For Immediate Release: November 30, 2023  
Contact: Audrey Sandusky,  

NFPRHA Recognizes Sixth Circuit Court Ruling as a Victory for Title X Program 

Statement from Clare Coleman, President & CEO of the National Family Planning & Reproductive Health Association (NFPRHA) 

Washington, DC – “In a win for the Title X family planning program, the US Court of Appeals for the Sixth Circuit today protected a critical provision of the 2021 Title X program rule, upholding a lower court decision to protect abortion referral within Title X, a longstanding requirement in the program. The court also held that the 2021 rule’s program integrity requirements are not a permissible interpretation of the Title X statute but ruled that only Ohio was entitled to an injunction on this point. 

“This ruling is surprisingly good news, albeit with some unclear implications for Ohio and the network down the road. The bottom line is that today’s decision keeps the Biden administration’s rule fully in effect and has no immediate impact on the full network – that should bring welcome relief for patients and providers alike. 

“The 2021 Title X rule has been critical to undoing the immense public health harm caused by restrictions put in place by the previous administration. The Biden rule restored critical access points to care and reaffirmed Title X’s commitment to ensuring patients have equal access to high-quality family planning services. We are relieved by the Sixth Circuit’s holding and grateful for the Biden administration’s strong commitment to improving family planning and sexual health care access for all.”  


NFPRHA is a membership organization representing publicly funded family planning providers and administrators nationwide. NFPRHA advances and elevates the importance of family planning in the nation’s health care system and promotes and supports the work of family planning providers and administrators, especially those in the safety net. For more information, visit

National Family Planning & Reproductive Health Association

1025 Vermont Ave. NW, Suite 800, Washington, DC 20005
Phone: 202-293-3114  |

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