THE LIVING LIBRARY / ACCOUNTABILITY INVESTIGATION

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Heritage
Files.

I have spent enough time studying Project 2025 to recognize what gets lost when an ambitious political program is described as a routine set of administrative reforms: the people whose legal protections become negotiable once its recommendations reach an agency with real authority.

This investigation follows the Heritage Foundation's published agenda into the federal record, where proposals influence federal staffing and the rules that govern ordinary lives. I am writing from an unmistakably critical position, but I want the documentary trail to remain visible throughout, especially where an important connection has not yet been proved.

Read the six investigations ↓Why I am doing this
The Heritage Files editorial illustration, displayed while the licensed headquarters photograph loads
Heritage Foundation headquarters, photographed by Ajay Suresh, CC BY 4.0. If the original photograph cannot load, an editorial graphic appears instead.
The editorial position is mine, and the evidence belongs to the publicI identify the sources behind government actions and financial figures, distinguish forecasts from results, and disclose what the available records still cannot establish.
Start here / The point of the investigation

A plan for government is also a plan for the people who will live under it.

When the Heritage Foundation assembled Project 2025, it did more than produce another collection of conservative policy recommendations. It described a government in which responsibility for education could be moved or eliminated, protections against corporate abuse could be weakened, and career officials could lose safeguards intended to keep public service from becoming political patronage. I find the implications alarming because these decisions move well beyond the people writing the proposals, reaching families who depend on public institutions and who rarely have any opportunity to influence the decisions made about them.

My purpose is to establish how much of this agenda entered government practice, who had the authority to carry it out, and what the financial and legal records show about the consequences. That requires more than matching a phrase in Project 2025 with a later executive announcement: it requires examining the exact text of a statute, the administrative record behind an agency decision, and the limitations of an audit before reaching a conclusion. I intend to criticize this project without granting it the courtesy of confusing moral outrage with proof, because an investigation grounded in documents is harder for the people responsible to dismiss.

My position, stated plainly

I draw a comparison between the exclusionary vision in parts of Project 2025 and the ideology that animated the Ku Klux Klan, not because I believe the organizations share identical histories or methods, but because I recognize a persistent American willingness to define some people as less entitled to protection and belonging than others. The Klan used organized intimidation and racial terror to defend a violently unequal social order; Heritage works through policy advocacy and political institutions. Those differences are substantial, yet I remain deeply disturbed by proposals that would roll back protections for LGBTQ+ people and weaken federal commitments to equal treatment, particularly when the language of administrative efficiency makes the human cost easier to ignore.

I regard the agenda as extremist in its willingness to withdraw protections from people who already face discrimination, and I understand why opponents experience that project as threatening rather than merely theoretical. My use of that language is a stated political and moral judgment, not a claim that the Heritage Foundation is formally designated as a terrorist organization or has been proved to coordinate with the Klan. I would rather document precisely how power is being used than ask readers to accept a sweeping label without evidence, which is why the original Project 2025 manual remains available beside my criticism.

THE BLUEPRINTWhat did Heritage put in writing?
THE GOVERNMENTWhat actually happened in law and agency action?
THE CONSEQUENCESWho bears the burden, and what is still unproven?
The main investigations / Six case files

Six investigations into the exercise of federal authority

I have organized the material into six investigations so a reader can begin with a public institution they know and follow the policy, government action and supporting evidence without first learning the entire history of the project.

01EDUCATION

What happens when federal education responsibilities are moved out of sight?

Project 2025 envisioned an end to the Department of Education as a cabinet agency, while the administration later pursued interagency arrangements that shifted particular administrative services to other federal departments. I want to examine the people and programs affected by those decisions without pretending that moving work through an agreement is equivalent to Congress repealing the statutes that created the department's responsibilities.

The Education–Labor agreements and their later addenda reveal a complicated sequence in which responsibility for specific programs could be assigned, excluded and then partly restored. The House Education and Workforce Committee subsequently advanced legislation aimed at making additional transfers permanent, although a committee vote cannot accomplish that on its own. For students who depend on these programs, the distinction between a temporary administrative reassignment and a change in governing law is far more consequential than the slogans used to promote either one.

Open primary records, source links and the detailed case file

Heritage’s 2023 blueprint advocated reorganizing and ultimately eliminating the federal Education Department, whereas subsequent interagency service arrangements demonstrate an administrative transfer of responsibilities rather than statutory abolition. The July 2026 House committee docket records proposals and votes but does not establish that the proposals became law. Original state-by-state Perkins disbursement records are not in the verified case file.

Evidence status: Government administrative actions and a congressional committee record verified; details of the March signed addendum indexed but not fully retrieved; school-level and state-level payment impacts require original records.

Original Project 2025 manual ↗Committee source and markup ↗Federal agency statement ↗
Original agreement record: January and March 2026 revisions

The Education–Labor postsecondary interagency agreement was signed on September 30, 2025. According to an Education Department-hosted March 20, 2026 addendum, a January 9 addendum had prevented Labor from performing the designated administrative services for the HBCU Capital Financing and College Housing and Academic Facilities Loan programs. The March addendum reinstated certain services under paragraph 23 of the original agreement. The precise responsibilities must be checked against the signed attachment before final publication; the original PDF was indexed in search but blocked direct document extraction during the document review.

Boundary: A revision of administrative services does not transfer statutory congressional authority or prove the Department of Education was lawfully abolished. The Inspector General’s examination of the higher-education agreement was still listed as ongoing on October 14, 2026.

Education Department: March 20 addendum ↗December 5 federal implementation account ↗Education Inspector General: ongoing work ↗

Read the policy-to-record investigation and its legislative boundary

The chapter titled Department of Education in the 2023 Project 2025 manual advocated removing the department as a cabinet agency while redistributing federal education responsibilities. Its institutional recommendation is not an existing repeal. The federal government can assign administrative services through interagency agreements, but such agreements do not themselves amend underlying authorizing statutes or repeal a congressionally established department.

