Reflecting on President Trump’s first 100 days in office

On January 20, 2025, Donald J. Trump began his second term as President of the United States – marking his 100th day in office on April 29, 2025. In his second term, Trump has aggressively expanded the use of executive power to reshape federal policy, often bypassing Congress and setting new precedents that future administrations could capitalize on. By leveraging a compliant Republican-controlled Congress, the President has taken actions such as imposing tariffs and attempting to restructure federal agencies.

During these first three months, Trump has worked to staff his administration, prioritized improving border security, revitalizing traditional energy production, and renegotiating bilateral and multilateral trade deals with foreign nations. With Congress largely on the sidelines, Trump has signed 137 Executive Orders (“EO”) (from EO 14147 through EO 14283), many of which address related issues of national security, the trade deficit, and reshoring domestic manufacturing.

Nominations

After 100 days in office, the Trump Administration confirmed 53 nominees, including all of President Trump’s cabinet members, with the exception of the U.S. Ambassador to the United Nations (“UN”).

In contrast to Trump’s first term, the Administration is moving quickly and intentionally in staffing government positions, even as it works to cut large swathes of the federal workforce via Elon Musk’s Department of Government Efficiency (“DOGE”). For comparison, the pace of Senate confirmations of Trump appointees at the hundred day mark (53) is outpacing former President Biden’s 44 Senate confirmations, and nearly double his number of 28 Senate confirmations at this point during Trump’s first term.

Looking ahead to personnel announcements in the next 100 days

At the end of March, President Trump withdrew his nomination of Elise Stefanik as UN ambassador, the only unfilled position on his cabinet. He has yet to announce who will be his new nomination for the position. Overall, 221 Trump nominees are currently being considered by the Senate, and hundreds more positions he has yet to fill.

Musk has also announced he will depart his role as head of the “Department of Government Efficiency” in the next few weeks to return to his work as CEO of Tesla.

Finance and the federal budget

Trump’s first 100 days in office has been centered on efforts to reduce the federal budget. He has sought to achieve this through his executive power by placing a hiring freeze on the federal government and reducing the number of federal workers by tens of thousands. These efforts have been spearheaded by Elon Musk’s DOGE. Musk’s team has been tasked with rooting out inefficiencies in the federal government, which has resulted in the shuttering of entire agencies and numerous programs and offices across the government. As with much of the rest of Trump’s agenda, many of these actions have been challenged in court.

Over the next few months, Congressional Republicans will be working on a Reconciliation Bill to reprioritize federal spending and extend tax cuts. House Republican committee chairs will spend the next weeks working on their portions of the tax, energy, defense, and immigration package. The legislation will likely also extend the 2017 tax cuts, authorize additional tax cuts, and raise the debt ceiling by $5 trillion. Major questions loom over the fate of Medicaid and other social safety net programs as Republicans look to offset rises in defense spending and the costs of extending tax cuts for wealthy Americans. Extending the debt ceiling is an essential part of whatever package the Republicans take up, as the US government hit its debt limit of $36.1 trillion back in January. The Treasury has since been using “extraordinary measures” to finance ongoing government operations, but these measures will be exhausted by September, and possibly earlier in the summer.

Foreign policy and trade

Nowhere has Trump’s impact been more profound than in America’s relationship with the rest of the world. Trump came to office with an “America First” agenda built around stymying the flow of fentanyl into the U.S., enhancing economic security via trade negotiations, and tackling foreign influence in U.S. supply chains.

Diplomatically, Trump has reset American relationships with Canada, NATO, Europe and much of the rest of the world in ways that have upset an international political, economic, and security order that has existed for 80 years.

One of President Trump’s core campaign promises focused on reducing the U.S. trade deficit and curbing unfair trade practices with foreign trading partners. The Administration has since imposed a wide range of high-value tariffs aiming to encourage new trade deal negotiations, reshore manufacturing, preserve national and economic security, and reduce American reliance on foreign supply chains.

Tariff measures implemented to date include, but are not limited to, the following:

• 20% tariffs on China to curb the flow of fentanyl (issued in two tranches of 10% on February 4 and March 4, respectively)
• 25% tariffs on goods from Canada and Mexico, with a lower 10% tariff applied to certain energy and potash products (exempted are goods that are compliant under the U.S.-Mexico-Canada-Agreement (“USMCA”))
• 25% tariffs on automobiles and automobile parts (with limited exceptions, such as applying only to the U.S. content of USMCA-compliant vehicles)
• 25% tariffs on steel and aluminum products and related derivative goods
• 10% baseline reciprocal tariff on all goods from all countries, effective as of April 5th (with limited exceptions outlined in the reciprocal tariff Executive Order)
• Higher, individualized, country-specific reciprocal tariffs on a subset of approximately 60 countries (originally effective as of April 9th but paused for 90 days to enable bilateral negotiations)
• 145% reciprocal tariff on China (additive to the pre-existing Section 301 tariffs imposed during President Trump’s first term)

Trump has predominantly relied on legal authority from the International Emergency
Economic Powers Act (“IEEPA”), Section 232 of the Trade Expansion Act, and Section 301 of the Trade Act of 1974 to impose these tariffs. In conjunction with these implemented measures, the Administration launched several investigations into the potential national security impact of, and presence of unfair trade practices related to, certain products, e.g., semiconductors, pharmaceuticals, critical raw minerals, and shipbuilding. It is likely that several, if not all, of these investigations result in the imposition of additional levies.

