A Preview of Federal Priorities
Earlier this month, the Trump administration released the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions (Agenda). This document functions as the government’s to-do list, offering a preview of upcoming rulemakings across federal agencies before they ever hit the Federal Register. For state leaders, it is one of the best early indicators of where federal policy is headed and when to weigh in before key decisions are locked in.
This edition of Dispatch from DC highlights items from the Agenda that could have the greatest impact on state and local governments. These are rules still in the planning stage, which means there is an opportunity to shape their direction.
On Monday, the Centers for Medicare & Medicaid Services (CMS) released the much-anticipated details on the new Rural Health Transformation Fund, a $50 billion program created under the rebranded Working Family Tax Cuts Bill (formerly the “One Big Beautiful Bill”). The fund will issue grants to states over the next five years, and we highlight key takeaways from the newly released guidance.
The Unified Agenda: A First Look at Federal Priorities
The Unified Agenda isn’t just a filing cabinet of federal intentions, it’s a chance for state leaders to position themselves early in the rulemaking process. Because many of these actions are only at the planning stage, agencies are still weighing options and open to ideas on how to improve the policy. That means state leaders who move now can shape the contours of regulations before they harden into formal proposals.
For our network, the Agenda is especially valuable for spotting:
Rules that revisit prior federal overreach, offering a window to reassert state authority.
Programs that shift costs to states and may require legislative or budget adjustments.
Opportunities to showcase state reforms as working models that Washington can adopt.
What follows is a selective set of rules under consideration and not yet open for public comment. This is not a comprehensive list, but it highlights the rules most likely to affect state and local governments and where early engagement could make an impact:
Department of Agriculture
Strengthening Integrity and Reducing Retailer Fraud in SNAP: Implements reforms to crack down on retailer fraud.
Enhancing EBT Card Security Measures: Opens the door for states to adopt new card protections to combat skimming and cloning.
Reforming Categorical Eligibility for SNAP: Narrows eligibility to households with substantial, ongoing TANF benefits.
Reducing Complexity and Food Waste in Child Nutrition Programs: Simplifies rules to cut waste and ease state/school burdens.
Department of Education
Accreditation Issues: Starts rulemaking to ease switching accreditors.
Innovative Assessment Demonstration Authority (K–12): Expands state flexibility to pilot new assessment systems.
Elimination of Disparate Impact Theory (Title VI): Limits violations to intentional discrimination only.
Title VI Enforcement Procedures: Streamlines enforcement, focusing on intentional discrimination.
Protection of Pupil Rights Amendments (K–12): Expands parental notice/opt-out rights, including on sensitive issues.
FERPA Revisions (K–12 & Higher Ed): Clarifies definitions, data-sharing rules, and parental notification standards.
Environmental Protection Agency
Interstate Transport Plan Review for 2015 Ozone NAAQS: Reconsiders disapprovals of 21 state ozone plans, reopening space for cooperative federalism.
Section 111(d) State Plan Regulations: Revisits deadlines and backstops in light of West Virginia v. EPA.
Ozone Nonattainment Area Plan Deadlines: Likely to give states more flexibility on deadlines.
Greenhouse Gas Reporting Program Reconsideration: Reviews burdensome reporting covering 8,000+ facilities.
Regional Haze Program Revision: Begins restructuring to ease state obligations.
Definition of Waters of the United States: Aligns jurisdiction with Sackett v. EPA.
UCMR 6 for Public Water Systems: Next contaminant monitoring cycle; potential cost relief for states.
Universal Waste Regulations for Solar Panels & Batteries: Streamlines recycling/disposal rules; states may face new program costs.
Treasury
Deferred Compensation Plans (State/Local Gov. & Nonprofits): Updates tax treatment of retirement/severance benefits.
Department of Transportation
Uniform Procedures for Highway Safety Grants: Possibly reduces paperwork for state grants.
CAFE Standards Amendment: Reassesses Biden-era fuel efficiency targets.
Department of Labor
Heat Illness Prevention Standard: Biden OSHA rule expected to be withdrawn.
OSHA Standards Improvement Project 2025: Broad deregulatory package removing outdated provisions.
Department of the Interior
ESA Listing & Critical Habitat: Narrows criteria for listings/habitat designations.
ESA Protections for Threatened Species” Rolls back Biden-era provisions.
Oil & Gas Leasing Rule: Expands leasing/bonding for fossil development.
Rescission of Intermittent Energy Rule: Rolls back renewable energy siting/standards.
Department of Homeland Security / FEMA
Floodplain Management & Wetlands Regulations: Repeals Biden-era higher building standards for federally funded projects.
Department of Health & Human Services
Medicaid State Directed Payments & FFS Practitioner Payments: Sets new limits/caps, key for OBBB implementation.
Department of Energy
Preemption of State Efficiency Standards for Fixtures: Restores single national standard for showerheads, faucets, toilets.
How States Leaders Can Engage Now
Scan the Unified Agenda: Review both the items above and the full Agenda for possible rules that would impact your state.
Flag Issues of Interest: Let us know which proposals matter most - we can help identify timing and strategy for engagement.
Use Best Practices: SPN’s Center for Practical Federalism can assist with early outreach, preparing public comments, and ensuring your state’s perspective is heard.
By acting early and strategically, states can ensure Washington’s decisions strengthen, not sideline, the principles of federalism. Contact Jennifer Butler at butler@spn.org for more information.
Rural Health Transformation Fund: What States Should Do Now
CMS has released the full Notice of Funding Opportunity for the Rural Health Transformation (RHT) Fund, a $50 billion grant program to be distributed over five years (FY 2026–2030). Half of the funding ($25 billion) will be split equally among states, $500 million per each state. The other half will be awarded through a points-based formula that combines rural and hospital data with a technical score tied in part to state policy actions. Applications are due November 5, 2025, with awards finalized by December 31, 2025.
Key policy levers in the scoring formula include:
SNAP waivers restricting “non-nutritious” items like sugary drinks and candy.
Reestablishing the Presidential Fitness Test.
Certificate-of-Need reform, licensure compacts, and scope-of-practice expansion.
Allowing short-term, limited-duration insurance.
Expanding remote care through telehealth access.
Immediate steps for state leaders include:
Ensure there is a governor-led application team that includes health and human services officials, rural providers, and good-government stakeholders.
Leverage partial credit for future policy changes by moving quickly on waivers, compacts, or executive actions, even if full enactment waits until 2026.
Encourage transparency and accountability by building in clear reporting, stakeholder input, and public-facing updates to strengthen your application and set reforms up for long-term credibility.