Executive Order Tracker: Health Care Actions

Executive Order Tracker

Below are brief analyses of relevant Administrative Actions—including Executive Orders (EOs), Proclamations, Memoranda, and Guidance—issued by President Trump, ordered with the most recent Actions first. Expand each item by clicking on it to learn more.

Every day we are doing in-depth analysis of these Administrative Actions. If you’d like to learn more about what these mean for you and your business, don’t hesitate to contact us regarding health care Executive Orders, and information for additional subjects can be accessed using the links below.

HHS Announces Transformation to Make America Healthy Again

March 27, 2025 — Details ⮟

Overview: HHS announces that it would be undergoing a significant workforce reduction alongside a number of additional administrative and organizational changes. HHS plans to terminate an additional 10,000 full-time employees, which would ultimately reduce HHS to 62,000 full-time employees from a pre-Administration level of 82,000. Of the 10,000 employees, 3,500 will come from the Food and Drug Administration (FDA), 1,400 will come from the current CDC, 1,200 will come from NIH, and 300 will come from CMS. According to HHS, this reduction will lower costs by $1.8 billion per year.
Topics: Federal workforce
Learn More: Visit The White House website.

EO 14221: Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information

February 25, 2025 — Details ⮟

Overview: Directs the Secretaries of Treasury, Labor, and HHS to take all "necessary and appropriate action" to "rapidly implement and enforce" the healthcare price transparency regulations issued pursuant to EO 13877, Improving Price and Quality Transparency in American Healthcare to Put Patients First (June 24, 2019).

Within 90 days of the date of this EO, the Secretaries must take action to:
- require the disclosure of the actual prices of items and services (not estimates);
- issue updated guidance or proposed regulatory action ensuring pricing information is "standardized and easily comparable" across hospitals and health plans; and
- issue guidance or proposed regulatory action updating enforcement policies designed to ensure compliance with the transparent reporting of complete, accurate, and meaningful data.
Agencies Receiving Instructions: Secretary of Treasury; Secretary of Labor; and Secretary of HHS
Topics: Health care; price transparency
Learn More: Visit The White House website.

EO 14216: Expanding Access to In Vitro Fertilization

February 18, 2025 — Details ⮟

Overview: Provides that within 90 days of the EO, the Assistant to the President for Domestic Policy is required to submit a list of policy recommendations to the President on “protecting [in vitro fertilization (IVF)] access” and “aggressively reducing” out-of-pocket and health plan costs for IVF treatment.

States that it is the Trump Administration’s policy “to ensure reliable access to IVF treatment, including by easing unnecessary statutory or regulatory burdens to make IVF treatment drastically more affordable.”
Agencies Receiving Instructions: Assistant to the President for Domestic Policy
Topics: Reproductive care; IVF; infertility; health plans
Learn More: Visit The White House website.

Keeping Education Accessible and Ending COVID-19 Vaccine Mandates in Schools

February 15, 2025 — Details ⮟

Overview: Asserts that it is the policy of the Federal Government to aggressively combat critical health challenges, including the rising rates of mental health disorders, obesity, diabetes, and other chronic diseases. Requires executive departments and agencies that address health or healthcare to focus on reversing chronic disease.

Provides that all federally funded health research should empower Americans through transparency and open-source data, and should avoid or eliminate conflicts of interest that skew outcomes and perpetuate distrust.

Provides that NIH and other health-related research funded by the Federal Government should prioritize gold-standard research on the root causes of why Americans are getting sick.

Directs agencies to work with farmers to ensure that U.S. food is the “healthiest, most abundant, and most affordable in the world.”

Directs agencies to ensure the availability of expanded treatment options and the flexibility for health insurance coverage to provide benefits that support beneficial lifestyle changes and disease prevention.

Establishes the President’s Make America Healthy Again Commission. Requires the Commission submit a “Make our Children Healthy Again Strategy” to the Presidents within 180 days of the release of the EO.
Agencies Receiving Instructions: Secretary of HHS; Assistant to the President for Domestic Policy; Secretary of Agriculture; Secretary of Housing and Urban Development; Secretary of Education; Secretary of Veterans Affairs; Administrator of the Environmental Protection Agency (EPA); Director of the OMB; Assistant to the President and Deputy Chief of Staff for Policy; Director of the National Economic Council; Chairman of the Council of Economic Advisers; Director of the Office of Science and Technology Policy; Commissioner of Food and Drugs; Director for the Centers for Disease Control and Prevention (CDC); Director of NIH; and other members of the Administration invited to participate
Topics: Health care
Learn More: Visit The White House website.

EO 14212: Establishing the President's Make America Health Again Commission

February 13, 2025 — Details ⮟

Overview: Asserts that it is the policy of the Federal Government to aggressively combat critical health challenges, including the rising rates of mental health disorders, obesity, diabetes, and other chronic diseases. Requires executive departments and agencies that address health or healthcare to focus on reversing chronic disease.

