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Protection of Conscience Project

Service, not Servitude


Anderson RM, Bishop LJ, Darragh M, Gray HH, Nolen AL, Poland SC. Pharmacists and Conscientious Objection (Scope Note 2006). Kennedy Inst Ethics J. 2006 Dec;16(4):379-96. PubMed PMID: 17847603.

Richard M. Anderson, Laura Jane Bishop, Martina Darragh, Harriet Hutson Gray

  • In March 2005, a Wisconsin pharmacist's act of conscience garnered headlines across the United States. After a married woman with four children submitted a prescription for the morning-after pill, the pharmacist, Neil Noesen, not only refused to fill it, but also refused to transfer the prescription to another pharmacist or to return the prescription to the customer. As more such incidents occurred, many states ". . . decided to consider and enact laws setting the bounds of pharmacists' and other health care workers' professional obligations" (III, Grady 2006, p. 327). Discussions of objector legislation, also referred to as "conscience clauses," "refusal clauses," and "abandonment laws" (III, Appel 2005, p. 279), are not limited to professional ethics, but also draw from philosophical, theological, and legal perspectives. The purpose of this Scope Note is to present a wide variety of viewpoints on the health provider's right to conscience.

Antommaria AM. "Who should survive?: one of the choices on our conscience": mental retardation and the history of contemporary bioethics. Kennedy Inst Ethics J. 2006 Sep;16(3):205-24. PubMed PMID: 17091558.

Armand Matheny Antommaria

  • Abstract: The film "Who Should Survive?: One of the Choices on Our Conscience" contains a dramatization of the death of an infant with Down syndrome as the result of the parents' decision not to have a congenital intestinal obstruction surgically corrected. The dramatization was based on two similar cases at The Johns Hopkins Hospital and was financed by the Joseph P. Kennedy, Jr., Foundation. When "Who Should Survive?" was exhibited in 1971, the public reaction was generally critical of the parents' decision and the physicians' inaction. Although technological developments in medicine were a necessary condition for the production of this film and its unanticipated reception, they were not a sufficient condition. The proximate cause was a changed understanding of the capabilities of individuals with Down syndrome. Part of the impetus for this change was data showing the adverse effects of institutionalization on normal children.

Appel JM. May doctors refuse infertility treatments to gay patients? Hastings Cent Rep. 2006 Jul-Aug;36(4):20-1.

Jacob M. Appel

  • One of the most sacrosanct principles of medical  practice in the United States is that physicians have a right to choose their own patients as long as the patient is not in a medical emergency. During the 1980s, a minority of health care professionals invoked this prerogative in refusing to treat AIDS patients.  More recently, doctors incensed over malpractice premiums have refused to care for lawyers and their family members.  However, this sort of physician autonomy is not without certain limits-most notably the restrictions found in various federal and state civil rights statutes. No physician or hospital receiving government funding, including Medicare and Medicaid, may discriminate against potential patients on the basis of race, color, religion, or national origin, and many states have expanded these protections to cover gender and sexual orientation. What remains unclear is whether physicians with bona fide religious objections to treating certain patients are exempt from these proscriptions. A California case, currently on appeal before a state court, may soon decide the matter. . .

Asch A. Two cheers for conscience exceptions. Hastings Cent Rep. 2006 Nov-Dec;36(6):11-2. PubMed PMID: 17278865.

Adrienne Asch

  • In a recent discussion of conscience exceptions in medicine, Julian Savulescu writes: "If people are not prepared to offer legally permitted, efficient, and beneficial care to a patient because it conflicts with their values, they should not be doctors."1 Such strong statements have an appeal for anyone who laments that reproductive health services may be available de jure but in some parts of the United States are unavailable de facto. . .

Baergen R, Owens C. Revisiting pharmacists' refusals to dispense emergency contraception. Obstet Gynecol. 2006 Nov;108(5):1277-82. PubMed PMID: 17077256.

Ralph Baergen, Christopher Owens

  • Pharmacists' refusals to fill prescriptions for emergency contraceptives for reasons of conscience have contributed to a national debate regarding the permissibility of such actions. Some in the medical community assert that pharmacists ought not to refuse to dispense emergency contraceptives on this basis. Three lines of argument have become prominent in defense of that position . . .

Balmer L.  Royal Pharmaceutical Society and conscientious objectors. Lancet.  2006 Jun 17;367(9527):1980. PubMed PMID: 16782487.

Lynsey Balmer

  • In her Comment (April 15, p 1219),1 Katrina Bramstedt highlights conscientious objection by US pharmacists to the prescription of emergency contraception. Readers might be interested to learn the position with regard to pharmacists working in Great Britain who might have similar objections. . .

Bennett I, Aguirre AC, Burg J, Finkel ML, Wolff E,  Bowman K, Fleischman J.  Initiating Abortion Training in Residency Programs: Issues and Obstacles. Fam Med 2006;38(5):330-5.)

Ian Bennett, Abigail Calkins Aguirre, Jean Burg, Madelon L. Finkel, Elizabeth Wolff, Katherine Bowman, Joan Fleischman

  • Objectives: Early abortion is a common outpatient procedure, but few family medicine residencies provide abortion training. We wished to assess experiences and obstacles among residency programs that have worked to establish early abortion services.

Methods: From 2001–2004, 14 faculty participated in a collaborative program to initiate abortion training at seven family medicine residencies. Ten focus groups with all trainees were followed by individual semi-structured interviews with a smaller group (n=9) that explored the progress and obstacles they experienced. Individual interviews were recorded and analyzed to identify major themes and sub-themes related to initiating abortion training.

Results: Five of seven sites established abortion training. Five major themes were identified: (1) establishing support, (2) administration, (3) finance, (4) legal matters, and (5) security/demonstrators. Faculty from sites where training was ultimately established rated the sub-themes of billing/reimbursement, obtaining staff support, and state/hospital regulations as most difficult. Gaining support from within the department and institution was most difficult for the two sites that could not establish training. None experienced difficulty with security/demonstrators.

Conclusions: Developing the clinical and administrative capacity to provide early abortion services in family medicine residency programs is feasible. Support from leadership within departments and from the wider institution is important for implementation.

Blustein J. Infertility treatments for gay parents? Hastings Cent Rep. 2006 Sep-Oct;36(5):6. PubMed PMID: 17091688.

Jeffrey Blustein

  • The short essay by Jacob M. Appel, "May Doctors Refuse Infertility Treatments to Gay Parents?" (July-August 2006) raises interesting questions about the limits of conscience exemptions for health professionals. The discussion explores these issues in relation to an ongoing California case, Benitez v. NCWC, in which a lesbian seeking infertility treatments is suing her physicians for refusing to assist her because of their religious objections. . .

Cantor JD. When an adult female seeks ritual genital alteration: ethics, law, and the parameters of participation. Plast Reconstr Surg. 2006 Apr;117(4):1158-64; discussion 1165-6. PMID: 16582781

Julie D. Cantor

  • Ritual genital cutting for women, a common practice in Africa and elsewhere around the world, remains dangerous and controversial. In recent years, a 14-year-old girl living in Sierra Leone exsanguinated and died following a ritualistic genital cutting. Hoping to avoid that fate, women with backgrounds that accept ritual genital cutting may, when they reach majority age, ask plastic surgeons to perform genital alterations for cultural reasons. Although plastic surgeons routinely perform cosmetic procedures, unique ethical and legal concerns arise when an adult female patient asks a surgeon to spare her the tribal elder's knife and alter her genitalia according to tradition and custom. Misinformation and confusion about this issue exist. This article explores the ethical and legal issues relevant to this situation and explains how the thoughtful surgeon should proceed.

Chandrasekhar CA. Rx for drugstore discrimination: challenging pharmacy refusals to dispense prescription contraceptives under state public accommodations laws. Albany Law Rev. 2006;70(1):55-115. No abstract available. PMID: 17302002

Charu A. Chandrasekhar

  • Introduction: In January 2005, a Wisconsin mother of six children who experienced condom failure after intercourse ohtained a prescription for emergency contraception and traveled to a Milwaukee Walgreens to fill the prescription. Instead of honoring the physician's medical instructions, however, pharmacist Michelle Long refused to fill the prescription and "publicly berated" the customer, telling her, 'You're a murderer. I will not help you kill this baby. I will not have the blood on my hands.'' Although the customer tried to reason with the pharmacist, the pharmacist's castigation only escalated. . .

Chervenak FA, McCullough LB.  Conscientious Objection In Medicine: Author did not meet standards of argument based ethics. (Letter) BMJ 2006 February 18; 332: 425 

Frank A. Chervenak, Laurence B. McCullough

  • Savulescu's account of conscientious objection in medicine is a bold statement that requires all obstetricians to perform abortions, regardless of any moral convictions that they may have to the contrary. Unfortunately, he violates the standards of argument based ethics. . .

