The Claim

Directed all federal agencies to protect religious expression in the workplace.

The Claim, Unpacked

What is literally being asserted?

The administration issued a directive to all federal agencies requiring them to protect religious expression by federal employees in the workplace.

What is being implied but not asserted?

The implication is that religious expression was previously unprotected or suppressed in federal workplaces, and that this directive represents a new, distinct policy achievement. The framing suggests federal employees were forbidden from expressing their faith at work before this action.

What is conspicuously absent?

That religious expression in the federal workplace has been explicitly protected since at least 1997 under Clinton-era guidelines, reinforced by Title VII of the Civil Rights Act of 1964, and further strengthened by the Supreme Court’s unanimous 2023 decision in Groff v. DeJoy. Also absent is any acknowledgment that item 239 on this same list — “Signed an executive order protecting religious freedoms” — already covers the executive orders that generated this directive. This is the implementation memo repackaged as a separate achievement.

Padding Analysis: Same Executive Order Chain, Different Line Item

Item 239 claims credit for “signed an executive order protecting religious freedoms,” which refers to the administration’s chain of religious liberty executive orders: EO 14202 (“Eradicating Anti-Christian Bias,” February 6, 2025), EO 14205 (White House Faith Office, February 7, 2025), and EO 14291 (“Establishment of the Religious Liberty Commission,” May 1, 2025). Item 247 claims credit for “directed all federal agencies to protect religious expression in the workplace,” which refers to the OPM memorandum of July 28, 2025, titled “Protecting Religious Expression in the Federal Workplace” — a document that explicitly states it implements EO 14291 and the related executive orders. ¹

The OPM memo is the implementation vehicle for the executive orders claimed in item 239. Signing the executive order and then issuing implementing guidance are sequential steps in a single policy action, not two independent achievements. This is analogous to claiming credit for both “signed a law” and “told agencies to follow that law.”

Evidence Assessment

Established Facts

The OPM memorandum “Protecting Religious Expression in the Federal Workplace” was issued on July 28, 2025, by OPM Director Scott Kupor. The memo directed agency heads to “robustly protect and enforce each Federal employee’s right to engage in religious expression in the Federal workplace.” It cites EO 14291, the First Amendment, Title VII, Groff v. DeJoy (2023), and Kennedy v. Bremerton School District (2022) as legal authorities. ²

The OPM memo explicitly implements the executive orders claimed in item 239. The memo states it aligns with President Trump’s EO 14291 (Religious Liberty Commission), which “directs federal agencies to vigorously enforce protections for religious expression under federal law.” It is an administrative guidance document flowing directly from those executive orders. ³

Title VII of the Civil Rights Act of 1964 already prohibited religious discrimination in employment and required reasonable accommodation. Federal employees have had statutory protection for religious expression for six decades. The Supreme Court’s unanimous 2023 decision in Groff v. DeJoy significantly strengthened these protections by raising the “undue hardship” standard from the previous “de minimis cost” test to requiring employers to show that accommodation imposes a “substantial” burden “in the overall context” of their operations. ⁴

President Clinton issued comprehensive guidelines on religious expression in the federal workplace in 1997. These guidelines established that “departments must permit personal religious expression by federal employees to the greatest extent possible” and prohibited discrimination or harassment based on religion. The 2025 OPM memo covers substantially the same ground with similar language. ⁵

Individual agencies subsequently issued their own implementing guidance repeating the OPM memo’s content. For example, the USDA issued its own guidance on November 20, 2025, which it acknowledged was following the OPM memorandum and aligning with EO 14291 — further confirming the chain of implementation from a single policy decision. ⁶

Strong Inferences

The OPM memo’s most significant expansion beyond existing law is its permissive stance on proselytizing. The memo states that a federal employee “may engage another in polite discussion of why his faith is correct and why the non-adherent should re-think his religious beliefs,” with cessation required only if the recipient requests it. Previous Labor Department guidance required employees to cease proselytizing “with respect to any individual who indicates that the communications are unwelcome.” The shift from “unwelcome” (objective) to “requests to stop” (requiring affirmative action by the uncomfortable party) is substantive, though it flows from the executive orders already claimed in item 239. ⁷

