Warning: Hobby Lobby SCOTUS Ruling May Not Apply to Your PHC

In dramatic fashion, the Supreme Court of the United States (SCOTUS) waited until the very last day of the session to release one of the most anticipated rulings, its decision in Burwell, Secretary of Health and Human Services, et al v. Hobby Lobby Stores, Inc., et al. The 5-4 majority found the central argument involved the religious liberty of closely held for-profit corporations, Hobby Lobby and Conestoga Wood Specialties Corp in particular.

Warning: a pregnancy help organization (PHO) is not a “closely held for profit corporation.” No, indeed, it is not. However, if it does not have the one thing that will help connect it to this ruling, namely, solid footing that it is intended to be and acts, at least in part, like a religious organization, then the finding today will likely not serve as protection in future government encroachment.

The court noted in its ruling that “[T]he Hahns and Greens have a sincere religious belief that life begins at conception.  They therefore object on religious grounds to providing health insurance covering methods of birth control that, as HHS acknowledges may result in the destruction of an embryo.  By requiring the Hahns and Greens and their companies to arrange for such coverage, the HHS mandate demands they engage in conduct that seriously violates their religious beliefs.”

A pregnancy help organization staffed by Christians motivated by biblical faith is likely not enough evidence of being a “religious organization.” So what can a PHO do to position itself appropriately as a “religious organization”? The best evidence must be found entrenched in its own governing documents.

Alliance Defending Freedom, one of the same organizations that championed the Hobby Lobby case to victory at the Supreme Court level, provides insights into how PHOs can best protect themselves. Just two years ago, Joseph Infranco, Senior Counsel at ADF, wrote “To Be or Not to Be a Religious Non-Profit: The Question for all PRCs.” In his article (which is reprinted in full in this issue of Capitol Matters) , Mr. Infranco references LeBoon v. Lancaster Jewish Community Center Ass'n, 503 F.3d 217 (3d Cir.2007) in which the Third Circuit articulated a nine-part test which included #3 “whether the entity's articles of incorporation or other pertinent documents state a religious purpose.”

Do your articles of incorporation, bylaws, and policy and procedure clearly identify your religious nature? If not, making the case you should be afforded “religious liberty” is difficult at best.

The question could be asked, “If your organization were on trial for being religious, would there be enough evidence to convict you?” In order to appropriate the benefit of the First Amendment and the religious liberty flowing from it, we should intentionally plant the evidence of our religious nature. We need to wisely assert the Christian values motivating and informing our missional efforts. Mr. Infranco’s full article tells us why and how it is important.

We are grateful for Hobby Lobby and the Alliance Defending Freedom team for bringing this battle before the Supreme Court. Let’s do our part to position ourselves for future ones!

Heartbeat International Annual Conference 
Cincinnati, OH |  March 25 - 27, 2026

Key Dates to Remember

• September 15 - Deadline to submit online proposals
• October 15 - Proposal status updates (yes/no) emailed to submitters
• November 15 - Confirmation/commitment from presenter received
• January - February - Pre-recording of in-person and virtual workshops
• March 25 - 27, 2026 - Heartbeat International Annual Conference

General Submission Guidelines 

Submissions for The Annual Conference must be:

• Practical
• Relevant
• Compelling
• Non-commercial in content
• Non-compete with a current Heartbeat program

Submitting a proposal does not guarantee selection. We will notify those chosen directly. While Heartbeat International affiliation and/or exhibiting is preferred, it is not mandatory.

Special Notes:

1. Heartbeat Affiliates and Exhibitors may be prioritized. Heartbeat International affiliation and/or exhibiting is preferred, but not a requirement for submission. All are welcome to submit a workshop proposal.

2. Submission does not guarantee selection. We are blessed each year with more submissions than workshop slots, so submission does not guarantee selection. Proposals will be evaluated in light of the course description, learning objectives, presenters’ credentials and expertise, past evaluations of presenters from previous Conference workshops, and the overall needs of the Conference program. Presenters selected for the Conference will be notified directly at the contact information provided. Only the person submitting the workshop information is being considered as the primary presenter, if approved. 

