Distinguished Chair Wm Wagner Files Official Comment Supporting VA Proposed Rule on Reproductive Health Services

Comment praises Department of Veterans Affairs’ proposed rule (RIN: 2900-AS31(P)) as a measure that protects the dignity of human life and restores good governance under the rule of law.

SPRING ARBOR, MI — William Wagner, Distinguished Chair for Faith & Freedom at Spring Arbor University, and others, filed an official public comment today in strong support of the Department of Veterans Affairs (VA), Veterans Health Administration (VHA), proposed rule “Reproductive Health Services” (RIN: 2900-AS31(P), Federal Register No. 2025-14687, CFR: 38 CFR Part 17).

Their submission commends the VA’s proposal to reinstate historic exclusions on abortion and abortion counseling from the VA medical benefits package. Wagner argues that the rule will protect vulnerable pre-born children, safeguard the health and well-being of women in military families, uphold constitutional governance, and exercise both economic stewardship and human compassion.

Protecting the dignity of human life

The filing emphasizes that “there is no government interest greater than the protection of human life.” The authors underscore that pre-born children of military personnel and CHAMPVA-eligible families deserve the same protections afforded elsewhere in society. They highlight medical and psychological risks of abortion for women, particularly in military families already enduring unique stresses, and urge the government to support mothers and children rather than subsidize abortion.

Restoring good governance under the rule of law

The comment applauds the VA for affirming its clear legal authority to exclude abortion services, noting that neither Congress nor the Constitution grants a right to abortion. Wagner argues that reinstating long-standing exclusions not only aligns with Supreme Court precedent in Dobbs v. Jackson Women’s Health Organization but also corrects a legally questionable 2022 interim final rule. He concludes that the proposed rule represents a decisive return to lawful, accountable governance.

Exercising economic stewardship

The submission reviews the VA’s regulatory analysis and demonstrates that, far from creating undue costs, supporting childbirth promotes long-term economic growth. The authors calculate that even a small increase in live births generates significant tax revenue over time, offsetting costs many times over and strengthening the broader economy.

Acting with human compassion

Finally, the authors stress that the proposed rule reflects genuine compassion toward the most vulnerable. “These children are more than just potential life—they are persons with potential,” the comment states. By affirming life, the rule meets families with dignity, honor, and hope, rather than guilt or despair. Wagner stated, “This rulemaking affirms the inherent worth of every human life, restores constitutional integrity to agency action, and exercises wise stewardship of public funds.

About William Wagner

Hon. William Wagner (Ret) is a constitutional law scholar and former federal judge in the United States Courts. He currently serves as the WFFC Distinguished Chair for Faith & Freedom at Spring Arbor University