Trump Administration to Consolidate Certain Domestic Federal Procurements into GSA
The Trump Administration on March 20, 2025, issued an executive order titled "Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement" (the EO), which will result in a major change in the landscape of federal procurement by making the General Services Administration (GSA) primarily responsible for domestic federal procurement with respect to common goods and services. This EO builds on actions the Trump Administration has taken to date in overhauling the federal procurement system, which includes GSA coordinating "the termination or economization of over 6,000 contracts across the federal government" since Jan. 20, 2025.1 Overall, the EO represents a shift in the use of Government-Wide Acquisition Contracts (GWACs), with potential benefits and challenges. By making GSA responsible for managing the procurement of common goods and services, the federal government aims to optimize its spending and improve service delivery, though the transition will require careful management to address any arising issues and transition risks.
The GSA was established in 1949 through the Federal Property and Administrative Services Act to provide "an economical and efficient system" for the core procurement services for agencies. 40 U.S.C. 101. In this role, GSA has managed the Federal Supply Schedules (FSS) Program and developed other GWACs, such as the OASIS, Alliant, VETS and 8(a) STARS vehicles. Over the years, other agencies have stood up their own GWACs, such as such as NASA's Solutions for Enterprise-Wide Procurement (SEWP) vehicle and the Chief Information Officer – Solutions and Partners (CIO-SP) vehicle administered by the National Institutes of Health Information Technology Assessment and Acquisition Center (NITAAC).2 Some of these non-GSA GWACs have eroded the dollars spent under GSA's GWACs by providing procedures that agencies and contractors have found more flexible and easier to use.
This EO represents a major win for GSA, as NASA, NITAAC and other agencies that have established GWACs for common goods and services will presumably be directed to discontinue their vehicles. However, it remains to be seen if agencies will enjoy working exclusively through GSA-managed GWAC Indefinite Delivery, Indefinite Quantity (IDIQ) contracts, given the innovations that have been driven by other agencies over the years. It is understood that competition from other agencies' GWACs is what drove reforms in GSA's FSS program such as Transactional Data Reporting and the new Order Level Materials CLIN.
We summarize key points of the EO below.
Consolidating of Category Management Procurement Functions at GSA
The EO requires that the "domestic" procurement of "common goods and services" be centralized within the GSA, which is tasked with conducting these procurement activities for all federal agencies. This centralization aims to streamline procurement processes and reduce redundancy.
Notably, the EO defines "common goods and services" to mean "the common Government-wide categories defined by the Category Management Leadership Council3 led by the Office of Management and Budget (OMB)." As such, the scope of this EO is limited to the categories identified by OMB. OMB's current category management initiative focuses on 10 categories of common procurement of commercial products and services for government-wide procurement, which are 1) Information Technology, 2) Professional Services, 3) Security and Protection, 4) Facilities and Construction, 5) Industrial Products and Services, 6) Office Management, 7) Transportation and Logistics, 8) Travel, 9) Human Capital and 10) Medical.
Look for those 10 categories to be consolidated in the GSA – which will notably take the current leadership away from the U.S. Departments of Defense (DOD), Veterans Affairs (VA) and Homeland Security (DHS), as well as the U.S. Office of Personnel Management (OPM), in one or more of these categories as shown by the below chart.4
Other Agencies Seem Likely to Utilize FAR Part 16 or Subpart 8.4 Procedures to Award Task and Delivery Orders Under the GWACs Managed by GSA
The EO appears to contemplate the use of FAR Part 16 or Subpart 8.4 procedures by contracting officers at other federal agencies. The primary contract vehicle to be established by GSA is defined in the EO as an "indefinite delivery contract vehicle," which the EO defines as "an agreement through which an agency can order goods and services over a defined period without setting forth quantities or a delivery schedule up front." This indicates that the EO intends GSA to establish GWACs for common goods or services but that agencies would conduct their own procurements with their own contracting officers by issuing task or delivery order solicitations under these GSA-administered GWACs.
No Definition of "Domestic"
The EO does not include a definition of "domestic," which may lead to varied interpretations and raises questions over the scope and intent of the EO's implementation, particularly regarding the inclusion of international procurement activities. If not clarified during subsequent rulemaking or guidance, this ambiguity could result in inconsistent application across agencies, potentially impacting international contracts and partnerships. Further, current contracts may need to be reviewed and potentially renegotiated to align with the new centralized procurement framework, which could be complex and time-consuming. The ambiguity surrounding "domestic" procurement could further complicate these adjustments.
