Tax Filing as Easy as Mobile Banking: Creating Product-Driven Government
Americans trade stocks instantly, but spend 13 hours on tax forms. They send cash by text, but wait weeks for IRS responses. The nation’s revenue collector ranks dead last in citizen satisfaction. The problem isn’t just paperwork — it’s how the government builds.
The fix: build for users, not compliance. Ship daily, not yearly. Cultivate talent, don’t rent it. Apple doesn’t outsource the creation of its products; the IRS shouldn’t outsource taxpayer experience. Why?
The goal: make taxes as easy as mobile banking.
The IRS, backed by a Congress and an administration that truly wants real improvements and efficiencies, must invest in building its tax products in house. Start with establishing a Chief Digital Officer (CDO) at the IRS directly reporting to the Commissioner. This CDO must have the authority to oversee digital and business transformation across the organization. This requires hiring hundreds of senior engineers, product managers, and designers—all deeply embedded with IRS accountants, lawyers, and customer service agents to rebuild taxpayer services. This represents true government efficiency: redirecting contractor spending to fund internal teams that build what American taxpayers should own rather than rent.
This is about more than broken technology. This is a roadmap for building modern, user-centric government organizations. The IRS touches every American, making it the perfect lab for proving the government can work.
Transform the IRS first, then apply these principles across every agency where citizens expect digital experiences that actually work.
Challenge & Opportunity
It’s April 15th. For the first time, you’re not fretting.
You finished filing your taxes on a free app. It took 15 minutes. Your income? Already there. Your credits? Pre-calculated and ready to claim. Your refund? Hitting your bank account tomorrow.
For millions around the world, swift, painless tax filing isn’t a dream. It’s the norm. It should be for Americans, too.
But in the U.S., the IRS experience is still slow, opaque, process-heavy, and frustrating. Tax filing is one of the few universal interactions Americans have with their government—and it’s not one that earns much trust.
It doesn’t have to be this way. We were on the path to delivering that with IRS Direct File and needed to recommit. To deliver wildly easier taxes for Americans, we can, and must, build an IRS that meets high modern expectations: fast, transparent, digital-first, and relentlessly taxpayer-focused.
The Diagnosis
Each year, the IRS collects more than 96% of the revenue that funds the federal government—$5.1 trillion supporting everything from Social Security, defense, infrastructure, veterans’ services, and investing in America’s future.
The quote from Justice Oliver Wendell Holmes, carved into the limestone face of the IRS headquarters in D.C., captures the spirit well:
“Taxes are what we pay for civilized society.”
It is not only essential to the functioning of government—it is also a major way most Americans interact with it. And that experience? Frustrating, costly, and confusing. According to a recent Pew survey, Americans rate the IRS less favorably than any other federal agency. The average taxpayer spends 13 hours and $270 out of pocket just to file their return.
The core problem: The IRS needs to be user-focused.
Despite the stakes, the IRS operates far behind what Americans expect. We live in a world where people can tap to pay, split bills by text, or trade stocks in slick apps. But that world does not include the IRS.
A staggering 63% of the 10.4 billion hours Americans spend dealing with the federal government are consumed by IRS paperwork. But much of the source of that pain isn’t the IRS, but Congress with the crushing complexity of decades long tax code changes, sedimented on top of each other. This year was no different. The “One Big Beautiful Bill” runs 331 pages, with large swaths devoted to new, intricate tax changes.
Dealing with the IRS still often involves paper forms, long phone waits, chasing down documents, and confusing processes.
If you’ve dealt with the IRS for anything beyond filing, it feels impossible to get a task finished. Will someone pick up the phone? Can I get an answer to my questions and resolve my situation? Would I expect the same answer if I talked to someone else? Last year the IRS answered just 49% of the 100 million calls it received, including automated answering.
This underperformance is beyond outdated technology—it’s structural and institutional. The IRS’s core systems are brittle and fragmented. Ancient procurement rules and funding constraints have made sustained modernization nearly impossible. Siloed organizations sit within siloes. In place of long-term investment, the agency leans heavily on short-term contractor fixes, band-aids applied to legacy wounds.
This complexity has stymied scaled change.
The root cause: The IRS has never treated world-class technology and product development as mission-critical capabilities core to its identity, to be hired, owned, and continually improved by internal teams focused on user outcomes.
A modern service agency builds end-to-end experiences for users—from pre-populating data through to filing and refunds. Empowered teams building these features have a holistic viewpoint and control over their service to ensure taxpayers are able to repeatedly and reliably complete their task.
Today’s reality is different: federal agencies like the IRS treat technical and product expertise as afterthoughts—all nice-to-haves that serve bureaucratic processes rather than core capabilities essential to their mission. Strategy and execution get outsourced by default. This creates a growing divide between “business” and “IT” teams, each lacking a deep understanding of the other’s work, despite both being critical to delivering services that actually function for taxpayers.
This outsourcing has hollowed out the agency’s internal technical capacity. Rather than building technical competency in-house, and paying that talent a salary approaching private companies, the IRS grows more dependent on vendors. It no longer knows what it needs technically, what questions to ask or which paths to pursue. Instead they must trust the vendors–companies financially incentivised towards ballooning scopes, lock-in, and complexity.
The result: a siloed experience that mirrors a siloed organization, one that is risk-averse, paper-heavy IRS, too slow to meet modern expectations.
The agency approaches service delivery as a compliance and bureaucratic process to digitize, rather than a product to design. “Never ship your org-chart” is a common refrain you’ll hear at tech companies, to explain how products tend to take on the communication style of their builders. Yet IRS product faultlines visibly follow its org structure and thus fail to deliver a holistic experience.
There were bright spots. Direct File showed what’s possible when empowered teams build for users. A dead simple idea: let Americans file taxes directly on the IRS site was a reality. It worked. It was well regarded. In surveys, users beamed about Direct File: 9 out of 10 gave it an “excellent” or “above average” rating, 74% said they preferred it over what they used before, and 86% said it increased their trust in the IRS.
The government actually delivered for its citizens, and they felt it.
But it didn’t last. The project was abruptly dismantled due to political ideology, not taxpayer experience or feedback.
Many of the people with the technical skills and vision to modernize the IRS have left, often without a choice. The agency will likely slide further backward—into deeper dependence on systems built by the lowest bidder or those currying political favor, with poorer service and diminished public trust in return.
We’ve seen this up close.
Both of us worked at The White House’s technology arm; the U.S. Digital Service. One of us helped lead Direct File into existence and built the Consumer Financial Protection Bureau’s digital team. The other previously led Google’s first large language model products and prototyped AI tools at the IRS to streamline internal knowledge work.
In our work at the IRS, we witnessed how far the agency must go. Inside the IRS Commissioner’s office, with leaders across the agency, we built a collaborative digital strategic plan. This memo details those proposals since left by the wayside after seven different IRS commissioners rotated in the seat, just this year.
The IRS needs more than modernization. It will need a systemic rebuild from:
- compliance, to user-centered design and product thinking
- vendor dependence to empowered internal product teams
- once-a-year panic to real-time, year-round services
- fragile mainframes to composable platforms and APIs
- waterfall contracting to iterative, continuous delivery
We’re sharing these recommendations for a future Day One—when there’s a refocus on rebuilding the government. When that day comes, the blueprint will be here: drawn from inside experience, built on hard lessons, and focused on what it will take to deliver a digital IRS that truly works for the American people.
What we need is the mandate to build a tax system that makes Americans think: “That was it? That was easy.”
Plan of Action
The IRS must rebuild taxpayer services around citizen needs rather than compliance and bureaucratic processes. This requires in-housing the talent to strategically build it. We propose establishing a Chief Digital Officer directly reporting to the Commissioner, with the authority to oversee digital and business transformation across the organization, hire hundreds of senior engineers, product managers, and designers. The goal, a team empowered to deliver a tax-filling product experience that meets modern expectations.
The Products
Build for Users, Not Internal Compliance
We’ve become accustomed to a user-focused fit-and-finish in the app era. Let’s deliver that same level for taxpayers.
It all starts around building a digital platform that empowers taxpayers, businesses, and preparers with the information, tools and services to handle taxes accurately and confidently. A fully-featured online account becomes the one-stop, self-service hub for all tasks. Taxpayers access their complete tax profile, updated in real-time, with current data across income sources, financial institutions, and full tax history. The system proactively recommends tax breaks, credits, and withholding adjustments they’re eligible for.
Critically, this can’t be built in a vacuum. It requires rapid iteration with users as part of a constant feedback loop. This digital platform runs on robust APIs that power internal tools, IRS public sites, and third-party software. Building this way ensures alignment across IRS teams, eliminates duplicate efforts, and lifts the entire tax software ecosystem.
This is what we need to build for Americans:
Online tax filing: From annual panic to year-round readiness
Reboot Direct File. Stop forcing everything into tax season. Let taxpayers update information year-round—add a child, change addresses, adjust withholdings, upload documents. When April arrives, their return is already 90% complete.
This is a natural evolution of Direct File and the existing non-editable online account dashboard into a living, breathing system taxpayers optimize throughout the year. And not just for individuals—this should be extended to businesses—reducing this burden for as many filer types as possible.
Pre-populated returns: Stop making people provide what the IRS already knows
The IRS already has W-2s, 1099s, and financial data. Use it. Pre-populate returns to cut filing time from hours to minutes. Deliver secure APIs so any tax software can access IRS data (with taxpayer permission), and use machine learning to flag issues including fraud before submission. This increases accuracy, reduces errors, and spurs competition by making it easy to switch between tax-filing programs.
Income verification as a service: Turn tax data into financial opportunity
The IRS sits on verified income data that could help Americans access government services, credit, mortgages, and benefits like student aid. Instead of weeks-long transcript requests, offer instant verification through secure APIs. This creates a government-backed source alongside credit bureaus, increases financial access, and reduces paperwork across all government services.
Tax calculator as a platform: One source of truth
Every tax software company recreates the same calculations, each slightly different. Across the organization, the IRS itself uses multiple third-party tax calculators in audits. This should be a core, integral service the IRS offers—build a definitive tax calculator as an API, the single source of truth that internal audits and checks use, and external software can access or run on their own. Make it transparent, auditable, and open source. Put up cash “bounties” to encourage the public to find bugs and errors and invite taxation-critics to review the code. Use generative AI to aid IRS accountants, lawyers and engineers translate tax law changes into code–speeding the roll out of Congressional tax changes.
When everyone calculates taxes the same way the IRS does, errors vanish. When everyone can see how the IRS does it, trust grows.
Modern MeF: From submission pipe to intelligent platform
Today’s Modernized e-File (MeF) is barely modern—it’s a dumb pipe that accepts tax returns and hopes for the best. Transform it into intelligent infrastructure that validates in real-time, catches errors immediately (not weeks later in confusing notices), and stops fraud before refunds are deposited. Build it like a real API, not XML dumps. Enable multi-part submissions so taxpayers can fix mistakes without starting over. This isn’t just a technical upgrade—it’s the foundation that makes every other improvement possible.
The Process
Ship Daily, Not Yearly
Taxpayer-first product development
The IRS is the single largest interaction point between Americans and their government. Every improvement saves millions of hours and builds trust. This requires abandoning bureaucratic processes for product thinking.
Build with taxpayers from day one through constant user testing and feedback loops. Organize around taxpayer journeys—”I need to update my withholdings” or “I’m checking my refund”—not org charts.
Measure what matters: time-to-file, satisfaction scores, error rates, not only compliance metrics. Internal Objectives and Key Results planning makes priorities clear and syncs the organization towards focused goals. Publish Service Level Objectives on external products to ensure we target creating systems that others can confidently rely and build on.
Give full-stack product teams the authority to make integrated technical, design, policy and legal decisions together. Staff these teams with internal technologists embedded alongside accountants and lawyers in functional organizations, building IRS competency while reducing contractor dependence. Today’s IRS is highly siloed across functions with authority so fragmented it’s unclear who “owns” what. Yet go to any top tech organization and you’ll see what we’re pushing for: aligned and cross-functional teams whose job is delivering with clear ownership. Inherently we’re pushing for more than a new team, we’re factoring out unclear ownership in general away from IT and Business Divisions.
When teams own outcomes, we can better ensure taxpayer experience transforms from painful to painless.
API-first architecture
The IRS is fundamentally a data organization, yet information flows through siloed systems that can’t talk to each other. Amazon solved this with a simple mandate: all teams must expose their data and communicate through APIs. (This mindset set in motion the seeds of Amazon Web Services, the company’s most profitable division).
The IRS needs the same revolution.
Every team exposes data and functionality through standardized REST APIs—no direct database access, no per-department clones of the data, no exceptions. Design every API to be externalizable (with strong access controls) from day one, unlocking government APIs to become platforms for innovation. When systems communicate through versioned APIs instead of tangled dependencies, teams can ship improvements daily without compromising everything else. This isn’t just technical architecture—it’s how modern organizations move fast without breaking things.
The People
Cultivate it, Don’t Outsource It; Build a Delivery Culture
A digital IRS that delivers for Americans cannot be built by the lowest bidder. Its core capability isn’t digitized forms–it’s people who can understand taxpayers’ needs, imagine solutions, design thoughtfully, ship them fast, listen to users, and keep improving based on feedback.
