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Trump memo targets regulatory overhaul

President Trump issued a memo on April 9 directing agencies to find "potentially unlawful regulations" by early June and repeal them.

Why it matters: This directive could alter the regulatory landscape and bypass traditional rulemaking procedures that include public comments.

According to the memo, agency heads can quickly make changes using a "good cause" exception in the Administrative Procedure Act. The memo says agencies have the legal authority to immediately repeal "unlawful regulations."

  • This follows a March 3 policy statement by the Department of Health and Human Services (HHS) announcing it will increasingly use the good cause exception and bypass the public comment process.

The big picture: The White House initiative cites recent Supreme Court rulings that struck down rulemakings to justify a regulatory overhaul.

What's next: The Office of Management and Budget is seeking deregulation ideas with a response deadline of May 12, 2025. The Centers for Medicare & Medicaid Services has also issued a request for information to streamline regulations. The CAP is engaged on regulatory changes and will advocate for the pathology specialty.

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