(Recorded) Title X Final Rule & Current Legal Challenges
Update: Please note that after the live recording of this webinar the Office of Population Affairs (OPA) announced that Title X recipients have more time to comply with the amended Title X regulations.
- By August 19, 2019,Title X grantees must submit (a) a written assurance stating that the project does not provide abortion and does not include abortion as a method of family planning, and (b) an action plan describing the steps that they will take to come into compliance with all aspects of the amended Title X regulations.
- By September 18, 2019, Title X grantees must submit a written statement that the grant project is in compliance with the amended Title X regulations, except for the physical separation requirements. In addition, for each requirement, the grantee must describe the steps that were taken to ensure that the grant project is in compliance and provide any relevant documentation needed for OPA to verify compliance (e.g., copies of revised policies, plan for monitoring subrecipients, staff training plan).
On March 4, 2019, the U.S. Department of Health and Human Services (HHS) published a final rule dramatically revising the Title X family planning program regulations. Several Federal courts and U.S. Courts of Appeals are currently hearing arguments regarding whether the amended regulations are lawful. Because of a pending hearing before the Ninth Circuit, as of July 3, 2019, the amended regulations are not in effect unless and until the Ninth Circuit issues a ruling in HHS’s favor. This evolving litigation has resulted in considerable confusion regarding the impact of the final rule and the potential outcome of the lawsuits.
This webinar will summarize the key changes to the Title X family planning program, including that the amended regulations:
- Prohibit Title X projects from referring for abortion as a method of family planning
- Require clear financial and physical separation between Title X projects and programs or facilities where abortion is a method of family planning
- Eliminate the requirement to provide options counseling to pregnant women, and require that all pregnant women be referred to prenatal care
- Require that Title X grantees include, as part of their applications, a list of subrecipients and agencies or individuals providing referral by name, location, expertise and services provided or to be provided
This webinar will also briefly describe the legal challenges to the final rule, and will highlight anticipated next steps.
Join FTLF attorneys for an overview of the potential major changes to the Title X program, as well as a summary of the ongoing litigation challenging the final rule.
To register for the live version of this webinar, click here.
Management and/or clinical staff from Title X grantees and subrecipients
After this webinar, you will be able to:
- Understand the process to update the Title X regulations
- Describe key changes to the Title X regulations
- Discuss the current legal challenges to the Title X regulations
CARRIE BILL RILEY
Carrie Bill Riley is a Partner in the health law practice group. She counsels a wide variety of health care clients, including Title X grantees and subrecipeints, and other private and public health care providers, on contracting, regulatory compliance, fraud and abuse, and reimbursement matters. Carrie also provides counsel on transactional matters, including formation and agreements for multi-provider affiliations/joint ventures, general contracting, and residency training arrangements. Prior to going to law school, Carrie worked at a Title X regional training center for several years. [Full Bio]
CHRISTOPHER ("CJ") FRISINA
As of October 2019, Christopher is no longer with the firm.
Christopher (“CJ”) Frisina is an Associate with the Firm in the Federal Grants and Health Law practice groups. In this role, CJ routinely advises clients on the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the “Uniform Guidance”) and assists clients facing cost disallowances, deficiency findings, and grant terminations, resolving many through negotiations with agency officials prior to the need for any administrative appeal or federal litigation.
There are no continuing professional education (CPE) credits associated with this course.
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