No Exemption for DOD or DHS Procurements
Surprisingly, the EO has no exemption for procurements conducted by the DOD or DHS. These agencies have unique procurement needs that often require specialized goods and services not typically covered under general procurement categories. These agencies frequently engage in procurements that are critical to national security and defense, which may not align with the standardized procurement processes intended for common goods and services. Further, the scale and complexity of procurements by the DOD and DHS are often significantly greater than those of other federal agencies. This complexity might not be easily accommodated within a centralized procurement framework managed by GSA, which is primarily designed for more standardized procurement activities.
Historically, the DOD and DHS have also maintained a degree of operational autonomy in their procurement processes to ensure that they can respond swiftly and effectively to emerging threats and operational requirements. The EO's failure to address these agencies could potentially hinder their ability to procure necessary items in a timely manner, impacting their operational readiness in the future.
Timeline for Implementation
Within 30 days of issuance of the EO, the OMB Director shall designate the GSA Administrator as the executive agent for all GWACs for information technology (IT). The GSA Administrator, in consultation with the OMB Director, is also required to defer or decline the executive agent designation for GWACs for information technology "when necessary to ensure continuity of service or as otherwise appropriate." The GSA Administrator is also instructed to "rationalize Government-wide indefinite delivery contract vehicles for information technology for agencies across the Government, including as part of identifying and eliminating contract duplication, redundancy, and other inefficiencies" on an ongoing basis. Within 14 days of the EO, the OMB Director is directed to issue a memorandum to agencies implementing the foregoing.
Within 60 days of the EO, federal agency heads are required to submit to the GSA Administrator proposals to have the GSA "conduct domestic procurement with respect to common goods and services for the agency, where permitted by law."
Within 90 days of the EO, the GSA Administrator is required to submit a comprehensive plan to the OMB Director for the GSA to procure common goods and services across the domestic components of the government.
Expect this initiative to leverage and utilize FAR procedures for task order procurements under Part 16 (multiple award task order contracts) and Subpart 8.4 (FSS Program). Some revisions may be necessary to clarify that only GSA is authorized to issue and maintain GWACs for common goods and services in the categories identified by OMB.
Implications for Contractors
The EO looks like the next iteration of category management (a procurement reform initiative ongoing over the past decade) with "best-in-class" contracts limited to GWACs awarded by GSA. Agencies will need to navigate the transition of their procurement functions to GSA, which may involve logistical challenges and require careful coordination.
Contractors might expect non-GSA GWACs, such as NASA SEWP and NITAAC's CIO-SP vehicle to be discontinued as part of this reform initiative. Contractors selling information technology products and services can expect GSA's vehicles to ultimately be the only vehicles utilized by federal agencies, limiting the number of GWACs they must obtain and maintain in order to complete for IT requirements. During the transition of IT procurement to GSA, the EO provides that GSA "in consultation with the Director of OMB, shall defer or decline the executive agent designation for Government-wide acquisition contracts for information technology when necessary to ensure continuity of service or as otherwise appropriate." (emphasis added)
The EO also states that GSA shall, on an ongoing basis and consistent with applicable law, "rationalize GWACs for information technology for agencies across the Government, including as part of identifying and eliminating contract duplication, redundancy, and other inefficiencies." It is unclear what this means, but it may relate to the need to wind down GWACs established by non-GSA agencies for IT products and services.
The consolidation could create new opportunities for small businesses and nontraditional contractors to engage with the federal government, as streamlined processes may provide lower barriers to entry. With those potential benefits, however, contractors will likely face a modified array of compliance requirements as procurement processes are standardized across agencies, necessitating adjustments in their operations. As such, engaging with legal counsel is essential given the dynamic regulatory environment and rapid changes being pursued by the Trump Administration.
Notes
1 White House, "Fact Sheet: President Donald J. Trump Eliminates Waste and Saves Taxpayer Dollars by Consolidating Procurement" (last visited March 21, 2025).
2 The statutory authority allowing usage of the SEWP and NITAAC contracts by the entire federal government is NASA's and NIH's designation as an executive agent by OMB based on the Information Technology Management Reform Act (ITMRA) of 1996, now the Clinger-Cohen Act.
3 Acquisition.gov provides that: "The Category Management Leadership Council ("CMLC") is a council of representatives that come from the agencies who comprise the majority of federal procurement spending. The CMLC's mission is to be the governing body that makes important decisions and sets the direction of the government's category management initiative. The council is chaired by the Administrator of Federal Procurement Policy and it has representatives from the Departments of Defense (DOD), Energy, Health and Human Services, Homeland Security, Veterans Affairs, the General Services Administration (GSA), the National Aeronautics and Space Administration (NASA), and the Small Business Administration (SBA)." (last visited March 21, 2025).
4 Acquisition.gov, 10 Government-wide Categories (last visited March 21, 2025).
