Russell Vought has been selected as Trump’s Director of the Office of Management and Budget. Vought is one of the principle architects of Project 2025, authoring a chapter in the 922-page Mandate for Leadership: The Conservative Promise and drafting a secret 180-day playbook for the incoming Trump administration.

Vought defines the OMB Director as “the keeper of [the] ‘commander’s intent’” on page 45 of the Mandate for Leadership, explaining that the OMB Director should be “the best, most comprehensive approximation of the President’s mind” so that they can “shape the most efficient way to pursue an objective.”

How Vought will go about this task is an open question. Trump is known for his mercurial temper and inconsistent policy positions, which led the Washington Post to label him “King of Flip-flops” in 2017. 

Trump largely ignored intelligence reports during his first term as president, opting for oral briefings instead of reading the daily written memos he received. Even then, James Clapper, Trump’s former Director of National Intelligence, said that Trump would go off on tangents during the oral briefings. “There might be eight or nine minutes of real intelligence in an hour’s discussion,” Clapper said.

His disinterest in the day-to-day responsibilities of the office had deadly consequences: the intelligence community repeatedly warned Trump about the very real possibility of a COVID-19 pandemic starting as early as January 2020, but he didn’t read their memos. Instead, he relied on reports from Chinese President Xi Jinping. 

The daily briefs, had he read them, would have also warned that President Jinping was downplaying the severity of the pandemic.

Given how unpredictable Trump’s positions are – and his lack of engagement with basic presidential duties – there’s a real risk that Vought ends up keeper of his own intent, not the president’s. In that world, Vought will have significant power to enact his personal plans, as he explains in his Project 2025 chapter.

Experts have long argued that a rogue OMB is a risk even under normal circumstances with highly engaged presidents. A Yale Law Review article published in 2016 examined the ways that OMB can control policy across the federal government, while OMB’s confidentiality policies “‘offer the tantalizing possibility of influence without fingerprints.’”

The author, Eloise Pasachoff, explains that OMB staff portfolios are “vast and full of discretion” and they have an unusual level of power. Where Senate-confirmed officials are typically given the most authority, “civil servants and lower-level political appointees in OMB can supersede the policy goals of Senate-confirmed agency officials.“ For that reason, there is “a danger, more than theoretical, that their role will be co-opted in the service of partisan action.”

Pasachoff says the OMB can exert control over policy decisions in other federal agencies during budget preparation, budget execution, and through management initiatives.

During budget preparation, Pasachoff describes three levers for control:

• The “form-and-content lever” refers to OMB’s power to set the terms of a budget discussion. OMB decides how other agencies can present their budget proposals (the form) and what they are allowed to include in the proposal (the content). OMB Directors can also issue memoranda to further focus an agency’s budget proposals. Through these levers, the OMB can direct agency priorities before any funding is even requested.
  
  For example, Obama’s OMB Director issued a memorandum in 2016, directing agencies to prepare “budget submissions for particular programs designed to counter biological threats.” Agencies responded by adding programs to aid in fighting pandemics or biological warfare, which necessarily meant reducing or eliminating funding requests for other programs.
  
• The “approval lever” refers to OMB’s authority to approve, reject, or modify the budget proposals submitted by other agencies. The OMB can demand adjustments both to funding requests and to the policy language in budget proposals. The budget proposal will not go to Congress until OMB approves the funding amounts and the policy language that supports the request. “These are the policy choices that the administration—including agency officials themselves—will advocate for during the subsequent congressional budget process.”
  
  “The approval lever functions both at a broad level, securing overall agency compliance with the President’s general policy preferences, and at a narrow level, governing budget and policy choices in discrete line items,” Pasachoff writes.
  
• The “confidentiality lever” refers to OMB’s authority to control what agency officials and civil servants are allowed to say to outside groups – including advocacy groups, the media and even Congress – when it comes to budget requests. Historically, OMB has banned agency officials, even cabinet-level appointees, from voicing any disagreement with the final presidential budget proposal OMB provides to Congress. OMB staff monitor Congressional hearings, “efforts to circumvent the confidentiality requirement may have negative consequences for both officials and their agencies.”
  
  In this way, OMB is able to influence the policy language and decisions of other agencies while hiding the changes they may have forced onto those agencies.

During budget execution, Pasachoff identifies two more levers for control:

• The “specification lever” refers to OMB’s control over the apportionment process. “The apportionment power gives OMB a regular opportunity to control how agencies conduct their operations. The RMOs [Resource Management Offices]  take the lead in this responsibility.” One of their most significant powers here is the footnote, which can place restrictions on how an agency can use its funding, either by limiting how much can be spent on a program or directing the agency to spend some amount of money on a favored project. The footnotes carry the force of law – violating or ignoring footnotes can lead to “suspension without pay or removal from office” or even criminal penalties, “including a fine of up to $5,000 and up to two years imprisonment.”
  
  Violating one of the footnotes is punishable even in some emergency cases. For example, the Forest Service violated the Anti-Deficiency Act when they exceeded a $100 million limit on aviation expenses laid out in a footnote, even though it was done during a wildfire emergency.
  
  On top of this, “there is no public collection of apportionment decisions, much less apportionment footnotes,” meaning the public has no way to know how often footnotes are used, what they are used for, or if any agencies are commonly targeted by footnotes. Once again, OMB is given significant power to direct other federal agencies while keeping their influence secret from Americans.
  
