How Trump policies and Project 2025 match up after first 100 days

Washington — President Trump repeatedly distanced himself from Project 2025 on the campaign trail, saying he had "nothing to do with" the initiative spearheaded by the Heritage Foundation, had not read it and didn't have any plans to.

But as the president marks 100 days in the White House, many of the plans he has rolled out since the start of his second term closely align with those in the pages of Project 2025's sprawling, 900-page policy blueprint, which lays out an overhaul of the executive branch.

Overseen by the Heritage Foundation, Project 2025 was an initiative that was designed to provide a roadmap for the next Republican president, now Mr. Trump. On the campaign trail, the president called some of its proposals "abysmal" and said he knew nothing about it, though CBS News' analysis showed many of its proposals were similar to his own.

The authors of some of the policy guide's chapters served in his first administration and have returned for the second. Russ Vought is leading the Office of Management and Budget, and John Ratcliffe is in place as CIA director, while Peter Navarro, who was a top trade adviser to Mr. Trump in his first administration, returned for a second stint in the White House.

Some of Mr. Trump's actions taken in his first days in office reinstate measures he put in place during his first term that were revoked by President Biden. But in other instances, Mr. Trump has taken new executive actions that echo policies outlined in Project 2025's policy book.

Republicans have long called for the Department of Education to be dismantled, and that recommendation was also made in Project 2025, which declared that "federal education policy should be limited and, ultimately, the federal Department of Education should be eliminated."

Mr. Trump took steps to begin that process with an executive order he signed in March. The administration has already cut the Education Department's staff and is making plans to move some of its functions to other agencies.

Shuttering the Department of Education, however, would require an act of Congress.

The president frequently rails against diversity, equity and inclusion, or DEI, practices, and he signed an executive order on the day he returned to the White House ending all DEI programs within the federal government.

Mr. Trump claimed in his order that DEI policies can violate federal civil rights laws and shut out Americans "who deserve a shot at the American dream" because of their race or sex.

Project 2025 likewise calls for the "DEI apparatus" at a variety of agencies to be dismantled.

Project 2025's policy book also calls for deleting a variety of terms, including DEI, abortion and gender equality "from every federal rule, agency regulation, contract, grant, regulation, and piece of legislation that exists."

Some of the Trump administration's early efforts to purge mentions of gender or race resulted in missteps that prompted a public outcry and were later reversed.

Shortly after the start of his second term, Mr. Trump established a review council to advise him on the ability of the Federal Emergency Management Agency, or FEMA, "to capably and impartially address disasters occurring within the United States." The council will also advise the president on recommended changes related to FEMA, his order states.

Mr. Trump's directive came after he suggested that he could "get rid" of FEMA and leave disaster response management to the states.

"That's what states are for, to take care of problems," he said in late January.

Mr. Trump also signed an executive order in March that declares it is the policy of the U.S. that "state and local governments and individuals play a more active and significant role in national resilience and preparedness," and says that his administration will "enable state and local governments to better understand, plan for and ultimately address the needs of their citizens."

The overhaul at FEMA has sparked concerns about the agency's capabilities to deliver disaster assistance ahead of hurricane season. FEMA has already denied requests for federal aid in response to severe storms and tornadoes in Arkansas, flooding in parts of West Virginia and storms in Washington.

Project 2025's sweeping book of policy proposals calls for "reforming FEMA emergency spending to shift the majority of preparedness and response costs to states and localities instead of the federal government."

It also urges Congress to change the cost-sharing arrangement so the federal government covers 25% of the costs for small disasters and up to 75% for "truly catastrophic disasters." Currently, for Public Assistance, which provides financial and direct assistance to state and local governments for disaster response and recovery work, FEMA covers a minimum of 75% of costs, and the president can increase the federal cost-share at his discretion, according to a 2023 report from the Congressional Research Service.

The recommendation follows a warning from Project 2025's authors that FEMA is "overtasked, overcompensates for the lack of state and local preparedness and response, and is regularly in deep debt." Project 2025's book also calls on Congress to end preparedness grants for states and localities.

"DHS should not be in the business of handing out federal tax dollars: These grants should be terminated," it states.

