Published July 18, 2022
On Friday, July 15, 2022, EPPC Fellow Rachel N. Morrison met with federal government officials to discuss concerns over an upcoming proposed rule by nine different agencies that would alter regulations for faith-based organizations partnering with federally-funded social service programs across the nine agencies.
Among other points, she raised the following concerns:
- The agencies must identify a need and show how the rule meets that need, especially for any proposed notice-and-referral requirement.
- The agencies must apply recent Supreme Court cases, which are particularly relevant to any redefinition of “indirect.”
- The agencies should consult EEOC’s Religion Guidance for direction on the scope of Title VII’s religious organization exemptions.
- The agencies cannot discriminate or encourage discrimination under the guise of “equity.”
- The agencies must consider the rule’s costs and transfers, especially those related to any religious accommodation regulation changes.
A written version of those comments, submitted to the government, is available here (PDF).