Photo of Lorraine M. CamposPhoto of Adelicia R. CliffePhoto of Robert BurtonPhoto of Laura J. Mitchell BakerPhoto of Alexandra Barbee-GarrettPhoto of William B. O'Reilly

On March 20, 2025, the White House issued Executive Order (“EO”), “Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement,” to consolidate domestic civilian contracting for “common goods and services” within one agency—the General Services Administration (“GSA”). The EO defines “common goods and services” as those described in the Category Management system first developed as part of a previous effort, dating back to 2014, to coordinate spending across the government.

The EO asserts that “standardized procurement functions should be carried out in the most efficient and effective manner possible for the American taxpayer,” because, under the current system, “multiple agencies and agency subcomponents separately carry out these same functions in an uncoordinated and less economical fashion.”

The EO’s procurement consolidation effort sets forth four key deadlines.

Within 14 days of the EO’s issuance, by April 3, 2025, the Director of the Office of Management and Budget (“OMB”) is required to issue a memorandum to executive agencies for implementation, and then within 30 days of the EO’s issuance, by April 19, 2025, implement the following:

  • The OMB Director must designate the GSA Administrator as the executive agent for all governmentwide acquisition contracts (“GWACs”) for information technology (“IT”). The Administrator must, however, defer or decline its executive agent designation when doing so is necessary to ensure continuity of service or is otherwise appropriate.
  • The Administrator, on an ongoing basis, must rationalize agencies’ use of IT GWAC vehicles by identifying contracts deemed duplicative, redundant, or inefficient for elimination.

Within 60 days of the EO, by May 19, 2025, all agency heads, in consultation with their respective procurement officials, must submit to the Administrator proposals for GSA to conduct “domestic procurement with respect to common goods and services for the agency, where permitted by law.”

Within 90 days of the EO, by June 18, 2025, the Administrator must submit to the OMB Director a comprehensive plan to procure “common goods and services” across “the domestic components of the Government, where permitted by law.”

Key Takeaways

  • While the EO proposes significant changes, the immediate impacts on current and prospective government contractors could be modest depending on what is considered a “common good or service” and what authority the customer agencies retain to continue certain procurement activities. If these changes disrupt active contracts, contractors should know their rights in the event of performance delays, changes, and terminations.
  • Contractors may expect fewer contracting opportunities and solicitations in the near future, as the EO requires GSA to cull efforts that it considers duplicative or redundant.
  • Contractors may notice increased closures of procurement offices across numerous agencies as procurement functions shift to GSA.
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Photo of Lorraine M. Campos Lorraine M. Campos

Lorraine M. Campos is a partner and member of the Steering Committee of Crowell & Moring’s Government Contracts Group and focuses her practice on assisting clients with a variety of issues related to government contracts, government ethics, campaign finance, and lobbying laws. Lorraine…

Lorraine M. Campos is a partner and member of the Steering Committee of Crowell & Moring’s Government Contracts Group and focuses her practice on assisting clients with a variety of issues related to government contracts, government ethics, campaign finance, and lobbying laws. Lorraine regularly counsels clients on all aspects of the General Services Administration (GSA) and the U.S. Department of Veterans Affairs (VA) Federal Supply Schedule (FSS) programs. She also routinely advises clients on the terms and conditions of these agreements, including the Price Reduction Clause, small business subcontracting requirements, and country of origin restrictions mandated under U.S. trade agreements, such as the Trade Agreements Act and the Buy American Act. Additionally, Lorraine advises life sciences companies, in particular, pharmaceutical and medical device companies, on federal procurement and federal pricing statutes, including the Veterans Health Care Act of 1992.

Lorraine has been ranked by Chambers USA since 2013, and she was recognized by Profiles in Diversity Journal as one of their “Women Worth Watching” for 2015. Additionally, Lorraine is active in the American Bar Association’s Section of Public Contract Law and serves as co-chair of the Health Care Contracting Committee.

Lorraine joined the firm from Reed Smith, where she chaired their Government Contracts & Grants Team since 2010. Prior to that, she worked as a consultant for Grant Thornton, where she advised the Intelligence Community, analyzed the Department of Defense utility privatization program, and performed numerous Circular A-76 studies for the Office of Management and Budget.

