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In a separate post, we discuss how President Trump’s Executive Order (EO) 14240 (Mar. 20, 2025) will affect federal purchasing of information technology.

EO 14240 may also change how the federal government buys billions of dollars in other “common goods and services”, a phrase that include nearly everything the Government buys from private industry. The Order defines “common goods and services” as the “common Government-wide categories defined by the “Category Management Leadership Council led by the Office of Management and Budget (OMB).” It includes construction, technical and engineering services, logistics, telecommunications, and pharmaceuticals.

Federal Actions and Impacts 1200x628

President Trump’s Executive Order (EO) 14240 (Mar. 20, 2025) provides for the General Services Administration (GSA) Administrator to assume responsibility for all Government-wide contracts for the acquisition of information technology and to develop a plan to consolidate purchasing of many other goods and services within GSA.

In this post, we discuss the impacts of EO 14240 on federal IT purchasing. We look at how EO 14240 will affect purchasing of common goods and services in a separate post.

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UPDATE:  As of January 29, 2025, the Trump Administration appears to have rescinded OMB Memo M-25-13 ordering a temporary pause on federal financial assistance activities and disbursements.

OMB Memorandum (M-25-13) advises federal agencies that they must temporarily pause all activities and disbursements of federal financial assistance that may be implicated by any of President Trump’s recent Executive Orders at 5:00 p.m. Eastern Time today, January 28, 2025.

The ongoing debt ceiling negotiations are approaching the “X Date” with little certainty of a resolution. The X Date, the date on which the U.S. Government runs out of money to pay all of its bills, is estimated to be June 1. Failing to raise the debt ceiling by that date would be unprecedented and, by most accounts, would have dire consequences for the economy.

Section 822 of the 2023 National Defense Authorization Act, Public Law No. 117-7776 (Dec. 23, 2022) provides new authority for some defense contractors and subcontractors to obtain price increases that address the impacts of inflation. The new authority is welcome relief for contractors and subcontractors holding fixed-price defense contracts, which typically do not allow a price increase due solely to inflation.

Government Seal

The Department of Defense (“DoD”) requested industry comments by April 28, 2021 to assist with the DoD’s forthcoming report identifying risks and policy recommendations regarding the supply chain for strategic and critical materials.  The Apr. 13, 2021 Federal Register notice notes “the need for resilient, diverse, and secure supply chains to ensure U.S. economic prosperity…

Have you received a Section 889 letter yet? If not, you may soon. The letters ask whether you provide or use “covered telecommunications equipment or services.” They are part of the implementation of Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (the 2019 NDAA), which has two phases. The first phase started in August 2019 but has a limited scope. The second phase—which started in August 2020—is much broader and raises a lot more questions. This article answers some of those questions and provides some tips on how to comply.

Keep in mind that Section 889 is still being implemented. Much of this analysis is based on interim rulemakings at 85 F.R. 42665 and 85 F.R. 53126. Final rules may change based on public comments.