and sustained.''). The patient benefits that will accrue
from respect for provider conscience protections may take time to
develop, but the Department anticipates that such benefits will be
individualized and long-lasting.
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\170\ Emmanuel Scheppers, et al., Potential Barriers to the Use
of Health Services Among Ethnic Minorities: A Review, 23 Family
Practice 325, 343 (2006), available at https://academic.oup.com/fampra/article/23/3/325/475515.
\171\ Id.
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Societal Benefits From Conscience Protections
The proposed rule will also yield lasting societal benefits. The
rule will mitigate current misunderstanding about what conduct the
Federal government is legally able to support and fund, and it will
educate individuals about their Federal health care conscience rights.
The proposed rule would provide an enforcement mechanism for
individuals and institutions to file complaints with the Department
when such individuals and institutions believe that their rights have
been curtailed. The Department expects that, as a result of this
proposed rule, more individuals, having been apprised of those rights,
would assert them, and such assertions would contribute to the general
public's knowledge and appreciation of these protections.
Fostering respect for the existing Federal health care conscience
and associated anti-discrimination laws also fosters lawfulness more
generally. As one author stated,
[L]aw and conscience are deeply intertwined. . . . But the
phenomenon of conscience isn't important only to legal experts. Just
as conscience helps explain why people follow legal rules, it helps
explain why people follow other types of rules as well, such as
employers' rules for employees, parents' rules for children, and
schools' and universities' rules for students. It may also help
explain why people adhere to difficult-to-enforce ethical rules and
to the sorts of cultural rules (``social norms'') that make communal
life bearable. . . . Twenty-first century Americans still enjoy a
remarkably cooperative, law-abiding culture.\172\
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\172\ Lynn Stout, Cultivating Conscience: How Good Laws Make
Good People 17 (2011).
Because fostering conscience in individuals contributes to a more
lawful and virtuous society, governments and their subdivisions have a
significant interest in encouraging expressions of, and fidelity to,
conscience. Governments also have an interest in ensuring the
implementation and enforcement of existing laws, as part of the greater
virtue of the rule of law.
It is difficult to monetize the respect for conscience to the
individual and society as a whole, but the benefit is clearly
significant. As the Supreme Court has said:
Both morals and sound policy require that the state should not
violate the conscience of the individual. All our history gives
confirmation to the view that liberty of conscience has a moral and
social value which makes it worthy of preservation at the hands of
the state. So deep in its significance and vital, indeed, is it to
the integrity of man's moral and spiritual nature that nothing short
of the self-preservation of the state should warrant its violation;
and it may well be questioned whether the state which preserves its
life by a settled policy of violation of the conscience of the
individual will not in fact ultimately lose it by the process.
United States v. Seeger, 380 U.S. 163, 169 (1965) quoting Harlan
Fisk Stone, The Conscientious Objector, 21 Col. Univ. Q. 253, 269
(1919).
The Department seeks comment regarding the benefits of this
proposed rule, and how they might be quantified or monetized and
specifically seeks supporting data, studies, reports, or other
documentation.
Analysis of Regulatory Alternatives
The Department carefully considered alternatives to this proposed
rule, but concluded that none struck the appropriate balance between
the Administration's goal of robust enforcement of existing Federal
statutory protections for conscience in the health care field without
unduly burdening entities in that field.
First, the Department considered maintaining the status quo,
enforcing part 88 as it current exists and largely deferring to States
to enact and enforce their respective conscience laws, but such an
approach would create a significant risk of unaddressed violations of
the conscience rights of persons, entities, and health care entities.
Specifically, it would leave OCR's minimal administrative enforcement
scheme as the only remedy for alleged violations of the Weldon, Coats-
Snowe or Church Amendments. See supra Part VI (reasons for the proposed
rule). That minimalistic scheme, so different from those that pertain
to other civil rights laws, undermines both OCR's authority and public
perception of the value of these protections. And it fails to allow for
strategic coordination with respect to the compliance and enforcement
of the many Federal health care conscience and associated anti-
discrimination protections that exist outside the Weldon, Coats-Snowe
or Church Amendments.
Second, the Department also considered alternative approaches to
the policies enunciated in the proposed rule. The Department considered
developing a rule that specifies
[[Page 3918]]
performance objectives rather than the manner of compliance to allow
persons and entities more flexibility. For instance, instead of
providing the text of a notice in Appendix A for recipients to post,
the Department considered allowing recipients to develop the text of
their own notices, so long as such notices achieved certain substantive
objectives. But the Department was sensitive to the time it might take
each entity to draft a notice and to obtain the proper legal
consultation and executive sign-off. In lieu of requiring, or
permitting, each entity to re-create the wheel, the Department proposes
that entities use the notice in Appendix A to reduce burden. The
Department also considered requiring fewer recipients to execute the
assurance and certify compliance, and/or to post notices of
individuals' conscience and anti-coercion rights and the recipients'
corresponding obligations.
The Department invites comment on our proposed approach, as well as
other approaches to achieve robust enforcement of Federal health care
conscience laws with minimal regulatory burden.
Executive Order 13771
Executive Order 13771 (January 30, 2017) requires that the costs
associated with significant new regulations ``to the extent permitted
by law, be offset by the elimination of existing costs associated with
at least two prior regulations.'' The Department believes that this
proposed rule is a significant regulatory action as defined by
Executive Order 12866. If this rule is finalized as proposed, it would
be considered a regulatory action under Executive Order 13771.
Excluding any ancillary costs attributed to this proposed rule that
result from health outcomes or other effects of protecting conscience
rights (as this RIA seeks comment on such costs, which have not yet
been quantified), the Department estimates that this rule generates
$112 million in annualized costs at a 7% discount rate, discounted
relative to year 2016, over a perpetual time horizon.
Regulatory Flexibility Act
HHS has examined the economic implications of this proposed rule as
required by the Regulatory Flexibility Act (RFA) (5 U.S.C. 601-612).
The RFA requires an agency to describe the impact of a proposed
rulemaking on small entities by providing an initial regulatory
flexibility analysis unless the agency expects that the proposed rule
will not have a significant impact on a substantial number of small
entities, provides a factual basis for this determination, and proposes
to certify the statement. 5 U.S.C. 603(a), 605(b). If an agency must
provide an initial regulatory flexibility analysis, this analysis must
address the consideration of regulatory options that would lessen the
economic effect of the rule on small entities. For purposes of the RFA,
small entities include small businesses, nonprofit organizations, and
small governmental jurisdictions. HHS considers a rule to have a
significant impact on a substantial number of small entities if it has
at least a three percent impact of revenue on at least five percent of
small entities.
Based on its examination, the Department has preliminarily
concluded that this proposed rule does not have a significant economic
impact on a substantial number of small entities. The entities that
would be affected by the proposed rule, in industries described in
detail in the RIA, are considered small by virtue of either nonprofit
status or having revenues of less than between $7.5 million and $38.5
million in average annual revenue, with the threshold varying by
industry.\173\ Persons and States are not included in the definition of
a small entity. The Department assumes that most, if not all, of the
entities affected meet the threshold of a small entity.
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\173\ https://www.sba.gov/sites/default/files/files/Size_Standards_Table_2017.pdf.
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Although the proposed rule will apply to and thus affect small
entities, the proposed rule's per-entity effects are relatively small.
The Department estimates that this rule would impose an average cost of
$665 in the first year of compliance following publication of the final
rule and about $266 per year in subsequent years. Furthermore, these
costs would generally be proportional to the size of an entity,
suggesting that the smallest affected entities will face lower average
costs. Given thresholds discussed above, we believe these average costs
are well below those required to have a significant impact on a
substantial number of small entities.
Despite this determination, the proposed rule attempts to minimize
costs imposed on small entities. For example, the assurance and
certification requirements in proposed Sec. 88.4 contain exceptions to
relieve many small entities of the requirement to submit an assurance
and certification. The Department has further committed to leveraging
existing grant, contract, and other Departmental forms where possible
to implement Sec. 88.4 rather than create additional, separate forms
for recipients to sign. Similarly, in an effort to reduce economic
burden imposed by the notice requirements in proposed Sec. 88.5, HHS
has drafted a notice in Appendix A for recipients to use so that the
recipients do not have to bear the labor costs of consulting with
counsel and executives. In light of this determination, the Secretary
proposed to certify that this rule will not result in a significant
impact on a substantial number of small entities.
Unfunded Mandates Reform Act
HHS similarly concludes that the requirements of the Unfunded
Mandates Reform Act of 1995 are not triggered by the proposed rule.
Section 202(a) of that Act requires us to prepare a written statement,
including an assessment of anticipated costs and benefits, before
issuing ``any rule that includes any Federal mandate that may result in
the expenditure by State, local, and tribal governments, in the
aggregate, or by the private sector, of $100,000,000 or more (adjusted
annually for inflation) in any one year.'' The current threshold after
adjustment for inflation is $148 million, using the most current (2016)
Implicit Price Deflator for the Gross Domestic Product. As discussed in
this Regulatory Impact Analysis, if finalized as proposed, this rule
would not result in an expenditure in any year that meets or exceeds
that amount with regard to State, local, or tribal governments but will
exceed that amount with regard to the private sector.
Executive Order 13132--Federalism
The Secretary has also preliminarily determined that this proposed
rule does not implicate the requirements of Executive Order 13132. That
Executive Order requires an agency to meet certain requirements when it
promulgates a proposed rule (and subsequent final rule) that imposes
substantial direct effects on (1) States, including political
subdivisions thereof, (2) the relationship between the Federal
government and the States, or (3) the distribution of power and
responsibilities among the various levels of government. Although this
rulemaking is expected to affect State and local governments, the
anticipated affect is not substantial.
First, this rulemaking does not impose substantial direct effects
on States or political subdivisions of States. The substantive
prohibitions and requirements in Federal health care conscience and
associated anti-discrimination laws already apply to State and local
governments. Moreover, State and local government agencies who are
recipients of HHS awards must already assure compliance with applicable
Federal laws and certify
[[Page 3919]]
compliance with them in the normal course of receiving such awards. And
although proposed Sec. 88.5 imposes a new requirement to post a notice
about rights and obligations under Federal health care conscience and
associated anti-discrimination laws, this requirement involves a
minimal one-time opportunity cost on staff time, attaches only to
recipients, and is similar to notice requirements already in force for
other civil rights laws. Under such circumstances, the notice
requirement cannot be understood to impose substantial direct effects
on States or their political subdivisions.
Second, this proposed rulemaking does not have substantial direct
effects on the relationship between the Federal government and the
States. The proposed rule would be promulgated under longstanding
Federal laws that leave room for State activity. For example, 42 U.S.C.
280g-1(d) authorizes the Department to provide grants and cooperative
agreements for newborn and infant hearing screening, but makes clear
that such grants do not preempt or prohibit any State law, including
State laws that allow parents to assert religious objections to such
screening. Similarly, 42 U.S.C. 1396f clarifies that nothing in that
subchapter shall be construed to require a State to compel a person to
undergo medical screenings, examination, diagnosis, treatment, health
care or services if a person objects on religious grounds (except for
discovering and preventing the spread of infection or contagious
disease or protecting environmental health). And the requirement in 42
U.S.C. 1396s(c)(2)(B)(ii) for providers to offer pediatric vaccines is
subject to applicable State law, including any law relating to any
religious or other exemption. Given these provisions, it is no surprise
that, as described supra, in Part VIII, all fifty States have some
protections in place for conscientious objectors to certain health or
medical services.\174\
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\174\ See Kevin Theriot & Ken Connelly, Free to Do No Harm:
Conscience Protections for Healthcare Professionals, 49 Ariz. St.