The expanded religious expression framework creates tension with LGBTQ+ workplace protections that the administration simultaneously weakened. Williams Institute surveys found that over half of LGBTQ+ employees who experienced workplace discrimination reported it was religiously motivated, with over a third told that God “hates gay people” or “only made two genders.” The OPM memo arrived months after the administration revoked non-discrimination protections for LGBTQ federal employees, creating an asymmetric framework: expanded protections for religious expression alongside reduced protections for those most likely to be targeted by it. ⁸

What the Evidence Shows

The factual core here is real but duplicative: the administration did issue an OPM memorandum directing agencies to protect religious expression in the workplace. But this memo is the implementation step for the executive orders already claimed in item 239. Claiming both the executive order and the guidance memo that implements it as separate achievements is textbook list-padding — counting the same policy action twice by splitting it into “we decided to do it” and “we told people to do it.”

The substance of the OPM memo is itself less novel than it appears. Religious expression in the federal workplace has been protected by Title VII since 1964, by comprehensive Clinton-era guidelines since 1997, and by a strengthened Supreme Court standard since Groff v. DeJoy in 2023. The memo’s primary departure from existing guidance — a more permissive stance on workplace proselytizing — is a meaningful policy shift, but it is one provision within one implementation document, not a separate presidential achievement.

The broader context reveals a selective application of “expression” protections. The same administration that issued expansive guidance permitting religious proselytizing in federal workplaces banned pride flags, restricted transgender employees’ bathroom access, and revoked LGBTQ non-discrimination protections. The resulting framework protects one category of expression while restricting another, and the groups whose expression is restricted are disproportionately the targets of the expression that is newly expanded. Multiple lawsuits from LGBTQ+ federal employees challenging this asymmetry were pending as of early 2026.

The Bottom Line

This item is padding of item 239. The OPM memorandum directing agencies to protect religious expression is the implementing guidance for the religious liberty executive orders already claimed eight items earlier on the same list. It is one step in a single policy chain, not an independent achievement. The administration did direct agencies to protect religious expression in the workplace — because that is what happens when you sign executive orders: agencies issue implementing guidance. Listing both the order and its implementation doubles the count while describing one action.

Footnotes

1. White House, “Establishment of the Religious Liberty Commission,” May 1, 2025; OPM, “Protecting Religious Expression in the Federal Workplace,” July 28, 2025. ↩

2. OPM Memorandum CPM 2025-11, “Protecting Religious Expression in the Federal Workplace,” July 28, 2025. ↩

3. USDA Press Release, “USDA Issues Guidance to Protect Religious Expression in the Federal Workplace,” November 20, 2025 (confirming OPM memo implements EO 14291). ↩

4. Groff v. DeJoy, 600 U.S. 447 (2023); Congressional Research Service, “Groff v. DeJoy: Supreme Court Clarifies Employment Protections for Religious Workers,” LSB10999. ↩

5. Clinton White House, “Guidelines on Religious Exercise in the Federal Workplace,” August 14, 1997. ↩

6. USDA, “USDA Issues Guidance to Protect Religious Expression in the Federal Workplace,” November 20, 2025. ↩

7. Government Executive, “Trump Administration Reminds Federal Employees They Can Proselytize in the Office,” July 28, 2025; McAfee & Taft, “Will Expanded Freedom of Religious Expression Lead to Increased Tension in the Workplace?” ↩

8. The Advocate, “How the Trump Administration Is Greenlighting Discrimination Against LGBTQ+ Federal Employees,” August 1, 2025; 19th News, “A Pride Flag, a Bathroom Ban, a Job Change: LGBTQ+ Federal Workers Challenge Trump in Court,” February 2026. ↩