Project 2025 Tracker / What’s done, what’s next

Section 3 · The General Welfare

14 Department of Health and Human Services

449–502 · Roger Severino

  • 9 done
  • 33 partially done
  • 22 attempted
  • 130 not started
  • 6 already true

Major recommendations (21)

What has happened

The Mandate said

“HHS should rescind the Biden Administration’s regulation and reinstate the Trump Administration regulation for the program. It should also do this quickly (the Biden Administration completed its regulatory process and issued a final rule in less than nine months) and expand the potential grantee population beyond abortion providers like Planned Parenthood.”

What happened

Attempted

HHS has formally scheduled the rulemaking this ask names, and nothing has changed on the ground. The 2026 Unified Agenda, published 2026-08-14, carries HHS/OASH RIN 0937-AA15, "Compliance with Title X Statutory Program Integrity Requirements", at Proposed Rule Stage against 42 CFR part 59 subpart A, with a proposed rule listed for 07/2026 and none published. Its abstract - "This NPRM proposes to ensure HHS's Title X regulation complies with statutorily mandated program integrity requirements" - is the title and the frame of the 2019 Trump regulation the Quote asks HHS to reinstate. The 2021 Biden rule is still the governing regulation: HHS's Office of Population Affairs presents it as current at 42 CFR part 59 and lists no Program Policy Notice later than 2024, and no proposed or final rule rescinding it or reinstating the 2019 rule has appeared in the Federal Register since 2025-01-20. A dated agenda entry naming the ask's object is `attempted` and never more (playbook §3b, settled 2026-09-01); only a published NPRM would climb further. The Quote's third limb - expanding the grantee population beyond abortion providers - is not mentioned in the entry.

The Mandate said

“The redefinition of sex to cover gender identity and sexual orientation and pregnancy to cover abortion should be reversed in all HHS and CMS programs as was done under the Trump Administration. This includes the Children’s Health Insurance Program (CHIP).”

What happened

Partially done

CMS finalized a rule barring federal Medicaid and CHIP funds for sex-rejecting procedures for minors, requiring State Medicaid and separate CHIP plans to refuse payment (effective 2026-10-13, with a six-month run-off for beneficiaries already on cross-sex hormone therapy). This reaches CHIP, which the Mandate names. It is the furthest the reversal has gone by rule; no HHS-wide regulation redefining sex across every program was found, so the sweep is not complete.

The Mandate said

“Add work requirements and match Medicaid benefits to beneficiary needs. … Clarify that states have the ability to adopt work incentives for able-bodied individuals (similar to what is required in other welfare programs) and the ability to broaden the application of targeted premiums and cost sharing to higher-income enrollees.”

What happened

Done

CMS published an interim final rule with comment period interpreting and implementing the community engagement requirement — qualifying activities, exceptions, exclusions, verification and State outreach duties (effective 2026-07-31; States must apply the requirement by 2027-01-01). Work requirements are now in both the statute and 42 CFR.

The Mandate said

“HHS should restore Section 1557, Section 504, and other OCR regulations and fix guidance documents.”

+1 more citation

What happened

Partially done

HHS published notice that the U.S. District Court for the Southern District of Mississippi, in Tennessee v. Kennedy, No. 1:24-cv-161-LG-BWR, had on 2025-10-22 vacated the provisions of the 2024 Section 1557 rule that extend sex discrimination to gender identity; those provisions are legally void and the rest of the rule stands. The Biden expansion is gone, but by court order rather than by the proposed rule restoring the 2020 Trump regulation that the Mandate asks HHS to issue — and no such proposed rule has appeared. Round 3 (2026-08-28) found that one is planned but unpublished: HHS OCR carries RIN 0945-AA32, "Modify Portions of Department of Health and Human Services Regulations Implementing Section 1557 of the Affordable Care Act", new to the 2026 Unified Agenda (published 2026-08-14) with an NPRM listed for 02/2027. That question is now settled and the answer does not move this item: a dated agenda entry is `attempted` and never more (playbook §3b, settled 2026-09-01), and this item already stands above `attempted`. The entry was re-checked on 2026-09-01 against the full HHS agenda on reginfo.gov (agencyCd=0900, 183 active RINs) and no NPRM for the RIN has been published.