L.J. 549, 575-76, app. I, 587-600 (2017) (summarizing State laws).
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The proposed rule makes clear that it is not intended to interfere
with the operation of State law, except as required by existing Federal
health conscience protections. Thus, proposed Sec. 88.8 states that
this proposed rule does not preempt any Federal, State, or local law
that is equally as protective of the rights of conscience and against
coercion as the regulation. And the proposed Sec. 88.7 borrows from
enforcement mechanisms already available to OCR to enforce similar
civil rights laws. States are familiar with such mechanisms from
decades of investigations, compliance reviews, and remedial actions
taken pursuant to existing civil rights laws (e.g. Title VI, Section
504 of the Rehabilitation Act, and Title II of the Americans with
Disabilities Act). HHS believes that this approach does not alter or
have any substantial direct effects on the relationship between the
Federal government and the States.
The Department invites comments from States and local governments
on whether provisions of this proposed rule implicate federalism
concerns not identified and ways to minimize any such burden,
consistent with meeting the Department's objectives of ensuring (1)
knowledge of the obligations imposed, and the rights and protections
afforded, by Federal health care conscience and associated anti-
discrimination laws; and (2) compliance with their nondiscrimination
provisions.
Congressional Review Act
The Congressional Review Act defines a ``major rule'' as ``any rule
that the Administrator of the Office of Information and Regulatory
Affairs (OIRA) of the Office of Management and Budget finds has
resulted in or is likely to result in--(A) an annual effect on the
economy of $100,000,000 or more; (B) a major increase in costs or
prices for consumers, individual industries, Federal, State, or local
government agencies, or geographic regions; or (C) significant adverse
effects on competition, employment, investment, productivity,
innovation, or on the ability of United States-based enterprises to
compete with foreign-based enterprises in domestic and export
markets.'' 5 U.S.C. 804(2). Based on the analysis of this proposed rule
under Executive Order 12866, the Department deems that this proposed
rule is a major rule for purposes of the Congressional Review Act.
Assessment of Federal Regulation and Policies on Families
Section 654 of the Treasury and General Government Appropriations
Act of 1999, Pub. L. 105-277, section 654, 112 Stat. 2681 (1998)
(codified at 5 U.S.C. 601 (note)), requires Federal departments and
agencies to determine whether a proposed policy or regulation could
affect family well-being.\175\
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\175\ This section discusses the assessment required in
Executive Order 12606, The Family, which was revoked on April 21,
1997. Memorandum from Jacob Lew, Dir., Office Of Mgmt. & Budget,
Exec. Office of the President, To Heads of Exec. Dep'ts, Agencies, &
Independent Establishments Assessment of Federal Regulations and
Policies on Families (Jan. 26, 1999) https://www.fws.gov/policy/library/rglew.pdf.
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Agencies must assess whether the proposed regulatory action: (1)
Impacts the stability or safety of the family, particularly in terms of
marital commitment; (2) impacts the authority of parents in the
education, nurture, and supervision of their children; (3) helps the
family perform its functions; (4) affects disposable income or poverty
of families and children; (5) if the regulatory action financially
impacts families, are justified; (6) may be carried out by State or
local government or by the family; and (7) establishes a policy
concerning the relationship between the behavior and personal
responsibility of youth and the norms of society.\176\
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\176\ Treasury and General Government Appropriations Act of
1999, Public Law 105-277, sec. 654, 112 Stat. 2681 (1998).
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It is unlikely that this proposed rule will negatively impact the
stability of the family or impact parental authority. In addition, the
proposed rule has no bearing on the disposable income or poverty of
families and children, and none of the rule's proposed provisions
concern the relationship between the behavior and personal
responsibility of youth and the norms of society. Finally, the action
taken in this proposed rule cannot be carried out by State or local
government or by the family because the rule pertains to the
enforcement of certain Federal laws. Therefore, this proposed rule
probably will have minimal to no impact on family well-being.
If the determination is affirmative, then the Department or agency
must prepare an impact assessment to address criteria specified in the
law. The Secretary proposes to certify that this proposed rule has been
assessed in accordance with Section 654 of the Treasury and General
Government Appropriations Act of 1999, Public Law 105-277, section 654,
112 Stat. 2681 (1998), and will not negatively affect family well-
being.
Paperwork Reduction Act
This notice of proposed rulemaking would call for new collections
of information under the Paperwork Reduction Act of 1995 (44 U.S.C.
3501-3520). Congress enacted the Paperwork Reduction Act of 1995 to
``maximize the practical utility and public benefit of the information
created, collected, disclosed, maintained, used, shared and
disseminated by or for the Federal government'' and to minimize the
burden of this collection. 44 U.S.C. 3501(2). As defined in 5 CFR
1320.3(c),
[[Page 3920]]
``collection of information'' comprises reporting, record-keeping,
monitoring, posting, labeling, and other similar actions.
The collections of information required by the proposed rule relate
to Sec. 88.4 (Assurance and Certification), Sec. 88.5 (Notice), and
Sec. 88.6(d) (Compliance Requirements).
Information Collection for Proposed Sec. 88.4 (Assurance and
Certification)
Summary of the Collection of Information: The proposed rule
requires each recipient (or applicant to become a recipient), with
limited exception, to assure and certify compliance with Federal
conscience and associated anti-discrimination laws. Specifically,
proposed Sec. 88.4(a) requires each recipient or applicant to include
in its application for Federal funds, or accompany its application
with, an assurance and a certification that it will operate applicable
projects or programs in compliance with applicable Federal health care
conscience and associated anti-discrimination laws. The Federal laws
with which recipients would be required to assure compliance, if
applicable, are:
Provider conscience laws related to abortion (the Weldon Amendment
for Medicare Advantage, e.g. Public Law 115-31, Div. H, sec. 209, 131
Stat. 135, 539 (2017));
Certain provisions of the Affordable Care Act applying Federal
conscience protections (42 U.S.C. 18023(b)(4)), regarding assisted
suicide (42 U.S.C. 18113), and providing a conscience exemption to the
individual mandate (26 U.S.C. 5000A(d)(2));
Certain laws governing provider counseling, referral, and
implementation of directives (counseling and referral in Medicare
Advantage ((42 U.S.C. 1395w-22(j)(3)(B)), counseling and referral in
Medicaid (42 U.S.C. 1396u-2(b)(3)(B)), and performance of advanced
directives in the Medicare and Medicaid programs (42 U.S.C.
1396a(w)(3), and 14406);
Conscience and anti-coercion laws applicable to Global Health
Programs for HIV/AIDS Prevention, Treatment, or Care (22 U.S.C.
7631(d)) and certain funds appropriated to the U.S. Department of State
and USAID (the Helms Amendment (e.g., Consolidated Appropriations Act,
2017, Public Law 115-31, Div. J, sec. 7018));
Laws providing for patient objections to receiving health care
services, including medical screening, examination, diagnosis,
treatment, or other health care (42 U.S.C. 1396f), occupational illness
testing (29 U.S.C. 669(a)(5)), pediatric vaccination (42 U.S.C.
1396s(c)(2)(B)(ii)), youth suicide prevention and treatment (42 U.S.C.
290bb-36(f)), and newborn health screening (42 U.S.C. 280g-1(d)); and
Laws protecting religious nonmedical health care by exempting
religious non-medical institutions from health facility review (42
U.S.C. 1320a-1), peer review (42 U.S.C. 1320c-11), certain health
standards (42 U.S.C. 1396a(a)(9)(A)), medical evaluation (42 U.S.C.
1396a(a)(31)), medical licensing review (42 U.S.C. 1396a(a)(33)), and
from utilization review plan requirements (42 U.S.C. 1396b(i)(4)), and
protecting the exercise of religious nonmedical health care in the
Elder Justice Block Grant Program (42 U.S.C. 1397j-1(b)) and in the
Child Abuse Prevention and Treatment Act (42 U.S.C. 5106i(a)(2)).
Need for Information: Requiring certain recipients and applicants
to assure and certify compliance serves two purposes. First, through
the act of reading and reviewing the statutory requirements to which
recipients or applicants assure and certify compliance, recipients
would be apprised of their obligations under the applicable Federal
health care conscience and associated anti-discrimination laws. Second,
a recipient's or applicant's awareness of its obligation would increase
the likelihood that it would comply with such laws and consequently
afford entities and individuals protection of their conscience rights
and protection from coercion or discrimination. Because of this
awareness, the Department anticipates that this rule may generate
changes in the policies, procedures, and operations of the entities
that this proposed rule covers.
Proposed Use of Information: The Department and its components
awarding Federal funds and OCR would use the signed assurance and
certification as documentation of: (1) A recipient's or applicant's
awareness of its obligations under the Federal health care conscience
and associated anti-discrimination laws and the proposed rule, and (2)
a recipient's commitment to comply with such statutes and the proposed
rule. This use would most likely occur during an OCR investigation of
the recipient's compliance with Federal health care conscience and
associated anti-discrimination laws and this proposed rule.
Description of the Respondents: The respondents are applicants or
recipients for Federal financial assistance or Federal funds from the
Department to which the proposed Sec. 88.3 applies. Respondents
include hospitals, research institutions, health professions training
programs, qualified health plan issuers, Health Insurance Marketplaces,
home health agencies, community mental health centers, and skilled
nursing facilities.
Number of Respondents: The Department estimates the number of
respondents at 123,302 persons or entities. This estimate represents
the average between the lower-bound (94,214) and upper-bound (152,389)
estimates of entities that will have to sign an assurance or a
certification. These figures appear supra in Table 2.
Respondents are a subset of the recipients subject to the relevant
Federal health care conscience and associated anti-discrimination laws
and the proposed rule because proposed Sec. 88.4(c)(1) through (4)
excludes certain categories of recipients. Specifically, the proposed
rule excludes physicians, as defined in 42 U.S.C. 1395x(r), physician
offices, or other health care practitioners who are recipients, as
defined in proposed Sec. 88.2, only in the form of reimbursements for
participation Medicare Part B. See proposed Sec. 88.4(c)(1). The
proposed rule also exempts recipients of certain grant programs
administered by the Administration for Children and Families or the
Administration for Community Living when the program's purpose is
unrelated to health care and certain types of research, does not
involve health care providers, and does not involve any significant
likelihood of referral for the provision of health care. See proposed
Sec. 88.4(c)(2) and (3). Finally, the proposed rule excludes Indian
Tribes and Tribal Organizations when contracting with the Indian Health
Service under the Indian Self-Determination and Education Assistance
Act. See proposed Sec. 88.4(c)(4).
Burden of Response: The Department is committed to leveraging
existing grant, contract, and other Departmental forms where possible
rather than creating additional, separate forms for recipients to sign.