3. Conference Focus. Required teaching content is 60 minutes (mandatory for CEUs). You agree not to promote or request support for your own organization or its services but to provide valuable teaching content and information on your area(s) of expertise, including practices and takeaways that meet Heartbeat’s submission guidelines.

4. Please note the level of your workshop submission (Basic/Intermediate/Advanced). We will seek to offer a blend of all three levels in our training tracks.

5. Connect to the Conference theme. Although not required, you are welcome to connect your title and content with the Conference theme, "Power of Love" with a focus on John 15:12. Heartbeat reserves the right to edit the workshop title for marketing purposes and modify the course description.

6. Learn About Your Audience. Heartbeat International's Annual Conference is designed for ministry leaders, staff, board members, and volunteers of life-affirming pregnancy resource centers, medical clinics, maternity homes, and non-profit adoption agencies, as well as professionals in the areas of medicine, counseling, social work, and education.

• Executive Directors - Leadership is best when equipped, encouraged, and engaged. This Conference includes tactical techniques, spiritual support, and everything in between.
• Key Staff/Volunteers - Deepen your understanding by accessing the Track or Workshops of your area of ministry work - or broaden your information and inspiration by learning about related matters.
• Medical Personnel - While our Medical Track features professionals who can speak the medical language and your passion for life, other topics may be of interest to enhance you and your ministry.
• Board Members - Governance is a high calling and one that is informed by experience and understanding. Strategic Leadership topics will strengthen your knowledge and wisdom.
• Housing Professionals - Housing ministries provide long-term, in-depth support for women during pregnancy and beyond. Join other housing ministry leaders in discussing the joys and challenges unique to residential programs.
• Internationals - Pregnancy help ministries exist all over the world and they encounter the same concerns U.S. centers have every day. This Conference is proud to include international guests from six continents.

Presentation Format

We welcome presentations tailored to various levels of experience—basic, intermediate, and advanced. Workshops should provide 60 minutes of rich, actionable content (required for CEUs). Whether you're addressing new practices or established methods, your presentation should deliver practical takeaways that align with Heartbeat’s mission. Please note that promotional content for your own organization is not permitted.

How to Submit a Workshop Submission

1. Develop a workshop outline that covers 60 minutes of content.
2. Complete the online form (a separate form is required for each submission).
3. Submit your proposal by September 15, 2025, for review by our Conference Planning Team.
4. Plan to join us in Cincinnati, Ohio, March 25-27, 2026.

Content Guidelines

The majority of workshop submissions should be oriented toward the Pregnancy Help Community (pregnancy centers, medical clinics, maternity homes and adoption agencies). This year our workshop tracks will encompass similar topics as listed below:

1. Leadership/Management
2. Medical
3. Fundraising/Development
4. Prevention (Sexual Integrity, Sexual Health)
5. Intervention (Client Culture, Client Programs)
6. Board Business
7. Marketing to Clients
8. Staffing/Human Resources Considerations
9. Extended Care (Housing, Adoption, etc.)
10. Healing (Abortion Recovery, Spiritual Wholeness, Emotional Health, Addiction Recovery)

If your proposal is selected, you will receive additional information about recording and registration procedures. Workshop presenters generally cover their own Conference registration fees, travel and lodging expenses. As a thank you, Heartbeat will provide the primary presenter with a discounted rate for attending the Conference.

The forward momentum of the pro-life movement over the last four years is about to run head-on into an empowered pro-abortion offensive bent on recovering all lost ground and establishing its own forward momentum.

By any objective analysis of actions specifically related to abortion, the Trump administration has been the “most pro-life” administration since the issue began to dominate our politics in the sixties. President Trump’s desire to be seen as doing more and doing it better actually translated in solid gains across the pro-life spectrum. From the Supreme Court to the policy wonks at Health & Human Services, from defunding Planned Parenthood (as best he could in the face of an unsupportive Congress) to refusing to allow taxpayer funding support abortion in other countries (the “Mexico City policy”), this administration has been proactive in advancing the sanctity of life in a variety of ways.

Most, if not nearly all, of that is about to stop.

Or at least become severely impeded.