Brendan Carr, head of the Federal Communications Commission, informed the heads of National Public Radio and PBS in a letter earlier this year that the agency had opened an investigation into the airing of their programming across their roughly 1,500 broadcast member stations, according to The New York Times.

Those stations are licensed by the FCC to operate, but are limited to operating as noncommercial educational broadcast stations. These stations, or NCEs, are exempt from licensing fees and operate on a specific "reserved" frequency band. Federal law prohibits these noncommercial educational broadcast stations from airing commercial advertisements.

In his letter, Carr wrote that he is "concerned that NPR and PBS broadcasts could be violating federal law by airing commercials. In particular, it is possible that NPR and PBS member stations are broadcasting underwriting announcements that cross the line into prohibited commercial advertisements."

Carr also said that he also does not see a reason for Congress to continue approving federal dollars for NPR and PBS "given the changes in the media marketplace." PBS CEO Paula Kerger said the cuts "would devastate PBS member stations and the essential role they play in communities, particularly smaller and rural stations."

Carr authored the section of Project 2025's policy book that deals with the FCC, but another portion of the blueprint urges Congress to defund the Corporation for Public Broadcasting, which provides grants to NPR and PBS.

According to Project 2025, "stripping public funding would, of course, mean that NPR, PBS, Pacifica Radio, and the other leftist broadcasters would be shorn of the presumption that they act in the public interest and receive the privileges that often accompany so acting." The outlets should therefore no longer be qualified as noncommercial educational broadcast stations, according to the book.

One of Mr. Trump's first actions as president was to establish the White House's Department of Government Efficiency — DOGE — run by Elon Musk, to slash regulations and spending, and restructure federal agencies.

On the heels of that move, the Office of Management and Budget, or OMB, issued a two-page memo in January that ordered a freeze on grant, loan or federal assistance programs covered by Mr. Trump's executive orders, which would allow his administration "time to review agency programs and determine the best uses of the funding for those programs consistent with the law and the president's priorities."

The memo sparked widespread confusion and prompted concerns about whether programs providing meals for the elderly, pre-school funding for low-income children, medical research and other priorities approved by Congress would be impacted by the order.

The White House then rescinded the memo but maintained the funding pause "to end any confusion" created by a federal court order temporarily pausing implementation of the freeze. Federal courts have since ordered the administration to reinstate any money that was frozen subject to the memo.

Vought, the head of OMB, authored the section of Project 2025's policy book covering the Executive Office of the President, which includes the agency he has been tapped to lead.

In it, he likens the budget office to an air-traffic control system for the president "with the ability and charge to ensure that all policy initiatives are flying in sync and with the authority to let planes take off and, at times, ground planes that are flying off course."

The memo may have been aimed at sparking a legal challenge to the Impoundment Control Act, a 1974 law that limits the president's ability to unilaterally freeze certain funds appropriated by Congress, and in most cases requires the president instead to ask Congress to rescind spending legislation

In Project 2025's policy blueprint, Vought also wrote the director of OMB must have "sufficient visibility into the deep caverns of agency decision-making," and can achieve this by ensuring political appointees on his staff sign off on apportionments of funding authorized by Congress.

Vought cited a 1870 law known as the Anti-Deficiency Act, which prohibits federal agencies from spending federal dollars in advance and requires funding be doled out in installments.

"This process, whereby agencies come to OMB for allotments of appropriated funding, is essential to the effective financial stewardship of taxpayer dollars," he wrote. "OMB can then direct on behalf of a president the amount, duration, and purpose of any apportioned funding to ensure against waste, fraud, and abuse and ensure consistency with the president's agenda and applicable laws."

Mr. Trump issued an executive order in January that seeks to bar the use of federal funds for gender-affirming care — puberty blockers, hormone therapy and surgical procedures — for people under the age of 19.

Called "Protecting Children from Chemical and Surgical Mutilation," the order directs certain executive agencies to take steps to ensure medical institutions that receive federal grants "end the chemical and surgical mutilation of children."

It also instructs the secretary of defense to take regulatory action to exclude gender-affirming care for minors from insurance coverage provided by TRICARE, the Defense Department's health care program, and federal employee health benefit programs.

