The Department of Health and Human Services is the primary federal agency responsible for protecting the health of all Americans and providing essential human services. With a budget exceeding $1.7 trillion, HHS oversees Medicare and Medicaid coverage for more than 140 million Americans, regulates the nation's food and drug supply through the FDA, leads public health surveillance and emergency preparedness through the CDC, funds the National Institutes of Health's biomedical research enterprise, and administers critical programs through the Health Resources and Services Administration, the Substance Abuse and Mental Health Services Administration, and dozens of other constituent agencies. The department touches every dimension of American health: from the safety of the food on American tables to the affordability of insulin, from the integrity of vaccine science to the survival rates of mothers giving birth.
Project 2025 proposed to convert HHS from a public health institution into an ideological instrument. Its architects described the department as a mechanism for advancing a specific moral and religious vision under the heading "Department of Life," replacing the mission of protecting health with the mission of enforcing a particular set of cultural values. They called for reversing FDA approval of mifepristone, defunding the Title X family planning program, restructuring the CDC to serve political ends, imposing Medicaid block grants and work requirements to curtail coverage for tens of millions of Americans, and purging federal health agencies of career scientists who reach conclusions inconsistent with the administration's preferred outcomes. The Trump administration, beginning in January 2025, implemented large portions of this agenda: cutting 20,000 HHS employees, terminating approximately 5,844 NIH research grants totaling over $2.7 billion, freezing $65.8 million in Title X grants, launching a politically motivated FDA safety review of mifepristone, and dismantling public health infrastructure built over decades.
The next Democratic administration will restore HHS to its statutory mission and go further: building the most equitable, comprehensive, and scientifically rigorous public health system in American history. This means not merely reversing the damage but enacting structural reforms that prevent any future administration from weaponizing health agencies against the people they serve. It means achieving universal healthcare coverage, eliminating maternal mortality disparities, treating mental health with the same urgency as physical health, ending the opioid epidemic with evidence-based treatment, closing the racial health equity gap, and building pandemic preparedness infrastructure that can withstand the next biological crisis.
The Stakes: Approximately 335 million Americans depend on HHS programs, regulations, and institutions. Approximately 76 million people were enrolled in Medicaid and CHIP as of late 2025. A record 21.4 million Americans signed up for ACA marketplace plans for 2025 coverage. Black women die in childbirth at a rate of 50.3 per 100,000 live births — more than three times the rate for white women. More than 80,000 Americans died of drug overdoses in 2024. The CDC and FDA are the world's most consequential public health institutions. What happens to them determines whether Americans live or die.
Key Reforms:
- Restore CDC scientific independence through statutory protection and restructure agency leadership to insulate public health guidance from political interference
- Reinstate and expand FDA scientific integrity protocols, withdraw the politically motivated mifepristone safety review, and codify medication abortion access nationwide
- Strengthen the Affordable Care Act by making enhanced premium tax credits permanent, expanding Medicaid in all remaining holdout states, and creating a public option
- Expand Medicare to cover dental, vision, and hearing; protect and enforce drug price negotiation authority under the Inflation Reduction Act
- Protect and expand reproductive healthcare access, including Title X, contraception coverage, and abortion care as a recognized component of primary care
- Rebuild the public health workforce: restore all unlawfully terminated HHS employees and fund 50,000 new public health positions over four years
- Restore and increase NIH research funding, reverse research censorship, and protect scientific freedom from political interference
- Achieve full enforcement of the Mental Health Parity and Addiction Equity Act and fund a national substance use treatment expansion
- Eliminate the Black maternal mortality gap through the Black Maternal Health Momnibus Act and targeted federal investment in maternal care
- Build a permanent pandemic preparedness infrastructure including a fully funded Strategic National Stockpile and domestic medical manufacturing capacity
Constitutional and Legal Basis: Public Health Service Act (42 U.S.C. § 201 et seq.); Food, Drug, and Cosmetic Act (21 U.S.C. § 301 et seq.); Affordable Care Act (42 U.S.C. § 18001 et seq.); Social Security Act (42 U.S.C. §§ 1395 et seq., 1396 et seq.); Title X of the Public Health Service Act (42 U.S.C. § 300 et seq.); Mental Health Parity and Addiction Equity Act (29 U.S.C. § 1185a); HIPAA (42 U.S.C. § 1320d et seq.); Children's Health Insurance Program (42 U.S.C. § 1397aa et seq.); 21st Century Cures Act (Pub. L. 114-255); Inflation Reduction Act (Pub. L. 117-169); Spending Clause, U.S. Const. Art. I, § 8; Commerce Clause, U.S. Const. Art. I, § 8, cl. 3.
What Project 2025 Did:
Project 2025 proposed dismantling the CDC as a unified institution by splitting it into two separate agencies — one for data collection and one for policy recommendations — on the stated theory that the CDC was "not equipped to make policy decisions" (Project 2025, p. 453). This structural proposal was not about scientific rigor. It was designed to sever the scientific evidence base from the health recommendations that flow from it, allowing future administrations to accept CDC surveillance data while rejecting any public health guidance that proved politically inconvenient.
Workforce Decimation: The Trump administration reduced the CDC workforce by approximately 2,400 employees in the March 2025 restructuring, eliminating divisions responsible for infectious disease prevention, immunization programs, environmental health surveillance, and health equity research. The Administration for Strategic Preparedness and Response, which Congress elevated to independent agency status to ensure pandemic response capacity outside of ordinary bureaucratic chains, was collapsed back into the CDC and stripped of the independent authority that gave it operational effectiveness.
Research Censorship: The administration terminated and froze thousands of research grants across NIH and CDC on the basis of ideological content: research on vaccine hesitancy, health disparities, diversity in clinical trials, misinformation, infectious disease surveillance, and environmental health factors were systematically targeted. The administration's approach constituted a form of viewpoint-based censorship in violation of First Amendment principles applicable to government-funded research and the statutory mandates of 42 U.S.C. § 241, which directs the Secretary to study and investigate the causes, diagnosis, treatment, control, and prevention of physical and mental diseases.
Abortion Surveillance Weaponization: Project 2025 proposed mandating that all states submit detailed abortion data to the CDC or face funding sanctions — reporting requirements that went far beyond established epidemiological need and were designed to enable state-level enforcement targeting of abortion providers and patients. The document recommended that the CDC "use every available tool, including the cutting of funds, to ensure that every state reports exactly how many abortions take place within its borders, at what gestational age of the child, for what reason, the mother's state of residence, and by what method" (Project 2025, pp. 455-456).
Pandemic Preparedness Hollowed Out: Cuts to the Hospital Preparedness Program and Public Health Emergency Preparedness Program resulted in the loss of hundreds of millions of dollars in state and local preparedness infrastructure. At the same time, proposed fiscal year 2026 budget cuts requested a 26.2 percent reduction in HHS funding — the single largest proposed cut to a domestic department in modern American history.
Grant Clawbacks Paralyzing State Public Health: As a direct consequence of federal grant clawbacks, state and local public health agencies across the country halted ongoing projects and initiated emergency layoffs of staff hired under terminated federal cooperative agreements. The specific programs suspended included infectious disease surveillance networks, vaccination promotion campaigns, outbreak response infrastructure, community health worker programs, and health equity initiatives targeting communities facing the greatest burden of preventable disease. The March 2025 restructuring represented a unilateral administrative decision to abandon the federal government's statutory obligation under 42 U.S.C. § 247b to support state and local disease prevention infrastructure.
Immunization Infrastructure Undermined: The Trump administration, operating under the ideological influence of vaccine skeptics within the cabinet, reduced CDC immunization communications funding, eliminated positions in the National Center for Immunization and Respiratory Diseases, and signaled skepticism toward established childhood vaccination schedules — despite the absence of any credible scientific basis for that skepticism. The result was a measurable erosion of public trust in vaccination programs that had eliminated diseases causing tens of thousands of American deaths annually in the pre-vaccine era. Measles outbreaks reported in 2025 in communities with declining vaccination rates represented the direct and foreseeable consequence of this institutional sabotage.
What Project 2025 Did:
Project 2025 called for the FDA to "reverse its approval of chemical abortion drugs because the politicized approval process was illegal from the start" — a statement that inverted reality, falsely characterizing the 2000 approval of mifepristone as politically motivated when the evidence demonstrates the opposite. FDA career scientists conducted a thorough review under the standard statutory criteria of 21 U.S.C. § 355, and the drug has been used safely by more than five million American women since its approval.
Mifepristone Assault: In May 2025, HHS Secretary Robert F. Kennedy Jr. directed the FDA to conduct a safety review of mifepristone that career agency scientists and outside experts described as politically motivated and scientifically unwarranted. The review created regulatory uncertainty that constrained access to medication abortion, which by mid-2025 accounted for nearly 30 percent of all abortions nationally and was obtained via telehealth by a substantial portion of patients in states without abortion prohibitions. The Trump Justice Department simultaneously signaled potential reinterpretation of the 1873 Comstock Act (18 U.S.C. §§ 1461-1462) to block nationwide shipment of mifepristone, a legal theory rejected by the Biden DOJ and without support in any federal appellate court.
Workforce Cuts Threatening Public Safety: The March 2025 restructuring eliminated 3,500 FDA positions. Former FDA Commissioner Robert Califf stated: "The FDA as we've known it is finished." While the administration claimed that drug, food, and medical device reviewers would be protected, the broader institutional disruption — including the elimination of the FDA's entire communications team — degraded the agency's capacity to manage safety signals, conduct inspections, and communicate transparently with the public. An agency incapable of communicating credibly about drug safety cannot fulfill its statutory mandate under 21 U.S.C. § 393.
Food Safety Neglect: The HHS restructuring plan proposed merging food safety functions across agencies without adequate planning, creating gaps in oversight of an inspection system that protects the nation's food supply from contamination. Project 2025 simultaneously proposed weakening the FDA's authority over dietary supplements (21 U.S.C. § 342) in ways that would expose consumers to unproven and potentially dangerous products.
Regulatory Review Process Corrupted: Project 2025 proposed subjecting FDA regulatory decisions to enhanced White House Office of Information and Regulatory Affairs review, effectively giving political appointees veto power over scientific determinations that are by statute the exclusive province of the FDA Commissioner and career agency scientists. This proposal would have created a pathway for the executive branch to block drug approvals, weaken food safety standards, or accelerate approvals of products favored by politically connected industry interests — precisely the corruption of the scientific process that the FDA's institutional independence was designed to prevent. The Administrative Procedure Act's requirement that agency action not be arbitrary and capricious (5 U.S.C. § 706(2)(A)) applies to FDA regulatory decisions; political override of scientific findings would render those decisions legally vulnerable to challenge.
Dietary Supplement Deregulation: Project 2025 proposed treating dietary supplements under a framework more permissive than the current Dietary Supplement Health and Education Act of 1994 (21 U.S.C. § 342), effectively eliminating the FDA's ability to remove demonstrably dangerous supplements from the market through post-market safety actions. This proposal directly benefits a multi-billion-dollar industry with documented records of selling products containing undisclosed pharmaceutical ingredients, heavy metals, and substances causing liver damage, cardiac events, and death.
