Executive Summary
The National Health Law Program submitted comments on the Department of Health and Human Services’s (HHS) Notice of Proposed Rulemaking to implement federal health care refusal laws, called “Safeguarding the Rights of Conscience as Protected by Federal Statutes.” Our comments thank HHS for proposing to rescind the most harmful provisions of its 2019 final rule on the subject. We also highlight opportunities to strengthen the proposed rule and further minimize harm to low-income and underserved populations most often affected by refusals of care, including women, LGBTQI+ people, people with disabilities, and people who live in rural communities.