Roger Severino wrote the HHS chapter of Project 2025. The Trump administration is delivering it.
- The Department of Health and Human Services is reinstating the Conscience and Religious Freedom Division that Roger Severino first built in 2018.
- The Equal Employment Opportunity Commission (EEOC), in the same week, moved to scrap the EEO-1 report that has anchored federal workplace discrimination enforcement for 60 years.
- A federal Task Force to Eradicate Anti-Christian Bias, created by Trump executive order in February, released a 200-page report that HHS now cites by name in its restructuring announcements.
On May 20, the Department of Health and Human Services announced it would split its Office for Civil Rights into three divisions. One would handle traditional civil rights complaints. One would handle health information privacy. The third would be called the Conscience and Religious Freedom Division — a resurrection of the office that Roger Severino created in 2018 while he was running it for Trump. The Biden administration dissolved Severino’s division in 2023. In Severino’s Project 2025 chapter, he called on the next Republican president to bring it back.
Severino’s Project 2025 chapter laid out what he wanted out of the agency. Abortion was no longer to be treated as health care. The Food and Drug Administration should pull its approval of medication abortion. The Hyde Amendment’s narrow exceptions for rape, incest, and the life of the mother needed to go. Severino also called for reviving the Comstock Act, which would expose anyone shipping abortion medication through the mail to federal prosecution. Federal healthcare nondiscrimination protections for LGBTQ+ patients would be stripped out altogether.
The Atlantic, in a 2017 profile of Severino’s first tour at the Office for Civil Rights, described his sparsely furnished office, the crucifix on the wall, and the Clarence Thomas bobblehead on the desk. The Human Rights Campaign called him “a radical anti-LGBTQ-rights activist.” During his four years running the office, he stripped federal protections for transgender patients and weakened the Affordable Care Act’s nondiscrimination provisions. He redirected Title X family planning grants toward abstinence programs. His signature project, the Denial of Care Rule, would have let any healthcare worker refuse to participate in any procedure on religious grounds, including in emergencies. A federal court blocked the rule before it could take effect.
Biden pushed Severino out in 2021. He moved to the Ethics and Public Policy Center for a stretch, then to Heritage, where he served as director of the HHS Accountability Project. He spent those years writing the Project 2025 chapter and waiting for the election.
HHS Secretary Robert F. Kennedy Jr. called the new division a promise that Americans “will never have to choose between their faith and their livelihood.” The Office for Civil Rights has been making good on that promise for months. When a pediatric nurse refused to administer puberty blockers, the office opened a complaint on her behalf. It took up the cases of clinical technicians who would not perform ultrasounds during abortion procedures. By the time HHS announced the new division on May 20, the office was already pursuing nearly 20 conscience-related enforcement actions.
Every one of those enforcement actions has a patient on the other end. The conscience statutes the office cites carry no requirement that a refusing worker hand the prescription to a colleague, refer the patient elsewhere, or even tell the patient where to go next. In Petoskey, Michigan, a pharmacist told Rachel Peterson he was “a good Catholic male” and would not fill the misoprostol her doctor had prescribed for her miscarriage. He refused to transfer the script. Peterson drove three hours to another pharmacy. That was 2018, before the new enforcement infrastructure existed. Misoprostol manages miscarriage by expelling retained tissue. Without it, she faced infection or a surgical procedure she did not need.
Anna Nusslock walked into Providence St. Joseph Hospital in Eureka, California, in February 2024. She was pregnant with twins. Her water had broken at 15 weeks. Doctors told her she needed an abortion to prevent life-threatening complications. The hospital refused because the twins still had fetal heart tones. Staff drove her twelve miles to another hospital. She was hemorrhaging on arrival. A year and a half later, Rachel Harrison sued Dignity Health after two of its California hospitals turned her away during separate pregnancies when her water broke early. The second refusal sent her into sepsis. She needed a blood transfusion at a hospital outside her insurance network.
The pediatric nurse the office is defending refused to administer puberty blockers. The patient who needed them is now somewhere in the system without that prescription. The clinical technicians who would not perform ultrasounds had patients in the next room. A 2024 Federal Register docket on the previous administration’s conscience rule logged refusals of prescription refills, denials of gender-affirming care, refusals to process HIV lab specimens, and emergency rooms turning patients away. HHS counts the worker who refused. It does not count the patient who got refused.
The new division gives that work a permanent home.
Back in 2018, when Severino first opened up the division, the American Medical Women’s Association predicted exactly what would happen. A pharmacist invoking conscience would have grounds to turn away a woman asking for birth control. The same logic would let a clinician refuse to perform a Pap smear or send a trans patient out of the office without treatment.
