Executive Action Watch

Julio 21 — The Centers for Medicare & Medicaid Services (CMS) released a proposed rule on health care-related provider taxes that, if finalized, will increase state budget hardships, restrict states’ ability to respond to rising costs and economic crises, and put enrollees’ coverage and access in greater jeopardy. Consistent with a recent pattern of Administration actions, the CMS rule codifies the 2025 Republican reconciliation law’s restrictions on Medicaid provider taxes while also going beyond the provisions of the statute, deepening its harms. Comments on the rule are due by September 21.

The harmful 2025 Republican reconciliation law severely limits states’ use of provider taxes, which nearly every state has used to help fund its portion of Medicaid spending. Provider taxes support state efforts to expand eligibility and increase provider payment rates to address access to care challenges. The reconciliation law prohibits states from enacting any new provider taxes (or increasing existing taxes).

For Medicaid expansion states, the 2025 law changed long-standing federal rules guiding states’ use of provider taxes by reducing the so-called “hold harmless” threshold. This threshold ensures providers do not receive tax payments back from Medicaid reimbursements or other sources, whether directly or indirectly. Currently, the threshold is 6 percent, meaning providers can receive Medicaid reimbursements up to 6 percent more than what they paid in taxes before a state is penalized and has to return federal Medicaid funding. But the rule would phase down the threshold to 3.5 percent between 2028 and 2032 only in expansion states. That means fewer revenues for these states to fund their Medicaid programs.

The CMS rule codifies the 2025 laws’ restrictions and goes beyond its provisions, expanding the new provider tax requirements to other health-care related entities, like non-Medicaid health insurers. If finalized, this change will further limit state options to raise revenue for health care-related policies, increasing the budget pressures states are already facing. The rule also requires states to use a new methodology to calculate and ensure a tax’s compliance with the “hold harmless” threshold. This will not only add more burdensome and frequent reporting requirements but may also increase the likelihood of a tax being determined non-compliant. Taken together, these proposed changes and enhanced threats to states’ federal funding may lead states to reduce provider taxes beyond what is required by the law to mitigate their risk of exceeding the threshold.

Similar to the rule on state directed payments, the proposed rule is expected to deepen the harm already caused by the 2025 law — cutting federal Medicaid spending by over $245 billion over the next decade. This is likely an underestimate since CMS’s analysis excludes the impact on state budgets from extending the restrictions to new taxes. (CBO projected the provisions would decrease federal funding by $191 billion and result in 1.1 million people becoming uninsured.) As states reckon with fewer federal dollars and providers see billions less in Medicaid payments, enrollees’ access care will likely diminish.

Junio 11 — The Centers for Medicare & Medicaid Services (CMS) released guidance for states on the new budget neutrality framework for section 1115 demonstrations, as required by the 2025 Republican megabill (H.R. 1). The framework, which CMS plans to propose in upcoming rulemaking, will increase administrative burden for states, stifle innovation, and likely limit states’ ability to implement or continue certain policies. CMS’s letter explicitly notes that it anticipates the policy will reduce federal spending on section 1115 demonstrations, putting funding for coverage and benefit expansions and service delivery innovations at risk.

CMS has had a long-standing but informal policy requiring demonstrations to be budget neutral — resulting in no additional federal spending beyond what would occur absent the demonstration. H.R. 1 has now codified this policy and added a requirement for CMS’s Chief Actuary to certify that any new demonstration, amendment, or renewal is expected to be budget neutral beginning January 1, 2027.

States will now have to rigorously analyze the projected direct and indirect costs of expenditures for populations or services only permitted through 1115 authority, including costs that were previously excluded from calculations, such as the administrative costs of implementing a policy. Other longstanding policies, such as uncompensated care pools, will also be subject to the new analysis.

Additionally, CMS is changing how it treats certain services for which states previously did not have to show “savings” (the difference between projected federal cost and actual expenditures in a demonstration period.) This could affect states’ ability to continue certain policies, such as covering a subset of former foster care youth. The guidance also updates the rules CMS will use to calculate savings for use in subsequent demonstration periods.

Because many states use section 1115 demonstrations for some or most of their Medicaid programs, almost every state will be affected by these changes. Although the extent to which they are affected will differ, this will universally add to state Medicaid agencies’ workloads. For some states, the new rules may result in further cuts to federal Medicaid spending, as CMS indicates in the guidance.

Junio 11 — The U.S. Department of Housing and Urban Development (HUD) abruptly and indefinitely barred the Los Angeles Homeless Services Authority (LAHSA) from receiving additional HUD funding to address and reduce homelessness. This disruptive action threatens progress that community-based agencies across Los Angeles have made in cutting homelessness for two consecutive years, including a 14 percent reduction in unsheltered homelessness. It also puts more than 11,000 formerly homeless seniors and people with disabilities at risk of losing their homes.

LAHSA, one of the nation’s largest homelessness services agencies, coordinates over $200 million in HUD Continuum of Care (CoC) funds in the Los Angeles region for housing and services for people experiencing homelessness.

If HUD’s action withstands legal challenges, it will block LAHSA from applying for future HUD funding until HUD’s Office of Inspector General completes an investigation of LAHSA’s financial management practices, though HUD provided no detail about the supposed investigation’s scope or timeline. The action could also delay or block distribution of previously awarded funds that nonprofit agencies need to continue providing services this year and into 2027.

It is unclear whether another Los Angeles-based entity could apply for funds in LAHSA’s place, leaving homelessness service providers that rely on LAHSA’s HUD funding unsure if they will be able to continue housing thousands of formerly homeless LA residents. Many of those residents will be at imminent risk of returning to the streets and shelters if they lose their housing assistance.

HUD’s suspension of LAHSA funds is highly unusual and comes amid numerous Trump Administration actions — many of which are unlawful — to withhold federal funding from other important economic security programs and perceived political opponents, including the state of California.

Suspending LAHSA’s CoC funding could also advance the Trump Administration’s broader efforts to redirect funds away from evidence-based homelessness solutions that pair low-barrier housing with supportive services and have driven Los Angeles’ recent success in reducing homelessness. The Administration could pressure or compel communities to instead use those funds for less effective and more punitive approaches.

Mayo 20 — The Centers for Medicare & Medicaid Services (CMS) proposed a rule that would cap Medicaid payment rates across the program, going well beyond the limits required by H.R. 1, the Republican megabill enacted last summer. If finalized, the changes will reduce Medicaid enrollees’ access to care. Comments on the proposed rule are due on July 21.

The rule applies to state directed payments (SDPs), which states use to direct Medicaid managed care organizations to pay specific providers to drive access and quality. H.R. 1 created a new limit on SDPs in four service areas (inpatient, outpatient, nursing facility, and qualified practitioners in academic setting), capping rates at 100 percent of Medicare rates in Medicaid expansion states and at 110 percent of Medicare rates in non-expansion states. H.R. 1 permitted some SDPs approved at higher rates to remain in place during a transition period.

The new rule, building on a CMS letter to states from earlier this year, proposes regulatory changes to codify these limits and details how states will be expected to phase down existing SDPs that exceed allowable limits, beginning with managed care rating periods that start on or after January 1, 2028.

But CMS is proposing changes that go significantly beyond H.R. 1, including by:

1. extending payment limits to all services covered under SDPs, not just those specified in H.R. 1, for managed care rating periods beginning on or after January 1, 2029;
2. eliminating one of the methodologies states currently use to authorize SDP rate increases, for rating periods beginning on or after January 1, 2028;
3. extending SDP limits to U.S. territories starting in January 2029; and
4. imposing the same new payment limits on certain Medicaid fee-for-service payments, also starting in January 2029.

As in H.R. 1, the proposed changes to both managed care and fee-for-service rates impose lower payment limits on expansion states than non-expansion states.

Taken together, these changes will lower payments to providers and reduce access to services for Medicaid enrollees. CMS doesn’t acknowledge that impact in its press release and fact sheet.

CMS estimates that the rule will cut federal Medicaid funding to states by $510 billion over the next ten years. The Congressional Budget Office estimated that the SDP provisions in H.R. 1 would cut $149 billion in federal Medicaid funding over ten years; the rule goes well beyond that, which will add to the losses in coverage and access due to H.R. 1’s cuts of more than $900 billion to Medicaid.

Mayo 15 — The Centers for Medicare & Medicaid Services finalized rule changes that will expose people to very high out-of-pocket health care costs while doing little to improve the affordability or value of coverage. The new rule is expected to reduce marketplace enrollment by up to two million people in 2027 alone, and by as much as 5.2 million people between 2027 and 2030.

The rule relaxes regulations for bronze and catastrophic plans, which have lower premiums than other marketplace plans but much higher deductibles and out-of-pocket maximums. Under the new rule, insurers can increase the out-of-pocket maximums for these plans beyond the statutory limit. After congressional Republicans failed to extend premium tax credit enhancements at the end of 2025, generous plans with higher premiums became unaffordable for many people, driving them to enroll in bronze plans for 2026. Starting in 2027, the new rule changes will expose people in these plans to higher costs than they would have faced otherwise.

The rule also advances new plan designs that will make choosing and using health insurance more confusing and put enrollees at greater risk of facing higher medical costs. For example, insurers will be allowed to offer plans in the Affordable Care Act marketplace without a provider network, if permitted by state insurance law. These plans set specific dollar amounts for covered services but do not have a network of providers that have agreed to accept these rates. Instead, enrollees are responsible for negotiating payment rates with providers and risk having to pay the difference out of pocket if their provider won’t accept the plan’s rate.

In addition, the rule reintroduces changes from a 2025 marketplace rule that are currently stayed by a federal court. These provisions would impose multiple new documentation barriers, making it harder for eligible people to enroll in and maintain marketplace coverage.

Mayo 13 — Since the beginning of the year, the Centers for Medicare & Medicaid Services (CMS) has been threatening Medicaid funding and initiating other actions that add burdens to states. In particular, CMS has focused on home and community-based services (HCBS) that help elderly and disabled people live in the community rather than institutions. CMS’s actions risk reducing health care access for millions of people for whom Medicaid is a lifeline, both by cutting Medicaid and by making it harder to access honest providers.

Now, the Administration has escalated and expanded these counter-productive actions to all states:

• In letters sent to all state Attorneys General, the Administration announced it would be auditing state Medicaid Fraud Control Units (MFCUs), threatening a range of actions, including withholding federal Medicaid funding if the review determines the state’s MFCU is not “effectively fulfilling” statutory requirements.
• CMS also announced it would be suspending new Medicare enrollment for certain home health and hospice providers for the next six months. CMS indicated states should consider applying a moratorium to these providers in Medicaid and CHIP as well. (One state has already done so.)
• Last month, CMS directed all states to revalidate Medicaid providers within the next two years.

Factual instances of fraud should be addressed. But in reality, all these actions will do is jeopardize necessary care for those whose coverage comes from the program, and they risk upending the longstanding state-federal partnership to promote program integrity. On top of that, these actions add administrative burdens as states work to implement many complex requirements of H.R. 1.

