This primer is designed for you, a Presidential appointee tasked with overseeing the distribution of federal resources. Action, not passivity, should guide your decisions. You are the vital conduit that transforms the American people’s mandate to this administration into the real, tangible results delivered across every corner of government.
The Appointee’s Guide to Strategic Stewardship
1. Understanding Your Mandate and Duty
You were appointed to execute the administration’s agenda in a way that faithfully reflects the national interest. Under EO 14332, “Improving Oversight of Federal Grantmaking“ and EO 14398, “Addressing DEI Discrimination by Federal Contractors” AKA the March 2026 Neutrality Mandate, you are charged with exercising authority over discretionary grantmaking, and preventing illegal DEI activities in federal contracting, respectively, consistent with the applicable law. Blindly delegating these duties to those outside the appointee leadership is unacceptable because it cedes powerful tools to the inertia of the previous administration and embedded career employees who may actively or passively resist the will of the people as channeled through the executive branch according to the Constitution.
You are empowered to ensure that every dollar spent advances the President’s priorities where permitted under the law. When the American people vote for change, “business as usual” will not suffice.
2. The Decision-Making Framework: Law, Facts, and Policy
Deliberate and decide within three critical constraints:
- Points of Law and Regulation: Start with the relevant statutory and regulatory authorities. What did Congress intend for this money? What do the regulations permit? Ensure you are operating within the bounds of 2 CFR Part 200 (“the Uniform Guidance”) for federal assistance (grants, cooperative agreements), or the Federal Acquisition Regulation (“the FAR,” 48 CFR Chapter 1) for procurement contracts, or any other applicable authorities. If your agency can award Other Transactions (OTs), use that alternate authority, which is not subject to the FAR, thereby allowing greater flexibility of contract.
- Material Facts: Rely on the data. Start with (but don’t stop at) the technical evaluation provided by the career staff. The technical evaluation contains recommendations, but the ultimate decision does not have to follow those recommendations. You can arrive at a different conclusion (and choose a different vendor) based on the same facts and evaluation criteria. EO 14332 speaks directly to this practice.
- Policy Preference: This is where your unique leadership role enters the process. Your decisions, discretion, and judgement control policy. Apply the recognized policy preferences of the President and the agency leadership (e.g., as made explicit in Presidential and Secretarial orders). Whatever the relevant priority may be (e.g., Restoring Energy Dominance, Supply Chain Security, Permitting Reform, Gold Standard Science) you can ensure that the grants and/or contracts serve the broader mission. The career staff may not be fully informed about the correct direction for policy; it is your job to steer them. Be firm, consistent, and active (present, engaged) in all policy decisions.
3. Early Involvement: Forming the Solicitation, Funding Opportunity, or Public Notice
Requests for Proposals (RFP), Notices of Funding Opportunities (NOFO), and other public notices are too often released without accounting for the Presidential requirement to expand the applicant pool beyond former and current recipients of federal funding—entrenched incumbents. Many incumbent and legacy organizations may not be committed to, and may even be actively hostile to, the priorities of the administration. Expanding the range of potential recipients and contractors maximizes the impact of taxpayer money, supports the national interest, and meets the objectives of Presidential directives.
We need to depart from “how it’s always been done” and EO 14332 requires your direct effort toward that goal. Your direct participation in the solicitation, NOFO, or RFP planning process is vital because otherwise, procedures created by others will constrain your judgment, objectives, and discretion during the evaluation and award process. To be effective, you must shape the government requirement, scope of work, evaluation method, and other details—before the public-facing document is released.
- Engage Early with Clear Requirements: Get involved with the program office and contracting or grantmaking office prior to a funding opportunity being released to ensure that the evaluation criteria, while legally supportable, are clearly identified and align with the administration’s agenda. This will also help avoid future protests or confusion among applicants down the road.
- Expand Outreach: Consider whether application requirements unintentionally favor incumbents or highly specialized grant-writing operations over substantive merit that can provide immediate, demonstrable results consistent with the purpose of the grant.
- Barriers to Entry: Ensure that RFPs or NOFOs do not assign unjustified preference to prior experience (e.g., did you do it before) or past performance (e.g., how well you did it before), contain unnecessary administrative burdens, or require unrealistic cost-sharing requirements that may discourage otherwise qualified new entrants.