The Mandate said

“The redefinition of sex to cover gender identity and sexual orientation and pregnancy to cover abortion should be reversed in all HHS and CMS programs as was done under the Trump Administration. This includes the Children’s Health Insurance Program (CHIP).”

What happened

Partially done

HHS's Office for Civil Rights rescinded or disavowed a set of its own guidance documents under Executive Orders 14192 and 14219, including (the following day) the 2023 guidance to retail pharmacies on nondiscriminatory access to reproductive health care that had read sex discrimination to reach abortion-related services.

Still to come

Executive action 95

  1. 454 Ban CDC Foundation acceptance of pharmaceutical industry money Notable Not started
  2. 454 Transfer VAERS, VSD, and CISA vaccine safety programs to the FDA Notable Not started
  3. 455 Cut funds to force every state to report abortion data to the CDC Notable Not started
  4. 455 Require CDC reporting of abortion complications and born-alive infants Notable Not started
  5. 456 Prohibit brand-name makers from parking first-to-file generic rights Notable Not started
  6. 457 Replace pass/fail drug facility inspections with a graded system Notable Not started
  7. 457 Exempt multi-source generic drugs from Medicaid rebate requirements Notable Not started
  8. 458 Restore the mifepristone REMS in-person dispensing requirement Notable Not started
  9. 459 Reinstate pre-2016 safety protocols for Mifeprex and its generics Notable Not started
  10. 459 Stop approving mail-order abortion drugs Notable Not started
  11. 462 Decommission the CDC and NIH Foundations Notable Not started
  12. 464 Restore the Medicare Advantage Qualifying Payment Arrangement Incentive demonstration Notable Not started
  13. 464 Restore the Global and Professional Direct Contracting (ACO REACH) model Notable Not started
  14. 468 Launch a Medicaid "personal option" for coverage outside the program Notable Not started
  15. 468 Add time limits or lifetime caps on Medicaid benefits Notable Not started

and 80 more →

Needs Congress 35

  1. 452 Have Congress clearly define and limit the CDC's legal authorities Major Not started
  2. 452 Split the CDC into two separate agencies Major Not started
  3. 453 Create a national epidemiological agency required by law to publish all data Major Not started
  4. 462 Block grant the NIH grants budget to the states Major Not started
  5. 465 Make Medicare Advantage the default enrollment option Major Not started
  6. 465 Repeal the Medicare Shared Savings Program and the Inflation Reduction Act Major Not started
  7. 465 Repeal the Medicare drug price negotiation program Major Not started
  8. 466 Reform Medicaid financing with block grants or per capita caps Major Not started
  9. 474 Permanently codify the Hyde and Weldon amendments Major Not started
  10. 482 Eliminate the Head Start program and the Office of Head Start Major Not started
  11. 456 Enact the Ensuring Accurate and Complete Abortion Data Reporting Act Notable Not started
  12. 461 Ban three-parent embryo creation and human cloning research Notable Not started
  13. 464 Remove ACA restrictions on physician-owned hospitals Notable Not started
  14. 465 Replace Medicare Advantage's payment formula with competitive bidding Notable Not started
  15. 465 Reconfigure the Medicare Advantage risk adjustment model Notable Not started

and 20 more →

All recommendations in this chapter

Every recommendation this chapter is the home of, in printed-page order.