Additionally, the Administration continues to target Medicaid funding in several Democratic-led states, which will harm enrollees. Notably:

• The Administration announced it would withhold $1.3 billion in federal Medicaid dollars from California as CMS reviews service claims largely for home care services. This deferral, the largest in the Medicaid program’s history, primarily affects the state’s In-Home Supportive Services program, which the state notes has grown due to intentional policy choices to improve access to the services.
• CMS deferred another $91 million in federal Medicaid funding from Minnesota for claims related to certain HCBS, adding to the over $250 million in deferred payments CMS is already reviewing.
• The Administration indicated plans to turn its efforts to Maine next but has made no formal announcement about actions against the state.

Marzo 16 — A Colorado judge has issued a written order formally blocking the Department of Agriculture from imposing a harmful SNAP “pilot project” on the state, following a similar order in Minnesota. USDA had directed these states to immediately recertify the eligibility of all SNAP households in certain counties — in violation of legal requirements for timely, accurate, and fair service — or otherwise face withheld funding and threats to their “continued participation in SNAP.”

As the Colorado judge observed, arbitrarily shortening certification periods for hundreds of thousands of households and forcing them to immediately re-verify their eligibility isn’t just logistically infeasible, it “promises to generate confusion, disruption, and erroneous terminations,” putting eligible low-income families at risk of losing food assistance.

USDA made its demands based on vague claims of SNAP misspending that the courts found it could not substantiate. As the Minnesota judge noted, “the USDA evidently believes that it may make sweeping, nonspecific, and unsupported accusations of ‘fraud, waste, and abuse’ and threaten to withhold administrative funding from Minnesota when, if anything, the evidence before this Court – including from the USDA itself – undermines those allegations.” (Emphasis in original.)

SNAP households already must recertify their eligibility periodically, typically every six or 12 months. Federal law and regulations set guardrails for this process, such as requiring adequate notice before households must renew their eligibility and prohibiting early termination of a household’s certification period unless there is evidence that they are no longer eligible.

Because USDA’s demands would have forced the states to violate these federal safeguards, USDA presented them as a “pilot,” citing a provision of SNAP law that allows USDA to waive certain statutory requirements to test program improvements — but only in limited circumstances and upon request by a state. This mandatory “pilot” represented an unprecedented and unlawful attempt to unilaterally ignore SNAP’s statutory protections and force states to accept those harmful new terms as a condition of continued funding.

And it did so in service to the Trump Administration’s continued use of unsubstantiated fraud claims as a pretext to block vital assistance for basic needs to residents of politically disfavored states.

Marzo 6 — The Centers for Medicare & Medicaid Services (CMS) released guidance instructing states how to implement the harmful Republican megabill’s (HR 1) requirement that they renew Medicaid eligibility for the “expansion” population twice as often — every six months instead of 12.

No matter what, requiring more frequent renewals will cause coverage losses among eligible people. Helpfully, the guidance says the new requirement applies to renewals initiated in 2027. States typically initiate an enrollee’s renewal (by starting the ex parte process) three months before their eligibility period ends, which can occur in any month.

But the first of two options CMS gave states for transitioning current enrollees to the new timeframe would cause significant confusion and accelerate coverage losses among eligible people. It lets states move up people’s renewals and initiate them for nearly two-thirds of the state’s expansion caseload, all in January. This concentration would overwhelm eligibility workers and lead to people losing coverage, even among those completing the required steps. States would at the same time be newly applying the Medicaid work requirement to the same large concentration of people, adding to the confusion, questions, and strain to an untested eligibility system, and leading to large coverage losses as soon as March or April 2027.

The second option CMS gave states is to transition to six-month renewals more gradually. Here, states would apply a six-month eligibility period at individuals’ next regularly scheduled renewal, beginning with those initiated in January 2027. This option would mitigate unnecessary coverage loss by giving a state fewer renewals it must do in 2027 as it implements major system changes, spreading the work out more evenly over the year, and allowing it to troubleshoot issues as they arise.

The guidance also provides important clarifications about the six-month renewal requirement, including that HR 1 neither requires nor allows states to apply the six-month renewal requirement to groups other than the expansion population (as we have seen some state legislation propose).

Febrero 20 — The Department of Housing and Urban Development (HUD) published a proposed rule that would force 20,000 families to choose between losing the assistance that helps them pay rent or separating their family. The rule would prohibit citizens and eligible immigrants in “mixed-status” families from receiving any rental assistance if a member of their household is ineligible because of their immigration status. 

For decades, these families received assistance prorated to only cover eligible family members. For example, if one parent in a family of three has Temporary Protected Status, and is therefore ineligible for rental assistance, the family would receive two-thirds of the full assistance amount. 

Of the nearly 80,000 people in mixed-status families, about 37,000 are children and 2 out of 3 are U.S. citizens. People without documented immigration status and with certain categories of legal immigration status have always been ineligible for rental assistance. This proposal puts entire families, including eligible citizens and immigrants, at risk of eviction and homelessness. 

The proposal also adds red tape for everyone receiving or applying for rental assistance and for the housing agencies and owners administering these programs. The rule would require agencies and owners to verify citizenship and eligible immigration status using the Systematic Alien Verification of Entitlements (SAVE) tool, an online Department of Homeland Security (DHS) service used to check immigration-related eligibility for federal public benefits.  

However, among other legal and privacy concerns, the SAVE process has inherent limitations that result in certain groups not being able to have their status immediately verified. Individuals who cannot have their citizenship verified through SAVE will have to submit additional documentation, such as birth certificates and passports, which many people may not readily have or struggle to obtain.

Our paper includes additional analysis and state-level data. The rule is open for public comment through April 21.

Febrero 13 — The White House ordered the Centers for Disease Control and Prevention (CDC) to cancel more than $600 million in grants to California, Colorado, Minnesota, and Illinois — four states that did not support President Trump in the 2024 general election and are led by Democratic governors. The terminated grants had been provided to state and local health agencies, universities, health centers, and nonprofit organizations providing public health services. In response to a lawsuit from the four states, a judge has already temporarily paused the Administration’s attempted terminations of these grants. It is clear this is another example of the continuing escalation of the Administration’s illegal weaponization of federal funding.

In January, the Trump Administration had separately attempted to block federal funds for child care and other social services from going to these four states plus New York. This action was based on nothing more than the Department of Health and Human Services’ (HHS) undefined and unsubstantiated suspicion of fraud and was also blocked in federal court by a lawsuit.

With regard to cancelling the CDC grants, the Administration has failed to provide a consistent explanation for why these four states were again being singled out and targeted by the federal government. Although an Office of Management and Budget spokesperson told the New York Post it was for unsubstantiated and undefined “waste and mismanagement,” HHS informed Congress that the grants were being cancelled because they were “inconsistent with agency priorities.” Neither explanation provides justification for why only projects in these four states were targeted for termination when similar projects in other states were not.

For more on the Administration’s increasingly blatant efforts to misuse federal funds to coerce and punish residents of states President Trump considers to be political enemies or which disagree with the President’s preferred policies, see our January 27 blog post.

Febrero 9 — Department of Government Efficiency (DOGE) officials at the Social Security Administration (SSA) entered a secret data sharing agreement with a partisan advocacy group that aimed to "find evidence of voter fraud and to overturn election results in certain states," according to a court filing by the Justice Department on January 16. The agreement was signed March 24, 2025 — after a judge had already prohibited DOGE from accessing data at the agency. It was not reviewed or approved by SSA officials, who would normally oversee such agreements. Ten months after the agreement was signed, the Trump Administration told the court that it is still not able to determine what data DOGE may have shared with this election denier group.

During the same month they entered into the previously undisclosed agreement with the election denier group, DOGE officials spread falsehoods about Social Security and elections and sought access to state voter files. For example, Elon Musk and Antonio Gracias, a DOGE operative at SSA, appeared at a political rally in Wisconsin alleging they’d discovered noncitizens on state voter rolls using SSA data — a claim that was debunked at the time. At the same time, another SSA DOGE operative, Aram Moghaddassi, who later became the agency’s Chief Information Officer, contacted state election officials to request their voter registration data.

Then in May 2025, the Trump Administration secretly — and likely illegally — began using SSA data in an attempt to verify voters’ citizenship in dozens of states, despite clear limitations on using Social Security data in this manner.

These revelations raise significant concerns about the Administration misusing Social Security data in ways that could disenfranchise legitimate voters ahead of the midterm election — particularly as the Administration has demanded voter records from Minnesota and seized 2020 ballots in Georgia. Further, the President has said he wants to “take over” the administration of elections from the states, contrary to the Elections Clause of the Constitution.

Febrero 9 — A new proposed rule from the Centers for Medicare and Medicaid Services (CMS) to make broad changes to the Affordable Care Act (ACA) marketplaces would reduce marketplace enrollment by two million people in 2027 alone. These proposed changes come on the heels of an open enrollment season in which marketplace enrollment declined by more than a million people — a result of congressional Republicans’ refusal to extend expiring premium tax credit enhancements.

Several changes in the proposed rule would let insurers offer coverage that is less comprehensive than what is currently allowed on the ACA marketplaces, making shopping for health coverage more complicated and exposing people to higher medical costs.

One provision would expand eligibility and relax regulations for catastrophic plans, which do not cover any benefits (aside from preventive care and three primary care visits) until a person reaches the annual maximum out-of-pocket limit. In 2027, that is $12,000 for an individual or $24,000 for a family. The proposal would allow certain plans to exceed even these high maximum out-of-pocket limits.

The proposed rule seeks to reverse a number of Biden-era regulations aimed at simplifying plan selection and expanding coverage of adult dental services. It implements provisions of the harmful Republican megabill that will take away marketplace coverage from around 1.23 million lawfully present immigrants.

The proposed rule also constrains state regulatory authority by requiring states to defray the cost of any state-mandated Essential Health Benefit issued after 2011 and extending the prohibition on creating income-based Special Enrollment Periods. In addition, the proposal reintroduces provisions from a 2025 marketplace rule that are currently stayed by a federal court; these provisions would impose multiple new documentation barriers that would make it harder for eligible people to enroll in and maintain marketplace coverage.

Enero 12 — Despite its core mission to protect human health and the environment, the U.S. Environmental Protection Agency (EPA) indicated that it would no longer take into account the health benefits of reduced air pollution in its cost-benefit analyses for clean air regulations.

An EPA analysis accompanying a final rule that weakens limits on emissions of gas-burning power plants states that the agency will no longer calculate the dollar value of health benefits from reducing fine particulate air pollution (PM2.5) and ozone pollution. Significant research, including research by the EPA, has linked these pollutants to increased respiratory issues, worsening heart conditions, and other risks to people's health. Experts are concerned this change could make rolling back other air pollution regulations easier.

