Joint Letter on Nondiscrimination in Health Programs and Activities

On behalf of the United States Conference of Catholic Bishops, National Association of Evangelicals, Christian Medical Association, Institutional Religious Freedom Alliance, Christian Legal Society, World Vision (US), Ethics and Religious Liberty Commission of the Southern Baptist Convention, Liberty Institute, Family Research Council, and the National Catholic Bioethics Center, we respectfully submit the following comments on

November 18, 2015

We agree that the prevention of sex discrimination in health programs and activities is a laudable statutory goal. Everyone should have access to health care and health coverage. The proposed regulations are problematic, however, because they construe sex discrimination to include— •discrimination based on “termination of pregnancy” (insofar as this might be read to require the provision of, or coverage or referral for, abortion). •discrimination based on “gender identity.” •the categorical or automatic exclusion by an insurer of “services related to gender transition,” and the denial or limitation of coverage of such services in some circumstances. •discrimination based on “sex stereotypes,” defined to protect “individuals who identify as neither, both, or as a combination of male and female genders.” •discrimination based on the sex of a person with whom an individual has a “relationship or association” (insofar as this might be read to treat same-sex relationships as a classification protected at law).


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