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, Policy Analyst Natalie Dodson, 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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Trump HHS Clarifies Biden Rule on Gender Dysphoria Discrimination Is Not Enforceable

Rachel N. Morrison

On April 11, 2025, the Trump Department of Health and Human Services (HHS) issued a “clarification” document “out of an abundance of…

Articles

The Federalist Society / April 15, 2025

EPPC Scholars Submit Comment Supporting HHS’s Proposed Removal of Sex-Rejecting Procedures from Essential Health Benefits 

Eric Kniffin, Jamie Bryan Hall, Mary Rice Hasson, Rachel N. Morrison

On Friday, April 11, 2025, EPPC scholars Eric Kniffin, Rachel N. Morrison, Mary Rice Hasson, and Jamie Bryan Hall submitted…

Articles

PDF / April 15, 2025

EPPC Scholar Submits Public Comments Supporting FDA Consideration of Sex Differences

Rachel N. Morrison

On April 7, 2025, EPPC Administrative Accountability Project Director Rachel N. Morrison submitted two public comments in response to draft…

Articles

 

EPPC Scholar Submits Public Comment Testimony Urging Washington State Not to Erase Clergy-Penitent Privilege, Pressure…

Eric Kniffin

On Tuesday, March 18, EPPC scholar Eric Kniffin submitted public comment on Senate Bill 5375, pending before the Washington State…

Articles

PDF / March 20, 2025

EPPC Scholars Submit Comment Encouraging Agency to Ensure Telemedicine Rules Respect States’ Rights  

Eric Kniffin, Rachel N. Morrison

On March 18, 2025, EPPC scholars Eric Kniffin and Rachel N. Morrison submitted a public comment in response to the…

Articles

PDF / March 19, 2025

EPPC Scholars Urge Government Officials to Rescind Department of Veterans Affairs Rule Mandating Taxpayer-Funded Abortion…

Natalie Dodson, Rachel N. Morrison

On Tuesday, March 17, 2025, EPPC scholars Rachel N. Morrison and Natalie Dodson met with government officials in the Executive…

Articles

PDF / March 19, 2025

EPPC Supreme Court Amicus Brief Defends Parents’ Free Exercise Right to Protect Children from Gender…

Eric Kniffin

On March 10, the Ethics and Public Policy Center filed a Supreme Court amicus brief in Mahmoud v. Montgomery County (MD)…

Articles

PDF / March 19, 2025

Program Media

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Natalie Dodson discusses the moral dilemma of IVF

The American Mind Roundtable / February 19, 2025

Natalie Dodson discusses pro-life executive orders

EWTN Pro-Life Weekly / January 30, 2025

Rachel Morrison answers “Is Gender Dysphoria a Protected Disability?”

Fourth Branch Podcast / December 18, 2024

Eric Kniffin on Tennessee Senate Bill 1

The Federalist Society / November 26, 2024

Eric Kniffin on Creating a Culture of Support for Catholic Health Care

Catholic Healthcare Leadership Alliance / November 2, 2024

Rachel Morrison discusses Religious Liberty, Conscience Rights, and Federal Power

Faithful Politics Podcast / November 2, 2024

Rachel Morrison discusses Presidential Powers and Abortion

University of St. Thomas / October 31, 2024