  1. 452 Free NIH, CDC, and FDA regulators from private biopharmaceutical funding Not started
  2. 452 Impose a 15-year cooling-off period on federal drug regulators Not started
  3. 452 Restrict pharmaceutical executives from moving into regulatory agencies Not started
  4. 452 Adopt outcome-based metrics across HHS Not started
  5. 452 Have Congress clearly define and limit the CDC's legal authorities Needs Congress Not started
  6. 452 Split the CDC into two separate agencies Needs Congress Not started
  7. 453 Create a national epidemiological agency required by law to publish all data Needs Congress Not started
  8. 453 Require by law that the CDC stay out of political policy assessments Needs Congress Not started
  9. 453 Limit the CDC to facilitating rather than developing diagnostic tests Not started
  10. 454 Prohibit CDC guidance from taking on a prescriptive character Not started
  11. 454 Ban CDC Foundation acceptance of pharmaceutical industry money Not started
  12. 454 Require HHS to modernize electronic public health data collection Needs Congress Not started
  13. 454 Enter a public–private partnership to build a real-time health data system Partially done
  14. 454 Transfer VAERS, VSD, and CISA vaccine safety programs to the FDA Not started
  15. 454 Eliminate CDC programs that do not respect life or conscience rights Attempted
  16. 455 Fund CDC studies into the risks and complications of abortion Not started
  17. 455 Prohibit research using aborted fetal cells and baby body parts Needs Congress Partially done
  18. 455 Update CDC messaging on fertility awareness–based family planning Not started
  19. 455 Cut funds to force every state to report abortion data to the CDC Not started
  20. 455 Require CDC reporting of abortion complications and born-alive infants Not started
  21. 456 Enact the Ensuring Accurate and Complete Abortion Data Reporting Act Needs Congress Not started
  22. 456 End CDC collection of gender identity data Partially done
  23. 456 Prohibit brand-name makers from parking first-to-file generic rights Not started
  24. 456 Create legal remedies for generic makers to obtain brand-name samples Needs Congress Not started
  25. 456 Let laboratory-developed tests be shared between laboratories Not started
  26. 457 Revise statutes and rules to ease access to laboratory-modified tests Needs Congress Partially done
  27. 457 Disentangle FDA and CMS authority over medical tests Needs Congress Not started
  28. 457 Replace pass/fail drug facility inspections with a graded system Not started
  29. 457 Add facility codes to drug packaging and build a searchable database Attempted
  30. 457 Exempt multi-source generic drugs from Medicaid rebate requirements Not started
  31. 457 Promote efficacy trials of new uses for generic drugs Not started
  32. 458 Withdraw FDA approval of chemical abortion drugs Attempted
  33. 458 Restore the mifepristone REMS in-person dispensing requirement Not started
  34. 459 Reinstate pre-2016 safety protocols for Mifeprex and its generics Not started
  35. 459 Fix FAERS reporting of abortion pill complications Not started
  36. 459 Make abortion pill manufacturer inspections transparent Not started
  37. 459 Stop approving mail-order abortion drugs Not started
  38. 460 Restore the RFRA waiver for importing ethically derived vaccines Not started
  39. 460 Require drug development free of aborted fetal cell lines Not started
  40. 460 Impose a lengthy cooling-off period on FDA reviewers Not started
  41. 460 Restrict pharmaceutical direct-to-consumer advertising Partially done
  42. 461 Restore the ethics advisory board for fetal tissue research Needs Congress Not started
  43. 461 End NIH intramural fetal tissue research and the embryonic stem cell registry Partially done
  44. 461 Fund ethical alternatives to embryo-destructive research Attempted
  45. 461 Reconvene a National Council on Bioethics Not started
  46. 461 Ban three-parent embryo creation and human cloning research Needs Congress Not started
  47. 461 Create a research agenda on the harms of abortion to women Not started
  48. 462 Impose term limits on top career NIH leaders Not started
  49. 462 Block grant the NIH grants budget to the states Needs Congress Not started
  50. 462 Decommission the CDC and NIH Foundations Not started
  51. 462 Abolish the NIH Office of Equity, Diversity, and Inclusion Partially done
