During the 2024 presidential campaign, Donald Trump distanced himself from Project 2025 – a policy manual for “the next conservative President” that was produced by the Heritage Foundation and written by veterans of the first Trump administration and other conservatives.
Trump signs proclamations and executive orders on Sept. 25 in the Oval Office. Official White House photo by Joyce N. Boghosian.
Trump claimed he knew “nothing about Project 2025” and had “no idea who is behind it,” despite evidence to the contrary, while Democrats portrayed the document as “Trump’s Project 2025.”
Democratic presidential nominee Kamala Harris ran an ad campaign tying Trump to Project 2025 and created the website TrumpsProject2025.com. At the Democratic National Convention, multiple speakers warned about the project’s proposals (not alwaysaccurately), including speakers who used an oversize copy of the book as a stage prop.
Democrats focused on specific Project 2025 proposals – including some, such as closing the Department of Education, that Trump did support and has acted on since returning to office, and others, that he didn’t endorse and have yet to happen, including a ban on mailing abortion pills.
Since taking office, Trump has been actively implementing or trying to implement many of Project 2025’s recommendations through directives, executive orders, his proposed fiscal year 2026 budget and major pieces of legislation, notably the One Big Beautiful Bill Act.
In a series of stories over the coming days, we will lay out numerous examples of how Trump has implemented Project 2025 proposals and how at times he diverged from the document.
Our articles focus on immigration, climate change/fossil fuels, social safety net programs and divisive cultural issues, such as reproductive rights, transgender protections and DEI, or diversity, equity and inclusion programs.
We start today with the document’s promise to “dismantle the administrative state” – a theme that will emerge in our other articles.
By one count, Trump has implemented or is in the process of implementing about half of Project 2025’s proposals. That seems on track with what Trump did in the first year of his first term. In April 2023, when Project 2025 was released, Heritage said that “the Trump administration embraced nearly 64% of the 2016 edition’s policy solutions after one year.”
But Project 2025 is more than a list of conservative proposals.
Formally titled the “Mandate for Leadership: The Conservative Promise,” Project 2025 is a clarion call to “dismantle the administrative state” – which is one of four “promises” that Heritage President Kevin D. Roberts wrote about in the document’s foreword.
Roberts described the “administrative state” as “the policymaking work done by the bureaucracies of all the federal government’s departments, agencies, and millions of employees” – which is viewed in the document as an obstacle to overcome. A “courageous conservative President” can wield his power to “handcuff the bureaucracy” and “bring the Administrative State to heel,” Roberts wrote.
“The Conservative Promise lays out how to use many of these tools including: how to fire supposedly ‘un-fireable’ federal bureaucrats; how to shutter wasteful and corrupt bureaus and offices; how to muzzle woke propaganda at every level of government; how to restore the American people’s constitutional authority over the Administrative State; and how to save untold taxpayer dollars in the process,” he wrote.
(The document describes “woke propaganda” as support for abortion, transgender rights, climate change, diversity and international treaties, among other things.)
Similarly, in a chapter on the executive office of the president, Russ Vought — Trump’s past and present director of the White House Office of Management and Budget — wrote that the Constitution gives the president “enormous power” and the president must make “aggressive use” of this power “to bend or break the bureaucracy to the presidential will.”
Trump has made Project 2025’s call to “dismantle the administrative state” a central tenet of his second term.
Paul Dans, director and co-editor of Project 2025, told us in a phone interview that Trump’s efforts so far have “exceeded my expectations. My wildest dreams, if you will.”
Dans called the promise to “dismantle the administrative state” his “number one goal” for Project 2025 and “the essence, the ethos behind it.”
At the start of the project, Dans told us, he surveyed conservatives and asked, “What would you like to see in the next president and accomplish in the next administration?”
“The common theme from all of that was that we needed to get over the hurdle of this administrative roadblock,” said Dans, a lawyer who is no longer with Heritage and is now running against Sen. Lindsey Graham in the Republican primary in South Carolina. “A permanent government in Washington. Uncontrollable, not responsive to the electorate, and kind of standing in the way of the agenda that the people have just sent the president to enact.”
As president, Trump immediately set out to implement “the essence” of Project 2025, as Dans called it. The president has sought, in Roberts’ words, to “fire supposedly ‘un-fireable’ federal bureaucrats,” “shutter” federal agencies, and “muzzle woke propaganda” in government and the private sector.
Keeping a campaign promise, Trump immediately appointed billionaire businessman Elon Musk to head the so-called Department of Government Efficiency, or DOGE, which cut government contracts and spearheaded the firing of federal employees. As of Sept. 23, more than 200,000 federal employees have been fired or agreed to leave, according to the nonprofit Partnership for Public Service, which based its estimate on public reports of federal workforce cuts.
