The Administration for Children and Families has offices in the Hubert H. Humphrey Building, a Brutalist government office building located at the foot of Capitol Hill. Completed in 1976, it was one of the final designs of the preeminent Bauhaus-trained architect Marcel Breuer and serves as the headquarters of the U.S. Department of Health and Human Services.

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Washington often talks about reducing regulatory burdens as part of a messaging strategy. At the Administration for Children and Families (ACF), this is starting to look more like the operating model. In a February ACF fact sheet, the agency said it had rescinded 35,781 pages of sub-regulatory guidance. In less than two weeks at the end of March and beginning of April, it followed that guidance purge with a burst of cleanup rulemakings across major program offices. For an agency that touches child welfare, refugee resettlement, anti-poverty grants, domestic violence programs, and Native communities, that is a meaningful amount of movement in a short period of time.

The backdrop is the broader HHS deregulatory push announced in May of last year. In a department-wide request for information, HHS committed to a “10-to-1” policy under Executive Order 14192, which requires that for every new regulation proposed, at least ten existing regulatory actions would be rescinded. Just as important, HHS said the initiative would extend beyond formal rules to guidance documents, memoranda, policy statements, and similar directives. This last point matters because much of the modern administrative burden comes not from formal rules alone but from the layers of informal instruction that accumulate around them.

ACF’s guidance review is the clearest sign the agency understands this problem. According to the same ACF fact sheet, it took three weeks to simply catalog the agency’s active guidance. The review identified more than 4,000 documents totaling 55,776 pages, some dating all the way back to 1976. After ACF required offices to justify what was still necessary, the agency concluded that 74% of its sub-regulatory guidance could be rescinded. Eleven of thirteen offices reportedly found that more than half of their guidance was obsolete.

As Assistant Secretary Alex Adams put it, “We found there were more than 60 pages of sub-regulatory guidance for every formal page of regulation. This means that informal guidance – not regulation – constituted the dominant framework for governing ACF programs. While it generally has been assumed that sub-regulatory guidance exceeded formal regulations, this was even more slanted than expected, and led us to conclude that a comprehensive sunset and new approach was needed.”

Pages, of course, are an imperfect measure of regulatory burden. A hundred pages of narrative explanation may not be equivalent to a hundred pages of binding commands. But when an agency removes 35,781 pages of instructions that grantees were expected to navigate, the economic meaning is still plain. It means lower search costs, fewer conflicting requirements, and a smaller universe of quasi-rules that can shape behavior without ever going through full notice-and-comment rulemaking. In a Fox News report on the cleanup, Adams dubbed this activity “regulatory dark matter,” while the organization Social Current emphasized the practical benefit to nonprofits and grantees of knowing what guidance is actually active.

ACF’s transparency reforms are just as important. ACF said rescinded documents would remain public but archived, while active guidance would be centralized on the HHS Guidance Portal. The portal currently lists 4,742 guidance documents department-wide. It also states that HHS may not cite, use, or rely on guidance that is not posted there, except to establish historical facts. Thus, guidance reform is about more than deleting old memos. It is about changing the default so that unposted instructions cannot quietly function as enforceable law. That is a meaningful institutional shift.

ACF next moved from guidance cleanup to formal regulatory housekeeping. Between March 27 and April 8, the agency issued separate rule actions for Native American programs, refugee resettlement, repatriation, runaway and homeless youth, family violence services, and community services. Across these actions, the rationale for the updates was consistent. If a provision merely repeats statute, belongs in a separate notice of funding opportunity, or governs a dead program, it should not continue taking up space in the Code of Federal Regulations.

Adams frames the broader effort in structural terms. “ACF is approaching regulatory burden as a three-legged stool – eliminating unnecessary regulations, sub-regulatory guidance, and paperwork burden. We have already eliminated 74% of sub-regulatory guidance, and we are on pace to eliminate 30% of regulations. Paperwork burden is being tackled in renewal of PRA packages, and we are streamlining unnecessary collections that are unrelated to oversight of use of funds. We are making major progress on all three legs.”

Some of the cleanups are especially revealing. In a direct final rule from the Office of Refugee Resettlement, ACF moved to remove the State Legalization Impact Assistance Grants regulation in its entirety. Congress appropriated $4 billion for SLIAG beginning in fiscal year 1988, states could obligate funds through the mid-1990s, and Congress repealed the program in 1998. Yet the rule remained on the books. ACF notes that the program has sat dormant without appropriations for three decades and that removing its regulation will spare grantees the burden of navigating rules that are inactive.

The repatriation proposal tells a similar story. ACF proposes to repeal provisions that duplicate statutory definitions already found in statute and to remove an outdated payment approach that predates more recent government-wide grant management rules. This is common sense code maintenance. If a rule adds no real value or is obsolete, leaving it in place increases noise, not clarity.

The Native American Programs proposal is notable for a different reason. Here the underlying mission is very much alive. The Administration for Native Americans, which is an office within ACF, said it awarded $50.7 million in fiscal year 2025. But the agency is still proposing to strip away provisions that duplicate statute, embed notice of funding opportunity-style instructions in regulation, or govern the now-unfunded Native Hawaiian Revolving Loan Fund, whose appropriations ended in FY2021. ACF is therefore separating current program administration from regulatory sediment left behind by prior funding cycles.

The same pattern shows up in other human services programs. The Runaway and Homeless Youth proposal removes provisions that either duplicate statute or merely point applicants back to the notice of funding opportunity for key requirements. The Family Violence proposal likewise targets provisions that restate grant requirements better handled in statute or in grant documents. And the Community Services proposal reaches some of the oldest clutter of all, including an appendix that still referenced reporting on PC diskettes using Lotus 1-2-3, an Assets for Independence program last funded in 2016, and an Emergency Community Services Homeless Grant Program that ceased operating in 1999.

This is what a zero-based approach to regulation looks like in practice. Old guidance and old rules are no longer presumed necessary just because they exist. The zero-based framing is not accidental. ACF chief Adams previously led Idaho’s zero-based regulation initiative before coming to Washington. He understands a lesson economists have long understood. Regulatory accumulation is easy; but subtraction requires a different set of institutions and incentives.

Adams emphasizes the cultural dimension of making these changes stick. “Perhaps the most significant effort needed to maintain is cultural. We are resetting the baseline of regulations by eliminating those that are unnecessary. Staff is now discussing regulations and guidance documents as a scarce resource rather than a default response. Further, we are looking at staggered sunsets on new guidance documents.”

There is still more to do. ACF has reduced page counts, document counts, and a running list of obsolete rules. The next frontier may be a robust public accounting of paperwork hours saved, compliance costs avoided, and administrative dollars freed for service delivery. Adams indicates that work is already underway. “We are working with groups to estimate the economic impact of eliminating regulations and sub-regulations.” Compiling those metrics could be the next chapter of this story. If ACF follows through, it may offer one of the clearest federal examples in years of how to cut red tape without losing sight of program administration. That is the kind of deregulation worth taking seriously.