The bill
GOOD Act
S. 252, 119th Congress.
Sponsored by
Sen. Johnson, Ron [R-WI]
ID: J000293
Follow the money
The bill
S. 252, 119th Congress.
The sponsor
Every bill has someone who introduced it. That name is where the paper trail starts.
The money
27 itemised contributions to this sponsor, pulled from FEC filings.
The alignment
This bill's text tracks the "Department of Education" section, p. 389-391 of the Mandate for Leadership.
Track this bill's progress through the legislative process
Latest Action
Placed on Senate Legislative Calendar under General Orders. Calendar No. 565.
September 13, 2026
📍 Current Status
Next: The bill will be reviewed by relevant committees who will debate, amend, and vote on it.
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5. Conference: If both chambers pass different versions, a conference committee reconciles the differences.
6. Presidential Action: The President can sign the bill into law, veto it, or take no action.
7. Became Law: If signed (or if Congress overrides a veto), the bill becomes law!
**Summary of S. 252: The GOOD Act (Guidance Out Of Darkness Act)** *Reported in Senate, 119th Congress (2025–2026)*
**1. Main Purpose & Objectives** The stated purpose of the GOOD Act is to “increase access to agency guidance documents.” In plain English: Congress noticed that federal agencies bury internal memos, blog posts, and interpretive letters in obscure corners of the internet—or don’t publish them at all—then use them to regulate by stealth. This bill aims to force agencies to publish all such “guidance documents” in one centralized, searchable online location so the public, regulated entities, and even other government employees can actually find them. The noble goal? Transparency. The likely reality? A performative gesture that ignores why agencies love opaque guidance in the first place: it lets them make policy without accountability, notice, or congressional oversight.
**2. Key Provisions & Changes to Existing Law** The bill mandates that: - Agencies must publish *every* guidance document (defined breathtakingly broadly to include memos, notices, bulletins, directives, news releases, letters, blog posts, speeches, and “no-action” letters) on the same day it’s issued. - Within 180 days of enactment, agencies must publish all currently effective guidance documents. - All such documents must be housed in a single, centralized website designated by the OMB Director within 90 days. - Agencies must link to this central repository from their own websites. - Documents exempt under FOIA (e.g., classified, privileged, or law enforcement-sensitive material) are excluded—though the bill naively assumes agencies won’t abuse this loophole to hide politically inconvenient “guidance.” - Rescinded guidance must be removed promptly.
This creates a new procedural burden where none existed before, effectively treating informal agency communications as de facto rules requiring publication—without granting them the force of law. It’s a half-measure: transparency without accountability.
**3. Affected Parties & Stakeholders** - **Federal Agencies:** Forced to track, categorize, and publish vast volumes of informal guidance—many of which were never meant for public consumption. Expect compliance to be spotty, with agencies over-classifying or under-reporting to avoid work. - **OMB Director:** Tasked with designing and maintaining the central portal—a thankless IT project likely to be underfunded, outdated, and ignored. - **Regulated Industries (e.g., finance, healthcare, energy):** Theoretically benefit from easier access to agency interpretations—but will likely drown in low-value noise while missing the few documents that actually matter. - **Public Interest Groups & Litigants:** Gain a new tool to challenge “guidance as law” arguments in court—but only if they can parse the flood of irrelevant material. - **Taxpayers:** Fund the infrastructure for a system that may improve access but won’t curb the underlying abuse of guidance to bypass the Administrative Procedure Act.
**4. Potential Impact & Implications** The GOOD Act treats a symptom (poor access to guidance) while ignoring the disease: agencies use guidance to make binding policy without rulemaking constraints because it’s faster, cheaper, and politically safer. Publishing guidance doesn’t stop agencies from treating it as law—it just makes the subterfuge more visible.
In practice: - Agencies will flood the portal with trivial or redundant material to obscure consequential guidance. - Litigation over whether guidance constitutes “binding interpretation” will increase, clogging courts. - The central site will likely become a bureaucratic ghost town—poorly maintained, rarely used, and emblematic of Congress’s fondness for symbolic reforms that solve nothing.
Ultimately, this bill is less about transparency and more about Congress pretending to fix a problem it enabled by refusing to rein in executive overreach. It’s a bandage on a bullet wound—well-intentioned, utterly inadequate, and slightly insulting to anyone who’s actually tried to navigate the federal regulatory maze.
