The Department of Defense’s (“DoD”) Under Secretary for Acquisition and Sustainment issued a memorandum on June 23, 2025, that tightens oversight on DoD contracts for information technology consulting & management services (“ITC&MS”) and advisory & assistance services (“A&AS”).

What contracts are impacted?

The memorandum applies to unclassified, FAR-based contracts or task orders for ITC&MS or A&AS. ITC&MS are services provided by integrators or consultants that involve system information technology (“IT”) integration, implementation, or advice and that are valued at over $10 million. A&AS are services for consulting, advising, assisting, or any professional services for similar functions, and that are valued over $1 million. The memorandum expressly notes that requirements may not be split into multiple efforts to stay under the $10 million and $1 million thresholds. Additionally, the memorandum does not apply to already existing consulting and advisory contracts. 

What is the timeline for review?

Effective immediately, DoD agencies must secure advance approval from the Department of Government Efficiency (“DOGE”) for all qualifying ITC&MS or A&AS contracts. DoD agencies must include in their approval request a description of the contract’s purpose, a cost/benefit analysis, and a justification as to why the efforts cannot be insourced or acquired from a direct service provider. DOGE then has three business days to respond. If DOGE does not respond or approves the contract, then the contract may proceed. If DOGE raises issues with the contract, then DOGE and the DoD agencies are required to work collaboratively to resolve those issues. The memorandum does not specify whether DOGE can block a DoD agency from moving forward with the contract, whether there is any time limit on DOGE and DoD’s attempts to work collaboratively, or whether the agency has a specific appeal process if it disagrees with DOGE’s assessment.

Scope and Exemptions

Not all ITC&MS or A&AS contracts are subject to review. The memo expressly excludes:

• ITC&MS contracts involving “direct service providers” performing services rather than resellers, integrators, or intermediaries.
• ITC&MS contracts in direct support of defense weapon system programs or sustainment activities.
• A&AS contracts for systems engineering and technical assistance in support of major defense acquisition programs.

These exemptions align with the Administration’s decision to prioritize war fighting efforts as well as procure more supplies and services from Original Equipment Manufacturers.

Strategic Implications for Contractors and Agencies

This memorandum reflects a strategic push—rooted in broader federal efficiency initiatives—to trim consulting spend, eliminate unnecessary intermediation, and ensure rigorous scrutiny of high-value service awards.

While the exact impact this memorandum will have on contractors is still unclear, contractors working in the ITC&MS or A&AS space can take several steps to reduce their risk:

• Preempt DOGE scrutiny with clear justifications: Articulate in your proposal how your services provide unique value and cost-effective support.
• Clarify your role: Emphasize direct mission-critical support—especially for exempt programs. Avoid generic management consulting language that could trigger heightened scrutiny.
• Collaborate with agency customers: Work early with DoD contracting and program officials to help them develop the rationale for approving your contract or identifying an applicable exception.
• Streamline pricing and deliverables: Clearly define work products, performance metrics, and accountability mechanisms.