The Honorable Secretary Kathleen Sebelius
The U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, D.C. 20201

Dear Secretary Sebelius:

As leaders and supporters of faith based service organizations, we write to express our grave concern about the two-class concept of religious organizations that has been created by your department and other federal agencies in connection with contraceptives/abortifacients mandate of the health insurance regulations for preventive services for women.

Our organizations, and we ourselves, do not all share the same view of the moral acceptability of the contraceptive drugs and services that comprise the contraceptives/abortifacients mandate. We have varied views on the adequacy of the “accommodation” that the administration has promised for religious organizations with deep objections to the contraceptives mandate but that are not eligible for the narrow religious employer exemption. Our organizations are involved in different areas of service. We belong to different faiths.

But we are united in opposition to the creation in federal law of two classes of religious organizations: churches — considered sufficiently focused inwardly to merit an exemption and thus full protection from the mandate; and faith-based service organizations — outwardly oriented and given a lesser degree of protection. It is this two-class system that the administration has embedded in federal law via the February 15, 2012, publication of the final rules providing for an exemption from the mandate for a narrowly defined set of “religious employers” and the related administration publications and statements about a different “accommodation” for non-exempt religious organizations.

And yet both worship-oriented and service-oriented religious organizations are authentically and equally religious organizations. To use Christian terms, we owe God wholehearted and pure worship, to be sure, and yet we know also that “pure religion” is “to look after orphans and widows in their distress” (James 1:27). We deny that it is within the jurisdiction of the federal government to define, in place of religious communities, what constitutes true religion and authentic ministry.

This two-class scheme rewards those religious organizations focused on activities inside steepled buildings on the corner while punishing religious organizations that engage in service outside the walls of worship buildings. The scheme honors acts of worship while burdening those whose faith leads them to service in our common life. Among its many troublesome aspects, the scheme moves us further toward an unconstitutional, unhistorical, and unhealthy naked public square.

The administration has said that the narrow definition of “religious employer” is not intended to be a precedent in federal law and that the two-class system is not meant to disparage the mission or motivation of non-exempt religious organizations. Yet these are only intentions, whereas the narrow definition of religious employer and the narrow scope of the exemption have been inserted, despite widespread protest, into actual federal law. We note, as well, that the administration itself has justified the narrow exemption by its use in the insurance rules of several states. The presence of the narrow exemption in federal regulations can only make it more likely to be used in additional federal policies, notwithstanding any current promises.

Secretary Sebelius, we believe that there is one adequate remedy: eliminate the two-class scheme of religious organization in the preventive services regulations. Extend to faith-based service organizations the same exemption that the regulations currently limit to churches. This would bring the preventive services regulations into line with the long-standing, respected, and court-tested provisions of Title VII of the 1964 Civil Rights Act [§§702, 703(e)] which provide a specific employment exemption for every kind of religious organization, whether they be defined as “a religious corporation, association, educational institution, or society.”

Secretary Sebelius, please restore the federal government’s full respect for faith-based educational, social-service, and health organizations as authentic vehicles for religious service.