Photo of Adelicia R. Cliffe Adelicia R. Cliffe

Adelicia Cliffe is a partner in the Washington, D.C. office, a member of the Steering Committee for the firm’s Government Contracts Group, and a member of the International Trade Group. Addie is also co-chair of the firm’s National Security practice. Addie has been…

Adelicia Cliffe is a partner in the Washington, D.C. office, a member of the Steering Committee for the firm’s Government Contracts Group, and a member of the International Trade Group. Addie is also co-chair of the firm’s National Security practice. Addie has been named as a nationally recognized practitioner in the government contracts field by Chambers USA.

Photo of Robert Burton Robert Burton

Robert A. Burton is a partner with Crowell & Moring’s Government Contracts Group in the firm’s Washington, D.C. office. He is a nationally-recognized federal procurement attorney, an expert witness on government contracts issues in federal court and arbitration proceedings, and a leader who…

Robert A. Burton is a partner with Crowell & Moring’s Government Contracts Group in the firm’s Washington, D.C. office. He is a nationally-recognized federal procurement attorney, an expert witness on government contracts issues in federal court and arbitration proceedings, and a leader who assists government contractors with navigating the complex and rule-driven procurement process. He represents a wide range of companies that conduct business with the federal government, from large defense contractors and systems integrators to small businesses.

Photo of Laura J. Mitchell Baker Laura J. Mitchell Baker

Laura J. Mitchell Baker is a counsel with Crowell & Moring’s Government Contracts Group in the firm’s Washington, D.C. office.

Laura represents government contractors in litigation and administrative matters, including contract disputes with state and federal entities, suspension and debarment proceedings, mandatory disclosures…

Laura J. Mitchell Baker is a counsel with Crowell & Moring’s Government Contracts Group in the firm’s Washington, D.C. office.

Laura represents government contractors in litigation and administrative matters, including contract disputes with state and federal entities, suspension and debarment proceedings, mandatory disclosures to the government, prime-sub disputes, and False Claims Act investigations. Her practice also includes counseling on federal, state, and local government contracts, government contracts due diligence, and regulatory and compliance matters, as well as conducting internal investigations.

Photo of Alexandra Barbee-Garrett Alexandra Barbee-Garrett

Alexandra Barbee-Garrett is an associate in Crowell & Moring’s Washington, D.C. office, where she practices in the Government Contracts Group.

Alex represents government contractors in both litigation and counseling matters. Her practice includes bid protests before the Government Accountability Office (GAO), the U.S.

Alexandra Barbee-Garrett is an associate in Crowell & Moring’s Washington, D.C. office, where she practices in the Government Contracts Group.

Alex represents government contractors in both litigation and counseling matters. Her practice includes bid protests before the Government Accountability Office (GAO), the U.S. Court of Federal Claims, and the U.S. Court of Appeals for the Federal Circuit. Alex’s practice also focuses on federal regulatory compliance, mandatory disclosures to the government, contract disputes under the Contract Disputes Act (CDA), prime-sub disputes, and False Claims Act and internal investigations.

Prior to joining Crowell & Moring, Alex was a law clerk to Judge Richard A. Hertling of the U.S. Court of Federal Claims and a government contracts associate at another large law firm. Alex graduated honors from The George Washington University Law School, where she was an articles editor of The Public Contract Law Journal. Alex won the 2015 Government Contracts Moot Court Competition and served as chair for the 2016 competition. Prior to law school, Alex worked as a health care legislative assistant for Rep. Rick Larsen (WA) in the U.S. House of Representatives. She received her B.A. in international studies and anthropology from the University of Washington.

Photo of William B. O'Reilly William B. O'Reilly

William B. O’Reilly is a counsel in Crowell & Moring’s Washington, D.C. office, where he is a member of the firm’s Government Contracts Group.

Liam assists clients with all phases of government contracting, including contract formation and award controversies, performance counseling, and claims…

William B. O’Reilly is a counsel in Crowell & Moring’s Washington, D.C. office, where he is a member of the firm’s Government Contracts Group.

Liam assists clients with all phases of government contracting, including contract formation and award controversies, performance counseling, and claims and disputes litigation. His practice includes representing clients in bid protests before the Government Accountability Office and U.S. Court of Federal Claims. Liam also regularly advises clients on supply chain risk management, addressing issues such as cybersecurity, country of origin and domestic preferences, and counterfeit part detection and avoidance, as well as conducting internal investigations and mandatory disclosures for performance breaches and potential violations of the False Claims Act (FCA).