April 1, 2025
Jason Sheffield, National Director, Benefits Compliance
During the short tenure of President Trump’s second term, his administration has signed at least ninety-three (93) Executive Orders, chiefly designed to impart guidance reflective of the President’s public policy goals. As unfunded mandates, Executive Orders are generally more instructive than actionary; however, the President has sought to expand the scope and voracity of Executive Orders by utilizing them as a replacement for enacted public laws and and published agency rulemaking.
While the full scope of Trump’s flurry of executive orders is beyond the purview of this article, herein we focus on providing overview and status reports respecting the Executive Orders and Presidential Proclimations carrying the most significance for employee benefit related issues, or issues of labor and employment law, generally. Respecting each Executive Order detailed below, please find a title, overview, and status report.
We intend to update this inventory as additional orders are signed, or as litigation related events shape the course of implementation and enforcement of Trump’s bevy of orders.
Executive Orders Summary
Title:
Restoring Accountability to Policy-Influencing Positions Within the Federal Workforce
Overview:
This reinstates a prior executive order President Trump signed near the end of his first administration, which reclassified career federal employees into a new category of political appointees. This reclassification removes these employees’ civil service protections, which insulated them from political pressures so that they may now be fired at will.
Status:
The National Treasury Employees Union filed a lawsuit on January 21, 2025, seeking to halt its implementation, arguing it undermines civil service protections. As of now, the order remains in effect, with litigation ongoing. Three additional labor union groups have also sued the administration over the policy.
Title:
Reforming the Federal Hiring Process and Restoring Merit to Government Service
Overview:
This order aims to increase the overall efficiency of selecting and recruiting government employees. Agencies are directed to enact a process that prioritizes candidates committed to government efficiency and the “ideals of our American republic” without consideration of race, sex, or religion.
Status:
A coalition of labor unions and nonprofit organizations filed a lawsuit, arguing that the mass termination of probationary federal employees under this order violates federal personnel laws. In response, Judge William Alsup of the U.S. District Court for the Northern District of California temporarily blocked these terminations, stating that the Office of Personnel Management lacks the authority to mandate such dismissals across federal agencies. An evidentiary hearing is scheduled for March 13, 2025.
Title:
Ending Radical and Wasteful Government DEI Programs and Preferencing
Overview:
The director of the Office of Management and Budget (OMB) and other agencies are directed to terminate diversity, equity, and inclusion programs throughout the federal government. Agencies must report to the OMB director a list of all employees in DEI and “environmental justice” positions, as well as related committees, programs, activities, services, and budgets.
Status:
On February 21, 2025, the U.S. District Court for the District of Maryland issued a preliminary injunction blocking key provisions of the order, citing potential violations of constitutional rights. Additionally, civil rights organizations, including the National Urban League and the San Francisco AIDS Foundation, have filed lawsuits challenging the order’s legality.
Title:
Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government
Overview:
This order recognizes “two sexes, male and female.” It mandates that the federal government assert biological distinctions between men and women and refer to individuals by their “sex” instead of their gender identity. It further prohibits using federal funds “to promote gender ideology.”
Status:
On February 19, 2025, civil rights organizations, including the National Urban League and the National Fair Housing Alliance, filed a lawsuit in the U.S. District Court for the District of Columbia (National Urban League v. Trump, No. 25-00471), alleging that the order infringes upon constitutional rights and exceeds executive authority. Additionally, on February 20, 2025, the San Francisco AIDS Foundation and other LGBTQ+ organizations filed a lawsuit in the U.S. District Court for the Northern District of California (San Francisco AIDS Foundation v. Trump, No. 3:25-cv-01824), challenging the order’s legality.
Title:
Withdrawing the United States from the World Health Organization
Overview:
This order begins the process of withdrawing from the World Health Organization (“WHO”). It also rescinds a prior executive order, signed by former President Joe Biden, that coordinated the federal government’s COVID-19 response efforts and implemented processes to respond to emerging pandemics.
Status:
Legally, withdrawal from the WHO requires a one-year notice and full payment of outstanding dues, as stipulated in the joint resolution passed by Congress in 1948 (62 Stat. 441, 442). Consequently, the U.S. withdrawal would not take effect until January 20, 2026. Additionally, legal experts argue that since U.S. membership in the WHO was authorized by Congress, unilateral withdrawal by the executive branch may face legal challenges without congressional approval. As of now, this executive order is in effect, and the withdrawal process is underway, with legal and legislative challenges anticipated.
Title:
Initial Rescissions of Harmful Executive Orders and Actions
Overview:
This order rescinds 78 executive actions signed by former President Joe Biden, including several public health regulations. It also revoked an order promoting voter registration and a census order that could clear a path for reshaping election maps.
Status:
There have been no specific legal challenges reported against Executive Order 14150 itself. However, the revocation of prior orders has prompted legal actions. Notably, civil rights organizations have filed lawsuits challenging the termination of diversity, equity, and inclusion (DEI) programs, alleging violations of constitutional rights. For instance, the National Urban League and the San Francisco AIDS Foundation have initiated legal proceedings against the administration’s actions. As of now, Executive Order 14150 remains in effect, with its implementation proceeding amidst ongoing legal challenges.
Title:
Enforcing the Hyde Amendment
Overview:
This executive order reinforces Congress’ Hyde Amendment, which prohibits the use of federal dollars to cover abortion and related health care, with limited exceptions. Most notably, the order rescinds two of former President Joe Biden’s 2022 executive orders, which sought avenues to expand access to reproductive and emergency health care after the Supreme Court overturned Roe v. Wade’s Constitutional right to an abortion, despite President Trump’s assurances to leave abortion regulation to the individual states.
Status:
As of now, there have been no reported legal challenges targeting Executive Order 14152, and it remains in effect.
Title:
Restoring America’s Fighting Force
Overview:
This order states that the U.S. Armed Forces “should operate free from any preference based on race or sex.” It abolishes DEI offices and programs in the Defense Department and the Department of Homeland Security. It prohibits the promotion of “divisive concepts,” including that “America’s founding documents are racist or sexist.”
Status:
Multiple lawsuits have been filed by service members respecting the Executive Order, but at this time, the EO remains in effect without legal constraint.
Title:
Protecting Children from Chemical and Surgical Mutilation
Overview:
Purports that it is the policy of the United States that it will not fund, sponsor, promote, assist, or support the transitioning of gender for a child from one sex to another, and it will rigorously enforce all laws that prohibit these life-saving procedures. The EO expressly redefines gender affirming care as “chemical and surgical mutilation,” including the use of puberty blockers, including GnRH agonists and other interventions, to delay the onset or progression of normally timed puberty in an individual who does not identify as their sex, among other interventions.
Status:
On February 20, 2025, the San Francisco AIDS Foundation, along with other LGBTQ+ advocacy groups, filed a lawsuit in the U.S. District Court for the Northern District of California, arguing that the order violates constitutional rights and exceeds executive authority. Similarly, on February 26, 2025, a coalition of civil rights organizations filed a lawsuit in the U.S. District Court for the District of Columbia, seeking to block the enforcement of the order on grounds that it discriminates based on gender identity and infringes upon medical professionals’ ability to provide standard care. As of now, Executive Order 14169 remains in effect; however, its implementation is subject to ongoing legal proceedings that may impact its enforceability.
Title:
Implementing the President’s “Department of Government Efficiency” Cost Efficiency Initiative
Overview:
Significantly impacts federal employees by increasing oversight and transparency in government spending on contracts, grants, and loans. It mandates the creation of centralized technological systems for tracking payments and travel expenses, requiring written justifications for approvals. Employees will face heightened scrutiny on financial decisions, with a temporary freeze on government credit cards and a review of existing contracts for potential termination or renegotiation. Additionally, agencies must reassess real property holdings and leases, aiming to reduce costs. These measures enhance accountability but may also introduce administrative burdens and delays in procurement and travel processes.
Status:
The National Council of Nonprofits filed a lawsuit in the U.S. District Court for the District of Columbia, contesting the order’s directives on the grounds that they could unlawfully delay or cancel appropriated funds, potentially constituting impoundment. In response, U.S. District Judge Loren AliKhan issued an administrative stay, temporarily halting the enforcement of the order’s provisions related to the disbursement of federal funds under existing awards. As of now, Executive Order 14154 remains in effect; however, its implementation is partially suspended pending ongoing legal proceedings.
Title:
Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information
Overview:
Strengthens healthcare price transparency requirements, increasing compliance obligations for both private and federal employers that sponsor health plans. Employers must ensure that their health plans fully disclose actual, not estimated, costs for medical services and prescription drugs, as well as maintain user-friendly tools for employees to compare pricing. The order also calls for stricter enforcement of existing transparency rules, potentially increasing audits and penalties for non-compliance. Employers may need to update benefits platforms, negotiate clearer pricing structures with insurers, and enhance employee education on cost-saving healthcare options. These measures aim to reduce overall healthcare costs but could introduce new administrative burdens for compliance.
Status:
As of now, there have been no reported legal challenges specifically targeting this executive order, and Executive Order 14154 remains in effect.
Title:
America First Investment Policy
Overview:
This memorandum directly impacts private and public employers subject to ERISA by mandating updated fiduciary standards regarding investments in public market securities of “foreign adversary” companies. The Department of Labor is tasked with publishing new ERISA fiduciary guidance, which could impose stricter limitations on retirement plan investments that involve securities tied to countries such as China, Russia, Iran, and others. Employers and plan fiduciaries may need to review and potentially divest certain assets from their retirement plans, such as 401(k)s and pension funds, to ensure compliance with these new restrictions. Additionally, plan sponsors will face increased scrutiny regarding their investment selections, with potential enforcement actions for non-compliance. This policy shift could lead to administrative burdens, require changes to investment options, and impact the overall portfolio diversification strategies of ERISA-governed retirement plans.
Status:
As of now, there have been no reported legal challenges specifically targeting this NSPM, and it remains in effect.
Title:
Commencing the Reduction of the Federal Workforce
Overview:
Aims to reduce the size of the federal government by eliminating or downsizing various non-statutory agencies, advisory committees, and programs deemed unnecessary. Key agencies affected include the Presidio Trust, the Inter-American Foundation, and the United States Institute of Peace, among others, while the Presidential Management Fellows Program and certain Federal Advisory Committees will be terminated. For public employers, this could lead to federal workforce reductions and restructuring, impacting employees in affected agencies. Private sector employers may experience changes in federal contracting, regulatory oversight, and grant funding availability, particularly in industries tied to affected agencies. Initial compliance reports are due within 14 to 30 days, signaling immediate implementation efforts.
Status:
As of now, Executive Order 14156 remains in effect, with its implementation proceeding amidst ongoing legal challenges
Title:
Ensuring Lawful Governance and Implementing the President’s “Department of Government Efficiency” Deregulatory Initiatives
Overview:
This Executive Order directs federal agencies, including the IRS, DOL, EEOC, and EBSA, to review and potentially rescind or deprioritize enforcement of employment and employee benefits regulations deemed unconstitutional, overly burdensome, or lacking clear statutory authority. Employers may see reduced federal oversight on wage laws, workplace discrimination, ERISA fiduciary duties, ACA compliance, and OSHA safety regulations, potentially easing administrative burdens. However, state enforcement and legal challenges could maintain existing requirements, requiring employers to stay informed on regulatory updates. Employers should monitor agency guidance, review HR and benefits policies, and ensure compliance with evolving state and federal regulations.
Status:
As of the current date, there have been no reported legal challenges specifically targeting Executive Order 14156, which remains in effect, though several challenges are said to be in the works. The law and the Trump administration’s policy, though, are quite distinct. The White House’s attempts to purge the federal workforce, shutter entire departments, and centralize power in the executive branch are patently lawless. The courts have long been a venue for fights between industry interests, state governments, and environmental advocates. But the Trump administration’s attack on the separation of powers means the battles that groups wage in the courts are now about much more than policy disagreements, as parties seek to keep President Trump from ruling like a dictator.
Title:
Expanding Access to In Vitro Fertilization
Overview:
Aims to expand access to in vitro fertilization (IVF) treatments by lowering costs and removing regulatory barriers, recognizing infertility as a significant challenge for many Americans. Within 90 days of February 19, 2025, federal officials must present policy recommendations to reduce out-of-pocket and health plan costs for IVF. Public and private employers offering group health plans may face future requirements or incentives to cover IVF treatments or adjust plan designs to comply with new affordability measures. While the order does not mandate immediate changes, employers should monitor forthcoming policy updates that may impact health plan coverage and compliance obligations related to fertility treatments.
Status:
As of the current date, there have been no reported legal challenges specifically targeting Executive Order 14157, and it remains in effect.
Title:
Proclamation to Honor George Washington’s Birthday, 2025
Overview:
This proclamation designates February 17, 2025, as a reserved holiday to commemorate George Washington’s Birthday, honoring his legacy and contributions to the nation. Public sector employers may need to adjust operations if federal offices observe closures or modified schedules. Private employers are not mandated to recognize the holiday but may choose to offer time off or holiday pay in alignment with company policies. While the order does not impose new requirements, employers should review their holiday policies and workforce scheduling to accommodate any potential impacts on operations.
Status:
Presidential Proclamations carry little weight because they are unfunded and unenforceable. Generally, they are reserved for public policy and event related statements.
Title:
Keeping Education Accessible and Ending Covid-19 Vaccine Mandates in Schools
Overview:
Prohibits the use of discretionary federal funds to support schools, universities, and educational agencies that mandate COVID-19 vaccinations for in-person attendance. Within 90 days of February 19, 2025, the Secretary of Education must develop a plan to identify and penalize non-compliant institutions, potentially leading to funding restrictions. Public sector employers in education may need to modify their policies to maintain federal funding, while private sector employers in higher education or federally funded programs should review compliance requirements. While the EO does not directly impact private employers’ health plans, it may signal reduced regulatory focus on vaccine-related workplace mandates, affecting employment policies and benefits administration.
Status:
As of now, Executive Order 14158 remains in effect, with no reported legal challenges specifically targeting it.
Title:
Establishing the President’s Make America Healthy Again Commission
Overview:
Establishes the “Make America Healthy Again Commission” to address rising chronic disease rates, with a specific focus on childhood health issues. Within 100 days of February 13, 2025, the Commission must submit an assessment on childhood chronic diseases, followed by a comprehensive strategy within 180 days to restructure federal health policies. Public and private employers offering group health plans may see future policy changes promoting disease prevention, alternative treatments, and transparency in health data. Employers in healthcare, food production, and pharmaceuticals could face new regulatory scrutiny or reforms aimed at reducing chronic illness. While no immediate mandates are imposed, employers should monitor potential changes in health plan coverage requirements, workplace wellness programs, and federal health regulations.
Status:
As of now, there have been no reported legal challenges specifically targeting Executive Order 14159, and it remains in effect.
Title:
Eradicating Anti-Christian Bias
Overview:
Establishes the “Task Force to Eradicate Anti-Christian Bias” within the Department of Justice, directing federal agencies to review and eliminate policies perceived as discriminatory toward Christians. The Task Force must submit an initial report within 120 days of February 12, 2025, followed by a one-year progress report and a final report before its scheduled termination in 2027 unless extended. Public sector employers, particularly federal agencies like the EEOC, DOL, and HHS, may need to revise policies related to religious accommodations, workplace protections, and enforcement priorities. Private employers and group health plans could see shifts in EEOC religious discrimination enforcement and healthcare policies, potentially impacting religious exemptions and accommodations in employment practices and benefits coverage. Employers should monitor policy changes that may affect workplace religious protections, hiring practices, and benefit structures.
Status:
Executive Order 14160 remains in effect as of this date, and there have been no reported legal challenges specifically targeting it.
Title:
A Plan For Establishing A United States Sovereign Wealth Fund
Overview:
Directs the Treasury and Commerce Departments to develop a plan for establishing a sovereign wealth fund to promote long-term fiscal sustainability and economic security for the United States. Within 90 days of February 3, 2025, they must submit recommendations on funding mechanisms, investment strategies, and governance. While the order does not impose immediate changes on private or public employers, it could lead to future tax policy shifts, investment regulations, or economic policies that may impact businesses, retirement funds, and corporate financial planning. Employers should monitor developments for potential impacts on tax burdens, economic growth, and public sector investment strategies that could affect their financial planning and benefits programs.
