The Administrative State Accountability Project (ASAP) is a project of the Ethics and Public Policy Center. ¹ The EPPC started the HHS Accountability Project in 2022 and relaunched it in 2025 as ASAP to monitor other federal agencies beyond the Department of Health and Human Services (HHS). ²

ASAP scholars engage in agency rulemaking processes by providing legal and policy expertise on proposed regulations, submitting public comments, meeting with government officials, and facilitating the public’s participation in commenting on regulations. ¹

Background

The Administrative State Accountability Project, or ASAP, is a project of the Ethics and Public Policy Center, a right-of-center advocacy organization. ¹

ASAP argues that a single rule written by an unelected bureaucrat “can rewrite or change the meaning, application, and enforcement of laws passed by elected members of Congress.” ¹ ASAP director Rachel Morrison noted that in 2023, elected members of Congress passed 68 bills, while unelected bureaucrats finalized 3,018 new regulations. ³

The EPPC previously called the initiative the HHS Accountability Project, as it monitored only matters by the Department of Health and Human Services. In January 2025, it relaunched the initiative and expanded it to monitor other federal agencies, giving it a new name: the “Administrative State Accountability Project.” The name change reflected an expanded focus on multiple agencies on issues affecting health care, education, housing, and employment. ²

ASAP director Rachel Morrison said, “The new name acknowledges the full scope of the important work our team has done and will continue to do.” ²

ASAP advocates for a better public understanding of drafting, implementation, and rollback of government regulations. ¹

The project says it emphasizes legal protections Americans are entitled to, such as religious freedom, health care rights of conscience, and the right to life. ¹

EPPC president Ryan T. Anderson said, “ASAP has rapidly become the most effective force in Washington countering abuses of the government’s regulatory authority on matters touching human identity, dignity, and flourishing. We look forward to working with the Trump administration to assist them in undoing Biden regulations that attacked human dignity and in promulgating ones that will promote it.” ²

Advocacy

Before the name change to the “Administrative State Accountability Project,” the HHS Accountability Project contributed to several regulation changes at the Department of Health and Human Services (HHS). This included requiring acknowledgement of existing legal protections for religious freedom, conscience, and free speech to an LGBT foster care rule. It also successfully pushed conscience protections for staff working with unaccompanied refugee children entitled under federal law to abortions and gender transitions. ³

The Ethics and Public Policy Center said the accountability project caused the Biden administration to withdraw multiple proposed rules promoting gender ideology and undermining religious freedom. ²

Before the name change in 2025, the HHS Accountability Project submitted 40 public comments on agency rules. The project also filed 39 amicus briefs in court cases and conducted 28 meetings with government officials. ²

The project educates individuals and organizations on how to engage public comments and meetings regarding proposed regulations. It says these efforts led to increased participation and more substantive public comments from the public. ²

Leadership

Rachel N. Morrison is the director of the Administrative State Accountability Project. Morrison is a fellow with the Ethics and Public Policy Center. She is an attorney who focuses on religious liberty, health care rights of conscience, the right to life, nondiscrimination, and civil rights. Morrison was previously a special assistant to General Counsel Sharon Fast Gustafson at the Equal Employment Opportunity Commission. She was formerly litigation counsel for Americans United for Life. She was also a constitutional law fellow at the Becket Fund for Religious Liberty. She clerked on the U.S. Court of Federal Claims. ⁴

Eric Kniffin is a fellow with the Ethics and Public Policy Center. Kniffin was an attorney in the Civil Rights Division of the U.S. Department of Justice during the George W. Bush administration, where he helped enforce the Fair Housing Act and the Religious Land Use and Institutionalized Persons Act. He was legal counsel at the Becket Fund, where he contributed to the case of including Hosanna-Tabor v. EEOC and Burwell v. Hobby Lobby that found the government cannot force employers by law to provide abortion-inducing drugs and birth control to its employees over religious objections. As a private lawyer, Kniffin represented the U.S. Conference of Catholic Bishops, the Knights of Columbus, and the Assemblies of God, among others, in amicus briefs in Supreme Court cases. ^{3 5}

Natalie Dodson is a policy analyst at the Ethics and Public Policy Center. Previously, Dodson was a government affairs fellow at the Becket Fund for Religious Liberty. Before that, she worked for her alma mater, the University of Dallas, as the special assistant to the president. ⁶

Samuel Lucas is a legal associate with the Ethics and Public Policy Center who works with the
Administrative State Accountability Project. ⁷

1. “Administrative State Accountability Project.” Ethics and Public Policy Center. Accessed February 8, 2025. https://eppc.org/program/asap/
2. Press Release. “EPPC Launches the Administrative State Accountability Project.” January 13, 2025. Accessed February 8, 2025. https://eppc.org/news/eppc-launches-administrative-state-accountability-project/
3. Henderson, Kim. “Resisting the deep state.” World Magazine. November 14, 2024. Accessed February 8, 2025. https://wng.org/articles/resisting-the-deep-state-1731214893
4. “Rachel N. Morrison.” Ethics and Public Policy Center. Accessed February 8, 2025. https://eppc.org/author/rachel_morrison/
5. “Eric Kniffin.” Ethics and Public Policy Center. Accessed February 8, 2025. https://eppc.org/author/eric_kniffin/
6. “Natalie Dodson.” Ethics and Public Policy Center. Accessed February 8, 2025. https://eppc.org/author/ndodson/
7. Staff. Ethics and Public Policy Center. Accessed February 8, 2025. https://eppc.org/about/staff/