(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.

Target Audience

Management and/or clinical staff from Title X grantees and subrecipients

Learning Objectives

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
Course summary
Available credit: 
  • 1.50 Certificate of Attendance
Course opens: 
Course expires: 


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]


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.

Certificates of Attendance: We verify attendance upon completion of a webinar (live or recorded version) and will only issue certificates in the name of the account holder enrolled in the course. If you need to document attendance for someone other than the account holder, we provide blank Certificates of Attendance for a supervisor to sign and certify that a different individual viewed the course. 

Group Attendance: Due to the online nature of webinars, we cannot verify participation by more than one person. For groups, we provide an attendance record form and blank Certificates of Attendance to record attendance at a group viewing session and document each individual's participation. We recommend that a supervisor or colleague sign the certificate to certify attendance. 

Read more about maintaining an attendance record in our FAQs.

Available Credit

  • 1.50 Certificate of Attendance
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Required Hardware/Software

Google Chrome and Mozilla Firefox are the preferred browsers.