Stanley Carlson-Thies, President, Institutional Religious Freedom Alliance
Keith Wiebe, President, American Association of Christian Schools
Maureen Vandenberg, Legislative Director, American Association of Christian Schools
Dr. R. Lamar Vest, President and CEO, American Bible Society
Colby M. May, Director & Senior Counsel, Washington Office, American Center for Law &
Pamela Palumbo, CEO, Annapolis, Bowie, Crofton & Severna Park Pregnancy Clinic
Jeffrey Rivera, Apostle, Anointed Community of Restoration
Sister Mary Sarah, O.P., President, Aquinas College
Sandra C. Gray, President, Asbury University
Ralph E. Enlow, Jr., President, Association for Biblical Higher Education
Michael Galligan-Stierle, President, Association of Catholic Colleges and Universities
Thomas J. Cathey, Chief of Staff and Director for Legal/Legislative Issues, Association of
Christian Schools International
Mark Morley, Director of Human Resources, Association of Christian Schools International
Hal G. Cross, Vice President of Business & Finance , Baptist Bible College & Seminary
Dr. Byron Johnson, Distinguished Professor of the Social Sciences and Director, Institute for
Studies of Religion, Baylor University
Dr. Roger Parrott, President, Belhaven University
Dr. William K. Thierfelder, President, Belmont Abbey College
William J. Blacquiere, President/CEO, Bethany Christian Services
Marc Andreas, Vice-President, Client Marketing, Bethany Christian Services
Steve Cramer, President, Bethel College
James H Barnes III, President , Bethel University
Kenneth D. Hunn, Executive Director, The Brethren Church
Robert O’Neal, Pastor, Brookwood Community Church
Dr. Stephen D. Livesay, President, Bryan College
John F. Martin, Program & Research Officer , Butterfield Memorial Foundation
Patrick J. Reilly, President, The Cardinal Newman Society
Dr. Marianne Evans Mount, President, Catholic Distance University
Stephanie Summers, CEO, Center for Public Justice
Mike Brown, Administrative Pastor, Central Bible Church
Donna F. Bethell, Chairman of the Board of Directors, Christendom College
Jim Grennell, Executive Director, Christian Hope Association
Peter Rathbun, President, Christian Legal Society
Kimberlee Wood Colby, Senior Counsel, Christian Legal Society
Carl H. Esbeck, Board, Christian Legal Society
Peter Vander Meulen, Coordinator, Office of Social Justice, Christian Reformed Church
David Neff, Editor in chief, Christianity Today
David Wilson, General Secretary, Church of the Nazarene
Phil Whipple, Bishop, Church of the United Brethren in Christ
Dr. George A. Harne, President, The College of Saint Mary Magdalen
William L. Armstrong , President, Colorado Christian University
Raymond B. Marcin, Professor of Law Emeritus, Columbus School of Law, Catholic University
of America
Jay Van Groningen, Executive Director, Communities First Association
Catherine Washburn, Corporate Secretary, Community Christian Center
Justin Frank, Pastor, Community Church of East Gloucester
Rev. Clifford Christensen, Conservative Congregational Christian Conference
Karen Woods, co-principal, Cornerstone Community Resources, L3C
Paul R. Corts, President, Council for Christian Colleges & Universities
Robert C. Andringa, President Emeritus, Council for Christian Colleges & Universities
Bernard F. O’Connor, OSFS, President, DeSales University
Dr. Erik Hoekstra, President, Dordt College
David A. Lundberg, Director of Clinical Services, Evangelical Child and Family Agency
Bruce Hill, Bishop, Evangelical Congregational Church
William Hamel, President, Evangelical Free Church of America
Ronald J. Sider, President, Evangelicals for Social Action
Kevin York, Executive Director, Every Nation Churches
Rocky Rocholl, President, Fellowship of Evangelical Churches
Roberta Green Ahmanson, Trustee, Fieldstead and Company
Dave Evans, US President, Food for the Hungry
David Roller, Bishop, Free Methodist Church – USA
David Kendall, Bishop, Free Methodist Church – USA
Matthew Thomas, Bishop, Free Methodist Church – USA
Richard J. Mouw, President, Fuller Theological Seminary
Dr. Kenneth A. Smith, President, Geneva College
David W. Beam, Senior Chaplain, Good News Jail & Prison Ministry
Dr. Ronald E. Manahan, President, Grace College and Seminary
Jeffrey J. Barrows, Founder, Gracehaven
David Meldrum-Green, Director of Organizational Affairs & Treasurer, Great Commission
Janet Ross, President/CEO, Heart of God International Ministries, Inc.
Kenneth Belch, Senior Pastor, Hilltop Community Church
Paul Lanier, Bishop, Hope Community Church
Debbie Lanier, Pastor, Hope Community Church
Heather Martin, Administrative Assistant, Hope Community Church