Silicon Valley understands this instinctively on two fronts. The fight for great engineers is the fight to build teams that can deliver great products. And two, no leading tech company outsources its own R&D. Delivering well-functioning and beloved products requires tight ownership of the product iteration loop.
Businesses long learned to never outsource a core competency. OpenAI would never outsource the training of its models, Apple its industrial design, Google its search algorithm, or Facebook its social graph. The same should be true for the IRS.
Yet, despite accepting 93% of its tax returns digitally, it still does not consider itself to be a digital-first agency. Building great teams is inseparable from building great taxpayer experiences. For decades, the agency has outsourced its technical mission and vision.
What we witnessed at the IRS was often vendor theater. Consultants transformed routine meetings into sales presentations that should have been dedicated to improving the products. Solutions specialists added layers of proprietary middleware, despite readily available enterprise-grade open source solutions running on commodity servers could easily meet the objectives. All of this unfolded within an organizational culture where securing contracts took precedence over delivering meaningful outcomes. Contracts that, of course, cost multiples more than the price of a competent internal team.
Commodities like cloud infrastructure or off-the-shelf software that serve broad, generic needs should absolutely be acquired externally. But the IRS’s critical, taxpayer-facing products—the systems at the heart of filing, payments, and taxpayer accounts—must be built and owned internally. There is only one agency that collects taxes for the United States of America.
When everything is handed to vendors, the IRS sends more than money out the door; it loses institutional memory, technical craft, quality systems, and the ability to move quickly. A modern IRS cannot be built on rented skills.
Talent: Build a Permanent Product Core
This transformation starts with the people: build and keep an in-house corps of top-tier technologists—engineers, product managers, designers, user experience researchers—working in small, empowered, cross-functional teams hand in hand with fellow IRS accountants, auditors, customer service representatives and lawyers. Not a handful of digital specialists scattered in a bureaucracy as it was, but several hundred people whose full-time job is delivering and evolving the IRS’s core taxpayer experiences and services.
- Create a dedicated Digital Profession inside the IRS, led by a Chief Digital Officer with the authority to hire, fire, and shape teams and technology stacks.
- Break the straitjacket of outdated civil service rules by creating specialist pay bands to compete for top talent like the CFPB has done.
- Empower cross-functional teams to ship without endless escalation. Start small, test early, iterate quickly, and make product decisions by those close to the work.
Funding: Invest in Teams, Not Projects
Current funding locks the IRS into one-off projects that end when the money runs out, leaving no path for iteration. A product-centered IRS needs enduring funding for enduring teams. Long-lived services, not short-lived milestones. This should be no surprise for a tax organization. There are two certainties in life; death and taxes. We should properly set ourselves up to manage the latter.
- Fund continuous development rather than one-and-done “delivery.”
- Tie funding to taxpayer outcomes like faster filing, fewer errors, higher satisfaction, instead of compliance checklists.
- Secure multi-year budgets for core product teams so they can improve services year-round, not scramble for appropriations each cycle.
This shift will reduce long-term capital costs and ensure that every dollar invested keeps improving the taxpayer experience.
Quality & Standards: Build Once, Build Right
Owning our products means owning their quality. That requires clear, enforceable service standards, like performance, usability, scalability, and accessibility, that every IRS product must meet.
- Establish service performance benchmarks and hold teams accountable to them. These should be highly taxpayer centric; time to file, support response time, ease of use.
- Create communities of practice inside the organization to share patterns, tooling, and lessons learned across the agency.
- Apply spend controls that tie contract renewals to measurable outcomes and prevent redundant vendor builds.
Culture Eats Strategy: Time to Invest in a Delivery Culture
“Culture eats strategy for breakfast,” as Peter Drucker famously said. Yet government agencies too often treat culture-building as off-limits or irrelevant. This is backwards. Creating a shared, collaborative culture centered on delivery isn’t just important; it’s the foundation that makes everything else possible. The hardest and most critical step is investing in people. Give employees space to collaborate meaningfully, contribute their expertise, and take ownership of outcomes. Leadership must empower teams with real authority, establish clear performance standards, and hold everyone accountable for meeting—or exceeding—those benchmarks. Without this cultural shift, even the best strategy becomes just another plan gathering dust.
When every product meets the same high standard, trust in the IRS will grow—because taxpayers will feel it in every interaction.
A template for all agencies
The IRS touches more Americans than any other federal agency–making it the perfect proof point that the government can deliver digital products that work seamlessly. The principles–build for users, not compliance, shipping daily, not yearly, and keeping the talent in house is not unique to the IRS.
We believe these goals and strategies apply to nearly every agency and level of government. Imagine Social Security retirement planning tools that lead to easy withholding adjustments, a Medicare/Medicaid that is easy to enroll in, or a FEMA with easy to file disaster relief disbursement.
Transform the IRS this towards this path, and then use these lessons to reset and lift up expectations between Americans and their government. One so easy citizens say: “That was it? That was easy.”
Trust Me: What’s a High-Trust Government Look Like?
American trust in government institutions is at historic lows. Throw a stick at a workshop, op-ed, or white paper on state of governance today and you’ll run into a worrying statistic about trust in public institutions. The pervasiveness of this worry makes sense: the legitimacy of democracies relies on trust. Lower trust means every program, every public benefit, every crisis, every investment is just that much more difficult, if not impossible; the flywheels of low trust weakens government capacity for everyone.
But here’s the thing: what if low trust was not a given? Or, said another way: what if we had the power to improve trust in government – what would that world look like?
After studying trust in government for years, one of my top concerns is that we have simply accepted lower trust as a fact of life and, worse than that, irreparable. That declining trust in government is simply seen as an acceptable cost for Americans – a notoriously skeptical bunch when it comes to government – and perhaps we’re a little proud of it. This is concerning for all kinds of reasons but at the top of my list: it lets government (and everyone else!) off the hook.
Trust is complex and there is no one simple fix to permanently reset the relationship or shift the trendline between government and people. But that does not mean it’s off limits. I believe it is possible, but more importantly, I believe it is worthwhile to improve trust and trustworthiness in government
What could high trust (and trustworthiness) in government institutions yield? Better public health outcomes (higher trust leading to greater willingness to follow public health directives, like vaccines). Greater flexibility to navigate complex public challenges (greater trust leading to willingness to accept risk and endorse innovative approaches). Wider participation in public programs (and public program design), leading to more effective and representative services that achieve their intended impacts. Better ability to manage crises (public willingness to turn to central point of information for direction). Potential for fewer transaction costs or compliance barriers (put in place to mitigate low trust levels). Greater civic participation.
At the recent workshop on the future of trust in government hosted by the Federal of American Scientists, we explored the nature of trust in specific government functions and what the worse case scenarios of trust might be, but we also specifically addressed what good might look like.
Approach and Methods
The “Future of Trust” workshop brought together government capacity experts to examine how trust operates within specific government functions, the risks and consequences of its erosion, and what it would take to rebuild. Recognizing that trust in government is not generic, participants explored how Americans’ varied encounters with federal systems (such as hiring and talent management, data collection and reliability, procurement, and customer service) shape their perceptions and engagement. The group considered potential first- and second-order impacts of changing trust, early indicators that key thresholds may be at risk, and strategies for either restoring trust or adapting to a new reality. The discussion was grounded in the context of significant federal changes in management functions and larger trends imparting them.
While catastrophic breaking of trust can serve as both a cautionary tale and context for reform, genuine improvements can demonstrate why caring about trust and trustworthiness should be a north star for public sector organizations. To keep ourselves from falling into the depths of despair (and to recall why this work matters), we asked key functional areas in government would look like if they engendered high trust? Or, in other words: is building trust in the federal workforce, federal procurement systems, public sector customer experience, and federal data systems worthwhile?
Below are the four best case scenarios generated at the workshop, summarizing the best case scenarios for trust each of these functional areas.
Great Public Service is the Defining Image of American Governance
Imagine a future United States where public service is a dream opportunity and a top destination for talent at all levels. College students and young professionals aspire to join, knowing they’ll find meaningful work, fair treatment, and opportunities to build diverse lifelong careers based on the experiences they gain. Mid-career professionals move easily between government, academia, and the private sector, enriching federal expertise without stigma or political baggage, and impacting other sectors with their public-benefit mindset. Public servants are celebrated as heroes: not just astronauts or diplomats, but patent examiners, social security field officer workers, and climate analysts. Pop cultures elevates the everyday work of government as essential, positive, and valued, and audiences are exposed to a wide range of public service missions in film, TV, literature and more. People are motivated to better understand the diverse roles of government, and the public sees and feels the government’s responsiveness in their daily lives through their engagement with civil servants of all kinds.
Congress treats workforce issues as foundational to national strength, supporting reforms that sustain a professional, accountable, and diverse civil service. Systems of accountability ensure power is used responsibly, building confidence in government safety and fairness. Flexible hiring and a reliable stream of talent allow agencies to focus on long-term excellence rather than constant reinvention.
As a result, the federal government becomes one of the most competitive sectors (federal internships are career launchers; federal experience is a resume enhancement). The U.S. sets a global standard for how a trusted, high-performing workforce can underpin democracy. Pride in government work spreads outward, creating a virtuous cycle in which esteem, talent, and outcomes reinforce one another: people want to be on the winning and admired team. Great people doing great work, visibly and with integrity, become the defining image of American governance.
Federal Procurement is a Driver of Public Trust
In a world where trust in federal procurement is high, it’s widely recognized as one of government’s most powerful levers for delivering public value. Agencies consistently prioritize best value, ensuring that contracts translate into real improvements for people’s lives.
Procurement choices reflect thoughtful strategy and agencies clearly distinguish what must remain core government work from what can be outsourced. Institutional and technical expertise is fully integrated into the acquisitions workforce, making government a smart, discerning buyer that understands both the risks and the opportunities of each decision.
Transparency and clear communication are the norm, with citizens and Congress able to see how contracts are awarded, what outcomes are promised, and whether those outcomes are delivered. Confidence grows that procurement serves the public. Over time, procurement becomes a driver of trust: government dollars are seen to consistently buy not just goods and services, but fairness, innovation, and better outcomes for the American people.
Trustworthy Customer Experience is a Core Democratic Value
A world with high trust in federal customer experience has services are so effective, intuitive, and respectful that they become a source of national pride. Citizens never stand in long lines, wrestle with redundant forms, struggle with translations, wonder if their information is secure. Eligibility, verification, and delivery are proactive, straightforward, and seamless. Co-design is a given and people feel they have a role in shaping the services they receive. Every interaction feels human-centered, affirming dignity rather than imposing burdens.
This transformation is backed by strong political interest and political will. Recognizing their duty and role, Congress passes outcomes-based legislation, trusting agencies to determine the best delivery methods and iteratively measuring success by results, not process. Bipartisan support sustains investments in modern service delivery, while spending is transparently tied to clear and easy to understand metrics that are tracked, shaped by, and shared with the public.
Trust grows as effective services demonstrate government’s capacity to deliver on promises. Civic participation expands as people see their input reflected in co-designed services. Authentic, two-way communication reinforces this trust, showing that government not only serves but also listens. Over time, customer experience becomes a core democratic value: a system where outcomes are clear, accountability is real, and government simply works beautifully for the people it serves.
The Federal Data System is the Backbone of Democracy
Data underpins a government that is responsive, accountable, and anticipatory. Citizens no longer repeat the same information across agencies, with an “ask once” environment ensuring seamless, user-centric service. Secure and interoperable systems give government real-time insight, enabling proactive responses to emerging needs and building trust through visible speed and accuracy.
Data careers thrive inside government. Staff are recruited for their analytical and stewardship expertise, with robust pathways for career development. A diffuse community of data talent across academia, private industry, and civic tech reinforces data literacy and feeds a pipeline of skilled professionals into federal service. Government becomes a best place to work for data experts who want their skills to have national impact.
The public data ecosystem itself is diversified, reducing risks of manipulation by spreading data sourcing across suppliers. Public participation in data generation strengthens trust and relevance. Shared factual foundations guide decisions, ensuring policy debates are grounded in evidence rather than misinformation, and science agencies, service providers, and policy offices all benefit.
Conclusion
Feeling inspired? Take another deep breath – this workshop wasn’t about painting a utopia, but about imagining what’s possible when trust in government is built and sustained. What should stay with you is that trust isn’t an abstract ideal; it’s the foundation that enables strong workforces, smarter procurement, seamless services, and data ecosystems that keep government responsive and accountable. And while no single reform flips a switch to “high trust,” together they can create a virtuous cycle of legitimacy, performance, and pride. What we can do is this: as the government capacity community designs reforms and innovations, they can embed trust as both a principle and an outcome (how? Part three of this series will dig into concrete strategies!). These scenarios aren’t predictions but tools to chart the upside of reform, helping us see how investment in people, processes, services, and data can make government stronger.
Broken Trust in Government: Signals and Worst Case Scenarios
American trust in government institutions is at historic lows. That’s a known known and a long term trend. But while experts are right to worry about the trajectory of such trust in public life, this diagnosis is broad and hard to rectify given the broad spectrum of roles the federal government plays in American life. Trust in government is not generic–the way Americans encounter and engage government systems can vary significantly. At a period where the federal government is undergoing significant changes in how it hires, buys, collects and organizes data, and delivers, deeper exploration of trust in these facets as worthwhile.
