The Administration’s action would mean even more US global health funding will be subject to the restrictions contained in the MCP.
In the past, when in place, it has required foreign NGOs to certify that they will not “perform or actively promote abortion as a method of family planning”, using any funding (including their own), as a condition of receiving US global family planning assistance.
Upon taking office, one of President Trump’s first actions (on 1/23/17) was to reinstate the policy but he also significantly expanded it to apply to virtually all U.S. bilateral global health assistance, including PEPFAR, malaria, maternal and child health funding, and more.
This brought the policy from potentially applying to up to $600 million/year to more than $7 billion/year (to the extent that funding was channeled directly or indirectly to foreign NGOs).
Last year, Sec Pompeo further expanded the MCP, prohibiting foreign NGOs receiving U.S. global health aid from providing any $$ for any purpose (e.g., education) to other foreign NGOs that perform or actively promote abortion as a method of family planning.
To date, the policy has only applied to 2 types of funding mechanisms: grants and cooperative agreements. In 2017, the Administration announced its intention to also apply it to contracts, though this would need to be done through regulation.
The reg released today is that next step. There is a 60-day comment period.

By our estimate, close to 40% of global health funding obligated to prime recipients in recent years was provided through contracts.
This is an area where there is a clear-cut difference between President Trump and VP Biden. Whereas Trump has continued to expand the MCP, Biden would rescind it if elected.
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