The September 30, 2025 postsecondary Education–Labor agreement was changed twice. A January 9, 2026 addendum excluded specified Labor services for the HBCU Capital Financing and College Housing and Academic Facilities Loan programs. The Education Department's indexed March 20, 2026 addendum restored designated services under paragraph 23 of the original agreement; that dated chronology is supported by the federal document search record. The original signed PDF returned a 403 retrieval restriction in this review, so the precise task-and-funding assignments are not marked fully authenticated.

On July 15–16, 2026, the House Education and Workforce Committee voted to report multiple restructuring bills as amended. For example, the markup docket records a 19–16 vote to report H.R. 9607; a committee-reported proposal still requires further congressional action. Neither that vote nor the interagency addenda establishes the department's legislative elimination.

The Education Inspector General's online work register is the correct place to track its pending examination of the interagency arrangement. No completed adverse finding from that specific examination has been authenticated for this release.

Original July 2026 markup and roll calls ↗March 20 addendum, indexed federal PDF ↗Education OIG investigation status ↗
How the administration of two loan programs changed
September 30, 2025

Original Education–Labor agreement assigns specified services to Labor.

January 9, 2026

An addendum excludes the HBCU Capital Financing and College Housing and Academic Facilities Loan services.

March 20, 2026

The next addendum restores identified services under paragraph 23 of the original agreement.

Chronology paraphrased from the indexed federal addendum. The government PDF URL is retrievable in search, but direct PDF access is restricted to our document client; a signature-page facsimile is not available; no other terms beyond the indexed text are authenticated.

Open the source document on ed.gov ↗

The HBCU Capital Financing program separately lists a $22.5 million Benedict College financing transaction in June 2026 and a $25 million Edward Waters University transaction in September 2026. These are listed loan transactions, not evidence which federal agency performed each administrative task. Education Department loan transaction list ↗

02CLIMATE

EPA’s repeal of a climate protection and the contested savings projections

Heritage's manual urged the government to revisit the finding that greenhouse gas pollution endangers public health, and EPA subsequently took the more sweeping step of rescinding that finding. I am concerned by the regulatory consequences as well as the attempt to present a complex environmental decision through the convenience of an enormous projected savings figure, even though the agency's own analysis contains scenarios in which the change produces net costs.

A financial model cannot tell the public that money has actually been saved, particularly when its assumptions about future fuel prices and consumer behavior materially change the outcome. This investigation therefore places EPA's final rule beside its technical analysis, making the range of projected results visible while keeping the written Heritage recommendation distinct from EPA's ultimate decision. Similarity between the two records warrants scrutiny, but it does not by itself reveal who directed whom behind closed doors.

Open primary records, source links and the detailed case file

Project 2025 recommended an update to the 2009 finding; in February 2026, EPA finalized its rescission. EPA’s own cost-benefit scenarios contain materially different projected net outcomes, and the rule faces judicial review; Heritage’s relationship to the final EPA instruction remains unproved.

Evidence status: A federal final rule; modeled financial results, not realized savings.

Original Project 2025 manual ↗EPA final rule ↗EPA final rule and linked regulatory impact analysis ↗

Economic evidence / February 2026 EPA regulatory impact analysis

The EPA public announcement cited more than $1.3 trillion in gross savings. Its technical impact analysis modeled four different net results, depending on energy prices and how consumers are assumed to value fuel savings. All figures below are net present values over 2027–2055, in billions of 2024 dollars.

EPA rescission: modeled net savings or costs
RIA scenarioDiscount at 3%Discount at 7%Principal assumption
A1−$180B net cost+$89BReference energy prices, full lifetime fuel valuation
A2+$250B+$320BLower fuel-price sensitivity
A3+$790B+$600BReference prices, 2.5-year fuel valuation
A4+$920B+$680BLower prices, 2.5-year fuel valuation

A net saving is not an observed receipt; the 3% A1 result is a modeled net cost. Totals are rounded. The Heritage manual's request to update the 2009 finding was narrower than EPA's completed repeal. No private Heritage instruction to EPA is established in the records reviewed.

EPA original impact analysis, Tables 2–3 ↗GAO's independent rule review ↗Federal Register final rule, 91 FR 7686 ↗
03CONSUMER PROTECTION

The effort to weaken the agency that stands between borrowers and financial companies.

Project 2025 argued for abolishing the Consumer Financial Protection Bureau, and Congress later reduced the statutory ceiling on the funding the agency could request. I do not regard that change as an obscure budget adjustment, because the bureau was created to address practices that can leave ordinary borrowers fighting institutions with far greater resources, even though the enacted measure stopped short of the abolition Heritage had proposed.

To understand what happened, I have separated the agency's legal existence from the later funding formula and from transfers already recorded in its audited statements. That distinction is important whenever an administration portrays institutional weakening as an inevitable financial fact, particularly because a funding ceiling is not proof that the corresponding amount was transferred, withheld or spent. The evidence also records the subsequent litigation without assuming that a judicial ruling resolves every dispute about the bureau's future.

Open primary records, source links and the detailed case file

Project 2025 recommended abolishing the CFPB, but the legislation enacted in 2025 instead reduced its prospective funding ceiling, which is a narrower legal change than the elimination Heritage requested. Federal financial statements distinguish transfers made before the amendment from the later ceiling, while court decisions address separate disputes about the agency’s requests for funding and confirm the importance of keeping the legal questions distinct.

Evidence status: Established financial figures and judicial findings with separate legal contexts.

Original Project 2025 manual ↗Public Law 119-21 ↗CFPB audited financial report ↗
Read the funding, timing, and litigation reconciliation

Project 2025's consumer financial protection section advocated congressional abolition of the CFPB. Section 30001 of Public Law 119-21, enacted July 4, 2025, instead reduced the formula governing the Bureau's maximum new Federal Reserve transfers from 12% to 6.5% of the relevant operating expense base; that legislative change did not repeal the CFPB's underlying statute.

