Few of the Project 2025 policies, as of December 2024, are detailed enough to properly analyze. Several are likely to show up as Executive Orders in January and others will be in the proposed 2025-26 federal budget. General themes underlying the Project 2025 proposals do the opposite of our Preamble’s directive to Promote the General Welfare:
Most Project 2025 policies lie along a spectrum of bad to terrible. They are foolish, insensate, short-sighted, and wrong-headed. It is the prerogative of the incoming administration to embrace these characteristics and, to be fair, he did tell us he would.
However: it is deeply wrong to design policies in order to create suffering. And it is profoundly wrong to profit from that suffering. And it is those policies that the analysis below will focus on.
Project 2025 approaches health care from two perspectives: limiting personal autonomy and increasing insurance company profits. Every proposal either cuts services or limits eligibility – or has nothing to do with health care but simply punishes people for being poor.
Proposal: Restrict eligibility for Medicaid. Institute work requirements, set time limits on duration of eligibility, and enact a lifetime cap on the value of benefits. Additionally, convert the funds to a block grant to states.
Cruelty Index: High. This proposal ends health insurance for millions of working Americans, vulnerable Americans, and children. If the purpose was reduction in federal spending, it could be achieved by block-granting the program. But the purpose is to create suffering.
Proposal: Reducing Home- and Community-Based services to disabled MA recipients.
Cruelty Index: High. Lower-cost HCB services reduce higher-cost institutionalizations for disabled recipients. HCB allows disabled people a far greater degree of freedom and dignity than life in a nursing home; it is unclear what pretext of a public good there could even be for reducing these services.
Proposal: Allow drug manufacturers to name their own price in government insurance programs by repealing government authority to negotiate drug prices; remove the monthly and annual out-of-pocket caps on prescription drugs for insurance beneficiaries.
Cruelty Index: High. This is nothing but cruel, with no benefit to the taxpayer: raising prices on seniors solely to either punish the Biden Administration or increase profits for drug manufacturers.
Proposal: End requirements that insurers provide gender-affirming care, emergency contraception; reduce regulatory standards on insurers. Cut funding to states which keep their own such requirements.
Cruelty Index: High. (1) There is no benefit that outweighs the deaths associated with allowing insurance companies to stop covering care. (2) Cutting funding to states may ostensibly be considered a cost-saving measure, but budget savings is not the purpose of this policy – evidence by cutting funding to states whose priorities are different. The loss of life and health by removing medical coverage from potentially millions of Americans cannot be justified.
Proposal: Require states to develop surveillance systems on pregnancies: collect data, by race and state of residence, on abortions, births, and miscarriages.
Cruelty Index: This fosters cruelty. The government invasion of patient privacy has a chilling effect on providers and patients; there is no reasonable purpose for this data other than harassment. And it is expensive: it necessitates increasing bureaucratic monitoring for the health care system and for all levels of government.
Proposal: Rescind the requirement that hospitals provide emergency medical abortions; add an obligation that hospitals save unborn children regardless of the emergency medical problems of the mother.
Cruelty Index: Viciously cruel to women and families. Zero public benefit of any kind. This is simply cruel. Abortion is health care, particularly in emergency situations. This policy removes protections for health care providers by putting them at risk of serious criminal charges by providing life-saving care.
Proposal: End all federal funding for all purposes from medical providers who also provide abortion.
Cruelty Index: This goes far beyond the policy choice not to use taxpayer funds for unapproved purposes. This is an attempt to destroy Planned Parenthood, leaving potentially millions of Americans without health care.
Proposal: Reverse FDA approval of mifepristone & criminalize dissemination of abortion information.
Cruelty Index: High. Pulling a medication for religious reasons is cruel. Suppressing knowledge that can save lives is cruel.
Proposal: Weaken the ACA: separate the subsidized exchange from the nonsubsidized market, remove consumer protections, and allow discrimination against pre-existing conditions.
Cruelty Index: These proposals reduce the ability of the ACA to save lives, in exchange solely for increased insurance profits. There is no public good.
Proposal: Limit veterans’ eligibility for disability assistance by reducing the number and breadth of eligible conditions.
Cruelty Index: Absent detail, this appears to be cruel for cruelty’s sake. “Too many” eligible disabilities is an idiotic reason to reduce health care for men and women who fought for our country. Limiting health care services is a common theme in the panoply of cruel proposals. The human cost of denying care to veterans is immeasurable, particularly if the denials apply retroactively which appears to be the intent.