  52. 462 Fund NIH studies of the harms of cross-sex interventions Attempted
  53. 463 Restore the Medicare Coverage of Innovative Technologies (MCIT) rule Attempted
  54. 464 Restore the Risk Adjustment Data Validation (RADV) rule Partially done
  55. 464 Restore the Medicare Advantage Qualifying Payment Arrangement Incentive demonstration Not started
  56. 464 Restore the Global and Professional Direct Contracting (ACO REACH) model Not started
  57. 464 Advance Medicare site neutrality by eliminating the inpatient-only list Partially done
  58. 464 Restore conscience protections for providers in federal health programs Attempted
  59. 464 Remove ACA restrictions on physician-owned hospitals Needs Congress Not started
  60. 464 Expand competition between Medicare Advantage and private plans Needs Congress Not started
  61. 465 Make Medicare Advantage the default enrollment option Needs Congress Not started
  62. 465 Replace Medicare Advantage's payment formula with competitive bidding Needs Congress Not started
  63. 465 Reconfigure the Medicare Advantage risk adjustment model Needs Congress Not started
  64. 465 Base Medicare payments on patient health status, not site of service Needs Congress Attempted
  65. 465 Replace Medicare fee-for-service with value-based payments Needs Congress Attempted
  66. 465 Codify price transparency regulations Needs Congress Attempted
  67. 465 Restructure 340B drug subsidies toward beneficiaries Needs Congress Not started
  68. 465 Repeal the Medicare Shared Savings Program and the Inflation Reduction Act Needs Congress Not started
  69. 465 Repeal the Medicare drug price negotiation program Needs Congress Not started
  70. 465 Eliminate the Part D coverage gap and shift catastrophic costs to manufacturers Needs Congress Not started
  71. 466 Reform Medicaid financing with block grants or per capita caps Needs Congress Not started
  72. 467 End Medicaid state financing loopholes Partially done
  73. 467 Reform Medicaid payments to hospitals for uncompensated care Not started
  74. 467 Replace the Medicaid enhanced match rate Needs Congress Partially done
  75. 467 Restructure Medicaid financing and reform DSH payments Needs Congress Not started
  76. 467 Pay states a contingency fee for cutting Medicaid waste and fraud Not started
  77. 467 Tighten Medicaid eligibility determinations and asset tests Partially done
  78. 467 Conduct oversight and reform of Medicaid managed care Attempted
  79. 467 Let states require Medicaid recipients to share costs Partially done
  80. 468 Add work requirements to Medicaid Done
  81. 468 Launch a Medicaid "personal option" for coverage outside the program Not started
  82. 468 Add time limits or lifetime caps on Medicaid benefits Not started
  83. 468 Let states buy private insurance for Medicaid families Needs Congress Not started
  84. 468 Let states redesign Medicaid benefits without waivers Not started
  85. 468 Eliminate current Medicaid waiver and state plan processes Not started
  86. 469 Rescind Section 1115 waiver requirements for climate-related benefits Partially done
  87. 469 Clarify that direct primary care fees are not insurance Done
  88. 469 Scrap the No Surprises Act dispute resolution process Needs Congress Not started
  89. 469 Permit shared savings and reference pricing plan options Partially done
  90. 469 Separate the subsidized ACA exchange market from the non-subsidized market Not started
  91. 470 Add quality measures to hospital price transparency rules Not started
  92. 470 Codify expansion of association health plans, short-term plans, and HRAs Needs Congress Attempted
  93. 470 Expand access to health savings accounts Partially done
  94. 470 Revise CLIA scope-of-practice rules for clinical laboratories Attempted
  95. 470 Create CLIA-equivalent certification pathways for non-clinical labs Not started
  96. 471 Withdraw the Medicaid abortion travel guidance and Section 1115 waivers Partially done
  97. 472 Issue guidance that states may defund Planned Parenthood in Medicaid Partially done
  98. 472 Propose a rule disqualifying elective abortion providers from Medicaid Not started
  99. 472 Pass the Protecting Life and Taxpayers Act Needs Congress Not started
  100. 472 Approve Section 1115 waivers excluding abortion providers from Medicaid Not started
  101. 472 Withdraw Medicaid funds from states that mandate abortion insurance Not started