Shirley A. Mullen, President, Houghton College
Dr. Clyde Hughest, International Pentecostal Church of Christ
Derry Connolly, PhD, President, John Paul the Great Catholic University
Dr. Gary E. Weedman, President, Johnson University
James Kirland, Pastor, The King’s Praise Ministry
Dr. Nicholas V. Kroeze, President, Kuyper College
Duane Bras, Vice President for Business and Finance, Kuyper College
Alissa Holverson, Director of Pharmacy, Lawndale Christian Health Center (Chicago)
Dave Hillis, President, Leadership Foundations
Dr. Dale A. Lunsford, President, LeTourneau University
Mandi Campbell, Legal Director, Liberty Center for Law and Policy
Mathew Staver, Founder and Chairman, Liberty Counsel
Deryl Edwards, President, Liberty Counsel Action
James Ayers, Pastor, Life Church
Brooks Linde, Linebrook Church
Dr. Joe W. Aguillard, President, Louisiana College
Barbara Deemer, Member and Office Secretary, Main Street Baptist Church
Dr. Lee G. Royce, President, Mississippi College
Dr. Dan Struble, President, Montreat College
Sam Theilman, Ph.D., M.D., Trustee, Montreat College
Chip Milner, Trustee, Montreat College
Thomas H. Powell, President, Mount St. Mary’s University
Dr. Daniel R. Lockwood, President, Multnomah University
Suzanne Nelson, International Director, Music For Life, home of the African Children’s Choir
Thomas Gregory Bandy, Associate Representative, The Navigators
Leith Anderson, President, National Association of Evangelicals
Galen Carey, Vice President, Government Relations, National Association of Evangelicals
Dr. Donald Struble, Senior Pastor, National Conservative Christian Church
Samuel Rodriguez, President, National Hispanic Christian Leadership Conference
The Rev. Stephen Charles Mott, Ph.D., Retired Clergy, New England Annual Conference,
United Methodist Church
Jason Polling, Pastor, New Hope Community Church
Robert McCleland, CEO, North American Baptist Conference
Ivan Timm, Pastor, North Central Conference of Free Methodist Church
David Alexander, President, Northwest Nazarene University
Alan Cureton, President, Northwestern College (MN)
Dr. Richard L. Gathro , Dean & Special Assistant to the President, Nyack College, New York &
Washington, DC
Everett Piper, President, Oklahoma Wesleyan University
Walker Tzeng, Chief Operating Officer, Olivet University
William M. B. Fleming, Jr., President, Palm Beach Atlantic University
Dr. James R. Hart, President, The Robert E. Webber Institute for Worship Studies
Commissioner William A. Roberts, National Commander, The Salvation Army – USA
Michael A. Sommerfeld, Pastor, Sonrise Fellowship of Christian and Misisonary Alliance (Enid,
Isidro Salcedo, Pastor, Souls Ministries
Dr. Richard Land, President, Southern Baptist Ethics & Religious Liberty Commission
Dr. Loren Gresham, President, Southern Nazarene University
C. Pat Taylor, President, Southwest Baptist University
D. Gregory Main, President, St. Gregory’s University
Gregory Johnson, Reverend/President/Founder, Standing Together
Jules Glanzer, President, Tabor College
Dr. Eugene B. Habecker, President, Taylor University
Andrew Sears, Executive Director, TechMission
Dr. Robert Myers, President, Toccoa Falls College
Carl Nelson, President, Transform Minnesota: The Evangelical Network
Dr. Dan Boone, President, Trevecca Nazarene University
Rodolpho Carrasco, Managing Director, Two Forty Group
Ed Boschman, Executive Director, U.S. Conference of M.B. Churches
David S. Dockery, President, Union University
Rev. Deborah Reyes, B.Th., MM, Ph.D., General Secretary, UBCF Mission to Nicaragua, United
Brethren Community Fellowship
Rev. Lois Kaynich, B.Th., MM., Ph.D., Executive Director, UBCF Disaster Relief Outreach
Program, United Brethren Community Fellowship
Rev. Phyllis Pottorff-Albrecht, B.Th., MM, Ph.D., Executive Director, UBCF Outreach Program
to Families in Crisis, United Brethren Community Fellowship
Dr. Mark Foley, President, University of Mobile
Patricia H. Dorsett, Board of Trustees, University of Mobile
Jo Anne Lyon, General Superintendent, The Wesleyan Church
Dr. Kerry D. Kind, Director of Education and Clergy Development, The Wesleyan Church,
World Headquarters
Dr. Philip G. Ryken, President, Wheaton College
Dr. Robert Osburn, Executive Director, Wilberforce Academy
Dr. John Jackson, President, William Jessup University
Ken Schmoyer, Pastor, Winnebago Evangelical Fellowship
Sandra Schmoyer, Pastor’ wife, Winnebago Evangelical Congregational Church
Mike Reinders, Member, Winnebago Evangelical Fellowship
Stephan J. Bauman, President/CEO, World Relief
Richard Stearns, President, World Vision, Inc. (US)