The Department intends to update the HHS-690 Form, which includes
several Federal civil rights authorities with which applicants and
recipients must assurance compliance.\177\ The Department would
[[Page 3921]]
update the form to include a reference to Federal health care
conscience and associated anti-discrimination laws, as well as a Web
link to information about the requirements. The Department also intends
to update HHS-5161-1 Form, OMB No. 0930-0367 (Certification of
Compliance).
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\177\ HHS regulations implementing each of the following civil
rights laws require recipients to assure compliance with applicable
implementing regulations: Title VI of the Civil Rights Act of 1964,
Section 504 of the Rehabilitation Act of 1973, Title IX of the
Education Amendments of 1972, the Age Discrimination Act of 1975,
and Section 1557 of the Affordable Care Act. See 45 CFR 80.4
(requiring recipients to assure compliance with HHS Title VI
regulations), 84.5 (requiring recipients to assure compliance with
HHS Section 504 regulations), 86.4 (requiring recipients to assure
compliance with HHS Title IX regulations), 91.33 (requiring
recipients to assure compliance with the Age Act and HHS
implementing regulations), 92.5 (requiring recipients and entities
created under Title I of the Affordable Care Act to assure
compliance with Section 1557 and the HHS implementing regulation).
---------------------------------------------------------------------------
The burden for the assurance and certification is the opportunity
cost of recipient staff time (1) to review the assurance and
certification language as well as the requirements of the underlying
Federal health care conscience and associated anti-discrimination laws
referenced or incorporated, (2) to review entity-wide policies and
procedures or take other actions to self-assess compliance with
applicable Federal health care conscience and associated anti-
discrimination laws, and (3) to implement any actions to come into
compliance.
The methods that the Department uses are outlined supra in the
Assurance and Certification section of this RIA. The only adjustment to
those methods for this information collection analysis is to adjust the
mean hourly wage downward to exclude benefits and overhead. In doing
so, the Department calculates the following labor costs.
The labor cost is a function of a lawyer spending 3 hours reviewing
the assurance and certification and a chief executive spending one hour
to review and sign, as proposed Sec. 88.4(b)(2) requires a signature
by an individual authorized to bind the recipient. The mean hourly wage
(not including benefits and overhead) for these occupations is $67.25
per hour for the lawyer (occupation code 23-1011) and $93.44 for the
chief executive (occupation code 11-1011).\178\ The weighted mean
hourly wage (not including benefits and overhead) of these two
occupations is $73.80 per hour (($67.25 x .75) + ($93.44 x .25)). The
labor cost is $36 million each year for the first five years ($73.80
per hour x 4 hours x 123,302 entities).\179\
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\178\ Bureau of Labor Statistics, Occupational and Employment
Statistics, Occupational Employment and Wages, May 2016, https://www.bls.gov/oes/current/oes_nat.htm.
\179\ This total differs from the burden in the RIA because a
fully loaded wage that is adjusted upwards for benefits and overhead
must be used.
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The Department estimates that 61,652 recipients, which is half of
all respondents to this information collection (123,302 entities/2)
will review entity-wide policies and procedures or take other actions
to self-assess compliance with applicable Federal health care
conscience and associated anti-discrimination laws each year for the
first five years of publication, spending an average of 4 hours doing
so. The labor cost is a function of a lawyer spending 3 hours and a
chief executive spending one hour, which produces the same weighted
mean hourly wage of $73.80 per hour. The labor cost for self-assessing
compliance, such as reviewing policies and procedures, is a total of
$18.2 million each year for the first five years ($73.80 per hour x 4
hours x 61,652 entities).\180\
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\180\ This total differs from the burden in the RIA because a
fully loaded wage that is adjusted upwards for benefits and overhead
must be used.
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The Department estimates that approximately 5% of entities will
take an organization-wide action to improve compliance in the first
year and 0.5% will act each year in years two through five. This
percentage equates to 23,406 entities in year 1 and 2,341 entities
annually in years two through five. The Department estimates that each
year, the entities that engage in this voluntary compliance will spend
4 hours annually, on average. The labor cost is a function of a lawyer
spending 3 hours and a chief executive spending one hour, which
produces a weighted mean hourly wage of $73.80 per hour. The labor cost
is $6.9 million in year one ($73.80 x 4 x 23,406 entities) and
approximately $690,783 annually for years two through five ($73.80 x 4
x 2,341 entities).\181\
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\181\ This total differs from the burden in the RIA because a
fully loaded wage that is adjusted upwards for benefits and overhead
must be used.
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The Department asks for public comment on the proposed information
collection, including the particular issues below.
Whether the proposed collection of information is
necessary for the proper performance of OCR's functions and the
Department's and its components' functions to enforce Federal laws on
which Federal funding is conditioned, including whether the information
will have practical utility.
Whether the exception for Indian Tribes and tribal
Organizations in proposed 45 CFR 88.4(c)(vi) avoids ``tribal
implications'' and does not ``impose substantial direct compliance
costs on Indian Tribal governments'' as stated in Executive Order
13175, Consultation and Coordination with Indian Tribal Governments,
sec. 5(b) (Nov. 9, 2000).
Whether assuring compliance with the Federal health care
conscience and associated anti-discrimination statutes would constitute
a burden exempt from the Paperwork Reduction Act as a usual and
customary business practice incurred by recipients during the ordinary
course of business.
How the quality, utility, and clarity of the information
to be collected may be enhanced.
How the manner of compliance with the assurance and
certification requirements could be improved, including through use of
automated collection techniques or other forms of information
technology.
Information Collection for Proposed Sec. 88.5 (Notice)
Summary of the Collection of Information: Under the proposed rule,
each recipient and the Department must post a notice that apprises
persons, entities, and health care entities of their rights under
Federal health care conscience and associated anti-discrimination laws
and this proposed part.
Need for Information: Notice serves three primary purposes. First,
persons become apprised of their rights under the applicable Federal
health care conscience and associated anti-discrimination laws,
including the right to file a complaint with HHS OCR. Second, a
person's awareness of his or her rights increases the likelihood that
the person will exercise those rights. Third, recipients and their
managers and employees will be reminded and be made aware of their own
obligations under these laws.
Proposed Use of Information: In the event that the OCR Director
investigates or initiates a compliance review of a recipient, the OCR
Director will consider as one of many factors whether the recipient
posted the notice in the documents described in Sec. 88.5(c)(1)
through (3), as applicable.
Description of the Respondents: The respondents are recipients.
Respondents include, but are not limited to, hospitals, research
institutions, health professions training programs, qualified health
plan issuers, Health Insurance Marketplaces, home health agencies,
community mental health centers, and skilled nursing facilities.
Number of Respondents: The number of respondents is estimated at
611,372 establishments. This estimate represents the average between
the lower and upper-bound estimates of how many recipient
establishments must post notices. Respondents are a subset (99.5%) of
the total scope of entities subject to this proposed rule because the
[[Page 3922]]
notice requirement does not apply to sub-recipients.
Burden of Response: The Department estimates that the burden for
the notice is represented in terms of opportunity costs of staff time
to download, print, and post the notice, combined with material costs
for paper and ink. These costs are a one-time burden in the first year
of this proposed rule's implementation.
The Department estimates that it would take \1/3\ of an hour for an
administrative assistant to download the notice, print notice(s) and
post them in physical locations of the establishment where notices are
commonly posted. To post the notice on the Web, the Department
estimates that it will take 2 hours for a Web developer to execute the
design and technical elements to post the notice online. For some
establishments, it may take an administrative assistant or Web
developer longer to perform these functions; for other establishments,
it may take less time.
The Department uses the same method for calculating the cost of
this requirement supra in the RIA but adjusts the hourly wage downward
to exclude benefits and overhead. The mean hourly wage (not including
benefits and overhead) for an administrative assistant is $19.39 per
hour (occupation code 43-6010).\182\ The mean hourly wage (not
including benefits and overhead) for a Web developer is $34.69 per hour
(occupation code 15-11134). This labor cost is approximately $46.4
million ((\1/3\ hour x $19.39/hr. x 611,372 establishments) + (2 hours
x $34.69/hr. x 611,372 establishments).\183\
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\182\ Bureau of Labor Statistics, Occupational and Employment
Statistics, Occupational Employment and Wages, May 2016, https://www.bls.gov/oes/current/oes_nat.htm.
\183\ This total differs from the burden in the RIA because a
fully loaded wage that is adjusted upwards for benefits and overhead
must be used.
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The number of locations where notices are commonly posted in an
establishment will vary based on multiple factors. The Department also
assumes that the cost of materials (paper and ink) is $0.05 per page.
Based on this assumption, the first-year cost to post 5 notices across
all establishments would be (611,372 establishments x $.05 per page x 5
pages), which amounts to about $152,843. Because the Department assumes
that this cost is a one-time, upfront cost, it will not recur in the
out-years.
The proposed notice provision at Sec. 88.5(c)(1) through (3)
includes language designed to incentivize recipients to include the
OCR-drafted notice in certain types of documents or publications.
Because this provision is permissive, the Department assumes that
305,686 establishments will undertake such action in the first year,
which is half of all establishments subject to the notice requirement
(611,372 establishments x 50%). Approximately 152,843 establishments
(305,686 establishments/2) will annually undertake such voluntary
posting in years 2 through 5. The Department assumes that an
administrative assistant paid at $19.39/hour would identify documents
in which to include the notice, revising the documents or their layouts
to include the notice, or otherwise printing an insert to include with
paper documents. The assistant may spend a total of 2 hours in year one
and 1 hour annually in years 2 through 5. The labor cost in year 1 is
$11.9 million ($19.39 x 2 x 305,686 establishments) and $3 million
annually in years 2 through 5 ($19.39 x 1 x 152,843 establishments).
The Department anticipates that there may be some additional
printing costs where inclusion of the notice adds a page to the
underlying document. There is a high degree of uncertainty as to the
average number of documents in which a recipient may proactively
include the notice. There is also uncertainty as to whether a recipient
would print the publications or house them online. The Department
estimates that a recipient that voluntarily includes the notice in
publications may print some publications and house others online; on
balance, the recipient might print approximately 100 extra pages. With
these assumptions, the cost of voluntarily included notices, as
proposed Sec. 88.5(c) incentivizes, will cost approximately $1.5
million in the first year (305,686 entities x 100 pages x $.05 per
page) and $764,216 annually in years two through five.
Total first-year costs (mandatory plus voluntary) for the notice
requirement are estimated at $59.9 million and $3.7 million annually in
years 2 through 5.
The Department asks for public comment on the proposed information
collection, including the particular issues below.
Whether the proposed collection of information is
necessary for the proper performance of OCR's functions and the
Department's and its components' functions to enforce Federal laws on
which Federal funding is conditioned, including whether the information
will have practical utility.
Feedback on the assumptions that form the basis of our
cost estimates for the notice provision.
How the manner of compliance with notice provision could
be improved, including through the use of automated collection
techniques or other forms of information technology.