At a recent workshop hosted by the Federation of American Scientists, we explored the nature of trust in specific government functions, the risk and implications of breaking trust in those systems, and how we’d known we were getting close to specific trust breaking points. The scenarios we developed were not only meant as cautionary tales, but to serve as reference foundations to plan against for any future reform efforts, should trust continue to decline generally or specifically. Experts considering reforms and improvements to key government functions may additionally need to take into consideration whether and how stakeholders will re-engage with low-trust systems, or how to grapple with second and third order effects of trust declines like growing non-governmental alternatives. For example, reforms to the federal talent management system could need to adapt to a world where Americans do not trust that civil service is a durable career path, or do not trust that hiring is nonpartisan.
What do we know about trust in government and why does trust matter
Trust in government has been on a downward trend in not only the United States but many democracies worldwide. Citizens bring good reasons for their decreasing trust–government response to disasters, approaches to transparency and accountability, profound historic inequities, disparate beliefs on the role of government, and much more–and many government leaders take these trends seriously. Scholars have considered the consequences of low trust through many lenses, but the short version is the legitimacy of democracies relies on trust. Lower trust means less engagement with functions that government performs uniquely or drives, whether disaster response, weather warnings, federal benefits, security functions, public health, or independent data collection and analysis–and that lesser engagement means those functions work less well for everyone else. This has a cascading impact as democratic institutions weaken when government cannot, does not, or is not believed to deliver on expectations of its citizens.
Approach and Methods
The “Future of Trust” workshop at the Federation of American Scientists brought together government capacity experts to examine how trust operates within specific government functions, the risks and consequences of its erosion, and what it would take to rebuild. Recognizing that trust in government is not generic, participants explored how Americans’ varied encounters with federal systems (such as hiring and talent management, data collection and reliability, procurement, and customer service) shape their perceptions and engagement. The group considered potential first- and second-order impacts of declining trust, early indicators that key thresholds may be at risk, and strategies for either restoring trust or adapting to a new reality. The discussion was grounded in the context of significant federal changes in management functions and larger trends imparting them.
Despite breakouts into the four different functional areas, there were several common and intersecting attributes of possible broken trust worst case scenarios, including:
- Greater citizen disinterest in engaging government, more “opting out” which lowers quality of public services and goods
- Increased cynicism about government
- Disconnect between commitments or public statements and reality
- Erosion of expertise and capacity in government
- Increase in seeking non-government alternatives that do not serve all
- Failure to deliver intended services
- Increased partisanship
- Increased bias or corruption, or perceptions thereof
Overall, participants anticipated a cycle of declining trust, leading to a hollowing out of government capacity and expertise, which in turn would result in a failure to deliver essential services effectively, further eroding public trust and fostering widespread cynicism and disengagement. Sounds like something we should take a look at!
Workforce
What do we know about trust in the civil service?
The limited research available American’s understanding of and feelings about the federal civil service is complex. In 2024 surveys by the Partnership for Public Service, Americans demonstrate overwhelmingly strong beliefs in the importance of nonpartisan civil service our democracy, and that politicization of the civil service does harm to government effectiveness (even among those who support cuts to the Federal government). But feelings on federal workers themselves are split: just over half of of Americans belief their civil servants are competent and committed to helping “people like me.” In similar 2022 research, other positive qualities have a comparable breakdown (such as “hard-working” or “committed to public service” in research by the Partnership, and “great deal or a fair amount of confidence” in research by Pew). As a rule, however, views on federal workers are more positive than on the federal government itself. As for why federal workers choose to serve, the majority of Americans surveyed believed serving their communities was a key factor (57%)–but far more believed it was job security (77%).
Based on recent and significant changes to policies around federal hiring and civil service protections, trends around politicization of the federal workforce, and the significant cuts made via reductions in force and other workforce shaping initiatives, we wanted to better understand things like:
- If Americans’ trust in the federal civil service as a promising career path changes, how might that impact the United States ability to recruit the government workforce it needs?
- If Americans trust that federal workers are hired and retained based on merit and performance change, how might that impact American’s engagement with government?
Participants considered scenarios where trust in the civil service as an institution and employer improves significantly and where trust breaks down, and outlined specific attributes they would anticipate in both best and worst cases. For the worst case, participants were concerned about cascading effects on recruitment, performance, public perception, and the ability of government to function effectively.
- An American public that does not believe the civil service has an important government function therefore does not want to use, or participate in it
- Lack of interest by outstanding candidates in federal jobs, resulting in no experts available for relevant policy issues.
- At the same time, the “covenant is broken” around stability versus pay, meaning no one wants to work in the government for what it pays if stability dissolves.
- A lower esteem for service careers would mean a large group of Americans held in contempt and poorly treated by communities. The government would become “an employer of last resort”.
- People are convinced that the federal workforce is hyperpartisan. There would be widespread pervasive cynicism about corruption.
- Civil servants themselves would lose grip on whether their work can even be done in a non-partisan way. The federal workforce would be perceived as “full of partisan hacks”.
- Expansion of the political staffing system and a widespread use of “Schedule F” would allow a majority of staff to be hired and fired with each administration. Turnover creates huge, unmeetable burden and perpetual gaps: work simply cannot get done.
- Cycle of increasing distrust would increase because the link between the workforce and results for citizens breaks down. There is widespread decline in effectiveness, leading to a less safe, lower quality of life, and less prosperous nation. Major scandals on accountability, due to people not knowing their jobs and/or a failure to deliver services, builds on the negative stereotypes and stigmas about government work would become true. This leads to mistreatment of current public employees.
- Congress would “never decide to care about the fed workforce,” with negative polarization against reform making it impossible for the civil service to recover.
What falling trust in the federal workforce may look like in practice
Trust is obviously a fungible and flexible concept, changing both based on context and individual experience–participants did not imagine a bright line between overarching trust and distrust. With that in mind, we considered key signals that might indicate that breakdowns in trust, or negative consequences from such, are growing more likely. These signals range from shifts in hiring patterns and workforce composition, to declines in service quality, to more visible public and political hostility toward civil servants. Together, they provide early warning signs that the relationship between the public and its professional government workforce is fraying. For example:
- Decreased numbers of applications to civil service roles, fewer applicants for mission-critical jobs, and fewer young people accepting and starting federal jobs
- Increasing applications / interest in government support contractor roles
- A shift in the ratio of first-time applicants versus repeat applicants for federal jobs
- Negative results from Federal Employee Viewpoint Surveys (FEVs)
- Unusual staff promotions or inappropriate leadership appointments
- Increased number of Schedule F appointments
- First and major second rounds of firings of Schedule F employees for questionable charges
- Major second rounds of voluntary departures
- Repeated extensions of hiring freezes
- Increased threats against or attacks on public servants
- Increased diversion of money or resources to contractors for previously governmental functions
- Less diversity in the federal workforce
- Noticeable changes in service quality, particularly related to workforce-heavy fields on front lines and measurable decreases in customer trust or service experiences
- Negative profiles of public servants in press or media
- Negative mentions of public servants in congressional record
- Decrease interest in pipeline programs (PMF, Marshall Scholarship)
- Decrease in applications to Master of Public Policy (MPP) and related educational programs
- Decrease in outreach to contact centers (as trust in civil servants to respond appropriately declines)
- Increase in private service providers who concierge government services (as trust in civil servants to deliver declines)
- Corruption scandals and higher incidence of corruption or crime by federal employees;
- Scandals related to accountability of staff due to loss of expertise (e.g., FEMA issues or misuse of funds)
Procurement
What do we know about trust in government procurement?
There’s little explicit research on American views on the U.S. government as a trustworthy business partner, or its ability to effectively procure goods or services. One can take signals from things like participation in the federal market (generally competitive but with declines in both prime contractors and small businesses, and greater concentration in vendors) and attempts to shape its policies and procedures (active), but that only addresses specific trust audiences. Similarly, bid protest trends may be an indicator of views on the system; these have declined by 32% in the last decade. With close to three-quarters of a trillion dollars are spent on contracts annually–more than double federal worker compensation–American views on waste may be relevant. Partnership research says 85% of Americans believed the government to be “wasteful” in 2024, up 15 points from 2022, with 74% believing it is corrupt. These signals are concerning but not necessarily a clear critique of federal procurement. While these are weak signals, what is clear is that procurement can be a significant vehicle for trust building: transparency, integrity, fair decision-making, and effective public outcomes from procurements are public mechanisms with the capacity to demonstrate accountability and trustworthiness.
Procurement processes, outcomes, and participants are always evolving, but recent trends (growth in AI) and events (contract cancellations and overall greater scrutiny early in the Administration, alongside the well-received streamlining Revolutionary FAR overhaul) made us want to better understand the implications of changes to procurement trust landscape. What if, for example, American businesses’ trust in the reliability of government contract agreements shifts? What impacts does that have on the federal government’s ability to buy and outsource?
Participants considered scenarios where trust in the federal procurement improves significantly and where trust breaks down, and outlined specific attributes they would anticipate in both best and worst cases. In more negative scenarios, participants projected the risk that procurement systems would be hollowed out, captured by private interests, or stripped of the government expertise, fairness, and accountability needed to serve the public interest. Some imagined outcomes:
- The market would become so consolidated that only one or two businesses could deliver anything.
- Everything is privatized and contracts are not managed, with nobody in-house to buy or manage complex contracts, and a complete lack of technical expertise within the government (“Who still knows how to build ships?”).
- The business community would define what services are needed, not the government, and these services would not be tied to strategy or mission.
- The government would be completely overshadowed by consultants, lacking the capacity or skill to be a good partner with contractors.
- The contracting process would devolve into a spoils system, becoming more and more unfair, with insidious corruption.
- There would be a major diffusion of accountability or responsibility, leading to no trust in public service provision, and political leadership could allow contractors to take the blame. This would manifest as a “procurement version of nepotism”.
What falling trust in federal procurement may look like in practice
We also considered key signals that might indicate that breakdowns in trust, or negative consequences from such, are growing more likely. Participants suggested monitoring things like:
- Changes in the number of bids/proposals received
- The share of awards going to non-incumbents, new entrants, small business enterprises, or disadvantaged business enterprises (DBEs), as well as the time it takes to get the first award
- A lack of variety in who is getting subs or supplier contracts
- An increase in contracts for things that are inherently governmental
- Decreasing technical capacity within the government
- Scores on vendor performance evaluations
- More “sign-and-forget” contracting
- An increase in contracts awarded to donors
- A decrease in the degree to which the government acts as the integrator
- Contracts that do not provide what they are supposed to
Customer Experience (CX)
What do we know about trust in government services?
Successive administrations have sought to increase and rebuild trust in the federal government through improvements in federal services. These efforts have born out: several measures have shown positive public views of federal services (e.g., the Partnership’s research finds around 75% or more are satisfied with individual services), and in 2024, the American Customer Satisfaction Index showed citizen satisfaction with U.S. federal government services reaches the highest level since 2017, with recent growth surpassing private counterparts. One example: the IRS’s Direct File free tax filing service.
Federal service providers with the greater number of customer interactions are required to collect and monitor post-transaction customer feedback, including views on trust and drivers of trust, and for a period these were shared in a public dashboard. Overall, about half of services reported that a significant majority of customers (75% or more) trusted the relevant agency, with primary drivers of such trust being service effectiveness and ease. Such data is used by agencies to evaluate and improve services, and across services to identify trends, risks and opportunities across common services. The Office of Management and Budget Customer Experience Team makes the strongest case why this work on trust matters in their explainer:
When individuals feel high levels of trust, they are more likely to seek out information from the government, access services, and use benefits they are eligible for. To support the goal of increasing trust in service providers, and the government overall, HISPs (high impact service providers) are required to collect and report trust data, and use customer feedback to continuously improve services.
The current administration has not pursued the same emphasis on customer service yet, but has recognized it as a critical factor for agencies to prioritize in their reform initiatives and committed to eliminating waste and fraud from such programs. At the same time, they have cut or curtailed initiatives once aimed at improving trust, such as field office and contact center availability at the Social Security Administration, or free and streamlined tax filing services. With the clear link between trust and impact, we wanted to better understand implications of changes in trust to federal services, exploring questions like: what if Americans change their views on whether applications for benefits and services are adjudicated fairly? What if Americans believe that services will be sustainably and reliably available for themselves, but not for their communities?
Participants considered scenarios where trust in the federal services improves significantly and where trust breaks down, and outlined specific attributes they would anticipate in both best and worst cases. In more negative outcomes, participants projected that federal services would become fragmented, inequitable, and alienating—eroding participation, driving people toward alternative providers, and deepening the gap between public expectations and the government’s ability to deliver, with attributes like:
- Rhetoric and public perception would not match the actual quality of service
- A developing trust divide would emerge among different users of federal programs, with people living in different realities regarding the quality of government CX based on the services they use
- A worsening government CX experience would also drive down other forms of political participation.
- People would withdraw from government participation (e.g., not providing info, lower uptake of services, stop paying taxes).
- People would shift their reliance to nonprofits, community-based organizations (CBOs), and intermediaries, further straining the system. This would undermine support for investment in government services.
- There would be confusing changes to services (e.g., changes to phone service at Social Security).
- Customers would be more prone to fraud or scams from external parties amidst confusing changes.
- There would be uncertainty about the status or future of programs.
- Structural barriers to access and opportunity would remain unaddressed.
- It would become easier for the government to collect unnecessary data, which would violate privacy and undermine trust.