This shift is a particularly glaring example of changes agencies are making in their cost-benefit analysis that undermine health, safety, and well-being under the Trump Administration. For example, in May 2025, President Trump directed federal agencies to stop including the cost of climate damages from greenhouse gas emissions in their regulations and permitting decisions. In April 2025, FEMA changed how it calculates the cost-effectiveness of projects requesting access to Hazard Mitigation Assistance funding. This change reduces the value of future benefits in a cost-benefit analysis, meaning projects with benefits that materialize further in the future — as is the case for hazard mitigation projects that build resilience to climate impacts — are now less likely to be approved for the funding.

The Trump Administration has touted its success at rolling back important health and safety regulations. These attacks on how agencies conduct their cost-benefit analysis, a primary tool for developing and assessing regulations, make it easier for the Administration to hide harm being done, overturn protections, and limit investments that support the environment and people’s health and well-being. Communities of color and communities with low income or low wealth are more exposed to higher levels of air pollution and other climate risks. Ignoring the human cost of climate change does not make it go away; it just makes it harder to address these disparities.

Diciembre 30 — The Department of Energy issued an order requiring a coal plant in northwest Colorado to stay open past its planned retirement date on December 31, 2025. The order for the Craig Station plant joins those issued for two coal plants in Michigan, a combined oil and gas plant in Pennsylvania in May, and three coal plants in Indiana and Washington earlier in December that were also nearing their planned retirement dates. Each of the orders is valid for 90 days; the Michigan and Pennsylvania orders have been renewed three times.

Each of the seven plants was slated to close because their respective owners and regional electric grid operators had determined that they were neither economical to run nor necessary to maintain reliability of the electric grid. It costs tens of millions of dollars to keep the plants open, $615,000 a day in one Michigan coal plant alone. These costs fall to ratepayers at a time when average U.S. electricity prices are rising faster than overall inflation for the first time in 15 years — and are expected to increase by 7.6 percent this winter.

The Trump Administration is issuing these orders under Section 202(c) of the Federal Power Act, which grants the Secretary of Energy the power to alleviate electric grid emergencies. However, in challenging both the stay-open orders and an executive order issued by the Administration in January declaring a national energy emergency, states and electric grid operators have argued that there is no emergency, calling into question the legality of the Administration’s use of those powers.

Diciembre 18 — The Department of Health and Human Services (HHS) announced a flurry of actions aimed at severely limiting access to gender-affirming care for transgender people under age 18, following explicit directives from President Trump’s executive order. The Heritage Foundation’s Project 2025 agenda also included proposals to severely limit gender-affirming care for youth.

The Centers for Medicare and Medicaid Services (CMS) released two notices of proposed rulemaking targeting the provision of gender-affirming care services for transgender youth in Medicaid and beyond. The first would prohibit federal funding for certain gender-affirming care services for transgender youth in Medicaid and the Children’s Health Insurance Program. (A similar policy was included in the House-passed version of the harmful Republican megabill. A separate, more extreme bill also passed the House recently that would make it a criminal offense to provide gender-affirming care to transgender youth.)

The second proposal would prohibit hospitals from participating in Medicare or Medicaid if they provide these services to transgender people under 18, regardless of type of insurance used to pay for care. Because Medicare and Medicaid account for almost half of hospital care spending, the financial implications would make it unlikely hospitals would forgo program participation and continue providing these services.

If these rules are finalized, states would be limited to state-only funding to cover gender-affirming care. Further, care would likely have to be provided outside of most hospital settings. These proposed rules are open for public comment until February 17, 2026; importantly, there is no change to coverage of or access to these services while the rule remains proposed.

Along with these two proposed rules, the Administration also removed federal protections for individuals with gender dysphoria and issued official agency policy refuting evidence supporting gender-affirming care for transgender youth. These moves come on top of previous rulemaking that removed gender-affirming care from the marketplace essential health benefits package.

These policies and proposals are contrary to the recommendations of major medical societies, and would undermine access to necessary services and interfere with patient-physician decision-making. Restricting coverage of gender-affirming care can result in worse health outcomes for transgender youth — including significant mental health challenges — or higher costs for families who seek to pay out of pocket for care.

Diciembre 8 — The Centers for Medicare & Medicaid Services (CMS) released its first guidance on the Republican megabill’s mandatory Medicaid work requirement for certain adults, which largely outlines the parameters affected states must adhere to when implementing the policy. Under the new law, states that cover Medicaid expansion adults or similar adults with full coverage through state waivers must begin imposing work requirements on those individuals no later than January 1, 2027.

The guidance offers few new details to help states implement the provision; more comprehensive directions will presumably come through the interim final rule that CMS must release by June 1, 2026. CMS indicated that it also expects to issue additional guidance on the use of reliable data sources to show compliance with the policy as well as on managed care plans’ role in supporting implementation.

The guidance does clarify a few issues. For example, CMS confirms that states can renew eligibility if people subject to the requirement meet it in any month during the six-month eligibility period, and that states that opt to require multiple months of compliance between their biannual renewals cannot require compliance in consecutive months. The guidance also gives slightly more insight into how CMS will weigh state requests to delay implementation, noting that decisions will be made on a case-by-case basis and that the agency is likely to approve limited exemptions only for states that experience “severe and/or unexpected issues that hinder their progress.”

States must meet a tight timeline to establish policies, build systems, and develop outreach materials for work requirements — with significant risks that people’s coverage will be taken away or denied if they cannot meet this work requirement or qualify for an exemption. State policy and implementation choices will largely determine how many people lose coverage.

The newly released guidance does little to give states all the information they need to implement on time. However, they can still begin considering opportunities to mitigate coverage losses.

Noviembre 19 — The Trump Administration has moved to rescind the Biden Administration’s public charge rule, reigniting fear and confusion among people who are immigrants and their families. The proposed rule does not replace the Biden-era regulation with new policy; instead, it indicates that new policy will be shared through guidance and other tools after the Biden-era regulation is rescinded.

Despite no immediate change in policy, many people will expect the future policy to be harsh, given the Administration’s track record of advancing harmful policies and actions against people who are immigrants and their families. As a result, eligible people will likely forgo medical care, food, and other support for themselves or their children out of fear that participating in economic and health security programs will ruin their chance of obtaining an immigration status for themselves or their family members in the future. The chilling effect of the new rule will largely impact U.S. citizens in families that include immigrants.

Under long-standing U.S. immigration law, certain individuals can be denied admission to the U.S. or permission to adjust their immigration status to lawful permanent resident (also known as a green card) if they are determined likely to become a “public charge.” For decades, this was defined as receipt of government-funded cash assistance for income maintenance or institutionalization for long-term care.

The first Trump Administration’s public charge rule radically broadened this policy to include receipt of a large array of benefits, including Medicaid, SNAP, and housing assistance, and to treat low-income as a negative factor. The effect would have been to block people without substantial wealth from obtaining a green card or other lawful status, dramatically remaking the U.S. immigration system. Even before the rule was finalized, widespread confusion about it resulted in many people eligible for benefits going without them, even if they would never be required to undergo a public charge assessment.

Several courts blocked the implementation of the first Trump public charge rule, and the Biden Administration finalized a new rule that largely restored long-standing policy that has guided public charge determinations for decades. Actions by the Trump Administration to undo this regulation will frighten eligible people from accessing benefits once again.

Noviembre 3 — Last month, the Trump Administration issued reduction in force (RIF) notices to over 1,400 Treasury employees, including IRS employees who ensure large businesses pay the taxes they legally owe, those who maintain critical technology, and those who train IRS staff members. Their positions would officially be terminated on December 9. There is no budget rationale for these politicized RIFs.

The RIFs come on top of a series of debilitating actions to the IRS taken by the Trump Administration and congressional Republicans. Staff cuts and voluntary departures through deferred resignation programs have caused one-quarter of the workforce to leave the agency since January, including 30 percent of revenue agents and long-time career staff. Through a series of funding rescissions, Congress eliminated virtually all of the remaining enforcement money that was part of the mandatory funding stream. Senate appropriators have proposed further rescissions of remaining funding supporting IRS operations, including critical technological modernization efforts.

These actions leave an already-strained agency with little capacity to fulfill its basic operations or to prepare for the 2026 filing season. The Treasury Inspector General expressed concern earlier this month that prior staff cuts threaten the IRS’s ability to adequately serve taxpayers and process tax returns in the 2026 filing season. The latest RIFs and the shutdown — which has resulted in about half of IRS staff being furloughed (as of October 8) — will likely exacerbate these impacts.

Layoffs cost the government money in the long run; less staff means that it is harder to enforce compliance and answer taxpayer questions to foster voluntary compliance. Instead of decimating the IRS, policymakers should rebuild the agency so it can perform its basic function.

Septiembre 29 — Communities across the country rely on federal homelessness Continuum of Care (CoC) grants to fund evidence-based strategies that pair rental assistance with supportive services. The grants help hundreds of thousands of formerly homeless people stay stably housed. In a nation as wealthy as ours, we should expand rental assistance and services to rehouse more people and prevent people from being forced into homelessness.

Yet, Politico reports that leaked Department of Housing and Urban Development (HUD) documents show it plans to severely cap CoC funding for permanent housing at 30 percent — a drastic shift from the current policy, under which 87 percent of CoC funds support permanent housing. HUD estimates that would strip over 170,000 formerly homeless people of their housing assistance. Those individuals and their families would be at grave risk of being forced back onto the streets, or into cars or shelters. Many of their landlords will face unpaid rent and may be deterred from renting to unhoused people or others using rental assistance again, limiting unhoused people’s options out of homelessness.

HUD would implement this funding cap as part of its plan to cancel the second half of two-year CoC grants awarded in January 2025 and require CoC grantees to reapply this fall for funds they need in 2026. If HUD releases a new funding application, it will be difficult for grantees to complete the radically different process, and some may lose funding altogether. HUD is unlikely to finish processing applications in time to release new funding before many grantees face shortfalls that will disrupt housing assistance and services.

Both the late timing and substance of the new application would cause chaos, disrupting services that help people who are unhoused survive and access housing. To avoid this, Congress should require HUD to renew existing CoC grants for next year, providing communities with continuity.

Politico also indicates the new application may penalize grantees that previously undertook efforts to advance racial equity and serve transgender and nonbinary people in accordance with their gender identity. A separate CoC funding application included similar, harmful policies, which a federal court has temporarily halted while a lawsuit challenging the funding notice moves forward.

Septiembre 23 — A new report from the Government Accountability Office (GAO) raising concerns about the cost of Georgia’s Pathways to Coverage Medicaid waiver program is a forewarning about how expensive work requirements are to administer. The Republican megabill takes Medicaid coverage away from people who can’t meet a work requirement and requires states to implement the requirements by January 1, 2027.

Georgia, which has not adopted the Affordable Care Act’s Medicaid expansion, sought a Medicaid 1115 waiver to serve a similar enrollee population and condition their enrollment on meeting a burdensome work requirement. The Pathways program requires adults with incomes below 100 percent of poverty to meet a work requirement of 80 hours a month to get and keep Medicaid coverage. GAO’s report found that $54 million in state and federal funds were spent on administrative expenses in the first four and a half years of the program. This spending far outweighed the costs of providing medical care to enrollees, which were about $26 million.

Furthermore, the administrative costs per person were higher than the state originally estimated due to low enrollment. The state estimated 25,000 people would be enrolled in the first year, but less than 3,500 people enrolled in that time. This low enrollment can be attributed to technical glitches, understaffing, and the red tape people faced when needing to show they are working or exempt before they can enroll, as the megabill also requires. Georgia’s experience underscores how work requirements keep working people and people who should be exempt from getting Medicaid coverage.

Despite these concerns with costs and enrollment, the Centers for Medicare and Medicaid Services (CMS) has allowed Georgia to extend and amend the Pathways program until the end of 2026. Although the megabill allows states to impose work requirements earlier than 2027, it requires early-adopters to design their work requirements to comply with the provisions of the law and it prohibits waivers of these new requirements.

August 29 — Last night, the Trump Administration sent Congress a second spending cuts package. But this time, the Administration clearly plans to illegally withhold the money until it expires whether Congress acts or not.

While President Trump’s Office of Management and Budget appointees have called this made-up end of fiscal year maneuver a “pocket rescission,” CBPP outlined four reasons that it is obviously illegal in a recent report:

1. The Impoundment Control Act was passed to prevent unilateral presidential impoundments, not enable them.
2. The Impoundment Control Act does not allow Presidents to delay providing funding when authorizing and appropriations statutes require that it be released.
3. The Impoundment Control Act does not allow the President to strategically time rescission proposals for the end of the fiscal year as the Trump Administration has done.
4. If allowed, “pocket rescissions” would function like a line-item veto — which the Supreme Court ruled was unconstitutional.

This is the first time that a President has sought to abuse the Impoundment Control Act to cancel funds unilaterally without congressional action.

Not only is this pocket rescission illegal, but absent action from Republicans in Congress to put a stop to illegal Trump funding freezes, it also greatly increases the likelihood of a federal government shutdown when the fiscal year ends on September 30. That’s because it will be difficult for the Senate to reach an agreement on funding for the next fiscal year when the President maintains he can unilaterally cancel any funding in the agreement later through a “pocket rescission.”

August 22 — A federal court in Maryland issued an injunction that temporarily stops seven provisions of the 2025 Marketplace Integrity and Affordability Final Rule from taking effect. The pause on implementing these provisions will remain in place as the case moves forward until a decision or appeals are made.

The court issued a stay preventing implementation of seven of the nine provisions being challenged, including some that were set to take effect on Monday, August 25 (these are marked with an asterisk):

• Requiring submission of additional paperwork to verify income before eligibility for premium tax credits (PTCs) can be determined for people for whom tax data are missing or who attest to income eligibility for PTCs but federal databases show as having incomes below 100 percent of the poverty level;*
• Allowing insurers to deny coverage to people who have unpaid past-due premiums with that insurer;*
• Charging a $5 fee to people who are automatically reenrolled in an Affordable Care Act marketplace plan with a $0 premium for 2026;
• Allowing insurers to offer plans with higher cost-sharing charges for enrollees (via lower “actuarial values”) than were permitted previously;
• Requiring applicants to provide additional verification for commonly used special enrollment periods (which are needed to enroll outside the regular annual open enrollment period); and
• Determining people ineligible for PTCs if they failed to reconcile their advanced PTCs on their federal tax returns for one year.

The injunction does not affect other provisions of the Trump Administration rule. For example, from August 25, 2025 through December 31, 2026, the rule eliminates the special enrollment period that enables people with income below 150 percent of the poverty level ($23,475 for an individual in 2025) to enroll in coverage year-round and prohibits people with DACA from enrolling in marketplace coverage or receiving PTCs.

August 19 — The Centers for Medicare and Medicaid Services (CMS) announced it has begun sending states a monthly list of Medicaid and CHIP enrollees who states will have to take steps to reconfirm meet citizenship or immigration requirements, burdening states and putting eligible people at risk of losing coverage.

Long-standing policy requires applicants to attest (under penalty of perjury) that they are U.S. citizens or have satisfactory immigration statuses to enroll. States confirm most applicants’ citizenship status using Social Security Administration (SSA) data, but some citizens must have their status checked by the Department of Homeland Security’s SAVE system. Still others must provide documents that prove their citizenship and identity (such as a birth certificate and driver's license). Though Medicaid and CHIP ban many immigrants with lawful status from coverage, some are eligible, and the SAVE system is used to verify their eligibility

Many citizens who were born abroad, such as children of military personnel, can’t have their status verified by SSA and must provide documents to prove their status. Medicaid regulations have a “once and done” policy on U.S. citizenship verification; once a person proves their citizenship, they never have to again. That’s because Medicaid has no reason to re-prove circumstances that are not likely to change, and citizenship almost never changes.

But against its own regulations, CMS will now re-check the citizenship of Medicaid enrollees, which will make states needlessly re-run processes. At best, most states will check their files, see that citizenship was already proven, and report this to CMS. At worst, a state may jump to re-verifying status, making people navigate duplicative bureaucracy.

The CMS guidance will require states report on how they reconfirm eligibility for people for whom CMS included in their monthly lists; more details about reporting requirements are forthcoming.

Julio 29 — The Environmental Protection Agency’s mission is to protect human health and the environment, yet it has released a proposed rule to rescind the 2009 Greenhouse Gas Endangerment Finding that would do the opposite.

The Endangerment Finding identifies six greenhouse gases that endanger public health and welfare. Rescinding it would undermine the federal government’s authority to regulate greenhouse gas emissions, leading to more climate and air pollution and worse health. It would be especially harmful for low-income, rural, and tribal communities and communities of color, who are more likely to live in frontline areas that experience the most immediate and severe impacts of climate change and environmental hazards.

The Endangerment Finding provides the legal basis for several critical EPA regulations under the Clean Air Act. This includes emissions standards for passenger cars and trucks, which are expected to cut billions of metric tons of greenhouse gases and reduce oil consumption over the next few years, and the methane emissions standard for the oil and gas industry, which is projected to reduce methane emissions from the oil and natural gas sector by 80 percent and prevent thousands of tons of air pollutants from being released.

Decades of research and court rulings confirm the role of greenhouse gases in causing climate change and climate change’s impact on human health and well-being. The Trump Administration’s attempt to overturn the Endangerment Finding is the latest in a series of actions putting polluting corporations ahead of people’s health and well-being. And it comes at a time when heat, droughts and floods, wildfire, and other impacts are already causing tens of thousands of deaths globally per year, and rising.

The proposed rule will be open for public comments through September 15, and EPA is planning public hearings.

Julio 26 — The Social Security Administration (SSA), the Department of Health and Human Services, and the Food and Nutrition Service issued guidance on how they will bar certain newborns from obtaining Social Security numbers, health care, food assistance, and other programs and services if President Trump’s executive order (EO) ending birthright citizenship takes effect. The EO, which would limit citizenship only to those newborns whose parents meet specific citizenship or immigration requirements, remains on hold as a result of two nationwide injunctions.

The guidance details new bureaucracy that benefit-granting agencies, providers, and individuals would have to navigate to verify parents’ citizenship or immigration status to determine if their newborns met the EO’s citizenship requirements. Newborn babies blocked from their right to citizenship would in many cases become stateless and lose eligibility for vital services including health care and food assistance.

The release of this guidance is a sobering reminder of not only the incredible harm these newborns would face, but also that if the EO were implemented, this would require all new parents in the U.S. to overcome red tape and obstacles to prove their own citizenship or immigration status in the days following the birth of their child.

The guidance documents explain when parents could use documents (such as passports, which only around 53 percent of U.S. citizens have) and/or electronic verification of status through databases run by the Department of Homeland Security or SSA. Both of these databases are used to verify status in some benefit programs today, and both have limitations that result in delays and other hurdles for some people despite being citizens or having an eligible immigration status. The SSA guidance recognizes these limitations and indicates some people may have to use in-person or phone customer service options that have been devastated by recent staff reductions.

Julio 24 — In a nation as wealthy as ours, we can solve big problems like homelessness and ensure no one is forced to sleep outside, in their car, or in a shelter. And we can do it while respecting people’s dignity and civil rights.

But a cruel new executive order — if implemented — will worsen homelessness and punish people for being priced out of housing. It will also undermine decades of bipartisan efforts to help more people with disabilities access housing and services to stay and thrive in their communities. The order does nothing to address the fact that many people’s incomes aren’t enough to pay rent and consistently meet other basic needs. To date, the Trump Administration has worsened the problem, including by slashing Medicaid and food assistance funding via the harmful Republican megabill.

The order weaponizes federal programs to force people who are unhoused or have mental health conditions, use substances, and/or have disabilities into “long-term institutional settings,” echoing the Trump Administration’s brutal and dehumanizing efforts to round up, detain, and disappear people who are immigrants. It directs key federal agencies to, among other things:

• Pressure states and communities to fine and arrest people living outside who have nowhere else safe to go, worsening inequities and making it harder to get housing and health care;
• Pressure states and communities to force more people with mental health conditions into psychiatric hospitals — which is traumatizing and fails to address the underlying need for community-based care;
• Defund homelessness solutions that work; and
• Defund substance use harm reduction services that save lives and offer support.

The order is part of a broader Trump Administration effort to deeply cut funding for proven solutions to homelessness that pair rental assistance with supportive services.

Policymakers at all levels should reject the cruel and short-sighted approaches in the order. Instead, they should focus on ensuring everyone can access affordable, quality housing and community-based health care.

Julio 18 — The Centers for Medicare & Medicaid Services (CMS) announced plans to reduce duplicate enrollment in more than one state’s Medicaid program or in Medicaid and an Affordable Care Act (ACA) marketplace plan with a premium tax credit (PTC). But the Administration’s approach raises the risk that people who are properly enrolled could lose coverage or face higher costs.

Under the CMS plan, when records indicate people are simultaneously enrolled in Medicaid and an ACA marketplace plan with PTC, they will have 30 days to submit documentation to the marketplace to prove they are not also enrolled in Medicaid, or to end their PTC. People who do not comply in time will lose their PTC, but they will remain enrolled in their marketplace plan. If they don’t actively terminate their enrollment, they will be responsible for the full-cost premium.

CMS said it will give state Medicaid agencies lists of people enrolled in multiple Medicaid or Children’s Health Insurance Program plans and will issue guidance in August with more details about requirements for states.

Available data may show someone as being enrolled in more than one program for many reasons that are neither intentional nor avoidable. For example, state Medicaid eligibility systems often have backlogs of unprocessed enrollment changes. Individuals may be enrolled in a form of Medicaid that does not make them ineligible for a marketplace PTC. And individuals have been victims of unauthorized enrollment activity, in which brokers signed them up for new marketplace plans without their knowledge. The CMS plan will require enrollees to bear the brunt of resolving what are often system-generated issues or broker-initiated fraud, putting their health coverage at risk.