Clark PA. Physician participation in executions: care giver or executioner? J Law Med Ethics. 2006 Spring;34(1):95-104. PMID: 16489988

Peter A. Clark

  • To circumvent objections that the death penalty was "cruel and unusual punishment" and therefore a violation of the Eighth Amendment to the Constitution, advocates proposed lethal injection and the involvement of physicians to overcome the negative perceptions associated with the death penalty, and to increase public acceptability of the practice. Initiated in 1982, lethal injection is now the primary method of execution in 37 of the 38 states with the death penalty. . .

Collins MK. Conscience clauses and oral contraceptives: conscientious objection or calculated obstruction? Ann Health Law. 2006 Winter;15(1):37-60.

Mary K. Collins

  • Introduction: A busy mother of two runs by her neighborhood pharmacy to refill her birth control pills, a routine chore she has engaged in monthly for the past year. The pharmacist tells her, "I personally don't believe in birth control and therefore I'm not going to fill your prescription." Increasing numbers of pharmacists and physicians are refusing to dispense or prescribe these forms of pregnancy prevention, citing moral objections to hormonal contraceptives like the Pill. The objections are based on the belief that hormonal methods of contraception are abortifacients; that is, that the use of these methods will result in the destruction of a fertilized egg. . .

Croxatto HB, Fernéndez SD. Emergency contraception - a human rights issue. Best Pract Res Clin Obstet Gynaecol. 2006 Jun;20(3):311-22. Epub 2006 Feb 9. PubMed PMID: 16480928.


Dickens BM.  Ethical misconduct by abuse of conscientious objection laws. Med Law. 2006 Sep;25(3):513-22. PubMed PMID: 17078524.

Bernard M. Dickens

  • Abstract: This paper addresses laws and practices urged by conservative religious organizations that invoke conscientious objection in order to deny patients access to lawful procedures. Many are reproductive health services, such as contraception, sterilization and abortion, on which women's health depends. Religious institutions that historically served a mission to provide healthcare are now perverting this commitment in order to deny care. Physicians who followed their calling honourably in a spirit of self-sacrifice are being urged to sacrifice patients' interests to promote their own, compromising their professional ethics by conflict of interest. The shield tolerant societies allowed to protect religious conscience is abused by religiously-influenced agencies that beat it into a sword to compel patients, particularly women, to comply with religious values they do not share. This is unethical unless accompanied by objectors' duty of referral to non-objecting practitioners, and governmental responsibility to ensure supply of and patients' access to such practitioners.

Dietz LH, Jacobs A, Leming TL , Kennel JR. Duty to Refer Patient to Specialist or Qualified Practitioner. 61 Am. Jur. 2d Physicians, Surgeons, and Other Healers 214 (2006).


Duvall, M. Pharmacy Conscience Clause Statutes: Constitutional Religious "Accommodations" or Unconstitutional "Substantial Burdens" on Women?" American University Law Review [Vol. 55:1485] 2006.

Melissa Duvall

  • Introduction:  As Americans increasingly integrate religion into their daily lives, "conscience clause" statutes are proliferating and influencing professional conduct across the United States. Conscience clauses allow Americans to practice religion not only in their homes and places of worship, but also in their professions. These statutes exempt individuals and entities from legal requirements that conflict with their religious beliefs, and they often become controversial when they pit one citizen's religious freedom against another's health or safety. . .

Gampel E. Does professional autonomy protect medical futility judgments? Bioethics. 2006 Apr;20(2):92-104. PubMed PMID: 16770879.

Eric Gampel

  • Abstract: Despite substantial controversy, the use of futility judgments in medicine is quite common, and has been backed by the implementation of hospital policies and professional guidelines on medical futility. The controversy arises when health care professionals (HCPs) consider a treatment futile which patients or families believe to be worthwhile: should HCPs be free to refuse treatments in such a case, or be required to provide them? Most physicians seem convinced that professional autonomy protects them from being forced to provide treatments they judge medically futile, given the lack of patient benefit as well as the waste of medical resources involved. The argument from professional autonomy has been presented in a number of articles, but it has not been subjected to much critical scrutiny. In this paper I distinguish three versions of the argument: 1) that each physician should be free to exercise his or her own medical judgment; 2) that the medical profession as a whole may provide futility standards to govern the practice of its members; and 3) that the moral integrity of each physician serves as a limit to treatment demands. I maintain that none of these versions succeeds in overcoming the standard objection that futility determinations involve value judgments best left to the patients, their designated surrogates, or their families. Nor do resource considerations change this fact, since they should not influence the properly patientcentered judgment about futility.

