Administrative State Accountability Project

The administrative state, made up of federal agencies, has a very powerful, though largely invisible influence on law, politics, and culture in the United States. Agency regulations, which have the force and effect of law, are issued by unelected agency officials and are the result of a complex process. A single rule can rewrite or change the meaning, application, and enforcement of laws passed by elected Members of Congress.  

EPPC’s Administrative State Accountability Project (ASAP), directed by Rachel N. Morrison, advocates for an authentic understanding of the human person in the drafting, implementation, and rollback of government regulations.  

Emphasizing a sound understanding of the legal protections Americans are entitled to, including religious freedom, health care rights of conscience, and the right to life, Project scholars engage in the agency rulemaking process by providing legal and policy expertise on proposed regulations, submitting public comments, meeting with government officials, and equipping others to participate. 

Formerly called the HHS Accountability Project, the work of the Project has expanded to include other agencies. 

Project scholars regularly publish articles, advise policymakers, give presentations, and file amicus briefs to advance the Project’s priorities. 

EPPC Fellow Eric Kniffin and Legal Associate Sam Lucas also serve in the Administrative State Accountability Project. 


Engagement on Agency Actions

To shape policy, EPPC monitors and engages with federal agency actions. EPPC primarily engages in the rulemaking process by submitting written public comments and requesting meetings with government officials to provide input and specific suggested changes or improvements the agency must consider for its rulemaking. EPPC scholars also educate other organizations and individuals on how to effectively engage in the regulatory process and provide legal and policy expertise on various agency actions.

Amicus Briefs

EPPC and our scholars regularly file amicus briefs in key cases to promote a true and full account of human nature and human flourishing in the context of American constitutional law. Compiled on this page are some of our amicus briefs in cases addressing the right to life, marriage, gender ideology, religious freedom, free speech, and the rule of law. 

How to File a
Federal Conscience Complaint

How to Submit a Public Comment on Agency Rulemaking

How to Request a Meeting with Government Officials on Agency Rulemaking

Program Publications

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EPPC Scholars Support EEOC’s Draft Strategic Plan for Addressing Employment Discrimination

Eric Kniffin, Rachel N. Morrison

On July 19, 2026, EEPC scholars Rachel N. Morrison and Eric Kniffin submitted a public comment in support of the…

Public Comments

PDF / July 20, 2026

EPPC Scholars Encourage CMS to Stop States from Creating Unlawful Insurance Mandates

Eric Kniffin, Jamie Bryan Hall, Rachel N. Morrison

On July 13, 2026, EPPC Scholars Eric Kniffin, Rachel N. Morrison, and Jamie Bryan Hall submitted a public comment to…

Public Comments

PDF / July 20, 2026

EPPC Scholars Offer Support and Suggestions for the Presidential Religious Liberty Commission’s Draft Report

Eric Kniffin, Rachel N. Morrison

On July 13, 2026, EPPC Scholars Eric Kniffin and Rachel N. Morrison submitted a public comment in response to a…

Public Comments

PDF / July 20, 2026

EPPC Scholars Encourage HHS to Ensure Healthcare Benefits Promote Restorative Reproductive Medicine, Treat Diagnosed Infertility

Aaron Kheriaty, Eric Kniffin, Jamie Bryan Hall, Katelyn Walls Shelton, Rachel N. Morrison

On July 13, 2026, EPPC Scholars Eric Kniffin, Rachel N. Morrison, Aaron Kheriaty, Katelyn Walls Shelton, and Jamie Bryan Hall…

Public Comments

PDF / July 20, 2026

EPPC Scholars Submit Comment Supporting Uniform Agency Regulations for Federal Financial Assistance

Eric Kniffin, Jamie Bryan Hall, Rachel N. Morrison

EPPC scholars Rachel N. Morrison, Eric Kniffin, and Jamie Bryan Hall submitted a public comment supporting a proposed rule by the Office…

Public Comments

PDF / July 16, 2026

EPPC Scholars Urge FTC to Evaluate X Corp.’s Consent Decree to Protect Citizens from Censorship

Aaron Kheriaty, Rachel N. Morrison, Ryan T. Anderson

On July 2, 2026, EEPC President Ryan T. Anderson and EPPC Fellows Rachel N. Morrison and Aaron Kheriaty submitted a…

Public Comments

PDF / July 2, 2026

EPPC Scholar Submits Comment Supporting Housing Regulations that Recognize Biological Reality and Protect Safety and…

Rachel N. Morrison

On June 29, 2026, EPPC scholar Rachel N. Morrison submitted a public comment encouraging the Department of Housing and Urban…

Public Comments

PDF / June 30, 2026