Comments Submitted to Dept. of Health and Human Services on Title X Funding

Charlotte Lozier Institute  

On October 7, the Charlotte Lozier Institute (CLI) filed two separate comments to the Department of Health and Human Services regarding its proposed rule on entities qualifying for the government’s Title X family planning funds. The proposed rule (Compliance with Title X Requirements by Project Recipients in Selecting Subrecipients, 81 FR 61639-61646), which was published September 7, seeks to preclude states from taking action to “restrict participation by certain types of providers as subrecipients in the Title X Program…”


The first comment, filed jointly by Alliance Defending Freedom (ADF), Susan B. Anthony List (SBA List), and CLI, clarifies that “certain types of providers” is a “euphemistic way of referring to elective abortion providers such as Planned Parenthood Federation of America affiliates.” In the comment, ADF, SBA List, and CLI maintain that the proposed rule “contradicts the letter and spirit of Title X not to subsidize elective abortion, and runs contrary to the right of States in our federal system to optimize health care for women.”


In sum:

Because FQHCs [Federally Qualified Health Centers] and RHCs [Rural Health Centers] provide primary preventive care and access to comprehensive diagnostic care, unlike boutique “reproductive healthcare providers,” prioritizing public healthcare funds to such entities is simply better fiscal healthcare policy. The proposed rule should be withdrawn, and the example of State innovation demonstrated by such prioritization systems should be allowed to continue.

To read the full comment, please see: ADF, SBA List, CLI Comment to Proposed Rule Regarding Title X Requirements.


In the second comment that CLI filed jointly with Family Research Council, SBA List, and the March for Life Education and Defense Fund, the groups state their opposition to the proposed rule for the following reasons:

  • the Title X statute does not require states to provide funding to abortion providers;
  • the Title X statute does not preclude grant recipients, including state and local governments, from prioritizing subgrants to organizations that do not perform abortions;
  • the proposed regulation disregards the holistic health care goals of states;
  • HHS’ claims about family planning “effectiveness” lack proper evidence and clear definition; and
  • the proposed HHS regulation itself would undermine health care access and potentially cause a disruption in current healthcare services.

To read the full comment, please see: FRC, SBA List, CLI, March for Life Comment to Proposed Rule Regarding Title X Requirements.


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