Mr. Trump's order directs the head of the Department of Health and Human Services to withdraw March 2022 guidance on gender-affirming care.

Project 2025's chapter on the Department of Health and Human Services calls for its Office of Civil Rights to "remove all guidance issued under the Biden administration concerning sexual orientation and gender identity," including the March 2022 document.

The book generally criticizes gender-affirming care as causing "irreversible physical and mental harm to those who receive them" and argues there is a lack of evidence surrounding it.

Many families and doctors who care for transgender youth dispute that assessment, and a group of families filed a lawsuit claiming the order is discriminatory. Two different federal district courts have blocked the president's directive, and those injunctions are being appealed.

Mr. Trump took executive action to start the process of revoking the security clearances of dozens of former intelligence officials who signed a letter in 2020 claiming emails found on a laptop owned by Hunter Biden bore the hallmarks of a Russian disinformation campaign. He also announced he would revoke the security clearances of a number of prominent Democrats including former President Joe Biden, former Vice President Kamala Harris and Hillary Clinton.

Project 2025 also proposed stripping former intelligence officials of security clearances, under a more narrow set of circumstances, in a section on the intelligence community authored by Dustin Carmack, who worked at the Office of the Director of National Intelligence during Mr. Trump's first term.

"The president should immediately revoke the security clearances of any former directors, deputy directors, or other senior intelligence officials who discuss their work in the press or on social media without prior clearance from the current director," he wrote.

Among the slew of actions Mr. Trump took on his first day back in the White House was to reinstate an executive order issued during his first term that created "Schedule F in the Excepted Service." The order creates a new employment category for many career civil servants, effectively stripping them of employment protections.

The order states that in recent years, "there have been numerous and well-documented cases of career federal employees resisting and undermining the policies and directives of their executive leadership."

"Principles of good administration, therefore, necessitate action to restore accountability to the career civil service, beginning with positions of a confidential, policy-determining, policy-making, or policy-advocating character," Mr. Trump's order reads.

The order makes some minor changes to the president's prior measure from October 2020. But it notably adds a section that states that while employees in these new "Schedule Policy/Career Positions," are not required to personally or politically support the current president or his policies, they are "required to faithfully implement administration policies to the best of their ability, consistent with their constitutional oath and the vesting of executive authority solely in the president."

Failure to do so is grounds for termination of employment, Mr. Trump's executive order states. Critics say the change would enable the administration to fire government employees for no cause and replace them with Trump loyalists.

Project 2025 repeatedly calls for Mr. Trump's Schedule F proposal to be reinstated.

The president directed the secretaries of Defense or Homeland Security to reinstate service members, both active-duty and reserve, who were discharged after refusing to receive the COVID-19 vaccine. (The vaccine requirement was lifted in 2023.) His order also states they should be reverted to their former rank and receive full back pay, benefits, bonus payments or compensation.

The Project 2025 blueprint's section on the Defense Department, authored by Chris Miller, calls for the next administration to "reinstate servicemembers to active duty who were discharged for not receiving the COVID vaccine, restore their appropriate rank, and provide back pay."

Miller served as acting defense secretary in the final weeks of Mr. Trump's first term. His chief of staff, Kash Patel, is now serving as director of the FBI.

During his first four years in the White House, Mr. Trump prohibited transgender people from serving in the military. President Biden repealed that ban, but Mr. Trump has issued an order that effectively bars transgender people from serving in the armed forces and withdraws his predecessor's order.

Mr. Trump's executive order states that "expressing a false 'gender identity' divergent from an individual's sex cannot satisfy the rigorous standards necessary for military service." Identifying as transgender, it continues, "conflicts with a soldier's commitment to an honorable, truthful, and disciplined lifestyle, even in one's personal life."

"It is the policy of the United States Government to establish high standards for troop readiness, lethality, cohesion, honesty, humility, uniformity, and integrity. This policy is inconsistent with the medical, surgical, and mental health constraints on individuals with gender dysphoria," the president's order states. "This policy is also inconsistent with shifting pronoun usage or use of pronouns that inaccurately reflect an individual's sex."

