On June 23, 2025, the DoD issued a memorandum, "Implementation of Department of Government Efficiency Cost Efficiency Initiative," to establish a new DOGE approval process for unclassified IT consulting and management services (ITC&MS) contracts or task orders (TOs), and advisory and assistance services (A&AS) contracts or TOs. The memorandum establishes a formal approval process, which directs DOGE to review and provide input for certain contract requirement packages included in Defense Secretary Pete Hegseth's May 27, 2025 directive, "Implementation of Executive Order 14222 – Department of Government Efficiency Cost Efficiency Initiative" ("Contract Guidance").
Specifically, FAR-based ITC&MS contracts over $10 million and A&AS contracts over $1 million, as well as task orders, must be submitted for approval by DOGE. The DoD components must submit each contract for review with supporting artifacts and a template titled "Contract Approval Data Capture Elements." DOGE will either respond to the submission and provide written evidence that the requiring activity has either incorporated or dispositioned DOGE input, or if no response is provided by close of the two full business days following submission of the request for approval, the submission should be treated as "no comment" and the procurement may proceed as normal. The memorandum includes the following example to clarify the timing requirements: "if a component submits the required information at any time on Tuesday, after receiving no response from the DoD DOGE team, the component may proceed with forwarding their requirements package to the contracting activity after close of business on Thursday." Requirement packages accepted prior to the issuance of the memorandum must follow the same written evidence and timing requirements before a new solicitation or contract/order is issued. If DOGE finds problems with a contract submission, then the DOGE team will address the concerns directly with the requirements owner or escalate the concern up the chain of command. The DoD will also conduct intermittent reviews to monitor compliance with the approval process, and any noncompliant awards will be subject to termination.
The following contracts are excluded from this new approval process: (i) ITC&MS contracts with direct service providers (i.e., not intermediaries, consultants, or integrators); (ii) ITC&MS contracts in direct support of defense weapon system programs and directly associated program sustainment activities; and (iii) A&AS contracts for systems engineering and technical assistance, in support of systems architecture, systems engineering, acquisition program management, or sustainment services when in support of major defense acquisition programs.
In addition, the memorandum implements the Contract Guidance for DOGE's review of covered unclassified contract requirement packages expected to result in FAR-based contracts/orders or order modifications that use funding identified with Budget Object Class Codes (OCCs) 23.3, "Communications, Utilities, and Miscellaneous Charges," or 25.1, "Advisory and Assistance Services," or any other OCCs where the requirements package is to procure IT services (Product Services Codes (PSCs) beginning with "D") or Professional Support Services (PSCs beginning with "R"). This includes contracts or orders where the contracting activity is actively executing pre-award activities. The DoD DOGE team is not required to review these types of contracts for support emergency/contingency operations, among other exceptions.
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