The Bureau's audited financial report lists $494 million in Federal Reserve transfers during fiscal 2025 despite a revised annual cap near $445.8 million. The same report says those transfers were requested before the July 4 effective change. Comparing an entire year's transfers against a lower cap that took effect during that year does not establish an illegal excess payment. Total spending, historical fund balances, civil penalties and quarterly transfers are separate accounting concepts.

On September 25, 2026, in State of New York v. Vought, the District of Oregon vacated challenged funding-refusal decisions. The court interpreted the relevant Federal Reserve “combined earnings” language as gross revenues without deducting expenses, and granted declaratory relief. This is a trial-court ruling; subsequent appellate proceedings or funding receipts must be checked independently before representing the ruling as a final nationwide disposition.

Public Law 119-21, Section 30001 ↗Audited FY2025 financial report ↗September 25 court opinion and order ↗
04FOREIGN ASSISTANCE

The dismantling of foreign assistance has a record that cannot be reduced to a headline.

Heritage proposed extensive changes to the foreign-assistance bureaucracy, while the later federal restructuring terminated thousands of USAID awards and transferred important responsibilities to the State Department. I consider the scale of that disruption serious enough to require an accounting that follows the awards and administrative decisions individually rather than turning a multiyear contractual amount into a misleading claim about cash already lost.

The GAO findings show how many awards were terminated and which obligations were associated with them, but they do not establish that every reported dollar had already been paid or that Heritage personnel secretly ordered the agency's decisions. I am keeping those categories distinct because the real accountability questions concern programs stopped, commitments disrupted and decisions that can be traced to identifiable federal authority. Those questions become harder to answer when dramatic but inaccurate figures replace the underlying documents.

Open primary records, source links and the detailed case file

The 2023 manual called for USAID cuts and restructuring. The later administrative transfer to State exceeded the specific printed USAID proposal. GAO reported approximately 6,780 terminated awards, reflecting $79.1 billion of multiyear historical obligations rather than newly missing cash; state OIG documented operational oversight gaps.

Evidence status: Auditor-reported totals; do not mislabel cumulative obligations as diverted funds.

Original Project 2025 manual ↗GAO USAID transfer audit ↗State OIG award review ↗
05FEDERAL WORKFORCE

Political control of the civil service changes whose judgment survives an administration.

Project 2025 advocated reviving a Schedule F-style approach to federal employment, and the administration later established the Schedule Policy/Career designation for selected positions. I see the weakening of career-service protections as a consequential shift in power because officials who administer federal programs should not have to treat political loyalty as the price of carrying out their lawful responsibilities.

The published reclassification figures establish the scale of an initial personnel action, not the number of employees dismissed or a hidden roster of people targeted for punishment. Office of Government Ethics records also show that certain public financial-disclosure obligations were altered for qualifying positions while other filing duties remained. My purpose is to follow what the rules actually changed and who possessed the authority to change them, rather than substitute insinuation for personnel records that have not been obtained.

Open primary records, source links and the detailed case file

The 2023 manual recommended reinstatement of Schedule F. OPM’s final rule and June 2026 executive order moved approximately 7,600 positions into Schedule Policy/Career, changing removal protections while retaining career designation. OGE preserved pre-existing financial-disclosure requirements and excluded an estimated 6,400 from new filing solely due to classification; a later petition phase has unverified outcomes.

The disclosure rule and its quantified paperwork trade-off

OGE's July 23, 2026 interim rule preserved existing financial-disclosure filing status for many reclassified career positions. It did not cancel public or confidential filings required on other grounds. Its estimated savings represent paperwork and ethics-review hours avoided, not cash recovered from agencies.

6,400Estimated would-be new public filers, without the rule
$14.6MEstimated cost of filing and review avoided
$0.85MEstimated cost to review classification-related obligations
Examine the rule's original arithmetic and exception

The published assumptions are 10 hours of employee preparation at $162.22/hour and 5 hours of ethics review at $132.28/hour per estimated affected employee. The modeled gross avoided labor is $14,615,040; one hour per employee for exemption assessment costs $846,592; OGE describes roughly $13.7 million in first-year net savings. The underlying amounts are estimates; rounded agency summary figures need not be mathematically exact at the displayed precision.

Legal qualification: 5 CFR §2634.203(e) exempts positions from new public reporting arising solely from Schedule Policy/Career status. Other disclosure obligations remain in place, and agency ethics officials still assess the standards for confidential filings.

Original OGE rule and cost analysis, 91 FR 46239–46243 ↗ · OPM's July 2026 second-phase instruction ↗

Evidence status: Verified initial reclassifications; second-wave conversions are unverified.

Project 2025 chapter 3 ↗June executive order ↗July OGE ethics rule ↗Second-phase OPM data call ↗

Statutory precision: OGE added 5 CFR § 2634.203(e), a rule-based exclusion for certain Schedule Policy/Career employees. It does not cancel separate public filer obligations under 5 CFR § 2634.202 or the assessment of confidential filings under § 2634.904(a)(4). Read original final regulatory text, page 46243 ↗

06HEALTH COVERAGE

A federal work requirement reaches well beyond a line in a policy manual.

Project 2025 proposed allowing states to pursue Medicaid work requirements, and legislation enacted in 2025 went further by establishing a federal community-engagement condition for a defined population beginning generally in 2027. I oppose the prospect of health coverage being placed at risk through another layer of eligibility reporting, particularly when federal data show that many Medicaid beneficiaries already participate in paid employment during the year.

The immediate evidence cannot tell us how many people will lose coverage under rules whose nationwide operation has not yet occurred, but it can show what earlier eligibility systems cost, which implementation expenses CMS has projected and where GAO found weaknesses in existing oversight. I have kept actual state spending separate from national forecasts and have refused to turn an individual's employment in one month into an assumption about meeting every later reporting deadline, because the administrative burden itself is part of the policy's human consequence.

