When news broke last week that the Trump administration had quietly restored federal Planned Parenthood funding, which he had previously cut, pro-life conservatives were understandably upset. Yet, as Elizabeth Mitchell reported for the Daily Signal, the move was not a mere handout to the biggest abortionists in the country, despite its appearance to the contrary. In fact, it may have paved the way for more lasting cuts to Planned Parenthood subsidies down the road.
On April 1, 2025, Trump’s Health and Human Services froze just over $65 million worth of Title X grants to family planning clinics, citing concerns with “possible violations” of federal civil rights law. HHS said it would investigate clinics for “widespread practices across hiring, operations, and patient treatment that unavoidably employ race in a negative manner” as well as “taxpayer subsidization of open borders”—for example, conducting programs in a way that “overtly encourages illegal aliens to receive care.”
The funding in question had been for sixteen grantees in seven states—California, Hawaii, Maine, Mississippi, Missouri, Montana, and Utah—including nine Planned Parenthood state affiliates, and affecting roughly eight hundred abortion sites across the United States. (The total number of abortion clinics in the United States is unknown, but most estimates suggest roughly eight hundred are currently in operation.) Other states that receive grants under Title X, such as Texas, received partial funding during the freeze.
Within weeks, the American Civil Liberties Union and National Family Planning and Reproductive Health Association, which represents most Title X grantees, sued the administration for “unlawful” withholding of the grants. In the ensuing months, affected abortion clinics provided materials to HHS in response to the concern that they violated federal rules for diversity, equity, and inclusion programs. That lawsuit was dropped last Monday, after the Trump administration began releasing frozen funds on December 19, citing a completed review of the grants in question.
Pro-abortion activists have said that the lack of Title X funding caused many clinics to shutter, though the total number of brick-and-mortar abortion shops had already begun dropping before the Dobbs v. Jackson Women’s Health Supreme Court decision, following the prevalence of mail-order mifepristone. At least two shops in Utah did close during the freeze, one on the northern border near Idaho, where abortion is banned, and the other on the southern border near Arizona. Apparently, the demand for Planned Parenthood’s services was not significant enough to sustain a clinic, absent heavily subsidized and free options for low-income clients.
Veteran pro-life strategist Tom McClusky, director of government affairs at CatholicVote, called the move to return the grant money strategically necessary, since the Trump administration was “virtually certain to lose the lawsuit, forcing them to repay the full amount plus interest and cover attorneys’ fees,” he told the Daily Signal.
One reason for this is that HHS withheld the money before amending 42 U.S. Code Part 300, a rule that governs family planning grants. As currently written, the rule allows HHS to grant and contract with public or nonprofit private entities to establish voluntary family planning services, including “natural family planning methods, infertility services, and services for adolescents,” with additional memoranda from Biden in 2023 to explicitly protect abortion access and promote mifepristone availability in the wake of the Dobbs decision.
At its inception in 1970, Title X of the Public Health Service Act was championed by President Richard Nixon and incoming President George H. W. Bush, as it sought to improve access to family planning services to low-income women. It was an easy sell because, in its original form, the Title X program expressly prohibited grant recipients from using the funding to provide abortions, as aborting an unborn child was not considered a legitimate form of “family planning” at the time. Yet since then, Title X has been subject to a match of political volleyball, with Democratic presidents ordering HHS to use the funds for abortion clinics, while Republican presidents from Ronald Reagan onward have instated the Protect Life Rule, which prohibits the funding from being used in the same facilities where abortions take place.
The Protect Life Rule, neutered by President Joe Biden, has yet to be reinstated by Trump during his second term. Yet, as the pro-life research organization Charlotte Lozier Institute has pointed out, the rule is ultimately a mere stopgap for more sturdy congressional action: “A bill that explicitly amends Title X to prohibit abortion referrals in Title X projects and requires strict separation between the projects and abortion businesses would avert threats to this federal program by future administrations.” In other words, Republican congressmen can defund Planned Parenthood themselves, and more permanently than Trump ever could. One has to wonder what they’re waiting for, with a Republican majority in both houses and a Republican in the Executive Office.
Despite their political strength, Republicans are still sheepish on national abortion legislation, perhaps habitually so. This is somewhat understandable: Multiple state-level pro-life ballot initiatives have failed (though few have been exceptionally strategic), and the fearmongering from the left about a national abortion ban has yet to let up since 2022. Truly, there is nothing a Republican loves less than proving a Democrat right, even for the sake of an objectively good policy.
Yet, Trump was re-elected after his judges overturned Roe. This says something, however ambiguous, about the moral compass of the American people. Abortion turned out to be a lot less of a rallying cry for either side in the 2024 election than expected, which means now could be exactly the moment to gently roll the ball forward. There is much room between banning abortion and saying the government may not, in fact, subsidize organizations that profit from killing low-income, minority children.
In any case, the dismissal of the Title X lawsuit clears the way for a more successful fight against Planned Parenthood funding, which rumors on Pennsylvania Avenue suggest could be coming soon. At the very least, reinstating the Protect Life Rule would seem an easy win for pro-life voters on the eve of the March for Life in Washington, D.C.
