New DoD memo outlines review process for IT consulting contracts
“The memo provides a means for DoD leaders to more closely scrutinize our requirements for the covered contracts listed in the memo,” John Tenaglia said.
The Defense Department’s new memo expands on how contracts for IT consulting, management services and advisory support will be reviewed, establishing a formal approval process in line with Defense Secretary Pete Hegseth’s recent directive.
Effective immediately, DoD components must seek approval from the Department of Government Efficiency (DOGE) before awarding most new unclassified contracts or task orders that fall under the categories of IT consulting, management or advisory services.
The policy applies to FAR-based IT and management services contracts over $10 million and advisory and assistance services contracts over $1 million.
All submissions must include information such as deliverables, the total potential cost of the contract, estimated initial obligation, a cost-benefit analysis, evidence that alternatives were evaluated and justification that the work cannot be done in-house or purchased from a direct service provider.
DoD components must upload all supporting documents to go.mil/dogecontractreview — if DOGE does not respond within three business days, the submission should be treated as “No comment” and the procurement is allowed to proceed as normal.
Should DOGE find problems with a contract submission, they will address concerns directly with the requirements owner or escalate it up the chain of command.
Excluded from the review process are contracts in direct support of defense weapon system programs and advisory and assistance services contracts for systems engineering and technical assistance in support of systems architecture, systems engineering, acquisition program management or sustainment services supporting major defense acquisition programs.
“Requirements may not be split into multiple efforts to stay under the dollar threshold limit. My staff will monitor compliance with this approval process by conducting intermittent reviews. Any awards identified as noncompliant will be subject to termination,” Michael Duffey, the Pentagon’s acquisition chief, who is responsible for monitoring compliance with Hegseth’s recent initiative, wrote in the June 23 memo.
The memo also broadens DOGE’s review authority beyond IT and assistance services contracts — any unclassified FAR‑based contract requirements packages funded under Budget Object Class Codes 23.3, “Communications, Utilities, and Miscellaneous Charges,” or 25.1, “Advisory and Assistance Services,” or associated with Product Service Codes (PSCs) beginning with “D” or “R” must be reviewed by the DOGE team before being submitted to a DoD contracting agency or outside agency like the General Services Administration.
The procurement is allowed to proceed as normal if DOGE doesn’t respond within two business days.
The memo comes after Hegseth released a series of directives aimed at reducing reliance on outside firms and increasing its in-house capabilities.
The updated memo extended the review period to 72 hours as opposed to the 48 hours in the initial directive.
John Tenaglia, the principal director for defense pricing, contracting and acquisition policy told Federal News Network the new memo “provides a means for DoD leaders to more closely scrutinize our requirements for the covered contracts listed in the memo.”
“We are trying to reexamine the requirements and those acquisitions that are in process before they go to industry. This is about validating our internal requirements,” Tenaglia said. “Now the military services and defense agencies have the guidance to put these reviews into practice.”
Stan Soloway, president and CEO of Celero Strategies and federal acquisition expert, said it is unlikely that Hegsteth’s initiative to increase insourcing and improve financial efficiency through these measures will have a meaningful positive impact.
“It’s rarely the case that added layers of compliance drive better outcomes,” Soloway told Federal News Network.
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