Project 2025 calls for a reversal of policies "that allow transgender individuals to serve in the military. Gender dysphoria is incompatible with the demands of military service."

SPARTA Pride, a nonprofit group comprised of thousands of transgender service members, veterans and their supporters, disputed such claims, saying: "Transgender Americans have served openly and honorably in the U.S. Armed Forces for nearly a decade. Thousands of transgender troops are currently serving, and are fully qualified for the positions in which they serve."

The transgender military ban has since been blocked by two different federal courts, though the decisions have been appealed. The Trump administration has asked the Supreme Court to intervene in one of those cases and is seeking to begin enforcing the ban.

There are more than 1.2 million active-duty members of the military, according to the Defense Department. A January report from the Congressional Research Service found that roughly 1,892 active-duty service members received gender-affirming care from the Pentagon between January 2016 and May 2021. A Feb. 26 memo from the Pentagon found that between 2015 and 2024, it spent $52 million on care for active-duty members of the military to treat gender dysphoria.

On his first day in the White House, Mr. Trump issued a memorandum freezing hiring of federal civilian employees, which he extended to July 15. Positions that were vacant as of his inauguration at noon on Jan. 20 should also not be filled, he said.

The order was part of his plans to reduce the size of the federal workforce, also a recommendation made in the Project 2025 policy roadmap.

The book, though, warns that while "reducing the number of federal employees seems an obvious way to reduce the overall expense of the civil service," prior attempts to do by presidents of both parties "did not lead to permanent and substantive reductions in the number of nondefense federal employees."

Instead, Project 2025 suggests a "freeze on all top career-position hiring to prevent 'burrowing-in' by outgoing political appointees."

Mr. Trump withdrew the U.S. from the World Health Organization in 2020 due to what his first administration said was a mishandling of the COVID-19 pandemic. Biden reversed that decision when he took office, and Mr. Trump rolled back that move on his first day back in the White House.

His latest order directed the secretary of state to inform the secretary-general of the United States and World Health Organization leadership of the U.S. decision to withdraw from the group. Health officials in the U.S. and around the world have warned the move will leave people at greater risk of dangerous outbreaks and give China a more dominant role at the World Health Organization.

Project 2025, too, criticized the World Health Organization for its handling of the pandemic.

"The manifest failure and corruption of the World Health Organization (WHO) during the COVID-19 pandemic is an example of the danger that international organizations pose to U.S. citizens and interests," its book states.

It said that when institutions act contrary to U.S. interests, the government "must be prepared to take appropriate steps in response, up to and including withdrawal."

Immigration was the topic of several executive actions taken by Mr. Trump on the first day of his presidency, including one order that assigns troops "the mission to seal the borders and maintain the sovereignty, territorial integrity and security of the United States."

The chapter of Project 2025's blueprint that covers the Department of Homeland Security was authored by Ken Cuccinelli, who served in the first Trump administration, and it, too, sees a role for the Defense Department in securing the U.S.-Mexico border.

The Pentagon, Cucinelli writes, should "explicitly acknowledge and adjust personnel and priorities to participate actively in the defense, including using military personnel and hardware to prevent illegal crossings between ports of entry and channel all cross-border traffic to legal ports of entry."

A section on the Justice Department urges the next administration to "take a creative and aggressive approach" to tackling criminal organizations at the southern border.

"This could include use of active-duty military personnel and National Guardsmen to assist in arrest operations along the border — something that has not yet been done," Project 2025's chapter on the Justice Department states.

Entry into the U.S. by refugees under the U.S. Refugee Admissions Program was suspended earlier this year in accordance with an order by Mr. Trump on Jan. 20. His directive also orders the secretary of Homeland Security to suspend decisions on applications for refugee status.

Mr. Trump has claimed that during the Biden administration, the U.S. has been "inundated" with high levels of migration, including through the Refugee Admissions Program.

Project 2025, too, blames the Biden administration for overseeing what it says was a "collapse" of U.S. border security and immigration enforcement. To address this "crisis," Project 2025 calls for "rightsizing refugee admissions."

"The federal government's obligation to shift national security–essential screening and vetting resources to the forged border crisis will necessitate an indefinite curtailment of the number of USRAP refugee admissions," its chapter on the State Department reads.

