Trump Administration Executive Actions

Shortly after taking office in his second term, President Donald Trump and his administration issued executive actions related to federal grant funding, immigration, health care, student financial aid, diversity, equity, and inclusion (DEI), global health, and other areas. The actions listed below are among the most likely to impact academic medicine.

Federal Research Grants and Other Funding

On Jan. 27, the White House Office of Management and Budget (OMB) issued a memo (PDF) directing all federal agencies “to the extent permissible under applicable law ” to “temporarily pause all activities related to obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated by the executive orders [issued recently by President Trump].” Some further details and actions related to this memo:

• In a Jan. 28 guidance document (PDF), the OMB clarified that the pause and review process will not apply to any program that “provides direct benefits to Americans,” including mandatory programs like Medicaid and the Supplemental Nutrition Assistance Program.
• Also on Jan. 28, the Federal Student Aid Office of the Department of Education published an electronic announcement clarifying that the temporary pause does not impact Higher Education Act Title IV student aid funds provided to individual students.
• On Jan. 29, the OMB issued a memo (PDF) rescinding the memo from two days earlier.

Immigration

• The Trump administration’s executive order Protecting the American People Against Invasion is designed to expand immigration enforcement. (Issued Jan. 20.)
• The Trump administration issued a rescission of a Biden administration memorandum that had previously restricted immigration enforcement actions in or near “protected areas (PDF),” including medical and mental health facilities, such as hospitals, doctor’s offices, clinics, vaccination sites, and other locations. (Issued Jan. 21.)

Health Care

The Trump administration on Jan. 20 rescinded several Biden administration executive orders, including those that:

• Established a special enrollment period for uninsured Americans seeking coverage through the federal Marketplace exchanges and directed federal agencies to review existing policies, regulations, and other agency actions to “make high-quality healthcare accessible and affordable for every American.”
• Directed the Treasury Department and the IRS to address the so-called family glitch, expanding the availability of premium tax credits to families who are unable to afford their employer-sponsored insurance.
• Directed the Centers for Medicare & Medicaid Innovation Center to develop new payment and delivery models designed to lower drug costs and promote access to innovative, high-cost drug therapies for Medicare and Medicaid enrollees.

On Feb. 13, the Trump administration issued the executive order Establishing the President’s Make America Health Again Commission. The order tasks the commission (chaired by the Secretary of Health and Human Services Robert F. Kennedy Jr.) to investigate and address the root causes of America’s escalating health crisis, with a focus on childhood chronic disease.

On Feb. 25, the Trump administration issued the executive order Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information. Building on Executive Order 13877 (Improving Price and Quality Transparency in American Healthcare To Put Patients First) of June 2019, the order directs the Secretary of the Treasury, the Secretary of Labor, and the Secretary of Health and Human Services to enforce health care price transparency regulations such as requiring the disclosure of actual prices of items and services (not estimates), issue update guidance ensuring pricing information is standardized, and issue guidance or proposed regulatory action updating enforcement policies that ensure compliance with the reporting of complete, accurate, and meaningful data.

On March 3, the Department of Health and Human Services rescinded the long-established Richardson Waiver which invited public participation in decisions related to “agency management or personnel or to public property, loans, grants, benefits, or contracts.”

Diversity, Equity, and Inclusion

• The Trump administration issued the executive order Ending Illegal Discrimination and Restoring Merit-based Opportunity which directed the attorney general and secretary of education to issue joint guidance within 120 days to state and local educational agencies and higher education institutions receiving federal funds regarding measures and practices required to comply with the Students for Fair Admissions v. Harvard Supreme Court decision. This executive order also directed the OMB director to compile a report outlining recommendations for enforcing federal civil rights laws and encouraging the private sector to end illegal discrimination and preferences. As part of this report, federal agencies are to identify potential civil compliance investigations of entities including large nonprofit associations, state and local medical associations, and institutions of higher education with endowments over $1 billion. (Issued Jan. 25.)
• The Trump administration issued an executive order directing the OMB director to identify and terminate all DEI or DEIA mandates, policies, programs, and activities within the federal government. (Issued Jan. 20.)
• The Trump administration also issued an executive order directing federal agencies to interpret the definition of “sex” as an individual’s biological classification as “male” or “female,” defining “female” as “a person belonging, at conception, to the sex that produces the large reproductive cell” and defining “male” as “a person, belonging, at conception, to the sex that produces the small reproductive cell.” The executive order rejects the concept of “gender identity” as a “meaningful basis for identification.” (Issued Jan. 20.)

