“The [proposal] imposes an inaccurate view of human nature and sexuality,” the comment from the Catholic institutions said.

“It is internally inconsistent, unworkably vague, and fails to consider a significant aspect of the issue presented — the intersection of the [proposal’s] requirements with the Title IX religious exemption,” it continued. “We respectfully recommend that the Department abandon this rulemaking.”

The coalition argued that the proposed rule rests on an inaccurate view of gender.

“Human bodiliness is … intrinsically connected with human sexual differentiation,” the coalition wrote.

“Just as every human person necessarily has a body, so also human bodies, like those of other mammals, are sexually differentiated as male or female,” the comment continued.

“Just as bodiliness is a fundamental aspect of human existence, so is either ‘being a man’ or ‘being a woman’ a fundamental aspect of existence as a human being, expressing a person’s unitive and procreative finality.”