What Project 2025 Did:
Project 2025 described the Affordable Care Act as requiring fundamental restructuring and called for converting Medicaid into a block grant or per-capita cap system — effectively capping federal spending regardless of enrollment, economic conditions, or healthcare costs. This proposal would force states to reduce eligibility, cut benefits, or eliminate coverage during precisely the economic downturns when coverage is most needed.
ACA Subsidy Sabotage: The Trump administration declined to extend the enhanced premium tax credits enacted under the American Rescue Plan and the Inflation Reduction Act, which had driven ACA marketplace enrollment to a record 21.4 million Americans in 2025. Congressional Budget Office estimates projected that allowing the enhanced subsidies to expire would cause at least 4.2 million Americans to lose coverage. Congressional Republicans pursued this outcome through the "One Big Beautiful Bill" legislation, incorporating Medicaid cuts and ACA subsidy reductions projected to cause millions of coverage losses.
Medicaid Work Requirements and Coverage Cuts: The administration moved to impose work requirements on Medicaid beneficiaries — requirements that academic research consistently demonstrates reduce coverage without increasing employment, functioning primarily as bureaucratic barriers to care for people who are already working, caregiving, or unable to work due to illness or disability. As of November 2025, Medicaid and CHIP enrollment had fallen to 76 million, down 3.4 million from December 2024, in part due to administrative changes designed to reduce enrollment.
Poverty Guideline Elimination: In a particularly devastating administrative action, the HHS restructuring laid off all staff responsible for calculating and updating federal poverty guidelines — the numerical thresholds that determine eligibility for Medicaid, CHIP, ACA subsidies, and dozens of other federal programs serving tens of millions of Americans. This action, if not reversed, would freeze in place outdated poverty thresholds that would progressively exclude eligible Americans from coverage they need and are entitled to receive.
Medicare Advantage Overpayment and Market Distortion: While proposing cuts to traditional Medicaid and ACA coverage, the Trump administration continued to tolerate documented overpayments to Medicare Advantage plans. GAO and HHS Inspector General reports have consistently found that Medicare Advantage risk adjustment scores are manipulated by insurers to increase capitation payments without corresponding increases in patient severity, costing the Medicare program tens of billions of dollars annually. These overpayments represent a massive transfer of public funds to private insurers at the expense of Medicare's financial sustainability and the traditional Medicare program that serves the most vulnerable beneficiaries.
Children's Health Insurance Program: The administration's approach to Medicaid block grants would have devastated the Children's Health Insurance Program, which provides coverage to approximately 7.2 million children in families with incomes too high for Medicaid but too low for affordable private insurance. CHIP's federal matching rate — among the highest in the Medicaid program — would be eliminated under a block grant structure, forcing states to cut children's coverage during economic downturns when child poverty rates rise and coverage need is greatest.
What Project 2025 Did:
Project 2025 proposed renaming HHS the "Department of Life" and establishing an anti-abortion task force to replace the existing Reproductive Healthcare Task Force. It called for creating a "Special Representative for Domestic Women's Health" whose actual purpose was to coordinate anti-abortion policy across federal agencies — converting a department constitutionally obligated to protect public health into an enforcement arm for a specific ideological position on reproductive autonomy.
Title X Defunding: The Trump administration froze approximately $65.8 million in Title X family planning grants — a program explicitly prohibited by statute from funding abortions. Title X funds contraception, cancer screenings, sexually transmitted infection testing and treatment, and other preventive care for millions of low-income Americans. The Guttmacher Institute documented that Title X-supported services prevent approximately 822,000 unintended pregnancies annually. Defunding these services does not reduce abortion — the evidence establishes that restricting contraceptive access increases unintended pregnancy and therefore increases abortion.
Conscience Clause Weaponization: Project 2025 proposed expanding conscience clause protections to allow healthcare providers to deny care based on personal or religious objections to an unprecedented degree — including refusals to provide contraception counseling, emergency contraception, and referrals for legal medical services. This expansion would eliminate the reciprocal duty of care that medical licensure has always imposed, converting the federal healthcare system into a tool for imposing the religious views of providers on patients in medical emergencies.
Abortion Reporting Weaponization: The proposal to mandate state-level abortion surveillance with financial penalties for non-compliance represented a federal effort to create a national database of abortion patients and providers — a direct assault on the patient privacy protections of HIPAA (42 U.S.C. § 1320d) and a foundation for future state-level prosecution of patients and providers.
Emergency Contraception and Contraceptive Sabotage: Project 2025 proposed allowing healthcare providers — including pharmacists, nurses, and hospital-based providers — to refuse to dispense emergency contraception based on personal religious objection, without any obligation to refer the patient to a willing provider. This proposal would have created a right of denial without remedy, leaving patients in medical emergencies without recourse. Emergency contraception prevents fertilization and is not an abortifacient under any established pharmacological definition — yet Project 2025 treated it as such, deliberately conflating contraception with abortion to justify the broadest possible scope of provider refusal.
Pregnancy Crisis Centers and Misinformation: Project 2025 proposed increasing federal funding for pregnancy resource centers that provide medically inaccurate information about abortion safety and contraceptive efficacy, while simultaneously defunding evidence-based reproductive health providers. This use of federal funds to promote misinformation violates the principle established in Rust v. Sullivan, 500 U.S. 173 (1991), that while government may choose which programs to fund, it may not fund programs that actively mislead beneficiaries about the nature of their medical options.
What Project 2025 Did:
The Trump administration terminated approximately 5,844 NIH research grants, eliminating approximately $2.7 billion in research funding through early 2025 according to a Senate committee minority report. These terminations were not driven by scientific merit review — the established process under 42 U.S.C. § 289 — but by ideological screening of grant content. Projects addressing vaccine hesitancy, health disparities, diversity in clinical trials, environmental health, infectious disease modeling, and gender minority health were disproportionately targeted.
Proposed Destruction of NIH: The administration's fiscal year 2026 budget proposed cutting NIH by more than 40 percent — a reduction that, if enacted, would eliminate entire research programs, force the termination of clinical trials mid-enrollment endangering patient safety, and drive thousands of American scientists abroad. The JAMA Health Forum published analysis estimating that cutting NIH by even 20 percent would result in an $8 trillion long-term reduction in healthcare productivity and economic value. NIH research contributed to treatments that saved over 90 percent of patients diagnosed with childhood leukemia, created the mRNA vaccine platform that ended the COVID-19 pandemic's acute phase, and produced the drug therapies that have transformed HIV from a death sentence into a manageable chronic condition.
Research Workforce Collapse: The NIH issued 24 percent fewer grants in 2025 compared to the prior decade's average. Researchers at American universities, many mid-study, faced funding terminations that halted clinical trials, destroyed research cohorts assembled over years, and forced early-career scientists out of research careers entirely. The United States risks losing a generation of scientific talent to institutions abroad.
Clinical Trial Participant Harm: The termination of active clinical trials mid-enrollment placed research participants in direct medical jeopardy. Patients enrolled in NIH-funded cancer trials, HIV treatment studies, cardiovascular disease research, and rare disease investigations lost access to experimental treatments from which they were already receiving benefit. The Common Rule (45 C.F.R. Part 46), which governs the ethical treatment of human research subjects, requires that researchers protect the welfare of enrolled participants and that IRBs review any termination of ongoing research for potential harm. Terminating trials by grant cancellation without IRB review of participant impact violated these federal research ethics requirements.
Brain Research Defunded: The BRAIN Initiative, a multi-year, multi-agency effort to map the human brain and develop treatments for neurological and psychiatric diseases including Alzheimer's, Parkinson's, depression, PTSD, and traumatic brain injury, faced severe cuts under the Trump administration's NIH reduction. The BRAIN Initiative represented one of the most ambitious federal research programs in American history, with estimated economic returns from successful treatment development far exceeding the research investment. Cutting brain research does not save money — it defers costs onto future patients, families, and the healthcare system.
What Project 2025 Did:
The Trump administration's budget eliminated or severely cut programs administered by the Substance Abuse and Mental Health Services Administration, cutting approximately $1 billion from SAMHSA. The Department of Justice simultaneously terminated $88 million in grants for substance abuse treatment, mental health services, and co-responder programs that paired law enforcement with mental health professionals to divert people in behavioral health crisis from jails to treatment. The administration also announced it would not enforce the final rule implementing the Mental Health Parity and Addiction Equity Act, abandoning legal requirements that insurers provide mental health benefits equivalent to physical health benefits.
These cuts arrived at a moment when the opioid crisis, though showing initial signs of improvement, had killed more than 80,000 Americans in 2024 and when youth mental health rates of anxiety, depression, and suicidality remained at historically high levels.
Youth Mental Health Crisis Abandoned: The U.S. Surgeon General issued an advisory in 2021 identifying youth mental health as a national crisis, with rates of adolescent depression, anxiety, and suicidal ideation at record levels. Federal investment in school-based mental health services, pediatric mental health training, and youth crisis intervention programs had begun to respond to this crisis. The Trump administration's cuts to SAMHSA and the abandonment of MHPAEA enforcement reversed this trajectory, leaving the generation of young Americans most affected by the COVID-19 pandemic's disruption without adequate public mental health infrastructure.
Rural Mental Health Desert Expansion: The combination of SAMHSA funding cuts, DOJ grant terminations for behavioral health programs, and the abandonment of MHPAEA enforcement disproportionately harmed rural communities, which already faced the greatest shortage of mental health providers. Rural Americans are significantly more likely than urban residents to live in mental health professional shortage areas, and they bear higher rates of suicide, substance use disorder, and unmet mental health need. Federal withdrawal from this crisis does not reduce the suffering — it transfers costs to emergency departments, county jails, and homeless shelters that are structurally incapable of providing the treatment that prevented admission to those institutions.
The damage from these actions is not abstract. Specific populations have borne specific harms:
- Approximately 76 million Medicaid and CHIP enrollees face coverage uncertainty as the administration imposes work requirements and proposes block grants
- At least 4.2 million Americans are projected to lose coverage if enhanced ACA subsidies are not restored
- Black women continue to die in childbirth at a rate of 50.3 per 100,000 live births — more than three times the rate for white women — in a country that has refused to treat maternal mortality as the public health emergency it is
- Thousands of NIH-funded clinical trial participants faced mid-study terminations as grants were cancelled, placing patients who had enrolled in medical research at direct risk
- An estimated 822,000 unintended pregnancies that Title X services would have prevented are now at risk annually as family planning funding is withdrawn
- Community health centers serving 30 million low-income Americans — the primary care safety net — face funding uncertainty as HRSA is targeted for restructuring
- State and local public health agencies, already understaffed, received grant clawbacks that forced them to halt infectious disease surveillance, immunization programs, and outbreak response operations
- The 5,844 terminated NIH grants represented the research careers of thousands of scientists and the treatment prospects of millions of patients enrolled in or anticipating clinical trials — losses that cannot be fully recovered even when funding is restored, because scientific talent lost to other countries and careers abandoned mid-training cannot simply be recalled
- Approximately 1.9 million Americans living in the eleven Medicaid non-expansion states — a coverage gap created by the Supreme Court's holding in NFIB v. Sebelius and perpetuated by state political refusal — continued to be denied coverage they would receive in any expansion state, while paying the same federal taxes
- The 20,000 HHS employees terminated in the restructuring represented decades of accumulated expertise in drug safety, food inspection, disease surveillance, child welfare, and public health emergency response that cannot be replaced through simple rehiring — institutional knowledge is lost, relationships with state and local counterparts are severed, and operational systems built over years must be rebuilt from damaged foundations
- Rural Americans faced the most acute consequences of the combined HHS cuts: loss of HRSA rural health grants, loss of SAMHSA behavioral health funding, loss of community health center capacity, and loss of the telehealth reproductive health services that had extended care to communities lacking local providers
- The 1 in 5 American adults living with mental illness faced a healthcare system increasingly unable to meet their needs as MHPAEA enforcement was abandoned, SAMHSA was defunded, and behavioral health providers dependent on federal grants and adequate insurance reimbursement lost the resources to operate
The federal government's authority over healthcare and public health rests primarily on three constitutional provisions.