- Trust would be exploited without real power-sharing, leading to “participation fatigue”.
- Digital-first or digital-only transitions would worsen access gaps.
- Speed and efficiency (perhaps through AI) would undermine due process and human review. “Efficiency” would lead to diminished capacity to deliver services.
- Mass departure of civil servants with decreasing faith in their own ability to be effective, crashing many programs
What falling trust in federal service delivery may look like in practice
We also considered key signals that might indicate that breakdowns in trust, or negative consequences from such, are growing more likely. Participants suggested monitoring things like:
These are indicators irrespective of performance, though may be linked to performance
- Sharply reduced uptake of government services (e.g., drop-offs in SNAP, Medicaid)
- Walmart quarterly earnings (indicating SNAP use is down)
- Reduced tax compliance
- Increased college drop-out rates (FAFSA utilization)
- Surges in negative media coverage and inaccurate narratives
- Increased traffic in Reddit forums for federal programs/agencies
- Spikes in constituent complaints to Congress regarding government services
- Increases in congressional casework data and application volumes
- A dearth of knowledge regarding the collection, usage, and reporting of data
- Weaponized customer data
- Violence perpetrated against and/or by public servants
- Staff loss at critical service delivery entities
- Reduced employee engagement and an increase in whistleblower complaints
- Increased charitable giving (as people turn to non-governmental support)
- Increased demand for non-government support services
- New private businesses concierging or replacing government services
- Decreased funding for government services (unrelated to delegation to states)
- Increases in shelter censuses
These indicate lower performance
- Long waits, overwhelmed call centers, and longer appeals processes
- Increases in error rate data for programs like SNAP or SBA loans
- Higher denial or error rates based on zip code, geography, race, income, etc.
- Institutional regression, a return to compliance over outcomes (focusing on KPIs only related to speed/volume)
- Increases in Social Security Administration and other backlog measures
Data
What do we know about trust in federal data?
One of the hallmarks of the extensive federal data and statistical apparatus is credibility. Government and economic institutions rely on data the federal government collects, analyzes, and publishes for decisionmaking from spanning interest rates to hurricane evacuations; public health institutions provide and rely on insights from the federal government for basic care to pandemic preparedness. The more than 300,000 data sets in the federal data ecosystem generally have few substitutes and underwrite, in some form, every sector in the country. With that mandate–and pressure–major federal statistical program have historically taken pains to both showcase and increase transparency in their methods, though not without criticism.
Despite its import, trust in federal data systems are hard to measure–many Americans do not access them, or realize their ubiquity and relevance. Still, a recent NORC-Amerispeak survey found that 57% of Americans tend to trust federal statistics, with majorities also believing that policymakers and businesses rely on federal statistics to make decisions, stable with 2024 findings. Despite these results, half also have no view on whether federal statistics are biased. The Partnership’s research shows that in 2024 only 15% of Americans believe the federal government is transparent (a measure that has been on the decline since they began their research in 2022). When asked specifically about agencies known to have major data missions (Census, CDC), majorities have favorable opinions. That said, some studies found significant declines in confidence in public health institutions during the pandemic (though still with small majorities) and partisan splits on the role of science in policymaking.
The Trump administration clearly recognizes the power and influence of the federal statistical ecosystem, having highlighted the need for high quality data and a strong data infrastructure in the recent AI Action Plan release. But it also applies that understanding to removing or changing datasets that do not align with their perspectives and priorities. These moves have generated significant criticism from data customers and champions, who have banded together to preserve key components outside government. While there is indication that published federal data and statistics are less trustworthy, the firing of the Bureau of Labor Statistics Commissioner based on jobs reporting raised significant alarm, as have stated plans to review and make changes to the federal jobs report process. With these major disruptions, we wanted to better understand the potential implications to changes in trust in federal data, and explore questions like:
- What might the impact be of changes to American trust in public health data accuracy, or or ability to warn of public health concerns?
- If American trust in science data is divisive across partisan or other lines, what are the potential impacts?
- What if Americans are distrustful of the Census in disparate ways?
Participants considered scenarios where trust in the federal data ecosystems improves significantly and where trust breaks down, and outlined specific attributes they would anticipate in both best and worst cases. In the most negative scenarios, participants projected that, the federal data ecosystem would lose its integrity, accessibility, and public purpose, becoming politicized, biased, and unevenly available. Possible outcomes include:
- Data integrity is politically compromised or punished.
- Policy that relies on statistical ecosystem is or seems untethered from reality
- Private actors would be able to enter the market and stratify who can afford access to high-quality data
- Increased purposeful and inadvertent bias in federal data sets and products.
- AI that draw from government data would be built on biased data.
- The government would no longer produce data as a public good.
- Skewed analysis reinforced by changing underlying data, making it impossible to challenge outcomes.
- Continued partisan split about purposes and outcomes of data.
- Destabilization in sectors where the federal government typically fills a market gap.
- Weaponization of data to undermine civil society and human rights.
- Government develops an “information panopticon”.
What falling trust in the federal data may look like in practice
We also considered key signals that might indicate that breakdowns in trust, or negative consequences from such, are growing more likely. Participants suggested monitoring things like:
- Changes in updates to data repositories and clearinghouses
- Delays in provision of govt-provided data
- Reduction of access to archives
- Skinnier and federal data based publications
- Government releases data that is flawed
- Government gets caught abusing/misusing data;
- Clear or tacit service quality decline
- Government relies on AI for reporting typically based on federal statistical systems
- Participation rate going down in federal data collection
- Data on government performance and oversight disappearing, such as accountability data, Office of Personnel Management data, usaspending.gov, and social security performance data
- More private sector entrants into data brokering market
- Private alternatives of typical federal data systems are launched
- Breaches of privacy laws (Title 13, 26, Privacy Act)
- Increased political oversight or pre-publication review of science and data publications
- Budgetary changes to federal statistical systems and data / evidence work
- Staff departures in federal statistical and evidence roles
- People feel like their lived experience is really different from what government shares
- Divergent results from private and public sources
- Backsliding on Evidence Act Implementation
- Backsliding on data modernization efforts
- “Sharpie scenario” redux across datasets (political interference in data-driven predictions and reports)
- Incidents where good-government groups are calling out government integrity, credibility, transparency
- Declining FOIA response times regarding federal data ecosystem
Worried yet? Take a deep breath–this workshop was meant to help experts like you plan and prepare, not predict the future (ok, maybe worry a little). What should stay with you is that trust is the bedrock of many vital functions in government, and while such trust can weather variability, trust breakdowns have consequences. And, critically there’s no bright line that will suggest when that shift starts or cascades. What we can do is this: As the government capacity community dreams up reforms and improvements to key management and operating systems, they can bake in considerations of trust to their proposals (how? Part two of this series will offer some ideas!). The scenarios and signals are tools for anticipating and navigating the complex realities of governing in an era where trust cannot be taken for granted. They highlight the need for reform strategies that are resilient not only to technical and operational challenges, but also to shifts in public perception, political dynamics, and the broader ecosystem of service and data providers. By grounding reforms in an understanding of how trust is built, eroded, and rebuilt, and by preparing for the downstream consequences of its loss, leaders can design systems that remain effective, legitimate, and connected to the people they serve.
Direct File Is the Floor, Not the Ceiling
And the Direct File product model approach shouldn’t just be for product teams, but all teams
Once a year Code for America brings together 1000+ of the most curious, forward thinking public sector minds at their annual Summit. Teams from across the country, from the federal, state, and local governments come together to discuss tangible ways to have a greater impact on their communities and constituents.
I was asked to give a talk on what lessons organizations can learn from my experience working on Direct File – the IRS’s beloved, free, online tax filing service – and how governments at any level can embark on greater digital transformation. You can check it out.
As you can tell, I’m proud of what our team accomplished with Direct File – but going forward, services similar to Direct File should be the bare minimum that government agencies offer. We proved that excellent digital experiences are possible in the federal government and the Direct File playbook can be adapted for not just new services, but the approach is applicable to wider agency transformation. The key plays – prototyping from day one, relentless user focus, empowering teams and holding them accountable for mission-level outcomes – are transferable not just from a product launch, but also to support agency modernization.
What can we learn from Direct File?
From my vantage point, Direct File success story offers both inspiration and frustration. First, the inspiration:
With satisfaction rates higher than Apple or Netflix and an 86% increase in trust for the IRS (PDF), Direct File proved that government can deliver excellent digital services by following this playbook:
- Prototype, even when you don’t think you’ve got a shot
- Appoint a single service owner
- Obsessively put the product in front of users with all different abilities – every day
- Build an in-house team that is both technically savvy, and in this example, tax savvy
- Build a service team – join up product and customer support so you have a continuous, real time feedback loop
- Use product data to inform product updates and reduce errors (in this example, the number of rejected returns submitted)
- Skip flashy launches in favor of actually helping people and their experience with government services.
This wasn’t a playbook that was handed to us. The Direct File team empowered itself without waiting for permission and ultimately demonstrated when you have when you bust through siloes, anything can be possible in government.
Now, the frustration:
This success – a successful, high stakes launch of a complex tax product that people loved – highlighted a painful truth: excellent products alone don’t transform institutions.
Despite Direct File’s achievements, it remained largely isolated within the broader IRS ecosystem. It was bolted onto existing systems rather than fundamentally changing how government operates. The public interest / civic technology sector has spent a decade of launching brilliant services and building strong teams and yet, the pattern remains the same – we create adjacent solutions without addressing the underlying institutional problems. With only 22% of Americans trusting the federal government to do the right thing, this incremental approach is no longer sufficient.
The path forward requires thinking bigger and going beyond the margins. Direct File should be the floor, not the ceiling – the bare minimum standard for government services. We need leaders who understand that government is fundamentally a software organization operating within bureaucracy built before telephones existed, and who are curious to explore how to run an entire agency with the same user-centric, technology-strategic approach that made Direct File successful. Technology and excellent user outcomes must be viewed as a strategic imperative at the highest levels, not an afterthought left to a silo within a large organization.
Building the future, today
While the chaotic ransacking of federal programs and firing hundreds of thousands of employees is no longer making headlines and seemingly slowed down come to an end, the principles of the so-called Department of Government Efficiency (DOGE) will likely persist. Budget cuts will further constrain already constrained organizations.
Now, as a traumatized federal workforce is left to pick up the pieces of a government that was already in a precarious position pre-DOGE, the question is how can the government deliver for users in the future? Not just replace the capacity we’ve lost, but build a new infrastructure for federal employees to deliver real improvements for Americans that is relevant and resilient in the modern era?
Starting immediately where feasible, and with a vision for what’s possible, we should focus on building better institutions rooted in service to contemporary constituents. To do this we must start thinking of our institutions as places where, to use a software term, there is continuous improvement built in from the get-go.
Right now, I’m connecting with people who believe this is possible and necessary. We come from a diverse range of perspectives but we are all excited about exploring new operating models, theories of change, and building effective government services. We are all focused on providing tangible and ambitious new structures and services that can be implemented given current constraints, and hopefully built upon in the future.
Direct File showed that government can deliver in a new way that increases trust and raises expectations. Giving up on this momentum and progress is not an option – people rely on their government and will continue to do so in spite of whatever disdain elected officials may have for those who design and deliver those services.
As I said in my Code for America talk “The first rule of government transformation is: there are a lot of rules. And there should be-ish. But we don’t need to wait for permission to rewrite them. Let’s go fix and build some things and show how it’s done.”
We cannot afford to lose the progress we’ve gained, the lessons that have been learned over decades – and we can’t wait to take action. Connect with us to share your ideas where we can use technology and modern product led approaches to improve not just government service delivery, but also how we can reimagine how government works, now.
Federal Climate Policy Is Being Gutted. What Does That Say About How Well It Was Working?
On the left is the Bankside Power Station in 1953. That vast relic of the fossil era once towered over London, oily smoke pouring from its towering chimney. These days, Bankside looks like the right:
The old power plant’s vast turbine hall is now at the heart of the airy Tate Modern Art Museum; sculptures rest where the boilers once churned.
Bankside’s evolution into the Tate illustrates that transformations, both literal and figurative, are possible for our energy and economic systems. Some degree of demolition – if paired with a plan – can open up space for something innovative and durable.
Today, the entire energy sector is undergoing a massive transformation. After years of flat energy demand served by aging fossil power plants, solar energy and battery storage are increasingly dominating energy additions to meet rising load. Global investment in clean energy will be twice as big as investment in fossil fuels this year. But in the United States, the energy sector is also undergoing substantial regulatory demolition, courtesy of a wave of executive and Congressional attacks and sweeping potential cuts to tax credits for clean energy.
What’s missing is a compelling plan for the future. The plan certainly shouldn’t be to cede leadership on modern energy technologies to China, as President Trump seems to be suggesting; that approach is geopolitically unwise and, frankly, economically idiotic. But neither should the plan be to just re-erect the systems that are being torn down. Those systems, in many ways, weren’t working. We need a new plan – a new paradigm – for the next era of climate and clean energy progress in the United States.
Asking Good Questions About Climate Policy Designs
How do we turn demolition into a superior remodel? First, we have to agree on what we’re trying to build. Let’s start with what should be three unobjectionable principles.
Principle 1. Climate change is a problem worth fixing – fast. Climate change is staggeringly expensive. Climate change also wrecks entire cities, takes lives, and generally makes people more miserable. Climate change, in short, is a problem we must fix. Ignoring and defunding climate science is not going to make it go away.
