Project 2025 Tracker / What’s done, what’s next

14. Department of Health and Human Services · Minor

Restore OCR authority over RFRA vaccine accommodation requests

Partially done

495 14. Department of Health and Human Services

“HHS should restore OCR authority to review requests for and render opinions on the application of RFRA to requests for religious accommodation of people, families, and doctors who cannot in good conscience take or administer vaccines, including those made or tested with aborted fetal cell lines.”

What has happened

  1. Partially done

    HHS's June 2026 OCR reorganization restores to OCR an independent conscience and religious freedom program: the department's mission statement for the office now includes ensuring that federal agencies, state and local governments, providers, plans and other covered entities "comply with Federal laws protecting the free exercise of religion and conscience and the right to be free from coercion in HHS-conducted or funded programs", and the re-created Conscience and Religious Freedom Division holds that program. The authority limb is delivered. The specific function the Quote names is not: RFRA is not among the statutes the notice assigns to the division, and no allowlisted document shows OCR reviewing or rendering opinions on religious accommodation requests about vaccines, including vaccines made or tested with aborted fetal cell lines.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • Federal Register full text “Religious Freedom Restoration Act” since 2025-01-20: seven documents - EO 14202, the two January 2026 OCR rescission notices, an HHS Privacy Act notice, an Education accountability rule, a CMS model rule and the OMB grants proposal. None is a vaccine-accommodation review mechanism.
  • The delegation rulemaking that would settle this, RIN 0945-AA24, is unpublished; its listed alternatives include “engaging in technical rulemaking only to add related authorities to OCR’s delegation to enforce the federal health care conscience statutes”.
  • #1239 (RFRA waiver for importing ethically derived vaccines) is a separate item; this item is the domestic accommodation-review ask.
Action
restore
Object
OCR authority over RFRA vaccine accommodation requests
ID
1394