Julio 17 — The Centers for Medicare & Medicaid Services (CMS) announced it does not anticipate renewing or approving state policies aimed at building and strengthening the health care workforce.

Its announcement comes as the just-enacted Republican budget law creates new obstacles to individuals entering the health care field (like caps on graduate student loans) and will make it harder for existing providers to maintain services or even keep their doors open. It also comes the same day CMS announced it would no longer allow future state policies that expand continuous Medicaid eligibility, for children or adults.

Several states — California, Massachusetts, New York, North Carolina, and Vermont — have been authorized to use Medicaid funding to support initiatives to recruit, train, and sustain their health care workforce in order to help promote access to care for Medicaid enrollees. These include programs related to student loan repayment as well as initiatives to address workforce shortages.

The Biden Administration approved these state efforts through what are known as section 1115 demonstrations (or waivers). Section 1115 demonstrations allow the Secretary of Health and Human Services to authorize state experimental or pilot projects that promote the objectives of Medicaid. States have used section 1115 to implement a wide variety of policies, from providing specialized benefits to individuals with certain health conditions to expansions of eligibility.

Julio 17 — The Centers for Medicare & Medicaid Services (CMS) announced it does not anticipate renewing or approving state policies that extend Medicaid continuous eligibility (CE) for certain groups, including multi-year CE for young children.

Rolling back extended CE policies will put enrollees, particularly children, at risk of gaps in coverage due to administrative barriers or temporary changes in family income. These gaps can be especially harmful for children, preventing them from attending well-child visits crucial for supporting their development.

The Biden Administration approved the policies through what are known as section 1115 demonstration (or waiver) requests, as part of an effort to improve Medicaid access. CMS’s more recent announcement is consistent with others on section 1115 demonstrations — including one ending supports for the health care workforce — signaling a change in policy direction but stopping short of rescinding approved demonstrations.

Federal law requires all states to provide CE for 12 months to children in Medicaid and the Children’s Health Insurance Program (CHIP). The Biden Administration allowed nine states to provide multi-year CE periods to children — mostly from birth up to age 6 — beginning with Oregon in 2022.

Having uninterrupted coverage is important for adults, too, and multiple states have used section 1115 demonstrations to expand CE to parents and certain low-income adults to align with the 12-month CE period for children. And a few states have provided it for up to 24 months.

Citing program integrity concerns, CMS noted that states with expanded CE policies will have to develop a plan to notify enrollees and conduct full eligibility renewals for the phase-down.

Julio 16 — The Trump Administration issued a series of notices attempting to further restrict immigrant access to a number of services and programs that are funded at least in part by the federal government. Patients receiving cancer treatment, parents relying on Head Start for quality education and child care, and people receiving mental health services may face consequential, life-altering challenges without access to these essential services.

The people living lawfully in the U.S. who would lose access to vital services due to these changes, in addition to those without documented status in some cases, include people granted Temporary Protected Status; children granted special immigrant juvenile status who have been abused, abandoned, or neglected by one or both parents; survivors of serious criminal activity who have cooperated with law enforcement; and people with Deferred Action for Childhood Arrivals (DACA), and other people living lawfully in the U.S.

The notices, issued by the Department of Agriculture, the Department of Health and Human Services, the Department of Education, the Department of Labor, and the Department of Justice, attempt to broaden the list of programs designated as a “federal public benefit” under a 1996 law that severely limits access to such benefits based on immigration status. The change would impact programs that for decades both Republican and Democratic administrations have interpreted as open to eligible members of the public regardless of immigration status.

The notices imply that the policies would take effect immediately or soon after publication, though none clarify how impacted entities would be expected to modify their application and renewal processes to reflect these changes. This would take significant time and resources at a time when many programs, like Head Start, are already struggling. Some programs could also face conflicting requirements regarding their obligations to serve the public, such as the requirement that community health centers offer care to all patients regardless of their ability to pay. States and other impacted groups have filed suits challenging the legality of these notices.

Junio 20 — The Centers for Medicare & Medicaid Services (CMS) finalized a rule that will make Affordable Care Act marketplace coverage less affordable for enrollees, create new barriers to enrolling in and maintaining coverage, and cause up to 1.8 million people to lose marketplace coverage in 2026 alone, CMS estimates.

The rule’s sweeping changes will affect marketplaces in all states. Effective August 25, it will: eliminate the special enrollment period (SEP) that enables people with low incomes to enroll in coverage year-round, eliminate marketplace and Basic Health Program coverage for people with Deferred Action for Childhood Arrivals (DACA), and impose burdensome verification requirements that will cause gaps or losses in coverage.

In 2026, it will levy financial penalties on certain people who automatically reenroll in marketplace coverage instead of actively renewing it, adjust premium calculations in ways that will raise premiums and out-of-pocket costs, and prohibit marketplace plans from including gender-affirming care as an essential health benefit. The rule also shortens the annual open enrollment period, starting with open enrollment for 2027 (November 1 – December 15, 2026).

Because most provisions will take effect within the next six months, marketplaces, insurers, enrollment assisters, and enrollees have little time to prepare. The scheduled expiration of enhanced premium tax credits (PTCs) on December 31 will compound enrollees’ cost increases and confusion. And the Administration has slashed federal funding for the navigator program, which helps enrollees manage changes like these in the 30 states that use HealthCare.gov.

In a rare move that will make implementation even more confusing for enrollees and assisters alike, CMS is sunsetting many of the provisions at the end of 2026. This enabled Republicans to increase the health care budget cuts in their recently enacted reconciliation legislation, which includes marketplace changes that will create permanent barriers to enrollment. Those changes include eliminating automatic reenrollment for people who receive PTCs, prohibiting enrollees who use an income-based SEP from accessing PTCs, imposing new red-tape barriers before people can enroll, eliminating PTC eligibility for many immigrants living and working lawfully in the U.S., and removing caps that protect low- and moderate-income people from having to repay excessive PTC amounts at tax time.

Mayo 21 — The U.S. Department of Justice is suing New York, Vermont, Hawai‘i, and Michigan over the states’ efforts to hold oil companies accountable for climate change. This is the latest in a string of actions by the Trump Administration to attack efforts that address climate change and instead prop up the fossil fuel industry, which donated hundreds of millions of dollars to Trump’s campaign and the groups supporting him.

The Trump Administration’s lawsuits against these four states are not likely to succeed. Their arguments have already failed in multiple courts. The Supreme Court has twice refused to get involved.

Given the shaky legal ground, the lawsuits may be attempting primarily to dissuade Democratic-led states from using their authority to protect their residents from shouldering the costs of climate damages. Regardless, they are a direct attack on states’ authority to manage public health, disaster costs, and consumer protections — the very things the Trump Administration has stated should be under state control.

The lawsuits against New York and Vermont target their recently adopted Climate Superfund laws, which protect their constituents from the harms of climate change and recover costs from the companies responsible for causing them, rather than have taxpayers shoulder this burden.

The lawsuits against Hawai‘i and Michigan seek to stop those states from filing planned lawsuits against oil companies. Nevertheless, Hawai‘i went forward with its lawsuit, following dozens of other states, tribes, and local governments who have brought oil companies to court in recent years for failing to warn the public of the danger of their product. These suits pave the way for government entities and individuals to recover costs from oil companies for climate change damages.

Oil companies have known since at least the 1960’s that the planet warming gasses created by the extraction, production, and use of their product are causing dangerous changes in weather patterns, rising seas, increases in extreme events, and a host of impacts with rising costs to the economy and human lives. These impacts fall hardest on people of color (particularly Black, Latine, and Native American people) and people with low incomes or low wealth.

Abril 29 — The Department of Education issued a letter to State Education Agencies (SEAs) and then a separate document they were asked to complete by April 24 to certify that they will not engage in “illegal DEI practices” or else risk losing Title I funding, which goes to schools that serve large numbers of students from families with incomes below the poverty line.

The Administration is threatening to cut federal funds from schools that engage in certain practices it deems discriminatory, but those practices are not clearly specified in the materials provided. For instance, the letter claims as discriminatory programs that “teach students that certain racial groups bear unique moral burdens that others do not” without specifying how states are to determine whether particular teachings have the impact the department claims. Curriculum that teaches about the country’s history of racial and gender oppression does not necessarily produce a discriminatory environment for students who identify as white or male, for example, yet the department’s letter does not specify whether any school that teaches this history may be threatened with reduced federal funding.

States have had disparate responses to the letter in part due to its lack of clarity, and multiple federal court rulings have blocked the Administration’s ability to pause funding in this manner.

The Administration has demonstrated its willingness to withhold or cancel federal funds for public education through other actions, such as withholding already-approved funding for schools still needed post-pandemic and threatening to withhold funding from Maine over a disagreement related to trans student athletes.

Federal education funding is designed to promote equity, and to assist where state and local governments face more challenges in meeting the needs of all students, in particular those who have a disability or attend schools with large numbers of students living in poverty. Title I funding accounts for the largest portion of federal K-12 funding — almost $20 billion this school year, or the equivalent of almost 400,000 teaching positions.

Losing federal funding would have serious consequences. Research demonstrates that student outcomes improve with increased investments and that funding cuts tend to particularly harm students with marginalized racial and ethnic identities or low incomes, so withholding federal school funding would be expected to result in declines in student test scores and deeper inequities in achievement along lines of race, ethnicity, and income. Withholding this critical funding would harm students and undermine the federal government’s commitment to equal educational opportunity.

Abril 15 — Court filings have made clear that within days of the start of the Trump Administration, DOGE political appointees gained unprecedented access to federal payment systems and acted to intercept and pause legitimate federal payments that had been properly certified by agency officials — despite lacking clear authority for such interference. In a recent paper, CBPP warned that political access to and interference with centralized payments systems created an avenue for significant abuse — including the illegal withholding of payments to or benefits from targeted recipients — among other data privacy, operational, and cybersecurity risks.

President Trump’s March 25 Executive Order related to the federal government’s centralized payment systems could further the risks of political interference. The EO includes a directive that would potentially require legitimate payment orders submitted to Treasury to also comply with an ambiguous set of “other payment, account, and payee validation programs and services” chosen by the Secretary of the Treasury and the OMB Director in ways that go beyond the legitimate goal of preventing improper or fraudulent payments.

As described in CBPP’s paper, Treasury’s role in the payment process is well-established by law: it is responsible for disbursing payments, but it does not determine who is eligible to be paid — that is the role of the agency that Congress appropriated funds to. Given the degree to which the Trump Administration, Elon Musk, and DOGE have often defined payments that the Administration simply disagrees with on policy grounds as “fraud” — even when those payments are permitted or even required by laws passed by Congress — the risk is that the Administration implements this EO in a way that allows Treasury and OMB to disrupt legitimate payments. 

The Administration owes greater transparency to the public as to how it intends to implement this EO consistent with existing laws — and clear assurances that it is not creating a back-door method to block payments that households, states and localities, nonprofits, and others are legally entitled to.