Status:
As of the current date, Executive Order 14196 remains in effect, with the mandated plan under development and expected to be presented to the President by early May 2025.
Title:
Limiting Lame-Duck Collective Bargaining Agreements That Improperly Attempt to Constrain the New President
Overview:
Limits last-minute collective bargaining agreements (CBAs) finalized within 30 days before a new administration takes office, preventing outgoing administrations from binding a new President to labor agreements that alter federal workforce policies. It prohibits CBAs from creating new obligations, making substantive changes, or extending agreements during this period, with exceptions for law enforcement officers. Public sector employers, particularly federal agencies, may need to disapprove or renegotiate non-compliant CBAs, impacting policies like remote work, pay structures, and employment terms. While private sector employers and group health plans are unaffected, the order signals a shift in federal labor policy that could influence future regulatory approaches to collective bargaining and workforce management.
Status:
Legal challenges have emerged in response to this memorandum. Notably, federal employee unions have filed lawsuits alleging that the directive violates established labor laws and undermines collective bargaining rights. These legal proceedings are in the preliminary stages, and no court decisions have been issued yet. As of the current date, the memorandum remains in effect, pending the outcomes of ongoing legal challenges.
Title:
Additional Measures to Combat Anti-Semitism
Overview:
Reaffirms and expands Executive Order 13899 to combat anti-Semitism in educational institutions and hold perpetrators of harassment and violence accountable. Within 60 days of February 12, 2025, federal agencies must submit reports identifying legal tools and enforcement actions to address civil rights violations related to post-October 7, 2023, campus anti-Semitism. Public sector employers, particularly educational institutions, may face increased scrutiny, Title VI investigations, and potential loss of federal funding for non-compliance. Private sector employers, especially those in higher education or receiving federal funding, should prepare for enhanced civil rights enforcement and workplace policy reviews to ensure compliance with anti-discrimination laws. Employers should review their harassment policies, reporting procedures, and campus security measures to mitigate legal and reputational risks.
Status:
As of now, Executive Order 14161 remains in effect with no reported legal challenges specifically targeting it.
Title:
Ending Radical Indoctrination in K-12 Schooling
Overview:
Directs federal agencies to eliminate funding for K-12 schools that promote gender ideology and discriminatory equity ideology, while reinforcing parental rights and anti-discrimination laws like Title VI, Title IX, FERPA, and PPRA. Within 90 days of February 12, 2025, agencies must submit an Ending Indoctrination Strategy identifying funding sources, enforcement actions, and compliance measures. It also reestablishes the 1776 Commission to promote patriotic education and oversee educational programs leading up to the 250th anniversary of American independence in 2026. Public schools receiving federal funding may face increased oversight and potential funding restrictions, while private employers in education and training sectors should monitor shifts in federal grant priorities. Employers should review DEI programs, educational training policies, and compliance with evolving federal education standards to ensure alignment with these changes.
Status:
As of now, there have been no reported legal challenges against Executive Order 14190, which remains in effect.
Title:
Protecting Children From Chemical and Surgical Mutilation
Overview:
Issued on January 28, 2025, prohibits federal funding and support for gender-affirming medical procedures for minors, including hormone treatments and surgeries. It directs federal agencies such as HHS, the Department of Defense, and the Office of Personnel Management (OPM) to eliminate coverage for these procedures in Medicare, Medicaid, TRICARE, and federal employee health benefits (FEHB) plans. Additionally, federal research and education grants to medical institutions that support such treatments will be rescinded. Public and private employers offering group health plans may need to reassess coverage policies in light of federal regulatory changes, particularly if they participate in government programs or receive federal funds. Insurance carriers providing federal employee health benefits (FEHB and PSHB) must exclude pediatric transgender-related treatments by the 2026 Plan Year.
Status:
There have been no reported legal challenges specifically targeting Executive Order 14169, and as of the current date, it remains in effect.
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