  102. 473 Reinstate the Trump ACA abortion separate payment regulation Not started
  103. 473 Audit HHS compliance with the Hyde Amendment Not started
  104. 474 Rescind the EMTALA abortion guidance Partially done
  105. 474 Withdraw DOJ EMTALA enforcement lawsuits against pro-life states Done
  106. 474 Repromulgate the national coverage determination on gender reassignment surgery Not started
  107. 474 Use EMTALA and Section 504 to investigate born-alive infant cases Not started
  108. 474 Revive the Trump rule on treatment of infants born alive Not started
  109. 474 Pass the Born-Alive Abortion Survivors Protection Act Needs Congress Attempted
  110. 474 Permanently codify the Hyde and Weldon amendments Needs Congress Not started
  111. 475 Reverse the redefinition of sex across HHS and CMS programs Partially done
  112. 475 Keep lactation room requirements in Section 1557 rulemaking Not started
  113. 475 Announce nonenforcement of the CMS COVID-19 vaccine mandate Not started
  114. 475 Refrain from COVID-19 mask mandates on health care facilities Done
  115. 476 Pay damages to workers fired under the CMS vaccine mandate Not started
  116. 476 Apply TANF work requirements to noncash benefits Not started
  117. 476 Require states to track and audit TANF spending outcomes Not started
  118. 476 Require explicit measurement of TANF marriage and family formation goals Not started
  119. 477 Bar TPP and PREP subgrantees from promoting abortion Not started
  120. 477 Give Sexual Risk Avoidance programs equal grant funding Not started
  121. 477 Abolish approved sex education curriculum lists Partially done
  122. 477 Create criteria for evaluating sex education curricula Partially done
  123. 477 Repeal the 2016 SOGI nondiscrimination condition on HHS grants Not started
  124. 478 Restore religious waivers of HHS grant conditions for faith-based agencies Attempted
  125. 478 Pass the Child Welfare Provider Inclusion Act Needs Congress Attempted
  126. 478 Withdraw the ORR policy allowing elective abortions in custody Attempted
  127. 479 Create a child support tax credit for nonresident parents Needs Congress Not started
  128. 479 Induce states to adopt a child support payment smartphone app Not started
  129. 480 Use HMRE funds for high school marriage and risk avoidance curricula Not started
  130. 480 Let child welfare funding pay for marriage and relationship education Needs Congress Not started
  131. 480 Require Title X clinics to provide marriage information and referrals Not started
  132. 480 Give HMRE programs a fair and realistic assessment Partially done
  133. 481 Open HMRE grants to faith-based groups defining marriage as one man and one woman Not started
  134. 481 Launch a national pro-fatherhood messaging campaign with HMRF funds Not started
  135. 481 Prioritize faith-based programs in HMRF grant allocations Not started
  136. 482 Fund father-involvement programs and speed termination of parental rights Attempted
  137. 482 Eliminate the Head Start program and the Office of Head Start Needs Congress Not started
  138. 482 Rescind Head Start COVID-19 vaccine and mask requirements Not started
  139. 482 Ensure ACL programs do not facilitate physician-assisted suicide Not started
  140. 483 Rewrite the National Strategy to Support Family Caregivers Not started
  141. 483 Let CMS use HRSA's 340B data instead of its own survey Needs Congress Not started
  142. 483 Define the telehealth locus of service as the provider's location Needs Congress Not started
  143. 483 Restore Trump religious and moral exemptions to the contraceptive mandate Not started
  144. 484 Require HRSA to set women's preventive services mandates by rulemaking Not started
  145. 484 Rescind HRSA's ACOG contracts and appoint a new advisory committee Not started
  146. 485 Require coverage of fertility awareness–based methods and supplies Not started
  147. 485 Remove male condoms from the women's preventive services mandate Not started
  148. 485 Remove Ella from the contraceptive mandate Not started
  149. 485 Withdraw Ryan White guidance funding gender transition procedures Attempted
  150. 485 Ensure medical and doula training is not used for abortion training Not started
  151. 486 Investigate medical school compliance with the Coats–Snowe Amendment Not started
  152. 486 Ensure ACGME complies with conscience statutes Not started