Abril 10 — The Trump Administration appears poised to approve requests from states to ban the use of SNAP benefits to purchase certain items, like soft drinks, despite the significant downsides of these policies and without evidence that they address the root causes of poor diet and chronic disease. The Administration’s recent cuts to relevant SNAP research further undermine claims that these initiatives will be effective in improving health.

Over the years, several states have proposed prohibitions on items like soft drinks and candy, ostensibly in the name of improving nutrition. However, all such requests have been denied, including under the first Trump Administration, due to concerns about their effectiveness, increased stigma for SNAP participants, burden on retailers, feasibility and cost of implementation, and the inadequacy of the proposed evaluation, which the law requires.

But instead of addressing these concerns, the Trump Administration last month terminated a research project that had already been in progress for over a year to study how to effectively measure the impact of restricting SNAP purchases. A now-deleted USDA research plan indicates that this was intended address the debate surrounding restrictions with empirical evidence and to better understand how to operate and evaluate these initiatives. Agriculture Secretary Brooke Rollins also championed the cancellation of another research contract, a longitudinal study evaluating how changes in SNAP policy and benefit levels over time affected participants’ diet quality and food purchases.

The data we do have indicate there are no meaningful differences in the types of foods purchased with SNAP versus other payment methods, calling into question the effectiveness of public health interventions that only single out SNAP participants.

Moving ahead without answers about how to effectively operate and evaluate these initiatives — or whether they’re even warranted in the first place, given that SNAP participants and non-participants make broadly similar dietary choices — risks exacerbating the harm of these restrictive policies, while failing to answer whether they have even moved the needle on diet or health.

Abril 8 — On Wednesday, Veterans Affairs Secretary Doug Collins will make his first appearance in front of Congress since an internal memo leaked last month revealing DOGE plans to lay off roughly 80,000 employees at the Department of Veterans Affairs (VA), an estimated 17 percent reduction in staffing.

Following the direction from President Trump's February 11 Executive Order these deep cuts would lead to significant service impacts, degraded customer service, and longer wait times and backlogs at an agency that in 2025 is expected to provide direct health care to over 7 million patients, administer disability compensation and pension benefits to roughly 7 million veterans and family members, and deliver other critical care services and benefits earned by the country's veterans.

The table below shows how a 17 percent reduction would affect VA staffing in every state:

Abril 8 — President Trump signed four executive orders that streamline development of harmful fossil fuels, undermine years of progress on clean energy development and environmental justice, and take power away from states to protect their communities from environmental harms.

• Protecting American Energy From State Overreach: stymies states’ efforts to protect their residents from climate impacts and collect damages from the fossil fuel companies responsible for climate change. The order directs the Department of Justice to identify and stop enforcement of all state laws and policies that address “climate change,” “environmental justice,” “greenhouse gas” emissions, and funds to collect on carbon taxes. Regardless of how the executive order is implemented, the threat to states’ climate policies is clear.
• Regulatory Relief for Certain Stationary Sources to Promote American Energy: waives emissions standards on hazardous air pollutants from coal and oil plants for two years, stripping the EPA’s ability to regulate dangerous pollutants.
• Strengthening the Reliability and Security of the United States Electric Grid and Reinvigorating America’s Beautiful Clean Coal Industry and Amending Executive Order 14241: reverse progress on phasing out coal, which in 2022 accounted for about 55 percent of climate pollution from the electric power sector and produces smog, haze, and other pollutants associated with respiratory illness, particularly among children. One executive order calls for using emergency authorities to keep coal plants open, and the other designates coal as a "critical mineral" and lifts barriers for extracting coal on public lands, encouraging more coal production.

Communities of color already face higher exposure to pollutants from fossil fuel generation. Increasing coal production while stripping protections from its harmful effects will especially harm Black, Latine, Native American, and low-income communities. 

Abril 7 — In an unprecedented break from past practice related to taxpayer privacy, the IRS and Immigration and Customs Enforcement (ICE) signed a Memorandum of Understanding (MOU) that sets out a procedure to share taxpayer data, which ICE reportedly wants to support its mass deportation efforts.

For decades, people who are ineligible for a Social Security numbers (SSNs) have filed and paid taxes using Individual Taxpayer Identification numbers (ITINs). The IRS has previously explained that statutory requirements limit its ability to share their data for immigration enforcement purposes. As it stated in 2017:

The IRS has strong processes in place to protect the confidentiality of taxpayer information, and this includes information related to tax returns filed using ITINs. . . . There is no authorization under this provision [i.e., recent federal legislation that required many people to reapply for their ITINs] to share tax data with ICE.

If the IRS now proceeds to share taxpayer data with ICE, its actions would violate this understanding and could put taxpayers in harm’s way.

For example, IRS data sharing raises the risk of individuals erroneously being identified as targets of ICE investigations, given that IRS databases are not designed for immigration enforcement and ICE has a checkered history with data errors.

A shift in the IRS’s data-sharing practices could also have a chilling effect on tax compliance among people who are undocumented and taxpayers more broadly, which could lower revenues significantly. People without a documented immigration status paid an estimated $66 billion in federal taxes in 2023, according to the Yale Budget Lab.

The MOU has raised significant concerns within IRS and led to the departure of several senior IRS officials. An unprecedented weakening of taxpayer privacy protections in one area also raises serious concerns across the board.

Abril 2 — The Department of Health and Human Services (HHS) is moving forward with its plan to fire 10,000 employees, consolidate 28 divisions into 15, and eliminate five of its ten regional offices.

This latest round of “restructuring” is on top of previous efforts that resulted in 10,000 HHS employees losing or leaving their jobs. Together, these efforts are expected to cut the HHS workforce by 25 percent. The extent of these cuts raises serious potential legal concerns, given the challenge of fulfilling HHS’s statutorily required duties — including ensuring food and drug safety, supporting and conducting medical research, and protecting the country from public health threats — with a significantly smaller staff.

HHS argued that cutting staff won’t impact “critical services” because many of the workers who are being fired have communications, operations, and administrative roles. However, experts and federal workers have argued that eliminating support roles will undermine HHS programs and could negatively impact food safety and medical research advances. Hundreds of former HHS employees signed a letter stating that the “reality” of these cuts “is the abandonment of people who rely on us the most: the sick, the vulnerable, the poor.”

HHS has asserted that staffing cuts “will not impact Medicare and Medicaid services,” but cuts to the Centers for Medicare & Medicaid Services’ Office of Program Operations and Local Engagement (OPOLE) could impact Medicare and Affordable Care Act (ACA) marketplace enrollees. OPOLE identifies regional issues that could affect these enrollees, helps Medicare health and drug plans comply with program rules, and acts as a liaison between ACA marketplace enrollees and plans when issues arise.

In terms of restructuring, HHS has begun dismantling the Administration for Community Living (ACL), firing 40 percent of ACL staff and purporting to put its functions into other HHS agencies. ACL supports independent living and community participation for older adults and people with disabilities, many of whom are enrolled in Medicare or Medicaid. Dismantling it threatens access to care for underserved populations.

HHS also announced plans to merge some agencies into a new Administration for a Healthy America, among other reorganization efforts. Public health experts describe these rearrangements as “nonsensical” and argue that they will result in lost progress and devastating impacts on health services.

Marzo 31 — The Department of Health and Human Services is temporarily withholding Title X grants to 16 health care providers in 22 states, which could have an immediate effect on providers of essential reproductive health services and the patients they serve. The funding freeze has left seven states with no Title X-funded providers.

The Administration says it is withholding the grants to review “possible violations” of federal civil rights laws and President Trump’s recent executive orders. If the grants are terminated, almost 900 facilities and around 850,000 patients would be affected.

Title X provides grants to providers for family planning and related preventive health services, especially for uninsured individuals or those with low incomes. The grants support a broad range of services for millions of people, including contraceptive care, cancer screenings, and testing and treatment for sexually transmitted infections. Consistent with federal law prohibiting the use of federal funds for abortion, Title X funds do not fund abortions.

Cuts to Title X funding would restrict or eliminate access to critical services and exacerbate racial and ethnic disparities in health care, as Title X-funded health centers are an important source of care for people of color. The effects would likely be especially acute in Southern states, where many of the patients served by funded clinics fall into the Medicaid coverage gap and thus are uninsured.

The first Trump Administration targeted Title X through a 2019 rule that prohibited grantees from referring clients for abortion services, among other significant changes. Over a thousand facilities left the program following this policy shift. The Biden Administration reversed the 2019 changes.

Just a day after freezing the Title X grants, the Trump Administration restored separate Title X funding to grantees in two states whose funding had been withheld during the Biden Administration for not meeting program requirements to counsel pregnant patients on all of their options.

Marzo 25 — The Department of Housing and Urban Development (with the Department of Homeland Security) is the latest agency to announce actions that may stop people who are immigrants or in families that include immigrants from accessing federal programs, though this does not change current law or regulations.  Sparked by a February 19 executive order, several agencies are taking steps that will create fear and deter eligible people from accessing benefits.

The Department of Agriculture (USDA) and the Administration for Children and Families (ACF) have also announced their intentions to ensure states and territories are taking steps to prevent people who are undocumented from getting benefits, despite existing bars and other harsh barriers to federal programs for these and other people who are immigrants. USDA oversees state administration of SNAP (food assistance), and ACF does cash assistance, child care, and many other programs, for many of the lowest-income families.

Though these announcement letters do not modify existing laws or regulation, they may set in motion inefficient, punitive approaches in the delivery of programs as agency officials feel compelled to show they are cracking down on how programs are administered and who is served. Such actions undoubtedly create even more fear among families that include immigrants, causing them to forgo needed benefits for eligible individuals in their households, such as U.S. citizen children. This may also harm people who are eligible for the narrow programs and services that are available to people regardless of status, such as life-saving services.

Marzo 24 — The Trump Administration’s targeting of the IRS is uniquely revealing, as my colleague Chuck Marr wrote for Bloomberg last week. Attacks on the IRS are costly and undermine DOGE’s stated goals of reducing fraud and abuse. If the Administration were truly in pursuit of government efficiency, it would commit to funding and staffing IRS operations to ensure smooth operations that work for honest taxpayers.

Yet, the Administration has already fired over 7,000 IRS employees and is planning to cut 11,000 more by May 15, reportedly with the end goal of cutting the agency workforce by up to half. Staff and program cuts are likely to increase tax evasion, reduce federal revenues, and raise costs for honest tax filers.

In 2022 Congress addressed years of chronic IRS underfunding with an $80 billion investment, which has already started paying off in improved customer service and crackdown on wealthy tax cheats. But that rebuilding is at grave risk.

Many of the DOGE staff cuts so far have occurred in the enforcement division — particularly on the teams auditing businesses and their owners, who make up a disproportionate share of the $700 billion annual tax gap. The IRS is reportedly already dropping audits of high-income people because of insufficient staffing.