The Administration noted approximately 15 formal trade deals are being actively negotiated. Meanwhile, several countries have either begun or momentarily paused a series of countermeasures in response to the latest wave of reciprocal tariffs, including China, Canada, Mexico, and the European Union.

Relatedly, the Trump Administration also launched the “America First Investment Policy” and subsequent U.S. Investment Accelerator, designed to stimulate foreign investment into the U.S. and U.S. investment abroad while reducing national security threats and lengthy transaction review processes.

Energy & climate agenda

Trump has rapidly reshaped U.S. energy and environmental policy, declaring a “national energy emergency” and issuing a series of executive orders and agency deregulation efforts aimed at reversing the Biden administration’s climate agenda, reversing industry emission standards, and boosting the production of fossil fuels..

Trump’s broad sweeping order “Unleashing American Energy” redefined what constitutes energy—excluding wind and solar—and directed federal agencies to prioritize infrastructure over conservation, particularly through a reevaluation of the Endangered Species Act. Other executive actions called for expanded drilling and production for domestic oil, gas, and mineral development while rolling back regulations that support electric vehicles. The President has also withdrawn the U.S. from the Paris Climate Accords, is trying to revive the coal industry, and paused disbursement of funds appropriated through the Inflation Reduction Act (“IRA”) and the Infrastructure Investment and Jobs Act (“IIJA”). Agencies were instructed to “revise, rescind and suspend” rules that could restrict energy development, with the EPA using this directive to revisit foundational emissions policies such as its 2009 endangerment finding on greenhouse gases.

The administration has also issued more targeted directives to shore up grid reliability, and alter enforcement under environmental laws. Citing these executive orders, the Department of Energy has issued new LNG export permits, seeking to streamline the permitting process, and explore deep sea mining in his “Unleashing America’s Offshore Critical Minerals and Resources” EO. In parallel, Trump’s team is pursuing personnel reductions across key environmental agencies, including the EPA, Interior, and Energy Departments. The EPA has already announced workforce cuts in its environmental justice offices, and hiring freezes are underway at Interior and DOE. Broader impacts are hitting agencies like NOAA, where large-scale staff reductions have raised concerns about weakened forecasting capabilities and degraded public services.

Trump targets drug prices and HHS restructuring

President Trump and HHS Secretary Robert Kennedy Jr campaigned on a “Make America Healthy Again” agenda (MAHA), promising to reform the public health system in the United States. President Trump has begun efforts to massively reform the Department of Health and Human Services (“HHS”), with the Food and Drug Administration (“FDA”), Centers for Disease Control and Prevention (“CDC”), and Centers for Medicare and Medicaid Services (“CMS”) being a particular focus. Kicked off by a February 13, 2025, MAHA Executive Order, much of Trump’s activities have focused on reforming the federal health bureaucracy. Through layoffs and voluntary departures, as well as funding freezes, the Trump Administration has begun its plans to restructure HHS in line with MAHA’s goals of promoting nutrition and combatting chronic disease.

President Trump also issued an April 15, 2025, Executive Order aimed at lowering drug costs. Among other things, the Executive Order identified changes to the IRA’s Medicare Drug Price Negotiation Program and directed HHS to tackle other issues like Prescription Benefit Management reform and expediting the drug approval process for generics and biosimilars. An outstanding question remains to what extent prescription drugs will be subject to increased tariffs. Additionally, the healthcare industry is watching Congressional Republicans attempts to reform the Medicaid system as part of their reconciliation process, which is expected to take shape in the coming weeks and months.

Education overhaul through executive actions

President Donald Trump has used executive authority to advance his campaign pledge to effectively dismantle the Department of Education. In March, Trump signed an executive order instructing Education Secretary Linda McMahon to begin dismantling the department, following a significant reduction in staff by nearly half. Trump argues that eliminating the department would restore education authority to the states, though critics highlight contradictions in federal actions that seek to regulate school policies on issues such as transgender participation in sports and campus antisemitism. Court rulings have temporarily blocked parts of these efforts, particularly those attempting to tie funding to reductions in diversity, equity, and inclusion programs. The administration has also resumed collection on defaulted federal student loans and issued a series of executive orders to reshape education policy, including promoting artificial intelligence in schools, reinstating strict discipline models, overhauling accreditation processes, and increasing transparency on foreign funding at educational institutions.

Travel abroad and meetings with foreign leaders

President Trump has only travelled abroad once since his inauguration, to The Vatican for the funeral of Pope Francis. However, over the next 100 days Trump plans visits to Saudi Arabia, Qatar, and the United Arab Emirates, and possibly the United Kingdom. Vice President J.D. Vance travelled to both Italy and India recently to progress discussion regarding trade negotiations, and he also attended the Munich Security Conference in February.

Several delegations from foreign trading partners have visited the U.S. since President Trump took office, primarily to discuss the impact of the reciprocal tariffs. Such countries include Japan, Italy, South Korea, among others. Israel’s Prime Minister Netanyahu has visited with Trump twice in the Oval Office and the President has hosted leaders of Ukraine, Japan, the UK, and Italy, among others. As negotiations progress, and or additional tariffs are imposed, we anticipate future meetings with foreign delegations.

Next steps

These are unprecedented times given the rapid and ever-evolving pace of policy change at the federal level. Our team will continue to monitor this progress and related updates, and in the interim we are well-positioned to answer any questions or address any concerns resulting from ongoing presidential action.

Authored by Aaron Cutler, Tim Bergreen, Shelley Castle, Valerie Marshall, Ches Garrison, and Nicki Ghazarian-Foye.