President Trump Changes National Security Council to Align with New Priorities
On January 20, 2025, President Trump signed the National Security Presidential Memorandum (NSPM-1), which lays out the framework for how the National Security Council (NSC) will be organized under his administration.1 The Trump NSC framework is different from Biden’s, which was articulated in NSM-2, in some ways.2
Key Takeaways:
- In a change from Biden administration processes, NSPM-1 merges the Homeland Security Council (HSC) and the NSC on certain agreed-to topics, providing more discretion about who can or cannot attend meetings, and a more structured process for decision-making.
- The framework set forth in NSPM-1 should allow for faster policy decision-making, which may result in the more frequent issuance of regulations to implement and enact policy determinations. National Security Advisor (NSA) Mike Waltz and Homeland Security Advisor (HSA) and White House Deputy Chief of Staff for Policy Stephen Miller will likely push their respective policy formulation processes to result in actionable policy options and will expect relevant principals attending NSC staff-led meetings (including certain staff representing executive branch agencies at the NSC) to be well prepared.
- We expect NSA Waltz and HSA Miller, as well as White House Chief of Staff Susie Wiles, to act as gatekeepers to the President under this new framework, with the intent of administrating an orderly system to resolve disputes amongst Secretaries about key policy issues.
The Merging of Homeland Security Policy with Traditional National Security Policy Processes through what is called ‘Staff Fusion’
The Trump administration has combined the NSC process and brought back the HSC process under NSPM-1. NSPM-1 states, “[t]he NSC shall convene as the HSC on topics agreed to in advance by the Assistant to the President for National Security Affairs (National Security Advisor) and the Assistant to the President for Homeland Security (Homeland Security Advisor).” The HSC traditionally focuses on issues such as counterterrorism, immigration and cybersecurity threats.
During the Biden administration, however, National Security Advisor Jake Sullivan’s NSC played a prominent role in all national security and foreign policy issues. The only other difference between the NSC and an HSC is that the Secretary of Homeland Security and the HSA are expected to attend the President-chaired HSC. Biden’s HSC was chaired by HSA Elizabeth Sherwood-Randall, whereas border security and immigration hardliner Stephen Miller will serve as Trump’s HSA. However, like Trump’s NSPM-1, Biden’s NSM-2 stated that when homeland security issues are in the agenda for Deputy Committee (DC) or Principal Committee (PC) meetings, the HSA would be the chairperson. Though it may be a distinction without a difference, by explicitly including the HSC in the NSPM-1 with Stephen Miller as the HSA, Trump is signaling that policies on immigration and border security policy will be prioritized and given the same national security urgency as other traditional national security matters.
More Discretion to the NSA and HSA on who can Attend Policy Meetings
The Trump administration’s core voting members of the POTUS-chaired NSC are the Department heads listed in Section 101(c)(1) of the Act (50 U.S.C. 3021(c)(1). These include the President, Vice President, the Secretaries of State, the Treasury, Defense and Energy, and the Director of the Office of Pandemic Preparedness and Response Policy. The Trump NSC also includes the Attorney General, the Secretary of the Interior, the White House Chief of Staff and the National Security Advisor. Also listed are non-voting leads of the Central Intelligence Agency (CIA), Office of the Director of National Intelligence (ODNI), the Chairman of the Joint Chief of Staff, as well as White House counsel and White House policy principals. Though other Department heads may be invited to a meeting, the National Security Advisor ultimately maintains the authority to “determine the attendee list.”
The HSA retains the same authority for POTUS-chaired HSCs. Meetings of lower decision-making committees, such as PCs and DCs, will follow the same organization. This is a departure from the Biden administration’s NSC, which listed more Cabinet leads in NSM-2, signaling that he preferred more voices at the table. For example, the Secretary of Commerce was listed in NSM-2, whereas in Trump’s NSPM-1, the Secretary of Commerce is not mentioned, though Waltz would likely invite Commerce to participate in NSC-led meetings on export controls. This indicates that the Trump NSC may seek to be leaner, the staff that supports the NSC may be smaller, and decisions and deliberations will be closely held. A leaner NSC staff means that more policy formulation will either come down from the President or from the agencies to the NSC staff rather than formulated by NSC staff.
Structured Policy Decision Process with Clear Rules for the Escalation of Decisions
The Trump administration’s NSC will have strict rules by which policy disputes from Principal Committee meetings should be escalated to the NSC. If the DC comes to a policy resolution with which a participant disagrees, that participating agency will have to formally escalate the decision, in writing, through the Executive Secretary and the Principal Deputy National Security Advisor/Deputy HSA within three business days to the White House Chief of Staff or the White House Chief of Staff for Policy for a decision. There is a similar process when there is a dispute at a PC meeting. The Biden administration did not have a formal dispute mechanism and decisions were often escalated by the NSA or at the request of another agency, even if there was agreement at the lower levels. This made policy decision making at times slow and cumbersome.
Through the mechanism set forth in NSPM-1, the Trump administration NSC staff are seeking to introduce more rigor into the escalation process and ensure decisions are made during DCs and PCs as opposed to during “discussion meetings.” This new process also indicates recommendations at Principal Coordination Committee (PCC) meetings (formerly called Interagency Policy Committee (IPC) meetings) will be given more weight than in the Biden administration given that decision making will be prioritized at the DC and PC levels.
Why NSPM-1 Matters to Clients
Stakeholders should be sensitive to how their concerns may bridge both HSC and NSC policy equites to ensure that they are engaging the White House at appropriate levels. In addition, stakeholders should enhance their engagement at the Deputy Assistant Secretary- and Assistant Secretary-level at relevant executive branch agencies; and request inclusion of the stakeholder’s issues in the briefing papers that inform senior agency staff decision-making. It will be critical that engagement at the Assistant Secretary and Deputy Secretary levels are prioritized because policy decisions may be made at the Assistant Secretary and Deputy Secretary levels more frequently.
1 Organization of the National Security Council and Subcommittees – The White House.
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