Each dollar spent on IRS tax enforcement raises multiple dollars in revenue, which means that every dollar cut from IRS enforcement loses more than a dollar of revenue. The Yale Budget Lab estimated that the planned reduction in force could lose almost $160 billion in net revenue — a conservative estimate because these cuts could undermine voluntary compliance.

The Administration has also announced plans to close taxpayer assistance centers and proposed large staff cuts to the Taxpayer Advocate Service and the team running the IRS’s Direct File tool that over 140,000 people used last year to complete their taxes for free. Those cuts will mean taxpayers will get less help with addressing their tax questions and filing their returns.

Marzo 24 — HUD is imposing harmful new requirements in federal grant agreements under the Continuum of Care (CoC) program — the main HUD program that funds communities’ long-term solutions to homelessness — that will disrupt efforts to help people exit or avoid homelessness.

Rather than promoting proven solutions that pair rental assistance with supportive services, the Administration is pressuring grantees to abandon equity and inclusion efforts that are needed to solve homelessness for everyone, including people of color and people with disabilities. HUD could try to enforce the vague new language in ways that undermine access to rental assistance and supportive services for unhoused people who are transgender, nonbinary, or immigrants, among others. A U.S. district court has temporarily blocked the new requirements for eight local governments suing HUD.

HUD’s abrupt changes came after it delayed the release of $3.6 billion in CoC funding for more than two months, which created a funding gap for some providers even as the latest data show the number of people experiencing homelessness at an all-time high.

Already, grantees’ efforts to understand unclear HUD directives are diverting much-needed resources from efforts to help people find shelter and housing. Grantees are struggling to determine whether they could lose funding if they don’t alter local programs, even though there have been no changes in the underlying laws and regulations governing the CoC program. Many grantees have limited alternative funding sources and may feel pressured to accept the new terms despite this uncertainty.

Prior executive actions have left CoCs with little support in understanding HUD’s changing policies. HUD cancelled contracts with organizations providing technical assistance to local homelessness and affordable housing initiatives. President Trump issued an executive order and took other actions gutting the U.S. Interagency Council on Homelessness, which coordinates federal efforts to solve homelessness. Proposals from Elon Musk and DOGE to slash HUD staffing by half would further undercut services and assistance that help people in every state afford housing and exit homelessness.

Marzo 20 — The Trump Administration’s Social Security changes, including a move to stop identity verification by phone, could make it harder for millions to access the Social Security benefits they've earned.

CBPP’s Kathleen Romig spoke to the PBS News Hour about how these changes could affect people across the U.S.: https://www.pbs.org/newshour/show/trump-administrations-social-security-changes-could-limit-access-to-benefits-for-millions.

Marzo 18 — A new Trump Administration executive order shifts financial responsibility for disaster preparedness to states, local governments, and individuals and adopts a flawed approach to emergency management. The order will lead to a significant weakening of preparedness efforts, making it more difficult for communities — especially rural, coastal, and low-income communities, which disproportionately suffer the growing impacts of extreme weather and climate change-fueled disasters— to prepare for and recover from them.

The order states that the Administration intends to “streamline” its preparedness operations and encourage entities outside the federal government to take on those responsibilities. The Administration recently announced plans to end FEMA’s Building Resilient Infrastructure and Communities program and began freezing some post-disaster grant funds, arguing that states are using them to support people who are immigrants. State, tribal, territorial, and local governments rely on these FEMA programs to make cost-saving, life-saving upgrades to buildings, roads, and critical infrastructure. These projects reduce disaster response and recovery costs — which the federal government is mandated to help cover under the Stafford Act — by as much as $13 for every $1 invested.

The order also calls for a shift from an “all-hazards” approach to disaster preparedness to a “risk-informed” approach. This will undermine decades-long work to integrate disaster preparedness across multiple functions of government and parts of society so actions to reduce disaster risk in one geographic area, economic sector, or population group don’t increase risks in another. Such risk shifting often results in lower risk for neighborhoods whose residents are largely white or wealthy and increased risk for neighborhoods whose residents are largely people of color or low income. As climate change increasingly worsens certain disasters, an all-hazards approach —which allows for complex information about future climate risk to be integrated into disaster preparedness — is even more important.

In addition to the new executive order, President Trump and other Administration officials, such as Department of Homeland Security Secretary Kristy Noem, have repeatedly said they intend to dismantle or significantly restructure FEMA. While there are many reforms that the nation’s disaster policy and funding system could benefit from, the Administration’s policies are a step in the wrong direction.

Marzo 14 — President Trump signed an Executive Order (EO) to significantly reduce the size of seven small governmental entities, as a precursor to seeking to eliminate them entirely. The EO seeks to dismantle agencies that have traditionally had strong bipartisan support, including:

• The Community Development Financial Institutions Fund, which supports financial institutions deploying capital to support small businesses and affordable housing in economically disadvantaged communities, including cities and rural and tribal areas. 
• The United States Agency for Global Media, which works to expand freedom of information and America’s democratic values globally. – The Agency supervised the Voice of America, which has already gone silent after broadcasting since 1942 into countries that censor the press. 
• The Institute of Museum and Library Services (IMLS), which supports libraries, museums, and archives in every state that offer educational, health, job, cultural, historical, and scientific resources and collections.
• The United States Interagency Council on Homelessness, which coordinates federal efforts to solve homelessness and supports communities in implementing best practices. 

Also targeted are the Federal Mediation and Conciliation Service; the Woodrow Wilson International Center for Scholars in the Smithsonian Institution; and the Minority Business Development Agency within the Department of Commerce.

The EO's goals are troubling: these entities play important functions, and it would be deeply damaging for them to be dismantled. But importantly, the EO itself is not able to legally achieve the Administration’s goal of eliminating these entities, which each have funding, enacted by legislation passed on March 14, that must be spent under the law for congressionally intended purposes. 

For example, IMLS was appropriated $294.8 million in the continuing resolution providing full-year funding for federal government operations. Typically, about 60 percent of IMLS’s funding has gone to states as grants to support local libraries each year, and nearly 20 percent has supported museums. Regardless of the EO, the Administration is legally required to spend this money by the end of fiscal year 2025 in September.  

Marzo 14 — The Department of Health and Human Services’s (HHS) recent decision to cancel pilot projects for five states in the Temporary Assistance for Needy Families (TANF) program is a major setback for low-income families, as my colleague Nick Gwyn explained earlier this week.

Under TANF, states must meet rigid work participation rates. The pilot projects, created by the Fiscal Responsibility Act of 2023, aimed to move away from these work reporting requirements and instead focus on measuring families’ work and well-being outcomes. This would facilitate long-term economic stability and mobility for families, maximize earnings, and increase family well-being.

Twenty-two states and Puerto Rico applied to participate in the pilot, which showed states’ eagerness to move TANF in a better direction and better serve their TANF families. After a rigorous process, HHS selected California, Kentucky, Maine, Minnesota, and Ohio for the pilots, each with promising plans to make TANF more effective. Now, HHS says that states must reapply, under a not-yet-announced new process. This will hamper vital progress.

Marzo 13 — Elon Musk and the “Department of Government Efficiency” (DOGE) have reportedly called for discharging at least half of overall staff at the Department of Housing and Urban Development (HUD). Some of their proposals may be illegal, and all would undermine policies most effective at helping people afford housing — at a time when homelessness is at an all-time high.

The DOGE proposals would slash staffing in offices critical to prompt and efficient use of tens of billions of dollars of rental and homelessness assistance, which people struggling to keep a roof over their heads badly need. Rental assistance and other services sharply reduce housing instability and homelessness, and should instead be getting investment boosts to address funding limitations and waitlists.

HUD, meanwhile, has also yet to deliver any of the $3.6 billion in homelessness assistance funding awarded January 17, which communities are counting on to provide rental assistance, shelter, outreach, and other services to people experiencing homelessness. While HUD notified at least some grantees that they will begin to receive funds soon, the uncertainty has disrupted community plans to address homelessness and the funding may be accompanied by abrupt policy changes that undermine best practices.

And HUD officials have called for evicting or cutting off rental assistance for people who don’t meet burdensome work requirements, a step that would increase administrative costs and expose many children, people with serious health conditions or caretaking responsibilities, and others to severe hardship.

Marzo 12 — The Trump Administration has directed federal agencies to submit plans by March 13 for large-scale layoffs and staff reductions known as “reductions in force” (RIFs). Because Congress has appropriated sufficient funds for these positions' salaries and benefits, these RIFs will constitute unlawful impoundments of appropriated funds. Some agency cuts will likely be enormous, harming Social Security benefits administration and other services people count on, from already strained agencies.

Take, for instance:

• The Social Security Administration (SSA), where Elon Musk and the “Department of Government Efficiency” (DOGE) have called for eliminating thousands of jobs. The agency that administers Social Security benefits is already experiencing a customer service crisis — long hold times on the phone and record-long waits for disability determinations — fueled by long-time austere funding and understaffing. Staff cuts, especially if large scale, would exacerbate this crisis.
• The IRS. The Treasury Department is reportedly considering cutting IRS staffing by up to half. In 2022 Congress addressed years of chronic IRS underfunding with an $80 billion investment, which has already started paying off in improved customer service and a crackdown on wealthy tax cheats. But that rebuilding is now at grave risk. An understaffed IRS would only benefit tax cheats and reduce revenue collections.
• The Department of Education, which announced it was firing more than 1,300 staff; with other cuts this brings the department to half its size since President Trump took office. This will harm student loan administration and college affordability while weakening civil rights enforcement in schools.

We will monitor the RIF plans as they become public for these and other agencies in the coming weeks.

Marzo 12 — The General Services Administration (GSA) announced that it is discontinuing the Notify.gov platform, which has been used to send critical text message notifications to Medicaid enrollees about steps they need to take to keep their coverage.

This announcement came shortly after Thomas Shedd, former Tesla software engineer turned Deputy Federal Acquisition Services Commissioner of Technology Transformation Services, requested admin access to the Notify.gov codebase, which is a significant privacy concern. GSA stated it is “working closely with a small number of impacted partners to transition off the platform with minimal disruption.”

Notify.gov was piloted through GSA’s Public Benefits Studio to improve client experience and reduce the administrative costs of contacting participants in health and economic security programs like Medicaid. Texting is a particularly powerful tool for reaching low-income applicants and enrollees, with over 90 percent owning a cell phone. It is also a more reliable form of communication than physical mail, which takes multiple days to deliver and may not reach clients due to changed or inaccurate addresses.

Instead of the current standard, where each state spends money and time to build out its own texting platform, Notify.gov was a shared federal service. It was designed to be easily used by state agencies with minimal startup effort; they simply had to upload a file with recipients’ phone numbers and the message to be texted to them. This is particularly useful during times of rapid change like Medicaid unwinding. For example, Virginia used Notify.gov to send thousands text messages to families about renewals and eligibility requirements.

Notify.gov was created to show it is possible to create a shared federal service that improves client experience while also lowering administrative costs.

