Project 2025 Has Bad Medicine for HHS

Roger Severino, a prominent attorney for the Christian right, led the Department of Health and Human Services’ Office of Civil Rights during the Trump administration. In 2017, The Atlantic called him “the man behind Trump’s religious-freedom agenda for health care.” The profile contrasted Severino’s sparsely decorated office—adorned with a crucifix and a Clarence Thomas bobblehead—with his elaborate domestic agenda.

During Severino’s time there, Trump’s Department of Health and Human Services weakened the Affordable Care Act; strengthened the ability of healthcare providers to claim religious exemptions from providing all kinds of medical care, from abortion to birth control to vasectomies to gender-affirming care; and created a Conscience and Religious Freedom Division in his office. Under Severino’s legal counsel, HHS cut teen-pregnancy prevention programs and prioritized abstinence in its Title X family-planning grants. Backing Severino’s crusade was his boss, HHS secretary and former Eli Lilly president Alex Azar, best known for helping Trump botch his Covid response and presiding over his border policy of separating migrant children from their parents. Azar came to call his department “the Department of Life.”

In his chapter of Project 2025’s Mandate for Leadership, Severino promises to make HHS the “Department of Life” again—and to go even farther than Azar did. The plan outlines how HHS would use its power as a federal agency to dramatically curtail access to reproductive health services. Severino pledges that HHS will restrict access to birth control, rescind the FDA’s approval of medication abortion, and abolish what he calls “mail-order abortion”—the latter by using the long-dormant Comstock Act to prosecute anyone who provides such medication by mail. HHS will also focus on weeding out programs geared to the rights of LGBT people, especially anyone who is transgender. It would direct subsidies for childcare facilities to parents themselves—all in a punitive, misguided effort to shore up the nuclear family. This isn’t a public health document; it’s a theocratic manifesto, an attempt at ensuring public health through ultra-orthodox Christianity.

So much for “religious freedom.” Under “the next administration” (read: a Trump administration), Severino recommends that nearly every HHS program or agency—with special emphasis on the Administration for Children and Families, the Centers for Disease Control and Prevention, the Food and Drug Administration, the National Institutes of Health, and the Office of the Surgeon General—be retooled with the goal of promoting heterosexual marriage and procreation. He argues that the next president should use his powers to “maintain a biblically based, social science–reinforced definition of marriage and family.” Of course, he believes that “families comprised of a married mother, father, and their children are the foundation of a well-ordered nation and healthy society.” He claims that “all other family forms” apart from “heterosexual, intact marriage…involve higher levels of instability.”

Severino attacks President Biden for “focusing on ‘LGBTQ+ equity,’ subsidizing single motherhood, disincentivizing work, and penalizing marriage”—while offering no examples of his policies that did any of the last three things. Severino calls on HHS to repeal antidiscrimination policy statements that identify sex with “gender identity or sexual orientation.” Here’s the crescendo: “Working fathers are essential to the well-being and development of their children, but the United States is experiencing a crisis of fatherlessness that is ruining our children’s futures.”

Thus, HHS policies would “prioritize married father engagement” and stress the importance of heterosexual marriage in all of its health, education, and welfare programs, and it would even enable child-abuse prevention funds to be applied to marriage promotion efforts. The CDC would be directed to “eliminate programs and projects that do not respect human life and conscience rights and that undermine family formation.”

The anti-abortion crusade, too, would continue throughout each of the department’s agencies: “HHS should return to being known as the Department of Life by explicitly rejecting the notion that abortion is health care,” and the secretary should make sure that “all HHS programs and activities are rooted in a deep respect for innocent human life from day one until natural death.” He or she would see to it that no funding whatsoever goes to abortion—not via Hyde Amendment exceptions for rape, incest, or the life of the mother; not even via private insurance subsidized by the Affordable Care Act. Severino recommends eliminating the HHS Reproductive Healthcare Access Task Force and creating a “pro-life task force to ensure that all of the department’s divisions seek to use their authority to promote the life and health of women and their unborn children.”

Severino would force the FDA to “reverse its approval of chemical abortion drugs because the politicized approval process was illegal from the start. The FDA failed to abide by its legal obligations to protect the health, safety, and welfare of girls and women.” This argument is in front of the Supreme Court right now, and even some of the conservative justices don’t appear to be convinced by it.

Severino promises that no Medicaid funding will go to Planned Parenthood. He also proposes reversing a Biden administration regulation that groups receiving Title X funds must be willing to “refer” women to abortion providers even if they don’t provide abortion themselves, thereby allowing “otherwise qualified pro-life grantees” to receive funding.

Severino also aims to restrict access to birth control, which many of us said would be the right’s next priority after banning abortion wherever possible. He announces that HHS must promote “public messaging about the unsurpassed effectiveness [fact check: This is widely disputed] of modern fertility awareness–based methods (FABMs) of family planning…. CDC should fund studies exploring the evidence-based methods used in cutting-edge fertility awareness.” Severino calls for HHS to prohibit women’s health facilities that receive Title X funding from distributing condoms. And by declaring that life begins at conception, his manifesto appears to commit HHS to finding ways to outlaw IVF, which relies on generating multiple embryos, most of which are not implanted. It could also eliminate birth control methods like the IUD and even some forms of the pill.