What is Project 2025? 8 healthcare notes

Project 2025 is a package of sweeping federal policy proposals from the Heritage Foundation, intended for the next Republican presidential administration.

The conservative Washington, D.C.-based think tank proposed the 922-page initiative in 2022. On its website, Project 2025 notes that it "does not speak for any candidate or campaign, in any capacity."

Former President Donald Trump publicly disavowed the package in July. The Trump campaign has said that its 16-page policy plan, Agenda47, along with the 2024 Republican Party platform, will be the focus if he wins reelection in November. Agenda 47's healthcare policy proposals are sparse and are included in the chapter aimed at addressing affordability broadly. 

"Healthcare and prescription drug costs are out of control," the proposal says. "Republicans will increase transparency, promote choice and competition, and expand access to new affordable healthcare and prescription drug options. We will protect Medicare, and ensure seniors receive the care they need without being burdened by excessive costs."

In contrast, Project 2025 offers more detailed policy proposals across specific topics and federal agencies, including major reforms at HHS, CMS, the CDC and NIH. According to CNN, 140 former Trump administration officials have contributed to Project 2025, and Mr. Trump’s vice presidential candidate, Sen. JD Vance, wrote the introduction of an upcoming book from the Heritage Foundation's president, Kevin Roberts.

Eight key healthcare proposals in Project 2025:

1. HHS reform. The department should be reformed to promote work, traditional marriage and nuclear families, not abortion as a healthcare service and LGBTQ equity efforts. Terms such as "sexual orientation, "gender identity" and "reproductive health" should be removed from all federal rules and regulations. States would be the ultimate regulators of the medical profession. HHS would also not be able to declare indefinite public health emergencies.

2. Medicare. Medicare Advantage would become the default enrollment option for older adults, and beneficiaries would be given "direct control" of spending. A "competitive bidding model" would be introduced and the current risk adjustment model would be reconfigured. Site-neutral payment policies would be promoted, with Medicare payments being the same across all healthcare settings.

Medicare would be banned from negotiating drug prices, and 340B subsidies restructured "toward beneficiaries rather than hospitals."

3. Medicaid. Federal Medicaid funding would be reduced and lifetime caps on benefits would be introduced "to disincentivize permanent dependence." States could impose work requirements to receive benefits and providers would be able to "make payment reforms" without state or federal approval where possible. Other proposals include block grants, stricter eligibility determinations, the establishment of a voucher system to purchase private insurance with Medicaid funding, and more oversight and reform of managed care organizations.

Medicaid funds would be banned from going to Planned Parenthood, and elective abortion providers would not be covered through state Medicaid programs. 

4. Abortion. Abortion would not be considered a healthcare service and no federal funding should be allocated toward facilities that provide those services, including for active military personnel. Reporting and surveillance of those seeking or obtaining abortion services would become more strict in every state. Healthcare workers, particularly those in hospitals, would be required to report abortion pill complications. Medical schools that offer abortion-related training should do so under an opt-in basis. The FDA's approval of abortion pills such as mifepristone would be revoked, and mailing abortion medications or obtaining them virtually would be banned. The ACA insurance mandate to cover the "week-after" contraceptive pill Ella would also be rescinded.

Any federally-funded research using human embryonic stem cells should not occur, and "abortion and embryo destructive related research, cell lines, and other testing methods become both fully obsolete."

"Miscarriage management or standard ectopic pregnancy treatments should never be conflated with abortion," the proposal says. 

5. Affordable Care Act/Insurance. The ACA should be reformed to better promote direct primary care policies, and CMS should promote more shared savings and reference pricing models. Health plan choices such as association plans, short-term plans, and ICHRAs should all be expanded, and the subsidized ACA exchange market should be separated from the non-subsidized insurance market. 

The independent dispute resolution process established under the No Surprises Act should be dissolved. Restrictions on physician-owned hospitals would be removed, and hospital price transparency regulations should be strengthened. 

6. Gender-affirming care. A Biden administration policy asserting that transgender minors have a right to gender-affirming care should be reconsidered. CMS would not issue any national coverage determinations regarding gender reassignment surgery for Medicare beneficiaries. Discrimination laws on the basis of sexual orientation, gender identity, and transgender status would be rescinded.

Transgender people would be banned from serving in the military, and no federal funding would be allocated for gender-affirming services for military personnel.  

7. CDC reform. The agency should be split into two entities: an epidemiological agency responsible for publishing data, and an agency responsible for public health but with a "severely confined ability to make policy recommendations."

8. Corporate consolidation. The next administration should focus on preventing "the regulatory capture of our public health agencies by pharmaceutical companies, insurers, hospital conglomerates…" The FTC should work more closely with state attorneys general on antitrust enforcement policy, including proposed hospital mergers.

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