The Spending Clause (U.S. Const. Art. I, § 8, cl. 1) grants Congress plenary authority to spend federal funds for the general welfare, including healthcare programs. The Supreme Court in South Dakota v. Dole, 483 U.S. 203 (1987), confirmed that Congress may attach conditions to federal spending even in areas otherwise reserved to the states, provided the conditions are related to the federal interest in the program. Medicaid, Medicare, ACA subsidies, Title X grants, and federal research funding all rest on this authority. The Spending Clause also has limits: NFIB v. Sebelius, 567 U.S. 519 (2012), held that Congress cannot coerce states into program participation by threatening to strip all Medicaid funding — a constraint that informs how Medicaid expansion must be structured to be legally sustainable.
The Commerce Clause (U.S. Const. Art. I, § 8, cl. 3) supports federal regulation of healthcare markets, pharmaceutical manufacturing and distribution, insurance markets, and interstate health commerce. Congress relied on the Commerce Clause in enacting the Food, Drug, and Cosmetic Act, HIPAA, and substantial portions of the ACA. Gonzales v. Raich, 545 U.S. 1 (2005), confirmed broad federal authority to regulate even local activities that have substantial effects on interstate commerce.
The Necessary and Proper Clause (U.S. Const. Art. I, § 8, cl. 18) supports congressional authority to establish and operate federal agencies like the FDA, CDC, and NIH as necessary and proper means of executing the commerce and spending powers.
Public Health Service Act (42 U.S.C. § 201 et seq.): The foundational statute for federal public health programs. Section 241 mandates that the Secretary conduct and support research into the causes, prevention, and treatment of disease. Section 300 et seq. establishes the Title X family planning program. Section 247d authorizes the Secretary to declare public health emergencies and deploy emergency resources.
Food, Drug, and Cosmetic Act (21 U.S.C. § 301 et seq.): Grants the FDA authority to regulate food safety, drug approval and post-market surveillance, and medical device safety. Section 355 establishes the new drug application process and requires approval based on substantial evidence of safety and efficacy — the legal standard under which mifepristone was approved in 2000 and which the administration cannot override through political directive.
Social Security Act (42 U.S.C. §§ 1395 et seq., 1396 et seq.): Titles XVIII and XIX establish Medicare and Medicaid respectively. Title XIX requires states to provide Medicaid coverage to categorically eligible populations and prohibits the Secretary from converting the entitlement to a block grant or per-capita cap without congressional authorization. Converting Medicaid to a block grant requires statutory authorization — it cannot be accomplished by executive action alone.
Affordable Care Act (42 U.S.C. § 18001 et seq.): Establishes the ACA marketplace infrastructure, premium tax credit subsidies, essential health benefits requirements, protections for people with pre-existing conditions, the Medicaid expansion framework, and numerous public health programs. NFIB v. Sebelius (2012) and California v. Texas, 593 U.S. 659 (2021), established the ACA's constitutional durability.
Mental Health Parity and Addiction Equity Act (29 U.S.C. § 1185a; 42 U.S.C. § 300gg-26): Requires group health plans and insurance issuers to provide mental health and substance use disorder benefits that are no more restrictive than comparable medical and surgical benefits. The final rule implementing MHPAEA, published in 2024, required insurers to conduct and document comparative analyses demonstrating parity. The Trump administration's announcement that it would not enforce this rule is legally questionable — non-enforcement of a clear statutory mandate is subject to challenge under the Administrative Procedure Act (5 U.S.C. § 706).
Title X Family Planning (42 U.S.C. § 300 et seq.): Establishes a grant program for family planning services and explicitly prohibits the use of program funds for abortion services. The Secretary has authority to set program priorities and eligibility criteria but may not abolish the program without congressional action.
HIPAA (42 U.S.C. § 1320d et seq.): Establishes minimum privacy protections for individually identifiable health information. Mandating state reporting of individualized abortion data without HIPAA-compliant privacy protections violates the statute's prohibition on unauthorized disclosures of protected health information.
The Trump administration's actions at HHS raised fundamental administrative law questions. Grant terminations imposed without notice-and-comment rulemaking, without individualized review of grant merit, and on the basis of ideological content violated the APA's prohibition on arbitrary and capricious agency action (5 U.S.C. § 706(2)(A)). Multiple federal courts issued injunctions blocking NIH grant terminations on these grounds. The Supreme Court's decision in Department of Education v. Brown, 600 U.S. 551 (2023), and West Virginia v. EPA, 597 U.S. 697 (2022), reinforce the principle that major policy changes require clear congressional authorization — a principle that applies to the attempted conversion of HHS into a "Department of Life" without any statutory mandate for that transformation.
The targeted termination of NIH research grants based on subject matter — singling out grants addressing vaccine hesitancy, health disparities, gender minority health, and DEI in clinical research — raises serious First Amendment concerns about viewpoint-based conditions on federal funding. While the government generally has authority to set conditions on its own spending under Rust v. Sullivan, 500 U.S. 173 (1991), and National Endowment for the Arts v. Finley, 524 U.S. 569 (1998), the systematic targeting of research based on its political implications — rather than its scientific merit — constitutes the kind of viewpoint discrimination that Agency for International Development v. Alliance for Open Society International, 570 U.S. 205 (2013), suggests has constitutional limits when conditions are designed to suppress disfavored viewpoints rather than merely define program boundaries.
The next administration will work with Congress to codify in statute that NIH grant peer review cannot include viewpoint-based criteria, and that no grant may be terminated solely on the basis of the subject matter it addresses without a documented scientific finding of merit deficiency under the established review standards of 42 U.S.C. § 289.
The administration's ACA and Medicaid restructuring proposals raised significant federalism questions regarding the scope of conditions Congress may attach to federal healthcare funding without converting cooperative programs into mandates. NFIB v. Sebelius established that Medicaid expansion could not be made a condition of existing Medicaid participation. Any federal fallback program to achieve universal Medicaid-equivalent coverage must be structured as a direct federal benefit rather than a coercive condition on state Medicaid programs.
Conversely, the Medication Abortion Access Act's federal preemption of state laws prohibiting telehealth prescription of mifepristone rests on the Supremacy Clause and the Commerce Clause: mifepristone is an FDA-approved drug that travels in interstate commerce, its prescription via telehealth involves interstate communications commerce, and the FDA's statutory authority to regulate drug distribution under 21 U.S.C. § 353 preempts conflicting state requirements that would add prescribing conditions beyond FDA's approved labeling. The Supreme Court's preemption jurisprudence under Geier v. American Honda Motor Co., 529 U.S. 861 (2000), and Wyeth v. Levine, 555 U.S. 555 (2009), supports this analysis: where Congress has established a comprehensive federal regulatory scheme for a product category, state law that conflicts with or frustrates that scheme is preempted.
Issue Executive Order reinstating all CDC employees terminated in the March 2025 reduction in force, reversing the dismantling of the Center for Global Health, the Office of Health Equity, and the immunization communications infrastructure. Restore the Administration for Strategic Preparedness and Response to its independent operating status within HHS, with a dedicated director confirmed by the Senate and protected from at-will termination by the same statutory protections that apply to independent agency heads.
Propose the CDC Independence and Scientific Integrity Act (see Legislative Requirements below) to establish by law that the CDC Director serves a fixed six-year term and may be removed only for cause; that scientific advisory committees are populated through merit-based processes free of political screening; and that CDC-issued health guidance may not be altered, suppressed, or withdrawn by the Secretary of HHS or the White House Office of Information and Regulatory Affairs without a documented scientific basis reviewed by the agency's own career scientists.
Issue a formal HHS policy statement affirming the scientific consensus on vaccine safety and efficacy, the evidence base for the childhood immunization schedule established by the Advisory Committee on Immunization Practices, and the federal government's commitment to evidence-based vaccine communications. Direct the CDC to rebuild and fully fund its immunization communications infrastructure, specifically including dedicated communications capacity targeting communities with declining vaccination rates and reversing the erosion of childhood vaccination rates documented in 2025. Appoint ACIP members exclusively on the basis of scientific credentials and active clinical or research expertise in immunology, infectious disease, or related fields, ending the Trump administration's practice of appointing individuals with documented records of vaccine skepticism to advisory positions.
Restore the National Center for Environmental Health to full operational status with all workforce positions eliminated in the Trump administration's restructuring. The NCEH conducts surveillance of chemical and environmental exposures, tracks lead poisoning rates in children, monitors the health effects of climate change, and provides the evidence base for EPA regulatory decisions that protect communities from toxic exposures. Cutting environmental health surveillance does not eliminate environmental health hazards — it eliminates the federal government's ability to detect and respond to them before they cause mass harm.
Commit $5 billion over four years to restore and expand the public health workforce at the federal, state, and local levels. The Centers for Disease Control has consistently documented that state and local health departments are dramatically understaffed relative to the populations they serve. The United States entered the COVID-19 pandemic with a public health workforce smaller per capita than at any time since the 1950s. This expansion will fund 50,000 new public health positions, including epidemiologists, contact tracers, environmental health specialists, community health workers, and public health informatics experts deployed through cooperative agreements with state and local health departments under 42 U.S.C. § 247b.
Establish a permanent Pandemic Preparedness and Response Office within HHS with guaranteed multi-year appropriations for the Strategic National Stockpile, the Biomedical Advanced Research and Development Authority, the Hospital Preparedness Program, and state and local preparedness cooperative agreements. Develop domestic manufacturing capacity for essential medicines, personal protective equipment, and medical countermeasures through the BARDA Other Transaction Authority (42 U.S.C. § 247d-7e), with a target of producing 80 percent of essential medicines domestically within ten years.
The Strategic National Stockpile must be maintained at levels capable of supporting a 90-day national emergency response for a disease affecting 30 percent of the population simultaneously, based on modeling from the Johns Hopkins Center for Health Security and the RAND Corporation's documented pandemic preparedness benchmarks. The COVID-19 pandemic revealed that the United States entered a global health emergency with an SNS depleted below these levels and a domestic manufacturing base that could not surge to meet demand for essential protective equipment. This failure cost American lives. It must not be repeated.