The policy book calls for the State Department bureau that administers the Refugee Admissions Program to shift resources to challenges "until the crisis can be contained and refugee-focused screening and vetting capacity can reasonably be restored."

As part of Mr. Trump's sweeping immigration crackdown, his administration has moved to end the Temporary Protected Status program for Haitians and Venezuelans.

The TPS designation was created by Congress in 1990, and it allows the federal government to grant temporary immigration protections to migrants from countries facing war, environmental disasters or other crises that make it dangerous to send deportees there. The program allows beneficiaries to apply for renewable work permits and deportation deferrals.

A federal judge in late March agreed to delay the Trump administration's attempt to end the TPS program that shields roughly 350,000 Venezuelan migrants, and a federal appeals court declined to pause that order while proceedings continue.

Project 2025 calls on Congress to "repeal temporary protected status designations."

The National Institutes of Health announced in a February memo that it would be capping the amount of funding for "indirect costs" at 15%, a cut from an average of between 27% and 28%. Indirect costs cover general expenses like facilities and administration.

NIH said in its memo that it has spent billions on indirect costs for more than 2,500 universities, medical schools and other research institutions across the country, and noted that "most private foundations that fund research provide substantially lower indirect costs than the federal government, and universities readily accept grants from these foundations."

Project 2025 also focused on indirect costs and called on Congress to "cap the indirect cost rate paid to universities so that it does not exceed the lowest rate a university accepts from a private organization to fund search efforts."

"This market-based reform would help reduce federal taxpayer subsidization of leftist agendas," the policy book read.

While Project 2025 said it is up to Congress to cap the indirect cost rate, the Trump administration took this step unilaterally, prompting legal challenges from universities, states and organizations that represent medical colleges and schools.

Universities and the NIH said the cuts will have a "dire impact" on lifesaving research, including clinical trials for cancer and Alzheimer's patients.

As part of a series of executive orders addressing the education system, Mr. Trump issued a directive on April 23 that directs the education secretary to enforce a provision of the Higher Education Act that requires higher education institutions that receive federal dollars to disclose any gifts of contracts from a foreign source valued at $250,000 or more in a calendar year.

The move is also part of Project 2025, which calls on the next administration to enforce that statute, investigate higher education institutions that do not honor the obligations laid out in the law and make "appropriate referrals" to the Justice Department.

Since returning to the White House, Mr. Trump has sought to fire the members of independent agencies and inspectors general, despite federal laws that lay out the grounds for their removals.

The terminations have sparked multiple court fights that appear aimed at asserting what the Trump administration believes is the president's unrestricted power to remove executive branch officials. But a 90-year-old Supreme Court decision, Humphrey's Executor v. United States, found that Congress could impose for-cause removal protections to multi-member commissions of experts that are balanced along partisan lines and do not exercise any executive power.

In a February letter to Congress, then-acting Solicitor General Sarah Harris said the Justice Department "intends to urge the Supreme Court to overrule that decision, which prevents the president from adequately supervising principal officers in the executive branch who execute the laws on the president's behalf, and which has already been severely eroded by recent Supreme Court decisions."

Project 2025, too, suggested the next Republican presidential administration should seek the reversal of Humphrey's Executor.

"The next conservative administration should formally take the position that Humphrey's Executor violates the Constitution's separation of powers," it states.

Project 2025's policy book calls for the National Oceanographic and Atmospheric Administration, known as NOAA, to be "dismantled and many of its functions eliminated, sent to other agencies, privatized, or placed under the control of states and territories."

The guide says NOAA's six main components should either be downsized or broken up, including Oceanic and Atmospheric Research, or OAR, which Project 2025 claims is the "source of much of NOAA's climate alarmism."

The Trump administration has proposed sweeping changes and job cuts for NOAA, including a 25% cut to its 2026 budget, according to an internal memo obtained by CBS News in April. The proposal calls for OAR to be eliminated as an office, as well as funding for climate, weather and ocean laboratories, cooperative institutes and other programs.

Current and former officials with NOAA have said the memo's objectives are "devastating," and have argued that research is crucial to improving services such as severe weather forecasts for the public.

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