Case Particulars

Tribunal

Health & Human Services Office for Civil Rights (HHS OCR)

Date Filed

November 9, 2026

Docket No.

N/A

Case Status

OCR Complaint Filed

Case Overview

On November 9, 2026, the Equal Protection Project (EPP) filed a civil rights complaint with the U.S. Department of Health & Human Services (HHS) Office for Civil Rights (HHS OCR) against Tulane University School of Medicine (“Tulane Medical School” or “Tulane”) “regarding its IMPRESS program which appears to discriminate on the basis of race, color, and/or national origin in
violation of Title VI and/or Section 1557 of the Affordable Care Act.”

EPP’s civil rights complaint continues:

Section 1557 of the Affordable Care Act (“ACA”) prohibits discrimination on the basis of race, color, national origin, sex, age, and disability in certain health programs and activities receiving federal financial assistance. Specifically, Section 1557 prohibits individuals from being excluded from participation in, denied the benefits of, or subjected to discrimination under covered health programs or activities on grounds prohibited by Title VI, the Age Discrimination Act, or Section 504 of the Rehabilitation Act. 42 U.S.C. § 18116(a).

 

HHS regulations apply to “[e]very health program or activity, any part of which receives Federal financial assistance, directly or indirectly, from the Department.” 45 C.F.R. § 92.2(a)(1). A “health program or activity” includes undertakings that “[p]rovide health education for health care professionals or others,” as well as “[a]ll of the operations of any entity principally engaged” in providing or administering health programs or activities. 45 C.F.R. § 92.4(1)(v), (2).

 

Tulane University School of Medicine receives federal financial assistance from HHS and operates IMPRESS through its Department of Surgery. IMPRESS provides aspiring medical professionals with clinical and surgical training, exposure to medical specialties, and mentorship from physicians and surgeons. It also offers participants housing, meal stipends, and professional development opportunities. Accordingly, IMPRESS constitutes a covered health program or activity because it provides health education and operates within an HHS-funded medical school. The absence of federal funding specifically designated for IMPRESS does not, by itself, exclude the program from Section 1557’s coverage.

EPP’s complaint summarizes and requests HHS OCR take action:

HHS has the authority to investigate Tulane University School of Medicine’s administration of IMPRESS, including its eligibility requirements, recruitment practices, and participant selection criteria. HHS should determine whether Tulane uses race, color, or national origin in determining access to IMPRESS’s educational, professional-development, and financial benefits. HHS should also examine whether these practices violate applicable federal antidiscrimination laws, conflict with Executive Orders 14173 and 14332 or applicable federal funding requirements, or are inconsistent with any certifications or representations Tulane has made concerning its compliance with federal law. Where authorized and warranted, HHS should pursue appropriate remedial measures, including proceedings to suspend or terminate federal financial assistance or referral to the Department of Justice for judicial enforcement. After all, “[t]he way to stop discrimination on the basis of race is to stop discriminating on the basis of race.” Parents Involved in Cmty. Sch. v. Seattle Sch. Dist. No. 1, 551 U.S. 701, 748 (2007).

 

Accordingly, we respectfully request that HHS promptly open a formal investigation; determine whether Tulane University School of Medicine’s IMPRESS program violates Title VI, Section 1557 of the ACA, or other applicable federal antidiscrimination requirements; and obtain all appropriate remedial relief necessary to ensure that federal funds do not support or facilitate discrimination based on race, color, or national origin.

HHS OCR is evaluating EPP’s civil rights complaint for further action.