Addressing Risks from Susman Godfrey (Trump EO Tracker)

The Executive Order (“EO”) directs the alignment of the U.S. core childhood vaccine schedule with the best practices of peer, developed countries, while preserving access to vaccines and protecting religious freedoms and enforcing legal protections for parents. Based on a scientific assessment completed by HHS pursuant to a Presidential Memorandum dated December 5, 2025, the order notes that the U.S. currently recommends more childhood vaccines than any peer nation and identified a set of consensus vaccines consistently recommended across all peer countries. The order directs the Centers for Disease Control and Prevention (“CDC”) and its Advisory Committee on Immunization Practices (ACIP) to review the scientific assessment and take appropriate steps to update the childhood and adolescent vaccine schedule, while providing maximum flexibility to parents and doctors regarding the timing and sequencing of routine immunizations. Additionally, all immunizations on the ACIP-recommended schedule and adopted by the CDC must continue to be covered without cost sharing by private insurance, Medicaid, the Children’s Health Insurance Program, and the Vaccines for Children Program. The order also reaffirms the Administration’s commitment to fulfilling all legal obligations with respect to parental authority, religious freedom, disability accommodations, and equal protection under the law.

Expands upon Executive Order 14380 that established a national emergency regarding Cuba due its threat to U.S. national security by directing the Department of State and Treasury to block U.S. trade with foreign persons designated for operating in specified sectors of the Cuban economy, imposing immigration penalties and suspending entry for designated individuals associated with the Cuban government as determined by the Department of State, and directing the Treasury Department to sanction foreign financial institutions.

Grants Bridger Pipeline Expansion LLC a Presidential permit to construct and operate a cross-border oil pipeline in Montana, subject to federal oversight, compliance with all applicable laws, and conditions on modification, inspection, reporting, and potential government control or removal.

Establishes a policy shift in federal procurement to prioritize fixed-price, performance-based contracts over cost-reimbursement models, aiming to improve cost predictability, strengthen contractor accountability, and reduce government overspending. Requires justification and senior-level approval for non-fixed-price contracts above certain thresholds and directs agencies to review and potentially renegotiate existing high-value contracts to incorporate performance-based pricing.
 
Within 45 days, the Office of Management and Budget must issue implementation guidance. Within 90 days, agencies must review and begin modifying their largest contracts and submit initial reports. Within 120 days, proposed updates to the Federal Acquisition Regulation and training programs must be developed.