Provides that all federally funded health research should empower Americans through transparency and open-source data, and should avoid or eliminate conflicts of interest that skew outcomes and perpetuate distrust.

Provides that NIH and other health-related research funded by the Federal Government should prioritize gold-standard research on the root causes of why Americans are getting sick.

Directs agencies to work with farmers to ensure that U.S. food is the “healthiest, most abundant, and most affordable in the world.”

Directs agencies to ensure the availability of expanded treatment options and the flexibility for health insurance coverage to provide benefits that support beneficial lifestyle changes and disease prevention.

Establishes the President’s Make America Healthy Again Commission. Requires the Commission submit a “Make our Children Healthy Again Strategy” to the Presidents within 180 days of the release of the EO.
Agencies Receiving Instructions: Secretary of HHS; Assistant to the President for Domestic Policy; Secretary of Agriculture; Secretary of Housing and Urban Development; Secretary of Education; Secretary of Veterans Affairs; Administrator of the Environmental Protection Agency (EPA); Director of the OMB; Assistant to the President and Deputy Chief of Staff for Policy; Director of the National Economic Council; Chairman of the Council of Economic Advisers; Director of the Office of Science and Technology Policy; Commissioner of Food and Drugs; Director for the Centers for Disease Control and Prevention (CDC); Director of NIH; and other members of the Administration invited to participate
Topics: Health care
Learn More: Visit The White House website.

Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates

February 7, 2025 — Details ⮟

Overview: The National Institutes of Health (NIH) announced it was capping facilities and administration (indirect) costs at 15% (average is 28%) immediately for existing as well as new grants.
Notes: This guidance, along with its associated policies, is subject to temporary restraining orders in the U.S. District Court for the District of Massachusetts (case numbers: 1:25-cv-10338; 1:25-cv-10340, 1:25-cv-10346). The court subsequently issued a preliminary injunction on March 5, 2025 and a permanent injunction on April 4, 2025. On April 8, 2025, the federal government filed an appeal before the U.S. Court of Appeals for the First Circuit (case number 25-1343).
Agencies Receiving Instructions: Office of the Director, NIH
Topics: Federal grants
Learn More: Visit the National Institutes of Health (NIH) website.

EO 14187: Protecting Children from Chemical and Surgical Mutilation

January 28, 2025 — Details ⮟

Overview: Requires agencies to rescind or amend all policies that rely on World Professional Association for Transgender Health (WPATH) guidance. Within 90 days, the HHS Secretary is required to publish a review of existing literature on “best practices for promoting the health of children who assert gender dysphoria, rapid-onset gender dysphoria, or other identity-based confusion.” The HHS Secretary shall also take steps to increase the quality of data “to guide practices for improving the health of minors with gender dysphoria, rapid-onset gender dysphoria, or other identity-based confusion, or who otherwise seek chemical or surgical mutilation.”

Heads of each executive department or agency that provides research or education grants to medical institutions—including medical schools and hospitals—must take steps to ensure that institutions receiving Federal research or education grants “end the chemical and surgical mutilation of children.”

The Secretary of HHS must also take action to end “the chemical and surgical mutilation of children.” Also provides that the Secretary of Defense shall take action to “exclude chemical and surgical mutilation of children.” Also requires the HHS Secretary to withdraw HHS’s March 2, 2022, entitled “HHS Notice and Guidance on Gender Affirming Care, Civil Rights and Patient Privacy.”

States that the Director of OPM shall include provisions in the Federal Employee Health Benefits (FEHB) and Postal Service Health Benefits (PSHB) programs call letter for the 2026 Plan Year providing that eligible carriers will exclude coverage for pediatric transgender surgeries or hormone treatments and negotiate to obtain corresponding reductions in FEHB and PSHB premiums.

Further requires the Attorney General, in part, to take enforcement actions to protect against “female genital mutilation” and work with Congress to enact a “private right of action” for children and their parents “whose healthy body parts have been damaged by medical professionals practicing chemical and surgical mutilation, which should include a lengthy statute of limitations.”

Within 60 days of the EO, agency heads with responsibilities under the order must submit a report to the Assistant to the President for Domestic Policy detailing their progress.

On February 20, 2024, HHS Office for Civil Rights (OCR) rescinded prior Administration guidance entitled “HHS Notice and Guidance on Gender Affirming Care, Civil Rights, and Patient Privacy,” issued March 2, 2022.

On March 5, 2025, CMS issued an alert to hospital providers “to the dangerous chemical and surgical mutilation of children, including interventions that cause sterilization.” CMS explained that it may begin to take “steps in the future to align policy, including CMS-regulated provider requirements and agreements,” to prevent this type of care.

