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

14. Department of Health and Human Services · Minor

Impose a 15-year cooling-off period on federal drug regulators

Not started

452 14. Department of Health and Human Services

“We must shut and lock the revolving door between government and Big Pharma. Regulators should have a long “cooling off period” on their contracts (15 years would not be too long) that prevents them from working for companies they have regulated.”

What has happened

  1. Not started

    The administration moved the other way on day one. EO 14148 §2 revoked EO 13989 of 2021 (Ethics Commitments by Executive Branch Personnel), whose signed pledge bound every appointee to post-employment restrictions beyond the statutory minimum: two years of the 18 U.S.C. 207(c) communication ban rather than one (pledge ¶4), a further year of not materially assisting others' lobbying (¶5), and a bar on lobbying covered officials for the remainder of the administration or two years, whichever was longer (¶6). Nothing replaced it — a full-text Federal Register search for "ethics pledge" since 2025-01-20 returns zero documents, and the only in-window document naming "Ethics Commitments by Executive Branch Personnel" is the revocation itself. Federal drug reviewers are therefore back to the government-wide statutory floor in 18 U.S.C. 207 — a lifetime bar on the particular matters they handled personally, two years on matters under their official responsibility, one year for senior employees — nothing approaching fifteen years, and nothing specific to drug regulators. The three cooling-off bills of the 119th Congress (H.R. 510, the Regulatory Cooling Off Act; H.R. 3554 / S. 1850, the Close the Revolving Door Act; H.R. 3582, on Foreign Military Sales) are about regulators generally, financial regulators and arms sales, and all sit in committee.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • A trap in the Federal Register text. The govinfo HTML of the Federal Register text of EO 14148 (https://www.govinfo.gov/content/pkg/FR-2025-01-28/html/2025-01901.htm) contains the order’s sections but not §2’s list of revoked orders — the list was published as a graphic, so a search of that page for “13989” or “Executive Order” finds nothing and reads as a negative. The whitehouse.gov version of the same order carries the list in text and names “Executive Order 13989 of January 20, 2021 (Ethics Commitments by Executive Branch Personnel)”. Both URLs are kept as Evidence for that reason.
  • EO 13989’s pledge was read in full at https://www.govinfo.gov/content/pkg/FR-2021-01-25/html/2021-01762.htm. It pre-dates the evidence window, so it is context rather than Evidence; what is in the window is its revocation.
  • The near-identical FDA-specific ask at p. 460 is #1241 (Impose a lengthy cooling-off period on FDA reviewers), also not started, but without the EO 14148 revocation attached.
  • One search covered all the asks on pp. 452–453 together.
Action
restrict
Object
cooling off period for federal drug regulators
ID
1203