“DOGE is essentially derivative of Project 2025,” Dans said. “In a way, Project 2025 was a concept car and DOGE was maybe one of the first production units off the line. And in a way DOGE was somewhat cooler, if you will, than the concept car. My hat goes off to Elon Musk.”
Trump also has taken steps to eliminate, cut or remake multiple federal agencies and programs, remove Democratic members of independent federal agencies and boards (sometimes without cause), and wield the “enormous power” of the presidency (as Vought put it) to change policies at the state and local levels, as well as higher education institutions and private companies. He also has overhauled the Justice Department to ensure that its “litigation decisions are consistent with the President’s agenda,” as Project 2025 proposed.
“The second Trump administration is engaged in the first real transfer of power since 1933,” Mike Gonzalez, a senior fellow at Heritage and one of the Project 2025 authors, wrote in March.
In a TV interview, David Graham, author of “The Project: How Project 2025 Is Reshaping America,” said he didn’t appreciate the thoroughness of the conservative document until after the election – providing Trump with not only policy proposals but “a scheme for how to make it happen.”
“I’m somewhat ashamed to admit, after the election that I sat down and read the whole thing start to finish,” Graham said. “And I feel like it gave me a new appreciation for what a complete plan it is, like, how systematic and how methodical they are.”
During the campaign, Trump voiced support for many of the proposals contained in Project 2025. He campaigned, for example, on ending diversity, equity and inclusion programs, pulling out of international agreements that address climate change, and abolishing the Education Department.
And the Trump administration in some cases has followed Project 2025’s suggested methods of implementing the proposals.
The document suggested, for example, using “the full force” of the Civil Rights Division of the Justice Department against state and local governments, universities, and other private sector employers who engage in “unlawful discrimination,” such as “so-called diversity, equity and inclusion” offices and “‘equity’ plans.” That’s what the DOJ has done – angering hundreds of Civil Rights Division lawyers and staffers who quit.
By our count, 32 of the 40 named authors in Project 2025 have ties to past or current Trump administrations or campaigns – including eight who are currently working or consulting for executive agencies or were appointed to federal positions by Trump. That’s despite the head of Trump’s transition team saying a second Trump administration would not hire anyone affiliated with Project 2025. Prior to the election, the New York Times reported that at least 144 of the 267 “additional contributors” to Project 2025 also worked in Trump’s first administration, on his campaign or on transition teams.
We also found that half of the Education Department’s partners in the newly formed America 250 Civics Education Coalition also served on Project 2025’s advisory board. The department says the initiative is “dedicated to renewing patriotism, strengthening civic knowledge, and advancing a shared understanding of America’s founding principles in schools across the nation.”
In addition to Vought, these are the other prominent Project 2025 authors or contributors who are serving in the current administration or have been nominated by Trump:
Lindsey Burke, who now serves in Trump’s Education Department, wrote in Project 2025’s section on the department: “Federal education policy should be limited and, ultimately, the federal Department of Education should be eliminated.”
Tom Homan, a Project 2025 contributor, was acting director of the U.S. Immigration and Customs Enforcement in Trump’s first term and now serves as Trump’s border czar.
Peter Navarro, who wrote the section on “fair trade” and served as Trump’s trade adviser in the first administration, is now the White House senior counselor for trade and manufacturing.
Jonathan Berry, who wrote the section on the Department of Labor, was nominated to become the solicitor of the department. He has yet to be confirmed.
E.J. Antoni, a contributor and chief economist of Heritage’s Grover M. Hermann Center for the Federal Budget, was recently nominated as commissioner of the Bureau of Labor Statistics. Trump fired the previous commissioner after falsely accusing her of rigging jobs data.
John Ratcliffe, a contributor and former congressman from Texas, serves as the CIA director.
Adam Candeub, who wrote the section on the Federal Trade Commission, was hired as the FCC general counsel.
Another high-profile Trump appointee with ties to Project 2025 is Brendan Carr, who wrote the section on the Federal Communications Commission.
Trump appointed Carr to the FCC in 2017 and elevated him to FCC chairman this year. Carr has been criticized for suggesting the FCC could take action against Disney, ABC’s parent company, for late-night comedian Jimmy Kimmel’s comments related to the murder of conservative commentator Charlie Kirk.
Carr made no mention of broadcasters in Project 2025, but he noted that his chapter “does not purport to set forth a comprehensive agenda for the FCC” and addressed only “a selected handful of issue areas that may quickly rise to the attention of a new Administration.”
“Reining in Big Tech” was Carr’s top priority. He suggested ways to hold companies accountable for abusing their “dominant positions in the market … to drive diverse political viewpoints from the digital town square.” He proposed making it easier to successfully sue social media companies and other online service providers who remove user-generated content.
In the sections below, we review some of Project 2025’s recommendations to “dismantle the administrative state” and to what extent Trump has implemented them.
DOGE workforce reductions
Project 2025 repeatedly referred to federal departments and agencies as “bloated,” noting that there are more than 2 million executive branch civilian employees who receive about $300 billion in wages and compensation.
“Reducing the number of federal employees seems an obvious way to reduce the overall expense of the civil service, and many prior Administrations have attempted to do just this,” the document said, while warning that “reductions-in-force,” or RIFs, aren’t easy and could be costly if not done right.
Trump immediately set out to cut the federal government payroll. On Day 1, Trump issued a memo that instituted a hiring freeze and ordered DOGE and the directors of the Office of Management and Budget and the Office of Personnel Management to develop a plan “to reduce the size of the Federal Government’s workforce.”
Since then, the administration has reduced staff by offering incentives for voluntary resignations, issuing layoff notices and firing probationary workers who had been on the job for less than two years.
The staff cuts so far total more than 200,000, with the largest reductions in the departments of Defense (55,533), Treasury (30,267) and Agriculture (21,564), according to the nonprofit Partnership for Public Service, which tracks public reports of federal workforce cuts through Sept. 23.
“DOGE began its federal agency reduction efforts with the elimination of all employees in federal agencies who worked on diversity, equity, and inclusion, with these individuals being put on administrative leave,” according to Government Executive, a website for government officials and contractors.
In late January, OPM offered most civilian federal workers the chance to leave their jobs through a voluntary deferred resignation program, which allowed employees to resign but continue to get paid through the end of the federal fiscal year on Sept. 30. In a July 31 article, the Washington Post reported that more than 154,000 federal employees took the offer.
In late February, the Office of Personnel Management ordered agencies to fire en masse more than 25,000 probationary workers who had been working for less than two years — triggering months of legal wrangling, including a Supreme Court temporary order in April that allowed the administration to fire 16,000 of the workers. In September, District Judge William Alsup issued a summary judgment in favor of the workers. He found the mass firings unlawful because only agency heads, not OPM, can fire employees. He also acknowledged the workers “have moved on with their lives” and are unlikely to return to their government jobs, so he ordered OPM to update their files.
Also in February, the OMB and OPM directors sent department and agency heads a letter directing them to develop reorganization and reductions-in-force plans. The American Federation of Government Employees sued Trump, but the Supreme Court in July ruled, for now, that nearly two dozen departments can move ahead with their layoff plans while the case continues to be heard.
As of Aug. 31, Challenger, Gray & Christmas Inc., a recruitment firm, said the government sector lost more jobs in 2025 than any other sector.
“‘DOGE Actions’ remains the leading reason for job cut announcements in 2025, cited in 292,279 planned layoffs so far this year. This includes direct reductions to the Federal workforce and its contractors,” the company said in an August jobs report. “An additional 17,346 cuts have been attributed to DOGE Downstream Impact, such as the loss of funding to private non-profits and affiliated organizations.”
The August report said the loss of federal government jobs so far this year is nearly eight times the number of government job losses during the same period last year.
Public-sector unions
Calling public-sector unions “not compatible with constitutional government,” Project 2025 suggested ending collective bargaining rights for federal civilian employees.
The document called on federal agency managers and OPM to enforce “management rights” in the Civil Service Reform Act. “[A]ny future OPM and agency managements … should not be intimidated by union power.” It also said Congress should “consider whether public-sector unions are appropriate in the first place.”
Trump used the legal mechanism that the conservative document recommended to act.
On March 27, Trump issued an executive order terminating union contracts and ending collective bargaining rights for federal employees who work in agencies where the “primary function” is “intelligence, counterintelligence, investigative, or national security work.” A fact sheet accompanying his order said Trump was “using authority granted by the Civil Service Reform Act of 1978 (CSRA) to end collective bargaining” for national security reasons.
His order came nearly three weeks after Homeland Security Secretary Kristi Noem announced she eliminated collective bargaining for an estimated 47,000 TSA security officers who screen airport passengers.
On Aug. 28, Trump issued another executive order that expanded the list of agencies affected by his March order, bringing the total to 40.
In all, Trump’s executive orders affect more than a million federal employees, according to the American Federation of Government Employees.
Labor unions, including the AFGE, sued to prevent the orders from taking effect. But on Aug. 1, an appeals court allowed the Trump administration to end collective bargaining, while the lawsuit proceeds.
Project 2025 also called for making it easier to fire federal civil servants by reissuing an executive order that Trump signed late in his first term but never took effect.
On Oct. 21, 2020, Trump signed an order that created a new classification — Schedule F — for career civilian servants deemed by agency heads to have “policy-determining, policy‑making, and policy-advocating positions.” Two days later, OPM issued guidelines for implementing the new policy.
Dans, the Project 2025 director, worked at OPM in 2020 when Schedule F guidelines were issued. “Schedule F needed to be implemented” to make “these policy-determining positions responsive to the president,” Dans told us.
Dans co-authored the section in Project 2025 on “managing the bureaucracy,” which said Trump’s 2020 order creating Schedule F would have allowed for the removal of “career professionals in positions that are not normally subject to change as a result of a presidential transition.”
In his second term, Trump issued an executive order on Jan. 20 that says that federal workers in “policy-influencing positions” 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 dismissal.”
A week later, OPM issued guidance to department and agency heads on implementing Trump’s order. An estimated 50,000 positions would be reclassified, OPM said.
“This process intends to allow OPM to strip tens of thousands of federal employees in ‘policy-related’ jobs of civil service protections making it easier for them to be fired,” Government Executive wrote.
The National Treasury Employees Union sued, and the District Court issued a stay until it can receive a status update by Oct. 25 after a final rule has been issued.
Federal spending
Vought – who is now the influential OMB director at the White House – wrote in Project 2025 that the OMB director should “present a fiscal goal to the President” to”the federal government’s fiscal irresponsibility.”
“The President should use every possible tool to propose and impose fiscal discipline on the federal government,” he wrote. “Anything short of that would constitute abject failure.”
Under Vought’s direction, OMB told federal agencies in a Jan. 27 memo that they “must temporarily pause … all Federal financial assistance,” such as grants and loans, “that may be implicated” by Trump’s recent executive orders, “including, but not limited to, financial assistance for foreign aid, nongovernmental organizations, DEI, woke gender ideology, and the green new deal.”
The OMB memo, which placed the amount of federal assistance at stake at $3 trillion, was accompanied by a list of about 2,600 programs that were subject to an immediate freeze and further review, according to the New York Times.
But Trump’s attempts to unilaterally freeze or terminate congressionally appropriated funds ran afoul of the courts.
A day after the OMB memo was sent, U.S. District Court Judge Loren L. AliKhan in Washington, D.C., issued a temporary injunction to prevent the administration from denying federal payments. The next day, OMB rescinded its memo and directed department heads to “contact your agency General Counsel” on how to implement the president’s executive orders.
“This is NOT a rescission of the federal funding freeze. It is simply a rescission of the OMB memo,” White House Press Secretary Karoline Leavitt wrote on social media. “Why? To end any confusion created by the court’s injunction.”
Rescinding the memo did not stop the administration’s attempts to halt certain payments nor the flurry of legal challenges to different parts of the funding freeze.
In the subsequent months, AliKhan issued another ruling that continued to block the spending freeze, and twoother judges handling related lawsuits issued similar injunctions.
While the cases are still pending, the administration succeeded in getting Congress to rescind some funding it had previously approved. Trump signed bills in July that rescinded an estimated $540 billion in green energy tax credits and clawed back another $9 billion for foreign aid and public media organizations.
But in issuing orders to halt the cuts while the cases proceed, judges have repeatedly said that the Trump administration cannot withhold congressionally appropriated funds unless Congress votes to rescind the funding. One judge – U.S. District Judge Amir Ali – recently ordered the administration to obligate billions of dollars in congressionally appropriated foreign aid by the end of the fiscal year on Sept. 30.
“Under ‘settled, bedrock principles of constitutional law,’ the President ‘must follow statutory mandates so long as there is appropriated money available and the President has no constitutional objection to the statute,’” Ali wrote in a Sept. 3 order, quoting from a 2013 appeals court rulingwritten by Supreme Court Justice Brett Kavanaugh when he was on the D.C. Circuit Court of Appeals.
The administration filed an emergency application that asked the Supreme Court to temporarily block Ali’s order from taking effect. Chief Justice John Roberts issued an interim order on Sept. 9 granting the Trump administration’s request and the full court stayed Ali’s order on Sept. 26. Justice Elena Kagan wrote a dissent, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson, that said the order, while temporary, will have the effect of preventing the funds from ever being spent.
Any savings from federal spending cuts and labor reductions will be offset over time by Trump’s signature legislative accomplishment – the reconciliation bill known as the One Big Beautiful Bill Act. The nonpartisan Congressional Budget Office estimated that the new law will result in a net increase of $3.4 trillion in deficits over a 10-year period.
Department of Justice
In its section on the Department of Justice, Project 2025 said it is “essential that the next conservative Administration place a high priority on reforming the DOJ” — claiming “large swaths” of the department “have been captured by an unaccountable bureaucratic managerial class and radical Left ideologues.”
The document called for “a top-to-bottom overhaul” of the Justice Department, notably the Civil Rights Division. (We address the Civil Rights Division in a separate article.)
“At a practical level, not reforming the Department of Justice will also guarantee the failure of that conservative Administration’s agenda in countless other ways,” it said.
One Project 2025 recommendation: “Issue guidance to ensure that litigation decisions are consistent with the President’s agenda and the rule of law.”
“Ultimately, the department will have to make tough calls as it manages its litigation, but those calls must always be consistent with the President’s policy agenda and the rule of law,” the document said. “A line attorney should never either directly or indirectly pursue a policy agenda through litigation that is inconsistent with the agenda of his or her client agency or the President.”
Trump and his attorney general, Pam Bondi, have enacted that recommendation.
On her first day in office, Bondi issued a flurry of directives on Feb. 5 to align the department’s mission with Trump’s agenda.
One memo warned that “any attorney who … refuses to advance good-faith arguments on behalf of the administration, or otherwise delays or impedes the department’s mission will be subject to discipline and potentially termination, consistent with applicable law.”
The weaponization memo also targets for review any alleged “federal cooperation” with Manhattan District Attorney Alvin Bragg and New York Attorney General Letitia James for their successful prosecution of Trump for falsifying business records. The memo also directed the working group to review alleged “improper investigative tactics and unethical prosecutions” of people convicted (and later pardoned by Trump) of attacking the U.S. Capitol and law enforcement officials on Jan. 6, 2021.
The following month, Trump delivered a rare presidential speech at the Department of Justice to attack some of the people singled out in Bondi’s memo, including Bragg, James and “deranged Jack Smith,” as well as former FBI Director Jim Comey, whom Trump fired in his first term.
On Sept. 25, the DOJ indicted Comey just days after Trump pressured Erik Siebert to resign as U.S. attorney for the Eastern District of Virginia. Trump then urged Bondi to replace Siebert with Lindsey Halligan, a White House aide with no experience as a prosecutor, and pursue criminal charges against Comey, James and Democratic Sen. Adam Schiff. (Trump took credit for firing Siebert, and Halligan signed the two-page indictment against Comey.)
“I think there’ll be others,” Trump said, when asked who would be indicted next. “I hope there are others.”
In his DOJ speech, Trump described department employees as “a corrupt group of hacks and radicals.” Since then, the department has not only indicted Comey, but fired hundreds of lawyers and staffers, including employees who were assigned to work in the special counsel office under Smith. (The DOJ has also opened an investigation of Smith.) Hundreds more DOJ staffers have voluntarily left rather than continue to work under the revamped DOJ.
“DOJ is now being used as a personal weapon on behalf of Trump to a degree that is without precedent,” Peter Shane, a constitutional law professor at New York University, said in an interview with the Guardian.
Independent agencies
In 1935, the U.S. Supreme Court ruled in Humphrey’s Executor v. United States that President Franklin D. Roosevelt did not have the power to remove William E. Humphrey from the Federal Trade Commission – an independent regulatory agency that enforces consumer protection and antitrust laws.
The court held that Humphrey, an appointee of President Herbert Hoover, could be removed only for “inefficiency, neglect of duty, or malfeasance in office,” as stated in the Federal Trade Commission Act. “The commission is to be non-partisan, and it must, from the very nature of its duties, act with entire impartiality,” the court wrote.
Project 2025 called on the Department of Justice to seek to overturn the precedent, claiming it is unconstitutional.
“The FTC’s commissioners are not removable at will by the President, which many quite reasonably believe violates the Vesting Clause of Article II of the Constitution; it is for this reason that conservatives have long believed in either ending law enforcement activities of independent agencies or ending their independent status,” Project 2025 said. “The Supreme Court ruling in Humphrey’s Executor upholding agency independence seems ripe for revisiting—and perhaps sooner than later.”
In February, Trump’s Justice Department notified Congress that it had determined the “for-cause removal provisions” that protect members on certain independent regulatory commissions are unconstitutional. Specifically, the letter said “the statutory tenure protections” for members of the Federal Trade Commission, the National Labor Relations Board and the Consumer Product Safety Commission are unconstitutional.
There are 30 independent agencies, commissions and boards – including the FTC, NLRB and CPSC — that have “explicit ‘for-cause’ provisions” that allow the president to remove members only for “‘neglect of duty,’ ‘malfeasance in office,’ ‘inefficiency,’ or similar language,” according to the Administrative Conference of the United States’ Sourcebook of United States Agencies. (See Table 9)
About a month after the Justice Department’s letter, Commissioners Rebecca Slaughter and Alvaro Bedoya were removed from the FTC. Both received letters that said their “continued service on the FTC is inconsistent with my Administration’s priorities” – citing Article II of the Constitution, as Project 2025 did in its recommendation.