Principle 2. What we do should work. Tackling the climate crisis isn’t just about cleaning up smokestacks or sewer outflows; it’s about shifting a national economic system and physical infrastructure that has been rooted in fossil fuels for more than a century. Our responses must reflect this reality. To the extent possible, we will be much better served by developing fit-for-purpose solutions rather than just press-ganging old institutions, statutes, and technologies into climate service.
Principle 3. What we do should last. The half-life of many climate strategies in the United States has been woefully short. The Clean Power Plan, much touted by President Obama, never went into force. The Trump administration has now turned off California’s clean vehicle programs multiple times. Much of this hyperpolarized back-and-forth is driven by a combination of far-right opposition to regulation as a matter of principle and the fossil fuel industry pushing mass de-regulation for self-enrichment – a frustrating reality, but one that can only be altered by new strategies that are potent enough to displace vocal political constituencies and entrenched legacy corporate interests.
With these principles in mind, the path forward becomes clearer. We can agree that ambitious climate policy is necessary; protecting Americans from climate threats and destabilization (Principle 1) directly aligns with the founding Constitutional objectives of ensuring domestic tranquility, providing for the common defense, and promoting general welfare. We can also agree that the problem in front of us is figuring out which tools we need, not how to retain the tools we had, regardless of their demonstrated efficacy (Principle 2). And we can recognize that achieving progress in the long run requires solutions that are both politically and economically durable (Principle 3).
Below, we consider how these principles might guide our responses to this summer’s crop of regulatory reversals and proposed shifts in federal investment.
Honing Regulatory Approaches
The Trump Administration recently announced that it plans to dismantle the “endangerment finding” – the legal predicate for the Environmental Protection Agency (EPA) to regulate greenhouse gas emissions from power plants and transportation; meanwhile, the Senate revoked permission for California to enforce key car and truck emission standards. It has also proposed to roll back key power plant toxic and greenhouse gas standards. We agree with those who think that these actions are scientifically baseless and likely illegal, and therefore support efforts to counter them. But we should also reckon honestly with how the regulatory tools we are defending have played out so far.
Federal and state pollution rules have indisputably been a giant public-health victory. EPA standards under the Clean Air Act led directly to dramatic reductions in harmful particulate matter and other air pollutants, saving hundreds of thousands of lives and avoiding millions of cases of asthma and other respiratory diseases. Federal regulations similarly caused mercury pollution from coal-fired power plants to drop by 90% in just over a decade. Pending federal rollbacks of mercury rules thus warrant vocal opposition. In the transportation sector, tailpipe emissions standards for traditional combustion vehicles have been impressively effective. These and other rules have indeed delivered some climate benefits by forcing the fossil fuel industry to face pollution clean-up costs and driving development of clean technologies.
But if our primary goal is motivating a broad energy transition (i.e., what needs to happen per Principle 1), then we should think beyond pollution rules as our only tools – and allocate resources beyond immediate defensive fights. Why? The first reason is that, as we have previously written, these rules are poorly equipped to drive that transition. Federal and state environmental agencies can do many things well, but running national economic strategy and industrial policy primarily through pollution statutes is hardly the obvious choice (Principle 2).
Consider the power sector. The most promising path to decarbonize the grid is actually speeding up replacement of old coal and gas plants with renewables by easing unduly complex interconnection processes that would speed adding clean energy to address rising demand, and allow the old plants to retire and be replaced – not bolting pollution-control devices on ancient smokestacks. That’s an economic and grid policy puzzle, not a pollution regulatory challenge, at heart. Most new power plants are renewable- or battery-powered anyway. Some new gas plants might be built in response to growing demand, but the gas turbine pipeline is backed up, limiting the scope of new fossil power, and cheaper clean power is coming online much more quickly wherever grid regulators have their act together. Certainly regulations could help accelerate this shift, but the evidence suggests that they may be complementary, not primary, tools.
The upshot is that economics and subnational policies, not federal greenhouse gas regulation, have largely driven power plant decarbonization to date and therefore warrant our central focus. Indeed, states that have made adding renewable infrastructure easy, like Texas, have often been ahead of states, like California, where regulatory targets are stronger but infrastructure is harder to build. (It’s also worth noting that these same economics mean that the Trump Administration’s efforts to revert back to a wholly fossil fuel economy by repealing federal pollution standards will largely fail – again, wrong tool to substantially change energy trajectories.)
The second reason is that applying pollution rules to climate challenges has hardly been a lasting strategy (Principle 3). Despite nearly two decades of trying, no regulations for carbon emissions from existing power plants have ever been implemented. It turns out to be very hard, especially with the rise of conservative judiciaries, to write legal regulations for power plants under the Clean Air Act that both stand up in Court and actually yield substantial emissions reductions.
In transportation, pioneering electric vehicle (EV) standards from California – helped along by top-down economic leverage applied by the Obama administration – did indeed begin a significant shift and start winning market share for new electric car and truck companies; under the Biden administration, California doubled down with a new set of standards intended to ultimately phase out all sales of gas-powered cars while the EPA issued tailpipe emissions standards that put the industry on course to achieve at least 50% EV sales by 2030. But California’s EV standards have now been rolled back by the Trump administration and a GOP-controlled Congress multiple times; the same is true for the EPA rules. Lest we think that the Republican party is the sole obstacle to a climate-focused regulatory regime that lasts in the auto sector, it is worth noting that Democratic states led the way on rollbacks. Maryland, Massachusetts, Oregon, and Vermont all paused, delayed, or otherwise fuzzed up their plans to deploy some of their EV rules before Congress acted against California. The upshot is that environmental standards, on their own, cannot politically sustain an economic transition at this scale without significant complementary policies.
Now, we certainly shouldn’t abandon pollution rules – they deliver massive health and environmental benefits, while forcing the market to more accurately account for the costs of polluting technologies, But environmental statutes built primarily to reduce smokestack and tailpipe emissions remain important but are simply not designed to be the primary driver of wholesale economic and industrial change. Unsurprisingly, efforts to make them do that anyway have not gone particularly well – so much so that, today, greenhouse gas pollution standards for most economic sectors either do not exist, or have run into implementation barriers. These observations should guide us to double down on the policies that improve the economics of clean energy and clean technology — from financial incentives to reforms that make it easier to build — while developing new regulatory frameworks that avoid the pitfalls of the existing Clean Air Act playbook. For example, we might learn from state regulations like clean electricity standards that have driven deployment and largely withstood political swings.
To mildly belabor the point – pollution standards form part of the scaffolding needed to make climate progress, but they don’t look like the load-bearing center of it.
Refocusing Industrial Policy
Our plan for the future demands fresh thinking on industrial policy as well as regulatory design. Years ago, Nobel laureate Dr. Elinor Ostrom pointed out that economic systems shift not as a result of centralized fiat, from the White House or elsewhere, but from a “polycentric” set of decisions rippling out from every level of government and firm. That proposition has been amply borne out in the clean energy space by waves of technology innovation, often anchored by state and local procurement, regional technology clusters, and pioneering financial institutions like green banks.
The Biden Administration responded to these emerging understandings with the CHIPS and Science Act, Bipartisan Infrastructure Law (BIL), and Inflation Reduction Act (IRA) – a package of legislation intended to shore up U.S. leadership in clean technology through investments that cut across sectors and geographies. These bills included many provisions and programs with top-down designs, but the package as a whole but did engage with, and encourage, polycentric and deep change.
Here again, taking a serious look at how this package played out can help us understand what industrial policies are most likely to work (Principle 2) and to last (Principle 3) moving forward.
We might begin by asking which domestic clean-technology industries need long-term support and which do not in light of (i) the multi-layered and polycentric structure of our economy, and (ii) the state of play in individual economic sectors and firms at the subnational level. IRA revisions that appropriately phase down support for mature technologies in a given sector or region where deployment is sufficient to cut emissions at an adequate pace could be worth exploring in this light – but only if market-distorting supports for fossil-fuel incumbents are also removed. We appreciate thoughtful reform proposals that have been put forward by those on the left and right.
More directly: If the United States wants to phase down, say, clean power tax credits, such changes should properly be phased with removals of support for fossil power plants and interconnection barriers, shifting the entire energy market towards a fair competition to meet increasing load, as well as new durable regulatory structures that ensure a transition to a low-carbon economy at a sufficient pace. Subsidies and other incentives could appropriately be retained for technologies (e.g., advanced battery storage and nuclear) that are still in relatively early stages and/or for which there is a particularly compelling argument for strengthening U.S. leadership. One could similarly imagine a gradual shift away from EV tax credits – if other transportation system spending was also reallocated to properly balance support among highways, EV charging stations, transit, and other types of transportation infrastructure. In short, economic tools have tremendous power to drive climate progress, but must be paired with the systemic reforms needed to ensure that clean energy technologies have a fair pathway to achieving long-term economic durability.
Our analysis can also touch on geopolitical strategy. It is true that U.S. competitors are ahead in many clean technology fields; it is simultaneously true that the United States has a massive industrial and research base that can pivot ably with support. A pure on-shoring approach is likely to be unwise – and we have just seen courts enjoin the administration’s fiat tariff policy that sought that result. That’s a good opportunity to have a more thoughtful conversation (in which many are already engaging) on areas where tariffs, public subsidies, and other on-shoring planning can actually position our nation for long-term economic competition on clean technology. Opportunities that rise to the top include advanced manufacturing, such as for batteries, and critical industries, like the auto sector. There is also a surprising but potent national security imperative to center clean energy infrastructure in U.S. industrial policy, given the growing threat of foreign cyberattacks that are exploiting “seams” in fragile legacy energy systems.
Finally, our analysis suggests that states, which are primarily responsible for economic policy in their jurisdictions, have a role to play in this polycentric strategy that extends beyond simply replicating repealed federal regulations. States have a real opportunity in this moment to wed regulatory initiatives with creative whole-of-the-economy approaches that can actually deliver change and clean economic diversification, positioning them well to outlast this period of churn and prosper in a global clean energy transition.
A successful and “sticky” modern industrial policy must weave together all of the above considerations – it must be intentionally engineered to achieve economic and political durability through polycentric change, rather than relying solely or predominantly on large public subsidies.
Conclusion
The Trump Administration has moved with alarming speed to demolish programs, regulations, and institutions that were intended to make our communities and planet more liveable. Such wholesale demolition is unwarranted, unwise, and should not proceed unchecked. At the same time, it is, as ever, crucial to plan for the future. There is broad agreement that achieving an effective, equitable, and ethical energy transition requires us to do something different. Yet there are few transpartisan efforts to boldly reimagine regulatory and economic paradigms. Of course, we are not naive: political gridlock, entrenched special interests, and institutional inertia are formidable obstacles to overcome. But there is still room, and need, to try – and effort bears better fruit when aimed at the right problems. We can begin by seriously debating which past approaches work, which need to be improved, which ultimately need imaginative recasting to succeed in our ever-more complex world. Answers may be unexpected. After all, who would have thought that the ultimate best future of the vast oil-fired power station south of the Thames with which we began this essay would, a few decades later, be a serene and silent hall full of light and reflection?
The Direct File Dream Lives On
On May 28, we hosted 40 leaders from across government, civic tech, and advocacy at the Federation of American Scientists’ office in D.C. to reflect and chart the future of public interest tax filing. The backdrop was a wildly successful product beloved by users, which the AP reported DOGE and the Trump administration intend on sunsetting, while the public is calling for easy, free tax filing. This meeting was a coalition of experts unwilling to let this momentum go to waste.
Participants, ranging from former IRS staff and state tax teams to advocates, engineers, and policy veterans, brainstormed how to carry forward the most valuable parts of Direct File. What surfaced was clear: the tool was just the start. The ideas, tech, and values behind it can, and should, be applied far beyond a single product.
The good news: since this convening the IRS released Direct File software and made it open source.
Key findings
- Build the playbook. Show others, especially states, how Direct File was built, shipped, and maintained at high quality. Own the story, share the code, and make it replicable.
- Scale smart customer support. Direct File redefined what IRS service could look like, with real-time help and data-driven improvements. Let’s apply that bar elsewhere.
- Modernize the bureaucracy. From reforming the Paper Work Reduction Act to common-sense data sharing, participants named concrete ways to untangle red tape and better serve people.
- Unlock better benefits access. Direct File proved tax filing can be an on-ramp to other public benefits. Now let’s make that vision real—with smarter data use and simplified experiences.
- Support the states. Multiple attendees are already collaborating to help states stand up free filing tools or expand access to benefits using the Direct File codebase.
The outcome was shared clarity that the work continues. Direct File wasn’t just a product. It was a proof point that the government can deliver simple, elegant services that work. And the people who made that possible are already thinking about what comes next. The following outlines some of the key ideas, opportunities, and takeaways from the day – note, these are not comprehensive, nor are they commitments set in stone.
Key Resources
IRS Direct File Filing Season 2025 Report
Obtained by Center for Taxpayer Rights through a FOIA request, this report highlights the incredible results of Direct File in the 2025 filing season.
Direct File Source Code on GitHub: The source code for Direct File, currently being actively maintained by the IRS. As a work of the United States Government, this project is in the public domain within the United States of America.
