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Executive Order Formally Establishes U.S. DOGE Service with IT Modernization Initiative

Client Alert | 1 min read | 01.24.25

Among the flurry of executive actions taken during his first day in office, President Trump formally established the U.S. Department of Government Efficiency Service (DOGE) via executive order (EO) on January 20, 2025, reconstituting the formerly named U.S. Digital Service that was created in 2014 by President Obama within the Office of Management and Budget. 

Deviating from initial announcements that DOGE would operate as an external advisory body staffed by volunteers, the newly created DOGE has been designated as a “temporary organization” within the Executive Office of the President, scheduled to sunset on July 4, 2026, with an Administrator reporting directly into the White House.  Within 30 days, each federal agency is also directed to establish a “DOGE Team” with at least four employees to carry out the administration’s DOGE agenda—one team lead, one engineer, one human resources specialist, and one attorney—who will receive “prompt and full access” to all unclassified agency records, software, and IT systems.

The EO notably avoids reference to any government-wide cost-cutting measures, but rather focuses DOGE’s mandate on a Software Modernization Initiative that seeks to improve the quality and efficiency of government-wide software and IT systems, and to promote the interoperability between agency networks, ensure data integrity, and facilitate responsible data collection and synchronization.  Given the embedding of DOGE officials within each agency and the unfettered access they will have to IT and spending data, however, we anticipate ample opportunity for DOGE to identify and make cost saving recommendations to administration officials and lawmakers.  In the meantime, government contractors supporting federal IT systems and networks should brace for the establishment of formal DOGE Teams at each agency, and an enhanced push toward the modernization of information technology and infrastructure.

Insights

Client Alert | 3 min read | 03.03.25

HHS Suggests It Will Provide Less Notice and Opportunity for Comment on Grant and Contract Rules

On February 28, the Department of Health and Human Services (HHS) announced that it was rescinding the Richardson Waiver, a policy in place since 1971 which said HHS would provide notice of proposed rulemaking in certain cases where it was not otherwise required to do so by law. This announcement signals a policy shift for the agency and suggests that where permitted by law, HHS will generally now issue rules relating to “agency management or personnel or to public property, loans, grants, benefits, or contracts” without providing notice and comment to stakeholders, and may otherwise find good cause to forego notice and comment procedures....