Recent Changes — Public Health

Three separate EOs each addressed a distinct piece of the federal EJ framework. EO 14148 (January 20, 2025; "Initial Recissions of Harmful Executive Orders and Actions") revoked Biden's EO 14008 § 219 Justice40 Initiative and EO 14096 (2023 EJ Revitalization). EO 14151 (January 20, 2025; "Ending Radical and Wasteful Government DEI Programs and Preferencing") directs all federal agencies to "terminate, to the maximum extent allowed by law, all DEI, DEIA, and 'environmental justice' offices and positions." EO 14173 (January 21, 2025; "Ending Illegal Discrimination and Restoring Merit-Based Opportunity") revoked Clinton's EO 12898 (February 11, 1994). Some prior framing treats this as a single revocation event; the verification cycle identifies three distinct EOs.

Affects: Environmental Health.

EPA Administrator Lee Zeldin announced closure of the EPA Office of Environmental Justice and External Civil Rights, including EJ units in all 10 EPA regions including Region III (which covers PA, DE, MD, DC, VA, WV); a small headquarters staff was retained for external civil rights reviews only. EJScreen was taken offline on epa.gov around the same date. EPA OECA issued a memorandum prohibiting EPA enforcement officials from using historical EJScreen data "in any enforcement or compliance activity." The DOJ Environmental Justice unit within ENRD was abolished. Reconstructions exist via Harvard University (using scraped data) and Public Environmental Data Partners (unofficial reconstruction). EPA grant clawbacks targeting EJ-related infrastructure funds are underway. Sixteen-plus states have state-level EJ mapping tools (Maryland, Massachusetts, Minnesota named); a PA-specific state EJ mapping tool was not specifically located in the verification cycle.

Affects: Environmental Health.

On April 1, 2025, HHS sent RIF notices to approximately 10,000 employees, including approximately 3,500 FDA employees (approximately 18% of FDA's workforce per HHS estimate; refined from a "approximately 19%" earlier figure). CDRH lost approximately 250 staff (approximately 11% of 2,260 starting headcount); about 30 were later called back. Total HHS reduction reaches approximately 25% when approximately 10,000 voluntary separations are added. The April 1 RIFs were initially halted by Judge Susan Illston's preliminary injunction (N.D. Cal., May 2025); SCOTUS stayed the Illston injunction on July 8, 2025; HHS finalized terminations on July 14, 2025. The Rhode Island injunction (*State of Rhode Island v. Trump*, D.R.I., Judge Melissa DuBose; on appeal as No. 26-1070 to the First Circuit) was narrowed August 12, 2025 to cover FDA's Center for Tobacco Products, most CDC offices, HHS Office of Head Start, and HHS Office of the Assistant Secretary for Planning and Evaluation — but specifically excluded CDC's Immunization Services Division and Partnership and Vaccine Equity Branch, which were terminated. CBER Director Peter Marks resigned March 27, 2025; successor Vinay Prasad subsequently resigned amid political pressure (per PharmExec, February 2026).

Affects: Public Health Infrastructure & Governance · Communicable Disease Control · Chronic Disease (CTP protection).

*Kennedy v. Braidwood Management, Inc.*, 606 U.S. 748 (2025), decided June 27, 2025, 6-3 (Kavanaugh majority joined by Roberts, Sotomayor, Kagan, Barrett, Jackson; Thomas dissent joined by Alito, Gorsuch). SCOTUS reversed the Fifth Circuit and upheld the ACA § 2713 preventive services mandate. USPSTF members are *inferior officers* properly appointed under the Appointments Clause because the Secretary of HHS may remove them at will and review or block recommendations before they take effect. Cancer screenings, PrEP, tobacco cessation, and other USPSTF A/B services remain mandate-protected nationwide. Braidwood did not directly address ACIP (vaccines) or HRSA Women's Preventive Services. The RFRA / PrEP religious-objection claim was remanded for proceedings limited to the Braidwood plaintiffs' employer-plan exemption.

Affects: Communicable Disease Control · Maternal & Child Health · Chronic Disease · Health Access, FQHCs & SDOH.

HHS announced a "coordinated wind-down" of mRNA vaccine development under BARDA, terminating 22 BARDA contracts worth approximately $500 million and de-scoping mRNA-related work in additional contracts. Contracts with Emory University and Tiba Biotech terminated; contracts with Luminary Labs, ModeX, and Seqirus de-scoped; pre-award solicitations from Pfizer, Sanofi Pasteur, CSL Sequirus, and Gritstone rejected/canceled; DoD JPEO collaborations restructured. Predecessor action: HHS terminated a $590 million Moderna H5N1 grant in May 2025. The mRNA wind-down affects future-vaccine pipeline rather than current immunization availability.