*Word count:
Sen. Johnson, Ron [R-WI]
Congress 119 • 2024 Election Cycle
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This bill has 10 cosponsors. Below are their top campaign contributors.
ID: C001096
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26
ID: E000295
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23
ID: L000575
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22
ID: T000476
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ID: B001243
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ID: L000577
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Hub layout: Politicians in center, donors arranged by type in rings around them.
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Total contributions: $61
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This bill shows semantic similarity to the following sections of the Project 2025 policy document.AI-enhanced analysis provides detailed alignment ratings.
AI Analysis:
"The GOOD Act aligns strongly with Project 2025's emphasis on transparency and accountability in agency guidance, particularly through centralized publication and proactive disclosure of guidance documents, which supports the goal of preventing agencies from imposing binding standards via non-binding guidance."
— 357 — Department of Education NEW EXECUTIVE ORDERS THAT THE PRESIDENT SHOULD ISSUE Guidance Documents l The President should immediately reinstate and reissue Executive Order 13891: Promoting the Rule of Law Through Improved Agency Guidance Documents, 84 Fed. Reg. 55235 (Oct. 9, 2019), and Executive Order 13892: Promoting the Rule of Law Through Transparency and Fairness in Civil Administrative Enforcement and Adjudication (Oct. 15, 2019). These executive orders required all federal agencies to treat guidance documents as non-binding in law and practice and also forbade federal agencies from imposing new standards of conduct on persons outside the executive branch through guid- ance documents. They required all federal agencies to apply regulations and statutes instead of guidance documents in any enforcement action. President Biden revoked these executive orders on January 20, 2021, demonstrating that these executive orders effectively restrained the abuses of an expansive administrative state. l Require APA notice and comment. The President should issue an executive order requiring the Office for Civil Rights’ Case Processing Manual to go through APA (Administrative Procedures Act) notice and comment. l Protect the First Amendment. The President should issue an executive order requiring grant applications (SF-424 series) to contain assurances that the applicant will uphold the First Amendment in funded programs and work. l Minimize bachelor’s degree requirements. The President should issue an executive order stating that a college degree shall not be required for any federal job unless the requirements of the job specifically demand it. l Eliminate the “list of shame.” Educational institutions can claim a religious exemption with the Office for Civil Rights at the Department of Education from the strictures of Title IX. In 2016, the Obama Administration published on the Department of Education’s website a list of colleges that had applied for the exemption. This “list of shame” of faith-based colleges, as it came to be known, has since been archived on ED’s website, still publicly available. The President should issue an executive order removing the archived list and preventing such a list from being published in the future. — 358 — Mandate for Leadership: The Conservative Promise NEW AGENCY POLICIES THAT DON’T REQUIRE NEW LEGISLATION OR REGULATIONS TO ENACT Transparency of FERPA and PPRA Complaints l The Department of Education should be transparent about complaints filed on behalf of families regarding the Family Educational Rights and Privacy Act (FERPA) and the Protection of Pupil Rights Amendment (PPRA). l At the same time, the Department of Education should develop a portal and resources for parents on their rights under FERPA and PPRA. This portal should also contain an explanation of the Health Insurance Portability and Accountability Act (HIPPA) and public school procedures to demonstrate that the law does not deprive parents of their right to access any school health records. The D.C. Opportunity Scholarship Program In 2011, Congress added new requirements to the D.C. Opportunity Scholarship Program stating that participating private schools must submit to site visits by the program administrator, inform prospective students about the school’s accreditation status, mandate that teachers of core subjects have bachelor’s degrees, and require participating students to take some form of nationally norm-referenced test. Notably, the 2011 reauthorization also required, for the first time, that participating private schools be accredited or be on a path to accreditation. The 2017 reauthorization went further, requiring that each participating school supply a certificate of accreditation to the administering entity upon program entry, demonstrating that the school is fully accredited before being allowed to participate. The list of approved accreditors is entirely too small to serve the mission of the diverse schools in the nation’s capital. l Although the accreditation regulations should be removed entirely by Congress, in the meantime, the next President should issue an executive order expanding the list of allowable accreditors. Transparency Around Program Performance and DEI Influence The next President should issue a series of executive orders requiring: l An accounting of how federal programs/grants spread DEI/CRT/ gender ideology, l A review of outcomes for GEAR UP and the 21st Century grants programs,
AI Analysis:
"The GOOD Act aligns strongly with Project 2025's objective to limit the abusive use of guidance documents by requiring centralized, accessible publication, which supports transparency and prevents guidance from being used as binding law without public input."