Compliance Procedures (Sec. 88.6(d))
Summary of the Collection of Information: Proposed Sec. 88.6(d)
requires any recipient that receives a notice of investigation or
compliance review letter from OCR concerning Federal health care
conscience and associated anti-discrimination laws to report this fact
to each of the Departmental components from which the recipient
receives Federal funds. Additionally, this requirement applies to
complaints filed with OCR such that the recipient must disclose to the
applicable Departmental funding component the existence of the
complaint for five years from the date of the filing of the complaint
whenever it applies for new or renewed Federal financial assistance or
other Federal funds from the Department.
Need for Information: The information promptly informs applicable
Departmental components of OCR's pending investigation and historical
complaints to ensure appropriate coordination within the Department
during the pendency of the investigation and to inform funding
decision-making.
Proposed Use of Information: At a minimum, this requirement puts
the Departmental component on notice of OCR's investigation and
facilitates coordination between the component and OCR on technical or
factual matters underlying the recipient's or sub-recipient's extension
of Federal funds. The Department component may also use the information
to monitor the status of the investigation and history of complaints to
incorporate these facts into the component's decision-making when
deciding whether to approve or renew or modify Federal funding to the
recipient.
Description of the Respondents: The respondents are a subset of
recipients and sub-recipients subject to an HHS OCR investigation of
Federal health care conscience and associated anti-discrimination laws
and this proposed rule. Respondents include State and local
governments, physicians, hospitals, research institutions, health
professions training programs, qualified health plan issuers, Health
Insurance Marketplaces, home health agencies, educational institutions,
community mental health centers, and skilled nursing facilities, among
others.
Number of Respondents: The number of respondents on average is 30
[[Page 3923]]
recipients per year, which is the average between the lower-bound (10
recipients) and upper-bound (50 recipients) estimate.
Burden of Response: The Department estimates that the burden is the
opportunity cost that recipients will incur to spend 15 minutes to
email the appropriate grants management official(s). The Department
uses the same methodology used when calculating these costs in the RIA
but adjusts the hourly wage down to exclude benefit and overhead. The
mean hourly wage for the administrative assistant (not adjusted for
benefits and overhead) is $19.39 per hour. The annual labor cost is
$0.3 million across all 30 entities (30 entities x $19.39 per hour x
0.25 hours x 2,000 applications or renewals).
The Department asks for public comment on the proposed information
collection, including the particular issues below.
Whether the proposed collection of information is
necessary for the proper performance of OCR's functions and the
Department's and its components' functions to enforce Federal laws on
which Federal funding is conditioned, including whether the information
will have practical utility.
Feedback on the assumptions that form the basis of our
cost estimates.
The automated collection techniques or other forms of
information technology that could improve the efficiency of this
collection of information.
Comments regarding the collection of information proposed in this
rule must refer to the proposed rule by name and docket number and must
be submitted to both OMB and the Docket Management Facility where
indicated under ADDRESSES by the date specified under DATES.
When it issues a final rule, the Department plans to publish in the
Federal Register the control numbers assigned by the Office of
Management and Budget (OMB). Publication of the control numbers
notifies the public that OMB has approved the final rule's information
collection requirements under the Paperwork Reduction Act of 1995.
List of Subjects in 45 CFR Part 88
Abortion, Adult education, Advanced directives, Assisted suicide,
Authority delegations, Childbirth, Civil rights, Coercion, Colleges and
universities, Community facilities, Contracts, Educational facilities,
Employment, Euthanasia, Family planning, Federal-State relations,
Government contracts, Government employees, Grant programs-health,
Grants administration, Health care, Health facilities, Health
insurance, Health professions, Hospitals, Immunization, Indian Tribes,
Insurance, Insurance companies, Laboratories, Manpower training
programs, Maternal and child health, Medicaid, Medical and dental
schools, Medical research, Medicare, Mental health programs, Mercy
killing, Moral convictions, Nondiscrimination, Nursing homes, Nursing
schools, Occupational safety and health, Occupational training,
Physicians, Prescription drugs, Public assistance programs, Public
awareness, Public health, Religious discrimination, Religious beliefs,
Religious liberties, Religious nonmedical health care institutions;
Reporting and recordkeeping requirements, Rights of conscience,
Scholarships and fellowships, Schools, Scientists, State and local
governments, Sterilization, Students, Technical assistance, Tribal
Organizations.
Proposed Rule
For the reasons set forth in the preamble, the Department of Health
and Human Services proposes to revise 45 CFR part 88 to read as
follows:
PART 88--ENSURING THAT THE DEPARTMENT OF HEALTH AND HUMAN SERVICES
DOES NOT FUND OR ADMINISTER PROGRAMS OR ACTIVITIES THAT VIOLATE
CONSCIENCE AND ASSOCIATED ANTI-DISCRIMINATION LAWS
Sec.
88.1 Purpose.
88.2 Definitions.
88.3 Applicable requirements and prohibitions.
88.4 Assurance and certification of compliance requirements.
88.5 Notice requirement.
88.6 Compliance requirements.
88.7 Enforcement authority.
88.8 Relationship to other laws.
88.9 Rule of construction.
88.10 Severability.
Appendix A to Part 88--Notice Concerning Federal Health Care
Conscience and Associated Anti-Discrimination Protections
Authority: The Weldon Amendment (e.g., Consolidated
Appropriations Act, 2017, Public Law 115-31, sec. 507(d); Div. H,
sec. 209); the Helms Amendment (e.g., Consolidated Appropriations
Act, 2017, Public Law 115-31, Div. J, sec. 7018); 22 U.S.C. 7631(d);
26 U.S.C. 5000A(d)(2); 29 U.S.C. 669(a)(5); 42 U.S.C. 300a-7 (the
Church Amendments), 42 U.S.C. 238n (Coats-Snowe Amendment); 18113
(Section 1553 of the Affordable Care Act), 18023(c)(2)(A)(i)-(iii),
18023(b)(1)(A), 18023(b)(4); 280g-1(d)), 290bb-36(f), 1320a-1,
1320c-11, 1395cc(f), 1395i-5, 1395w-22(j)(3)(B), 1395x(e),
1395x(y)(1), 1396a(a), 1396a(w)(3), 1396f, 1396s(c)(2)(B)(ii),
1396u-2(b)(3)(B), 1397j-1(b), 5106i(a), 14406.
Sec. 88.1 Purpose.
The purpose of this part is to provide for the implementation and
enforcement of the Federal health care conscience and associated anti-
discrimination laws. Such laws, for example, protect the rights of
persons, entities, and health care entities to refuse to perform,
assist in the performance of, or undergo health care services or
research activities to which they may object for religious, moral,
ethical, or other reasons. Such laws, for example, also protect
patients from being subjected to certain health care or services over
their conscientious objection. Consistent with their objective to
comprehensively protect the conscience and associated anti-
discrimination rights of persons, entities, and health care entities,
the statutory provisions and the regulatory provisions contained in
this part are to be interpreted and implemented broadly to effectuate
their protective purposes.
Sec. 88.2 Definitions.
For the purposes of this part:
Administered by the Secretary means to be subject to the
responsibility of the Secretary of the U.S. Department of Health and
Human Services, as established via statute or regulation, for the
administration of Federal funds available to any program or activity.
Assist in the Performance means to participate in any program or
activity with an articulable connection to a procedure, health service,
health program, or research activity, so long as the individual
involved is a part of the workforce of a Department-funded entity. This
includes but is not limited to counseling, referral, training, and
other arrangements for the procedure, health service, health program,
or research activity.
Department means the Department of Health and Human Services and
any component thereof.
Discriminate or Discrimination means, as applicable and as
permitted by the applicable statute:
(1) To withhold, reduce, exclude, terminate, restrict, or otherwise
make unavailable or deny any grant, contract, subcontract, cooperative
agreement, loan, license, certification, accreditation, employment,
title, or other similar instrument, position, or status;
(2) To withhold, reduce, exclude, terminate, restrict, or otherwise
make unavailable or deny any benefit or privilege;
(3) To utilize any criterion, method of administration, or site
selection,
[[Page 3924]]
including the enactment, application, or enforcement of laws,
regulations, policies, or procedures directly or through contractual or
other arrangements, that tends to subject individuals or entities
protected under this part to any adverse effect described in this
definition, or have the effect of defeating or substantially impairing
accomplishment of a health program or activity with respect to
individuals, entities, or conduct protected under this part; or
(4) To otherwise engage in any activity reasonably regarded as
discrimination including intimidating or retaliatory action.
Entity means a ``person'' as defined in 1 U.S.C. 1 or a State,
political subdivision of any State, instrumentality of any State or
political subdivision thereof, or any public agency, public
institution, public organization, or other public entity in any State
or political subdivision of any State.
Federal Financial Assistance includes:
(1) Grants and loans of Federal funds;
(2) The grant or loan of Federal property and interests in
property;
(3) The detail of Federal personnel;
(4) The sale or lease of, and the permission to use (on other than
a casual or transient basis), Federal property or any interest in such
property without consideration or at a nominal consideration, or at a
consideration which is reduced for the purpose of assisting the
recipient or in recognition of the public interest to be served by such
sale or lease to the recipient; and
(5) Any Federal agreement, arrangement, or other contract which has
as one of its purposes the provision of assistance.
Health care entity includes an individual physician or other health
care professional, health care personnel, a participant in a program of
training in the health professions, an applicant for training or study
in the health professions, a post-graduate physician training program,
a hospital, a laboratory, an entity engaging in biomedical or
behavioral research, a provider-sponsored organization, a health
maintenance organization, a health insurance plan (including group or
individual plans), a plan sponsor, issuer, or third-party
administrator, or any other kind of health care organization, facility,
or plan. It may also include components of State or local governments.
Health program or activity includes the provision or administration
of any health-related services, health service programs and research
activities, health-related insurance coverage, health studies, or any
other service related to health or wellness whether directly, through
payments, grants, contracts, or other instruments, through insurance,
or otherwise.
Health service program includes any plan or program that provides
health benefits, whether directly, through insurance, or otherwise, and
is funded, in whole or part, by the Department. It may also include
components of State or local programs.
Individual means a member of the workforce of an entity or health
care entity.
Instrument is the means by which Federal funds are conveyed to a
recipient, and includes grants, cooperative agreements, contracts,
grants under a contract, memoranda of understanding, loans, loan
guarantees, stipends, and any other funding or employment instrument or
contract.
OCR means the Office for Civil Rights of the Department of Health
and Human Services.
Recipient means any State, political subdivision of any State,
instrumentality of any State or political subdivision thereof, and any
person or any public or private agency, institution, organization, or
other entity in any State including any successor, assign, or
transferee thereof, to whom Federal financial assistance is extended
directly from the Department or a component of the Department, or who
otherwise receives Federal funds directly from the Department or a
component of the Department, but such term does not include any
ultimate beneficiary. The term may include foreign or international
organizations (such as agencies of the United Nations).
Referral or refer for includes the provision of any information
(including but not limited to name, address, phone number, email,
website, instructions, or description) by any method (including but not
limited to notices, books, disclaimers, or pamphlets, online or in
print), pertaining to a health care service, activity, or procedure,
including related to availability, location, training, information
resources, private or public funding or financing, or directions that
could provide any assistance in a person obtaining, assisting, training
in, funding, financing, or performing a particular health care service,
activity, or procedure, where the entity or health care entity making
the referral sincerely understands that particular health care service,
activity, or procedure to be a purpose or possible outcome of the
referral.
