Withdraw funding from entities that violate conscience laws

What has happened

1. May 29, 2026 Partially done

   OMB, with HHS among 43 co-proposing agencies, proposed to revise the government-wide grants regulation at 2 CFR 200.300 so that the non-discrimination language in Federal awards expressly covers religion and conscience, so that compliance reviews may test whether a recipient complies with "Federal civil rights laws or conscience protection laws", and so that agencies and pass-through entities may not require discretionary case-by-case approval of conscience or religious accommodation requests. That is the Quote's second limb - telling grantees their conscience obligations are a condition of funding - proposed but not final. **No withdrawal of funding from a violating entity is on the record, and the negative is now complete rather than blocked.** OCR's own chronological conscience action list (page reviewed 2026-04-30) was enumerated on 2026-09-03: the in-window entries are the April 2026 and January 2026 fact sheets, the Illinois Notice of Violation, the Safeguarding Federal Conscience Dear Colleague Letter, three January 2026 rescission and disavowal notices, and two 2025 Dear Colleague Letters on the Vaccines for Children Program. **The only funding-withdrawal action OCR has ever listed is "December 16, 2020, HHS to Disallow $200M in California Medicaid Funds…"** — five weeks before the window opened, itself withdrawn in 2021 and disavowed again on 2026-01-21. OCR's conscience newsroom (`/conscience/newsroom/index.html`, reviewed 2025-02-07) lists no news releases or bulletins at all, only a link to a 2018–2024 archive. And HHS-OIG has published nothing: `conscience` returns 0 reports and 0 Work Plan projects, both control-verified. Re-leveled `partial` in place on 2026-09-29 by owner decision, for the same reason: the proposed rule is a further step inside a rung the October 2025 Grants Policy Statement had already reached.

   • OMB and 43 agencies including HHS, proposed rule: Regulation for Federal Financial Assistance (2 CFR 200.300)

     Primary Executive branch May 29, 2026

2. Jan 21, 2026 Partially done

   OCR issued a **Notice of Violation of the Weldon and Coats-Snowe Amendments to the State of Illinois**, read in full on 2026-09-03. It finds that the Illinois Health Care Right of Conscience Act as amended by P.A. 99-690 violates both Amendments, gives Illinois thirty days to say whether it will enforce the provision against objectors or take corrective action, and states that otherwise OCR "will forward this Notice of Violation and the evidence supporting OCR's findings in this matter to the appropriate HHS funding components for further action under applicable grants and contracts regulations … Such actions may ultimately result in suspensions, terminations, or other limitations on continued receipt of certain HHS funds." That is the enforcement step immediately short of the withdrawal the Quote asks for. Re-leveled `partial` in place on 2026-09-29 by owner decision: the October 2025 Grants Policy Statement had already put the item at `partial`, so this enforcement step is recorded within that rung rather than as a fall.

   • HHS OCR Notice of Violation of the Weldon and Coats-Snowe Amendments to the State of Illinois — OCR finds the Illinois Health Care Right of Conscience Act as amended violates both Amendments and warns that failure to give assurance may be referred to HHS funding components and 'may ultimately result in suspensions, terminations, or other limitations on continued receipt of certain HHS funds'

     Primary Executive branch Jan 21, 2026

3. Oct 1, 2025 Partially done

   HHS's department-wide grant terms now tell every recipient that the federal conscience statutes bind the award. The HHS Grants Policy Statement, Version 2.0, effective 2025-10-01, was read in full on 2026-09-29. It is "incorporated by reference in the official Notice of Award (NoA) as a standard term and condition" and applies to all HHS discretionary awards except NIH's, and its Appendix D reaches non-discretionary awards too. Appendix D.4 lists the laws that "apply to all recipients and subrecipients". Among them, for the first time, is Discrimination Based on Religion and Religious Conscience: "Church Amendments, 42 USC 300a-7; Coates-Snowe Amendment, 42 USC 238n; and the Weldon Amendment", marked "See General Certifications and Representations", the certifications every applicant makes at SAM.gov registration. None of the three earlier editions (October 2024, April 2025, July 2025) mentions conscience or any of the three statutes. That delivers a piece of the Quote's second limb, grant instruments that inform grantees of their conscience obligations as a condition of funding, through ASFR's grants policy. It is `partial` and not `done`. NIH awards are outside it, and the funding announcements themselves were not changed to say so: the 2026 TPP NOFO's conscience section tells grantees what they are protected from, not what they must comply with. The first limb, withdrawing funding from a violator, is at `attempted`.

   • HHS Grants Policy Statement, Version 2.0 (effective 2025-10-01): Appendix D.4 lists the Church, Coates-Snowe and Weldon conscience provisions among the laws binding all recipients and subrecipients

     Primary Executive branch Oct 1, 2025