Gans JA. Refusals by Pharmacists to Dispense Emergency Contraception: A Critique (Letter). 2006 Dec;108(6):1549.

John A. Gans

  • The commentary by Wall and Brown was striking in its intentional blurring of pharmacist refusals with unethical obstruction of patient access to medications, its ignorance of contemporary pharmacy practice, and its lack of citation of the positions of health care professional organizations. . .

Genuis SJ.  Dismembering the ethical physician. Postgrad Med J 2006;82:233–238.  doi:10.1136/pgmj.2005.037754

Stephen J. Genuis

  • Physicians may experience ethical distress when they are caught in difficult clinical situations that demand ethical decision making, particularly when their preferred action may contravene the expectations of patients and established authorities. When principled and competent doctors succumb to patient wishes or establishment guidelines and participate in actions they perceive to be ethically inappropriate, or agree to refrain from interventions they believe to be in the best interests of patients, individual professional integrity may be diminished, and ethical reliability is potentially compromised. In a climate of ever-proliferating ethical quandaries, it is essential for the medical community, health institutions, and governing bodies to pursue a judicious tension between the indispensable regulation of physicians necessary to maintain professional standards and preserve public safety, and the support for ''freedom of conscience'' that principled physicians require to practise medicine in keeping with their personal ethical orientation.

Glasberg AL, Eriksson S, Dahlqvist V, Lindahl E, Strandberg G, Söderberg A, Sørlie V, Norberg A. Development and initial validation of the Stress of Conscience Questionnaire. Nurs Ethics. 2006 Nov;13(6):633-48. PubMed PMID:17193804.

Ann-Louise Glasberg, Sture Eriksson, Vera Dahlqvist, Elisabeth Lindahl, Gunilla Strandberg, Anna Söderberg, Venke Sørlie, Astrid Norberg

  • Stress in health care is affected by moral factors. When people are prevented from doing 'good' they may feel that they have not done what they ought to or that they have erred, thus giving rise to a troubled conscience. Empirical studies show that health care personnel sometimes refer to conscience when talking about being in ethically difficult everyday care situations. This study aimed to construct and validate the Stress of Conscience Questionnaire (SCQ), a nine-item instrument for assessing stressful situations and the degree to which they trouble the conscience. The items were based on situations previously documented as causing negative stress for health care workers. Content and face validity were established by expert panels and pilot studies that selected relevant items and modified or excluded ambiguous ones. A convenience sample of 444 health care personnel indicated that the SCQ had acceptable validity and internal consistency (Cronbach's alpha exceeded 0.83 for the overall scale). Explorative factor analysis identified and labelled two factors: 'internal demands' and 'external demands and restrictions'. The findings suggest that the SCQ is a concise and practical instrument for use in various health care contexts.

Grady A.  Legal Protection for Conscientious Objection by Health Professionals.  Virtual Mentor. 2006; 8:327-331

Allison Grady

  • The emerging popularity of medical "conscience clauses" has been attracting attention most notably in the pharmaceutical field. Conscience clauses are laws that explicitly allow for health care workers to opt out of certain procedures, usually reproductive and end-of-life therapies, on moral, ethical, or religious grounds. Within medical circles, a doctor's right to refuse to offer specific treatments in a nonemergency setting, so long as alternative treatment options are provided, is well known and reinforced by state and federal laws and the American Medical Association's Code of Medical Ethics. But for other health care workers, including pharmacists, there is neither legislative support nor a rich professional tradition that allows for conscientious objection. . .

Greenawalt, K.  Objections In Conscience To Medical Procedures: Does Religion Make A Difference? 2006 U. Ill. L. Rev. 799

Kent Greenawalt

  • How should the government respond if people refuse standard medical treatment? What should the government do if people refuse medical treatment for their children, and what autonomy should teenagers be given in making such choices? Is religion a proper basis for refusing such medical treatment? Furthermore, should medical practitioners have a privilege not to render services that they object to in conscience? This article analyzes such questions and proposes that the most sensible answers depend on context. Legislatures should sometimes create no exemptions, should sometimes create exemptions based on nonreligious criteria, and should sometimes use criteria framed in terms of religion. As a matter of constitutional law, statutes may often use religion as a criterion for a privilege, but even then, legislatures may choose broader criteria.

