How Many Foreign NGOs Are Subject to the Expanded Mexico City Policy?

  • On January 23, 2017, President Trump reinstated the Mexico City Policy (see KFF explainer). In the past, the policy required foreign non-governmental organizations (NGOs) to certify that they would not “perform or actively promote abortion as a method of family planning,” using funds from any source, as a condition for receiving U.S. government global family planning assistance; it applied to foreign NGOs receiving funding directly, as prime recipients, and indirectly, as sub-recipients. It also required U.S. NGOs to ensure that their foreign NGO sub-recipients were in compliance.
  • Under the Trump Administration, the policy’s scope has been significantly expanded to include most other U.S. bilateral global health assistance, beyond just family planning funding, and additional funding agreements.
  • At this time, many questions remain about the potential impact of the expanded policy. One key unknown is the size of the universe of affected NGOs. To begin to answer this question, we analyzed data on U.S. global health assistance obligated over a recent three-year period (FY 2013-FY 20151) to identify the number of foreign NGOs that received funding. Our findings should be considered a minimum estimate, since we were only able to include a sample of NGO sub-recipients. Our analysis finds that:
    • If the policy had been in effect during this time, at least 1,275 foreign NGOs – half as prime recipients of U.S. global health assistance and half as sub-recipients – and approximately $2.2 billion in funding directed to these NGOs would have been subject to the policy.
    • In addition, at least 469 U.S. NGOs receiving U.S. global health assistance would have been required to ensure that their foreign NGO sub-recipients were in compliance.
    • The expansion of the policy greatly increased its reach. Among prime recipients alone, most affected foreign NGOs (92%) and funding (88%) would not have been subject to the policy under its pre-expansion terms.
  • Ultimately, while it is too soon to know the actual impacts of the expanded policy on the people served by U.S. global health programs, our analysis suggests that, at a minimum, a significant number of NGOs will be subject to the policy.
Issue Brief

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