Restore the ASPR Hospital Preparedness Program to full funding and expand its scope to include climate-related health emergency preparedness — heat wave response planning, hurricane and flood health infrastructure, wildfire health impacts, and the emerging infectious disease risks associated with climate-driven vector expansion. Climate change is a public health emergency with documented mortality consequences that the federal government has a statutory obligation under 42 U.S.C. § 247d to address.
Restore U.S. leadership in global health security through full WHO engagement, reinstatement of U.S. funding for the WHO at levels commensurate with U.S. population and economic share, and restoration of U.S. participation in the International Health Regulations framework. The United States cannot protect itself from pandemic threats that respect no borders without investing in the surveillance, response, and containment capacity of the global health architecture. Withdrawal from WHO — the Trump administration's action in both the first and second terms — is an act of unilateral disarmament in the face of biological threats that endanger every American.
Issue Executive Order on Day One directing the FDA Commissioner to immediately withdraw the politically motivated safety review of mifepristone initiated in May 2025 and affirming that the 2000 approval of mifepristone and all subsequent regulatory actions expanding its access — including the 2016 and 2021 label updates — reflect the considered judgment of career agency scientists applying the statutory standard of 21 U.S.C. § 355 and will not be disturbed on non-scientific grounds.
Direct the Department of Justice to issue formal guidance clarifying that the Comstock Act (18 U.S.C. §§ 1461-1462) does not prohibit the interstate shipment of mifepristone or any other FDA-approved medication abortion drug when lawfully prescribed, consistent with the Postal Service's established interpretation and the Biden administration's 2022 DOJ opinion.
Propose legislation codifying the right to access mifepristone and medication abortion drugs via mail and telehealth prescription as federal law, preempting state prohibitions on these lawful means of prescribing and dispensing FDA-approved medication. Model this legislation on the framework established in Whole Woman's Health v. Hellerstedt, 579 U.S. 582 (2016), requiring that any restriction on abortion access be justified by a genuine health benefit that outweighs the burden imposed.
Restore all 3,500 FDA employees terminated in the March 2025 workforce reduction. Commission an independent audit by the Government Accountability Office of the impact of the workforce reductions on FDA review timelines, food safety inspection capacity, drug surveillance operations, and public communications. Use audit findings to develop a five-year FDA staffing plan submitted to Congress as required by 21 U.S.C. § 393(d).
Establish by regulation the FDA Scientific Integrity Officer as a Senate-confirmed position protected from at-will termination, with authority to investigate, document, and publicly report on instances of political interference in FDA scientific determinations. This mechanism does not exist in current statute; creating it addresses the structural vulnerability the Trump administration exploited.
Enact the FDA User Fee Modernization Act to restructure PDUFA, MDUFA, GDUFA, and BsUFA user fee agreements to: increase the proportion of funding from congressional appropriations relative to industry user fees, reducing the structural conflict of interest created when the FDA's operating budget depends primarily on fees paid by the entities it regulates; increase FDA post-market surveillance authority and funding; and fund a dedicated Division of Drug Safety Communications with staffing sufficient to communicate safety signals to healthcare providers and the public within 30 days of detection.
Direct the FDA to accelerate implementation of the National Action Plan for Combating Antibiotic-Resistant Bacteria, including enhanced enforcement of antibiotic stewardship requirements in animal agriculture under the Veterinary Feed Directive (21 C.F.R. Part 558), expansion of antibiotic stewardship programs as a Medicare and Medicaid quality measure, and federal investment in the BARDA antibiotic development program to address the market failure that has produced an insufficient pipeline of new antibiotics. The CDC estimates that antimicrobial-resistant infections kill approximately 35,000 Americans annually and threaten to render common infections and routine surgeries life-threatening — a public health crisis comparable in scope to the opioid epidemic that receives a fraction of the policy attention.
Strengthen FDA authority over medical devices under 21 U.S.C. § 360c by eliminating the 510(k) substantial equivalence pathway for Class III devices — the highest-risk category — and requiring premarket approval with clinical evidence for all devices that pose serious risk of patient harm. The existing 510(k) pathway allows high-risk devices to reach the market by demonstrating similarity to existing devices, even when those predicates themselves had inadequate safety evidence. This systemic failure has contributed to device-related patient injuries documented by FDA's MAUDE adverse event database. Fully fund the Center for Devices and Radiological Health's postmarket surveillance mission and require mandatory reporting of all device-related adverse events from hospitals and outpatient facilities.
Accelerate implementation of the Food Safety Modernization Act (Pub. L. 111-353) inspection requirements for produce and processed food facilities. Increase FDA food safety inspection funding to achieve the inspection frequency required by statute, which the agency has historically been unable to meet due to chronic resource constraints.
Propose legislation making permanent the enhanced premium tax credits enacted under the American Rescue Plan Act and extended through the Inflation Reduction Act. These credits, which limit marketplace premiums to no more than 8.5 percent of household income for all income levels, drove ACA enrollment to a record 21.4 million Americans. Their expiration would cause at least 4.2 million Americans to lose coverage. Making them permanent provides market stability that enables insurers to offer more competitive products.
Propose a federal public health insurance option available to all Americans on the ACA marketplace and to employers who wish to offer it as an alternative to private coverage. The public option would offer comprehensive essential health benefits, negotiate provider rates based on a percentage of Medicare rates, and be available without income limits. This option would create market competition that drives down premiums and gives every American a guaranteed alternative to private insurance.
Create a federal fallback program providing Medicaid-equivalent coverage to individuals in the eleven states that as of 2025 have refused to expand Medicaid under the ACA. Use the Spending Clause authority to create this program as a direct federal benefit, eliminating the coverage gap that has denied Medicaid to approximately 1.9 million Americans in non-expansion states who earn too much to qualify for traditional Medicaid but too little to qualify for ACA subsidies. In parallel, increase the federal matching rate for newly expanding states to 100 percent for the first three years, creating strong financial incentives for final holdout states to adopt expansion.
Codify in statute the ACA's prohibition on pre-existing condition exclusions (42 U.S.C. § 300gg-3), community rating requirements, and essential health benefits requirements, making these protections permanent and explicitly eliminating any future waiver authority that would allow states to circumvent them.
Propose the Medicare Comprehensive Benefits Act to add dental, vision, and hearing coverage to traditional Medicare, covering approximately 65 million beneficiaries. Approximately 68 percent of Medicare beneficiaries have no dental insurance, resulting in untreated dental disease that is associated with heart disease, diabetes, and stroke. The oral health — general health connection is well-established in the medical literature; excluding dental care from Medicare is both arbitrary and medically indefensible.
Protect and expand the Medicare drug price negotiation authority enacted in the Inflation Reduction Act (Pub. L. 117-169, § 11001, codified at 42 U.S.C. § 1320f). The first round of negotiated prices achieved reductions of 38 to 79 percent on ten high-cost drugs used by approximately 9 million beneficiaries, with new prices taking effect January 1, 2026. Defend this authority in ongoing industry litigation, expand the number of drugs subject to negotiation from 10 in year one to 50 by year four, and use the negotiated prices as a benchmark for Medicaid drug pricing as well.
Establish a federal long-term care benefit under Medicare that covers home and community-based services, adult day care, and nursing facility care for Medicare beneficiaries who meet functional eligibility criteria. The United States is the only high-income country without a universal long-term care program. As the population ages, the absence of such a program is forcing families into impoverishment through spend-down rules and leaving millions of disabled and elderly Americans without needed care.
The long-term care workforce — home health aides, personal care attendants, certified nursing assistants — is among the lowest-paid in the American economy, with median wages that leave workers in poverty while performing physically demanding, emotionally intensive work caring for the nation's most vulnerable population. Any sustainable long-term care program must include workforce investments: living wages, benefits, training support, and career advancement pathways for the workers who will deliver care. Direct CMS to develop a long-term care workforce strategy as a condition of the expanded Medicare benefit, including wage floor requirements for providers receiving Medicare and Medicaid long-term care reimbursement.
Direct CMS to implement comprehensive Medicare Advantage oversight reforms to address documented overpayment, denial of care, and network adequacy failures that have cost the Medicare program billions of dollars while harming beneficiaries. Specific reforms include: mandatory prior authorization transparency reporting with 30-day denial appeal resolution; real-time audit of risk adjustment coding accuracy with financial clawbacks for documented upcoding; minimum medical loss ratio requirements ensuring that at least 85 percent of premiums are spent on patient care; network adequacy standards with enforceable time-and-distance requirements for all specialty types; and annual independent audit by the HHS Inspector General of the ten largest Medicare Advantage plans. Propose the Medicare Advantage Accountability Act to codify these requirements in statute and establish civil monetary penalties for non-compliant plans.
Issue Executive Order on Day One restoring all Title X funding frozen by the Trump administration and directing HHS to process all pending grant applications under the program rules established by the Biden administration's 2021 regulation, which restored referral requirements for the full range of pregnancy-related services including abortion. Propose increasing Title X annual funding from approximately $400 million to $750 million over four years to enable the program to reach its entire target population of low-income Americans who lack adequate access to contraception and reproductive healthcare.
Direct CMS to establish Medicaid coverage requirements for comprehensive reproductive healthcare services, including contraception, STI screening and treatment, pregnancy-related care, and referrals for all legal reproductive health services. Eliminate administrative barriers — prior authorization, waiting periods, and referral requirements — that apply specifically and uniquely to reproductive health services, which create discriminatory barriers to care that no comparable category of primary care faces.
Issue regulations clarifying that federal conscience protections for healthcare providers (42 U.S.C. § 238n, 42 U.S.C. § 300a-7) do not permit refusal of care in emergencies, refusal to provide the standard of care in urgent circumstances, or refusal to make medically necessary referrals for services a provider declines to perform. Conscience protections exist to protect providers from participating in procedures they object to — they do not and cannot authorize the abandonment of patients in medical distress.
Issue guidance requiring all Medicaid managed care plans and ACA marketplace plans to cover all FDA-approved contraceptive methods without cost-sharing, consistent with the ACA's preventive services requirement (42 U.S.C. § 300gg-13) and the Supreme Court's holding in Zubik v. Burwell, 578 U.S. 403 (2016), that the government has a compelling interest in ensuring contraceptive access.
Direct FDA to streamline the over-the-counter drug application review process for additional contraceptive methods, building on the successful OTC approval of Opill (norgestrel) in 2023 — the first FDA-approved OTC oral contraceptive. OTC contraceptive availability reduces barriers for women who face difficulty accessing healthcare providers for contraceptive prescriptions, including those in rural areas, those without insurance, and those in states where providers have exercised conscience refusals. This access expansion requires no change in statutory authority; it requires only the FDA regulatory action and the political will to prioritize it.