The Persecution Frame
In February 2025, two weeks into his second term, Trump signed an executive order creating the Task Force to Eradicate Anti-Christian Bias. Acting Attorney General Todd Blanche took the chair. On April 30, the task force released a 200-page report alleging that the Biden Justice Department had engaged in systematic religious persecution. Among the grievances: federal prosecutions of anti-abortion protesters under the Freedom of Access to Clinic Entrances (FACE) Act, a leaked Federal Bureau of Investigation memo on traditionalist Catholic networks, and the Biden administration’s posture toward COVID-19 vaccine religious exemptions. Blanche said the cumulative effect “devastated the lives of many Christian Americans.”
Interfaith Alliance, joined by more than two dozen Christian leaders and scholars, rejected the report’s premise. Rev. Paul Brandeis Raushenbush, a Baptist minister who runs the Alliance, described the task force as a vehicle for “a Christian nationalist crusade to undermine Americans’ religious freedom and First Amendment rights.” The task force operates alongside a White House faith office and a Religious Liberty Commission housed at the Justice Department.
HHS has plugged itself directly into that architecture. The agency’s announcements cite the anti-Christian bias report by name. Its fact sheets explain how the agency is clarifying protections for religious refusals by providers. A new whistleblower portal invites medical workers to report employers who expect them to do their jobs. Any hospital, clinic, or health system that declines to accommodate a worker’s religious refusal of standard medical care is now exposed to federal enforcement.
Stop Counting
Two blocks away, the EEOC is working from a different chapter of the same book. Kristie Ellickson, a senior scientist at the Union of Concerned Scientists, put it bluntly: “How do you make workplace injustices disappear? The Trump administration’s plan is to simply stop counting them.”
The instrument is the EEO-1 report. Since 1966, the report has required employers with 100 or more workers to file demographic data on their workforces — sex, race, ethnicity, broken out by job category. The EEOC mines the data to investigate pay disparities and hiring patterns. State and local civil rights agencies pull from the same numbers, and so do researchers, journalists, and the HR departments inside the reporting companies. The dataset covers 56 million American workers across 73,000 employers, the most comprehensive workforce demographic dataset the federal government maintains.
On May 15, the commission notified the Office of Information and Regulatory Affairs that it intends to scrap the report. Twelve former EEOC officials issued a joint statement warning that abandoning data collection would gut evidence-based enforcement of discrimination nationwide. Project 2025 named the EEO-1 collection as a target. The first Trump administration tried to kill it and was stopped. The second one is taking another swing.
This is not the first cut. In May 2025, the commission eliminated the option for employers to count nonbinary workers in the EEO-1. Without the full report, federal discrimination cases lose the data that makes them winnable. A 2024 study used EEO-1 numbers to show that Black, Hispanic, and women workers remain badly underrepresented in high-tech jobs. The Center for Investigative Reporting relied on the same data to expose diversity gaps at Silicon Valley companies. A National Academies of Sciences, Engineering, and Medicine panel used it to establish that pay gaps between men and women and between racial groups cannot be explained by differences in education, experience, or occupation. Without the EEO-1, the commission loses the foundation for the kind of pay-discrimination case that depends on numbers it no longer collects.
As Ellickson notes, the administration is not opposed to collecting demographic data in general. The federal government still collects plenty of demographic data — postsecondary education, for one — where doing so advances the administration’s priorities. The data the commission wants gone is the data that catches discrimination against women, Black, Indigenous, and other people of color (BIPOC), and LGBTQ+ workers in the American workplace.
The Blueprint at Work
Severino didn’t write the EEOC’s chapter. Other Project 2025 authors did, in the labor and corporate policy sections of the same blueprint. At HHS, the Office for Civil Rights is developing federal protections for providers who refuse care on religious grounds. At the EEOC, the federal dataset that records what happens to the worker on the receiving end of those refusals is being phased out. Both announcements landed within 72 hours of each other.
The HHS reorganization comes after 15 months in which the department lost more than 15,000 employees — a broader purge that gutted everything from public health research to community health services. The commission’s move arrives in an administration that has been at war with anything labeled diversity, equity, or inclusion since January 2025, canceling humanities grants and clawing back environmental justice funding along the way.
The Conscience and Religious Freedom Division goes live in the Federal Register in June, and public comment on the EEO-1 rescission opens after that. From there, the federal review clock runs out by year-end, on the schedule the commission has signaled. By then, a pharmacist who refuses to dispense birth control will have a federal office working his complaint, and the dataset that federal discrimination cases have been built on since 1966 will be gone. The next pay-discrimination case the EEOC declines to bring may be the one that reveals what is missing.