Knestout BP. An essential prescription: why pharmacist-inclusive conscience clauses are necessary. J Contemp Health Law Policy. 2006 Spring;22(2):349-82. Review. PubMed PMID: 17117701.

  • Critics of conscience clauses have held that such statutes should be narrowly restricted to purely sectarian institutions. Any type of connection to the public world would require the institution, and the people operating within it, to conform to secular principles. In short, such critics argue that if an individual or institution is "[i]n the public world, they should play by public rules." Such a test would add to another requirement prior to validation of a conscience clause that no burden be imposed on any other individual. Any type of burden that would be imposed on another person by a pharmacist's morally or religiously motivated refusal would be grounds to nullify the exemption. . .

Miller J. The unconscionability of conscience clauses: pharmacists' consciences and women's access to contraception. Health Matrix Clevel. 2006 Winter;16(1):237-78. PubMed PMID: 16689056. ¤

Jed Miller

Introduction: Pharmacists are now at the forefront of the controversy surrounding abortion and contraception. In recent years, some pharmacists, motivated by religious or moral scruples, have refused to dispense birth control and emergency contraception (EC) to their female customers.'' As a result, women's efforts to obtain contraception have been frustrated. The earliest report of a pharmacist who refused to dispense EC was in 1991.  Since then, pharmacists across the country have acted on their beliefs and denied women access to contraception. . .

Murray E, de Zulueta P. Conscientious Objection In Medicine: The ethics of responding to bird flu. (Letter)  BMJ 2006 February 18; 332: 425 

Elizabeth Murray,Paquita de Zulueta

  • We question Savulescu's statement that a specialist valuing her own life more than her duty to her patients during a bird flu epidemic would be demonstrating values "incompatible with being a doctor." By 6 February 2006 the World Health Organization had received reports of 165 confirmed cases of avian influenza in humans, of whom 88 had died (mortality 53%). The Department of Health's influenza pandemic contingency plan estimates an attack rate of 25% and a case fatality rate of 0.37%.3 Health care staff are likely to be particularly at risk, with estimated sickness absence rates double the rate of the general population. . .

Panicola MR, Hamel RP. Conscience, cooperation, and full disclosure. Can Catholic health care providers disclose "prohibited options" to patients following genetic testing? Health Prog. 2006 Jan-Feb;87(1):52-9. PubMed PMID: 16519284.


Savulescu J. Conscientious objection in medicine. BMJ. 2006 February 4; 332(7536): 294–297. doi:  10.1136/bmj.332.7536.294

Julian Savulescu

  • Shakespeare wrote that "Conscience is but a word cowards use, devised at first to keep the strong in awe" (Richard III V.iv.1.7). Conscience, indeed, can be an excuse for vice or invoked to avoid doing one's duty. When the duty is a true duty, conscientious objection is wrong and immoral. When there is a grave duty, it should be illegal. A doctors' conscience has little place in the delivery of modern medical care. What should be provided to patients is defined by the law and consideration of the just distribution of finite medical resources, which requires a reasonable conception of the patient's good and the patient's informed desires (box). If people are not prepared to offer legally permitted, efficient, and beneficial care to a patient because it conflicts with their values, they should not be doctors. Doctors should not offer partial medical services or partially discharge their obligations to care for their patients. . .

Smith VP.  Conscientious Objection In Medicine: Doctors' freedom of conscience. (Letter)  BMJ 2006 February 18; 332: 425 

Vaughn P. Smith

  • Since visiting Auschwitz, I have grappled with the question of how I would have behaved as a doctor in Nazi Germany or Stalinist Russia. I hope I would have had the moral courage to refuse to participate in the various perversions of medicine that these regimes demanded - for example, respectively, eugenic "research" and psychiatric "treatment" of dissidents. . .

Swartz MS. "Conscience clauses" or "unconscionable clauses": personal beliefs versus professional responsibilities. Yale J Health Policy Law Ethics. 2006 Summer;6(2):269-350. Review. PubMed PMID: 17133969.