Issue CMS guidance clarifying the application of the Emergency Medical Treatment and Labor Act (42 U.S.C. § 1395dd) to obstetric emergencies, specifically affirming that EMTALA requires hospitals to provide stabilizing treatment — including abortion when necessary to preserve the patient's life or health — regardless of state abortion laws. The Trump administration reversed Biden administration EMTALA guidance that made this affirmation, creating ambiguity that caused providers in states with abortion prohibitions to deny emergency obstetric care out of fear of prosecution. This denial of emergency care is not hypothetical — documented cases of women denied emergency abortion care resulted in near-fatal outcomes in multiple states. The federal EMTALA obligation is clear; the next administration must enforce it without equivocation.
Issue Executive Order directing NIH to reinstate all research grants terminated after January 20, 2025, except those cancelled through the established peer review and scientific merit process. Direct the NIH Office of Research Integrity to investigate each termination for compliance with the procedural requirements of 42 U.S.C. § 289 and the Administrative Procedure Act, and to report findings to Congress within 180 days.
Propose increasing NIH annual appropriations by 20 percent per year for four years, reaching approximately $77 billion by year four. Direct NIH to prioritize funding for: research on health disparities and the social determinants of health; climate and environmental health; emerging infectious diseases and pandemic preparedness; mental health and substance use disorders; maternal and reproductive health; and rare diseases. Restore all diversity supplements, minority-serving institution research grants, and health equity research programs cancelled by the Trump administration.
Propose the NIH Independence and Research Integrity Act to establish that: NIH grant funding decisions are made exclusively through peer review; NIH Directors of the institutes and centers serve fixed terms and may be removed only for cause; and no political appointee may direct the termination, suspension, or ideological screening of research grants. Grant terminations for scientific reasons must proceed through established processes with documented scientific justification.
Restore U.S. participation in all international health research collaborations severed by the Trump administration, including World Health Organization programs, Global Health Security Agenda partnerships, and bilateral research agreements. The United States cannot effectively combat pandemic threats, antibiotic resistance, or emerging infectious diseases without robust international scientific cooperation.
Restore and expand the NIH National Institute on Minority Health and Health Disparities (NIMHD) budget by 50 percent over four years, making it one of the ten largest NIH institutes. The United States has documented, persistent, and widening racial disparities in health outcomes across virtually every disease category: cancer, cardiovascular disease, diabetes, maternal mortality, mental health, and infectious disease. These disparities are not explained by genetics — they are explained by structural racism, differential access to care, differential exposure to environmental hazards, and differential treatment by the healthcare system. NIH investment in disparities research is the foundation for the evidence base needed to design interventions that close these gaps.
Require all NIH-funded clinical trials to enroll participants reflecting the demographic composition of the population likely to use the treatment being studied, and to analyze and report outcomes stratified by race, ethnicity, sex, age, and disability status. The FDA's existing guidance on diverse clinical trial populations (FDA-2020-D-1124) should be elevated to regulatory requirement with enforcement authority for non-compliant trial sponsors. Drug approvals based on trials that systematically excluded women, people of color, and elderly patients have produced medications with unknown efficacy and safety profiles in the populations who need them most.
Issue Executive Order on Day One directing HHS, DOL, and Treasury to immediately resume enforcement of the Mental Health Parity and Addiction Equity Act final rule (published 2024), which the Trump administration announced it would not enforce. Direct the Departments to initiate enforcement actions against the fifty largest insurers for documented MHPAEA violations, with published results, within 180 days of the order.
Propose the Mental Health Parity Enforcement Act to give the Departments explicit authority to impose civil monetary penalties of up to $100 per day per affected beneficiary on insurers that fail to demonstrate parity, eliminating the prior-authorization disparity, network adequacy disparity, and benefit limitation disparity that systematically disadvantaged mental health and substance use coverage relative to medical coverage.
Restore the $1 billion in SAMHSA funding cut by the Trump administration and propose an additional $2 billion in annual SAMHSA appropriations over four years, targeted at:
- Opioid Treatment Program expansion under 42 U.S.C. § 257(b)(3)(B), funding 2,000 new opioid treatment program sites nationally in underserved areas
- Buprenorphine prescribing expansion by eliminating all remaining federal barriers to office-based opioid treatment, including the DATA 2000 waiver requirements that the Mainstreaming Addiction Treatment Act of 2023 began dismantling
- Naloxone access expansion, fully funding naloxone distribution in all 50 states through the Community Services Block Grant and state opioid response grants
- Youth mental health crisis services, funding a national 988 Suicide and Crisis Lifeline capable of meeting the actual volume of contacts and dispatching mobile crisis teams in every major metropolitan area
Restore and expand the DOJ grants for mental health-law enforcement co-responder programs cut by the Trump administration. Propose transferring the primary federal funding mechanism for these programs from DOJ to SAMHSA, recognizing that mental health crisis response is a healthcare function, not a law enforcement function, and that co-responder programs reduce both incarceration and mortality.
Declare youth mental health a national public health emergency under the authority of 42 U.S.C. § 247d and deploy emergency resources including: federal grants to states for school-based mental health services serving all K-12 students; funding for training 50,000 additional mental health counselors and social workers for school deployment through a new School Mental Health Workforce Corps; national 988 crisis line expansion to meet actual call volume with meaningful response capacity including mobile crisis teams dispatched within 30 minutes in all metropolitan areas; and mandatory coverage of youth mental health services without prior authorization or visit limits for all Medicaid managed care plans serving children and adolescents.
Require all state Medicaid programs to cover behavioral health screenings using validated assessment tools (PHQ-A for adolescent depression, CRAFFT for substance use, SCARED for anxiety) at all well-child visits beginning at age 12, with immediate referral pathways and covered treatment — not just covered screenings that lead to six-month waits for a first treatment appointment. Screening without treatment capacity is not a public health intervention; it is a documentation exercise that does not reduce suffering.
Expand SAMHSA grants for peer recovery support services, which deploy people with lived experience of substance use disorder and recovery to support individuals seeking or maintaining recovery. Peer recovery support is among the most cost-effective evidence-based interventions in the substance use treatment continuum, with documented effectiveness in reducing relapse, increasing treatment engagement, and building community recovery infrastructure in areas with insufficient clinical provider supply. Establish a national certification framework for peer recovery specialists and require Medicaid coverage of peer support services as a covered benefit in all state programs under the authority of 42 C.F.R. § 440.130.
Propose comprehensive legislation implementing the full package of the Black Maternal Health Momnibus Act, including:
- Mandatory implicit bias training for all providers delivering federally funded obstetric care
- Funding for community-based doula programs serving Medicaid beneficiaries
- Maternal mental health integration in obstetric care settings
- Rural maternal care infrastructure grants targeting maternal care deserts
- Data collection requirements that enable systematic identification of racial disparities in maternal outcomes by hospital, provider, and state
Extend mandatory Medicaid postpartum coverage to twelve months in all states, building on the American Rescue Plan Act's temporary five-year option that many states have exercised. The postpartum period is when maternal mortality risk is highest; cutting off Medicaid coverage at 60 days postpartum — the prior rule — exposed the most vulnerable new mothers to the precise period of highest risk without coverage. Twelve months is the minimum appropriate standard.
Fund maternal mortality review committees in all 50 states and territories through CDC grants under 42 U.S.C. § 247b-12, with standardized data collection protocols that enable national comparisons and federal action on identified systemic causes. Currently, fewer than half the states have fully functioning maternal mortality review committees that report standardized data to CDC. This gap in surveillance infrastructure is itself a contributing cause of the mortality crisis.
Direct HRSA to expand the National Health Service Corps, the Teaching Health Center Graduate Medical Education program, and the Rural Health Clinic program to specifically address the obstetric care workforce shortage in rural and underserved areas. The United States has thousands of counties designated as Maternity Care Health Professional Shortage Areas. This is not an information gap — it is a failure of political will to fund the solutions that the data clearly identifies.
Fund the Midwifery Access Initiative to increase the certified nurse-midwife and certified midwife workforce serving underserved communities by 5,000 providers over four years through National Health Service Corps loan repayment, graduate medical education expansion at accredited midwifery programs, and Medicaid rate parity between CNM and OB/GYN reimbursement for identical services. Evidence from high-income countries with midwifery-centered maternity care systems demonstrates superior maternal and infant outcomes at lower cost than the predominantly physician-centered model that has produced the United States' uniquely poor maternal mortality record among peer nations.
Require all state Medicaid programs to cover comprehensive perinatal mental health services — screening, diagnosis, and evidence-based treatment for perinatal depression, anxiety, PTSD, and related disorders — as an essential component of prenatal and postpartum care. Perinatal mood and anxiety disorders affect approximately 1 in 5 pregnant and postpartum women, are the most common complication of pregnancy and childbirth, and are a leading contributor to maternal mortality through suicide and substance use. Despite this prevalence, perinatal mental health services remain underfunded, understaffed, and excluded from or inadequately reimbursed by insurance. Issue CMS guidance specifying minimum coverage requirements for perinatal mental health services under Medicaid managed care contracts and establishing quality metrics for perinatal mental health screening and treatment completion.
Elevate the Office of Minority Health from an office within HHS to a sub-agency with independent budget authority and a presidentially appointed director, modeled on the structure proposed in the REAL Act. Require every HHS agency to submit an annual health equity action plan with measurable targets, progress reporting, and consequences for failure to meet benchmarks.
Direct CMS to develop and implement value-based payment models for Medicaid and Medicare that explicitly incentivize providers to address social determinants of health — housing instability, food insecurity, transportation barriers, and social isolation — which account for approximately 30-55 percent of health outcomes. Use the Center for Medicare and Medicaid Innovation (42 U.S.C. § 1315a) to test and scale models that integrate social service navigation into primary care.
Coordinate with the EPA to ensure that communities of color and low-income communities facing disproportionate environmental health burdens — including air pollution, lead exposure, contaminated water, and proximity to industrial facilities — receive priority in both regulatory enforcement and community health investment. Use HRSA's Environmental Health Training in Emergency Response program to build environmental health capacity in communities facing the greatest pollution burdens.
Establish a Federal Interagency Task Force on Environmental Justice and Health, jointly chaired by the HHS Secretary and the EPA Administrator, charged with developing a National Environmental Health Equity Action Plan within 180 days of the administration's start. The Task Force will map the geographic overlap between pollution exposure, health outcome disparities, and federal program investment, identify the communities bearing the greatest cumulative environmental burden, and develop coordinated federal investment strategies targeting those communities with resources from HHS, EPA, HUD, and DOT.
Issue binding guidance under Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d) and the ACA's Section 1557 (42 U.S.C. § 18116) clarifying that all healthcare entities receiving federal financial assistance must provide meaningful language access services — qualified medical interpreters, translated vital documents, and bilingual patient navigators — for all patients with limited English proficiency. Restore the Biden administration's robust Section 1557 anti-discrimination rule, which the Trump administration weakened, and expand its application to cover gender identity, sexual orientation, disability status, and immigration status as protected characteristics in federally funded healthcare settings.
The evidence demonstrates that language barriers in healthcare result in medical errors, treatment non-adherence, delayed diagnoses, and patient harm at rates significantly higher than for English-proficient patients. Language access is not a courtesy — it is a patient safety requirement and a legal obligation under federal civil rights law.