State includes, in addition to the several States, the District of
Columbia. For those provisions related to or relying upon the Public
Health Service Act, the term ``State'' includes the several States, the
District of Columbia, the Commonwealth of Puerto Rico, Guam, the
Northern Mariana Islands, the U.S. Virgin Islands, American Samoa, and
the Trust Territory of the Pacific Islands. For those provisions
related to or relying upon the Social Security Act, such as Medicaid or
the Children's Health Insurance Program, the term ``State'' follows the
definition of ``State'' found at 42 U.S.C. 1301.
Sub-recipient means any State, political subdivision of any State,
instrumentality of any State or political subdivision thereof, and any
person or any public or private agency, institution, organization, or
other entity in any State including any successor, assign, or
transferee thereof, to whom Federal financial assistance is extended
through a recipient or another sub-recipient, or who otherwise receives
Federal funds from the Department or a component of the Department
indirectly through a recipient or another sub-recipient, but such term
does not include any ultimate beneficiary. The term may include foreign
or international organizations (such as agencies of the United
Nations).
Workforce means employees, volunteers, trainees, contractors, and
other persons whose conduct, in the performance of work for an entity
or health care entity, is under the direct control of such entity or
health care entity, whether or not they are paid by the entity or
health care entity, as well as health care providers holding privileges
with the entity or health care entity.
Sec. 88.3 Applicable requirements and prohibitions.
(a) The Church Amendments, 42 U.S.C. 300a-7--(1) Applicability. (i)
The Department is required to comply with paragraphs (a)(2)(i) through
(vii) of this section and Sec. Sec. 88.5 and 88.6 of this part.
(ii) Any State or local government or subdivision thereof and any
other public entity are required to comply with paragraphs (a)(2)(i)
through (iii) of this section.
(iii) Any entity that receives a grant, contract, loan, or loan
guarantee under the Public Health Service Act [42 U.S.C. 201 et seq.]
after June 18, 1973, is required to comply with paragraph (a)(2)(iv) of
this section and Sec. Sec. 88.4, 88.5, and 88.6 of this part.
(iv) Any entity that receives a grant or contract for biomedical or
behavioral research under any program
[[Page 3925]]
administered by the Secretary of Health and Human Services after July
12, 1974, is required to comply with paragraph (a)(2)(v) of this
section and Sec. Sec. 88.4, 88.5, and 88.6 of this part.
(v) Any entity that carries out any part of any health service
program or research activity funded in whole or in part under a program
administered by the Secretary of Health and Human Services is required
to comply with paragraph (a)(2)(vi) of this section and Sec. Sec.
88.4, 88.5, and 88.6 of this part.
(vi) Any entity that receives, after September 29, 1979, any grant,
contract, loan, loan guarantee, or interest subsidy under the Public
Health Service Act, or the Developmental Disabilities Assistance and
Bill of Rights Act of 2000 [42 U.S.C. 15001 et seq.] is required to
comply with paragraph (a)(2)(vii) of this section and Sec. Sec. 88.4,
88.5, and 88.6 of this part.
(2) Requirements and prohibitions. (i) Pursuant to 42 U.S.C. 300a-
7(b)(1), entities to whom this paragraph (a)(2)(i) applies shall not
require any individual who receives a grant, contract, loan, or loan
guarantee under the Public Health Service Act to perform or assist in
the performance of any sterilization procedure or abortion if his
performance or assistance in the performance of such procedure or
abortion would be contrary to his religious beliefs or moral
convictions.
(ii) Pursuant to 42 U.S.C. 300a-7(b)(2)(A), entities to whom this
paragraph (a)(2)(ii) applies shall not require any entity funded under
the Public Health Service Act to make its facilities available for the
performance of any sterilization procedure or abortion if the
performance of such procedure or abortion in such facilities is
prohibited by the entity on the basis of religious beliefs or moral
convictions.
(iii) Pursuant to 42 U.S.C. 300a-7(b)(2)(B), entities to whom this
paragraph (a)(2)(iii) applies shall not require any entity funded under
the Public Health Service Act to provide personnel for the performance
or assistance in the performance of any sterilization procedure or
abortion if the performance or assistance in the performance of such
procedure or abortion by such personnel would be contrary to the
religious beliefs or moral convictions of such personnel.
(iv) Pursuant to 42 U.S.C. 300a-7(c)(1), entities to whom this
paragraph (a)(2)(iv) applies shall not discriminate against any
physician or other health care personnel in the employment, promotion,
termination, or extension of staff or other privileges because such
physician or other health care personnel performed or assisted in the
performance, or refused to perform or assist in the performance of a
lawful sterilization procedure or abortion on the grounds that doing so
would be contrary to his or her religious beliefs or moral convictions,
or because of his or her religious beliefs or moral convictions
concerning abortions or sterilization procedures themselves.
(v) Pursuant to 42 U.S.C. 300a-7(c)(2), entities to whom this
paragraph (a)(2)(v) applies shall not discriminate against any
physician or other health care personnel in employment, promotion,
termination of employment, or extension of staff or other privileges
because such physician or other health care personnel performed or
assisted in the performance of any lawful health service or research
activity or refused to perform or assist in the performance of such
service or activity on the grounds that doing so would be contrary to
his or her religious beliefs or moral convictions, or because of his or
her religious beliefs or moral convictions.
(vi) Pursuant to 42 U.S.C. 300a-7(d), entities to whom this
paragraph (a)(2)(vi) applies shall not require any individual to
perform or assist in the performance of any part of a health service
program or research activity if such performance or assistance would be
contrary to the individual's religious beliefs or moral convictions.
(vii) Pursuant to 42 U.S.C. 300a-7(e), entities to whom this
paragraph (a)(2)(vii) applies shall not deny admission to or otherwise
discriminate against any applicant for training or study because of
reluctance or willingness to counsel, suggest, recommend, assist, or in
any way participate in the performance of abortions or sterilizations
contrary to or consistent with the applicant's religious beliefs or
moral convictions.
(b) The Coats-Snowe Amendment (Section 245 of the Public Health
Service Act), 42 U.S.C. 238n--(1) Applicability. (i) The Federal
government, including the Department, is required to comply with
paragraphs (b)(2)(i) through (ii) of this section and Sec. Sec. 88.5,
and 88.6 of this part.
(ii) Any State or local government or subdivision thereof that
receives Federal financial assistance, including Federal payments
provided as reimbursement for carrying out health-related activities is
required to comply with paragraphs (b)(2)(i) through (ii) of this
section and Sec. Sec. 88.4, 88.5, and 88.6 of this part.
(2) Requirements and prohibitions. (i) Pursuant to 42 U.S.C.
238n(a)(1), (2), and (3), entities to whom this paragraph (b)(2)(i)
applies shall not subject any individual or institutional health care
entity to discrimination on the basis that the individual or
institutional health care entity--
(A) Refuses to undergo training in the performance of induced
abortions, to require or provide such training, to perform such
abortions, or to provide referrals for such training or such abortions;
(B) Refuses to make arrangements for any of the activities
specified in (b)(2)(i)(A); or
(C) Attends or attended a post-graduate physician training program,
or any other program of training in the health professions, that does
not or did not require attendees to perform induced abortions or
require, provide, or refer for training in the performance of induced
abortions, or make arrangements for the provision of such training.
(ii) Pursuant to 42 U.S.C. 238n(b), entities to whom this paragraph
(b)(2)(ii) applies shall not, for the purposes of granting a legal
status to a health care entity (including a license or certificate), or
providing such entity with financial assistance, services or benefits,
fail to deem accredited any postgraduate physician training program
that would be accredited but for the accrediting agency's reliance upon
an accreditation standard or standards that require an entity to
perform an induced abortion or require, provide, or refer for training
in the performance of induced abortions, or make arrangements for such
training, regardless of whether such standard provides exceptions or
exemptions.
(c) Weldon Amendment (See, e.g., Pub. L. 115-31, Div. H, sec.
507(d))--(1) Applicability. (i) The Department, while operating under
an appropriations act that contains the Weldon Amendment, is required
to comply with paragraph (c)(2) of this section and Sec. Sec. 88.5,
and 88.6 of this part;
(ii) Any State or local government that receives funds under an
appropriations act for the Department that contains the Weldon
Amendment is required to comply with paragraph (c)(2) of this section
and Sec. Sec. 88.4, 88.5, and 88.6 of this part;
(iii) Any entity that receives funds through a program administered
by the Secretary or under an appropriations act for the Department that
contains the Weldon Amendment is required to comply with paragraph
(c)(2) of this section and Sec. Sec. 88.4, 88.5, and 88.6 of this
part.
(2) Prohibition. The entities to whom this paragraph (c)(2) applies
shall not subject any institutional or individual health care entity to
discrimination on the basis that the health care entity does not
provide, pay for, provide coverage of, or refer for, abortion.
[[Page 3926]]
(d) Medicare Advantage, Consolidated Appropriations Act of 2017,
Public Law 115-31, Div. H, Tit. II, sec. 209--(1) Applicability. The
Department, while operating under an appropriations act that contains a
provision under the Medicare Advantage program as set forth by Public
Law 115-31, Div. H, Tit. II, sec. 209, is required to comply with
paragraph (d)(2) of this section and Sec. Sec. 88.5, and 88.6 of this
part.
(2) Prohibition. The entities to whom this paragraph (d)(2) applies
shall not deny participation in the Medicare Advantage program to an
otherwise eligible entity (including a Provider Sponsored Organization)
because that entity will not provide, pay for, provide coverage of, or
provide referrals for abortions.
(e) Section 1553 of the Affordable Care Act, 42 U.S.C. 18113--(1)
Applicability. (i) The Department is required to comply with paragraph
(e)(2) of this section and Sec. Sec. 88.5, and 88.6 of this part.
(ii) Any State or local government that receives Federal financial
assistance under the Patient Protection and Affordable Care Act (or
under any amendment made by the Act) is required to comply with
paragraph (e)(2) of this section and Sec. Sec. 88.4, 88.5, and 88.6 of
this part.
(iii) Any health care provider that receives Federal financial
assistance under the Patient Protection and Affordable Care Act (or
under any amendment made by the Act) is required to comply with
paragraph (e)(2) of this section and Sec. Sec. 88.4, 88.5, and 88.6 of
this part.
(iv) Any health plan created under the Patient Protection and
Affordable Care Act (or under any amendment) is required to comply with
paragraph (e)(2) of this section and Sec. Sec. 88.4, 88.5, and 88.6 of
this part.
(2) Prohibition. The entities to whom this paragraph (e)(2) applies
shall not subject an individual or institutional health care entity to
discrimination on the basis that the entity does not provide any health
care item or service furnished for the purpose of causing, or for the
purpose of assisting in causing, the death of any individual, such as
by assisted suicide, euthanasia, or mercy killing; provided, that
nothing in this paragraph shall be construed to apply to, or to affect,
any limitation relating to:
(i) The withholding or withdrawing of medical treatment or medical
care;
(ii) The withholding or withdrawing of nutrition or hydration;
(iii) Abortion; or
(iv) The use of an item, good, benefit, or service furnished for
the purpose of alleviating pain or discomfort, even if such use may
increase the risk of death, so long as such item, good, benefit, or
service is not also furnished for the purpose of causing, or the
purpose of assisting in causing, death, for any reason.