Open primary records, source links and the detailed case file

The 2023 Project 2025 manual proposed authorizing Medicaid work requirements for certain adults at the state level. Section 71119 of the July 2025 reconciliation law instead requires specified states to establish such requirements, generally beginning January 2027. CMS issued an implementing rule in June 2026 and corrected procedural provisions later that month. The policy is enacted, but nationwide eligibility outcomes are not yet observed.

80 hoursMonthly activities for the covered population; exceptions apply
$1.52BCMS projected eligibility-system costs, 2026–2036, federal and state
$600M+Technology firms' voluntary pledged services and discounts, not audited savings
Read evidence qualifications

The $1.52 billion figure is a forecast that already includes a $200 million statutory system-funding allocation; CMS's January 2026 vendor pledge is not a contract-award register. The Congressional Budget Office's 7.5 million additional uninsured projection in 2034 concerns the entire 2025 Medicaid legislative package, not Section 71119 alone; no Heritage-directed procurement or improper enrichment is established.

Evidence status: Enacted statute and issued rule; national coverage impacts prospective. Procurement details open.

What the state spending records show

A federal audit of Georgia’s earlier Pathways demonstration shows the costs that actually occurred, separate from CMS’s forecast for the new nationwide eligibility system. These figures reflect FY2021 through March 2025 and are not a national cost estimate.

$54.18MAdministration, 67.5% of reported demonstration expenditure
$26.10MMedical assistance, same period
$47.44MFederal share of the administrative spending
Examine the audit, its disputed federal matching rates, and early state implementation

GAO found approximately $50.8 million of administrative spending involved eligibility-system changes, including about $45.1 million in contractor work. Those amounts are within, not additional to, the $54.18 million total. The $80.28 million demonstration total also includes $26.10 million in medical assistance; the earlier project delay affects the spending ratio.

GAO questioned approval of enhanced 90% federal reimbursement for some monitoring and communications activities. The relevant approval categories had aggregate budgets of $2.2 million and $2.8 million, but the report does not establish those sums were improperly paid. CMS reported that no federal matching money was spent on the questioned media activities, based on Georgia's representations.

Nebraska: State-plan amendment NE-26-0002 was approved September 4, 2026, with an effective date of May 1, 2026. This establishes a state-specific earlier implementation date; it does not establish how many Nebraska beneficiaries were disenrolled. The general nationwide effective deadline remains January 1, 2027.

Federal grants: CMS's December 2025 guidance divides $200 million available to 50 states and D.C. equally between a $100 million base allocation and a $100 million distribution proportional to the population subject to the rule. An available allocation is not a disbursement record.

Technology pledges: The vendor listings distinguish temporary no-cost licenses from separately priced integration and ongoing service fees. CMS publishing a pledge does not establish a contract award or audited public saving.

2023 manual, pp. 468–469 ↗Enacted statute § 71119 ↗June 2026 CMS rule ↗Corrected rule ↗CMS vendor pledge ↗CBO aggregate projection ↗
Follow the power / Follow the money

The institution financing and promoting the agenda

Heritage's financial statements and tax filings offer another way to examine the institution promoting this agenda, although they require the same discipline as the federal records. I can identify consolidated assets, expenses and disclosed dealings with related entities without treating an ordinary accounting disclosure as evidence of unlawful conduct. The point is to discover who exercised institutional authority and what the records permit us to say about that authority, while also identifying the documents needed to determine whether the relationships went further.

$129.2MHeritage Foundation and Affiliates expenses in its audited 2025 consolidated statements
561Public-source people-register entries, not 561 accusations or confirmed political appointees

The personnel history is likewise more substantial than a collection of overlapping names. Heritage Action's historical filings place Russell Vought and Jessica Anderson in documented organizational roles before their later work at the Office of Management and Budget, and Vought subsequently exercised authority at the CFPB. I find that movement between advocacy and government worthy of sustained public examination, while recognizing that employment history alone does not establish a private instruction channel, a prohibited financial transaction or a connection to Jeffrey Epstein.

The published blueprint

02 / The published blueprint

What Project 2025 proposed

The published Project 2025 manual and Heritage's own announcements are the appropriate starting points for examining its stated intentions, although they cannot substitute for a dated government order, official rule or enacted statute. I have retained the proposal categories below because each provides a documentary lead, not because every recommendation has been independently matched to government implementation.

Chapter 11 / Department of Education

Restructure federal education policy

The published manual advocates transferring or eliminating substantial functions of the Department of Education and changing federal education governance. The proposed action and any later government action require separate dated records.

Original Heritage publication
Chapter 17 / Department of Justice

Reorganize justice priorities

The policy agenda calls for changes to the Department of Justice and FBI, including enforcement priorities and administrative organization; Documented actions must be compared against the actual proposal text.

Original policy manual
Chapter 14 / Health and Human Services

Reframe health and family policy

The HHS chapter and Heritage's later family-policy publications provide a record for examining reproductive-health proposals, agency governance and subsequent public decisions.

Heritage 2026 family-policy event

Follow the financial disclosures

Heritage's fiscal-year 2024 Form 990 reports approximately $133.9 million in revenue and $142.2 million in expenses. The financial investigation needs to work from the entity's IRS filing and audited statements, separating donations, compensation, grants, and documented transactions from assumptions about influence.

View Heritage's EIN 23-7327730 filings   Heritage financial reports
Ten bills and the Education Department

HERITAGE LEGISLATIVE ADVOCACY

From interagency agreements to proposed permanent transfers

On July 17, 2026, Heritage Foundation education policy researcher Jonathan Butcher publicly urged Congress to codify ten interagency arrangements moving Education Department functions to other agencies, describing the bills as another step toward closing the department. His published endorsement establishes the Foundation’s public advocacy for the proposals, but it cannot establish that Heritage privately drafted the legislation or directed individual congressional votes.