Restore all HRSA programs disrupted by the Trump administration's restructuring, including the Health Center Program, the National Health Service Corps, the Ryan White HIV/AIDS Program, and the Maternal and Child Health Block Grant. Propose increasing Health Center Program funding by $2 billion over four years to expand the number of community health center sites from approximately 1,400 to 2,000, adding capacity to serve an additional 5 million patients annually.
Community health centers serve approximately 30 million patients annually at 15,000 delivery sites — the largest primary care system in the United States serving people regardless of their ability to pay. For every dollar invested in community health centers, studies estimate $6 to $8 in downstream healthcare cost savings through prevention and early intervention. This is among the most cost-effective investments in the federal health portfolio.
Fully fund all Ryan White HIV/AIDS Program parts (42 U.S.C. § 300ff et seq.) and direct HRSA to develop a five-year plan for ending the HIV epidemic consistent with the Ending the HIV Epidemic in the U.S. initiative, targeting a 75 percent reduction in new HIV infections by 2030 and a 90 percent reduction by 2035. Expand HIV pre-exposure prophylaxis (PrEP) access through federally funded health centers and Medicaid, eliminating cost-sharing requirements for a medication that prevents transmission of a preventable viral infection.
The CDC estimates that approximately 1.2 million Americans currently live with HIV, with approximately 35,000 new infections annually. Despite the availability of effective antiretroviral therapy that suppresses viral load to undetectable levels — eliminating transmission risk entirely — disparities in access to testing, PrEP, and treatment mean that Black Americans bear a disproportionate burden of new HIV infections and AIDS-related mortality. Ending the HIV epidemic requires targeted investment in the communities most affected, not merely expanding the programs that serve those who have already successfully navigated the existing system.
Restore and expand funding for healthcare-based domestic violence and sexual assault response programs administered by HRSA, including training for healthcare providers to identify and respond to domestic violence, Sexual Assault Nurse Examiner programs in all hospital emergency departments, and hospital-based violence intervention programs that connect victims with housing, legal aid, and safety planning services. The healthcare system is frequently the first point of contact for domestic violence victims outside the home; healthcare providers trained to identify and respond to domestic violence can interrupt cycles of abuse that would otherwise continue for years and escalate to lethal violence.
Direct CMS to require all Medicaid managed care plans to cover SANE forensic examination services without prior authorization, without notification to a partner or family member, and without billing the patient — consistent with the Violence Against Women Act's prohibition on charging victims for the cost of medical forensic examinations.
- Issue Executive Order withdrawing the FDA's mifepristone safety review and reaffirming the 2000 FDA approval and all subsequent regulatory actions as scientifically sound and legally valid
- Issue Executive Order restoring all Title X grants frozen by the Trump administration and directing processing of all pending applications under Biden-era program rules
- Issue Executive Order directing NIH to reinstate all research grants terminated without peer review process after January 20, 2025 and prohibiting future terminations outside the established 42 U.S.C. § 289 review process
- Issue Executive Order directing HHS to immediately resume full enforcement of the Mental Health Parity and Addiction Equity Act final rule abandoned by the Trump administration
- Issue Executive Order directing HHS Secretary to begin reinstatement proceedings for all employees terminated in the March 2025 and subsequent workforce reductions
- Issue Executive Order withdrawing any guidance, regulation, or policy designating HHS as a "Department of Life" or establishing an anti-abortion task force within HHS
- Issue Executive Order establishing that reproductive healthcare — including contraception, abortion, and fertility services — is a component of essential primary healthcare within HHS's statutory public health mission
- Revoke conscience clause regulations expanded by the Trump administration to permit patient abandonment in emergency circumstances; restore the duty to refer standard for providers who decline to perform legal medical procedures
- Issue memorandum to FDA Commissioner directing resumption of standard scientific review processes for all pending regulatory actions, withdrawing any White House instructions regarding specific drug or device regulatory decisions, and restoring the FDA's independent scientific communications function
- Restore staff responsible for federal poverty guideline calculations and direct publication of updated guidelines within 60 days, ending the freeze that threatened eligibility determinations for tens of millions of Americans
- Issue memorandum directing DOJ to publish formal guidance clarifying that the Comstock Act does not prohibit interstate shipment of lawfully prescribed mifepristone or misoprostol
- Issue Executive Order establishing the Federal Interagency Task Force on Environmental Justice and Health, jointly chaired by the HHS Secretary and EPA Administrator
- Issue Executive Order directing ASPR restoration to independent operating status and mandating a 90-day Strategic National Stockpile assessment
- Direct CDC to immediately reinstate the Office of Health Equity, Center for Global Health, and all immunization communications positions eliminated in the March 2025 restructuring
- Submit to Congress the CDC Independence and Scientific Integrity Act, the NIH Independence and Research Integrity Act, and the Mental Health Parity Enforcement Act
- Submit to Congress the Permanent ACA Subsidy and Public Option Act and the Medicaid expansion federal fallback program legislation
- Submit to Congress the Medicare Comprehensive Benefits Expansion Act and the Medication Abortion Access Act
- Submit to Congress the Black Maternal Health Momnibus Act (Comprehensive Version) and the Community Health Center Expansion and Primary Care Access Act
- Appoint an HHS Secretary committed to scientific integrity and the department's statutory public health mission; nominate CDC Director for Senate-confirmed fixed six-year term
- Nominate FDA Commissioner with career regulatory background and documented commitment to scientific independence from political direction
- Publish interim final rule restoring Biden-era Title X regulations requiring referral for the full range of pregnancy-related services
- Begin competitive grant process to restore terminated NIH research programs; direct NIH to prioritize clinical trial resumptions for trials with enrolled participants
- Issue HHS reorganization order restoring ASPR to independent operating status with dedicated Senate-confirmed director
- Direct CMS to submit within 90 days a plan for achieving full Medicaid expansion in all states, including the federal fallback mechanism for holdout states
- Restore U.S. membership in WHO, resume full funding obligations, and rejoin Global Health Security Agenda
- Begin reinstating all CDC employees terminated in March 2025 and subsequent workforce reductions
- Rebuild CDC Office of Health Equity, Center for Global Health, and National Center for Immunization and Respiratory Diseases
- Publish HHS reorganization plan rescinding the "Department of Life" framework and all associated anti-abortion policy infrastructure established under the Trump administration
- Issue CMS guidance clarifying EMTALA application to obstetric emergencies in states with abortion prohibitions
- Restore FDA communications infrastructure eliminated in the March 2025 workforce reduction
- Begin GAO audit of FDA and HHS workforce reduction impacts on public safety and regulatory capacity
- Direct HHS Inspector General to investigate all NIH grant terminations for APA compliance and report findings within 90 days
- Issue formal regulatory guidance clarifying that the Comstock Act does not prohibit interstate shipment of lawfully prescribed mifepristone
- Convene national commission on pandemic preparedness to assess current stockpile adequacy and domestic manufacturing gaps
- Launch Youth Mental Health National Initiative as a declared public health priority with initial SAMHSA grant competition for school-based mental health programs
- Enact permanent ACA enhanced premium tax credits through the Permanent ACA Subsidy Act
- Begin Medicaid expansion federal fallback program in states that have not expanded, providing immediate coverage to approximately 1.9 million Americans in the coverage gap
- Complete reinstatement of all unlawfully terminated HHS employees; issue new competitive hiring authority for 50,000-position public health workforce expansion
- Launch public health workforce expansion through state cooperative agreements under 42 U.S.C. § 247b, prioritizing counties in the bottom quintile for public health worker ratios
- Complete first round of expanded Medicare drug price negotiations targeting 20 additional high-cost drugs, including insulin, GLP-1 medications, and cancer drugs
- Establish federal poverty guideline calculation infrastructure with automatic annual updates indexed to CPI-U
- Begin community health center expansion program with first round of new site grants, prioritizing maternal care deserts and rural health professional shortage areas
- Achieve full MHPAEA enforcement against the 20 largest health insurers with documented parity violations
- Fund maternal mortality review committees in all 50 states and territories with standardized CDC data protocols
- Launch Ending the HIV Epidemic accelerated program with expanded PrEP access through all FQHCs and Medicaid
- Submit the Black Maternal Health Momnibus Act for congressional enactment with full funding commitments
- Publish NIH research restoration progress report documenting grant reinstatements, clinical trial resumptions, and restored research programs
- Issue HHS Section 1557 anti-discrimination rule reinstating Biden-era protections for gender identity, sexual orientation, and immigration status
- Restore EMTALA guidance affirming federal obligation to provide emergency abortion care when medically necessary regardless of state law
- Establish the Pandemic Preparedness and Response Office within HHS with guaranteed multi-year appropriations
- Restore U.S. WHO membership and full engagement in the Global Health Security Agenda
- Issue formal HHS policy statement affirming CDC vaccine safety consensus and childhood immunization schedule evidence base
- Complete HRSA program restoration: Health Center Program, Ryan White Program, National Health Service Corps, Maternal and Child Health Block Grant
- Begin competitive grant process for opioid treatment program expansion to 2,000 new sites in underserved communities
- Issue CMS guidance requiring Medicaid managed care coverage of perinatal mental health services as essential primary care
- Propose the Medicare Advantage Accountability Act with mandatory audit, prior authorization transparency, and network adequacy requirements
- Complete passage and implementation of Medicare dental, vision, and hearing benefit through the Medicare Comprehensive Benefits Expansion Act
- Achieve 50-drug Medicare negotiation target, generating estimated savings of $100 billion over ten years
- Enact federal public option legislation with marketplace availability in all 50 states and employer option for businesses with more than 50 employees
- Achieve 45-state Medicaid expansion through a combination of voluntary expansion and federal fallback program, reducing the uninsured rate to below 4 percent nationally
- Achieve 2,000 federally qualified health center site target, expanding primary care access to 35 million Americans
- Complete NIH funding restoration to pre-Trump levels and advance the 20 percent annual increase trajectory toward a four-year target of $77 billion
- Implement all Black Maternal Health Momnibus Act provisions with state grant awards, doula program launches, and implicit bias training requirements
- Achieve full SAMHSA funding restoration and opioid treatment program expansion to 2,000 new sites
- Implement long-term care Medicare benefit with phased-in eligibility beginning with beneficiaries meeting the highest functional need criteria
- Complete HHS scientific integrity institutional reforms — fixed terms, removal protections, independent scientific integrity officers at FDA, CDC, and NIH — across all major constituent agencies
- Publish first annual HHS Health Equity Progress Report with agency-specific measurable benchmarks and public accountability
- Complete pandemic preparedness infrastructure investment: Strategic National Stockpile at 90-day capacity, BARDA domestic manufacturing partnerships operational, Hospital Preparedness Program fully funded
- Achieve Medicare Advantage oversight reforms with first annual independent audits of major plans published
- Complete long-term care workforce living wage initiative with Medicaid rate increases tied to wage floor requirements for home health workers
- Restore and expand BRAIN Initiative with focus on early detection technologies for Alzheimer's and Parkinson's disease
- Achieve full Section 1557 anti-discrimination enforcement in all federally funded healthcare settings, including comprehensive language access compliance audits of major hospital systems and health plans
- Complete domestic violence and sexual assault healthcare response program expansion with SANE programs operational in all hospital emergency departments receiving federal reimbursement
- Purpose: Insulate CDC scientific operations and public health guidance from political interference by establishing statutory protections for CDC leadership and scientific processes
- Key Provisions: Fixed six-year term for CDC Director, removal only for cause; merit-based scientific advisory committee selection free of political screening; prohibition on political appointee alteration of CDC public health guidance without documented scientific basis; independent Inspector General for scientific integrity within CDC; whistleblower protections for career scientists who report political interference
- Constitutional Authority: Spending Clause, Art. I, § 8, cl. 1; Necessary and Proper Clause, Art. I, § 8, cl. 18; 42 U.S.C. § 201 et seq.
