EPPC Scholars and Others Submit Comments on HHS Proposal to Facilitate Abortions and Medical Gender Transitions for Unaccompanied Children 


December 6, 2023


On Monday, December 4, 2023, EPPC scholars Rachel N. Morrison and Mary Rice Hasson submitted a public comment on proposed changes to the unaccompanied children program. 

The rule, proposed by the Department of Health and Human Services’ Administration for Children and Families (ACF), relates “to the key aspects of the placement, care, and services provided to unaccompanied children” by the Office of Refugee Resettlement (ORR). The EPPC scholars’ comment focused on their concerns on ACF’s proposal that ORR consider “LGBTQI+ status” in making placements, facilitate abortions, and likely also facilitate medical “gender transitions” for unaccompanied children. 

As the EPPC scholar argued

Nothing in any federal statute gives ACF the power to mandate that ORR facilitate abortions. There is no constitutional right to abortion and no statutory obligation to pay for abortion or related travel. Abortion kills an unborn child and harms the mother. We call on ACF to clarify whether its proposal would mandate that ORR facilitate access to medical gender transitions for unaccompanied children. These medical interventions are harmful and should not be provided to children. Moreover, these proposals raise federalism concerns, implicate religious freedom and conscience rights, and negatively impact family well-being. 

The scholars urged ACF to drop the requirements that ORR consider “LGBTQI+ status” for placements and facilitate abortions and medical gender transitions for unaccompanied children. 

Religious, prolife, family, legal, and policy organizations also submitted public comments on HHS’ proposal. 

About the EPPC comment signers: 

Rachel N. Morrison, J.D., is an EPPC Fellow, director of EPPC’s HHS Accountability Project, and former attorney at the Equal Employment Opportunity Commission. 

Mary Hasson, J.D., is the EPPC Kate O’Beirne Senior Fellow, an attorney, and co-founder of EPPC’s Person and Identity Project, an initiative that equips parents and faith-based institutions to counter gender ideology and promote the truth of the human person. 

Others submitting comments on the proposed rule include: 


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