• The “monitoring lever” refers to OMB’s ability to “become intimately involved with agencies’ policy choices” by overseeing the implementation of agency programs. RMO program examiners – the frontline civil servants at OMB – can have frequent communication with agency officials. “Agency documents reflecting policy choices, such as grant criteria and other allocative decisions, may be significantly revised by the RMOs and sent back to the agency to incorporate changes.”
  
  Individual program examiners are given discretion in many of their decisions. While higher ranking civil servants or political appointees have more authority, not every decision is considered important enough to bring to their attention.
  
  “Again,” Pasachoff writes, “this is not to suggest that the RMO staff, whether civil servants or political appointees, regularly implement their own policy priorities but rather to note that independent judgment calls may have substantive effect.”

Pasachoff lists two levers under management initiatives:

• The ‘Presidential Management Agenda (PMA) lever” refers to OMB’s power to direct agencies to implement PMAs. PMAs are often presented as policy-neutral plans to improve government efficiency, but often have major policy implications.
  
  For example, President George W. Bush’s “Faith-Based and Community Initiative,” which supposedly worked to improve collaboration between federal agencies and religious organizations, “was not simply bureaucratic; it attempted to weaken the wall between church and state.”
  
• The “budget-nexus lever” refers to OMB’s ability to tie PMAs to budget proposals. The form-and-content lever is a primary tool here – OMB can force federal agencies to include implementation plans for PMAs in their budget proposals, tying agency funding to compliance with policy-changing presidential initiatives.

Vought’s chapter in Project 2025 shows he is fully aware of the power OMB holds over the federal government and that he is prepared to use it. He writes that “OMB’s budget team

plays a key role in executing policy across the executive branch, including at many

agencies wrongly regarded as ‘independent.’”

One of Vought’s primary goals at the OMB is to put as much power as possible in the hands of political appointees rather than career civil servants. He plans to have the Program Associate Directors (PADs), who are political appointees, take over the apportionment process, as they did during the first Trump administration. Typically, the Deputy Associate Directors (DADs) sign apportionments. DADs are career civil servants who “often have deep policy expertise in the areas they oversee,” according to Pasachoff.

PADs, on the other hand, are political appointees chosen for their partisan loyalty; Vought writes that the Director of the OMB must be “aggressive in wielding the tool [of apportionment] on behalf of the President’s agenda.”

Additionally, Vought says that “the existing six RMOs should be divided into smaller subject-matter areas, allowing for more PADs, and each of these PADs should have a Deputy PAD” on page 47. This would more than double the number of PADs, enabling “more comprehensive direction and oversight of policy development and implementation.”

Pasachoff described PADs as particularly dangerous officials in the OMB even when they didn’t have control of the apportionment process. 

“The PADs are even less transparent and more powerful than the so-called “czars” that received so much attention, much of it negative, in the early Obama Administration. They are less transparent because their appointment is routine, so their existence and portfolio is not scrutinized. Their work remains shrouded in secrecy because of the confidentiality lever. They are more powerful because they have clear responsibilities and duties that operate under statutory- and OMB-driven deadlines through all of the budget preparation, budget execution, and management levers discussed above. They do not fall under either category of political official presented in the conventional view—they are neither senior White House political advisors nor Senate-confirmed agency officials.”

By increasing the number and authority of PADs, Vought threatens to turn the OMB into the partisan puppetmaster of the federal government.

Vought’s plans extend beyond the “budget” side of OMB. He says the Director must choose a General Counsel who is “creative and fearless in his or her ability to challenge legal precedents that serve to protect the status quo.” The General Counsel will almost certainly work in tandem with the Office of Information and Regulatory Affairs (OIRA), which Vought also hopes to empower during the Trump administration.

“Regulatory analysis and OIRA review should also be required of the historically ‘independent’ agencies as the Office of Legal Counsel has found is legally permissible,” Vought writes on page 49. Independent agencies are a favorite target for Vought, who seems to believe that independent agencies should not exist. The fiercely partisan General Counsel Vought envisions for himself will certainly do their best to undermine independent agencies wherever possible.

Vought calls for the revival of eight executive orders – Executive Orders 13771, 13777, 13891, 13892, 13893, 13924 Section 6, 13979, and 13980 – all of which strengthen OIRA by giving it oversight over more regulations, make it harder for agencies to create new regulations or make it harder for agencies to enforce existing regulations. 

For example, EO 13771, titled “Reducing Regulation and Controlling Regulatory Costs,” required that agencies repeal two existing regulations any time they introduced a new one, based solely on a cost analysis. The order was lambasted as blatantly unconstitutional and illogical by groups like the NRDC, but lawsuits failed as groups struggled to establish their legal standing to sue.

Additionally, Vought will direct the Office of Performance and Personnel Management (OPPM) to start grading agency performance based on explicitly partisan metrics. On page 48, he writes that OPPM should “establish annual performance goals and review processes for agencies that reflect the President’s agenda. OPPM should also be part of the President’s strategy to set and enforce sensible policies and practices for the federal workforce.”

His influence may extend beyond federal agencies as well: Vought directs the Office of Federal Procurement Policy (OFFP) to “push back against woke policies in corporate America.” He may intend to make use of arcane rules that make it easier for federal agencies to change the terms of grants and contracts to exert control over private businesses, which we wrote about in detail here.

Taken together, these plans have the potential to establish Vought as the most powerful person in America – as long as he can keep his job under the pink slip-happy Trump, who set multiple records for firing senior officials in his administration.