New Trump DOGE Implementation Order Sustains Contracting Reviews and Overhauls

Yesterday, President Trump issued an Executive Order (EO), Implementing the President’s “Department of Government Efficiency” Cost Efficiency Initiative. The new EO puts additional structure and detail to the president’s January 20 EO, Establishing and Implementing the President’s “Department of Government Efficiency” (DOGE).

The stated purpose of the new EO is to transform federal spending on contracts, grants, and loans to ensure transparency and accountability, with several reporting provisions to be made publicly available. Throughout the directive, agency heads are to promote government efficiency and Trump Administration policies. Agency leaders are to work with their agency’s DOGE Team Lead and others as they implement these provisions.

Wide-Ranging Exclusions

While the EO applies to discretionary spending through federal contracts, grants, loans, and related instruments, the EO excludes “direct assistance to individuals; expenditures related to immigration enforcement, law enforcement, the military, public safety, and the intelligence community; and other critical, acute, or emergency spending, as determined by the relevant Agency Head.”

Agency heads are also permitted to exempt in writing “any other covered grant or contract, agency component, or real property … from all or part of this order.” Classified information or classified information systems are also excluded from this EO.

Relevant Contracting Provisions

The latest EO has several noteworthy elements of relevance to federal contractors.

• Immediate Review of Existing Contracts and Grants – Each agency has 30 days to review all existing contracts and grants and terminate or modify/renegotiate them to reduce spending or reallocate funds to promote efficiency and advance Trump Administration policies. Agencies are to prioritize the review of contracts and grants to educational institutions and foreign entities to identify any waste, fraud, and abuse.
• Contracting Policies and Process Review – Agencies have 30 days to conduct a comprehensive review their contracting policies, procedures, and personnel. During this time, agencies may not appoint new contracting officers without agency head approval. 
• Non-Critical Agency Credit Card “Freeze” – For the next 30 days, all credit cards held by agency employees “shall be treated as frozen,” except for charges related to “disaster relief or natural disaster response benefits or operations or other critical services … [or] such additional individualized or categorical exceptions as the Agency Head… deems appropriate.”
• New Contract and Grant Approval Policies and Reporting – Following the 30-day contract and grant review above, and prior to entering into any new contracts, each agency head is to issue guidance on signing new contracts or modifying existing contracts to promote government efficiency and Trump Administration policies. Exceptions to the no-new-contracts provision may be approved on a case-by-case basis. Each agency DOGE Team Lead is to provide the DOGE Administrator with a monthly report on contracting activities, including all payment justifications once that element is established.
• Non-Essential Travel Justification System and Reporting – Each agency is directed to build a system that centrally records approvals for federally funded travel for conferences and other non-essential purposes. Once built, all related federally funded travel will require the travel-approving official to submit a brief, written justification for the travel within the system. Each DOGE Team Lead will report monthly to the DOGE Administrator with a report listing each agency’s justifications for non-essential travel. Further, these travel justifications will be posted publicly unless prohibited by law or granted an exemption by the Agency Head.

Agency Real Property Provisions

The EO directs federal agencies to take the several actions that will impact the disposition of the properties they own, lease or administer.

• Real Property Report – Within 7 days each agency shall confirm to the General Services Administration (GSA) that the agency has updated the Federal Real Property Profile Management System (FRPP MS) with a complete and accurate inventory of real property that the agency administers.
• Real Property Leases – Within 30 days each agency is to identify all termination rights they have under existing leases of government-owned real property and determine whether to exercise such rights.
• Real Property Disposition – Within 60 days the GSA is to submit a plan to the Office of Management and Budget (OMB) for the disposition of government-owned real property which they deem as no longer needed.

Contractor Implications

This EO provides some much-anticipated detail into the evolving DOGE effort and its operational infrastructure. Hopefully, additional details will continue to emerge in the coming days and weeks as each agency seeks to implement this directive.

Clearly, the agency reviews of their contracts, grants and other funding activities will sustain ongoing concerns among those entities who have come to rely on these income streams for their businesses. So far, some of these disruptions have been more impactful to certain areas over others, e.g., foreign assistance, etc. However, ongoing agency efforts to pursue savings through legal contract cancellations and renegotiations will sustain a significant measure of uncertainty within the federal contracting sector. The current EO’s exclusion of huge segments of the federal landscape – defense, intelligence, law enforcement, etc. – means that the impacts of this EO’s activities will be felt disproportionately, at least for now.

The EO’s provisions directing agencies to build supporting IT systems could provide some “bright spots” in an otherwise unsettled picture. While most agencies already have, or have access to, existing systems to execute on federal payments, some modification or modernization of existing systems may be needed to comply with this EO.

Companies will not want to ride the DOGE wave alone. Perhaps now more than ever, it is crucial to have a key industry partner to stay attuned to what is happening and to the potential impacts to this market, and to your business. GovWin’s First 100 Days Resource Center will help you to stay aware of these immerging impacts and opportunities.