On March 5, 2025, HRSA issued an alert to stakeholders that it will review its policies, grants, and programs in light of the aforementioned CMS alert. HRSA specifically referenced that it will review its Children’s Hospitals Graduate Medical Education (CHGME) program for consistency with the CMS alert described above. Based on this review, the agency explains that it may “re-scope, delay, or potentially cancel new grants in the future depending on the nature of the work and any future policy change(s) HRSA may make.”

On March 6, 2025, SAMHSA alerted its “colleagues and grantees” stating that it will review its policies, grants, and programs in light of the concerns discussed in the March 5, 2025 CMS alert and may begin to take steps in the future to appropriately update its policies “to protect children from chemical and surgical mutilation.” SAMHSA said it may also consider “re-scoping, delaying, or potentially cancelling new grants in the future depending on the nature of the work and any future policy change(s) SAMHSA may make.”
Notes: The provision of this EO that would condition or withhold federal funding based on the fact that a healthcare entity or health professional provides gender affirming medical care to a patient under the age of 19 is subject to a temporary restraining order in the U.S. District Court for the District of Maryland (case number: 8:25-cv-00337). The court subsequently issued a preliminary injunction on March 3, 2025.

The provision of this EO that would condition or withhold federal funding based on the fact that a healthcare entity or health professional provides gender affirming medical care to a patient under the age of 19 is subject to a preliminary injunction in the U.S. District Court for the Western District of Washington (case number: 2:25-cv-244). In a subsequent order, on March 17, 2025, the court clarified that the preliminary injunction encompasses all gender affirming services for individuals with gender dysphoria (e.g., therapy, mental health care) and patient care provided during research studies.
Agencies Receiving Instructions: All agencies; Secretary of HHS; Director of the Office of Management and Budget; Secretary of Defense; Director of OPM; and Attorney General
Topics: Sex; gender; children’s health
Learn More: Visit The White House website.

EO 14184: Reinstating Service Members Discharged Under the Military's COVID-19 Vaccination Mandate

January 27, 2025 — Details ⮟

Overview: Makes reinstatement available to all members of the military (active and reserve) who were discharged solely for refusing to receive the COVID-19 vaccine. Enables those service members to revert to their former rank and receive full back pay, bonuses, or compensation. Allows service members who voluntarily left the service or allowed their service to lapse (rather than be vaccinated) return to service with no impact on their service status, rank, or pay.
Agencies Receiving Instructions: Secretary of Defense and Secretary of Homeland Security
Topics: Military vaccine requirements
Learn More: Visit The White House website.

Memorandum for the Secretary of State, the Secretary of Defense, the Secretary of Health and Human Services, the Administrator of the United States Agency for International Development

January 24, 2025 — Details ⮟

Overview: Reinstates the “Mexico City Policy” which requires foreign nongovernmental organizations receiving certain types of U.S. assistance to certify that they will not perform or actively promote abortion as a method of family planning, even if such activities are conducted with non-U.S. funds.
Agencies Receiving Instructions: Secretary of State; Secretary of Defense; and Secretary of HHS
Topics: Foreign aid; abortion; women’s health
Learn More: Visit The White House website.

EO 14182: Enforcing the Hyde Amendment

January 24, 2025 — Details ⮟

Overview: Announces it is the policy of the administration to adhere to the Hyde Amendment. Rescinds two EOs promulgated by President Biden related to access to reproductive health care.
Agencies Receiving Instructions: Director of the Office of Management and Budget
Topics: Abortion; women’s health
Learn More: Visit The White House website.

EO 14177: President's Council of Advisors on Science and Technology

January 23, 2025 — Details ⮟

Overview: Establishes the President’s Council of Advisors on Science and Technology (PCAST) to advise the President on matters involving science, technology, education, and innovation policy. The PCAST will be composed of not more than 24 members. Members will include the Assistant to the President for Science and Technology (APST) and the Special Advisor for AI & Crypto. If also serving as the Director of the Office of Science and Technology Policy, the APST may designate the U.S. Chief Technology Officer as a member. The remaining members will include individuals and representatives from sectors outside of the Federal Government appointed by the President.

Revokes Executive Order 14007 of January 27, 2021 (President’s Council of Advisors on Science and Technology), as amended by Executive Order 14109 of September 29, 2023 (Continuance of Certain Federal Advisory Committees and Amendments to Other Executive Orders).
Agencies Receiving Instructions: APST; Special Advisor for AI & Crypto; U.S. Chief Technology Officer; heads of executive departments and agencies; and Department of Energy
Topics: Science and technology; AI; crypto
Learn More: Visit The White House website.

Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis

January 20, 2025 — Details ⮟

Overview: Requires heads of all executive departments and agencies to deliver “emergency price relief” which includes appropriate actions to “eliminate unnecessary administrative expenses and rent-seeking practices that increase healthcare costs.”
Agencies Receiving Instructions: Heads of all executive departments and agencies and the Assistant to the President for Economic Policy
Topics: Household costs; health care costs
Learn More: Visit The White House website.

