On December 19, 2008, the Department of Health and Human Services (HHS) published a controversial final rule to implement and enforce certain federal nondiscrimination statutes protecting the conscience rights of health care providers and other entities. Among other things, the rule clarifies that non-discrimination protections allowing a provider to refuse to perform health care services to which they may object for religious, moral, ethical, or other reasons apply to institutional health care providers as well as to individual employees working for recipients of certain HHS funds; requires recipients of certain HHS funds to certify their compliance with laws protecting provider conscience rights; designates the HHS Office for Civil Rights as the entity to receive related discrimination complaints; and establishes compliance provisions, including termination and recoupment of funding paid in violation of the nondiscrimination provisions if voluntary compliance is not achieved. The rule is effective January 20, 2009, although HHS components have been given discretion to phase in the written certification requirement by October 1, 2009 (the beginning of FY 2010).