(f) Section 1303 of the Affordable Care Act, 42 U.S.C. 18023--(1)
Applicability. (i) The Department is required to comply with paragraph
(f)(2)(i) of this section and Sec. Sec. 88.5, and 88.6 of this part.
(ii) Qualified health plans, as defined under 42 U.S.C. 18021,
offered on any Exchange created under the Affordable Care Act, are
required to comply with paragraph (f)(2)(ii) of this section and
Sec. Sec. 88.4, 88.5, and 88.6 of this part.
(2) Requirements and prohibitions. (i) Pursuant to 42 U.S.C.
18023(b)(1)(A)(i), entities to whom this paragraph (f)(2)(i) applies
shall not require a qualified health plan to provide coverage of
abortion or abortion-related services as described in 42 U.S.C.
18023(b)(1)(B) as part of its essential health benefits for any plan
year.
(ii) Pursuant to 42 U.S.C. 18023(b)(4), entities to whom this
paragraph (f)(2)(ii) applies shall not discriminate against any
individual health care provider or health care facility because of its
unwillingness to provide, pay for, provide coverage of, or refer for
abortions.
(g) Section 1411 of the Affordable Care Act, 42 U.S.C. 18081--(1)
Applicability. The Department shall comply with paragraph (g)(2) of
this section and Sec. Sec. 88.5, and 88.6 of this part.
(2) Requirement. The Department shall provide a certification
documenting a religious exemption from the individual responsibility
requirement and penalty under the Affordable Care Act to:
(i) Any individual who is a member of a recognized religious sect
or division thereof and is an adherent of established tenets or
teachings of such sect or division by reason of which he is
conscientiously opposed to acceptance of the benefits of any private or
public insurance which, among other things, makes payments toward the
cost of, or provides services for, medical care (including the benefits
of any insurance system established by the Social Security Act); and
(ii) Any individual for the month for which such individual is a
member of a ``health care sharing ministry,'' as defined in 26 U.S.C.
5000A(2)(B)(ii).
(h) Counseling and referral provisions of 42 U.S.C. 1395w-
22(j)(3)(B) and 1396u-2(b)(3)(B))--(1) Applicability. (i) The
Department is required to comply with paragraphs (h)(2)(i) through (ii)
of this section and Sec. Sec. 88.5 and 88.6 of this part.
(ii) Any State agency that administers a Medicaid program is
required to comply with paragraph (h)(2)(ii) of this section and
Sec. Sec. 88.4, 88.5, and 88.6 of this part.
(2) Requirements and prohibitions. (i) Pursuant to 42 U.S.C. 1395w-
22(j)(3)(B), entities to whom this paragraph (h)(2)(i) applies shall
not require a Medicare Advantage organization to offer a plan that
provides, reimburses for, or provides coverage of, a counseling or
referral service if the organization objects to the provision of such
service on moral or religious grounds.
(ii) Pursuant to 42 U.S.C. 1396u-2(b)(3)(B), entities to whom this
paragraph (h)(2)(ii) applies shall not require a Medicaid managed care
organization to provide, reimburse for, or provide coverage of, a
counseling or referral service if the organization objects to the
provision of such service on moral or religious grounds.
(i) Advance Directives, 42 U.S.C. 1395cc(f), 1396a(w)(3), and
14406--(1) Applicability. (i) The Department is required to comply with
paragraph (i)(2) of this section and Sec. Sec. 88.5 and 88.6 of this
part with respect to the Medicare and Medicaid programs.
(ii) Any State agency that administers a Medicaid program is
required to comply with paragraph (i)(2) of this section and Sec. Sec.
88.4, 88.5, and 88.6 of this part with respect to its Medicaid program.
(2) Prohibitions. The entities to whom this paragraph (i)(2)
applies shall not:
(i) Construe 42 U.S.C. 1395cc(f) or 1395a(w) to require any
provider or organization, or any employee of such a provider or
organization, to inform or counsel any individual regarding any right
to obtain an item or service furnished for the purpose of causing, or
the purpose of assisting in causing, the death of the individual, such
as by assisted suicide, euthanasia, or mercy killing; or to apply to or
affect any requirement with respect to a portion of an advance
directive that directs the purposeful causing of, or the purposeful
assisting in causing, the death of any individual, such as by assisted
suicide, euthanasia, or mercy killing; or
(ii) Construe 42 U.S.C. 1396a to prohibit the application of any
applicable State law which allows for an objection on the basis of
conscience for any health care provider or any agent of such provider
which as a matter of conscience cannot implement an advance directive.
(j) Global Health Programs, 22 U.S.C. 7631(d)--(1) Applicability.
(i) The Department is required to comply with
[[Page 3927]]
paragraph (j)(2) of this section and Sec. Sec. 88.5 and 88.6 of this
part.
(ii) Any entity that receives Federal financial assistance for HIV/
AIDS prevention, treatment, or care to the extent administered by the
Secretary under section 104A of the Foreign Assistance Act of 1961 (22
U.S.C. 2151b-2), under Chapter 83 of Title 22 of the U.S. Code or under
the Tom Lantos and Henry J. Hyde United States Global Leadership
Against HIV/AIDS, Tuberculosis, and Malaria Reauthorization Act of
2008, is required to comply with paragraph (j)(2) of this section and
Sec. Sec. 88.4, 88.5, and 88.6 of this part.
(2) Prohibitions. The entities to whom this paragraph (j)(2)
applies shall not:
(i) To the extent administered by the Secretary under section 104A
of the Foreign Assistance Act of 1961 (22 U.S.C. 2151b-2), under
Chapter 83 of Title 22 of the U.S. Code, or under the Tom Lantos and
Henry J. Hyde United States Global Leadership Against HIV/AIDS,
Tuberculosis, and Malaria Reauthorization Act of 2008, require
applicants for assistance for HIV/AIDS prevention, treatment, or care
to:
(A) Endorse or utilize a multisectoral or comprehensive approach to
combating HIV/AIDS; or
(B) Endorse, utilize, make a referral to, become integrated with,
or otherwise participate in any program or activity to which the
applicant has a religious or moral objection, as a condition of
assistance.
(ii) Discriminate against applicants in the solicitation or
issuance of grants, contracts, or cooperative agreements under such
provisions of law for refusing to meet any requirement described in
this paragraph (j)(2).
(k) The Helms Amendment (e.g., Consolidated Appropriations Act of
2017, Public Law 115-31, Div. J, Tit. VII, sec. 7018) (codified at 22
U.S.C. 2151b(f))--(1) Applicability. The Department is required to
comply with paragraph (k)(2)(i) of this section and Sec. Sec. 88.5 and
88.6 of this part.
(ii) Any entity that receives Federal financial assistance under
Part I of the Foreign Assistance Act of 1961, as amended (22 U.S.C.
2151b-2), to the extent administered by the Secretary, is required to
comply with paragraph (k)(2)(ii) of this section and Sec. Sec. 88.4,
88.5, and 88.6 of this part.
(2) Prohibitions. (i) The entities to whom this paragraph (k)(2)(i)
applies shall not:
(A) Permit Federal financial assistance identified in (k)(1)(ii) to
be used in an manner that would violation provisions in paragraphs
(k)(2)(ii)(A)(1) through (5) of this section related to abortions and
involuntary sterilizations.
(B) Obligate or expend Federal financial assistance to any country
or organization if the President certifies that the use of these funds
by any such country or organization would violate provisions in
paragraphs (k)(2)(ii)(A)(1) through (5) of this section related to
abortions and involuntary sterilizations.
(ii) The entities to whom this paragraph (k)(2)(ii) applies shall
not:
(A) Use such Federal financial assistance identified in (k)(1)(ii)
to:
(1) Pay for the performance of abortions as a method of family
planning;
(2) Motivate or coerce any person to practice abortions;
(3) Pay for the performance of involuntary sterilization as a
method of family planning;
(4) Coerce or provide any financial incentive to any person to
undergo sterilizations;
(5) Pay for any biomedical research that relates in whole or in
part, to methods of, or the performance of, abortions or involuntary
sterilization as a means of family planning;
(B) Obligate or expend Federal financial assistance to any country
or organization if the President certifies that the use of these funds
by any such country or organization would violate provisions in
paragraphs (k)(2)(ii)(A)(1) through (5) of this section related to
abortions and involuntary sterilizations.
(l) Newborn and Infant Hearing Loss Screening, 42 U.S.C. 280g-
1(d)--(1) Applicability. The Department is required to comply with
paragraph (l)(2) of this section and Sec. Sec. 88.5 and 88.6 of this
part.
(2) Requirement. The Department shall not construe 42 U.S.C. 280g-
1(d) to preempt or prohibit State laws that do not require screening
for hearing loss of newborn infants or young children when their
parents object to the screening on the grounds that it conflicts with
the parents' religious beliefs.
(m) Medical Screening, Examination, Diagnosis, Treatment, or Other
Health Care or Services, 42 U.S.C. 1396f--(1) Applicability. The
Department is required to comply with paragraph (m)(2) of this section
and Sec. Sec. 88.5 and 88.6 of this part.
(2) Requirements and prohibitions. The Department shall not
construe anything in 42 U.S.C. 1396 et seq. to require a State agency
that administers a State Medicaid Plan to compel any person to undergo
any medical screening, examination, diagnosis, or treatment or to
accept any other health care or services provided under such plan for
any purpose (other than for the purpose of discovering and preventing
the spread of infection or contagious disease or for the purpose of
protecting environmental health), if such person objects (or, in case
such person is a child, his parent or guardian objects) thereto on
religious grounds.
(n) Occupational Illness Examinations and Tests, 29 U.S.C.
669(a)(5)--(1) Applicability. (i) The Department is required to comply
with paragraph (n)(2) of this section and Sec. Sec. 88.5 and 88.6 of
this part.
(ii) Any recipient of grants or contracts under 29 U.S.C. 669, to
the extent administered by the Secretary, is required to comply with
paragraph (n)(2) of this section and Sec. Sec. 88.4, 88.5, and 88.6 of
this part.
(2) Requirements. With respect to occupational illness examinations
and tests, the entities to whom this paragraph (n)(2) applies shall not
deem any provision of 29 U.S.C. 651 et seq. to authorize or require
medical examination, immunization, or treatment, as provided under 29
U.S.C. 669, for those who object thereto on religious grounds, except
where such is necessary for the protection of the health or safety of
others.
(o) Vaccination, 42 U.S.C. 1396s(c)(2)(B)(ii)--(1) Applicability.
(i) The Department is required to comply with paragraph (o)(2) of this
section and Sec. Sec. 88.5 and 88.6 of this part.
(ii) Any State agency that administers a pediatric vaccine
distribution program under 42 U.S.C. 1396s is required to comply with
paragraph (o)(2) of this section and Sec. Sec. 88.4, 88.5, and 88.6 of
this part.
(2) Requirement. The entities to whom this paragraph (o)(2) applies
shall comply with applicable State law, including any such law relating
to any religious or other exemption.