Before July 2026Interagency agreements redistribute administration; their precise terms differ by program.
July 15, 2026House Education and Workforce Committee advances a package of ten measures. This is committee action, not enactment.
July 17, 2026Heritage's published policy brief asks Congress to continue codifying these transfers into law.
Explore all ten congressional proposals and the destination agencies
Introduced billPolicy fieldProposed recipientAffected functions
H.R. 9607Workforce developmentEducation to LaborAdult education and workforce training
H.R. 9610K–12 educationEducation to LaborSelected K–12 education functions
H.R. 9611Higher educationEducation to LaborHBCU programs, TRIO, veterans and other postsecondary programs
H.R. 9605Foreign medical accreditationEducation to HHSReview of standards for foreign medical schools
H.R. 9604Tribal educationEducation to InteriorSelected tribal education responsibilities
H.R. 9606Student-parent child careEducation to HHSChild care support for students with children
H.R. 9603International educationEducation to StateSelected foreign-study and international education programs
H.R. 9602Foreign gift transparencyEducation to StateHigher education foreign gift reporting
H.R. 9608Family engagementEducation to HHSParent communications and school safety functions
H.R. 9609Federal student aidEducation to TreasuryFederal student aid and loan administration

Verification boundary: The House committee voted to advance the ten-bill package. For H.R. 9611 and H.R. 9609, the latest separately checked action remains the July 15 committee action. Neither the committee vote nor Heritage's endorsement makes any of these transfers enacted law; each bill requires its own status check before that can be stated.

Read the underlying record and the central distinction

The Heritage July 17 policy brief advocates the next statutory step. The July 15 House committee announcement lists all ten measures that passed committee. The H.R. 9611 federal legislative record and H.R. 9609 congressional record document the introduced measures. The Department of Education's signed-agreement URL remains inaccessible to direct inspection due to an HTTP 403 restriction. Its indexed chronology is not represented here as inspected signatures.

A proposed statutory transfer of legal power must be distinguished from an executive arrangement for services. Heritage's published endorsement does not prove authorship of legislative text, agency direction or undisclosed financial benefits.

Source hierarchy: Heritage policy advocacy; independent House committee record; official bill records. Last substantive audit: October 19, 2026.

Heritage Foundation audited finances

04 / The Foundation's own audited finances

Follow the money without inventing a motive.

The 2025 audited report for The Heritage Foundation and Affiliates offers an independent financial baseline; the audit describes consolidated entities, donor restrictions and related-party dealings. No audit disclosure here establishes that a donor purchased an agency decision, that a related transaction was improper, or that a counterparty had any connection to Jeffrey Epstein.

Total assets$406.4MDecember 31, 2025
Net assets$331.3MDecember 31, 2025
Annual expenses$129.2M2025 statement of activities
Public support$90.0M2025 unrestricted activity
2024–2025 audited comparison: accounting lines, not political influence
Original audited consolidated statements, 2024 and 2025, U.S. dollars
Line item20242025Change
Public support, contributions$102,252,608$90,024,505−$12,228,103
Total expenses$141,096,473$129,156,549−$11,939,924
Assets, year-end$416,269,980$406,379,294−$9,890,686
Net assets, year-end$335,683,043$331,303,456−$4,379,587
Assets available for general expenses within one year$52,510,250$43,126,782−$9,383,468

Sources: audited statements, PDF pp. 4–5 (printed financial statement pp. 3–4) and PDF p. 24, note 12. Public support is one disclosed category of unrestricted activity, not all donations recognized in restricted funds.

One year later2024 vs. 2025, $ millions
Public support
2024 · $102.3M
2025 · $90.0M
Expenses
2024 · $141.1M
2025 · $129.2M
Bars show two accounting categories. Changes are not evidence of changes in undisclosed donors or political influence.
Note 11: related-party transactions and trustee overlap

The auditor records a separate related entity with three directors who are also Heritage trustees. For 2025, Heritage disclosed $1,369,172 in administrative-service income, $4,000,000 in expenses for services received and a $550,000 contribution to that entity under an expenditure-control agreement. A further $173,050 in lease income was reported from the related entity. The transactions involve different accounting types and must not be added up as one payment or one flow of money.

Note 11 does not name its related-party counterparty. A separate cross-record audit now identifies Heritage Action for America as the strongly corroborated FY2022–FY2024 services and contribution counterparty. The FY2025 reciprocal return and original executed contracts have not yet been obtained; see the next section.

Auditor's note 11, pp. 22–23 ↗

Note 13: July 2026 property disposal and other subsequent events

The same financial report identifies a July 2026 sale of unspecified real property and improvements for approximately $10 million; it was not included as a 2025 recognized gain. The report also records new financing and interest-rate swap arrangements made in January 2026. Because property address and buyers are not stated, a public-records match is outstanding. No inference about Epstein or government action follows from the sale itself.

Audited notes 12–13 ↗

What is actually consolidated?

Note 1 names The Heritage Foundation, 3rd Street Properties LLC, Massachusetts Avenue Properties LLC, Intern Housing LLC, Education Freedom LLC and The Daily Signal Institute as the entities consolidated into the audited group. Consolidation establishes an accounting boundary, not a claim of misconduct by any entity.

Audited group description, note 1 ↗

Read the complete 2025 audited report · Independent auditor's opinion issued August 26, 2026 ↗

Heritage Action related-party accounting
Heritage Action and federal personnel

DOCUMENTED PERSONNEL TRANSITIONS

From Heritage Action to federal budget authority

A direct record connects Heritage Action for America, the federal Office of Management and Budget, and later leadership of the Consumer Financial Protection Bureau. The link is documented employment history, not proof that Heritage instructed any later agency decision.

2014–2016
Heritage Action vice president

IRS returns for Heritage Action for America list Russell Vought as vice president for grassroots outreach in 2014, 2015 and 2016. The publicly extracted 2016 return records $209,661 in organization compensation and $46,653 in other compensation; these figures refer to one fiscal year, not one payment.

