June 5, 2025 – On May 30, 2025, the US Department of Health and Human Services (HHS) released additional information related to the fiscal year (FY) 2026 president’s budget. These documents follow the “skinny” budget the administration released on May 2, 2025. As discussed in a recent Regs & Eggs blog post, the “skinny” budget was the first stage in the budget submission process and didn’t complete the full budget puzzle – when it came to HHS, it left several pieces missing. Now that we have these additional documents, the question becomes: do we have all the pieces?
As we attempt to the answer this question, let’s lay out what we received. HHS released the FY 2026 Budget in Brief (BIB) and select agency/division congressional justifications (CJs) on May 30 (and one more CJ on June 3). The BIB is an annual document that includes brief descriptions of each HHS agency and division’s budget requests (hence the name). Most HHS agencies and offices put out CJs and include lengthy, detailed justifications of the budget requests.
Taken together, the BIB and CJs do fill in some missing puzzle pieces, although as of today (June 5, 2025), not every HHS agency has released its CJ yet.
Available CJs
Pending CJs
- Administration for a Healthy America (AHA)
- Administration for Children, Families, and Communities (ACFC)
- National Institutes of Health (NIH)
Discretionary Versus Mandatory Budget
In previous years, president’s budgets have included both discretionary budget requests (funding that relies on congressional appropriations) and mandatory budget proposals (ideas for how to reform existing programs such as Medicare and Medicaid that do not rely on annual appropriations). The skinny budget only included the FY 2026 discretionary requests, and we were waiting to see if the administration would put forward any mandatory proposals in the president’s budget.
Mandatory budget proposals are typically described in the BIB. Previous BIBs have included chapters on Medicare, Medicaid, and other CMS programs, and HHS used those chapters to describe the current state of the programs, identify issues, and discuss how specific budget proposals could help address those issues. However, the FY 2026 BIB does not include these chapters, signaling that the FY 2026 president’s budget still does not include any mandatory healthcare proposals and only includes discretionary funding requests for HHS. In fact, the BIB is shorter than in previous years; while it is usually a couple hundred pages, it is only 55 pages this year.
Funding Levels for HHS Agencies
The skinny budget provided a top-line number for HHS’s FY 2026 discretionary budget request ($95 billion), as well as funding levels and short justifications for select HHS programs. However, it did not include budget requests for some current HHS agencies, such as the FDA, or any new agencies and offices, such as the AHA, that HHS had already announced would be formed through its major restructuring effort. The BIB fills in these missing details and provides a complete breakout of the FY 2026 discretionary request:
Dollars in Thousands
*While no funding was appropriated to these agencies or offices in FY 2025, the FY 2025 figures represent the combined funding levels for all the programs that will be transferred to these new entities.
The BIB includes separate chapters highlighting each of these requests, and the CJs that have been released thus far include detailed information describing the programs, contracts, and staff that the funding requests would support. Since most requests represent reductions in funding compared to 2025, the CJs attempt to justify these cuts and describe how each agency or office will be able to meet statutory obligations with less funding by eliminating unnecessary and duplicative functions and becoming more efficient.
HHS Restructuring
While the skinny budget referenced the HHS restructuring effort in a few cases, it did not provide funding requests for each of the new agencies and offices that the administration plans to eliminate. However, the BIB and the CJs do frame the budget request around HHS’s proposed new structure. These documents include funding levels for all HHS agencies and name the specific programs and functions that will be shifted to new parts of HHS. Here are some highlights of the major programmatic shifts that can be gleaned from the new budget documents:
While we can piece together the proposed new HHS structure from the budget documents, seeing a new HHS organization chart and learning who will fill key roles within each of the new agencies and offices could provide an even clearer picture of what HHS will look like once the restructuring is complete.
Going forward, Congress will use the additional documents (including the remaining CJs once they are released) to help assess HHS’s funding request as part of Congress’ FY 2026 appropriations process. Congress will need to decide what parts of the request to accept or reject, including whether to incorporate funding levels for the new HHS agencies and offices in the final appropriations bill. The president’s budget assumes that the HHS restructuring will go forward as planned, since the budget is supposed to reflect the administration’s vision for how programs should be structured and funded. However, future congressional action (including the FY 2026 appropriations bill) and other legal, logistical, or operational challenges may affect what steps HHS can take in the near term to turn the administration’s vision into a reality.
Until next week, this is Jeffrey saying, enjoy reading regs with your eggs.
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