Stephen Vladeck, a professor at Georgetown University Law Center, told SCOTUSblog that “opposition to Humphrey’s Executor has become something of a cause célèbre especially among conservative judges and scholars, but this is the first time I think we’ve seen the justice department specifically take the position not just that it’s wrong, but that it should be overruled.”
Slaughter, who was appointed by Trump in 2018 and reappointed by Biden in 2022, and Bedoya, who was appointed by Biden in 2022, sued Trump, saying the “Constitution empowers Congress to set reasonable limitations on the removal of the heads of independent agencies.”
“In short, it is bedrock, binding precedent that a President cannot remove an FTC Commissioner without cause,” the suit said. “And yet that is precisely what has happened here: President Trump has purported to terminate Plaintiffs as FTC Commissioners, not because they were inefficient, neglectful of their duties, or engaged in malfeasance, but simply because their ‘continued service on the FTC is’ supposedly ‘inconsistent with [his] Administration’s priorities.’”
In a court filing, the administration argued – as it did in its letter to Congress — that the “termination was lawful because the Commissioners’ removal protections are unconstitutional.”
Bedoya resigned in June, saying he needed to get a new job. The following month, U.S. District Judge Loren L. AliKhan granted Slaughter’s request for summary judgment and issued a permanent injunction that reinstated her to the FTC.
But after weeks of legal wrangling, the Supreme Court on Sept. 22 temporarily stayed AliKhan’s permanent injunction, allowing the administration to remove Slaughter, and the high court agreed to hear arguments on whether “statutory removal protections” for FTC members “violate the separation of powers.”
The FTC case “could dramatically upend Supreme Court precedent and give the executive branch much greater authority over federal agencies,” SCOTUSblog said about the Sept. 22 order.
In agreeing to hear the FTC case, the Supreme Court could overrule Humphrey’s Executor and find that the congressional protections are unconstitutional.
Trump’s attempt to remove Democratic appointees extends to the Federal Reserve, although in that case he fired Federal Reserve Governor Lisa Cook for cause.
Trump alleged that Cook committed mortgage fraud – although she has not been charged, and Trump’s fraud claim has been undercut by documents obtained by the Associated Press. Cook sued Trump, and on Sept. 15 a federal appeals court upheld a District Court judge’s temporary injunction that allows Cook to remain on the board, while she appeals her firing.
Department of Education
During the campaign, Trump and Project 2025 were in sync on eliminating the Department of Education.
“We’re going to close it up,” Trump said about the department in a September 2023 campaign video. “We’re going to send it all back to the states.”
In Project 2025, Burke, who was appointed the Education Department’s deputy chief of staff for policy and programs in June, called for the department’s elimination and wrote that federal education funding “should be block-granted to states without strings, eliminating the need for many federal and state bureaucrats.”
Only Congress can abolish the department, but the Trump administration has taken steps that would “facilitate” the closing of the department and change how the federal government funds schools.
On March 11, Education Secretary Linda McMahon, co-founder and former president of World Wresting Entertainment, announced the department would cut its staff in half, eliminating roughly 2,000 workers through buyouts (600) and layoffs (1,400). The next week, Trump issued an executive order that directed McMahon to “take all necessary steps to facilitate the closure of the Department of Education.”
Twenty states and the District of Columbia filed suit, claiming the “massive” layoffs amount to an illegal and unconstitutional attempt to incapacitate “key, statutorily-mandated functions.”
In July, however, the Supreme Court allowed the layoffs to move forward. The high court reversed a lower court ruling that temporarily blocked the staff cuts from taking effect.
As for funding, OMB on July 1 withheld more than $6 billion in education grants approved by Congress, claiming “many of these grant programs have been grossly misused to subsidize a radical leftwing agenda.” The administration relented after Democrats sued and Republicans complained.
For fiscal year 2026, which begins Oct. 1, Trump submitted a budget to Congress that would cut the Education Department by $12 billion, or 15.3%, which the department said in a budget document “reflects an agency that is responsibly winding down.”
In the GOP-controlled Congress, the House Appropriations Committee went along with Trump’s $12 billion cut to the department, but Senate appropriators rejected the cuts and approved a slight increase in the department’s overall budget from the fiscal 2025 level.
In Trump’s proposed budget, the biggest cut would come from eliminating the K-12 School Improvement Programs, which received nearly $5.8 billion this year, and replacing it with a new K–12 Simplified Funding Program, which would receive $2 billion – a cut of nearly $3.8 billion, according to the department’s proposed budget. (K-12 School Improvement Programs provide funding to help states and schools comply with the Elementary and Secondary Education Act, including “developing and administering student achievement assessments,” as explained in a House budget document.)
According to a summary of Trump’s budget proposal, the new Simplified Funding Program “consolidates 18 competitive and formula grant programs into a new $2 billion formula grant designed to reduce ED’s influence on schools and students and reduce bureaucracy.”
From its inception in July 2011 through Dec. 3, the CFPB said it has sent more than 6.8 million consumer complaints to companies and provided about $21 billion in financial relief to about 205 million people.
Project 2025 proposed the “immediate dissolution of the agency,” calling it “a shakedown mechanism to provide unaccountable funding to leftist nonprofits politically aligned with those who spearheaded its creation.”
Trump cannot abolish it, because it was established by law. But the president has essentially crippled the office’s ability to function.
In early February, Trump fired the CFPB director and installed OMB Director Vought as the CFPB’s acting director. Within days, Vought closed the bureau’s Washington office and told its employees not to come to work or “perform any work tasks,” as reported by NPR. The CFPB name and emblem were removed from its Washington building.
In April, Vought sent layoff notices to about 1,500 CFPB employees, reducing its staff to only 200. “An approximately 200 person agency allows the Bureau to fulfill its statutory duties and better aligns with the new leadership’s priorities and management philosophy,” the bureau’s chief legal officer said in an April 18 court filing.
This all triggered an ongoing legal fight that resulted in a court order in April that temporarily paused the mass firings from taking effect for months. But on Aug. 15, an appeals court in a 2-1 ruling lifted the stay and allowed the administration to move ahead with firing CFPB employees. The majority opinion said the District Court lacked jurisdiction.
During the legal back-and-forth, “the bureau has been mostly inoperable” and employees who won a court reprieve “essentially spend the workday sitting on their hands,” the Associated Press wrote.
Some work has been getting done, but there is a backlog of unresolved complaints.
In Trump’s first eight months in office, as of Sept. 29, agency data show that the CFPB received more than 3.6 million complaints from consumers – more than double the number that it received during the same time period last year. Most of this year’s complaints have been closed, including about 15,006 that ended with some type of monetary relief – down from 16,170 a year ago. But more than 930,870 of this year’s complaints remain in progress – far more than the 28,650 complaints that were in progress a year ago.
In July, the bureau announced it reached a $9 million settlement with a pawn shop chain accused in a November 2021 lawsuit filed during the Biden administration of charging excessive interest rates to military members. But that same month, the Wall Street Journal reported that CFPB dropped “more than 20 cases” against companies accused of bilking consumers, including a settlement with Navy Federal Credit Union that would have refunded members of the military $80 million.
IRS
The Inflation Reduction Act, which was enacted in 2022, provided about $80 billion over 10 years for the IRS. At the time, a Treasury Department spokesperson told us that the IRS would use the money to “improve taxpayer services – from answering the phones to improving IT systems – and to crack down on high-income and corporate tax evaders.”
Project 2025 called on Congress to rescind the funding the IRS received from the IRA, saying it “contains a radical $80 billion expansion of the IRS — enough to double the size of its workforce,” echoing misleading claims that we’ve debunked. “Unless Congress reverses this policy, the IRS will become much more intrusive and impose still greater costs on the American people.”
Congress has cut IRS funding, and Trump has cut its staff.
“Since 2023, Congress has rescinded $42 billion” of the nearly $80 billion the IRS received from the 2022 law, according to the Tax Policy Center. After congressional rescissions, the IRS was left with $37.6 billion from the IRA and about $5.7 billion of that was used on “technology modernization,” according to an August report by the Treasury Inspector General for Tax Administration.
In addition to funding cuts, the IRS has been part of Trump’s massive layoffs of federal employees – which cut more than 25,000 staffers, or roughly 25%, from the IRS workforce, according to a July 18 report by the Treasury Inspector General.
In addition, more than 7,000 probationary workers were given termination notices, but were later recalled by the IRS. “Currently, it is unclear whether any terminated probationary employees called back to work will be subject to a large-scale RIF,” the TIGTA report said.
In a June report to Congress about fiscal year 2026, the National Taxpayer Advocate, an independent IRS organization, expressed concerns about “operational readiness” for the 2026 tax filing season because of the staffing cuts. “Staffing reductions and the loss of experienced personnel, particularly in mission-critical areas, create vulnerabilities in service delivery, return processing, and taxpayer assistance,” it said.
After the reports were released, IRS human resources officials reportedly told their managers that the agency would recall some of those who were asked to leave or approved for deferred resignation programs, according to Government Executive. A Treasury spokesperson told Government Executive that the IRS will be “staffed appropriately to serve the American people effectively and efficiently.”