Martha Swartz

  • In 2002, a University of Wisconsin student brought a prescription for Loestrin to pharmacist Neil Noesen, who was working in a local community phannacy in Menomonie, Wisconsin. Noesen refused to fill the prescription, citing his  "conscientious objection to participation in refilling a contraceptive order." He failed to ask the student whether she had any medical conditions that might make pregnancy dangerous. He also refused to inform her of any other local pharmacies that were capable of filling the prescription. 3 When the student, on her own, located another pharmacy, Noesen refused to transfer the prescription, claiming that doing so would "induce another to do a morally wrong or sinful act pursuant to the doctrines of the Roman Cathoiic Church." As a result, the student was unable to ·take her medication as prescribed and risked pregnancy. . .

Vischer RK. Conscience in context: pharmacist rights and the eroding moral marketplace. Stanford Law Pol Rev. 2006;17(1):83-119. PubMed PMID: 17165232.

Robert K. Vischer

  • Introduction:  "The Religion then of every man must be left to the conviction and conscience of every man; and it is the right of every man to exercise it as these may dictate."

With these words, James Madison helped derail proposed legislation that would have provided taxpayer funding "for Teachers of the Christian Religion" in Virginia. Over the ensuing 220 years, Madison's sentiment has become a fixture of the American constellation of non-negotiable ideals. Religious devotion is a matter for individual conscience, not external coercion. As a citizeny, we comprise hundreds of wildly divergent faiths (including a rising number claiming no faith), and thus our common life requires uncommon tolerance, whether as a function of principle or simple survival.

Wall LL, Brown D. Refusals by pharmacists to dispense emergency contraception: a critique. Obstet Gynecol. 2006 May;107(5):1148-51. PubMed PMID: 16648422.

L. Lewis Wall, Douglas Brown

  • Over the past several months, numerous instances have been reported in the United States media of pharmacists refusing to fill prescriptions written for emergency postcoital contraceptives. These pharmacists have asserted a "professional right of conscience" not to participate in what they interpret as an immoral act. . .

Wall LL, Brown D.  Refusals by Pharmacists to Dispense Emergency Contraception: A Critique (Authors' reply). 2006 Dec;108(6):1549.

L. Lewis Wall, Douglas Brown

  • We thank Dr. Gans for his interest in our commentary. We are pleased that the organizations he represents are willing to go on record as opposing pharmacists who deliberately obstruct patient access to legitimate prescription medications. Likewise, we are pleased that he is willing to denounce pharmacists who use their position at the counter as a pulpit to advance their personal beliefs. Activities of this kind by pharmacists are becoming increasingly common and should be opposed by all health care professionals.

Wicclair MR. Pharmacies, pharmacists, and conscientious objection. Kennedy Inst Ethics J. 2006 Sep;16(3):225-50. PubMed PMID: 17091559.

Mark R. Wicclair

  • Abstract: This paper examines the obligations of pharmacy licensees and pharmacists in the context of conscience-based objections to filling lawful prescriptions for certain types of medications - e.g., standard and emergency contraceptives. Claims of conscience are analyzed as means to preserve or maintain an individual's moral integrity. It is argued that pharmacy licensees have an obligation to dispense prescription medications that satisfy the health needs of the populations they serve, and this obligation can override claims of conscience. Although efforts should be made to respect the moral integrity of pharmacists and accommodate their claims of conscience, it is argued that the health needs of patients and the professional obligations of pharmacists limit the extent to which pharmacists may refuse to assist patients who have lawful prescriptions for medically indicated drugs.

Winckler SC, Gans JA. Conscientious Objection and Collaborative Practice: Conflicting or Complementary Initiatives? J Am Pharm Assoc. 2006;45(1):12-13.

Susan C. Winckler, John A. Gans

  • Two articles in this issue of the Journal relate to emergency contraception. Borrego et al report results of research to assess pharmacists' knowledge, attitudes, and beliefs toward prescribing oral emergency contraception, and Monastersky and Landau provide their perspectives on pharmacists' efforts to expand consumer access to emergency contraception through collaborative practice agreements. Inherent in such discussions is the conscience clause issue, through which individual pharmacists can choose to opt out of participating in activities that conflict with their personal beliefs. As reflected in Tables 1 and 2, the American Pharmacists Association (APhA) supports both this conscience clause as well as expanded access to emergency contraception through collaborative practice agreements, and these positions have sparked questions about the apparent disconnect between the two concepts. . .