Opaque data and expanding medical claims underscore urgent need for transparency and oversight of unregulated pregnancy clinics (UPCs)
WASHINGTON, DC – Reproductive Health and Freedom Watch (RHFW) today responded to the Charlotte Lozier Institute’s newest report, A Legacy of Life & Love 2025: Rising to the Occasion with Unwavering Care, which claims to document the impact of 2,775 “pregnancy centers” across the United States in 2024.
Authored by the Charlotte Lozier Institute, Heartbeat International, Care Net, the National Institute of Family and Life Advocates, and Focus on the Family (“CLI et al.”) and released on November 17, 2025, this report is the latest installment in a long-running series of publications produced by the unregulated pregnancy clinic (UPC) industry. Taken together, data from these reports—spanning back to 2009 and reiterated in this newest release—indicate demand for UPC services has remained largely stagnant, even as revenues have surged to a projected $2.2 billion for FY 2024, fueled in part by millions in taxpayer dollars.
Key Findings
CLI et al. do not share the names of the 2,775 UPCs included in their analysis, making it impossible to independently verify or replicate their findings. But data presented in this and prior UPC industry reports – link to comparison table – reveal:
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2024 represents the smallest growth in UPC industry-reported value of goods and services delivered. Between 2022 and 2024, CLI et al. report a 26% increase—far below prior periods: 2010→2017 (+59.6%), 2017→2019 (+65.7%), and 2019→2022 (+34.4%).
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2024 also reflects stagnation in client engagement. Although CLI et al. stopped reporting total unique clients after 2019, their own data show the average number of new clients per UPC has fallen 25% since 2010. The slight uptick they report—just 3% since 2022—is in the context of a continued downward trend in per-clinic demand.
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Compared to 2022, CLI et al. report a 23% increase in ultrasounds, an 18% increase in STI/STD tests, and a slight 0.5% decrease in pregnancy tests. In 2024, they state 2,239 UPCs performed 636,514 ultrasounds—an average of 284 per clinic, or roughly 24 per month—raising concerns about quality, training, scope of practice, and oversight. Meanwhile, the rise in STI/STD testing reflects a broader push into public-health-adjacent services—without clinical accountability, reporting requirements, treatment linkages, or transparency.
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The most significant growth area is not medical care but baby supplies. According to CLI et al., the most dramatic increase in client “service demand” between 2022 and 2024 is for baby items such as diapers, which rose 77%, underscoring a greater demand for material-aid distribution than clinical services.
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UPCs continue to expand their staffing footprint. From 2022 to 2024, CLI et al. report increases in the number of paid staff (+5.2%), paid “licensed medical staff” (+7.8%), and volunteers (+4.72%).
A Call for Oversight
RHFW’s initial review of the CLI et al. report highlights a core problem: the report asks policymakers and the public to take its sweeping claims on faith, while withholding the basic information needed to independently verify or replicate any of its findings.
“This report reads like a glossy fundraising brochure, not a serious piece of health-services research,” said Debra Rosen, Executive Director of Reproductive Health and Freedom Watch. “At a moment when unregulated pregnancy clinics are expanding medical-sounding services and receiving hundreds of millions in taxpayer dollars, we need transparency, clinical accountability, and independent evaluation—not unverifiable numbers and self-assigned price tags. Before another dollar of public money flows into this system, policymakers should demand full clinic lists, clinical credentials, and independent evaluations—not just self-reported numbers and feel-good anecdotes.”
Because data from previous UPC industry reports have been used by public officials proposing taxpayer appropriations to the UPC industry, Charlotte Lozier Institute, Care Net, Heartbeat International, NIFLA, and Focus on the Family’s should address several questions, including:
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What are the 2,775 unregulated pregnancy clinics included in this report? Without a clinic-level list, the findings cannot be independently verified or replicated.
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What is the average budget of the 2,775 UPCs in this report? RHFW’s analysis of 2023 IRS Form 990 data for 1,687 tax IDs (representing an estimated 2,125 clinic locations) shows $1.9 billion in revenue, $1.7 billion in expenses, and $2.4 billion in assets across this ecosystem. Any serious impact analysis must be situated in that financial scale.
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The report calculates service “values” based on fair market costs for services provided by credentialed professionals–are estimated values for medical and mental health services being performed by providers with relevant credentials? The methodology values services such as ultrasounds, counseling, and classes by multiplying volumes by mean hourly wages for social workers, nurses, and sonographers, then adds a separate “value” per ultrasound procedure using a commercial price benchmark.
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The report treats the “value” of an ultrasound exam as distinct from the labor to provide it. What is the rationale for these two separate entries?
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Are the fair-market costs of the non-diagnostic, limited obstetric ultrasounds performed by UPCs comparable to the diagnostic first-trimester ultrasound rates that CLI et al. use to estimate the “value” of these services?
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