April–June 2017
Selection for federal budget leadership

Heritage Action announced Vought's planned nomination as OMB deputy director in April. Heritage's 2017 annual report, printed page 10, identifies him as a former Heritage Action vice president selected for that post.

2017–2018
A second named personnel pathway

The same 2017 Heritage report names Jessica Anderson as a former Heritage Action staffer serving as an OMB associate director; Heritage's 2018 report describes her subsequent return to Heritage Action. This is an earlier administration's personnel history, not a 2025 appointment record.

2025–2026
CFPB authority under Vought

Vought became acting CFPB director in February 2025 and signed the Bureau's fiscal-year 2025 financial report in that official capacity in January 2026. His precise administrative decisions are addressed in the separate CFPB case and relevant court records.

Original documents, independent corroboration and attribution limits

Verified organization sources: Heritage's 2017 annual report identifies Vought as a former Heritage Action vice president and names Anderson as another OMB appointee. Its 2018 annual report recounts Anderson's return to Heritage Action. The Heritage Action 2017 press announcement confirms the nomination at the time.

Tax-return source: ProPublica's IRS-sourced 2014, 2015 and 2016 return extract provides title and compensation. The older direct IRS PDF download was not independently reopened in this pass; the record is classified as IRS-derived filing data, corroborated by the employer's and Heritage's contemporaneous publications.

Government authority: CFPB's original FY2025 financial report bears Vought's acting-director signature. The employment path is not an employment contract, financial transfer, or direction from Heritage to an agency. Heritage-to-Epstein person-pair status is unchanged.

Heritage Action IRS filing series, 2014–2016 ↗ Heritage 2017 annual report, pp. 10 and 31 ↗ Heritage Action, April 2017 press release ↗ Heritage 2018 annual report, staffing history ↗ CFPB FY2025 signed financial report ↗

The contemporaneous Heritage 2017 annual report also says that more than 70 Heritage staff and alumni entered the first Trump administration. That figure is a self-reported historical claim, not an audited count and not evidence of appointments in 2025.

PERSONNEL RECORD CROSSCHECK

Two named staff members on the same IRS-derived organizational return

Heritage Action for America's FY2016 IRS-derived Form 990 lists Russell Vought as vice president for grassroots outreach and Jessica Anderson as grassroots director. In that fiscal year the organization and other compensation categories were $209,661 and $46,653 for Vought, and $114,760 and $28,776 for Anderson. These are distinct annual compensation classifications, not later government payments.

Heritage's contemporaneous 2017 annual report identifies both individuals in Office of Management and Budget roles; its 2018 account documents Anderson's return to Heritage Action. Those employment records establish a dated personnel pathway but cannot demonstrate private instructions or misconduct by either person.

Original sources and evidentiary limits
  1. Heritage Action FY2016 IRS Form 990 extract. Figures are IRS-derived; an original signed PDF was not independently authenticated here.
  2. Heritage 2017 annual report, contemporaneous organizational account of Vought and Anderson entering OMB.
  3. Heritage 2018 annual report, subsequent personnel history.

Boundary: An organizational affiliation is not evidence of an unlawful act, a federal instruction channel or a Jeffrey Epstein relationship.

Government savings and contract records

04 / Independent financial source verification

What do the reported savings actually show?

The GAO audits separate government claims about potential savings from changes actually recorded in contract and grant systems, including instances where the underlying calculation could not be verified. I find the discrepancies worth investigating, but I cannot use the auditors' findings about federal recordkeeping as proof of an undisclosed Heritage command relationship with DOGE or the Department of Homeland Security.

$110.34BDOGE's reported contract, grant and lease savings, audited as a claim
96.2%Share of reported grant savings for which GAO could not verify the calculation method
3,506USAID contract entries lacking public identifying data, whose identifiers GAO had previously retained
7 documented findings

DOGE's Wall of Receipts

$110.34 billion claimed

The total was displayed for contracts, grants and leases as of July 7, 2026. The lease headline did not match the sum of the listed lease entries; the total is not an amount independently certified as saved.

GAO financial-audit report ↗

Grant calculation method unavailable

$47.32B of $49.21B

GAO could not verify DOGE's calculation method for 13,553 listed grant terminations, representing 96.2% of reported grant savings; Unverified methodology is not itself evidence that no savings occurred.

GAO Table 6 ↗

Contract status not supported by recorded termination action

2,503 contracts · $27.4B claimed

GAO found no termination action recorded in the federal procurement database for these entries. Some could have had modifications or data gaps, so a missing termination flag does not prove no other action occurred.

GAO contract analysis ↗

USAID contract identifiers were removed from public view

3,506 affected entries

GAO obtained USAID identifiers before March 2025 redactions; the public savings display later lacked those identifiers. A retained early extract is an identifiable original-record acquisition target, not a dataset already recovered here.

GAO archival custody statement ↗

Case-specific $1.76B claimed with no action taken

$1.765B reported · $0 documented saving

GAO confirmed a Defense Health Agency technology contract was not terminated or reduced. This finding concerns that selected contract only; it does not extrapolate a zero-savings result to the whole program.

GAO selected contract review ↗

DHS potential costs avoided

$10.5B maximum ceiling · $92M net deobligated

The maximum possible contract ceiling is not an audited saving; GAO documented that similar services continued under other contracting vehicles. The two amounts cover different fiscal measures and are not directly subtractable.

DHS contract audit ↗

DHS grants: a separate award cohort

362 grants · $1.002B deobligated

GAO identified 2025 grant terminations and deobligations but documented reversals and delayed mitigation work. Do not conflate this DHS grant cohort with DHS contracts, USAID awards or national net savings.

DHS grant audit ↗

Attribution boundary: These are independent federal auditing records. The documented role of Project 2025 remains its published policy proposals; a private Heritage-to-DOGE command chain has not been established.