- Purpose: Protect NIH grant-making from political interference and establish statutory protections ensuring that research funding decisions are based on scientific merit
- Key Provisions: All grant funding decisions made exclusively through peer review under 42 U.S.C. § 289; NIH institute and center directors serve fixed five-year terms, removable only for cause; prohibition on political appointee direction of grant terminations; mandatory documentation of scientific basis for any grant action; civil penalty of $50,000 per grant for violations; enhanced whistleblower protections for researchers who report interference
- Constitutional Authority: Spending Clause, Art. I, § 8, cl. 1; Necessary and Proper Clause; 42 U.S.C. § 241
- Purpose: Provide HHS, DOL, and Treasury with explicit enforcement authority and civil penalty powers to achieve full compliance with the Mental Health Parity and Addiction Equity Act
- Key Provisions: Civil monetary penalties of up to $100 per day per affected beneficiary for documented parity violations; mandatory comparative analysis publication requirement for all group health plans; independent parity compliance audits for plans covering more than 100,000 beneficiaries; private right of action for plan beneficiaries denied mental health benefits in violation of parity; annual HHS report to Congress on MHPAEA compliance and enforcement actions
- Constitutional Authority: Commerce Clause, Art. I, § 8, cl. 3; 29 U.S.C. § 1185a; 42 U.S.C. § 300gg-26
- Purpose: Make enhanced ACA premium tax credits permanent and establish a federal public option available on all ACA marketplaces
- Key Provisions: Permanent extension of Inflation Reduction Act enhanced premium tax credits at all income levels; establishment of a federal public health insurance option available on ACA marketplaces and to employers, offering comprehensive essential health benefits; federal public option provider rate setting at 110 percent of Medicare rates; elimination of income cap for premium tax credit eligibility; automatic enrollment mechanism for individuals transitioning from Medicaid
- Constitutional Authority: Spending Clause; Commerce Clause; 42 U.S.C. § 18001 et seq.; Internal Revenue Code § 36B
- Purpose: Eliminate the Black maternal mortality gap through targeted investment in workforce, data, community-based care, and healthcare system accountability
- Key Provisions: Mandatory twelve-month Medicaid postpartum coverage in all states; federal grants for community-based doula programs serving Medicaid beneficiaries, targeting 10,000 trained doulas in underserved communities within five years; mandatory implicit bias training as a condition of federal reimbursement for obstetric providers; standardized maternal mortality review committee data collection in all states with annual CDC publication; rural obstetric care infrastructure grants targeting Maternity Care Health Professional Shortage Areas
- Constitutional Authority: Spending Clause; 42 U.S.C. §§ 1396 et seq.; 42 U.S.C. § 247b-12
- Purpose: Codify federal protection for access to FDA-approved medication abortion drugs and establish that state laws may not prohibit their prescription via telehealth or dispensing via mail
- Key Provisions: Federal preemption of state laws prohibiting prescription of mifepristone or misoprostol via telehealth by a licensed provider; federal preemption of state laws prohibiting dispensing of FDA-approved medication abortion drugs via mail; clarification that 18 U.S.C. §§ 1461-1462 (Comstock Act) does not apply to lawfully prescribed medications; private right of action for patients and providers whose access is prohibited by state laws preempted by this Act; civil monetary penalties for state officials who enforce preempted restrictions
- Constitutional Authority: Supremacy Clause, Art. VI; Commerce Clause, Art. I, § 8, cl. 3; 21 U.S.C. § 355
- Purpose: Add dental, vision, and hearing coverage to traditional Medicare, eliminating arbitrary gaps in coverage that harm the health of 65 million beneficiaries
- Key Provisions: Medicare Part B coverage for routine dental care including cleanings, fillings, extractions, and dentures; Medicare Part B coverage for annual eye examinations and corrective lenses; Medicare Part B coverage for hearing evaluations and hearing aids; income-graduated cost-sharing with low-income subsidy for beneficiaries below 200 percent of the federal poverty level; financing through drug price negotiation savings and elimination of wasteful Medicare Advantage overpayments
- Constitutional Authority: Spending Clause; 42 U.S.C. § 1395 et seq.
- Purpose: Double the capacity of the federally qualified health center system to serve underserved communities and achieve primary care access for all Americans regardless of ability to pay
- Key Provisions: $2 billion increase in Health Center Program appropriations over four years; funding for 600 new community health center sites, with priority to rural areas, maternal care deserts, and communities with documented primary care shortages; enhanced payment rates for health center services under Medicaid and Medicare; workforce grants for 5,000 additional primary care providers serving health centers through expanded National Health Service Corps loan repayment
- Constitutional Authority: Spending Clause; 42 U.S.C. § 254b
- Purpose: Eliminate documented overpayment, denial of care, and network adequacy failures in the Medicare Advantage program that harm beneficiaries and cost the Medicare program billions of dollars annually
- Key Provisions: Mandatory prior authorization transparency reporting with 30-day denial appeal resolution requirements; real-time audit of risk adjustment coding accuracy with financial clawbacks for documented upcoding; minimum medical loss ratio of 85 percent for all Medicare Advantage plans; network adequacy standards with enforceable time-and-distance requirements for all specialty types; annual independent audit by HHS Inspector General of the ten largest Medicare Advantage plans published online; civil monetary penalties of up to $1 million per violation for non-compliant plans
- Constitutional Authority: Spending Clause; 42 U.S.C. § 1395w-21 et seq.
- Purpose: Establish guaranteed multi-year appropriations for pandemic preparedness infrastructure, ending the cycle of inadequate preparedness exposed by COVID-19 and subsequently dismantled by the Trump administration
- Key Provisions: Mandatory minimum appropriations for the Strategic National Stockpile, BARDA, Hospital Preparedness Program, and state public health emergency preparedness cooperative agreements; domestic manufacturing partnerships for essential medicines with 80 percent domestic production target within ten years; independent Pandemic Preparedness Advisory Board appointed by the Secretary with required annual public report on preparedness status; prohibition on Secretary reducing SNS below 90-day emergency capacity without congressional notification
- Constitutional Authority: Spending Clause; Commerce Clause; 42 U.S.C. § 247d et seq.
- Purpose: Fund the 50,000-position public health workforce expansion needed to restore and build beyond the pre-COVID workforce levels that left the United States unprepared for the COVID-19 pandemic
- Key Provisions: $5 billion over four years in competitive grants to state and local health departments for public health workforce hiring; National Public Health Service Corps providing student loan repayment for public health professionals committing to two-year service in shortage areas; federal public health fellowship program placing graduates of accredited schools of public health in state and local agencies; minimum public health workforce ratio standards for states receiving CDC cooperative agreements; annual HHS report to Congress on public health workforce data by state and specialty
- Constitutional Authority: Spending Clause; 42 U.S.C. § 247b; Necessary and Proper Clause
Healthcare Coverage:
- Reduce the national uninsured rate from approximately 8 percent to below 4 percent within four years
- Achieve Medicaid coverage for all Americans earning below 138 percent of the federal poverty level in all 50 states and territories within three years
- Increase ACA marketplace enrollment to 30 million by year four through public option availability and permanent enhanced subsidies
- Eliminate the Medicaid coverage gap entirely: zero Americans earning below 138 percent of FPL in any state without access to public health coverage by year four
- Reduce disenrollment due to administrative barriers (procedural terminations) in Medicaid by 75 percent within two years by restoring continuous eligibility protections and 12-month renewal periods
Maternal Health:
- Reduce the overall maternal mortality rate from 22.3 per 100,000 live births (2022 baseline) to below 15 per 100,000 by year four
- Reduce the Black maternal mortality rate from 50.3 per 100,000 to below 25 per 100,000 by year four, with the stated goal of eliminating the racial disparity entirely by year eight
- Achieve twelve-month postpartum Medicaid coverage for all eligible mothers in all 50 states within two years
- Establish maternal mortality review committees with standardized CDC-compliant data in all 50 states and territories by the end of year one
- Reduce the number of counties designated as Maternity Care Health Professional Shortage Areas by 30 percent by year four through HRSA workforce investments
- Achieve National Health Service Corps obstetric provider placement in at least 500 rural maternity care desert counties within three years
Reproductive Health:
- Restore Title X services to all approximately 4 million patients served annually prior to the Trump administration grant freezes within 180 days of taking office
- Achieve medication abortion access via telehealth in all 50 states within two years of enactment of the Medication Abortion Access Act
- Expand Title X program capacity to 6 million patients annually by year four through the funding increase to $750 million annually
- Achieve contraceptive coverage without cost-sharing for all FDA-approved methods in 100 percent of Medicaid managed care plans and ACA marketplace plans within one year
Mental Health and Substance Use:
- Reduce drug overdose deaths from approximately 80,000 annually to below 50,000 within four years
- Achieve full MHPAEA compliance — as measured by mandatory comparative analyses — among the 100 largest health insurers within two years
- Expand opioid treatment program capacity to serve all Americans seeking medication-assisted treatment within 60 days of seeking care, eliminating treatment waitlists
- Achieve national 988 crisis line capacity to answer 95 percent of contacts within 30 seconds and dispatch mobile crisis teams to 80 percent of high-acuity callers within 30 minutes by year three
- Increase the number of Americans engaged in medication-assisted treatment for opioid use disorder by 50 percent within four years
- Reduce youth rates of reported depression and anxiety — as measured by the National Survey on Drug Use and Health — by 15 percent by year four through school-based mental health investments
Research:
- Restore all 5,844 unlawfully terminated NIH grants within 18 months of taking office
- Increase NIH appropriations by 20 percent per year for four years, reaching a target of $77 billion annually by year four
- Reduce disparity in NIH grant success rates between minority-serving institutions and Research-Intensive universities by 25 percent within four years
- Re-engage all international research collaborations severed by the Trump administration within 90 days of taking office
- Launch at least 500 new clinical trials in health disparities research areas within two years, using restored NIH funding
Public Health Workforce:
- Hire 50,000 new public health workers at federal, state, and local levels within four years
- Restore all 20,000 HHS employees terminated in the Trump administration workforce reduction within 18 months
- Achieve adequate public health workforce ratios of at least 50 public health workers per 100,000 population in all states by year four
- Achieve childhood vaccination rates above 95 percent in all 50 states and in all counties with populations above 10,000 by year four, restoring herd immunity thresholds eroded by the Trump administration's vaccine skepticism
Drug Pricing and Medicare:
- Expand Medicare drug price negotiation to 50 drugs by year four
- Achieve average drug price reduction of at least 50 percent on negotiated drugs compared to pre-negotiation list prices
- Implement Medicare dental, vision, and hearing benefit for all 65 million beneficiaries by year three
- Recover at least $5 billion annually in Medicare Advantage overpayments through enhanced risk adjustment audit authority
Health Equity:
- Reduce the racial gap in uninsured rates — between white Americans and Black, Hispanic, and American Indian/Alaska Native Americans — by 50 percent within four years
- Publish annual HHS Health Equity Progress Reports beginning in year one with agency-specific targets and public accountability for results
- Complete environmental health equity mapping and publish the National Environmental Health Equity Action Plan within 180 days of taking office
- Achieve language access compliance in all hospital systems and health plans receiving more than $10 million in annual federal reimbursement by the end of year two
Constitutional Provisions:
- U.S. Const. Art. I, § 8, cl. 1 (Spending Clause)
- U.S. Const. Art. I, § 8, cl. 3 (Commerce Clause)
- U.S. Const. Art. I, § 8, cl. 18 (Necessary and Proper Clause)
- U.S. Const. Art. VI (Supremacy Clause)
Federal Statutes:
- Public Health Service Act, 42 U.S.C. § 201 et seq.