Proposal: Allow sex-based discrimination in all aspects of education – admissions, enrollment, financial aid, athletics by rolling back the Title IX prohibition against discrimination based on sexual preference or sexual identity. Drop all pending investigations and review all closed investigations relating to sexual preference or sexual identity.
Cruelty Index: Very cruel. This signals approval from the government to harass students based on their nonconforming with gender roles approved by the White House. The government will not stand in the way discrimination against gay, lesbian, bi, or trans kids.
Proposal: Eliminate the Equity-in-IDEA regulations (Part B of the Individuals with Disabilities Education Act). Further, require the Office of Special Education and Rehabilitative Services to “prepare a digest” of the research showing the “false problem diagnosis” of overrepresentation in removing children from the classroom and to then distribute that digest to state education leaders.
Cruelty Index: Potentially high. The administration here is affirmatively declaring that the government is no longer interested in identifying and fixing schools which disproportionately segregate students of color from the classroom, whether for discipline or for special education services. And requiring public employees to cherry-pick quasi-research to write a “digest” with a pre-determined false narrative is the opposite of governing with professionalism and integrity.
Proposal: Move the Office of Special Education and Rehabilitative Services to DHHS.
Cruelty Index: Potentially high, if moving this office out of Department of Education also results in rolling back the commitment to providing a Free, Adequate Public Education in the most integrated setting to all students, including those with special needs. It is certainly true that splintering various federal education programs out of a unified, coordinated approach will result in an loss of efficiency.
Proposal: Move IDEA oversight to DHHS and convert the funding to a no-strings-attached block grant, flowing (as the “child’s portion”) to parents through Education Savings Accounts.
Cruelty Index: The authors calculate that each family would receive $1800 to be used for textbooks, tutors, therapies – but there would no longer be IDEA money going to the child’s school to finance school-based learning. The ESAs in Arizona and Florida are highlighted as exemplary: these states’ programs began as a way to supplement the education of home-schooled children – not to provide the education for students with special needs.
Proposal: Revoke civil rights protections to LGBTQI students. Drop all investigations re “sex”; take extraordinary steps to inform all schools they no longer have to comply with Biden’s policy changes and to issue a report on OCR actions that the Secretary of Education will use to “publicize the nature of the overreach engaged in by his predecessor.”
Cruelty Index: Any stance that abandons victims of discrimination is cruel. This permits harassment of children by adults in the schools. The only ostensible benefit -- cost savings from not investigating reports of discrimination – is consumed with the equivalent of rage-texting about an ex at 3 in the morning.
Proposal: Blanket priority: undo all regs of Biden Administration and do not enforce anything the Biden Administration directed. Issue new EOs declaring all agency guidance as unenforceable; only regs/statute can be used. Take affirmative steps to ensure regulated entities know they no longer have to comply.
Cruelty Index: Potentially high but absent actual analysis, it is impossible to tell. It’s such a puerile approach, it doesn’t even count as governance. Mozart responded to Emperor Joseph II’s criticism “There are simply too many notes” in the 1984 movie Amadeus with “Which few did you have in mind, Majesty?” One usually advises determining a thing’s value or purpose before deciding the thing’s fate.
Proposal: Eliminate Title I of the ESEA (Elementary and Secondary Education Act), which is the largest program of federal aid to schools, and which goes to the lowest-performing schools across the nation.
Cruelty Index: High. High-need, low-income schools rely heavily on Title I funding to meet the needs of their students. Title I supports 180,000 teachers for nearly 3 million students. Redesigning the three-legged (federal, state, local) stool of school finance structure is a valid policy discussion; cutting off the federal leg with nothing to help the schools other than a multi-year phaseout schedule is cruel, particularly when that third leg is supporting the system’s most vulnerable students.
Proposal: Prosecuting teachers & librarians re content and banned books.
Cruelty Index: High. Squashing knowledge and information is bad policy; criminalizing the dissemination of knowledge and information -- particularly from the very people children look to for knowledge and information -- is cruelty. Throughout Project 2025, the proposals either fiercely protect the freedom of speech regarding the Administration’s worldview or they ferociously reject the freedom of speech of any opposing view.
Proposal: Erode schools under Congressional jurisdiction by lowering standards, imposing restrictions on teacher speech (must have parental permission to use name/pronouns), eliminate need from needs-based financing.
Cruelty Index: This straddles the line between being a stupid policy and being a cruel policy. These proposals reduce the quality of services provided to children in D.C., DOD schools, and BIA schools and in some cases decrease opportunities available to low-income children, for no benefit to the public.