Thank you
I want to thank all the participants who contributed to this important conversation. The event followed the Chatham House framework to create a free and open dialogue; the following organizations agreed to be named:
- American Economic Liberties Project
- Economic Security Project
- Groundwork Collaborative
- New Practice Lab
- Vanderbilt Policy Accelerator
Thank you to our incredible facilitators, former Direct File teammates Allison Abbott, Sam Powers, and Andrea Schneider; and civic tech leader and friend of Direct File, Erie Meyer.
And thank you to the Federation of American Scientists for hosting.
Breaking Down the New Memos on Federal Hiring
On May 29, the Office of Personnel Management (OPM) published two memoranda that could substantially reshape federal hiring. The first–“Merit Hiring Plan”–issued with the White House Domestic Policy Council—implements Executive Order 14170. The second provides guidance on “Hiring and Talent Development for the Senior Executive Service”. Spanning 53 pages, the documents are written in dense HR jargon that can overwhelm even seasoned practitioners. To clarify their meaning and impact, the Niskanen Center and the Federation of American Scientists have teamed up to translate both memos for journalists, researchers, and the general public.
The Memos Generally: Lots To Like, Dangerous Partisanship, & A Long Road Ahead
The memos, at their core, attempt to address well-documented and long-existing challenges: federal hiring is too sluggish, procedural, and opaque. Both of our organizations have long argued for the need to move faster, hire better, and hold poor performing employees accountable while still adhering to the merit system principles. A high-performing, agile, and engaged federal workforce is essential if Americans are to trust if Americans are to trust that laws passed by Congress will be executed quickly, competently and efficiently.
These memos are the latest in a long line of efforts by Presidents of both parties to bring common sense to federal hiring and performance – speed up the hiring process, focus on the skills to do the job, evaluate those skills objectively, and share resources across agencies to economize on effort and investment. These memos push that agenda further than earlier efforts, delivering several long‑sought wins such as streamlined applications and résumés more in line with private‑sector norms.
They also venture further than any recent initiative in politicizing the civil service. Mandatory training and essay questions tied to the current Administration’s executive orders—and explicit political sign‑off on certain hiring actions—risk blurring the firewall between career professionals and partisan appointees. We have discussed the dangers associated with this type of partisan drift in other places, including in response to the recent OPM rulemaking on “Schedule Policy/Career”.
Implementing even the non-controversial portions will be daunting. Reforming the federal government–the largest employer in the country–requires sustained, years-long effort from OPM and OMB.
The memos themselves are only the starting gun. Notably absent is a realistic plan to resource this work: for example, OPM has fired or lost nearly all of its enterprise data analytics team, limiting its ability to supply the metrics needed for oversight and accountability. Additionally, the inclusion of extremely ideological and partisan goals politicizes the entire agenda and risks overshadowing the rest of the positive reform agenda, threatening its ability to succeed anywhere.
In evaluating these documents, we have to weigh each part of the Administration’s strategy separately and objectively – there is a lot to like in these documents, there are things that are deeply troubling, and there are things that desperately need leadership attention in implementation.
What We Like: Skills-Based Hiring, Resume Reform, Assessments, Sharing Across Agencies
The bulk of both memos represents a bold next step in long‑running federal hiring reforms—initiatives that agencies have piloted for years but often struggled to scale. We commend OPM for learning from past efforts and, in several critical areas, pushing further than any of its predecessors by:
- Recognizing the role of recruiting and sourcing talent – The plan highlights the importance of active recruiting in the hiring process.Agencies have long relied on USAJobs alone as a crutch, hoping the right kinds of talent will be scouring the job board every day and happen upon job postings – this works okay for some roles that are highly-specialized to government, but particularly as agencies have need for emerging talent it they cannot assume critical talent pools are even aware that the federal government wants to hire them.
- Focusing on skills and evaluating for those skills – The memo limits the use of self-assessments to minimum qualifications only and requires agencies to use some form of technical or alternative assessment for all postings, implementing 2024’s bipartisan Chance to Compete Act. This is a critical move forward from the reliance on applicant’s self-assessment,a status quo that disadvantages honesty and self-awareness.
- Implementing ‘Rule of Many’ ranking procedures – OPM will finalize its proposed ‘Rule of Many’ regulation from the last Administration, which empowers agencies to choose the various ways to “cut off” applicants after they are assessed. Finalizing ‘Rule of Many’ will enable agencies to set clear, objective criteria for which applicants it will consider based on test scores (e.g., considering the top 10% of scorers), a numerical approach (e.g., considering the top 50 applicants), and other mechanisms (e.g., clear pass/fail standards) that give hiring managers and HR specialists the flexibility they need to tailor hiring procedures to specific needs.
- Sharing resources and certifications of eligibles across agencies – This expands requirements for agencies to share candidates, position descriptions, and talent pools across agencies, including conducting pooled hiring actions where one candidate can apply once to many similar jobs across government. It builds on recent tremendous success agencies have with recruiting high-quality applicants across government through shared hiring actions, which enables agencies to surge talent in a specific field and advertise as one enterprise to potential applicants.
- Reducing size of referral resumes to two pages – OPM is finally attempting to move away from a “federal resume” format that needlessly burdens members of the public with overly-specific requirements. Previously, applicants that didn’t know to include things like the “average number of hours worked per week” or their complete salary history were unknowingly disqualifying themselves from federal employment and even those that knew better had to maintain two separate resumes, making it harder to jump between sectors.
- Simplifying Senior Executive applications – Applicants for Senior Executive Service roles will no longer be required to write multiple pages of essays describing their experience – a process so unique it has spawned a cottage industry of professional writers – and will be evaluated via resumes and structured interviews like their peers across the economy. This builds on a long history of successful pilots of new selection procedures focusing on resumes and structured interviews rather than the traditional essays.
- Removing unnecessary degree requirements – While efforts have been underway since the first Trump Administration to remove unnecessary degree requirements. The new memos solidify that trajectory, embracing a skills‑first hiring model that prizes demonstrated ability over paper credentials—a trend mirrored in state governments and the private sector. Yet dropping degree rules is only half the battle. To truly broaden the talent pool, agencies must replace résumé shortcuts (like “years of experience”) with rigorous, job‑relevant assessments that let candidates prove what they can actually do.
- Focusing on speed and responsiveness – The memo doesn’t ignore the aspect of the applicant experience that differs most from the private sector: speed and responsiveness, setting a government-wide target of 80 days for hiring actions and requiring timely updates to applicants on their status. This builds on years of work to wrestle down timelines for security clearances and recognizes that one of the biggest reasons the federal government loses amazing applicants is the length of the process, not the pay.
Finally, the memos contain a compendium of useful resources in Appendices that agencies that can use to improve their approach to hiring.
Potential Red Flags: Politicization, Red Tape, & Extra, Unfunded Mandates
While OPM is advancing important nonpartisan reforms, we are concerned that several explicitly ideological provisions could erode the civil service’s neutrality and jeopardize the very hiring‑efficiency agenda OPM seeks to champion:
- Requiring essay questions on political views–Despite reducing applicant burden in other areas, OPM also introduces a requirement for all applicants for jobs above GS-05 (98%+ of jobs) to draft responses to free-response essay questions that describe their views on the present administration, including identifying which of the current president’s Executive Orders are “significant” to them. At best, this is an additional requirement that will be irrelevant for most jobs – there shouldn’t be any impact of EOs on a seasonal wildland firefighter’s strategy for fighting fires, for instance. More realistically, this constitutes a partisan loyalty test for federal employees to evaluate their views on the current President. Federal employees swear their allegiance to the Constitution, not the current President and there are legitimate open questions about the constitutionality of many Executive Orders.
- Introducing extra layers of political approval in the hiring process–While the memo emphasizes time to hire, it also emphasizes that “agency leadership” must either personally approve or designate an official to approve all positions before they are posted and all selections prior to extension of an offer. It also requires that they do an “executive interview” with candidates and opens the door to obvious partisan abuse of the merit hiring process when paired with the free response essay questions. Even without that risk, however, this requirement adds tremendous amounts of friction into a process that is already too full of approvals and pulls the decision-making authority in the wrong direction: to leadership instead of to the line management that knows the needs of a given program best. We are already seeing the problems with this approach play out with a similar requirement for agency leadership to personally approve payments or contracts, leading to extreme slowdowns. Additionally, just as with OPM’s recent rulemaking on Schedule Policy/Career, the opportunity for abuse is extremely obvious: highly partisan agency leaders may see it as their right to disapprove of candidates for purely political reasons–like, for example, donations to opposing candidates.
- Prioritizes political training for the SES corps–While the Administration has closed down training programs like the Federal Executive Institute that were designed to train new generations of federal leaders, it is also adding ideological training to the SES that lacks a clear purpose or evidence that it will improve governing outcomes. Requiring Senior Executives to watch an “80-hour video-based program that provides training regarding President Trump’s Executive Orders” is both offensive to the principle of a nonpartisan civil service and a waste of time for the busiest, most senior leaders across the entire enterprise. While America’s most productive tech companies are trying to reduce the meeting load to free staff to get things done, torching 4% of our senior executives’ working years for ideological training is the opposite of efficient.
- No mention of resources to carry out these changes – As with past legislation, EOs, and memos requiring skills-based talent practices, no apparent financial or other resources come with these memos. This has hampered adoption for more than a decade. The Talent Teams at OPM and the agencies, the communications and education support, the changes to OPM and agency systems all need people, money, and IT support. The lack of committed resources will delay, and perhaps scuttle, implementation. We know this because it has happened before. In the Clinton Administration, for example, a major push to de-proceduralize federal hiring fell down because they underresourced agency HR offices to stick the landing. This will happen again on skills-based hiring without commensurate investment, a problem discussed at length in a recent paper from the Niskanen Center.
What’s Missing: A Scalable Implementation Strategy
Executing these reforms will be no small feat, and the toughest tasks are also the most crucial: getting good technical assessments in the hands of managers, conducting strategic workforce planning, changing the culture around hiring to empower managers and not HR, and letting line managers be managers. OPM’s memos are light on details about how they intend to resource and manage implementation, an omission that they have plenty of time to correct but one that needs some serious consideration if they are going to be successful:
- Changing entrenched oversight, HR, and hiring manager policies, practices, and culture – OPM and the agencies will need to focus on how to move decades-learned compliance and risk aversion behaviors embedded in the current hiring and performance management practices into a skills-based future. The change management and consistent leadership required here is a substantial undertaking. Because OPM has conditioned the federal HR profession to be incredibly risk-averse, it won’t immediately embrace these new mandates without coaching, training, and professional development. To facilitate this, OPM should re-submit its uncontroversial legislative proposal from last year to help professionalize and develop the federal HR workforce, and Congress should expeditiously pass it.
- Hiring is just one piece of the effective federal employee puzzle – Though the SES Memo addresses some aspects of performance management, the focus on hiring diminishes other parts of the management system that impact effectiveness and performance. Onboarding, the early job experience, consistent feedback, professional development, challenging assignments, and career paths all help to ensure employees are helping meet agency missions. Implementation needs to take the whole system into account if OPM and the agencies are going to impact effectiveness and accountability.
- An all-of-the-above approach for getting assessments into the hands of agencies – The memo focuses on USAHire but, as we’ve discussed, there are many third-party assessment vendors that offer validated assessments and tools to help lower the unit and marginal cost of using objective assessments. Emerging companies offer things like AI-proctored video interviews that could quickly surface the most promising candidates and are already in use by the private sector for high-volume roles. At the federal level, parts of the Department of Homeland Security and other agencies have already experimented with some of these platforms. We want to see OPM think bigger about how to quickly bring assessments online and recognize that the private sector can play a role in accelerating this transformation.
- Focus on the candidate experience – Job candidates – users of the federal hiring system – complain that the experience of applying for a federal job is neither easy nor seamless, as it can be in the private sector. While the memos make some progress in reducing the burden on candidates (e.g., reducing resume and SES application requirements), the system is still rife with bureaucratic bloat. High-performing candidates have many options; they will go elsewhere if we do not reduce the friction.
- Public accountability & data – According to the hiring plan memo, agencies need to develop a data-driven plan for implementation and report frequently to OPM and OMB on their progress. With the practical dissolution of OPM’s human capital data team and a years-long problem with lagging human capital data releases via Fedscope, OPM should commit to releasing data publicly on their progress: how many people are hired, where they are hired, how many apply, how many pass technical assessments, etc. that will hold agencies accountable for getting this work done, give Congress the insight it needs to trust OPM, and provide the public with a window into progress.
- A plan to staff for success – In the best of times, OPM struggles with capacity for human capital policy work, and it will need every federal human capital expert it can get to pull off implementation of these memos. However, at the same time, OMB’s FY2026 budget proposal outlines a significant reduction in total headcount for OPM that locks in a 25%+ reduction in headcount across all parts of the agency, from policy to direct support for agencies. Given the technical complexity involved in many of these efforts–delivering validated assessments, for example, will likely require bringing in new expertise from outside government–OPM will need a plan to staff itself for success that is missing in these memos today.
In urgent circumstances, agencies have experimented with some of these practices and policies (e.g., cybersecurity hiring and intelligence community hiring, infrastructure and energy development). However, action on skills-based talent practices is far from pervasive. Together with outside experts, we continue to map the obstacles that keep skills‑first hiring from taking root: limited resources, hesitant leadership, and a pervasive fear of downside risk. Many of the opportunities and chokepoints highlighted in the memos came from this work, and we will keep collaborating with all stakeholders to craft practical fixes.
Most of the reforms in these memoranda set federal hiring on a promising trajectory, but their impact will hinge on disciplined execution. Some of them are deeply troubling attacks on the basis of the merit system. We will track OPM’s progress closely—amplifying best practices and calling out any drift from merit‑based, nonpartisan norms. These challenges are not new, yet they have become increasingly existential to building a government that works; OPM must keep that urgency front and center as implementation moves forward.
Getting ‘What Works’ in Education into the Hands of Teachers and Students
For more than twenty years, the Department of Education’s Institute of Education Sciences (IES) has served as a guiding light for U.S. education research. Its work has pushed the field forward, supporting high-quality, rigorous research in a field known for its reliance on word-of-mouth over science. The studies it funded have answered critical questions about “what works” in key areas like improving reading achievement and increasing associate’s degree attainment. It has served as a centralized, objective repository of data and research to inform educator practice, school district procurement, and state legislation. Even with these achievements, IES has room to grow to ensure that cutting edge research makes it into the hands of those who need it, when they need it.
As part of IES’s ongoing leadership, it has been moving to adopt an approach called “living evidence.” Use of this emerging approach would keep decision-makers up-to-date about the solutions that have been rigorously tested and hold potential to address core challenges facing American schools: How do we respond to astonishingly low scores on NAEP tests? Are there evidence-based approaches we can employ in schools that will help end the national “epidemic” of social isolation? How do we ensure that both our college graduates and those who do not wish to attend college can obtain high-paying jobs?
Harnessing Innovation
This week, FAS and its partners at the Future Evidence Foundation (FEF) released a new report: Harnessing Innovation: Options for Implementing Living Evidence at the Institute of Education Sciences (which you can download using the button on the left-hand side of this page). It describes in great depth how IES could build on existing processes to produce living reviews as part of their What Works Clearinghouse.
Over time, many have come to believe that the agency moves too slowly to be responsive to practitioner needs, that its approach to sharing research findings does not make clear enough for users whether an intervention is backed by strong evidence, and that it needs to better support innovation. Living evidence is not the silver bullet that can address all of these issues in full. And yet, its proposed adoption could be the foundation for a sea change, allowing IES to more responsively share when new best practices and innovative approaches are identified in the academic literature through the What Works Clearinghouse. However, recent seismic shifts have severely damaged IES’s capability to move forward with using this innovative model: the Trump Administration’s cancellation of nearly all active contracts, including those that made the What Works Clearinghouse’s work possible, and a reduction-in-force (RIF) that led to the firing of nearly all of IES’s staff.
Report Insights and Key Takeaways
The report was produced as the product of a year-long partnership, where FAS and FEF were granted the opportunity to engage deeply with leadership and staff from IES. Our team learned about their day-to-day processes and potential roadblocks on the path to change. The final ‘options memo’ was carefully constructed to give the IES team a set of realistic approaches they could take to addressing some of their greatest challenges: discerning the topics where knowing ‘what works’ could be most beneficial to the more than 100 million people that the U.S. education system touches, finding the highest-quality academic research from the thousands of studies produced each year on education, and doing this work within a limited set of resources (IES funding made up less than 1% of the Department of Education’s overall spending in 2024). These recommendations were informed by conversations with many of those that knew IES’s work best, from its contractors to the readers of the What Works Clearinghouse’s reports. They offer feasible ways for IES to craft more efficient processes for developing their resources.
From this process, our team had two key takeaways:
- While the What Works Clearinghouse faces challenges in achieving its goal to make rigorous research accessible to policymakers and practitioners, the staff and contractors that led its work were steadfast in their dedication to improving its resources.
- Living evidence is not just the way of the future in academic circles beyond the U.S., but is a model that is feasible to implement in large federal agencies.
However, canceling contracts and firing experienced, dedicated staff has kneecapped IES’s ability to make the changes necessary to begin creating and deploying living reviews. An opportunity may now be missed to better align IES’s work not just to what their constituents need, but also to how a global community is moving forward in thinking about how to better connect evidence to policy and practice. While the administration has signaled its intent to rebuild IES in the future, it will take time to enact a new vision, and to fix what will inevitably break in the absence of staff to support key resources including the Regional Education Laboratories, the Education Resources Information Center (ERIC), and the What Works Clearinghouse. In that time, peer government R&D agencies such as UK Research and Innovation and major philanthropic organizations such as the Wellcome Trust will step up to lead the way on developing infrastructure that supports the use of emerging technology to build living reviews, moving the rest of the world forward while U.S. government agencies remain in the past.
Living Evidence Global Community of Practice
Living evidence still has a path forward in the U.S, and opportunities to continue to grow along with the growing global movement. Innovation outside of government for living evidence holds promise for U.S. education stakeholders, led by work through the HEDCO Institute at the University of Oregon and the clearinghouse Blueprints for Healthy Youth Development. The recommendations in the report will offer value for such organizations as they work to shift toward living systematic reviews, setting the tone for best practice in evidence synthesis while IES is in transition. FAS and FEF will continue to help support this work through our convening of a Living Evidence Community of Practice.
Further, it is our hope that the learnings shared in the report will be considered in re-imagining future iterations of IES. In its short 23 years of existence, IES has raised the rigor of evidence that influences education and made strides in both generating and summarizing evidence that has the potential to inform practice. Even if the administration moves forward in its stated aim of “returning education back to the states”, state and local leaders will still need IES’s resources to understand how best to disburse their budgets. Employing a living approach to evidence synthesis, disseminated at a national level, is a streamlined way to enable evidence-based decision-making nationwide. If the administration genuinely prioritizes government efficiency, the report’s recommendations warrant serious consideration.
Building an Environmental Regulatory System that Delivers for America
The Clean Air Act. The Clean Water Act. The National Environmental Policy Act. These and most of our nation’s other foundational environmental laws were passed decades ago – and they have started to show their age. The Clean Air Act, for instance, was written to cut air pollution, not to drive the whole-of-economy response that the climate crisis now warrants. The Energy Policy and Conservation Act of 1975 was designed to make cars more efficient in a pre-electric vehicle era, and now puts the Department of Transportation in the awkward position of setting fuel economy standards in an era when more and more cars don’t burn gas.
Trying to manage today’s problems with yesterday’s laws results in government by kludge. Legacy regulatory architecture has foundered under a patchwork of legislative amendments and administrative procedures designed to bridge the gap between past needs and present realities. Meanwhile, Congressional dysfunction has made purpose-built updates exceptionally difficult to land. The Inflation Reduction Act, for example, was mostly designed to move money rather than rethink foundational statutes or regulatory processes – because those rethinks couldn’t make it past the filibuster.
As the efficacy of environmental laws has waned, so has their durability. What was once a broadly shared goal – protecting Americans from environmental harm – is now a political football, with rules that whipsaw back and forth depending on who’s in charge.
The second Trump Administration launched the biggest environmental deregulatory campaign in history against this backdrop. But that campaign, coupled with massive reductions in the federal civil service and a suite of landmark court decisions (including Loper Bright) about how federal agencies regulate, risks pushing U.S. regulatory architecture past the point of sensible and much-needed reform and into a state of complete disrepair.
Dismantling old systems has proven surprisingly easy. Building what comes next will be harder. And the work must begin now.
It is time to articulate a long-term vision for a government that can actually deliver in an ever-more complex society. The Federation of American Scientists (FAS) is meeting this moment by launching an ambitious new project to reimagine the U.S. environmental regulatory state, drawing ideas from across ideological lines.
The Beginning of a New Era
Fear of the risks of systemic change often prevent people from entertaining change in earnest. Think of the years of U.S. squabbles over how or whether to reform permitting and environmental review, while other countries simply raced ahead to build clean energy projects and establish dominance in the new world economy. Systemic stagnation, however, comes with its own consequences.
The Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA) are a case in point when it comes to climate and the environment. Together, these two pieces of legislation represented the largest global investment in the promise of a healthier, more sustainable, and, yes, cheaper future. Unfortunately, as proponents of the “abundance” paradigm and others have observed, rollout was hampered by inefficient processes and outdated laws. Implementing the IRA and the IIJA via old systems, in short, was like trying to funnel an ocean through a garden hose – and as a result, most Americans experienced only a trickle of real-world impact.
Similar barriers are constraining state progress. For example, the way we govern and pay for electricity has not kept pace with a rapidly changing energy landscape – meaning that the United States risks ceding leadership on energy technologies critical to national security, economic competitiveness, and combating climate change.
But we are perhaps now entering a new era. The United States appears to be on the edge of real political realignments, with transpartisan stakes around the core role of government in economic development that do not match up neatly to current coalitions. This realignment presents a crucial opportunity to catalyze a new era of climate, environmental, and democratic progress.
FAS will leverage this opportunity by providing a forum for debate and engagement on different facets of climate and environmental governance, a platform to amplify insights, and the capacity to drive forward solutions. Examples of topics ripe for exploration include:
- Balancing agility and accountability. As observed, regulatory approaches of the past have struggled to address the interconnected, quickly evolving nature of climate and environmental challenges. At the same time, mechanisms for ensuring accountability have been disrupted by an evolving legal landscape and increasingly muscular executive. There is a need to imagine and test new systems designed to move quickly but responsibly on climate and environmental issues.
- Complementing traditional regulation through novel strategies. There is growing interest in using novel financial, contractual, and other strategies as a complement to regulation for driving climate and environmental progress. There is considerable room to go deeper in this space, identifying both the power of these strategies and their limits.
- Rethinking stakeholder engagement. The effectiveness of regulation depends on its ability to serve diverse stakeholder needs while advancing environmental goals. Public comment and other pipelines for engaging stakeholders and integrating external perspectives and expertise into regulations have been disrupted by technologies such as AI, while the relationship between regulated entities and their regulators has become increasingly adversarial. There is a need to examine synergies and tradeoffs between centering stakeholders and centering outcomes in regulatory processes, as well as examine how stakeholder engagement could be improved to better ensure regulations that are informed, feasible, durable, and distributively fair.
In working through topics like these, FAS seeks to lay out a positive vision of regulatory reconstruction that is substantively superior to either haphazard destruction or incremental change. Our vision is nothing less than to usher in a new paradigm of climate and environmental governance: one that secures a livable world while reinforcing democratic stability, through systems that truly deliver for America.
We will center our focus on the federal government given its important role in climate and environmental issues. However, states and localities do a lot of the work of a federated government day-to-day. We recognize that federal cures are unlikely to fully alleviate the symptoms that Americans are experiencing every day, from decaying infrastructure to housing shortages. We are committed to ensuring that solutions are appropriately matched to the root cause of state capacity problems and that federal climate and environmental regulatory regimes are designed to support successful cooperation with local governments and implementation partners.
FAS is no stranger to ambitious endeavors like these. Since our founding in 1945, we have been committed to tackling the major science policy issues that reverberate through American life. This new FAS workstream will be embedded across our Climate and Environment, Clean Energy, and Government Capacity portfolios. We have already begun engaging and activating the diverse community of scholars, experts, and leaders laying the intellectual groundwork to develop compelling answers to urgent questions surrounding the climate regulatory state, against the backdrop of a broader state capacity movement. True to our nonpartisan commitment, we will build this work on a foundation of cross-ideological curiosity and play on the tension points in existing coalitions that strike us all as most productive.
We invite you to join us in conversation and collaboration. If you want to get involved, contact Zoë Brouns (zbrouns@fas.org).
Goodbye IRS Direct File, Hello Inefficiency
Decision to Sunset IRS’ Direct File Previews Worse Taxpayer Experience in 2026
Yesterday, tens of thousands of taxpayers filed their returns using IRS Direct File, the agency’s new free, public, online tax filing service now in its second filing season. They joined hundreds of thousands who have used the service, and who have been nearly-unanimously thrilled to fulfill their tax obligations easily and directly. It seems we have finally done the impossible: make Tax Day anything but the most dreaded day of the year. At least we did.
Today, the Associated Press reported that the Treasury Department will discontinue the program. “Cutting costs and saving money for families were just empty campaign promises,” says Adam Ruben, a vice president at the Economic Security Project of the administration’s decision to end the program.
I was an original architect of Direct File from 2021 until just a few months ago, and got to see its impact on government and on taxpayers directly. Make no mistake: Direct File is a shining example of government capacity and government efficiency. By providing a critical government service for free, and helping taxpayers file more timely and more accurate returns, it is projected to eventually generate $11 billion in net savings for taxpayers every year.
The dismantling of the program is not, at all, a step toward government efficiency. This is a move that will degrade our government services, incurring massive costs for people trying to file their taxes, further damaging the capacity of the nation’s revenue-collection agency, and making our institutions less robust and less capable.
It’s no secret: Americans do not love tax season.
The Direct File story started for me, personally, when I moved back to the U.S. after living in London for 9 years. I had already spent years working in digital services: I had built the first in-house digital team at the brand-new Consumer Financial Protection Bureau in 2010, and then worked on multiple projects in London, culminating in helping the London Borough of Camden digitally transform its entire operations practically overnight during the pandemic. I moved back to the States and joined the US Digital Service to help rebuild after Covid, bringing the lessons I had learned from the UK. My first project at USDS was leading our efforts on Child Tax Credit expansion — ensuring that families across the country could access the enormous new child benefit that was created in the March 2021 American Rescue Plan.