- Food, Drug, and Cosmetic Act, 21 U.S.C. § 301 et seq.
- Affordable Care Act, 42 U.S.C. § 18001 et seq.
- Social Security Act, Title XVIII (Medicare), 42 U.S.C. § 1395 et seq.
- Social Security Act, Title XIX (Medicaid), 42 U.S.C. § 1396 et seq.
- Title X Family Planning, 42 U.S.C. § 300 et seq.
- Mental Health Parity and Addiction Equity Act, 29 U.S.C. § 1185a; 42 U.S.C. § 300gg-26
- HIPAA, 42 U.S.C. § 1320d et seq.
- Children's Health Insurance Program, 42 U.S.C. § 1397aa et seq.
- Ryan White HIV/AIDS Program, 42 U.S.C. § 300ff et seq.
- Community Health Centers, 42 U.S.C. § 254b
- National Institutes of Health Authority, 42 U.S.C. § 241; 42 U.S.C. § 289
- BARDA Authority, 42 U.S.C. § 247d-7e
- Public Health Emergency Authority, 42 U.S.C. § 247d
- Comstock Act, 18 U.S.C. §§ 1461-1462
- Food Safety Modernization Act, Pub. L. 111-353
- 21st Century Cures Act, Pub. L. 114-255
- Inflation Reduction Act, Pub. L. 117-169
- Mainstreaming Addiction Treatment Act of 2023
- American Rescue Plan Act of 2021, Pub. L. 117-2
- Administrative Procedure Act, 5 U.S.C. § 701 et seq.
- DATA 2000 (Drug Addiction Treatment Act of 2000)
Supreme Court Cases:
- NFIB v. Sebelius, 567 U.S. 519 (2012) (ACA constitutionality, Medicaid coercion doctrine)
- California v. Texas, 593 U.S. 659 (2021) (ACA standing and severability)
- South Dakota v. Dole, 483 U.S. 203 (1987) (Spending Clause conditions on federal grants)
- Gonzales v. Raich, 545 U.S. 1 (2005) (Commerce Clause breadth for intrastate health activity)
- Whole Woman's Health v. Hellerstedt, 579 U.S. 582 (2016) (undue burden standard for abortion access restrictions)
- Dobbs v. Jackson Women's Health Organization, 597 U.S. 215 (2022) (overruling Roe v. Wade, returning abortion regulation to states, establishing context for federal preemption strategy)
- Zubik v. Burwell, 578 U.S. 403 (2016) (contraceptive coverage, compelling government interest)
- Rust v. Sullivan, 500 U.S. 173 (1991) (government speech doctrine, Title X speech conditions)
- Agency for International Development v. Alliance for Open Society International, 570 U.S. 205 (2013) (limits on viewpoint-discriminatory conditions on federal funds)
- National Endowment for the Arts v. Finley, 524 U.S. 569 (1998) (government funding and viewpoint discrimination limits)
- Geier v. American Honda Motor Co., 529 U.S. 861 (2000) (conflict preemption in federal regulatory schemes)
- Wyeth v. Levine, 555 U.S. 555 (2009) (FDA drug labeling preemption standards)
- West Virginia v. EPA, 597 U.S. 697 (2022) (major questions doctrine requiring clear congressional authorization)
- Department of Education v. Brown, 600 U.S. 551 (2023) (limits on executive authority without statutory basis)
- Biden v. Nebraska, 599 U.S. 477 (2023) (major questions doctrine applied to executive branch loan program)
The reforms proposed in this chapter intersect with and depend upon provisions in multiple other chapters of Project 2029:
- Chapter 13 (EPA): Environmental health equity, climate health impacts, PFAS contamination, air quality and respiratory disease — coordinate with Reform IX (Health Equity and Environmental Justice) of this chapter
- Chapter 15 (HUD): Housing instability as a social determinant of health, housing for people with serious mental illness, domestic violence survivor housing — coordinate with Reform VII (Mental Health and Substance Use)
- Chapter 17 (DOJ): Civil rights enforcement in healthcare settings, criminal justice health, immigration detention health standards, youth diversion from criminal justice to mental health treatment — coordinate with Reforms VII and IX
- Chapter 18 (Labor): Workplace health and safety (OSHA), paid family and medical leave as a maternal health intervention, employer-sponsored health insurance, mental health benefits in collective bargaining — coordinate with Reforms VIII and III
- Chapter 22 (Treasury): Tax treatment of employer-sponsored health insurance, premium tax credits under the ACA, health savings account reform, IRS enforcement of nonprofit hospital charity care obligations — coordinate with Reform III
- Chapter 28 (Legal Accountability): Accountability for Project 2025 architects who directed the dismantling of HHS; enforcement of APA requirements violated by unlawful NIH grant terminations; civil rights enforcement for patients denied emergency care under EMTALA
- Chapter 29 (Structural Safeguards): Protecting scientific agencies from future political capture through structural reforms that extend beyond any single administration's policy preferences; independent inspector general authority over health agencies
- Chapter 30 (Fundamental Transformation): Universal healthcare coverage as a transformative structural reform; reclassifying healthcare access as a fundamental right enforceable against both federal and state governments; linking health equity to the broader constitutional equality framework
- Chapter 3 (Personnel Agencies): Civil service protections for federal public health scientists; merit-based hiring for HHS leadership positions; protection of career scientists from Schedule F-type reclassification that the Trump administration used to enable politicized terminations
- Chapter 31 (Constitutional Hardball): Responding to state court attacks on FDA mifepristone approval; defending federal preemption of state abortion restrictions in emergency care contexts; defending EMTALA enforcement against state-law interference
Regulatory Citations:
- 45 C.F.R. Part 59 (Title X Family Planning Program regulations)
- 45 C.F.R. Parts 144-158 (ACA insurance market regulations)
- 29 C.F.R. Part 2590 (MHPAEA regulations)
- 21 C.F.R. Part 314 (FDA new drug application regulations)
- 42 C.F.R. Parts 430-498 (Medicaid and Medicare regulations)
- 45 C.F.R. Parts 160, 164 (HIPAA Privacy and Security Rules)
Additional Regulatory and Administrative Sources:
- 42 C.F.R. Part 440 (Medicaid services, including peer recovery support)
- 45 C.F.R. Part 46 (Common Rule — Protection of Human Subjects in Research)
- 42 C.F.R. Part 482 (Conditions of Participation for Hospitals under Medicare/Medicaid)
- 45 C.F.R. Part 92 (Section 1557 — Nondiscrimination in Health Programs and Activities)
- 21 C.F.R. Part 558 (Veterinary Feed Directive — Antibiotic Stewardship)
- 45 C.F.R. Part 59 (Title X Program Integrity Rule, 2021)
- Food, Drug, and Cosmetic Act, 21 U.S.C. § 355 (New Drug Application standard)
- Emergency Medical Treatment and Labor Act (EMTALA), 42 U.S.C. § 1395dd
- Dietary Supplement Health and Education Act of 1994, 21 U.S.C. § 321(ff)
- Violence Against Women Act, Pub. L. 117-103, Title V (funding for SANE programs)
- Prescription Drug User Fee Act (PDUFA) reauthorizations
- Medical Device User Fee Act (MDUFA) reauthorizations
Key Sources and Data:
- Centers for Disease Control and Prevention, National Vital Statistics Reports (maternal mortality data, 2022-2023)
- Kaiser Family Foundation, Medicaid Enrollment and Unwinding Tracker (November 2025 data)
- CMS, Medicare and Medicaid by the Numbers (enrollment statistics)
- Guttmacher Institute, Title X Impact Analysis and Abortion Provider Census
- Senate Committee on Health, Education, Labor and Pensions Minority Report, NIH Grant Terminations (May 2025)
- Congressional Budget Office, ACA Subsidy Expiration Analysis (projected coverage loss estimates)
- American Public Health Association, Project 2025 and Public Health: An Analysis of Threats and Responses
- JAMA Health Forum, "Cutting the NIH — The $8 Trillion Health Care Catastrophe" (2025)
- Society of Family Planning, Medication Abortion Telehealth Access Report (mid-2025)
- NPR/STAT News, HHS Workforce Reduction Coverage (March-April 2025)
- Brennan Center for Justice, "Federal Cuts to Behavioral Health Will Harm Public Safety" (2025)
- KFF Health News, "Project 2025 Would Recast HHS as the Federal Department of Life" (2024)
- Science News, "See the Alarming Extent of NIH and NSF Funding Cuts in 2025"
- Nature, "US Science After a Year of Trump: What Has Been Lost and What Remains" (2026)
- Commonwealth Fund, "Status of Women's Health: 100 Days into the Trump Administration" (2025)
- Heritage Foundation, Mandate for Leadership: The Conservative Promise (2023), Chapter 14 (HHS), pp. 449-503
- National Health Law Program, "Authoritarian Project 2025 Agenda Endangers the Future of Medicaid and the Affordable Care Act" (2024)
- McKinsey Institute for Economic Mobility, "Closing the Black Maternal Health Gap: Healthier Lives, Stronger Economies" (2025)
- U.S. News and World Report, "Black Maternal Deaths Remain High Despite Overall Decline in U.S." (February 2025)
- ACA Signups, CMS Medicaid/CHIP Enrollment Report Analysis (November 2025)
- Network for Public Health Law, "Updates to HHS Restructuring and Funding Cuts: Impact on State and Local Public Health" (2025)
- American Medical Association, "Changes to Medicaid, the ACA and Other Key Provisions of the One Big Beautiful Bill Act" (2025)
- Johns Hopkins Bloomberg School of Public Health, Report on COVID-19 Pandemic Preparedness Failures and Lessons for Future Response Capacity