New Executive Order Consolidates Procurements with the General Services Administration (GSA)
Client Alert | March 26, 2025
On March 20, 2025, President Trump issued an Executive Order titled, “Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement” and accompanying Fact Sheet titled, “President Donald J. Trump Eliminates Waste and Saves Taxpayer Dollars by Consolidating Procurement.”
The Executive Order plans to “return the General Services Administration to its original purpose” of carrying out an “economical and efficient system” for core domestic procurement services for “common goods and services,” and for Government-wide acquisition contracts (GWACs) for information technology (IT). To effectuate this purpose, the Executive Order consolidates these types of procurements within the GSA. The Policy section of the Executive Order explains the Administration’s position that consolidating procurements within a single agency will eliminate waste and save money compared to the current system, under which multiple agencies and subcomponents separately carry out distinct procurements for the same types of goods and services. The Fact Sheet characterizes the Executive Order as an expansion of previous efforts to terminate or economize more than 6,000 contracts.
Common Goods and Services
By May 19, 2025, agency heads must submit to the GSA Administrator proposals “to have [GSA] conduct domestic procurement with respect to common goods and services for the agency, where permitted by law.” The Executive Order defines “common goods and services” by reference to the Office of Management and Budget (OMB)-led Category Management Leadership Council definition, which encompasses ten categories:
- Facilities & Construction, including construction-related and facility-related materials and services, as well as facilities purchases and leases;
- Professional Services, including business administrative services, financial services, legal services, management and advisory services, marketing, public relations, research and development, social services, and technical engineering services;
- IT, including software, hardware, consulting, security, outsourcing, and telecommunications;
- Medical, including drugs, pharmaceutical products, healthcare services, and medical equipment and supplies;
- Transportation and Logistics, including fuels, logistics support services, non-combat motor vehicles, package delivery, transportation equipment, and “Transportation of Things;”
- Industrial Products and Services, including fire, rescue, and safety environmental protection equipment; hardware and tools; installation, maintenance, and repair materials; machinery and components; oils, lubricants, and waxes; and test and measurement supplies;
- Travel, including employee relocation, lodging, and passenger travel;
- Security & Protection, including ammunition, protective apparel and equipment, security animals, security services, security systems, and weapons;
- Human Capital, including compensation, benefits, employee relations, human capital, strategy, policy, operations planning, talent acquisition, talent development; and
- Office Management, including furniture and office management products and services.
The Executive Order requires that by June 18, 2025, the Administrator must submit a “comprehensive plan” to OMB for the procurement of “common goods and services” across the “domestic components of the Government.”
IT GWACs
GSA currently maintains IT GWACs for solutions such as systems design, software engineering, information assurance, and enterprise architecture solutions. On its webpage dedicated to IT GWACs, GSA states that the pre-competed contracts allow agencies to procure IT solutions more efficiently and economically. Other agencies, such as National Aeronautics and Space Administration (NASA) and National Institutes of Health (NIH), also maintain their own non-GSA IT GWACs.
Under the Executive Order, the Administrator must “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.” The Director of OMB will issue a memorandum by April 3, 2025, providing further guidance to agencies on this section of the Executive Order. By April 19, 2025, the Director of OMB will designate the Administrator as the “executive agent” for all IT GWACs. The Administrator may consult with the Director of OMB to defer or decline the designation for a particular IT GWAC “when necessary to ensure continuity of service or as otherwise appropriate.”
Implications and Open Questions
The Executive Order gives significant discretion to GSA and OMB in implementing this consolidation of the government procurement system as related to “common goods and services” and IT GWACs. But the Order and Fact Sheet also raise many questions with important implications for contractors regarding how GSA and OMB will exercise that discretion, including:
- How will GSA expand the use of GWACs and assume additional procurement responsibilities in light of its current pause on new procurements and reductions in force?
- What constitutes a “domestic component of the Government”? To which agencies and which offices of which agencies will this Executive Order apply?
- What will happen to other IT GWACs maintained by other agencies, such as NASA’s Solutions for Enterprise-Wide Procurement (SEWP), or NIH’s CIO-SP3 vehicles?
Accordingly, the scope and extent of the impact on contracts and future procurements remain to be determined. However, contractors can likely expect additional contract disruptions, such as performance delays, stop work orders, or terminations as GSA and other agencies move to implement these requirements; the potential for fewer contract opportunities as a result of consolidation efforts; and a greater need to justify the costs and value of their contracts to government customers.
Gibson Dunn’s lawyers are available to assist in addressing any questions you may have regarding these developments. To learn more about these issues, please contact the Gibson Dunn lawyer with whom you usually work, any member of the firm’s Government Contracts practice group, or the following authors and practice leaders:
Lindsay M. Paulin – Partner & Co-Chair, Government Contracts Group,
Washington, D.C. (+1 202.887.3701, lpaulin@gibsondunn.com)
Dhananjay S. Manthripragada – Partner & Co-Chair, Government Contracts Group,
Los Angeles/Washington, D.C. (+1 213.229.7366, dmanthripragada@gibsondunn.com)
Joseph D. West – Partner, Government Contracts Group,
Washington, D.C. (+1 202.955.8658, jwest@gibsondunn.com)
Katie Rubanka – Associate, Government Contracts Group,
Washington, D.C. (+1 202.777.9409, krubanka@gibsondunn.com)
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