— 592 — Mandate for Leadership: The Conservative Promise Overtime Pay Threshold. Overtime pay is one of the most challenging aspects of the Fair Labor Standards Act rules. “Nonexempt workers” (e.g., workers whose job duties fall within the law’s power or whose total pay is low enough) must be paid overtime (150 percent of the “regular rate”) for every hour over 40 in a work- week. Overtime requirements may discourage employers from offering certain fringe benefits such as reimbursement for education, childcare, or even free meals because the benefits’ value may be included in the “regular rate” that must be paid at 150 percent for all overtime hours. And because some of these fringe ben- efits may be more valuable (and often come with tax preferences that benefit the worker), the goal should be to set a threshold to ensure lower-income workers have the protections of overtime pay without discouraging employers from offering these benefits. l DOL should maintain an overtime threshold that does not punish businesses in lower-cost regions (e.g., the southeast United States). The Trump-era threshold is high enough to capture most line workers in lower-cost regions. One possibility to consider (likely requiring congressional action) would be to automatically update the thresholds every five years using the Personal Consumption Expenditures (PCE) as an inflation adjustment. This could reduce the likelihood of a future Administration attempting to make significant changes but would also impose more adjustments on businesses as those automatic increases take hold. l Congress should clarify that the “regular rate” for overtime pay is based on the salary paid rather than all benefits provided. This would enable employers to offer additional benefits to employees without fear that those benefits would dramatically increase overtime pay. l Congress should provide flexibility to employers and employees to calculate the overtime period over a longer number of weeks. Specifically, employers and employees should be able to set a two- or four- week period over which to calculate overtime. This would give workers greater flexibility to work more hours in one week and fewer hours in the next and would not require the employer to pay them more for that same total number of hours of work during the entire period. Compliance-Assistance Programming. Labor agencies are often tempted to encourage “over compliance” by companies subject to regulation by pursuing “regulation through enforcement” strategies. Rather than giving regulated enti- ties clear boundaries for what they can and cannot do under the law, the agencies — 593 — Department of Labor and Related Agencies rely on the vagueness of the law to bring enforcement activity against businesses that fail to meet an inspector or agency head’s personal standard. This is not fair to regulated parties and results in disfavored companies bearing the brunt of the agencies’ enforcement efforts even though their behavior may be within the main- stream of employer behavior. l Labor agencies should provide compliance assistance to help businesses and workers better understand the agencies’ position on their own rules and should do so in a way that makes it easier to follow those rules. This frees people to focus on their work rather than slogging through an ever-growing body of laws, rules, and guidance documents generated by the agencies. Clear and Restrictive Rules on Guidance Documents. Federal agencies not only issue regulations to fill in gaps left by legislation, but also supplement those reg- ulations with “guidance” documents that occupy a unique and often confusing area between law and “helpful advice.” Unfortunately, wielded by overzealous enforcement agents, such guidance, some of it even hidden from public view, morphs into binding law used against unsuspecting employers. Guidance can be a tricky thing and can be used for good or bad. It should be used to make compli- cated regulations easier to understand, so that businesses can do their actual jobs and focus on providing jobs to American workers and value to consumers (really, compliance assistance). But guidance is often used to create new rules overnight without following legal requirements—like giving the public an opportunity to provide valuable input. This wrongful use of guidance hurts workers and those who employ them. In October 2019, President Trump signed an executive order ending this abusive practice and created a new, fairer system for American busi- nesses and their employees. In response, DOL published its PRO Good Guidance rule,10 which expressly limits its use of guidance in enforcement actions and gives the public the opportunity to submit comments to influence the department’s deci- sions on creating, revising, and even rescinding guidance. Under this rule, agencies cannot treat guidance as legally binding and must make all guidance documents readily accessible on their searchable online databases. This rule was immediately rescinded by the Biden Administration. l DOL should reinstitute the PRO Good Guidance rule via notice and comment. l Congress should amend the Administrative Procedure Act11 to explicitly limit the use of guidance documents.
AI Analysis:
"The GOOD Act's focus on increasing transparency and accessibility of federal agency guidance aligns with Project 2025's goal of strengthening the SBA Office of Advocacy and improving regulatory oversight, particularly by making agency interpretations more visible to small businesses and oversight bodies. Both emphasize accountability, access to information, and reducing regulatory burden through better dissemination of agency guidance."
— 751 — Small Business Administration implement relevant initiatives to reach small businesses. Programs would be nonduplicative and implemented on a first-come, first-served basis. l A modern, revamped, and streamlined SBA that better utilizes current technology and platforms for operations, for reporting, and in its programs to reach, service, and engage small businesses. l An Office of Advocacy that is strengthened by a renewed mandate and additional resources to protect against overregulation along with a research agenda that includes measuring the total cost that federal regulation imposes on small businesses. Accountability and Managerial Practice. The SBA lacks accountability and managerial practices to measure the effectiveness, success, and integrity of its various programs. As a future Administration evaluates agency structure and the particulars of how the SBA is spending appropriated funds, it should immediately require actions and procedures to compel a culture of accountability and perfor- mance. Specifically: l Require performance metrics and internal procedures to safeguard taxpayer dollars and program integrity. As noted in an October 2022 IG report, failure to adopt procedures that would reliably capture data and information for various programs, coupled with significant challenges and weaknesses regarding IT investments, systems development, and security controls, presents significant risks to program integrity and increased risk of waste, fraud, and abuse.34 Addressing these shortcomings and risks should be a priority challenge and action item for the next Administration. As underscored by the Inspector General in his introduction to the report, “Pandemic response has, in many instances, magnified the challenging systemic issues in SBA’s mission-related work.”35 l Review all internal government watchdog recommendations and require that SBA management implement or address outstanding and ongoing OIG and GAO recommendations within a specified time frame (ideally within 90 days of a recommendation) and on an ongoing basis. Strengthening the Office of Advocacy. The SBA Office of Advocacy (Advo- cacy) is “an independent office” within the SBA.36 It accounts for about one one-thousandth of SBA spending and 0.75 percent of SBA personnel. Under the Regulatory Flexibility Act, both under its current authority and with suggested — 752 — Mandate for Leadership: The Conservative Promise reforms, the Office of Advocacy could be a powerful weapon against the adminis- trative state’s regulatory extremism. l Amend the RFA so that all agencies are required to provide a copy of any proposed rule (other than bona fide emergency rules) along with initial regulatory flexibility analysis to the Office of Advocacy at least 60 days before a notice of proposed rulemaking is submitted for publication in the Federal Register. The Office of Advocacy would submit comments to agencies within 30 days, and each agency would have to consider these comments, make changes in the proposed rule based on those comments, or explain in a revised regulatory flexibility analysis why it chose not to change the proposed rule. The Office of Advocacy’s pre-proposing comments would be published on the agencies’ and its own websites. RFA economic analysis should be expanded to include indirect costs along with direct costs. In addition, the next Administration should require other agencies to seek Advocacy’s input. Currently, other agencies deny Advocacy the ability to enforce their duty to consider the effect of regulations on small entities by construing their regulations as not having significant economic impact, which would otherwise serve as a trigger for Advocacy’s input. Congress should presumptively exempt small businesses from new agency rules to force agencies to seek Advocacy’s input and permit new rules to apply to small businesses only with Advocacy signoff under specified criteria. l Increase the Office of Advocacy’s budget by at least 50 percent ($4.6 million). This would allow Advocacy to hire approximately 25 attorneys, economists, and scientists and enhance its role in the regulatory process. l Explicitly direct federal agencies to comply with the RFA. This would be similar to the approach adopted by President Trump in his January and February 2017 executive orders directing agencies to relieve the cost and burden of regulation on business.37 Advocacy should organize regional roundtables, onsite small-business visits, and an online platform to hear directly from small businesses and entities as it did from June 2017 through September 2018.38 This activity produced 26 letters to federal agencies and highlighted specific regulations that need reform and how Congress had addressed the most burdensome rules through the Congressional Review Act.39
Showing 3 of 5 policy matches
Policy matches are calculated using a hybrid approach: initial candidates are found using semantic similarity between bill summaries and Project 2025 policy text, then an AI model (Llama 3.1 70B) provides detailed alignment ratings and analysis. Ratings range from 1 (minimal alignment) to 5 (very strong alignment). This analysis does not imply direct causation or intent.