Proposal: Rescind all Title VI regs for school discipline and restorative justice, end all enforcement based solely on disparate impact claims; enforce civil rights laws only in the courts and not administratively; undertake “sweeping action to assure that the purpose of the CRA is not inverted through a disparate impact standard to provide a pretext for theoretically endless federal meddling.”
Cruelty Index: High. This comes not just from declining to address forms of discrimination but precluding the opportunity to even just learn of discrimination. There is no benefit to the public – and instead there will be cases of harm – by withdrawing a goal of restorative justice. This rejects a collaborative process with a long track record of success leading to community-wide improvements. Ending administrative actions to address and remediate civil rights violations has a chilling effect and will leave countless cases of discrimination unresolved.
Proposal: Allow employers’ religious beliefs to control treatment of employees re marriage, race, health care
Cruelty Index: Ending protections against discrimination is cruel on its face. There is zero benefit to the American public for allowing mistreatment based on human differences.
Proposal: Eliminate “disparate impact” as evidence of discrimination.
Cruelty Index: This effectively curtails all enforcement of anti-discrimination laws giving license to employers to discriminate in any way other than stating directly.
Proposal: Rescind EO 11246 from 1965, prohibiting federal contractors from discriminating on the basis of race, color, religion, sex, sexual orientation, gender identity, or national origin. Eliminate OFCCP (Office of Federal Contract Compliance Programs).
Cruelty Index: Undoing protections against discrimination that have stood for 60 years is cruel on such a large scale.
Proposal: Restrict the Supreme Court precedent in Bostock to mean that employer discrimination on the basis of sexual orientation, gender identity and transgender is prohibiting only for hiring and for firing. All other forms of employer discrimination – pay & benefits, disciplinary actions, dress code, harassment, promotions -- are allowed.
Cruelty Index: Cruelty measure through the roof.
Proposal: Rescind all federal regulations prohibiting discrimination on the basis of sexual orientation, gender identity, transgender status, and sex characteristics; direct federal agencies to focus all sex discrimination investigations only “on the biological binary meaning of sex.”
Cruelty Index: No explanation necessary.
Proposal: Allow state and local governments to opt out of several labor laws – OSHA, FLSA -- without substituting state law. Allow collective bargaining agreements to opt out of the same.
Cruelty Index: This proposal has no benefit. It is solely designed to hurt state and local public servants. Without knowing the proposal details, we can only speculate. Items at risk include protections put in place beginning in 1934 (take steps to prevent worker death and injury) and 1938 (minimum wage, child labor, overtime provisions).
Proposal: Reneg on the long-standing doctrine of federal pre-emption regarding ERISA; state that ERISA does not pre-empt states’ power to restrict abortion, surrogacy or other “anti-life” benefits.
Cruelty Index: This appears to be part of Plan B for the goal of enacting federal laws to ban abortion and other reproductive health measures: encourage it to take place state-by-state.
Proposal: Issue an Executive Order ensuring that “religious employers are free to run their businesses according to their religious beliefs.”
Cruelty Index: Unclear whether this applies to employers who are religious organizations already exempted from Title VII or whether this applies to all private-sector employers.
Proposal: Forbid ERISA plans and the federal Thrift Savings Plan from considering ESG (environmental, social, and governance factors) in fund management; prosecute managers who have used ESG to make management decisions.
Cruelty Index: Forbidding ESG from ERISA plans creates harm for no reason: there is no evidence of any problem or harm anyone has ever suffered as a result. The further provision, that managers who have used ESD in the past should be prosecuted is vindictive (evidenced by the specific calling-out of Black Rock and State Street Global Advisers).
Proposal: Enact a law allowing employers to discriminate based on citizenship.
Cruelty Index: This is cruel because it reinforces the noxious idea that some people are better and more worthy than others based solely on where they were born.
Proposal: Do not allow anyone to enlist who is “predisposed to require medical treatment”; set physical fitness standards by occupational field without regard to gender, race, ethnicity, or orientation.
Cruelty Index: Discrimination for no reason = cruelty.
Proposal: End services related to abortion and gender reassignment surgery.
Cruelty Index: On its face, this appears to simply be an extension of the misogyny and hatred underlying Project 2025 in toto. But the narrative hints at a new potential cruelty: these services are to be abolished because they are not “service-connected conditions.” If this restriction is applied throughout the VA health care system, it would be catastrophic for veterans who rely on the VA for coordination of their care.
Proposal: Eliminate a number of qualifying disabilities, in order to achieve “significant cost savings.”
Cruelty Index: Limiting health care services is a common theme in the panoply of cruel proposals. The human cost of denying care to veterans is immeasurable, particularly if the denials apply retroactively which appears to be the intent.
Proposal: Expel any military personnel who has gender dysphoria.
Cruelty Index: This has no budgetary or policy value – its only purpose is to inflict harm and reinforce the acceptability of discriminatory treatment.
Proposal: Broaden use of “community care” through, among other means, codifying the regulations within the VA Mission Act and shifting focus from VA medical campuses to community care outpatient clinics.
Cruelty Index: In this context, community care means outsourcing. Given the track record of the community care facilities currently involved with the VA health care system, and given the superficial regulatory controls over community care facilities, this proposal will lead directly to increased pain and suffering among our veterans.
Proposal: Automate claims applications.
Cruelty Index: This is another way to limit delivery of health care services, using a criminal art form perfected by for-profit health insurers. Automating claims is a means to drive government funds to private contractors, who set up the program to automatically deny claims (United HealthCare’s automated system allegedly has a 90% error rate – only one of 10 claim denials withstands scrutiny upon appeal). The writers of these proposals note that claim adjudication is lengthy, but “Hiring additional staff to process claims is costly, is inflexible, and has yielded mixed results. Attempting to change laws and regulations simply to adjudicate claims would be a herculean effort given their complexity.” One might argue – and many do – that government would actually be obligated to change laws and regulations that don’t work, even if those laws and regulations are “complex.” This is particularly true when the problem is inefficient service delivery to vulnerable populations. Further, this proposal appears to be a backdoor way to support campaign contributors from the shady cottage industry known as “claim sharks,” entities that charge veterans high fees to “help” shepherd their claims, despite the existence of groups who do the same work for free.
Project 2025 does not mention mass deportation but it prepares for it. The proposals gear up for whole-of-government cruelty against humans not born in the U.S. In total, these policies will:
These proposals do not improve the economy, nor do they restore allegedly stolen jobs to U.S. citizens. Their only economic benefit is to the private sector prison industry, already touting great growth projections to their stockholders due to expected new contracts with the federal government. Specific cruelty-boosting proposals are listed below.
Prepare for massive roundups and the construction of concentration camps:
Make legal status much harder to achieve
Remove any obstacles to deportation.
Make things worse for immigrants already here.
Finally, two proposals would reserve immense power for the discretion of the Secretary:
An overarching goal in Project 2025 is to reduce government spending that benefits low- and middle-income Americans and to reduce government taxation of high-income Americans and businesses. All proposals together would result in a massive shift of wealth from the bottom ~90% to the top ~10%.
This goal conflicts with the incessant refrain of purporting to support (traditional) families and children. The first of four pillars underlying the entire book is “Restore the family as the centerpiece of American life and protect our children.” The vast majority of the nation’s families and children are in the bottom 90%.
The “protect our children” applies only to sex. There are no policies protecting children from hunger, sickness, homelessness, or ignorance and, indeed, all the policies put kids more at risk.
The “restore the [traditional] family” is only in relation to nontraditional families. Project 2025 doesn’t build up [traditional] families; it tears down nontraditional families. There are no policies helping a family improve its economic footing and, unsurprisingly, all the policies make it harder for low- and middle-income Americans to get by. Health care, food, housing, child care, taxes – all will cost more.
Proposal: Apply a strict-scrutiny level to judicial review of governmental infringement of yet-to-be-defined "parental rights"; require all federal regulations to hew to this standard.
Proposal: End nonproliferation treaties with Iran and the U.N.
Proposal: Repeal all climate-change initiatives.
Proposal: Require VA hospitals to achieve the same administrative and patient-care metrics as in DOD medical facilities, despite the vast differences in the health and condition of the two populations (the average veteran age is 58, and 30% of them have a service-related disability; the average age of active-duty servicemembers is 28, and 0% of them have a service-related disability.)
Proposal: Exempt small businesses from labor regulations and OSHA fines.
Proposal: Eliminate race and ethnicity from existing data collected on education and labor; add race and ethnicity to a new data collection on pregnancies and abortions.
Proposal: Forbid ESG (environmental, social, governance factors) to be considered in ERISA plans and in the federal Thrift Savings Plan.
Proposal: Direct the Office of Nuclear Energy to stop intervening in “nearly all aspects” of the commercial nuclear energy industry and to reduce its regulatory burdens.
Proposal: End all scientific research as well as drug manufacturing based on aborted fetal tissue. Focus NIH research on the “harms” to girls and women of abortion and of “junk gender science.”
Proposal: Require the Bureau of Labor Statistics to add issue monthly or at least annually reports on the state of the American family and its economic welfare, to include items such as “marriage and fertility rates, the share of children living with both biological parents” and others.
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