- Actively Incentivize Innovation. The default procedure in many of the offices under your purview is to re-use the prior solicitation, usually to avoid both risk of protest and added work. This inevitably drives the same bidders to re-submit the same outdated thinking that led voters to issue President Trump such a mandate. It is incumbent upon you to make sure that every dollar you are entrusted to steward on his behalf contributes to that mandate. There are several ways you can achieve this shared goal:
- Scope of Work: make sure that every dollar awarded is keyed to specific outcomes, not just inputs. Outcomes must be measurable and documented, and risk must be shared – the days of Government issuing payment to contractors just for billing hours are over. We are accountable to the President as he is to the American people.
- Pricing: make sure all payments are tied to specific deliverables or progress that can be objectively evaluated. If the bidding community complains that this would introduce too much risk to submit a responsible bid, return to the SOW and more clearly define the outcomes you are buying on the Government’s behalf. Never supply an Independent Government Cost Estimate, and do not consider a wide range of price proposals to be a bad sign – if a bidder is willing to sign a contract to deliver a required outcome for a lower price, we will give them a chance and hold them to account.
- Key Personnel: evaluate key personnel not on the basis of education or tenure, but based on their recent and relevant accomplishments. Tie this to the outcomes defined in the SOW wherever possible. Use oral presentations wherever possible, limit participation to staff bid as key, and actively engage those key personnel in live problem-solving exercises. Do not be afraid to evaluate them outside the mean, whether above or below – the wrong key personnel can kill a program.
- Evaluation Criteria: explicitly define “innovation” as an evaluation criteria, and make sure it is the most heavily weighted. This forces all bidders to think – as we must – beyond past performance, and focus on newer, more effective ideas. It also removes a major barrier to competition by encouraging new players with new approaches. Be specific: look at the legacy contract or grants to identify performance issues and require new bids to explain a) how they will improve on those areas, and b) how they will measure and demonstrate those improvements. Consider adding evaluation points for bids that clearly show how the bidder will reduce unit costs, increase efficiency, and deliver more with less.
It is crucial to invest extra effort in all of these things before proposals or grant applications are submitted: they will govern how you are able to award the resulting funds, and are extremely hard to retrofit. As with all unfamiliar good ideas, you should expect pushback, because this will require more active performance management from the people who serve your Agency. This pushback is very useful in targeting another important responsibility you bear: reducing the size of the Federal workforce. Anyone not willing to actively manage the performance of the funds they are entrusted to steward on behalf of the American people should move to the top of your reduction in force lists.
4. Involvement in the Selection Process
Whether you have been an active participant in the development of the award opportunity or not, you can still have a material impact on the agency’s selection process and award decision as a final decision-maker.
As the selection official, your primary tool is Independent Judgment. You are NOT required to simply “rubber-stamp” the evaluations, analysis, and recommendations of your technical experts. In fact, EO 14332 forbids the practice of blindly deferring to the recommendations of others. Your Independent Judgment can override or deviate from those recommendations, if reasonably justified based on the evaluation criteria. Do not accept “we have always done it this way” as an answer. Examine if the candidates align with the administration’s strategic goals.
- Make Your Own Decisions: Treat the career staff’s recommendations as a starting point for your own independent analysis, not the conclusion. You can request further written justification for any review, analysis, or evaluation. As the final decision-maker, you can deviate from the conclusions, recommendations, and analysis of your team. As stated in EO 14332, you must use your independent judgment for discretionary grantmaking:“Senior appointees and their designees shall not ministerially ratify or routinely defer to the recommendations of others in reviewing funding opportunity announcements or discretionary awards, but shall instead use their independent judgment.”
- Meritocracy: Ensure that the selection is meritocratic, based on a culture of excellence. If a proposal focuses on prohibited social schemes like Diversity, Equity, and Inclusion (DEI) it is your duty (per EO 14398) to refocus that funding toward technical excellence and meritocracy.
- Choose – and Apply – Evaluation Criteria Carefully: Cost-effectiveness, technical approach to the work proposed, management and staffing, and other evaluation factors can influence the selection decision, provided those evaluation factors are written into the solicitation. What you initially choose for the evaluation criteria greatly influences the results.