Affects: Communicable Disease Control.

IRA Round 1 prices took effect January 1, 2026 for 10 drugs: Eliquis (apixaban; blood thinner), Jardiance (empagliflozin; diabetes/heart), Xarelto (rivaroxaban; blood thinner), Januvia (sitagliptin; diabetes), Farxiga (dapagliflozin; diabetes/heart/kidney), Entresto (sacubitril/valsartan; heart failure), Enbrel (etanercept; autoimmune), Imbruvica (ibrutinib; cancer), Stelara (ustekinumab; autoimmune), and NovoLog/Fiasp (insulin aspart; diabetes). MFPs were announced August 15, 2024; negotiated discounts range 38% to 79% off list (Entresto 53%; Enbrel 60% or more). CMS projects approximately $6 billion Medicare net Year-1 savings (approximately 22% reduction) plus approximately $1.5 billion beneficiary OOP savings under the defined-standard benefit design. ASPE utilization data shows 13% of non-LIS Medicare enrollees used at least one Round 1 drug in 2022 (vs. 18% of LIS enrollees). Round 2 (15 drugs; MFPs announced approximately late November 2025 with CMS Administrator Mehmet Oz framing the savings as 44% / $12 billion net) takes effect January 1, 2027. Round 3 (15 Part B plus Part D drugs) selections in early 2026 were affected by the OBBBA orphan-drug exclusion expansion (likely delaying Keytruda and Opdivo selections per KFF March 2026). Trump EO 14273 (April 15, 2025) directs program modifications without dismantling.

Affects: Chronic & Non-Communicable Disease · Health Access (340B + IRA Round 1 interaction).

Community Health Center Fund (CHCF) mandatory funding was extended through December 2026 via the 2026 Consolidated Appropriations Act. Companion FY26 funding levels: NHSC $350 million base; THCGME $225 million; Medicare telehealth flexibilities for FQHCs extended through 2027. No multi-year reauthorization was enacted despite advocate push from NACHC and Advocates for Community Health. OBBBA July 4, 2025 Medicaid cuts threaten FQHC financial stability over a multi-year horizon since Medicaid is 40%+ of FQHC revenue; CHC operating margins average below -2% with under 90 days cash on hand. The HRSA 340B rebate pilot model launched January 1, 2026 (concurrent with IRA Round 1); 65 of 78 active NDCs (85%) for 2026 IRA Round 1 drugs have lower 340B ceiling prices than MFP, creating accounting complexity. Scale data: 1,512 CHCs nationally; 17,000+ delivery sites; serving 34M to 52M Americans annually (1 in 7 nationally; 1 in 3 rural; 1 in 4 Medicaid; 1 in 5 uninsured).

Affects: Health Access, FQHCs & SDOH.

Two distinct events compose the ACIP-related disruption. The **January 5, 2026 CDC Decision Memo** signed by then-Acting CDC Director Jim O'Neill demoted seven vaccines (rotavirus, meningococcal, hepatitis A, hepatitis B, influenza, COVID-19, RSV) from universal recommendation to "shared clinical decision making" status. The Decision Memo cited a January 2026 Høeg/Kuldorff Assessment compared to "peer countries," particularly Denmark; the assessment was characterized in an *AAP v. Kennedy* amicus brief as employing "no generally accepted scientific methodology" with "misleading comparisons." The **April 9, 2026 ACIP charter renewal** broadened committee scope to include "vaccine safety research gaps," "cumulative effects" of childhood vaccines, aluminum adjuvants, "novel vaccine platforms such as mRNA," and reviewing "vaccine schedules used by other countries"; the renewal added non-voting liaison members from vaccine-skeptic organizations (Independent Medical Alliance; Physicians for Informed Consent; Association of American Physicians and Surgeons). 130+ medical, public-health, and patient-advocacy organizations issued a statement of concern dated April 9. Some prior framing treated the schedule reduction and charter rewrite as a single event; the verification cycle establishes them as separate.

Affects: Public Health Infrastructure & Governance · Communicable Disease Control.

