The first couple weeks of April had almost non-existent rulemaking activity. This past week, however, broke that streak. While there was not much else beyond it of any real consequence in the pages of the Federal Register, a Department of Health and Human Services (HHS) rule did bring some appreciable cost and paperwork impacts. Across all rulemakings, agencies published $793.4 million in total costs and added 575,856 paperwork burden hours.

REGULATORY TOPLINES

• Proposed Rules: 29
• Final Rules: 36
• 2025 Total Pages: 16,598
• 2025 Final Rule Costs: -$75.8 billion
• 2025 Proposed Rule Costs: $181.3 billion

NOTABLE REGULATORY ACTIONS

The most significant rulemaking of the week was the HHS rule regarding “Medicare and Medicaid Programs; Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly.” The rule makes a series of changes to the various programs included in the title. HHS estimates that administrative burdens from these various updates will come out to nearly 576,000 additional hours of paperwork each year. The annualized costs associated with these requirements add up to $111.2 million, or $781 million in present value when projected across a 10-year horizon.

TRACKING TRUMP 2.0

In terms of regulatory policy pronouncements emanating from the White House, this past week certainly could not match the one that preceded it. There were, however, a few items of note. These included:

• An executive memo on “Updating Permitting Technology for the 21st Century” directing agencies to “make maximum use of technology in environmental review and permitting processes for infrastructure projects”;
• The initial announcement of a set of “critical mineral production projects” will receive prioritized permitting attention as directed by a prior executive order; and
• A pair of actions seeking to loosen regulatory requirements for commercial fishing operations across relevant agencies.

With Congress currently on a two-week break, there were no notable developments on the Congressional Review Act (CRA) front. Upon their return, members of Congress – particularly senators – will have until early May to pass CRA resolutions of disapproval for Biden-era rules under the law’s expedited consideration provision.

Be sure to follow the AAF updated CRA tracker. As of today, members of the 119th Congress have introduced CRA resolutions of disapproval addressing 43 Biden-era rules that collectively involve $137.5 billion in compliance costs. AAF will continue to update this tracker as additional resolutions are introduced and receive votes on the floors of each chamber.

TOTAL BURDENS

Since January 1, the federal government has published $105.6 billion in total net costs (with $75.8 billion in cost savings from finalized rules) and 68.8 million hours of net annual paperwork cuts (with 48.4 million hours coming from final rules).