Administrative State Accountability Project

The administrative state, made up of federal agencies, has a very powerful, though largely invisible influence on law, politics, and culture in the United States. Agency regulations, which have the force and effect of law, are issued by unelected agency officials and are the result of a complex process. A single rule can rewrite or change the meaning, application, and enforcement of laws passed by elected Members of Congress.  

EPPC’s Administrative State Accountability Project (ASAP), directed by Rachel N. Morrison, advocates for an authentic understanding of the human person in the drafting, implementation, and rollback of government regulations.  

Emphasizing a sound understanding of the legal protections Americans are entitled to, including religious freedom, health care rights of conscience, and the right to life, Project scholars engage in the agency rulemaking process by providing legal and policy expertise on proposed regulations, submitting public comments, meeting with government officials, and equipping others to participate. 

Formerly called the HHS Accountability Project, the work of the Project has expanded to include other agencies. 

Project scholars regularly publish articles, advise policymakers, give presentations, and file amicus briefs to advance the Project’s priorities. 

EPPC Fellow Eric Kniffin and Legal Associate Sam Lucas also serve in the Administrative State Accountability Project. 


Engagement on Agency Actions

To shape policy, EPPC monitors and engages with federal agency actions. EPPC primarily engages in the rulemaking process by submitting written public comments and requesting meetings with government officials to provide input and specific suggested changes or improvements the agency must consider for its rulemaking. EPPC scholars also educate other organizations and individuals on how to effectively engage in the regulatory process and provide legal and policy expertise on various agency actions.

Amicus Briefs

EPPC and our scholars regularly file amicus briefs in key cases to promote a true and full account of human nature and human flourishing in the context of American constitutional law. Compiled on this page are some of our amicus briefs in cases addressing the right to life, marriage, gender ideology, religious freedom, free speech, and the rule of law. 

How to File a
Federal Conscience Complaint

How to Submit a Public Comment on Agency Rulemaking

How to Request a Meeting with Government Officials on Agency Rulemaking

Program Publications

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EPPC Scholars File Amicus Brief Urging En Banc Ninth Circuit to Hear Case and Correct…

Eric Kniffin, Rachel N. Morrison

On May 7, 2026, EPPC filed an amicus brief in the case Lopez v. United States, urging the Ninth Circuit…

Amicus Brief

PDF / May 15, 2026

EPPC Scholars File Amicus Brief Urging Supreme Court to Reinstate Abortion Drug’s In-Person Dispensing Safety…

Edward Whelan, Eric Kniffin, Rachel N. Morrison

On May 6, EPPC Distinguished Senior Fellow Ed Whelan and EPPC Fellows Eric Kniffin and Rachel N. Morrison filed an…

Amicus Brief

PDF / May 14, 2026

EPPC Scholars Submit Comment Supporting Federal Reserve Board’s Prohibition on Use of Reputation Risk in…

Eric Kniffin, Rachel N. Morrison

On April 27, 2026, EPPC Administrative State Accountability Project Director Rachel N. Morrison, Fellow Eric Kniffin, and Legal Associate Samuel…

Public Comments

PDF / May 5, 2026

EPPC Scholars Support Proposed Medical Codes to Help Victims of Gender Ideology

Eric Kniffin, Mary Rice Hasson, Rachel N. Morrison

On April 17, 2026, EPPC Scholars  Mary Rice Hasson, Rachel N. Morrison, and Eric Kniffin submitted a public comment to the Department of Health and Human…

Public Comments

PDF / April 23, 2026

EPPC Scholars File Amicus Brief Supporting Alaska’s Refusal to Castrate Sex Predator with Gender Dysphoria

Eric Kniffin, Mary Rice Hasson

On March 25, Ethics and Public Policy Center fellows Mary Rice Hasson and  Eric Kniffin filed an amicus brief in Wagoner v….

Amicus Brief

PDF / April 13, 2026

EPPC Scholars Encourage HHS to Rescind Pro-Gender Ideology and Anti-Family 2024 Foster Care Rule

Eric Kniffin, Rachel N. Morrison

On April 6, 2026, EPPC Scholars Rachel N. Morrison and Eric Kniffin submitted a public comment in support of HHS’s proposal to rescind a Biden-era foster care final rule that created…

Public Comments

PDF / April 9, 2026

EPPC Scholar Amicus Brief Urges Supreme Court to Protect Religious Organizations from Unconstitutional Government Intrusion 

Rachel N. Morrison

On February 19, 2026, an amicus brief was filed on behalf of EPPC Scholar Rachel N. Morrison in United States Conference of Catholic Bishops v. O’Connell, urging…

Amicus Brief

PDF / February 20, 2026

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