EO 14155: Withdrawing The United States From The World Health Organization

January 20, 2025 — Details ⮟

Overview: Provides that the U.S. intends to withdraw from the World Health Organization (WHO).
Agencies Receiving Instructions: Assistant to the President for National Security Affairs; Secretary of State; Director of OMB; and Director of the White House Office of Pandemic Preparedness and Response Policy
Topics: Global health
Learn More: Visit the The White House website.

EO 14168: Defending Women From Gender Ideology Extremism And Restoring Biological Truth To The Federal Government

January 20, 2025 — Details ⮟

Overview: Provides that it is U.S. policy to recognize two sexes, male and female, and that “[t]hese sexes are not changeable and are grounded in fundamental and incontrovertible reality.” Requires the Executive Branch to enforce all sex-protective laws to promote this “reality” and establishes definitions to govern Executive interpretation of and application of Federal law and administration policy.

On February 19, 2025, the Administration released guidance entitled, "Defining Sex: Guidance for Federal Agencies, External Partners, and the Public Implementing Executive Order 14168, Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government".

On March 5, 2025, the Centers for Medicare & Medicaid Services (CMS) issued an alert to hospital providers “to the dangerous chemical and surgical mutilation of children, including interventions that cause sterilization.” CMS explained that it may begin to take “steps in the future to align policy, including CMS-regulated provider requirements and agreements,” to prevent this type of care.

On March 5, 2025, the Health Resources & Services Administration (HRSA) issued an alert to stakeholders that it will review its policies, grants, and programs in light of the aforementioned CMS alert. HRSA specifically referenced that it will review its Children’s Hospitals Graduate Medical Education (CHGME) program for consistency with the CMS alert described above. Based on this review, the agency explains that it may “re-scope, delay, or potentially cancel new grants in the future depending on the nature of the work and any future policy change(s) HRSA may make.”

On March 6, 2025, the Substance Abuse and Mental Health Services Administration (SAMHSA) alerted its “colleagues and grantees” stating that it will review its policies, grants, and programs in light of the concerns discussed in the March 5, 2025 CMS alert and may begin to take steps in the future to appropriately update its policies “to protect children from chemical and surgical mutilation.” SAMHSA said it may also consider “re-scoping, delaying, or potentially cancelling new grants in the future depending on the nature of the work and any future policy change(s) SAMHSA may make.”

On March 17, 2025, the Department of Veterans Affairs, citing this EO, announced that it will phase out medical treatments for gender dysphoria.
Notes: The provision of this EO that would require transgender individuals to be housed in Bureau of Prisons (BOP) facilities based on their biological sex and that would prevent the BOP from generally providing gender-affirming care is subject to a temporary restraining order in the U.S. District Court for the District of Columbia (case number 1:25-cv-286).

The provision of this EO that would condition or withhold federal funding based on the fact that a healthcare entity or health professional provides gender affirming medical care to a patient under the age of 19 is subject to a temporary restraining order in the U.S. District Court for the District of Maryland (case number: 8:25-cv-00337). The court subsequently issued a preliminary injunction on March 3, 2025.

This EO is the subject of pending federal lawsuits filed in the U.S. District Court of Columbia (case number: 1:25-cv-00471), the U.S. District Court for the Northern District of California (case number: 3:25-cv-1824), the U.S. District Court for the District of Columbia (case number: 1:25-cv-00691), the U.S. District Court for the District of New Hampshire (case number: 1:24-cv-251), and the U.S. District Court for the District of New Jersey (case number: 1:25-cv-1918).

The provisions of this EO that would condition or withhold federal funding based on the fact that a healthcare entity or health professional provides gender affirming medical care to a patient is subject to a preliminary injunction in the U.S. District Court for the Western District of Washington (case number: 2:25-cv-00244). Of note this preliminary injunction only applies to Colorado, Minnesota, Oregon, and Washington. In a subsequent order, on March 17, 2025, the court clarified that the preliminary injunction encompasses all gender affirming services for individuals with gender dysphoria (e.g., therapy, mental health care) and patient care provided during research studies.
Agencies Receiving Instructions: Secretary of Health and Human Services (HHS); Secretary of State; Secretary of Homeland Security; Director of the Office of Personnel Management (OPM); Attorney General; Secretary of Housing and Urban Development; Assistant to the President for Legislative Affairs; Secretary of Labor; General Counsel and Chair of the Equal Employment Opportunity Commission; and Director of the Office of Management and Budget (OMB)
Topics: Gender; sex
Learn More: Visit The White House website.

Contacts

Timothy P. Trysla

Partner

Washington, D.C.

Phone: +1 202 239 3420

Email: tim.trysla@alston.com

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