Judge Brian E. Murphy of the U.S. District Court for the District of Massachusetts (1st Circuit) — not the Sixth Circuit as some earlier reporting suggested — granted a wide-ranging preliminary injunction in *American Academy of Pediatrics et al. v. Kennedy et al.* Plaintiffs include AAP, ACOG, AAFP, IDSA, ACP, SMFM, the Massachusetts Public Health Alliance, and an individual pregnant physician; the suit was filed July 2025 originally challenging the May 2025 COVID-19 directive and amended four times. Judge Murphy found that the reconstituted ACIP failed Federal Advisory Committee Act expertise requirements (only 6 of 15 members had meaningful vaccine expertise); the January 2026 Decision Memo was "arbitrary and capricious" because it "abandoned the agency's longstanding practice of getting recommendations from ACIP before changing the immunization schedules without sufficient explanation"; the schedule reduction was both a "technical, procedural failure" and "an abandonment of the technical knowledge and expertise embodied by that committee." The injunction stays the Decision Memo, blocks the reconstituted ACIP membership, invalidates three reconstituted-ACIP votes including the December 2025 hep B birth-dose downgrade, and overturns the May 2025 Secretarial Directive halting COVID-19 vaccine recommendations for pregnant women and healthy children. The pre-January 2026 federal childhood schedule is effectively restored. HHS appealed to the First Circuit.

Affects: Public Health Infrastructure & Governance · Communicable Disease Control · Maternal & Child Health.

DEA Final Order rescheduling state-licensed medical cannabis to Schedule III signed April 22-23, 2026 by Acting AG Todd Blanche; Federal Register publication and formal effective date approximately April 28, 2026. On April 23, 2026, Treasury and IRS issued a press release announcing forthcoming guidance with three components: (1) **prospective relief confirmed** — transition rule treats § 280E rescheduling as applying to the full taxable year that includes the Final Order's effective date, so for calendar-year filers the entire 2026 taxable year is § 280E-exempt for state-licensed medical cannabis activities; (2) **apportionment rules for mixed-business operators** — guidance will clarify allocation of shared costs between Schedule III medical activities (deductible) and Schedule I adult-use activities (still § 280E); allocation methodology unresolved (revenue-based vs. gross-profit-based vs. asset-based); (3) **retrospective relief NOT YET COMMITTED** — Treasury silent on retroactive refund possibility despite explicit DEA encouragement in the Final Order. Industry has over $1.6 billion in disputed § 280E positions (Trulieve alone approximately $445 million). PA medical cannabis operators (PA Medical Marijuana Act, Act 16 of 2016, 35 P.S. § 10231.101) qualify as state licensees per 21 CFR § 1300.01 and have become § 280E-exempt prospectively for 2026; PA does not have an adult-use program, so PA operators avoid the apportionment-rule complication. Broader rescheduling hearing for adult-use cannabis begins June 29, 2026 (concludes by July 15).

Affects: Substance Use & Harm Reduction.

Philadelphia overdose deaths trajectory: 2022 peak 1,376 → 2023 1,310 → 2024 1,045 (a 20% decline; PDPH) → 2025 preliminary 747 through December 23 — on track to be the lowest in nearly a decade (last sub-1,000 year was 2016 with 907 deaths). PA statewide declined from 3,340 in 2024 to 2,178 preliminary in 2025 — a 29% decline year-over-year. PA Overdose Prevention Program 2025: approximately 800,000 doses of naloxone distributed full-year (415,000 in January-June per PA Department of Drug and Alcohol Programs); 737,000 fentanyl and xylazine test strips distributed; nearly 9,500 overdose reversals (January-September). Since 2017, over 1.3 million naloxone doses have been distributed in Pennsylvania. **Demographic disparity persists.** 2023 PDPH data: 15% decrease among non-Hispanic White; only 5% decrease among non-Hispanic Black; 2% increase among Hispanic people. Pew Charitable Trusts 2025 polling indicates declines driven primarily by White rates dropping while Black rates continued rising through 2024. Kensington supply chemistry (Hochstatter et al., *Drug and Alcohol Dependence*, accepted June 2025, PMID 40578053): "demon" (fentanyl-medetomidine ± xylazine) has displaced "tranq" (xylazine-fentanyl); medetomidine reached 83% by March 2025; BTMPS reached 25%. **Temple Health recharacterization (separate institutional finding).** The second-pass "closure-scenario indicators" framing is recharacterized to "operational financial pressure under federal Medicaid uncertainty." Temple FY25 (year ending June 30, 2025) operating profit $22 million on $3.3 billion in revenue (+15%); Q1 FY26 operating loss $15 million improved from $17 million prior year; investment-grade BBB rating maintained; FY26 capital trim of $10-15 million to $60-65 million total due to federal Medicaid uncertainty; strategic investments continuing (8 oncologists at Fox Chase Cancer Center; new Women & Families Hospital in Juniata operating rooms opened May 2025). Einstein operationally part of Jefferson Health since the 2021 merger; standalone Einstein framing is anachronistic.

Affects: Substance Use & Harm Reduction · Health Access, FQHCs & SDOH.