(p) Specific Assessment, Prevention and Treatment Services, 42
U.S.C. 290bb-36(f), 5106i--(1) Applicability. (i) The Department is
required to comply with paragraphs (p)(2)(i) through (iii) of this
section and Sec. Sec. 88.5 and 88.6 of this part.
(ii) Any State; part of any State; public organization; or private
nonprofit organization, such as a school, educational institution,
juvenile justice system, substance use disorder program, mental health
program, foster care system, or other child and youth support
organization, designated by a State to develop or direct the State-
sponsored Statewide youth suicide early intervention and prevention
strategy under 42 U.S.C. 290bb-36 and that receives a grant or
cooperative agreement thereunder is required to
[[Page 3928]]
comply with paragraph (p)(2)(iii) of this section and Sec. Sec. 88.4,
88.5, and 88.6 of this part.
(iii) Any Federally recognized Indian tribe or tribal organization
(as defined in the Indian Self-Determination and Education Assistance
Act [25 U.S.C. 5301 et seq.]) or an urban Indian organization (as
defined in the Indian Health Care Improvement Act [25 U.S.C. 1601 et
seq.]) that is actively involved in the development and continuation of
a tribal youth suicide early intervention and prevention strategy under
42 U.S.C. 290bb-36 and that receives a grant or cooperative agreement
thereunder is required to comply with paragraph (p)(2)(iii) of this
section and Sec. Sec. 88.4, 88.5, and 88.6 of this part.
(iv) Any entity that receives funds under 42 U.S.C. Chapter 67,
Subchapters I or III is required to comply with paragraphs (p)(2)(i)
and (ii) of this section and Sec. Sec. 88.4, 88.5, and 88.6 of this
part.
(2) Requirements and prohibitions. (i) Entities to whom this
paragraph (p)(2)(i) applies shall not construe the receipt of funds
under or anything in 42 U.S.C. Chapter 67, Subchapters I or III as
establishing any Federal requirement that a parent or legal guardian
provide a child any medical service or treatment against the religious
beliefs of the parent or legal guardian.
(ii) Entities to whom this paragraph (p)(2)(ii) applies shall not
construe the receipt of funds under or anything in 42 U.S.C. Chapter
67, Subchapters I or III as requiring a State to find, or prohibiting a
State from finding, child abuse or neglect in cases in which a parent
or legal guardian relies solely or partially upon spiritual means
rather than medical treatment, in accordance with the religious beliefs
of the parent or legal guardian.
(iii) Entities to whom this paragraph (p)(2)(iii) applies shall not
require suicide assessment, early intervention, or treatment services
for youth whose parents or legal guardians object based on the parents'
or legal guardians' religious beliefs or moral objections.
(q) Religious nonmedical health care, 42 U.S.C. 1320a-1, 1320c-11,
1395i-5, 1395x(e), 1395x(y)(1), 1396a(a), 1397j-1(b), and 5106i(a)(2)--
(1) Applicability. (i) The Department is required to comply with
paragraphs (q)(2)(i), through (iii) of this section and Sec. Sec. 88.5
and 88.6 of this part.
(ii) Any State agency that administers a Medicaid or CHIP program
is required to comply with paragraph (q)(2)(ii) of this section and
Sec. Sec. 88.4, 88.5, and 88.6 of this part.
(iii) Any entity, including a State or local government or
subdivision thereof, receiving Federal financial assistance from Social
Services Block Grant is required to comply with paragraphs (q)(2)(i)
and (iv) of this section and Sec. Sec. 88.4, 88.5, and 88.6 of this
part.
(iv) Any entity, including a State or local government or
subdivision thereof, receiving Federal financial assistance from the
Elder Justice Block Grants is required to comply with paragraph
(q)(2)(iii) of this section and Sec. Sec. 88.4, 88.5, and 88.6 of this
part.
(2) Requirements and prohibitions. (i) The entities to whom this
paragraph (q)(2)(i) applies shall not fail or refuse to exempt a
religious nonmedical health care institution from the Medicare
requirement for peer review under 42 U.S.C. 1320cc and the Medicare
requirements under 42 U.S.C. 1320a-1, for evaluation by advisory boards
on capability to provide comprehensive health care services.
(ii) The entities to whom this paragraph (q)(2)(ii) applies shall
not fail or refuse to exempt a religious nonmedical health care
institution from the Medicaid requirements to:
(A) Meet State medical standards, under 42 U.S.C. 1396a(a)(9)(A);
(B) Be evaluated under 42 U.S.C. 1396a(a)(33), on the
appropriateness and quality of medical care and services;
(C) Undergo a regular program, under 42 U.S.C. 1396(a)(31), of
independent professional review, including medical evaluation, of
services in an intermediate care facility for persons with mental
disabilities; and
(D) Establish a utilization review plan under 42 U.S.C. 1395x(k);
or the Medicare, Medicaid, and Children's Health Insurance Program
requirements, under 42 U.S.C. 1320a-1, for evaluation by advisory
boards on capability to provide comprehensive health services.
(iii) Pursuant to 42 U.S.C. 1397j-1(b), the entities to whom this
paragraph (q)(2)(iii) applies shall not interfere with or abridge an
elder's right to practice his or her religion through reliance on
prayer alone for healing when this choice:
(A) Is contemporaneously expressed, either orally or in writing,
with respect to a specific illness or injury which the elder has at the
time of the decision by an elder who is competent at the time of the
decision;
(B) Is previously set forth in a living will, health care proxy, or
other advance directive document that is validly executed and applied
under State law; or
(C) May be unambiguously deduced from the elder's life history.
(iv) Pursuant to 42 U.S.C. 1395i-5, the entities to whom this
paragraph (q)(2)(iv) applies shall not prohibit coverage of inpatient
hospital services or post-hospital extended care services furnished an
individual in a religious nonmedical health care institution or home
health services furnished an individual by a religious nonmedical
health care institution if an individual makes an election providing
that:
(A) Such individual is conscientiously opposed to acceptance of
conventional or unconventional medical items and services (including
any medical screening, examination, diagnosis, prognosis, treatment, or
the administration of drugs); and
(B) Acceptance of such medical treatment would be inconsistent with
such individual's sincere religious beliefs.
Sec. 88.4 Assurance and certification of compliance requirements.
(a) In general--(1) Assurance. Except for an application or
recipient to which paragraph (c) of this section applies, every
application for Federal financial assistance or Federal funds from the
Department to which Sec. 88.3 of this part applies shall, as a
condition of the approval, renewal, or extension of any Federal
financial assistance or Federal funds from the Department pursuant to
the application, provide, contain, or be accompanied by an assurance
that the applicant or recipient will comply with applicable Federal
health care conscience and associated anti-discrimination laws and this
part.
(2) Certification. Except for an application or recipient to which
paragraph (c) of this section applies, every application for Federal
financial assistance or Federal funds from the Department to which
Sec. 88.3 of this part applies, shall, as a condition of the approval,
renewal, or extension of any Federal financial assistance or Federal
funds from the Department pursuant to the application, provide,
contain, or be accompanied by, a certification that the applicant or
recipient will comply with applicable Federal health care conscience
and associated anti-discrimination laws and this part.
(b) Specific requirements--(1) Timing. Applicants or recipients who
are already recipients as of the effective date of this part shall
submit the assurance required in paragraph (a)(1) of this section and
the certification required in paragraph (a)(2) of this section as a
condition of any reapplication for funds to which this part applies,
through any instrument or as a condition of an amendment or
modification of the instrument that extends the term of such instrument
or adds additional funds to it. Submission
[[Page 3929]]
may be required more frequently if the applicant or recipient fails to
meet a requirement of this part.
(2) Form and manner. Applicants or recipients shall submit the
assurance required in paragraph (a)(1) of this section and the
certification required in paragraph (a)(2) of this section in the form
and manner that OCR, in coordination with the relevant Department
component, specifies, or shall submit them in a separate writing signed
by the applicant's or recipient's officer or other person authorized to
bind the applicant or recipient.
(3) Duration of obligation. The assurance required in paragraph
(a)(1) of this section and the certification required in paragraph
(a)(2) of this section will obligate the recipient for the period
during which the Department extends Federal financial assistance or
Federal funds from the Department to a recipient.
(4) Compliance requirement. Submission of an assurance or
certification required under this section will not relieve a recipient
of the obligation to take and complete any action necessary to come
into compliance with Federal health care conscience and associated
anti-discrimination laws and this part prior to, or at the time of, or
subsequent to, the submission of such assurance or certification.
(5) Condition of continued receipt. Provision of a compliant
assurance and certification shall constitute a condition of continued
receipt of Federal financial assistance or Federal funds from the
Department and is binding upon the applicant or recipient, its
successors, assigns, or transferees for the period during which such
Federal financial assistance or Federal funds from the Department are
provided.
(6) Assurances in applications. An applicant or recipient may
incorporate the assurances by reference in subsequent applications to
the Department or Department component if prior assurances are
initially provided in the same year.
(7) Enforcement of assurances and certifications. The Department,
Department components, and OCR shall have the right to seek enforcement
of the assurances and certifications required in this section.
(8) Remedies for failure to make assurances and certifications. If
an applicant or recipient fails or refuses to furnish an assurance or
certification required under this section, OCR, in coordination with
the relevant Department component, may effect compliance by any of the
remedies provided in Sec. 88.7.
(c) Exceptions. The following persons or entities shall not be
required to comply with paragraphs (a)(1) and (2) of this section,
provided that such persons or entities are not recipients of Federal
financial assistance or other Federal funds from the Department through
another instrument, program, or mechanism, other than those set forth
in paragraphs (c)(1) through (4) of this section:
(1) A physician, as defined in 42 U.S.C. 1395x(r), physician
office, or other health care practitioner participating in Part B of
the Medicare program;
(2) A recipient of Federal financial assistance or other Federal
funds from the Department awarded under certain grant programs
currently administered by the Administration for Children and Families,
the purpose of which is either solely financial assistance unrelated to
health care or which is otherwise unrelated to health care provision,
and which, in addition, does not involve--
(i) Medical or behavioral research;
(ii) Health care providers; or
(iii) Any significant likelihood of referral for the provision of
health care;
(3) A recipient of Federal financial assistance or other Federal
funds from the Department awarded under certain grant programs
currently administered by the Administration on Community Living, the
purpose of which is either solely financial assistance unrelated to
health care or which is otherwise unrelated to health care provision,
and which, in addition, does not involve--
(i) Medical or behavioral research;
(ii) Health care providers; or
(iii) Any significant likelihood of referral for the provision of
health care.
(4) Indian Tribes and Tribal Organizations when contracting with
the Indian Health Service under the Indian Self-Determination and
Education Assistance Act.
Sec. 88.5 Notice requirement.
(a) In general. The Department and each recipient shall post the
notice text located in Appendix A to this part in accordance with
paragraph (b) of this section by April 26, 2018, or with respect to new
recipients, within 90 days after becoming a recipient.