Student Financial Aid/Loan Forgiveness

On Mar. 7, the Trump administration issued the executive order Restoring Public Service Loan Forgiveness which directs the Secretary of Education to propose revisions to the Public Service Loan Forgiveness Program that ensure the definition of “public service” excludes organizations that engage in particular activities.

Global Health

The Trump administration issued an executive order providing notice that the United States intends to withdraw from the World Health Organization (WHO). This order sets a 12-month notice for the United States to leave the WHO and discontinue its financial contributions. The executive order also directs the director of the White House Office of Pandemic Preparedness and Response Policy to “review, rescind, and replace the 2024 U.S. Global Health Security Strategy as soon as practicable.” (Issued Jan. 20.)

Gender-Affirming Care for Minors

The Trump administration issued the Protecting Children from Chemical and Surgical Mutilation executive order, intended to prohibit gender-affirming care for people under the age of 19. The order directs the heads of federal agencies that provide research or education grants to “medical institutions, including medical schools and hospitals,” to take steps to ensure that “institutions receiving Federal research or education grants end the chemical and surgical mutilation of children.”

The order, among other provisions, directs:

• Federal agencies to rescind or amend polices that rely on current standards of care for providing gender-affirming care.
• The secretary of Health and Human Services (HHS) to publish reviews on best practices on improving the health of minors.
• The HHS secretary to end gender-affirming care through regulatory and subregulatory actions across a number of laws, programs, issues, or documents.
• TRICARE to amend its provider handbook to exclude gender-affirming care.
• The Department of Justice to take related actions enforcing restrictions on gender-affirming care.

Within 60 days of issuance, the order directs agency leadership with responsibilities under the order to submit a report providing an update on implementation and a timeline for future actions. (Issued Jan. 28.)

Additional Actions

• On Jan. 20, the administration issued a freeze on the hiring of federal civilian employees throughout the executive branch. Following the freeze on Jan. 23, the Department of Veterans Affairs issued a memorandum and exemptions list that included physicians and additional health professions.
• On Jan. 21, Acting HHS Secretary Dorothy Fink, MD, directed agency leaders to temporarily pause external communications and public meetings. This policy was expected to remain in effect only until Feb. 1, but although some meetings have been scheduled, most regular communications from the agency have not yet resumed.
• On Feb. 7, the NIH issued a notice seeking to implement “a standard indirect rate of 15% across all NIH grants for indirect costs [also known as facilities and administrative (F&A) reimbursements] in lieu of a separately negotiated rate for indirect costs in every grant.” The AAMC led the filing of a lawsuit with four other organizations arguing that the Feb. 7 notice from the NIH was illegal and would result in irreparable harm if it went into effect. On Feb. 10, a federal judge in the U.S. District Court for the District of Massachusetts granted the AAMC’s motion and issued a nationwide temporary restraining order.
• On Feb. 14, the Department of Education Office for Civil Rights, in guidance issued through a Dear Colleague letter, warned that educational institutions who fail to comply with federal civil rights law may lose federal funding. The letter signaled its intent to enforce an expanded interpretation of the Supreme Court’s 2023 decision in Students for Fair Admissions v. Harvard, stating that SFFA’s legal framework should apply to the use of race in decisions pertaining to admissions, hiring, promotion, compensation, financial aid, scholarships, prizes, administrative support, discipline, housing, graduation ceremonies and “all other aspects of student, academic, and campus life.”
• On Feb. 26, the Trump administration issued the executive order Implementing the President’s “Department of Government Efficiency” Cost Efficiency Initiative. This order aims to transform Federal spending on contracts, grants and loans by requiring each agency to review existing contracts and grants, build a centralized technological system to record each payment by the agency with written justification for each payment, restrict non-essential travel for federal employees, and require each Agency Head to “in consultation with the agency’s DOGE Team Lead, issue guidance on signing new contracts or modifying existing contracts to promote Government efficiency and the policies of my Administration.”