Program II · Open Governance Frameworks — Public Pilot
Model policies and decision protocols any institution can adopt as written.
Standardized, openly licensed, annotated to controlling authority. Free for every employer, school system, healthcare institution, and public agency.
- No account required
- Free
- CC BY 4.0
- Open methodology
The law already binds these institutions
Employers
Title VII, 42 U.S.C. § 2000e(j), as construed in Groff v. DeJoy, 600 U.S. 447 (2023): accommodation is required unless the employer shows “substantial increased costs in relation to the conduct of its particular business.”
Groff v. DeJoy, 600 U.S. 447 (2023) — slip opinion, No. 22-174Verified · Official sourcesupremecourt.govLast verified July 13, 2026School districts
ESEA § 8524, 20 U.S.C. § 7904: annual written certification of compliance with the federal religious-expression guidance is a condition of receiving federal funds.
20 U.S.C. § 7904 — ESEA § 8524, constitutionally protected prayer certificationVerified · Official sourceuscode.house.govLast verified July 13, 2026Healthcare institutions
Federal conscience statutes — the Church, Coats-Snowe, and Weldon Amendments — administered and enforced by the HHS Office for Civil Rights.
HHS Office for Civil Rights — Conscience Protections (Church, Coats-Snowe, Weldon)Verified · Official sourcehhs.govLast verified July 13, 2026Law enforcement & municipal agencies
First Amendment free-exercise obligations arise in daily religious interactions. Documented codified precedent: Chicago Police Department General Order G02-01-05, Religious Interactions (eff. Apr. 29, 2022).
Chicago Police Department — Directives System (General Order G02-01-05, Religious Interactions)Verified · Official sourcedirectives.chicagopolice.orgLast verified July 13, 2026
Select your institution
The standard that binds you, the decisions your frontline staff face today, and the instrument in production — with every proposition linked to its official source.
Exposure draft · Module A
Religious Accommodation Decision Protocol — Exposure Draft v0.1 (post-Groff)
Step 1 — Intake
Accept the request in any form; no specific words are required. An employee need only provide notice sufficient to make the employer aware that a conflict exists between religious practice and a work requirement.
EEOC Compliance Manual § 12-IV(A); 29 C.F.R. § 1605.2
Step 2 — Religious nature and sincerity
“Religion” is defined broadly to include all aspects of religious observance and practice, as well as belief. A sincerity inquiry is permitted but narrow; disagreement with the belief, or the belief's unfamiliarity, is never a ground for denial.
42 U.S.C. § 2000e(j); 29 C.F.R. § 1605.1; EEOC Compliance Manual § 12-I(A)
42 U.S.C. § 2000e(j) — definition of “religion” (Title VII)Verified · Official sourceuscode.house.govLast verified July 13, 202629 C.F.R. Part 1605 — Guidelines on Discrimination Because of ReligionVerified · Official sourceecfr.govLast verified July 13, 2026EEOC Compliance Manual, Section 12: Religious DiscriminationVerified · Official sourceeeoc.govLast verified July 13, 2026Step 3 — Identify accommodation options with the employee
Explore accommodation options with the employee — schedule changes, voluntary shift swaps, lateral transfers, and modifications to workplace practices — and document each option considered.
29 C.F.R. § 1605.2(d); EEOC Compliance Manual § 12-IV(B)
Step 4 — Undue hardship under Groff
To deny, the employer must show that the burden of granting the accommodation “would result in substantial increased costs in relation to the conduct of its particular business,” assessed in light of the nature, size, and operating cost of the employer.
Groff v. DeJoy, 600 U.S. 447, 470 (2023)
Caution. Coworker impacts count only insofar as they affect the conduct of the business; hostility to religious practice or the fact of an accommodation cannot be considered. Groff, 600 U.S. at 472.
Step 5 — Decision and documentation
If denying, document the specific substantial-cost showing; Groff requires consideration of alternative accommodations before denial — it is not enough that the requested accommodation itself imposes hardship.
Groff v. DeJoy, 600 U.S. 447, 473 (2023)
Step 6 — Periodic review
Review granted and denied accommodations on a fixed cycle; log every decision. Changed business circumstances may change the substantial-cost analysis in either direction.
EEOC Compliance Manual § 12-IV; 29 C.F.R. Part 1605
Public comment
This exposure draft is open for public comment under the Institute's Documentation Standards. Submit comments via the contact page; all substantive comments and their dispositions will be published with the final module.
Exposure draft for public comment. Not legal advice. Final Module A releases Q1 2027 under CC BY 4.0.
Adoption Registry (optional)
Registration is never required. Every instrument on this site is free, identical, and openly licensed for every user. Institutions that choose to register their adoption receive a semiannual implementation survey; responses shape each numbered revision, and every resulting change is recorded in the public change log.
How instruments are built
Doctrinal mapping
The controlling doctrine for each institution class is mapped via Program I's Comparative Jurisprudence Lab, which consolidates the governing federal and state framework with pinpoint citations.
Instrument drafting
Each instrument is drafted as directives a frontline decision-maker can apply as written — no interpretation layer, no consulting engagement required.
Annotation
Every provision is pinpoint-cited to the controlling statute, regulation, or decision.
Field testing
Instruments are tested in structured-dialogue convenings with the institutions that must apply them; findings are published.
Publication
Publication under CC BY 4.0 — the instrument is identical for every adopter.
Maintenance
A biennial doctrinal-update cycle with versioned releases; every change is recorded in the public change log.
Public change log
| Version | Date | Instrument | Change | Nature |
|---|---|---|---|---|
| v0.1 | July 13, 2026 | Module A Exposure Draft | Initial public release for comment | — |
This log is append-only. Entries are never deleted.
Open-Access Policy Education Platform
- In Development — First training modules launch Q4 2027
Alongside its written instruments, Program II will deliver free, open-registration training on public policy and religious-freedom governance, with priority curricula addressing post-Groff religious-accommodation obligations for small employers and under-resourced public institutions. Distinct from the program's policy instruments, these training modules are educational programming — general content, not individualized legal advice.
The in-person component replicates the operating model of the International Religious Freedom Roundtable — in which the Institute's Founding Director serves as Co-Chair of the Latin America Working Group — relying on donation funding and in-kind venue contributions from partner universities and civic institutions rather than facility expenditures. Performance will be reported annually through verifiable indicators — registrations, module completions, and material downloads — consistent with the BBB Wise Giving Alliance Standards for Charity Accountability.
Q1–Q3 2027
Volunteer expert-faculty roster and venue partnerships enabling virtual and in-person education and dialogue spaces.
Q4 2027
First pre-recorded training modules published as open educational resources (CC BY 4.0); first in-person sessions at partner venues.
Receive updates or volunteer
For individuals and institutions interested in the Education Platform. Institutions adopting policy instruments should use the Adoption Registry above.
All course materials will be released under a Creative Commons Attribution 4.0 International (CC BY 4.0) license.