“Program of Action of the International Conference on Population and Development” comprises the majority of context within the twenty-year sustainable development plan, International Conference on Population and Development Program of Action, hereafter POA, published in 1994 by the United Nations Population Fund or UNFPA. Given the rising global population, the goal of the POA was to outline the steps governments around the world were to take to achieve sustainable development by 2014. Under leadership of the United Nations Population Fund, 179 countries met in Cairo, Egypt, to debate the best way to address the growing global population and the need for sustainable development. The debates began on 5 September 1994 and ended on 13 September 1994, resulting in all 179 participating countries endorsing the Program of Action. The Program of Action encouraged participating countries to prioritize human rights, reproductive rights, and women’s empowerment during all future sustainable development plans and programs.

On 29 June 1988, in Bowen v. Kendrick, the US Supreme Court ruled in a five-to-four decision that the 1981 Adolescent Family Life Act, or AFLA, was constitutional. Under AFLA, the US government could distribute federal funding for abstinence-only sexual education programs, oftentimes given to groups with religious affiliations. As a federal taxpayer, Chan Kendrick challenged the constitutionality of AFLA, claiming it violated the separation of church and state. The Supreme Court found that although AFLA funded programs that aligned with certain religious ideologies, it was constitutional because it did not encourage government involvement in religion, and it held a valid secular purpose in seeking to prevent adolescent pregnancy and premarital sexual relations. By upholding AFLA, Bowen v. Kendrick enabled the US government to continue funding abstinence-only education, which researchers have found to be ineffective.

On 23 April 2008, the US Government Accountability Office, or GAO, released a report titled, “Abstinence Education: Assessing the Accuracy and Effectiveness of Federally Funded Programs,” hereafter “Abstinence Education,” in which it investigated the scientific accuracy and effectiveness of abstinence-only education programs sanctioned by individual states and the US Department of Health and Human Services, or HHS. GAO is a government agency whose role is to examine the use of public funds, evaluate federal programs and activities, and provide nonpartisan support to the US Congress. In “Abstinence Education,” GAO found that as of August 2006, a variety of factors in such programs, such as inaccurate medical information, contributed to overall conclusions that abstinence-until-marriage programs were unsuccessful at reducing the rates of adolescent pregnancy. In “Abstinence Education,” GAO recommends that HHS implement procedures to better assure the accuracy of educational materials used in abstinence programs and to set standards that measure the effectiveness of those programs.