Federally, abortion is a political football. On day one of his presidency, Obama reversed the Bush (43) ban on funding international abortion entities. Trump reversed it back when he took office. He even made the constraints stronger and broader reaching. The incoming administration has clearly signaled that they will reverse the “Mexico City policy” and others that we have celebrated.

Biden and his impending administration have already tipped their hand in support of Big Abortion. More than rhetoric from the campaign trail, including “eliminating the Hyde Amendment” (which bans the use of federal funds for almost all abortions), is the slate of pro-abortion activists being proposed for cabinet-level positions. Chief among them is California Attorney General Xavier Becerra, who we know as the defendant from NIFLA v. Becerra, being tapped to lead the U.S. Department of Health and Human Services (HHS).

If you’re new to the pregnancy help movement, this was California’s effort to actively force pregnancy help centers to promote California’s abortion services. It was only one of Justice Anthony Kennedy’s last votes that swung in favor of pregnancy help that secured the slim 5-4 decision to keep governments from forcing pregnancy centers to speak what is reprehensible—a message favoring abortion.

If Becerra is confirmed to head HHS, he’ll certainly restore Planned Parenthood’s previous funding and move to again box out life-affirming pregnancy help from the gains made under the Trump administration.

Chemical abortion is rapidly becoming Big Abortion’s preferred method. A Biden administration will likely release the distribution of these abortions completely from all FDA constraints. Fewer constraints coupled with more funding can only lead to an increased number of abortions nationally.

The final blow is the failure—culminating in the Georgia run-off—to hold a solid pro-life majority in the Senate. As the votes are still being counted (and re-counted), there is only the slimmest chance to thwart sweeping changes to fundamentally tip the scales in favor of Big Abortion. Even a win will see the Senate numerically the same as the first two years of the Trump administration that failed miserably to secure key legislative gains proposed by the decidedly pro-life House during their term.

Only the supposed majority of conservative justices at the Supreme Court can serve as a backstop to the most radical of abortion agendas now (nearly) empowered in DC.

The immediate future looks bleak.

And that is just how she’s imagining her life if she says yes to that unplanned pregnancy.

And the very same thing we tell her is what we need to tell ourselves.

God’s got this.

While we can’t, with absolute certainty, tell her just exactly how God’s going to work in her specific situation, we can boldly proclaim with confidence that the Lord's plans for her involve a “hope and a future” (Jer. 29:11).

And that’s where we need to draw confidence as well. Even in the face of our opposition, Psalm 23 reminds us that God will meet our needs, secure our provision, and strengthen us by His own hand. Just like we know He will be faithful to meet hers.

We’ve seen drastic political twists and turns like this before. With trust in the name of the Lord our God and His anointing upon us, we can face this with a tenacious optimism that has been the hallmark of the pregnancy help movement.

“Some trust in chariots and some in horses, but we trust in the name of the Lord our God.” (Psalm 20:7)

She’s not looking to Washington for help. She’s looking for someone close by. Someone who can tell her, “Don’t let your heart be troubled.” (John 14:1a) Someone who will love her in the moment and help her see beyond the immediate obstacles. That someone is us.

The propensities of politics cannot compare to the Promise of Providence. His Glory is not diminished by a vote count, but instead is exalted in the faithfulness of His people. His calling to champion the Gift of Life will only need more of Him at work in us, for us, and through us.

God’s got this!

Jor-El Godsey

President, Heartbeat International

Thank you for submitting a workshop for consideration at the 2026 Heartbeat International Annual Conference. If you know someone who might be interested in presenting, please share this opportunity with them! Just send the following link so they can submit a form as well: https://www.heartbeatservices.org/training/conference/workshop-presenters

We are blessed each year with more submissions than workshop slots, so please understand that your submission does not guarantee selection.

Proposals will be evaluated in light of the course description, learning objectives, presenters’ credentials and expertise, past evaluations of presenters from previous Conference workshops, and the overall needs of the Conference program. Presenters selected for the Conference will be notified directly at the contact information provided. Only the person submitting the workshop information is being considered as the primary presenter, if approved. You are asked not to promote or request support for your own organization or its services but to provide valuable teaching content and information on your area(s) of expertise, including practices and takeaways that meet Heartbeat’s submission guidelines.