  153. 486 Make abortion training opt-in for medical students Not started
  154. 486 Require states receiving HHS funds to enforce Coats–Snowe Not started
  155. 486 Fund home-based childcare rather than universal day care Not started
  156. 486 Provide HRSA resources on the mother–child relationship Not started
  157. 487 Fund doula services for low-income mothers Not started
  158. 487 Expand private care options for Indian Health Service patients Not started
  159. 488 Increase rural telehealth access and interstate licensure Partially done
  160. 488 Limit HHS public health emergency declarations to a set time frame Needs Congress Not started
  161. 488 Reinstate and codify the HHS SUNSET rule Needs Congress Not started
  162. 488 Investigate HHS collusion with Big Tech to censor COVID dissent Partially done
  163. 489 Eliminate the HHS Reproductive Healthcare Access Task Force Partially done
  164. 489 Restore the HHS mission statement "from conception to natural death" Not started
  165. 489 Create a Special Representative for Domestic Women's Health Not started
  166. 490 Restructure the U.S. Public Health Service Commissioned Corps Needs Congress Not started
  167. 490 Merge the Assistant Secretary for Health and Surgeon General positions Needs Congress Not started
  168. 490 Convert the Principal Deputy ASH into a three-star Deputy Surgeon General Not started
  169. 491 Withdraw OASH support for cross-sex medical interventions Partially done
  170. 491 Appoint a Deputy Assistant Secretary for Population Affairs to refocus Title X Not started
  171. 491 End religious discrimination in Title X grant selections Attempted
  172. 491 Rescind the Biden Title X rule and reinstate the Trump Title X rule Attempted
  173. 491 Pass the Title X Abortion Provider Prohibition Act Needs Congress Not started
  174. 491 Review the ASPR–FEMA emergency response arrangement Not started
  175. 492 Invoke the Defense Production Act only in the gravest circumstances Not started
  176. 492 Reform the Strategic National Stockpile as supplier of last resort Not started
  177. 492 Rescind the OGC PREP Act liability memo Not started
  178. 492 Restore OCR authority over conscience and religious freedom enforcement Partially done
  179. 492 Repeal DOJ OLC memos allowing abortion funding despite Hyde Partially done
  180. 492 Rescind the legal analysis authorizing the COVID eviction moratorium Not started
  181. 492 Rescind the OGC analysis of the Bowen v. AHA injunction Not started
  182. 493 Rescind the analysis dismissing the University of Vermont Medical Center case Done
  183. 493 Rescind the analysis restoring $200 million in Medicaid funds to California Done
  184. 493 Retitle the Director of the Office of Global Affairs as Assistant Secretary Not started
  185. 493 Give OGA oversight of Mexico City policy implementation Not started
  186. 493 Co-locate all OGA staff in one building Not started
  187. 493 Train and replace health attachés who oppose Administration policy Not started
  188. 494 Pass the Conscience Protection Act Needs Congress Not started
  189. 494 Restore and fully fund the Conscience and Religious Freedom Division Done
  190. 494 Withdraw funding from entities that violate conscience laws Partially done
  191. 494 Issue and finalize the draft OCR RFRA and religious freedom rule Attempted
  192. 494 Reestablish religious exemption waivers for child welfare agencies Partially done
  193. 495 Restore OCR authority over RFRA vaccine accommodation requests Partially done
  194. 495 Restore the Trump-era Section 1557 and Section 504 OCR regulations Partially done
  195. 495 Remove Biden guidance on gender identity under Section 1557 Done
  196. 495 Announce nonenforcement of SOGI discrimination bans under Section 1557 Not started
  197. 496 Refocus Section 1557 enforcement on race, sex, and disability discrimination Not started
  198. 496 Finalize Trump-era disability rules on QALYs and assisted suicide Not started
  199. 496 Withdraw the OCR pharmacy abortion mandate guidance Done
  200. 497 Withdraw the OCR HIPAA abortion privacy guidance Not started

Also cited in this chapter

Recommendations whose home is another chapter but which this chapter repeats.

  1. Amend the TVPRA to move custody of unaccompanied alien children from HHS to DHS Needs Congress Not started
  2. Move the Office of Refugee Resettlement from HHS to DHS Needs Congress Not started