A New Milestone in DoD Acquisition Oversight
On June 26, 2025, the Department of Defense (DoD) issued a formal memo mandating that certain unclassified contracts—including IT consulting, management services, and advisory/support contracts—must undergo review and approval by the Department of Government Efficiency (DOGE) before awards are made. This move represents the next step in Secretary Hegseth’s strategy to better scrutinize external spending while enhancing reliance on in‑house DoD capabilities. What It Covers: IT & management services contracts over $10 million, and advisory/assistance contracts over $1 million FAR‑based packages funded under BOC 23.3 or 25.1, or PSCs starting with “D” or “R” Requires: deliverables, total ceiling, initial obligation, cost‑benefit analysis, alternatives review, and insourcing justification Response Time: DOGE must respond within 3 business days (2 for some), or the package proceeds by default. Exclusions: Weapon system sustainment and major defense acquisition programs Engineering support under PSC‑“T” (systems engineering) Direct service provider contracts and task orders below the respective thresholds. 🕰️ Why This Matters Now—As FY 2025 Winds Down Rushing Submissions = Risky Business With the government fiscal year end (September 30) fast approaching, DoD components may batch last‑minute opportunities. Missing crucial documentation—especially the required justification or cost‑benefit analysis—could trigger DOGE rejection, delay awards, or even lead to terminations. Pipeline Shift: Higher Scrutiny Even pre-solicitation internal pipeline efforts now need a full DOGE-ready rationale early. Expect slower proposal-to-award timelines, as third-party capture and proposal managers will need to account for DOGE review lead times. Incentive to Repackage Awards may be segmented (for example, separating under‑$10M tasks) to bypass DOGE thresholds. But beware: the memo explicitly forbids artificial splitting. Smart capture teams should map funding needs holistically, avoiding violations. 🔭 Looking Ahead to FY 2026 Early. Deep. DOGE-Ready Opportunities kicking off in late FY 2025 and early FY 2026 will likely be under DOGE’s microscope. Capture strategies must now include DOGE delivery packages—cost-benefits, alternatives, and insourcing rationale—as integral to BD/Vendor Intelligence. Change in Teaming & Positioning There’s renewed value in offering “direct service provider” status, which may exempt firms from DOGE review. Similarly, small, outcome-based modular scopes under the thresholds may be more attractive. Insourcing Pressure Means In-House Alignment Offerings that complement, not compete with, DoD internal resources may perform better in reviews. Demonstrating capability augmentation—not substitution—will be critical. ✅ Real-World Go‑Forward Checklist for GovCon Business Owners Audit your current pipeline Identify FY 2025 awards hitting thresholds. Verify that cost-benefits, alternatives, and insourcing justifications are not afterthoughts, but baked into capture deliverables. 2. Synchronize with Capture & Proposal Teams Include DOGE‑ready documentation early. Embed standard templates for deliverables, cost-benefit, alternatives, and in-house capacity analysis in proposal decks. 3. Segment and Package Smartly Only split if truly separate efforts; avoid dogmatic threshold games. Offer IR&D or low-dollar follow-on tasks under the $1–10 M limits. 4. Pursue “Direct Service Provider” status Emphasize technical execution, not aggregation. Highlight IP, integration capability, and hands-on staffing to avoid the integrator label. 5. Track and Capture DOGE Feedback Use tracking tools or capture platforms. If DOGE goes silent for their response window, treat as “no‑comment” and proceed—but document timelines. 6. Plan for FY 2026 early For opportunities in Q4 and early FY 26, build DOGE-reviewed capability statements into your pitch. Highlight how your services support —not displace—DoD workforce. 💡 Bottom Line for GovCon Leaders: Process discipline is now non-negotiable. Here’s the formula: Capture → DOC analysis → DOGE-ready bid → proactive follow-up = compliance + competitive edge. Positioning matters: Self-categorize as a technical provider, not a generalist integrator. Early planning wins: Delay is the enemy—get ahead of DOGE cycles. As GFY 25 closes, the firms best poised to succeed in GFY 26 will be those that bake DOGE compliance and alignment into every stage of capture and proposal management—showing beyond doubt why their services add value, fill gap, and support DoD’s internal mission. To help you put these insights into action, we’ve created a DOGE-Ready Compliance & Capture Checklist—perfect for year-end planning and FY2026 prep. DOGE-Ready Compliance & Capture Checklist Threshold & Scope Identification 🗂️ Know your limits: IT/management services contracts ≥ $10M Advisory & assistance contracts ≥ $1M Avoid artificial splitting to remain under thresholds—strictly prohibited. DOGE Submission Essentials Every applicable opportunity must include: Deliverables: Clear descriptions of tasks and outcomes Total Ceiling & Initial Obligation: Overall value plus first obligation amount Cost–Benefit Analysis: ROI vs. in-house alternatives Alternatives Review: Documented market scan or sourcing assessment In-House/Direct Service Justification: Why no existing DoD personnel or direct providers can perform the work. Submission Protocol Use go.mil/dogecontractreview for uploads Expect DOGE feedback in 3 business days (2 for some broader scope packages); if none, treat as “no comment” and proceed acq.osd.mil. Understand Exclusions Weapon systems sustainment or major acquisition support System engineering/technical assistance under PSC‑“T” IT contracts or advisory packages under the defined thresholds Work from “direct service providers” (no intermediary integrators) dau.edu Emergency/contingency / OCONUS exceptions may apply Pipeline & Proposal Integration Audit early: Mark FY 2025 and early FY 2026 awards with DOGE coverage Incorporate DOGE docs in capture deliverables—not just proposals: templates for cost-benefit, sourcing strategy, and in-house justification Track DOGE review windows: Automate reminders for 3-business-day clock and document “no comment” times Positioning for Competitive Edge Emphasize “Direct Service Provider” status—exempt from DOGE if truly delivering vs. integrating Highlight complementation of DoD in‑house skills, not replacement Use workforce sufficiency analysis: show why contractor FTEs are needed vs. training existing staff media.defense.gov Monitor Compliance & Avoid Termination DoD Under Secretary of Acquisition & Sustainment (USD(A&S)) is tracking quarterly—non-compliance may lead to contract termination. 📌 Implementation Steps for GovCon Teams: Step Action Who 1 Map pipeline: Tag existing/opportunities > thresholds BD / Capture Leads 2 Update capture docs: Embed DOGE-ready templates Proposal / Capture 3 Prioritize status: Label direct‑provider vs integrator Capture / BD 4 Submit & track: Upload at DOGE site, set reminders Contracts / PM 5 Position advantageously: Demonstrate support, not substitution Capture / Marketing 6 Prepare for audits: Store audit-ready documentation Operations / Finance 🎯 Bottom Line Proactivity wins: Don’t wait for RFP—build DOGE rationales up front Clarity beats confusion: Simple cost-benefit + sourcing logic is critical Position strategically:
