The Assault on Oversight in the Executive Branch

As we pass the first 100 days of the DOGE/Project 2025 onslaught against the administrative state, I keep thinking about how the technical assault has depended on a complementary demolition of oversight that would document, delay and even prevent some of the egregious abuses.

As every schoolkid knows, the US Constitutional system is designed to have checks and balances between the three coequal branches of government – the Executive, Legislative and Judicial. That isn’t functioning like it should. This is mainly because Congress has largely abdicated its role, leaving a void where the Trump administration has seized more power as its prerogative. The judiciary – in the form of lower federal courts – is providing much more resistance, but there is the looming question of how the Supreme Court will handle cases once they wind up there. Justice moves slowly too, and there is the worrisome thought of what happens if the President just refuses to listen to the courts? Time will tell.

Not as many people realize that there are also many oversight and regulatory functions within the Executive branch itself, most of which have been created by law over the years to deter the waste, fraud and abuse that the current administration claims it is here to stop. Simply put, DOGE’s stated mission is a lie, made obvious by the fact that they have sidelined and even attacked many of the mechanisms already in place to reduce waste and fraud. The real mission has been to accrue unchecked power, made possible by chipping away at anything that might constrain them. This piece is a look at some of the individual offices that the Trump administration has attacked to destroy oversight.

An Overview of Oversight

As the sole entity able to pass laws, Congress has used its power over the years to pass legislation that places limits on what the Executive branch can do. These limits are then usually enforced by the Judiciary branch when the Executive oversteps its authority.

The Pendleton Civil Service Reform Act (1883) created a nonpartisan civil service to replace the corrupt “spoils system” that had been in place since the presidency of Andrew Jackson in the 1820s. There had been multiple attempts at reform since the Civil War, but it took the assassination of President Garfield in 1881 to clear away significant opposition to reforms.
The Antideficiency Act (1884) was first enacted after the Civil War to prevent the practice of coercive deficiencies where agencies would purposefully run out of money to force more spending by Congress. It has been revised several times since (most recently in 1982) to ensure that the government does not enter into contracts that aren’t already fully funded and that operations do not occur without funding (this is why the government shuts down and also why businesses can’t give the government freebies). The purpose of this act is to prevent any subversion of Congressional control over spending.
The Privacy Act created rules about what personally identifiable information (PII) that the government can collect and how they must disclose its usage and give individual redress to correct wrong information about themselves in the system
The Inspector General Act (1978) created a standard set of independent Inspector General positions and offices across government with the authority to investigate fraud, handle whistleblowing complaints and monitor agency operations
The Civil Service Reform Act (1978) was the first major civil service reform act since the Pendleton Act. It abolished the existing US Civil Service Commission and established the Office of Personnel Management (OPM), Merit Systems Protection Board (MSPB) and the Federal Labor Relations Authority (FLRA). It also strengthened the power of federal unions.
The Whistleblower Protection Act (1989) protects federal whistleblowers from retaliation, defined prohibited personnel practices for federal employees and codified the role of the OSC in oversight here.
The Federal Vacancies Reform Act (1998) allows an incoming president 300 days to temporarily and unilaterally fill vacant Senate-confirmed positions in agency leadership with acting directors, provided they meet certain conditions.
The E-government Act (2002) defines the Federal Information Security Management Act (FISMA), which governs how government agencies should handle cybersecurity, and also defined the roles and responsibilities of Chief Information Officers (CIOs) within the federal government
Federal Information Technology Acquisition Reform Act (2014) increased the responsibilities of CIOs for IT acquisition, created a federal CIO council and defined a mechanism for some some CIOs to be appointed while others could be picked by the agency head
The Federal Acquisition Regulation or “The FAR” is not a law, but a collection of regularly-updated regulations standardizing the rules and practices of procurement across all federal agencies to ensure they are fair and transparent.

You might have noticed that some of these laws are clustered together. The 1880s were one fervent time for reform as corrupt practices and machine politics reached their peak, leading to a push for reform over the next 3 decades. Similarly, a number of oversight laws were passed in the 1970s in reaction to the excesses of Watergate. Taken together, these laws exist for the public to have faith in its government. They ensure transparency, fairness and responsibility in how the Executive branch enforces the law, procures goods and services and treats its citizens. Laws and regulations are a response – there is a saying that “every safety regulation was written in blood.” If we survive this, we will need new laws and rules to address the breach in trust and betrayal of faith in democracy.

Some laws like the Privacy Act do specify criminal penalties for breaking the law, but many oversight laws don’t include punishments. One of the jokes at 18F was “there’s no such thing as FISMA Jail,” because the law didn’t include any penalties for breaking it. This doesn’t mean there were no consequences. Even accidentally breaking the law can involve various levels of pressure and accountability. You would embarrass your agency. You would have to endure the scrutiny of the Inspector General. You – or more likely and far worse, your agency’s director – would be hauled in front of Congress to explain what happened. There would be FOIAs and attacks in the press. Following the law may often involve a fair number of bureaucratic hoops to jump through, but it’s far preferable to the risks that happen if you don’t.

An Ongoing Assault

Most of the direct disruption has happened in the Executive Branch, since that is where Trump and his allies have the most control. In line with their “run government like a business” model of top-down direction, they are intolerant of any idea that parts of the executive branch should be able to assert any independence. And there are many existing parts of the executive branch that were designed that way, to push back and negate some aspects of what the President can do. This is why they’ve been attacked.

Office of Personnel Management (OPM)

One of the ways in which DOGE surprised everybody was how it turned a relatively sleepy agency into a weapon against the entire government bureaucracy. Created by law in 1978, OPM’s main role before now was to standardize government policies around personnel and to offer shared services for human capital like the federal health plans. It also tracks all the paperwork around hiring, promotions, changes and retirement. And so, for most federal staff, their main interactions with OPM were receiving paperwork they were hired, fired or retired; or picking a health plan; or looking at the rules around various practices. But, all the other aspects of human resources were handled by their own agencies. Federal staff are hired to their specific agencies, their performance rankings are defined by their agency, they’re promoted by their agencies, they’re paid by their agencies, they follow the HR policies of their agencies. OPM provides the guidance, but it’s the agencies that implement it.

This is why OPM’s heel turn has been so confounding. Very early on, DOGE concentrated a large number of staff within OPM to capture control of the centralized databases and install a new email server to send/receive messages from every federal worker. The acting director was forced out and replaced by Charles Ezell, who then let DOGE wall off an area and keep out permanent agency staff. DOGE also brought in a slew of HR executives from startups who seemingly expected the agency to work for the entire federal government in the same way that HR operates within a single company. And so, they started acting like OPM had more centralized authority: ordering workers to the “five things” email; blasting commands to human capital officers at other agencies; asking for lists of workers so they could command agencies to fire probationary workers and short-cut established procedures for reductions in force. OPM used to be deliberative and formal with its rulemaking – the new OPM was fond of sending out memos to all agencies on Wednesdays demanding a response by Friday. None of this was normal; some of it was downright illegal. And the breach in trust has been irrevocable.

OPM has also been useful as a means of obscuring DOGE’s activities and also paying some of the staff for their work. Several of the prominent members of the DOGE crew of young techies – Akash Bobba, Gavin Kliger and Edward Coristine – were appointed to “special expert” roles at OPM and then assigned on a temporary basis (known as detailing in government parlance) to other agencies through formal staffing agreements. From there, they might be detailed even further. DOGE was also able to use its control of OPM to extract revenue for other agencies. For instance, as part of its planning to conduct a massive Reduction-in-Force (RIF) to eliminate most staff, CFPB leadership signed an agreement paying OPM for consulting services on how to layoff its staff.

2025-01-20: The DOGE team moves into OPM, installing sofa beds and armed security
2025-01-20: OPM sends a memo demanding that agencies must provide a list of all their probationary employees and justify why they should be retained. This is viewed by many agencies as a command to terminate them.
2025-01-22: OPM sends a memo to all agencies mandating they must revoke their telework and remote policies within 2 days.
2025-01-23: OPM sends out a first test email from its new government-wide email system.
2025-01-24: OPM sends a memo to all agencies that they must eliminate all staff associated with DEI within 60 days.
2025-01-27: OPM sends a memo that all agencies must submit within a 10 days a detailed plan for how all staff will return to office.
2025-01-28: OPM sends out the “Fork in the Road” email to all federal employees offering them a chance to resign. This is followed up by multiple emails and memos explaining things that weren’t answered in previous memos, suggesting an unfamiliarity with government employment regulations.
2025-01-31: Regular federal staff at OPM reportedly are locked out of access to key systems by DOGE and OPM leadership.
2025-02-05: To get out of a lawsuit, OPM issues a Privacy Impact Assessment for its Government-Wide Email System (GWES) that attests that responses to the email are considered voluntary, brief and contain no identifying information.
2025-02-24: After Elon Musk threatens to fire government staff who don’t comply, all government workers receive an email from OPM requesting they must optionally reply with a list of five things they did last week. Many agencies are mixed on if it’s required or optional.
2025-02-28: After litigation against it fails, OPM revises its Privacy Impact Assessment for the GWES system to declare that responses aren’t always to be considered voluntary.
2025-03-03: Federal staff receive a “Part II” email ordering them to provide a list of five things they did last week to an OPM email address by the end of Monday and to continue to do so every week. There are no other “Five Things” emails sent after this.
2025-03-04: OPM quietly revises its memo on probationary employees to suggest that it was not ordering agencies to fire them.
2025-03-20: Trump issues and executive order tellng OPM to start crafting new regulations that would give it more direct power to terminate staff at other agencies

General Services Administration (GSA)

The General Services Administration is another sleepy agency that was quickly subverted by DOGE to use a base of operations for its attacks. Before the DOGE era, the GSA was a base for shared services that were used by multiple agencies. This included things like purchasing and setting up buildings, cars for agencies and office supplies. This sometimes involves outlaying capital in ways that can’t be easily appropriated by Congress. To support this, the agency has always had some large funds that can be directed at the discretion of agency leadership, if they need to buy a building, for instance.

This flexibility has also allowed the agency to expand more into technical services as a shared offering across government. The GSA Acquisitions Services Fund is funded through reimbursable revenue generated from services to other agencies instead of appropriations from Congress. This allowed it to be the seed funding for 18F, the technology consultancy founded within GSA in 2013 which recouped its expenses by billing other agencies for custom software development services. Similarly, GSA has other technological services for offer as part of its Technology Transformation Service: cloud.gov, login.gov, notify.gov, etc. These are now under the leadership of Thomas Shedd, a 28-year-old software engineer with 8 years of working experience at Tesla. His main qualifications for the job seem to be unshakeable loyalty, boosting AI regardless of it applicability, a disregard for existing technical talent and experience, and a distinct lack of empathy.

Unfortunately, those same aspects that made it easy for GSA to provide new services have also made it easier to destroy the agency. Since many of its outlays are not appropriated from Congress, they could be canceled without fear of subverting Congress. Yes, it’s highly counterproductive to cancel a significant number of federal leases without forethought, but it’s technically constitutional. Many of the staff of 18F were hired as term employees, as a way of expediting federal hiring for techies looking to do a tour of duty in the federal government, but that also meant they were easier to fire. And GSA’s special role in providing services to other agencies meant that changes in GSA operations could have huge ramifications. Besides cancelling leases, DOGE has also moved to practically suspend purchase cards provided by GSA to support micro-purchases, individual expenses that are below $10,000 and do not need the same extensive procurement process. The damage from that has been extensive and catastrophic. And in a recent executive order, Trump is now decreeing that GSA should have the same arbitrary destructive power over software licenses that it has had over purchase cards. This, from the same agency which apparently hasn’t figured out how to procure enough Adobe Acrobat licenses for its own staff.

GSA is also the other agency that initially housed many DOGE staffers who were then detailed to other agencies. These staff also occupied and entire floor of GSA headquarters where only those with “A-level” access could enter. Notable members of the DOGE wrecking crew that were based out of GSA included Luke Farritor, Jeremy Lewin and Ethan Shaotran. There still is no public documentation on why DOGE staff were split between DOGE/USDS, OPM and GSA. It may have been just because those two agencies were where most DOGE activity was first focused, but it also became a useful way of obscuring who was detailed from where.

2025-01-24: Thomas Shedd, a 28-year-old with 8 years of work experience at Tesla, is named the head of TTS
2025-02-12: GSA technical staff describe being subjected to 15-minute interviews with Thomas Shedd and unidentified DOGE staffers where they are asked to defend their work.
2025-02-12: Dozens of workers within the Technology Transformation Services are summarily fired.
2025-02-20: GSA places an arbitrary $1 limit on all government spending cards.
2025-03-01: All remaining staff in 18F are fired via an email sent after midnight.

Office of Management and Budget

The Office of Management and Budget is the single most powerful department within the White House. It’s the division that most closely manages the President’s agenda and tracks spending across executive agencies. As a result, it often has served as the enforcer of many of these rules that don’t have a penalty. In the past, I’ve seen agency staff who are a lot more worried about how OMB might react than their own agency leadership about an embarrassing mistake. If you’ve seen “The Thick of It” and enjoyed one of Malcolm Tucker’s diatribes, then you can understand what I mean by this. In the past, OMB has also been the parent agency of the US Digital Service, an arrangement which gave USDS wide latitude to get involved in their work with other agencies. Unfortunately, the very same mechanisms that made it easier for USDS to do its work are what DOGE exploited to get its own elevated access in other agencies. This is just one of the “government hacks” that allowed the Obama administration to score achievements that have now been used against the government. But that’s a whole other essay.

In the second Trump administration, the OMB under Russell Vought has become a predatory enforcer, throwing its weight around to bully federal staff and cow independence from any leaders. Rather than a bold enforcer of the status quo and principle of least embarrassment, it’s become a wrecking ball that relies on withholding budgets, overt threats and novel legal theories that push the idea of what powers the Executive Office has. It has worked very closely with DOGE’s efforts to dismantle spending at agencies and with OPM to weaken civil service protections. An early example of this partnership was their collaboration to take down the CFPB. Within hours of Vought winning confirmation, DOGE staff swarmed into the agency, demanding superuser access to all systems under the claim that they were looking for fraud. To override any objections, Vought installed himself as the new Acting Director of the agency and ordered that all work at the agency should stop and the building was closed to all. The plan worked mostly – to this day, CFPB remains largely shuttered, with many key contracts and activities canceled under a new argument that agency activities should be limited to what is defined by statute (a seemingly precise definition that is intentionally vague by design). And agency leadership (Russell Vought) has worked seamlessly with OMB (also, Russell Vought) to attempt several times to reduce the agency staff to a shell of as few as “five people and a phone,” that would technically meet its statutory requirements but be unable to do anything of value. Thankfully, federal judges haven’t been swayed by OMB and DOJ’s attempts to be clever at interpreting the law, but the administration is hopeful that the Supreme Court will go their way. If the Court asserts that impoundment (the withholding of allocated funds) is constitutional, then OMB will truly be unstoppable.

2025-01-20: Another executive order issued by Trump mandates a hiring freeze and that hiring practices will be reviewed in a collaboration between DOGE, OPM and the OMB
2025-01-20: USDS is renamed the US Doge Service and transferred to its own White House office instead of being part of the OMB. This move is an attempt to skirt public records and FOIA laws that might apply.
2025-02-06: Russell Vought wins confirmation as the director of the OMB
2025-02-07: Russell Vought is named the acting director of the CFPB and shuts down the agency
2025-02-26: The OPM and OMB issue joint guidance on agency reorganization and reduction-in-force plans

Acting Directors

In one of its more novel tactics, the Trump Administration has repeatedly used acting directors as the mechanisms of agency destruction. Because many agency directors require Senate confirmation before they can be appointed and this process takes time, the Vacancies Act was passed to ensure continuity of operations when during a change of administration or when an agency leadership position is vacated. This act allows the President to name people as “acting” directors or other positions who are granted full powers until a Senate-confirmed appointee can be sworn in. The Vacancies Act does set some conditions for who can serve as acting directors:

By default, the “first assistant to the office” (i.e., the deputy director) fills the position
However, the President may direct a person serving in a different Senate-confirmed position to serve as the acting officer
Alternatively, the President can select a senior officer of the same agency to be acting director, provided they are at a certain high level and have been at the agency for more than 90 days

In the past, Acting Directors have largely acted as custodial roles, ensuring the operations of the agency continue but usually not making any major changes, since they are filling the seat until the real director can come in. The general assumption has been that agency directors would feel some loyalty to their staff or responsibility to be good stewards of the agency that has been entrusted to their care. The standard practice before this year for government transitions has been that an agency head appointed by the previous administration resigns on Inauguration Day and their deputy or another designee identified during the Presidential transition then serves as acting director until a permanent appointee is sworn in. To give an idea, here is the list of acting officials on January 20th, almost all of whom were current acting officials.

The Trump administration has dramatically upended this practice, using Acting Directors as a way to significantly change or even completely demolish other agencies. For the destruction of USAID, Trump fired the agency’s acting head and then declared the recently appointed Secretary of State, Marco Rubio, as the new acting director. Rubio then authorized all the activities of DOGE to demolish the agency. Similarly, within hours of being sworn in as director of the OMB, Russell Vought was named the acting director of the CFPB and ordered similar actions. in other cases, sympathetic quislings have been promoted from within in the agency to be the face of unpopular actions – these include Charles Ezell at the OPM, Leland Dudek at the Social Security Administration and Dorothy Fink at Health and Human Services. This tactic has been instrumental in the DOGE takeover at many agencies – in their first acts, the acting directors usually order that DOGE staff are given superuser access and that normal processes for approval should be bypassed and staff be placed on administrative leave so they can’t prevent or observe what is happening. It’s a bit like a bank heist where the branch manager is spearheading the crime. Also, this tactic has been used in lower positions as well, especially for DOGE staff who are often placed in positions at one agency but then serve in acting leadership positions in others.

I honestly don’t know how to fix this in the future. Our governance processes trust leaders will want to preserve the integrity and authority of the institutions under their charge. And this makes them vulnerable to parasitism like this. The business world has suffered from this issue for years – this is exactly how slash-and-burn private equity works – and there doesn’t seem to be a “zero trust” approach that scales to large organizations we could apply. Ultimately, the only thing to stop this will be oversight from the other branches. The courts can demand corrective actions, but only if they overstep the law and always far too late after the damage has been done. Congress is what could – and in any other situation probably would – move quickly to stop these incursions in the future, and it deserves significant blame for its total abdication here.

2025-01-20: The acting director of the Office of Personnel Managment is demoted and replaced by Charles Ezell, an obscure career employee in an analytics division
2025-01-20: Stephen Ehikian is named to a Deputy Administrator role, a senior role that doesn’t require appointment, and is then sworn in as acting director of the General Service Administration
2025-02-01: Several days after the resignation of the director of the CFPB, the Secretary of the Treasury Scott Bessent replaces the deputy director as the acting director of the CFPB
2025-02-03: Secretary of State Marco Rubio is named the new acting administrator of the United States Agency for International Development
2025-02-07: Hours after being sworn in as head of the OMB, Russell Vought is named as the new acting director of the CFPB and he proceeds to try to shutter the agency
2025-02-12: The Trump Administration names Doug Collins, the head of Veterans Affairs, as the acting director of the Office of Government Ethics.
2025-02-16: Secretary of State Marco Rubio is named the new acting director of the US Archives, including the national recordkeeping office
2025-02-17: After the resignation of the acting commissioner, Leland Dudek, an obscure career employee, is named the new Acting Commissioner of the Social Security Administration
2025-03-05: The Trump administration names Doug Collins, the head of Veterans Administration and the acting head of OGE, to be the acting head of the OSC

Independent Agencies

Over the years, Congress has seen it necessary to create agencies that are insulated from direct control by the President or even Congress itself. This is a common approach that was used to create many of the financial regulators in a time when legislators were more mindful of the corrosive effects of money in politics. For many of these agencies, the directors are often nominated by a President and approved by the Senate but with a 5-year or longer term to separate them from the usual election cycles. Once there, they are supposed to be able to serve independently, even if it means being in opposition to the president. For instance, the FTC Commissioner only “may be removed by the President for inefficiency, neglect of duty, or malfeasance in office.” This was affirmed by the Supreme Court in a 1935 case, Humphrey’s Executor v. United States which affirmed that “Congress intended to restrict the power of removal to one or more of those causes.”

And yet, when does the Trump Administration listen to laws and precedent? Indeed, a lot of the administration’s actions have been focused on explicitly targeting independent agencies. This is partially because many of them are watchdog entities that may regulate illegal activities within the government (e.g., NLRB, OGE, MSPB) or industries outside of the government that the Trump administration would prefer to be able to more directly reward/threaten. This is also because the Trump administration really wants to force a do-over on Humphrey’s Executor because it believes the current Supreme Court would be more cooperative.

Perhaps aware of the risk that the Court might not go their way, the Trump Administration hasn’t necessarily obliterated many independent agencies. Instead, they have tried two different tactics: reducing the agency its minimum footprint to meet its “statutory functions” or disabling it by eliminating quorum. In the case of the US Institute of Peace or the Institute of Museum and Library Services, DOGE installed acting directors who then reduced the agencies to a single person each, by claiming that person is enough to meet what the statutes have said. In the case of the Merit Systems Protection Board and similar, Trump has instead fired several commissioners, which then meant the agency is unable to take any actions because it doesn’t have quorum. Those firings are probably illegal (see above), but the agency is made inert while cases work their ways through the courts.

2025-01-28: Trump fires two of the three Democratic commissioners in Equal Employment Opportunity Commission (EEOC)
2025-01-28: Trump fires two Democratic members of the National Labor Relations Board (NLRB)
2025-02-07: Trump fires the head of the Office of Special Counsel, Hampton Dellinger
2025-02-10: Donald Trump fires the head of the Office of Government Ethics
2025-02-10: Trump fires a Democratic member of the Merit Systems Protection Board
2025-02-12: The Trump administration DOJ asserts to Congress that it feels that clauses that prevent removal of members from independent agencies are unconstitutional
2025-02-23: DOGE ousts the CEO of the Inter-Americas Foundation
2025-02-28: DOGE ally Peter Marocco declares himself CEO of the IAF and dissolves the agency
2025-03-12: Shelly Lowe, the chair of the National Endowment for the Humanities, is forced out of office by the Trump administration.
2025-03-16: DOGE staff show up and force out staff from the US Institute of Peace
2025-03-18: Trump fires both Democratic members of the Federal Trade Commission
2025-03-25: DOGE member Nate Cavanaugh is named the new President of the US Institute of Peace by remaining board members Rubio and Hegseth. He then proceeds to shutter the agency.
2025-03-28: An appeals court rules against the cases of Gwynne Wilcox of the NLRB and Cathy Harris of the MSPB that contested their removals.
2025-03-31: DOGE arrives and shuts down completely The Institute of Museum and Library Services (IMLS) and cancels all grants
2025-04-16: Trump fires two of the three members of the independent National Credit Union Administration, another independent federal watchdog group.

Inspectors General

What if I told you there had already been teams within each federal agency dedicated to rooting out waste, fraud and abuse long before DOGE entered the scene? Established by law in 1978, inspectors general (see, I remembered some copyediting knowledge from my days in journalism) are given unique powers to operate independently within each agency to root out fraud and law-breaking. To accomplish these goals, IGs are often given elevated read-only access to multiple systems to conduct audits and report on wrong-doing. They also operate tip-lines for whistleblowing from both agency staff and the general public. They’re highly effective entities that make sure agencies are performing their required duties efficiently and always following the law. Which is why DOGE had to eliminate them first.

One of the first moves of the Trump Administration was a reprise of Reagan’s mass removal of all IGs, with Trump abruptly firing 17 inspectors general across the government late on a Friday night. Under the law, the President has to provide a justification for removal, but Trump declined to offer any other justification beyond “changing priorities.” The initial agencies targeted seemed like a weird collection – Agriculture, Interior, HUD, Defense, EPA, State, HHS, Small Business Association and the VA – but many were also early targets of DOGE’s activities where the IG would normally investigate and document the laws they might have broken. Indeed, the USAID Inspector General was fired immediately after filing a report that cataloged DOGE’s destruction there. Surprisingly, the IGs for OPM and GSA were spared from the slaughter, and the OPM Inspector General is currently investigating the security of DOGE’s email server. Any bets on if they’ll be fired too?

Inspectors General aren’t always the only oversight layer against improper actions of agency leadership or staff. In many agencies, you will often see opposition from the Chief Counsel’s office if any activities seem like they might break the law. Similarly, the Chief Information Officer (CIO) will often balk at violations of cybersecurity practices or federal policies on information systems. And most agencies also have a Privacy Office to ensure that the Privacy Act is being followed. In many significant cases, staff in these roles too have been fired or placed on administrative leave indefinitely for daring to object to the actions of DOGE within agencies.

2025-01-24: Trump fires 17 inspectors general across multiple agencies late at night on a Friday, mostly concentrated at agencies which are early targets of DOGE.
2025-02-11: The USAID Inspector General is fired after releasing a report critical of DOGE’s actions.
2025-02-12: Eight Inspectors General file a lawsuit seeking reinstatement.
2025-03-10: OPM’s surprisingly not-fired Inspector General announces he will be starting an investigation of DOGE’s security practices
2025-03-13: Trump removes the Chief Counsel of the IRS, replacing him with a former inspector general from the prior Trump administration
2025-03-21: Trump eliminates the DHS Office for Civil Rights and Civil Liberties and two ombudsman offices responsible for investigating allegations of abuse from immigrants

Other Civil Service Oversight

This piece has already touched on some of the ways that the Trump administration has tried through OPM and OMB to redefine the nonpartisan civil service though both direct attacks as well as administrative changes. Recognizing the importance of civil service protections, Congress has created several different independent agencies that are tasked with policing and protecting the civil service itself. The Office of Government Ethics is responsible for defining and enforcing the ethics rules. It also creates and collects the annual OGE-450 form that all government employees are required to fill out to assure they do not even have the appearance of conflicts of interest. The Office of Special Counsel (OSC) is an investigative and legal agency whose responsibility is ensuring that the prohibited personnel practices stay relatively prohibited. This largely includes whistleblower protection. During election years, this also enforces the Hatch Act. The Merit Systems Protection Board (MSPB) was created in 1979 as a venue for government workers to arbitrate disputes when federal employees allege they have been illegally disciplined or fired from their jobs. Finally, the Federal Labor Relations Authority (FLRA) has governance over the labor relationship between the federal government and the approximately 2.1 million non-postal (they have their own thing) government employees in unions.

All of these agencies would normally play a role in resisting and overturning the Trump administration’s radical actions against government staff. Unfortunately, because they are independent agencies, they have been attacked with the same playbook outlined above – rendering them inert through either the illegal removal of the agency head or by eliminating enough members of the board to prevent quorum. The Trump administration has then attempted to use this to their advantage in federal court. For instance, DOJ lawyers would argue that lawsuits by federal employees shouldn’t be heard in federal court because they are normally supposed to be handled by the MSPB, even though Trump had already fired its chair. Or by arguing that class actions for entire classes of employees like probationary workers who were fired unjustly should instead be processed as individual cases before the OSC or MSPB (stretching out the timeline for relief into years). Thankfully, this argument has been roundly rejected by multiple judges in the Federal court system who recognized the Kafkaesque trap that the administration was proposing for harmed workers.

2024-03-06: Hampton Dellinger is sworn in for a five-year term as the head of the OSC after Senate confirmation
2024-12-16: David Huitema is sworn in for a five-year term as the head of the Office of Government Ethics
2025-02-07: Trump fires the head of the Office of Special Counsel, Hampton Dellinger
2025-02-10: Donald Trump fires the head of the Office of Government Ethics
2025-02-10: Hampton Dellinger files a lawsuit, alleging his termination was illegal since the head of OSC can only be fired for “only for inefficiency, neglect of duty, or malfeasance in office.”
2025-02-12: The Trump Administration names Doug Collins, the head of Veterans Affairs, as the acting director of the Office of Government Ethics.
2025-03-01: The judge in the case about the firing of the OSC rules that the firing is illegal and Hampton Dellinger should be reinstated to his position.
2025-03-03: The US court of the appeals for the District of Columbia reverses the lower court decision and lifts the stay against the firing of the head of the OSC. Hampton Dellinger drops his lawsuit.
2025-03-05: The Trump administration names Doug Collins, the head of Veterans Administration and the acting head of OGE, to be the acting head of the OSC

CIOs and Cybersecurity

As DOGE has been learning (and trying to blatantly ignore), developing software for the federal government is different in many ways from the startup world. For instance, Privacy Act regulations have prohibited connecting systems precisely because the American public doesn’t want government to create a panopticon system with a “God” view that makes execs at Palantir drool. While the agency’s Privacy Office and Chief Counsel will often determine what information sharing is legally allowed, the agency’s Chief Information Officer usually oversees the technical mechanisms which ensure that compliance. Furthermore, the CIO is primarily responsible for tracking IT budgets and contracts, which makes them a tempting target to support DOGE’s mission of centralizing and controlling all spending and procurement at federal agencies. The CIO also is sometimes able to directly enable DOGE’s elevated access to systems by ordering staff to grant them global admin access and to disable monitoring and safeguards that might get in their way. Finally, while I had mentioned before that there is no FISMA Jail, breaking the laws of FISMA can still invite oversight and litigation. Because it is sometimes necessary to skirt the rules for important and time-sensitive problems, CIOs are allowed to issue “get out of jail” cards. Known as Risk Acceptance Memos (RAMs), these are documents usually prepared by agency cybersecurity staff for the CIO to sign and accept the risk for problems that might reasonably occur because the normal compliance processes were bypassed. RAMs are highly useful when used strategically. They also are an obvious mechanism for abuse in the wrong hands.

So, it’s no surprises that DOGE’s work started with replacing CIOs in some key agencies to put in people sympathetic to DOGE’s aggressive actions. Over the last 100 days, the Trump administration has shown no hesitation in replacing other CIOs that got in their way to also remind any remaining CIOs and staff that they’re next. And it’s starting to use CIOs as part of its strategic plans. As an example, according to court filings, two DOGE staffers – Marko Elez and Aram Moghaddassi – at the Department of Labor were granted access to a highly-sensitive data system belonging to the Office of the Inspector General on March 21. This system contained sensitive data from Unemployment Insurance claims that DOGE wanted to scrape to use in anti-immigration efforts. Normally, such access would be blocked, but an Executive Order issued on March 20 demanding widespread data access for DOGE explicitly declared that “the Secretary of Labor and the Secretary’s designees shall receive, to the maximum extent consistent with law, unfettered access to all unemployment data and related payment records, including all such data and records currently available to the Department of Labor’s Office of Inspector General.” This data was still considered so highly sensitive that DOL counsel determined that access would need to be explicitly granted by the agency CIO. Conveniently enough, they had just appointed a new CIO a week before. His name? Thomas Shedd.

2025-01-20: Acting OPM Director Charles Ezell replaces existing CIO Melvin Brown with DOGE member Greg Hogan
2025-01-24: Thomas Shedd, a 28-year-old with 8 years of work experience at Tesla, is named the head of the Technology Transformation Services (TTS) division at GSA
2025-02-03: Mike Russo (a DOGE member) is appointed as the CIO at the Social Security Administration. He immediately demands access for DOGE member Akash Bobba that bypasses the normal procedures.
2025-02-04: The OPM issues a memo instructing agencies to reclassify CIO roles to reduce hiring restrictions and allow political appointees to serve in the position.
2025-02-05: Thomas Flagg, the CIO of the Department of Education, sends a memo to the heads of IT across the agency ordering them to give prompt access to DOGE when requested.
2025-02-10: DOGE CIO appointee Mike Russ convenes his own internal informational working group at SSA, does not inform the Director of his activities.
2025-02-10: Ryan Riedel is named the CIO of Department of Energy and grants admin access against internal projects to DOGE member Luke Farritor
2025-02-11: DOGE ally Greg Hogan is formally named the official CIO of OPM (he had been the acting CIO since January 20th)
2025-02-19: DOGE members Edward Coristine and Kyle Schutt are given superuser access to all email at the Cybersecurity and Infrastructure Security Agency (CISA)
2025-03-03: After DOGE arrives at the National Labor Relations Board (NLRB), the agency CIO demands there are to be no logs or records of DOGE’s account creation. Several suspicious accounts are later identified.
2025-03-07: Ryan Riedel unexpectedly resigns as the CIO of the Department of Energy
2025-03-10: Ross Graeber, who reportedly worked with DOGE at the State Department, is named the new CIO of the Department of Energy
2025-03-08: Federal IT staff at the department of Health and Human Services (HHS) who blocked DOGE from accessing the sensitive NDNH database are reportedly “no longer with the agency.”
2025-03-14: Thomas Shedd is also named the CIO of the Department of Labor while still serving as the head of TTS
2025-03-17: The Department of Homeland Security CIO orders that access should be expedited for DOGE staffers who want to access a sensitive data lake there.
2025-03-20: An executive order issued by Trump demands that all agency heads (and staff reporting to them) must share any data requested by DOGE without any delays. It also includes specific language to share data from the DOL OIG office.
2025-03-21: Acting at the CIO for the Department of Labor, DOGE member Thomas Shedd signs a memo granting access of a highly-sensitive dataset to DOGE members Aram Moghaddassi and Marko Elez.
2025-03-24: During this week, IT staff at the NLRB decide to report suspicious activity by DOGE to the CISA. The reply tells them to ignore the problem and stop tracking the issue.
2025-03-28: After expressing concerns about DOGE access to payroll systems, the CIO of the Department of the Interior insists the agency secretary would need to sign a RAM for it. Instead, he is suspended indefinitely.
2025-03-28: The CIO of the Small Business Administration (SBA) is abruptly removed from his position.
2025-04-03: Senior technical positions incluing the Director of Cybersecurity are terminated at the IRS.
2025-04-07: Unprecedented data sharing agreements are signed by the IRS and SSA to share data with DHS and Immigration and Customs Enforcement (ICE).
2025-04-10: A senior technical leader at SSA is forced out of his office by security guards after objecting to a DOGE plan to declare undocumented immigrants as dead in SSA files to interfere with their finances.

The Big Timeline

For your convenience, here is a merged timeline of all the sub-timelines above, with the color coding to show how the action proceeded in parallel on different fronts (and sometimes, a single action like replacing the OPM CIO would hit two themes at once).

2024-03-06: Hampton Dellinger is sworn in for a five-year term as the head of the OSC after Senate confirmation
2024-12-16: David Huitema is sworn in for a five-year term as the head of the Office of Government Ethics
2025-01-20: The Trump administration begins
2025-01-20: The acting director of the Office of Personnel Managment is demoted and replaced by Charles Ezell, an obscure career employee in an analytics division
: Acting OPM Director Charles Ezell replaces existing CIO Melvin Brown with DOGE member Greg Hogan
: Stephen Ehikian is named to a Deputy Administrator role, a senior role that doesn’t require appointment, and is then sworn in as acting director of the General Service Administration
: The DOGE team moves into OPM, installing sofa beds and armed security
: OPM sends a memo demanding that agencies must provide a list of all their probationary employees and justify why they should be retained. This is viewed by many agencies as a command to terminate them.
: Another executive order issued by Trump mandates a hiring freeze and that hiring practices will be reviewed in a collaboration between DOGE, OPM and the OMB
: USDS is renamed the US Doge Service and transferred to its own White House office instead of being part of the OMB. This move is an attempt to skirt public records and FOIA laws that might apply.
2025-01-22: OPM sends a memo to all agencies mandating they must revoke their telework and remote policies within 2 days.
2025-01-23: OPM sends out a first test email from its new government-wide email system.
2025-01-24: OPM sends a memo to all agencies that they must eliminate all staff associated with DEI within 60 days.
: Thomas Shedd, a 28-year-old with 8 years of work experience at Tesla, is named the head of TTS
: Trump fires 17 inspectors general across multiple agencies late at night on a Friday, mostly concentrated at agencies which are early targets of DOGE.
2025-01-27: OPM sends a memo that all agencies must submit within a 10 days a detailed plan for how all staff will return to office.
2025-01-28: Trump fires two of the three Democratic commissioners in Equal Employment Opportunity Commission (EEOC)
: Trump fires two Democratic members of the National Labor Relations Board (NLRB)
: OPM sends out the “Fork in the Road” email to all federal employees offering them a chance to resign. This is followed up by multiple emails and memos explaining things that weren’t answered in previous memos, suggesting an unfamiliarity with government employment regulations.
2025-01-31: Regular federal staff at OPM reportedly are locked out of access to key systems by DOGE and OPM leadership.
2025-02-01: Several days after the resignation of the director of the CFPB, the Secretary of the Treasury Scott Bessent replaces the deputy director as the acting director of the CFPB
2025-02-03: Secretary of State Marco Rubio is named the new acting administrator of the United States Agency for International Development
: Mike Russo (a DOGE member) is appointed as the CIO at the Social Security Administration. He immediately demands access for DOGE member Akash Bobba that bypasses the normal procedures.
2025-02-04: The OPM issues a memo instructing agencies to reclassify CIO roles to reduce hiring restrictions and allow political appointees to serve in the position.
2025-02-05: To get out of a lawsuit, OPM issues a Privacy Impact Assessment for its Government-Wide Email System (GWES) that attests that responses to the email are considered voluntary, brief and contain no identifying information.
: Thomas Flagg, the CIO of the Department of Education, sends a memo to the heads of IT across the agency ordering them to give prompt access to DOGE when requested.
2025-02-06: Russell Vought wins confirmation as the director of the OMB
2025-02-07: Trump fires the head of the Office of Special Counsel, Hampton Dellinger
: Hours after being sworn in as head of the OMB, Russell Vought is named as the new acting director of the CFPB and he proceeds to try to shutter the agency
2025-02-10: Donald Trump fires the head of the Office of Government Ethics
: Trump fires a Democratic member of the Merit Systems Protection Board
: Ryan Riedel is named the CIO of Department of Energy and grants admin access against internal projects to DOGE member Luke Farritor
: DOGE CIO appointee Mike Russ convenes his own internal informational working group at SSA, does not inform the Director of his activities.
: Hampton Dellinger files a lawsuit, alleging his termination was illegal since the head of OSC can only be fired for “only for inefficiency, neglect of duty, or malfeasance in office.”
2025-02-11: DOGE ally Greg Hogan is formally named the official CIO of OPM (he had been the acting CIO since January 20th)
: The USAID Inspector General is fired after releasing a report critical of DOGE’s actions.
2025-02-12: GSA technical staff describe being subjected to 15-minute interviews with Thomas Shedd and unidentified DOGE staffers where they are asked to defend their work.
: Dozens of workers within the Technology Transformation Services are summarily fired.
: Eight Inspectors General file a lawsuit seeking reinstatement.
: The Trump administration DOJ asserts to Congress that it feels that clauses that prevent removal of members from independent agencies are unconstitutional
: The Trump Administration names Doug Collins, the head of Veterans Affairs, as the acting director of the Office of Government Ethics.
2025-02-16: Secretary of State Marco Rubio is named the new acting director of the US Archives, including the national recordkeeping office
2025-02-17: After the resignation of the acting commissioner, Leland Dudek, an obscure career employee, is named the new Acting Commissioner of the Social Security Administration
2025-02-19: DOGE members Edward Coristine and Kyle Schutt are given superuser access to all email at the Cybersecurity and Infrastructure Security Agency (CISA)
2025-02-20: GSA places an arbitrary $1 limit on all government spending cards.
2025-02-23: DOGE ousts the CEO of the Inter-Americas Foundation
2025-02-24: After Elon Musk threatens to fire government staff who don’t comply, all government workers receive an email from OPM requesting they must optionally reply with a list of five things they did last week. Many agencies are mixed on if it’s required or optional.
2025-02-26: The OPM and OMB issue joint guidance on agency reorganization and reduction-in-force plans
2025-02-28: After litigation against it fails, OPM revises its Privacy Impact Assessment for the GWES system to declare that responses aren’t always to be considered voluntary.
: DOGE ally Peter Marocco declares himself CEO of the IAF and dissolves the agency
2025-03-01: The judge in the case about the firing of the OSC rules that the firing is illegal and Hampton Dellinger should be reinstated to his position.
: All remaining staff in 18F are fired in an email sent overnight.
2025-03-03: Federal staff receive a “Part II” email ordering them to provide a list of five things they did last week to an OPM email address by the end of Monday and to continue to do so every week. There are no other “Five Things” emails sent after this.
: The US court of the appeals for the District of Columbia reverses the lower court decision and lifts the stay against the firing of the head of the OSC. Hampton Dellinger drops his lawsuit.
: After DOGE arrives at the National Labor Relations Board (NLRB), the agency CIO demands there are to be no logs or records of DOGE’s account creation. Several suspicious accounts are later identified.
2025-03-04: OPM quietly revises its memo on probationary employees to suggest that it was not ordering agencies to fire them.
2025-03-05: The Trump administration names Doug Collins, the head of Veterans Administration and the acting head of OGE, to be the acting head of the OSC
2025-03-07: Ryan Riedel unexpectedly resigns as the CIO of the Department of Energy
2025-03-08: Federal IT staff at the department of Health and Human Services (HHS) who blocked DOGE from accessing the sensitive NDNH database are reportedly “no longer with the agency.”
2025-03-10: Ross Graeber, who reportedly worked with DOGE at the State Department, is named the new CIO of the Department of Energy
: OPM’s surprisingly not-fired Inspector General announces he will be starting an investigation of DOGE’s security practices
2025-03-12: Shelly Lowe, the chair of the National Endowment for the Humanities, is forced out of office by the Trump administration.
2025-03-13: Trump removes the Chief Counsel of the IRS, replacing him with a former inspector general from the prior Trump administration
2025-03-14: Thomas Shedd is also named the CIO of the Department of Labor while still serving as the head of TTS
2025-03-16: DOGE staff show up and force out staff from the US Institute of Peace
2025-03-17: The Department of Homeland Security CIO orders that acccess should be expedited for DOGE staffers who want to access a sensitive data lake there.
2025-03-18: Trump fires both Democratic members of the Federal Trade Commission
2025-03-20: Trump issues and executive order tellng OPM to start crafting new regulations that would give it more direct power to terminate staff at other agencies
: An executive order issued by Trump demands that all agency heads (and staff reporting to them) must share any data requested by DOGE without any delays. It also includes specific language to share data from the DOL OIG office.
2025-03-21: Trump eliminates the DHS Office for Civil Rights and Civil Liberties and two ombudsman offices responsible for investigating allegations of abuse from immigrants
: Acting at the CIO for the Department of Labor, DOGE member Thomas Shedd, signs a memo granting access of a highly-sensitive dataset to DOGE members Aram Moghaddassi and Marko Elez.
2025-03-24: During this week, IT staff at the NLRB decide to report suspicious activity by DOGE to the CISA. The reply tells them to ignore the problem and stop tracking the issue.
2025-03-25: DOGE member Nate Cavanaugh is named the new President of the US Institute of Peace by remaining board members Rubio and Hegseth. He then proceeds to shutter the agency.
2025-03-28: An appeals court rules against the cases of Gwynne Wilcox of the NLRB and Cathy Harris of the MSPB that contested their removals.
: After expressing concerns about DOGE access to payroll systems, the CIO of the Department of the Interior insists the agency secretary would need to sign a RAM for it. Instead, he is suspended indefinitely.
: The CIO of the Small Business Administration (SBA) is abruptly removed from his position.
2025-03-31: DOGE arrives and shuts down completely The Institute of Museum and Library Services (IMLS) and cancels all grants
2025-04-03: Senior technical positions incluing the Director of Cybersecurity are terminated at the IRS.
2025-04-07: Unprecedented data sharing agreements are signed by the IRS and SSA to share data with DHS and Immigration and Customs Enforcement (ICE).
2025-04-10: A senior technical leader at SSA is forced out of his office by security guards after objecting to a DOGE plan to declare undocumented immigrants as dead in SSA files to interfere with their finances.
2025-04-16: Trump fires two of the three members of the independent National Credit Union Administration, another independent federal watchdog group.

The story does not end here. This administration will continue to chip away at the oversight mechanisms that would keep its worst impulses in check (or rather, enable them to be prosecuted later). Is there something I should add that I missed? Feel free to contact me and let me know!