Education OIG's ongoing interagency-transfer audit ↗ is an open source-acquisition target, not a completed finding.

USAID contracts: what GAO recovered from the redacted identifiers

The Wall of Receipts omitted public contract identifiers for 3,506 USAID entries. GAO had saved an earlier copy of the identifiers and later matched 1,864 of those entries to the Federal Procurement Data System. The rest remain unmatched by that specific method; this does not prove an invalid contract or a fraudulent termination.

1,864 USAID matches to FPDS1,642 unmatched using this route
Why the different GAO contract counts cannot be combined

DOGE posted 13,440 contract entries, some of which covered multiple contracts, for a GAO reconstructed total of 13,476. The public page omitted identifiers for 3,751 contracts across agencies. GAO later recovered and matched some pre-redaction USAID identifiers and used other methods, ultimately linking 11,620 contracts across agencies. Of the 13,476 contracts, 2,503 had no termination action recorded in FPDS when GAO examined it, although other reductions and delayed filings could exist. These are different populations.

The pre-redaction contract list remains an acquisition target; it has not been independently obtained for this Atlas.

Read GAO-26-108615 and original methodology tables ↗ · Original report PDF ↗

GAO contract reconciliation: which contracts can actually be traced?
13,440DOGE's public contract entries
13,476Contracts GAO identified after resolving multi-contract entries
11,620Contracts GAO ultimately linked to federal procurement records
1,856Contracts GAO could not link

In GAO-26-108615, only 43.2% of claimed contract-savings dollars were associated with contracts whose procurement records showed complete or partial termination. Another 2,503 contracts had no recorded termination action, representing $27.4 billion in claimed savings. GAO cautioned that procurement recording delays and other actions, such as deobligations or reducing contract value, can affect these categories. This does not establish that all such contracts were fictitious or all claimed savings were zero.

GAO independently identified 7,710 contracts associated with $16.8 billion for which DOGE's stated calculation method matched the data; 3,910 associated with $37.0 billion had other or unidentifiable calculation methods, and 1,856 associated with $7.2 billion could not be traced to contracts by the available identifiers. These three mutually exclusive contract classes sum to 13,476. Even a matching calculation is not proof that a projected future saving was ultimately realized.

GAO's accessible original report and Tables 3–4 ↗

Public records / Who appears in the documents

The people named in the public record

The searchable register draws from published Project 2025 credits, Heritage's public directory and related source records, allowing readers to identify the role attached to a name and inspect where it appeared. I do not regard inclusion as an accusation; the purpose is to make a large institutional network more transparent without suggesting that every person in a public document endorses every proposal or took part in the same government action.

05 / Personnel and documented roles

Who appears in the original records?

This searchable register combines historical credits in the 2023 Project 2025 manual with people listed on Heritage's 2026 public directory and selected 2026 publications. Role text is preserved from the source roster, and identical names across unrelated contexts are not assumed to be the same individual.

Important: The searchable register records published credits and roles. It does not describe 561 confirmed political appointees or 561 people accused of anything. Use the source link in each row to check the exact attribution.

NameDocumented inclusionSpecific role / creditPrimary source
More original records / The extended research

Keep going. The underlying work is here.

I have kept the longer audits and case supplements intact for readers who want to check the figures or follow the documents in greater detail. These files include modeled figures, funding records and unresolved questions. They do not turn a missing answer into a proven one.

Construction financing and the interest-rate swap

AUDITED FINANCIAL STATEMENTS

The construction financing was not one transaction

The Foundation’s independently audited 2025 report identifies $55,381,245 in notes payable at December 31, 2025, compared with $57,377,662 one year earlier. Subsequent-events Note 13 then records a new $5 million construction-financing facility established in January 2026 and a separate $7,331,640 interest-rate swap on an earlier note. These arrangements are not the same financial instrument.

$55.38MNotes payable at December 31, 2025; audited year-end liability balance, not newly raised money
$5MJanuary 2026 facility limit for construction; actual draws and lender identity not disclosed in this note
$7.33MNotional amount of a separate January 2026 swap linked to the earlier $25M construction note
Instrument or eventWhat the audit actually saysWhat is not established
Notes payable at 2025 year end$55,381,245 total; includes three notes and excludes a new January 2026 facilityNo evidence that the 2026 $5M was already a 2025 liability
January 2026 construction noteFacility up to $5M; 24-month draw period; interest one-month SOFR plus 1.52%; stated maturity December 1, 2039Undrawn amount, exact draw schedule, lender and funded project are not disclosed
January 2026 interest-rate swap$7,331,640 notional; 5.68% stated effective rate on part of existing $25M noteNot a $7.33M new cash loan or recipient payment
Separate existing revolving credit line$10M available; zero outstanding at both December 31, 2024 and 2025Undrawn credit cannot be added to 2025 debt as if borrowed
July 2026 real-estate saleApproximately $10M selling price, with net proceeds expected to support operationsAddress, buyer and realized gain cannot be inferred from the audited note
Original document, methodology and records still needed

Primary source: The Heritage Foundation and Affiliates, 2025 consolidated audit, Note 5 (printed pp. 17–18), Note 6 (printed p. 19), Note 11 (printed pp. 22–23), Note 12 (printed p. 23), and Note 13 (printed pp. 23–24). Open the original pages to independently check accounting treatment.

Target documents: lender and construction-note filings where publicly available, the January 2026 swap agreement, D.C. deed and land records for the July 2026 property transaction, and Heritage Action’s 2025 original return or audit when published. No lender, buyer, or improper payment is named without verified independent records.

The construction-debt sequence, related-party services, and July property sale are distinct lines of inquiry. A disclosed financing arrangement does not establish illegal conduct, personal enrichment or an Epstein relationship.

