On May 18, 2026, HHS announced a reorganization of its Office for Civil Rights (OCR), shifting to a program-based structure organized around three distinct subject-matter divisions:
A separate Enforcement Division will continue to handle centralized complaint intake and breach reporting through OCR’s field offices.
OCR’s Enforcement Authority
OCR enforces conscious and religious freedom laws (including the Church Amendments and the Weldon Amendment), along with federal civil rights laws (including Section 504 of the Rehabilitation Act of 1973 and Section 1557 of the Affordable Care Act) and federal privacy and security laws (HIPAA and 42 CFR Part 2).
OCR’s Reorganization in Context
The CRFD was originally established in 2018 under the first Trump Administration. In 2023, the Biden Administration reorganized OCR by combining the CRFD and the Civil Rights Division within OCR’s Policy Division.
This new restructuring signals OCR’s renewed emphasis on protecting conscience and religious freedom. That emphasis is reflected in several recent OCR actions, including:
OCR has consistently stated that it will advance its conscience and religious freedom priorities through rigorous enforcement activities, proactive compliance reviews, complaint investigation and resolution, and specialized technical assistance. OCR maintains a dedicated webpage with information on filing conscience and religious freedom complaints, including links to its online complaint portal.
Why this Matters for Health Centers
Health centers should expect increased OCR scrutiny of policies, practices and employment actions that implicate conscious or religious freedom protections. Health centers should consider:
OCR is expected to publish a notice in the Federal Register on the reorganization next month, which may provide additional detail on operational and enforcement changes within OCR.
- Conscience and Religious Freedom Division (CRFD)
- Civil Rights Division
- Health Information Privacy, Data, and Cybersecurity Division
A separate Enforcement Division will continue to handle centralized complaint intake and breach reporting through OCR’s field offices.
OCR’s Enforcement Authority
OCR enforces conscious and religious freedom laws (including the Church Amendments and the Weldon Amendment), along with federal civil rights laws (including Section 504 of the Rehabilitation Act of 1973 and Section 1557 of the Affordable Care Act) and federal privacy and security laws (HIPAA and 42 CFR Part 2).
OCR’s Reorganization in Context
The CRFD was originally established in 2018 under the first Trump Administration. In 2023, the Biden Administration reorganized OCR by combining the CRFD and the Civil Rights Division within OCR’s Policy Division.
This new restructuring signals OCR’s renewed emphasis on protecting conscience and religious freedom. That emphasis is reflected in several recent OCR actions, including:
- Fact Sheet: How HHS is Eradicating Bias Against Americans of Faith (April 30, 2026)
- Dear Colleague Letter on Safeguarding Federal Conscience and Related Protections in Health Care (January 21, 2026)
- Dear Colleague Letter to Vaccines for Children Program Immunization Programs and Participating Providers (September 4, 2025)
OCR has consistently stated that it will advance its conscience and religious freedom priorities through rigorous enforcement activities, proactive compliance reviews, complaint investigation and resolution, and specialized technical assistance. OCR maintains a dedicated webpage with information on filing conscience and religious freedom complaints, including links to its online complaint portal.
Why this Matters for Health Centers
Health centers should expect increased OCR scrutiny of policies, practices and employment actions that implicate conscious or religious freedom protections. Health centers should consider:
- Reviewing existing policies related to employee accommodations, vaccination requirements, and participation in certain clinical services.
- Ensuring procedures are in place for evaluating and documenting requests for religious or conscience-based accommodations.
- Training leadership, human resources staff, and clinical supervisors on applicable federal conscience protections and nondiscrimination obligations.
OCR is expected to publish a notice in the Federal Register on the reorganization next month, which may provide additional detail on operational and enforcement changes within OCR.
For more information, please contact:
DIANNE PLEDGIE
dianne.pledgie@powerslaw.com
ALEX LIPOVTSEV
alex.lipovtsev@powerslaw.com