Our team will be reviewing all the submissions over the next several weeks and you will hear from us in October. 

We appreciate your heart for the pregnancy help movement and look forward to reviewing your workshop submission. 

Key Dates to Remember

• September 15- Deadline for submitting proposals
• October 15- Proposal decisions send
• November 15 - Confirmation/commitment from presenter received

Agreed Upon Terms & Conditions

By offering a workshop proposal to Heartbeat International, Inc. (“Heartbeat”), you agreed to the following terms and conditions:

• All are welcome to Submit a workshop proposal. Affiliation with Heartbeat International is not a requirement for submission, but Heartbeat affiliates may be given preference. 
• Because Heartbeat is blessed each year with more proposals than workshop slots, some people who submit proposals may not be selected to be a Presenter.
• Proposals will be evaluated according to the course description, learning objectives, how the proposal fits into the conference program, as well as your credentials and experience. Submissions should be practical, relevant, and compelling. Incomplete submissions might not be considered.
• If your proposal is selected, you will be notified at the contact information you provided and will receive additional information about registration procedures.
• Only the person submitting the proposal is being considered as a presenter. Therefore, if the proposal is approved, only the person who submitted the proposal may present, unless otherwise noted by Heartbeat. If you intend for multiple people to present, please include their names and information in your proposal. Heartbeat may request additional information.
• Workshop content and titles are subject to change. A Heartbeat staff member may contact you to discuss your workshop content or title.
• You agree not to promote materials that come into direct competition with Heartbeat and that all materials shall complement and be consistent with Heartbeat’s Mission, Vision and Principles.
• You agree not to promote or request support for your own organization or its services but to provide valuable information on your area(s) of expertise, including practices and takeaways that meet Heartbeat’s submission guidelines.
• You agree to focus on promoting life and the mission of the pregnancy help movement rather than a political or religious affiliation.
• Heartbeat does not compensate workshop presenters but may offer a discounted conference registration rate as a courtesy. Presenters will cover their own expenses, including but not limited to conference registration fees, travel and lodging.
• You agree to obtain permission from the owner of any intellectual property that is incorporated into the presentation before using it in the workshop. 
• Audio visual equipment will be provided to presenters at the in-person conference, as needed.  Presenters at both the in-person and the virtual conference must provide their own laptops. 
• If selected, and a PowerPoint will be part of your presentation, it should be uploaded to the Heartbeat App no later than March 2, 2026. You will receive instructions at a later date.  At Heartbeat’s discretion, you may share slides with participants.  If presenting In-Person, and you wish to supply slides in paper, you agree to bring sufficient handouts for participants. 
• The Heartbeat conference will be recorded and photographed. Your submission and recordings of the Presentation made by any means or device, including your image, voice, the words you speak and materials you present at the conference, regardless of whether the same are protected by copyright, trademark or other intellectual property agreement, may be reproduced and offered for sale by Heartbeat without compensation to you, as Submitter/Presenter from the sale of such recordings. 
• Heartbeat may make recordings available for educational purposes to their Affiliates or other life-affirming organizations.  You agree that your participation in this conference and Heartbeat’s use thereof (including any use of a photograph in Heartbeat publications or websites), will not constitute a violation of your rights of privacy and/or publicity. 
• You hereby release Heartbeat International, any of its affiliates or assigns, their directors, officers, agents, employees and volunteers, from any and all claims of any kind on account of such use.  You further agree not to make recordings of your workshop presentation including your image, voice, and words spoken by you at the Conference by any means or device.
• You agree not to post a recording of your presentation online either before or after the Conference (whether in person or virtual)
• If you choose to promote the event online, you agree to contact Heartbeat first to coordinate publicity efforts.

If you have any questions at all, please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it.. 

Welcome to the application portal for the 2021 E2 Grant Application. 

Please use the resources below to complete your application: 

Click here to access a tutorial for submitting the grant.

Click here to download the Grant Application Worksheet.

Click here to fill out and submit your Grant Application.