Marzo 12 — EPA Administrator Zeldin announced that the agency will be reconsidering 31 rules and regulations, including those related to:

• wastewater pollution and limiting power plant emissions;
• mandatory greenhouse gas reporting for large oil and gas operations;
• air quality standards;
• limits on mercury and other toxic pollutants from power plants; and
• the National Enforcement and Compliance Initiatives, which direct the EPA to work on mitigating climate change and to address exposure to PFAS (long-lasting chemicals linked to serious health issues), reduce air toxins in overburdened communities, and increase compliance with water standards, among other actions aimed at protecting community health.

The EPA will also reconsider EPA’s 2009 Endangerment Finding and its resulting regulations. This finding identified six greenhouse gases as public health risks and serves as the basis for the EPA’s ability to regulate greenhouse gas emissions under the Clean Air Act. The EPA’s methane emissions standard, for example, is projected to reduce approximately 510,000 tons of methane and 3,900 tons of air toxics in 2025, which would alleviate health problems linked to air pollution. Walking back the Endangerment Finding would make it more difficult to cap emissions from factories, cars, and industries such as agriculture.

People with low incomes and people of color are likelier to live in communities where polluting industries are more prevalent and therefore face higher levels of air pollution and other environmental hazards. These communities will be disproportionately harmed if the EPA overturns decades of regulations intended to protect human health and the environment.

Marzo 12 — The Trump Administration is advancing its goal of dismantling the Department of Education by firing nearly half its staff. Combined with other education-related executive orders, it’s clear we’re witnessing an attempt to gut public schools, roll back initiatives to promote equal opportunity and address inequality, and steal opportunities from the 90 percent of U.S. students who go to public school.

On rolling back equity efforts: the Trump Administration reportedly targeted the Education Department office that protects students’ civil rights for staff cuts, which will make it virtually impossible to investigate discrimination based on race, gender, and disability, according to some experts.

In addition, an executive order signed in January threatens funding for schools that teach about racism, sexism, and other forms of discrimination. The Administration has also targeted transgender student athletes.   

School districts are already losing teacher recruitment and retention grants, cut because the Administration classifies them as promoting diversity, equity, and inclusion. These cuts will ultimately harm students as districts will have to pull funding from other programs or risk losing teachers.

Although likely illegal, attacks on inclusive school policies could hurt teachers’ abilities to support LGBTQ+ students and students of color. Inclusive environments contribute to academic success for all students, regardless of gender or race. If school funding is cut because of inclusive policies and fewer supports are available, rates of bullying, depression, suicidality, and hate crimes will increase for all students.

On taking public funding away from public schools: President Trump signed an executive order that tries to shift federal funds from public schools to bankroll vouchers for wealthy families who already send their kids to private school. Diverting public dollars from public schools would acutely harm low-income and rural students.  

 It’s unlikely the Education Department will be completely dismantled, but the Administration’s attempt to do so will cause chaos, delays, and reduce oversight, diminishing accountability for student outcomes, and severely weakening public schools’ ability to serve every student.

Marzo 10 — The Centers for Medicare & Medicaid Services (CMS) issued a proposed Affordable Care Act (ACA) marketplace regulation that would reduce marketplace enrollment between 750,000 and 2 million people, CMS estimates, undoing recent progress in marketplace coverage and affordability. People currently struggling to afford the basics would once again lose out under this rule.

The rule would shorten the annual open enrollment period, require people to submit more documentation to verify eligibility (and give people less time to complete verifications), increase premiums and out-of-pocket costs for enrollees, eliminate the Special Enrollment Period that allows people with very low incomes to enroll year-round, and impose financial penalties on certain people if they let their coverage automatically renew at the end of the year instead of returning to the marketplace to actively renew their coverage. The proposal would also ban premium tax credits from paying for gender-affirming care and would make people with Deferred Action for Childhood Arrivals (DACA) ineligible for marketplace coverage.

CMS claims the changes are needed to protect program integrity. But instead of going after the bad actors — most often insurance agents and misleading marketing websites — that have actually exploited enrollees for personal financial gain, the proposal would punish people legitimately seeking to enroll in or renew marketplace coverage. The proposed rule is open for a 30-day comment period.

The proposal was published less than a month after the Administration announced plans to slash federal Navigator funding by 90 percent.

Marzo 7 — In Maine the Social Security Administration (SSA) terminated a long-standing nationwide policy under which parents can apply for a Social Security number (SSN) for their newborns in the hospital, then reversed course after public outcry. Also under the withdrawn policy, families in Maine would have had to complete a separate, paper-based process for death certificates, rather than report the deaths of their loved ones at funeral homes.

SSA acting Commissioner Lee Dudek acknowledged that the policy, which had been imposed without explanation and apparently only in Maine, would have “created an undue burden on the people of Maine,” affecting new parents, grieving families, and other Mainers needing SSA services. It also would have increased SSA’s improper payments and costs and affected other government and private-sector programs families rely on.

The birth and death reporting conveniences were both in place for decades before their abrupt withdrawal and reinstatement. They simplify critical SSA administrative functions, saving significant staff time and money. And automatic death reporting is SSA’s first line of defense against mistakenly continuing to pay Social Security and other benefits after a beneficiary’s death.

Marzo 4 — The Centers for Medicare & Medicaid Services (CMS) announced the rescission of two bulletins describing how states can address health-related social needs (HRSN) through Medicaid:

• Coverage of Services and Supports to Address Health-Related Social Needs in Medicaid and the Children’s Health Insurance Program and related Framework (November 2023)
• Coverage of Services and Supports to Address Health-Related Social Needs in Medicaid and the Children’s Health Insurance Program (December 2024)

This change in CMS policy is likely to impede state efforts to advance health equity. Many states’ requests for new section 1115 authorities reflected that unmet HRSNs were a driver in health inequities.

The 2023 and 2024 bulletins gave states opportunities to cover non-medical but clinically appropriate services, which multiple states pursued in section 1115 waivers approved during the Biden Administration. Allowable services outlined in the November 2023 framework included a range of housing- and nutrition-related supports, some of which were already allowed by the first Trump Administration, such as tenancy and supportive housing services, while others were newly authorized or allowed more comprehensive benefits. All HRSN services were required to be targeted to specific populations based on their health and social risk factors.

Under the revised policy, CMS will evaluate proposals from states to address HRSN through Medicaid on a case-by-case basis to determine if the proposals meet federal statute and regulations without the now-rescinded 2023 and 2024 guidance.

CMS said the rescission “does not negate existing approvals,” though it is unclear how the Trump Administration’s position will impact states’ ability to implement or renew their HRSN policies (section 1115 demonstrations must generally be extended every three to five years to continue). The new approach to considering state HRSN proposals is also likely to delay action on pending state requests, some of which have been awaiting CMS action for almost a year.

In announcing this rescission, CMS did not rescind its 2021 State Health Official Letter, which catalogues a range of authorities that states can use to address unmet social needs. That means states continue to have other options to address unmet HRSNs through a more limited set of services, such as supportive housing services and existing home- and-community-based services authorities.

Febrero 19 — President Trump issued an executive order directing agencies to block people who are undocumented from accessing public benefits — something they already can’t do, with few exceptions. But, as happened with similar directives under the first Trump Administration, this could greatly increase fear among families that include eligible people — including U.S. citizen children — causing them to forgo benefits they need for health care, food, and emergency housing.

For people without a documented immigration status, the bars on eligibility for federal means-tested public benefit programs are long standing. Limited exceptions include care for life-threatening emergencies, for which Medicaid pays health care providers. The executive order acknowledges that it can’t change existing laws, which already have these broad bars and narrow exceptions as well as robust procedures to ensure program integrity.

Nevertheless, the order directs agencies to identify programs that serve people who are undocumented and to report federal funding spent on people who are undocumented to OMB and DOGE within 30 days of the order. Agencies are also supposed to recommend strategies to align with the goal of the order, including changing verification processes used in determining eligibility.

As noted, few programs are accessible to people who do not have a documented status; many, if anything, block access to people with lawful immigration status due to over-strict, long-standing immigration-related eligibility rules. And this order may exacerbate the situation by causing agencies and states to think they must create new obstacles to enrollment for people who are immigrants and their family members. Families with members who qualify for programs may pass up on the opportunity to enroll due to new barriers and out of fear of this and other anti-immigrant actions that the Administration has taken. 

Febrero 7 — The Department of Housing and Urban Development (HUD) announced that it will stop enforcing the Equal Access Rule, which requires key HUD-funded shelters and housing programs to serve people based on their gender identity. Everyone — including transgender and nonbinary people — should be able to access lifesaving emergency shelter and other services without fear of discrimination or harassment.

HUD has initiated the process for rescinding the Equal Access Rule, but that is typically a long process, and the outcome is not guaranteed. The Equal Access Rule remains in effect and housing and shelter providers should follow it. Regardless of what happens to the Equal Access Rule, providers must comply with the Fair Housing Act and other civil rights laws.

In the first Trump Administration, HUD proposed (but never finalized) a rule that would have gutted the Equal Access Rule and sanctioned discrimination against trans and nonbinary people. Any policy that excludes people because of their gender identity or expression directly conflicts with HUD’s mission “to create strong, sustainable, inclusive communities and quality affordable homes for all.”

HUD’s announcement is one of a series of recent executive actions the Trump Administration has issued attacking trans people, some of which have been temporarily halted by the courts.

Enero 29 — The Trump Administration’s executive order on “school choice” offers another example of this Administration's priorities: subsidizing wealthy families who already send their children to private school at the expense of the 90 percent of students who attend public schools.

Shifting funds from departments of Education and Health and Human Services grants to private school vouchers would gut funding for public schools, especially those serving high proportions of students living in poverty, and support discriminatory religious private schools that can reject students because of a disability, LGBTQ+ identity, religious beliefs, or language.

At a time when revenue for public schools is threatened by deep and repeated state tax cuts and voters have rejected voucher programs, federal funds for public schools that educate all children, regardless of identity or background, are more critical than ever.

Enero 20 — President Trump signed new executive orders that will make it even more difficult to reduce climate pollution and adapt to its impacts. Low-income, rural, and tribal communities and communities of color will face outsized harms from these orders, as these communities require targeted federal funding to meet long-unaddressed, critical climate and energy needs resulting from decades of discrimination such as underinvestment and redlining.

These executive actions include:

• overturning several Biden-era executive orders, including the Justice40 Initiative and instructions for implementing the Inflation Reduction Act (IRA), which directed agencies to ensure that the benefits of federal climate programs reach disadvantaged communities;
• boosting oil and gas drilling, mining, and logging in Alaska; and
• leaving the Paris Climate Agreement, thereby walking away from the U.S.’s
  commitment to reduce greenhouse gas emissions by 61 to 66 percent by 2035 — which would have significantly improved public health.

The executive orders signal a dramatic change in direction for the country’s environmental policy and will undermine historic efforts to protect the health and well-being of people and communities.