Medicaid workforce evidence

GAO MEDICAID WORKFORCE RECORDS

A Medicaid work requirement meets the actual workforce record

GAO-26-108703, originally released June 2026 and reissued with specified corrections on August 24, 2026, estimated that 13.8 million adult Medicaid enrollees performed paid work at some point during 2024. For wage earners enrolled in Medicaid, its Appendix Table 1 measured 66.1% with a full-time weekly schedule of at least 35 hours; among that wage-earning group, 47.8% worked full-time during 50–52 weeks. These are different denominators and time measures.

13.8MEstimated adults enrolled in Medicaid who worked at some point in 2024, Census-based national estimate
66.1%Share of wage-earning adult Medicaid enrollees with a 35+ hour weekly schedule; not share of all covered adults
47.8%Share of wage-earning adult Medicaid enrollees working 35+ hours weekly for 50–52 weeks in 2024

These data show a substantial employed population among Medicaid enrollees. They do not demonstrate that any given person meets the new 80-hour-per-month legal requirement or its specific exceptions. GAO’s selected-state employer tables cover 11 participating states and are not nationally generalizable; they also must not be used to name private individuals or establish workplace misconduct.

GAO cohort or statisticInterpretationBoundary
13.8 millionAdults 19–64 who reported wages and Medicaid enrollment during 2024Employment at any point in the year, not every month and not only Section 71119 adults
66.1% (95% CI 64.6–67.6)Full-time weekly hours among wage-earning Medicaid-enrolled adultsGAO’s full-time definition is 35+ weekly hours
47.8% (95% CI 46.2–49.4)Wage earners working 35+ weekly hours for 50–52 weeksCannot infer future Medicaid eligibility decisions or effects
August 24 revised reportCorrections identified for Rhode Island data in GAO tables 6 and 22Use the revised federal PDF rather than an earlier table export

Read GAO-26-108703’s original audited analysis and Table 1 (PDF page 4). The new federal community-engagement requirement generally starts January 2027 and applies to a narrower statutory group. The published GAO workforce data are not a controlled outcome evaluation of that policy.

Medicaid eligibility oversight findings

GAO OVERSIGHT FINDINGS

The verification system already had documented weaknesses

The nationwide Medicaid community-engagement requirement generally begins in January 2027. Before that requirement, federal auditors had already found weaknesses in the system used to identify and correct state Medicaid eligibility errors. The older audit is relevant implementation context, not a study of the new rule’s consequences.

2019–2025Eligibility-error records reviewed by GAO
2Recommendations to CMS, each open when checked
0Findings attributable by this report to the January 2027 federal requirement
Original audit finding: incomplete corrective plans

GAO-26-108017 found that CMS had accepted some states' Medicaid eligibility Payment Error Rate Measurement corrective action plans without all federally required information. Auditors identified caseworker actions as a prevalent root cause of errors and found that CMS did not systematically compare states' recurring eligibility errors or their proposed remedies; the corrective plans cover both mistaken approvals and mistaken denials; Neither category of eligibility error establishes fraud without additional evidence.

Oversight response and limits of causation

GAO made two recommendations; CMS agreed to systematic cross-state analysis. CMS also pointed to a May 2026 update to its corrective-plan template as a reason to close the other recommendation; GAO said a template change had not prevented incomplete plans from being accepted and kept that recommendation open. The report's stated historical scope means it cannot be presented as a measured outcome of the later community-engagement mandate, nor as proof that new implementation problems are inevitable; state-by-state rollout and 2027 eligibility outcomes must be assessed separately.

GAO-26-108017: Medicaid eligibility corrective action plans · Accessible full report · Return to the Medicaid investigation

Separate research: identity and Epstein comparator

Some readers will ask whether individuals in these policy networks overlap with separate Epstein-related research; that is a different investigation with stricter identity and source controls. This first edition does not establish or allege any new Epstein connection. The source register below is for Project 2025 and institutional accountability, not evidence of participation in sexual abuse.

A separate line of inquiry, not an accusation

This Atlas will use the established 81-person frozen IDs and the existing 98-person expansion, applying the exact 38-category screening system; Initial exact-name comparison of the two selected rosters produced no overlaps. This limited result provides no conclusion about indirect connections, organizational paths, financial relationships or unseen records.

Identity control

Do the names refer to the same person?

Aliases, professional biographies, dates and source documents must resolve identity before attaching a relationship.

Relationship control

What connection is actually documented?

Separate direct contact, company participation, joint events, financing, appointments, shared professional intermediaries and unrelated appearances in the same archive.

Evidence control

What does the record establish?

Preserve the source passage and its limitations, including contrary documents. Unreviewed is neither corroboration nor exoneration.

Original documents / Read them yourself

The documents behind this investigation

I have linked the documents wherever possible because my conclusions should be open to challenge by the same records that informed them. The sources include the original policy manual alongside federal rules, agency financial reports and independent audits, and I mark the places where a signed document, individual contract or underlying dataset has not been obtained rather than concealing those gaps.

Read the Project 2025 manual ↗Heritage financial statements ↗U.S. Government Accountability Office ↗
Open the complete source list and verification notes

07 / Reference library

Check our work in the original documents.

Heritage Foundation and Affiliates: 2025 independently audited consolidated financial statements (pp. 3–4, notes 1, 11–13)Mandate for Leadership, original Project 2025 manualHeritage announcement and chapter-by-chapter authorsHeritage annual reports and audited financialsIRS filings for Heritage Foundation, EIN 23-7327730Heritage 2026 family-policy publicationU.S. Department of Justice Epstein records portalGAO-26-108703: June 2026 Medicaid and SNAP wage earners (revised Aug 24)Ajay Suresh photograph and CC BY 4.0 license record

I link to the official records and independently published extracts behind the investigation, identifying any signed originals that I could not inspect directly so readers can judge the evidence with those limitations in view.

This first public edition contains six investigations, while the broader historical personnel review and separate Epstein comparison remain unfinished and subject to their own evidentiary requirements. A name appearing in a public source is never, by itself, grounds for an accusation.