Federal Emergency Management Agency
The Federal Emergency Management Agency is the lead federal agency that responds to hurricanes, wildfires and other natural disasters. In fiscal years 2017 through 2020, which covers most of Trump’s first term, FEMA spent nearly $94 billion from its Disaster Relief Fund, according to the CBO.
In calling for an overhaul of the “bloated” Department of Homeland Security “bureaucracy and budget,” Project 2025 called for “reforming” FEMA and shifting “the majority of preparedness and response costs to states and localities instead of the federal government, eliminating most of DHS’s grant programs.”
In January, Trump signed an executive order that created a FEMA review panel to assess FEMA’s work over the past four years, which would only cover the Biden presidency. In remarks on the day he signed the order, Trump echoed the language of Project 2025.
“I’ll also be signing an executive order to begin the process of fundamentally reforming and overhauling FEMA or maybe getting rid of FEMA,” Trump said. “I think, frankly, FEMA is not good.”
If there was any doubt about the president’s plans, Noem – the Homeland Security secretary and a co-chair of the FEMA review panel – said at a Cabinet meeting in late March: “We’re going to eliminate FEMA.”
In June, the president again spoke about turning FEMA over to the states and providing “less money” from the federal government. Asked “how soon do you want to see FEMA eliminated,” Trump said: “After the hurricane season, we’ll start phasing that in.” The hurricane season extends from June 1 through Nov. 30 in the Atlantic.
“So we want to wean off of FEMA, and we want to bring it down to the state level,” Trump said. “A little bit like education, we’re moving it back to the states, so the governors can handle it. That’s why they’re governors. Now, if they can’t handle it, they shouldn’t be governor. But these governors can handle it, and they’ll work in conjunction with other governors. They’ll give each other a hand.”
Less than a month later, a Texas flood on July 4 killed at least 138 people, complicating Trump’s plans. On NBC News’ “Meet the Press” on July 13, Noem was asked if FEMA should be “eradicated” and she said, “No.” She said Trump “wants it to be remade so that it’s an agency that is new in how it deploys and supports states.”
Four days earlier, Noem attended the FEMA review council meeting on July 9, and the meeting minutes summarized her remarks by saying she “reiterated that federal emergency management should be state and locally led, which is why FEMA must be eliminated as it exists today.”
At that meeting, Virginia Gov. Glenn Youngkin, who chairs the review committee’s Federal-State Coordination Subcommittee, said his panel should be able to “provide recommendations on how we shift responsibility to the states, and therefore move FEMA from being a supplant role into a support role,” according to a Federal News Network article on the meeting.
The president’s order requires the FEMA review council to submit a report to him by November. But the administration has already declared victory.
On the 20th anniversary of Hurricane Katrina — which the National Weather Service said “was responsible for 1,833 fatalities and approximately $108 billion in damage” in 2005 dollars — DHS put out a press release that claimed Trump and Noem “have successfully reformed federal disaster response after decades of failure and neglect.”
The “FEMA Review Council is hard at work” and “FEMA reform is still active and ongoing,” the Aug. 29 release said.
However, in a letter to the review council, current and former FEMA employees said that staffing and program cuts and other changes already implemented by DHS and FEMA leaders “erode the capacity of FEMA … hinder the swift execution of our mission, and dismiss experienced staff whose institutional knowledge and relationships are vital to ensure effective emergency management.”
The letter said a third of FEMA’s full-time staff have left the agency due to “programs designed to incentivize our workforce to leave federal service, ongoing hiring freezes, and the cancellation of critical support contracts.”
Corporation for Public Broadcasting
The Corporation for Public Broadcasting is a “private, nonprofit corporation authorized by Congress in the Public Broadcasting Act of 1967,” as its website explains.
Regardless of party control, Congress has funded CPB for nearly six consecutive decades – even over the objections of Republican Presidents George W. Bush and Trump. Since fiscal year 1969, CPB has received nearly $16 billion in federal funds, which it distributed to PBS and NPR stations.
Project 2025 called for defunding CPB, which the document derided as “a liberal forum for public affairs and journalism.”
“[T]he next conservative President must finally get this done and do it despite opposition from congressional members of his own party if necessary,” Project 2025 said.
Trump succeeded in July, when he signed legislation that rescinded $1.1 billion in federal funding for CPB for fiscal years 2026 and 2027. “REPUBLICANS HAVE TRIED DOING THIS FOR 40 YEARS, AND FAILED….BUT NO MORE. THIS IS BIG!!!,” Trump wrote on social media.
CPB announced shortly after the bill signing that it would end operations, with most employees leaving on Sept. 30 and a “small transition team” staying in place through January 2026.
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