(b) Specific requirements. The notice text required in paragraph
(a) of this section shall appear:
(1) On the Department's and each recipient's website(s), and
(2) In a prominent and conspicuous physical location in every
Department and recipient establishment where notices to the public and
notices to their workforce are customarily posted to permit ready
observation. The text of the notice shall be large enough to be easily
read. The Department and each recipient shall take steps to ensure that
such notices are not altered, defaced, or covered by other material.
(c) Factors in evaluation of compliance. In evaluating a
recipient's compliance with the requirements of this part, OCR will
take into account whether the recipient has provided the notice text in
paragraph (a) of this section:
(1) In a personnel manual or other substantially similar document
for members of the recipient's workforce;
(2) In applications for membership in the recipient's workforce or
for participation in a service, benefit, or other program, including
for training or study; and
(3) In a student handbook or other substantially similar document
for students participating in a program of training or study, including
for post-graduate interns, residents, and fellows.
(d) Combined nondiscrimination notices. The Department and each
recipient may post the notice text provided in appendix A of this part
along with the content of other notices only if it retains all of the
language provided in appendix A of this part in an unaltered state.
Sec. 88.6 Compliance requirements.
(a) In general. The Department and each recipient has primary
responsibility to ensure that it is in compliance with Federal health
care conscience and associated anti-discrimination laws and this part,
and shall take steps to eliminate any violations of the Federal health
care conscience and associated anti-discrimination laws and this part.
If a sub-recipient is found to have violated the Federal health care
conscience and associated anti-discrimination laws, the recipient from
whom the sub-recipient received funds shall be subject to the
imposition of funding restrictions and other appropriate remedies
available under this part.
(b) Records and information. The Department, each recipient, and
each sub-recipient shall maintain complete and accurate records
evidencing compliance with Federal health care conscience and
associated anti-discrimination laws and this part, and afford OCR, upon
request, reasonable access to such records and information in a timely
manner to the extent OCR finds necessary to determine compliance with
the Federal health care conscience and associated anti-discrimination
laws and this part.
(c) Cooperation. The Department, each recipient, and each sub-
recipient
[[Page 3930]]
shall cooperate with any compliance review, investigation, interview,
or other part of OCR's enforcement process, which may include the
production of documents, the participation in interviews, the response
to data requests, and the making available of premises for inspection
where relevant. Failure to cooperate may result in an OCR referral to
the Department of Justice for further enforcement in Federal court or
otherwise.
(d) Reporting requirement. If a recipient or sub-recipient is
subject to an OCR compliance review, investigation, or complaint filed
with OCR regarding the recipient's or sub-recipient's compliance with
Federal health care conscience and associated anti-discrimination laws,
the recipient or sub-recipient must inform any Departmental funding
component of such review, investigation, or complaint and must, in any
application for new or renewed Federal financial assistance or
Departmental funding, disclose the existence of such compliance review
or investigation, and must also report on such applications, or in a
separate writing with such applications, the existence of any such
complaints filed with OCR for five years from such complaints' filing.
(e) Intimidating or retaliatory acts prohibited. Neither the
Department nor any recipient or sub-recipient shall intimidate,
threaten, coerce, or discriminate against any person, entity, or health
care entity for the purpose of interfering with any right or privilege
under the Federal health care conscience and associated anti-
discrimination laws or this part, or because such person, entity, or
health care entity has made a complaint or participated in any manner
in an investigation or review under the Federal health care conscience
and associated anti-discrimination laws or this part.
Sec. 88.7 Enforcement authority.
(a) In general. OCR has been delegated the authority to enforce the
Federal health care conscience and associated anti-discrimination laws,
which includes the authority to:
(1) Receive and handle complaints;
(2) Initiate compliance reviews;
(3) Conduct investigations;
(4) Supervise and coordinate compliance within the Department;
(5) In coordination with the relevant component or components of
the Department, make enforcement referrals to the Department of
Justice; and
(6) In coordination with the relevant component or components of
the Department, take other appropriate remedial action as the Director
of OCR deems necessary and as allowed by law to overcome the effects of
violations of Federal health care conscience and associated anti-
discrimination laws and this part.
(b) Complaints. Any entity, health care entity, or any person,
individually, as a member of a class, on behalf of others, or on behalf
of an entity, may file a complaint with OCR alleging any potential
violation of Federal health care conscience and associated anti-
discrimination laws or this part. OCR shall coordinate handling of
complaints with the relevant Department component. The complaint filer
is not required to be the person, entity, or health care entity whose
rights under the Federal health care conscience and associated anti-
discrimination laws or this part have been potentially violated.
(c) Periodic compliance reviews. OCR may from time to time conduct
compliance reviews or use other similar procedures as necessary to
permit OCR to investigate and review the practices of the Department,
Department components, recipients, and sub-recipients to determine
whether they are complying with Federal health care conscience and
associated anti-discrimination laws and this part. OCR may conduct
these reviews in the absence of a complaint.
(d) Investigations. OCR shall make a prompt investigation, whenever
a compliance review, report, complaint, or any other information found
by OCR indicates a threatened, potential, or actual failure to comply
with Federal health care conscience and associated anti-discrimination
laws or this part. The investigation should include, where appropriate,
a review of the pertinent practices, policies, communications,
documents, compliance history, the circumstances under which the
possible noncompliance occurred, and other factors relevant to
determining whether the Department, Department component, recipient, or
sub-recipient has failed to comply. OCR shall use fact-finding methods
including, but not limited to, site visits, interviews with
complainants, the Department component, recipients, sub-recipients, or
third-parties, and written data or discovery requests. OCR may seek the
assistance of any State agency.
(e) Destruction of evidence. Consistent with Sec. 88.6(b) and (c),
a Department component, recipient, or sub-recipient that knowingly or
recklessly destroys evidence potentially relevant to an OCR
investigation or compliance review that is ongoing or reasonably
anticipated shall be in violation of this part.
(f) Failure to respond. Absent good cause, a party's failure to
respond to a request for information or a data or document request
within 45 days of OCR's request, shall constitute a violation of this
part.
(g) Related administrative or judicial proceeding. Consistent with
other applicable Federal laws, testimony and other evidence obtained in
an investigation or compliance review conducted under this part may be
used by the Department for, and offered into evidence in, any
administrative or judicial proceeding related to this part.
(h) Supervision and coordination. If as a result of an
investigation, compliance review, or other enforcement activity, OCR
determines that a Department component appears to be in noncompliance
with its responsibilities under Federal health care conscience and
associated anti-discrimination laws or this part, OCR will undertake
appropriate action with the component to assure compliance. In the
event that OCR and the Department component are unable to agree on a
resolution of any particular matter, the matter shall be submitted to
the Secretary for resolution. OCR may from time to time delegate to
officials of the Department responsibilities in connection with the
effectuation of Federal health care conscience and associated anti-
discrimination laws and this part, including the achievement of
effective coordination and maximum uniformity within the Department.
(i) Referral to the Department of Justice. If as a result of an
investigation, compliance review, or other enforcement activity, OCR
determines that a recipient or sub-recipient is not in compliance with
the Federal health care conscience and associated anti-discrimination
laws or this part, OCR may, in coordination with the relevant
Department component make referrals to the Department of Justice for
further enforcement in Federal court or otherwise.
(j) Resolution of matters. (1) If an investigation or compliance
review reveals that no action is warranted, OCR will so inform the
subject of the complaint or review and complainant, if any, in writing.
(2) If an investigation or compliance review indicates a failure to
comply with Federal health care conscience and associated anti-
discrimination laws or this part, OCR will so inform the relevant
parties and the matter will be resolved by informal means whenever
possible. Attempts to resolve matters informally shall not preclude OCR
from simultaneously pursuing any action described in Sec. 88.7(j)(3).
[[Page 3931]]
(3) If there appears to be a failure or threatened failure to
comply with Federal health care conscience and associated anti-
discrimination laws or this part, compliance with these laws and this
part may be effected by the following actions, taken in coordination
with the relevant Department component:
(i) Temporarily withholding cash payments, in whole or in part,
pending correction of the deficiency;
(ii) Denying use of Federal financial assistance or other Federal
funds from the Department, including any applicable matching credit, in
whole or in part;
(iii) Wholly or partly suspending award activities;
(iv) Terminating Federal financial assistance or other Federal
funds from the Department, in whole or in part;
(v) Withholding new Federal financial assistance or other Federal
funds from the Department, in whole or in part, administered by or
through the Secretary for which an application or approval is required,
including renewal or continuation of existing programs or activities or
authorization of new activities;
(vi) Referring the matter to the Attorney General for proceedings
to enforce any rights of the United States, or obligations of the
recipient or sub-recipient, created by Federal law; and
(vii) Taking any other remedies that may be legally available.
Sec. 88.8 Relationship to other laws.
Nothing in this part shall be construed to preempt any Federal,
State, or local law that is equally or more protective of religious
freedom and moral convictions. Nothing in this part shall be construed
to narrow the meaning or application of any State or Federal law
protecting free exercise of religious beliefs or moral convictions.
Sec. 88.9 Rule of construction.
This part shall be construed in favor of a broad protection of free
exercise of religious beliefs and moral convictions, to the maximum
extent permitted by the terms of the Federal health care conscience and
associated antidiscrimination statutes implemented by the Constitution.
Sec. 88.10 Severability.
Any provision of this part held to be invalid or unenforceable
either by its terms or as applied to any person, entity, or
circumstance shall be construed so as to continue to give the maximum
effect to the provision permitted by law, unless such holding shall be
one of utter invalidity or unenforceability, in which event such
provision shall be severable from this part, which shall remain in full
force and effect to the maximum extent permitted by law. A severed
provision shall not affect the remainder of this part or the
application of the provision to other persons or entities not similarly
situated or to other, dissimilar circumstances.
Appendix A to Part 88--Notice Concerning Federal Health Care Conscience
and Associated Anti-Discrimination Protections
[Name of recipient, the Department, or Department component]
complies with Federal health care conscience and associated anti-
discrimination laws and does not exclude, treat adversely, coerce,
or otherwise discriminate against persons or entities on the basis
of their religious beliefs or moral convictions. You have the right
to decline to participate in, refer for, undergo, or pay for certain
health care-related treatments, research, or services (such as
abortion or assisted suicide, among others) which violate your
conscience, religious beliefs, or moral convictions under Federal
law.
If you believe that [Name of recipient, the Department, or
Department component] has failed to accommodate your conscientious,
religious, or moral objection, or has unlawfully discriminated
against you on those grounds, you can file a conscience and
religious freedom complaint with the U.S. Department of Health and
Human Services, Office for Civil Rights, electronically through the
Office for Civil Rights Complaint Portal, available at https://ocrportal.hhs.gov/ocr/portal/lobby.jsf or by mail or phone at: U.S.
Department of Health and Human Services, 200 Independence Avenue SW,
Room 509F, HHH Building, Washington, DC 20201, 1-800-368-1019, 800-
537-7697 (TDD). Complaint forms and more information about Federal
health care conscience and associated anti-discrimination laws are
available at http://www.hhs.gov/conscience.
Dated: January 18, 2018.
Eric D. Hargan,
Acting Secretary, Department of Health and Human Services.
[FR Doc. 2018-01226 Filed 1-19-18; 11:15 am]
BILLING CODE 4153-01-P