- Although new applicants may face start-up costs, they could also find new ways to save money. You can give preference to a lower indirect cost rate, for example, to expand competition beyond the familiar incumbents at large universities or NGOs.
- Diminish Incumbency Bias: While a track record of performance should be considered, do not accept that the top scores go only to organizations that have always received grants or contracts under prior administrations. Consider carefully any “hard requirements” for experience or past performance.
- Work with new applicants and small businesses who may be applying on their own or forming fresh partnerships; do not automatically disqualify them for an aspirational approach.
- Expanding Competition – Relatedly, expanding the eligible applicants beyond past awardees is essential to fulfill the Presidential mandate under EO 14332. During the award phase, use your authority and discretion to broadly interpret the evaluation criteria to expand applicant pool. Of course, all such criteria used must still be tied to the solicitation that all applicants were asked to respond to.
- Direction of Planning vs. Detailed Polish: In cooperative agreements (vice grants), the awardee works together with a to finalize the terms and to perform the project. In such cases, the initial application needs only to be directionally aligned with the administration’s agenda. After award and during performance, the involvement and direction of the government program officer can ensure the work supports the administration’s agenda. In contrast to cooperative agreements, grants involve substantially less government control.
- Your Reasoning: Write a Policy Alignment Briefing (PAB) or Source Selection Decision Document (SSDD). By documenting how the law, the facts, and the policy intersect, you create a legally defensible record that protects the agency and the decision. If appropriate, ask for input from your Office of General Counsel or contracting leadership. Strong documentation and disciplined processes strengthen, rather than weaken, political leadership authority.
- Focus on Strengths and Weaknesses: Every award decision boils down to comparative strengths and weaknesses. Do not assign a false sense of specificity or objectivity to scores, numbers, or “ratings.” What matters is the underlying strengths or weaknesses, explained in plain English. “The staffing plan is superior, including extra personnel for surge support” means something, but simply rating a score of 75, by itself, does nothing for your decision documentation. Consider using an LLM to draft a representative response to your solicitation before you release it, and then use the Evaluation Criteria to score it. If this proves challenging, revisit Section 3 and make sure your SOW and Evaluation Criteria are clearly defined and measurable.
5. Navigating Agency Dynamics
Working with career staff is a partnership because they provide institutional memory and technical expertise that make your policy goals possible.
- Encourage Transparency: Ask for the “raw” data behind the rankings. Understanding why a certain applicant was prioritized allows you to make a more informed policy assessment.
- Be Clear and Consistent on Priorities: The more clearly and consistently you communicate the administration’s goals, the better the staff can meet your expectations.
- Understanding Investigations: Review and oversight are a normal part of contracting and grantmaking. Investigations are not triggered by lawful policy decisions but rather may be a result of indicators such as fraud, financial mismanagement, procedural inconsistencies, insufficient documentation, or whistleblower complaints. Having buttoned-up internal policies, detailed documentation—including the rationale for any discretionary judgments—will protect against potential investigations. Always remember: your General Counsel and Inspector General serve you as you serve the President, and they are invaluable resources. Engage them at the earliest stages of any process or procurement that is likely to draw scrutiny to make sure that your hard work is not invalidated by unforeseen or unforced errors.
- Mitigating Protest Risk for Contracts: Disappointed would-be contractors may contest the award of federal contracts by filing a formal protest with the agency, Government Accountability Office (GAO), or Court of Federal Claims. The protest process explores whether the agency followed its policies and procedures and generally acted within its legal authority. All but a tiny fraction of protests are dismissed on procedural grounds, flatly denied, or resolved by agency corrective actions without any finding of misconduct. You can play an important role by carefully documenting the record while you ensure that selections are aligned with the administration’s priorities. Work with your Office of General Counsel and contracting leadership to mitigate the risk of protests, and remember that protest decisions boil down to underlying strengths and weaknesses (explained clearly), not arbitrary ratings.
A Note of Encouragement: The federal contracting and grantmaking process is one of the most powerful levers for change in the world. By exercising your authority with precision, fairness, and a focus on merit, you are not just managing a budget but leading the restoration of trust in the effectiveness and neutrality of the American government. You were chosen for this role because of your judgment; trust it.