Observers of the Trump administration’s OMB behavior are of two minds about this episode: some believe he is simply an impetuous disruptor who speaks before having fully considered the effect of his words; others believe he does anticipate reactions before speaking, and that much of his rhetoric is best understood as an effort to test the waters before proceeding to act further. Both his choice of words and his personal delivery of those words leave it unclear which of these interpretations may be the more correct.

Another analysis is that he may be deliberately laying the groundwork for enlarging the so-called Overton Window, believing that his election was a mandate to reassess the size and spending habits of the US central government. In light of the general confusion over the spending freeze incident, Douglas Holtz-Eakin of American Action Forum and former director of the Congressional Budget Office, attempted to rule out what these events were not:

Any major administration decision, such as this OMB memo from an acting director, should receive advance guidance on administrative policy. This memo apparently did not. The Congressional Budget and Impoundment Control Act of 1974 allows the president to pause spending for 45 days. This is called a “recission,” requiring a special presidential message to Congress. But this event was not a recission or impoundment.

A “deferral” process allows temporary suspensions of funds, also requiring a message to Congress, which can then agree or disagree within 45 days. But this event was not a deferral.

Holtz-Eakins contends that the Trump administration was “...picking a fight over the impoundment Control Act, which it believes is unconstitutional...counting on someone suing over the delay of funds, which will allow the courts to determine the constitutionality (or not) of President Trump’s unilateral action.”