But there was a problem: families naturally had to file a tax return to claim their tax credit. And I was pretty surprised to learn that our government still did not, in 2021, offer a free, online way to file your taxes directly with the government. Around the world, tax collection is seen as an inherent government function and, as such, tax filing is a service that the government offers free of charge. I thought we should too, especially if we were going to make such critical social supports contingent on it during a crisis.
Instead, in the U.S., we relied on a confusing — and sometimes costly — mishmash of private offerings and support from non-profits designed to ensure most people could maybe, sort of, file a return for free if they needed to. It made the barrier to entry high, both in terms of trying to navigate how to simply file a return, nevermind to do so without cost. Tax filing, I thought, is a core function of government, and making it free and easy to use would cut through this waste and deliver for the American people.
I wasn’t the only one who thought this way. By 2021, a free public filing service was already the “white whale” of civic tech; everyone knew this was the critical government function to bring into a modern digital product, and yet it was too big, too daunting, too much of a change. Honestly, never in a million years did I think we would pull it off, either. The IRS, for all its genuine accomplishments in the face of constantly shrinking budgets and aging technology, had no real experience launching an enormous, high-stakes tech product designed to simplify the mind-numbing complexities of an American tax return. This was government capacity we would have to create.
But, we did. Since Direct File launched as a pilot in March 2023, hundreds of thousands of people have now filed their returns with it, to stunning results. In its pilot year, 86% of users said that Direct File increased their trust in the IRS. In its second year, it is winning awards and killing it with users, with a Net Promoter Score in the +80s, up from +74 last year (Apple’s, which is considered astronomically high, is +72). Direct File is a wildly successful government startup. Not only that, but the IRS now has its own in-house capacity to continue building awesome digital experiences — capacity that could have gone toward cost savings and experience improvements in all matter of IRS operations. This is all capacity, needless to say, that has gone away, all in the name of “efficiency.”
The impact for taxpayers from Direct File alone are, and would have been, enormous. In the U.S., the IRS estimates that it takes the average person over 9 hours and costs $160 to file your taxes each year. We even heard anecdotally from Direct File users who had paid thousands of dollars to do what Direct File does for free. There also remain millions of households who, every year, don’t file their returns at all, leaving sizable refunds on the table, because they can’t navigate the confusing tax filing “offers” advertising tax filing services. These households would have stood to finally access billions of dollars they leave unclaimed every year.
Not only are taxpayers saving these hundreds of dollars, they also feel newly empowered to interact with their government and take control of their tax situations. For decades, Americans have been told that they are not smart enough to do your own taxes; only highly-paid specialists that you have to pay for, can do it for you. Direct File stripped away the noise and showed taxpayers that filing can be simple and easy. The valuable trust this creates in government and public institutions is impossible to quantify.
Finally, there is the issue of data privacy and security. Taxpayers filing via private services must expose their most sensitive personal and financial information to third parties that monetize their data, sometimes illegally and without taxpayers’ consent. Without a public filing option, taxpayers are more or less required to sacrifice their privacy and the security of their data just to fulfill their filing obligations. Direct File gives taxpayers the option to protect their data and provide it straight to the tax agency, without a middleman.
All this — the in-house capacity to modernize the IRS, billions of dollars in cost savings, an empowered public — is what is cancelled today. But they have it exactly backwards. It’s a functional, high-quality government that’s efficient. The chaos they are sowing is anything but.
Reforming the Federal Advisory Committee Landscape for Improved Evidence-based Decision Making and Increasing Public Trust
Federal Advisory Committees (FACs) are the single point of entry for the American public to provide consensus-based advice and recommendations to the federal government. These Advisory Committees are composed of experts from various fields who serve as Special Government Employees (SGEs), attending committee meetings, writing reports, and voting on potential government actions.
Advisory Committees are needed for the federal decision-making process because they provide additional expertise and in-depth knowledge for the Agency on complex topics, aid the government in gathering information from the public, and allow the public the opportunity to participate in meetings about the Agency’s activities. As currently organized, FACs are not equipped to provide the best evidence-based advice. This is because FACs do not meet transparency requirements set forth by GAO: making pertinent decisions during public meetings, reporting inaccurate cost data, providing official meeting documents publicly available online, and more. FACs have also experienced difficulty with recruiting and retaining top talent to assist with decision making. For these reasons, it is critical that FACs are reformed and equipped with the necessary tools to continue providing the government with the best evidence-based advice. Specifically, advice as it relates to issues such as 1) decreasing the burden of hiring special government employees 2) simplifying the financial disclosure process 3) increasing understanding of reporting requirements and conflict of interest processes 4) expanding training for Advisory Committee members 5) broadening the roles of Committee chairs and designated federal officials 6) increasing public awareness of Advisory Committee roles 7) engaging the public outside of official meetings 8) standardizing representation from Committee representatives 9) ensuring that Advisory Committees are meeting per their charters and 10) bolstering Agency budgets for critical Advisory Committee issues.
Challenge and Opportunity
Protecting the health and safety of the American public and ensuring that the public has the opportunity to participate in the federal decision-making process is crucial. We must evaluate the operations and activities of federal agencies that require the government to solicit evidence-based advice and feedback from various experts through the use of federal Advisory Committees (FACs). These Committees are instrumental in facilitating transparent and collaborative deliberation between the federal government, the advisory body, and the American public and cannot be done through the use of any other mechanism. Advisory Committee recommendations are integral to strengthening public trust and reinforcing the credibility of federal agencies. Nonetheless, public trust in government has been waning and efforts should be made to increase public trust. Public trust is known as the pillar of democracy and fosters trust between parties, particularly when one party is external to the federal government. Therefore, the use of Advisory Committees, when appropriately used, can assist with increasing public trust and ensuring compliance with the law.
There have also been many success stories demonstrating the benefits of Advisory Committees. When Advisory Committees are appropriately staffed based on their charge, they can decrease the workload of federal employees, assist with developing policies for some of our most challenging issues, involve the public in the decision-making process, and more. However, the state of Advisory Committees and the need for reform have been under question, and even more so as we transition to a new administration. Advisory Committees have contributed to the improvement in the quality of life for some Americans through scientific advice, as well as the monitoring of cybersecurity. For example, an FDA Advisory Committee reviewed data and saw promising results for the treatment of sickle cell disease (SCD) which has been a debilitating disease with limited treatment for years. The Committee voted in favor of gene therapy drugs Casgevy and Lyfgenia which were the first to be approved by the FDA for SCD.
Under the first Trump administration, Executive Order (EO) 13875 resulted in a significant decrease in the number of federal advisory meetings. This limited agencies’ ability to convene external advisors. Federal science advisory committees met less during this administration than any prior administration, met less than what was required from their charter, disbanded long standing Advisory Committees, and scientists receiving agency grants were barred from serving on Advisory Committees. Federal Advisory Committee membership also decreased by 14%, demonstrating the issue of recruiting and retaining top talent. The disbandment of Advisory Committees, exclusion of key scientific external experts from Advisory Committees, and burdensome procedures can potentially trigger severe consequences that affect the health and safety of Americans.
Going into a second Trump administration, it is imperative that Advisory Committees have the opportunity to assist federal agencies with the evidence-based advice needed to make critical decisions that affect the American public. The suggested reforms that follow can work to improve the overall operations of Advisory Committees while still providing the government with necessary evidence-based advice. With successful implementation of the following recommendations, the federal government will be able to reduce administrative burden on staff through the recruitment, onboarding, and conflict of interest processes.
The U.S. Open Government Initiative encourages the promotion and participation of public and community engagement in governmental affairs. However, individual Agencies can and should do more to engage the public. This policy memo identifies several areas of potential reform for Advisory Committees and aims to provide recommendations for improving the overall process without compromising Agency or Advisory Committee membership integrity.
Plan of Action
The proposed plan of action identifies several policy recommendations to reform the federal Advisory Committee (Advisory Committee) process, improving both operations and efficiency. Successful implementation of these policies will 1) improve the Advisory Committee member experience, 2) increase transparency in federal government decision-making, and 3) bolster trust between the federal government, its Advisory Committees, and the public.
Streamline Joining Advisory Committees
Recommendation 1. Decrease the burden of hiring special government employees in an effort to (1) reduce the administrative burden for the Agency and (2) encourage Advisory Committee members, who are also known as special government employees (SGEs), to continue providing the best evidence-based advice to the federal government through reduced onerous procedures
The Ethics in Government Act of 1978 and Executive Order 12674 lists OGE-450 reporting as the required public financial disclosure for all executive branch and special government employees. This Act provides the Office of Government Ethics (OGE) the authority to implement and regulate a financial disclosure system for executive branch and special government employees whose duties have “heightened risk of potential or actual conflicts of interest”. Nonetheless, the reporting process becomes onerous when Advisory Committee members have to complete the OGE-450 before every meeting even if their information remains unchanged. This presents a challenge for Advisory Committee members who wish to continue serving, but are burdened by time constraints. The process also burdens federal staff who manage the financial disclosure system.
Policy Pathway 1. Increase funding for enhanced federal staffing capacity to undertake excessive administrative duties for financial reporting.
Policy Pathway 2. All federal agencies that deploy Advisory Committees can conduct a review of the current OGC-450 process, budget support for this process, and work to develop an electronic process that will eliminate the use of forms and allow participants to select dropdown options indicating if their financial interests have changed.
Recommendation 2. Create and use public platforms such as OpenPayments by CMS to (1) aid in simplifying the financial disclosure reporting process and (2) increase transparency for disclosure procedures
Federal agencies should create a financial disclosure platform that streamlines the process and allows Advisory Committee members to submit their disclosures and easily make updates. This system should also be created to monitor and compare financial conflicts. In addition, agencies that utilize the expertise of Advisory Committees for drugs and devices should identify additional ways in which they can promote financial transparency. These agencies can use Open Payments, a system operated by Centers for Medicare & Medicaid Services (CMS), to “promote a more financially transparent and accountable healthcare system”. The Open Payments system makes payments from medical and drug device companies to individuals, healthcare providers, and teaching hospitals accessible to the public. If for any reason financial disclosure forms are called into question, the Open Payments platform can act as a check and balance in identifying any potential financial interests of Advisory Committee members. Further steps that can be taken to simplify the financial disclosure process would be to utilize conflict of interest software such as Ethico which is a comprehensive tool that allows for customizable disclosure forms, disclosure analytics for comparisons, and process automation.
Policy Pathway. The Office of Government Ethics should require all federal agencies that operate Advisory Committees to develop their own financial disclosure system and include a second step in the financial disclosure reporting process as due diligence, which includes reviewing the Open Payments by CMS system for potential financial conflicts or deploying conflict of interest monitoring software to streamline the process.
Streamline Participation in an Advisory Committee
Recommendation 3. Increase understanding of annual reporting requirements for conflict of interest (COI)
Agencies should develop guidance that explicitly states the roles of Ethics Officers, also known as Designated Agency Ethics Officials (DAEO), within the federal government. Understanding the roles and responsibilities of Advisory Committee members and the public will help reduce the spread of misinformation regarding the purpose of Advisory Committees. In addition, agencies should be encouraged by the Office of Government Ethics to develop guidance that indicates the criteria for inclusion or exclusion of participation in Committee meetings. Currently, there is no public guidance that states what types of conflicts of interests are granted waivers for participation. Full disclosure of selection and approval criteria will improve transparency with the public and draw clear delineations between how Agencies determine who is eligible to participate.
Policy Pathway. Develop conflict of interest (COI) and financial disclosure guidance specifically for SGEs that states under what circumstances SGEs are allowed to receive waivers for participation in Advisory Committee meetings.
Recommendation 4. Expand training for Advisory Committee members to include (1) ethics and (2) criteria for making good recommendations to policymakers
Training should be expanded for all federal Advisory Committee members to include ethics training which details the role of Designated Agency Ethics Officials, rules and regulations for financial interest disclosures, and criteria for making evidence-based recommendations to policymakers. Training for incoming Advisory Committee members ensures that all members have the same knowledge base and can effectively contribute to the evidence-based recommendations process.
Policy Pathway. Agencies should collaborate with the OGE and Agency Heads to develop comprehensive training programs for all incoming Advisory Committee members to ensure an understanding of ethics as contributing members, best practices for providing evidence-based recommendations, and other pertinent areas that are deemed essential to the Advisory Committee process.
Leverage Advisory Committee Membership
Recommendation 5. Uplifting roles of the Committee Chairs and Designated Federal Officials
Expanding the roles of Committee Chairs and Designated Federal Officers (DFOs) may assist federal Agencies with recruiting and retaining top talent and maximizing the Committee’s ability to stay abreast of critical public concerns. Considering the fact that the General Services Administration has to be consulted for the formation of new Committees, renewal, or alteration of Committees, they can be instrumental in this change.
Policy Pathway. The General Services Administration (GSA) should encourage federal Agencies to collaborate with Committee Chairs and DFOs to recruit permanent and ad hoc Committee members who may have broad network reach and community ties that will bolster trust amongst Committees and the public.
Recommendation 6. Clarify intended roles for Advisory Committee members and the public
There are misconceptions among the public and Advisory Committee members about Advisory Committee roles and responsibilities. There is also ambiguity regarding the types of Advisory Committee roles such as ad hoc members, consulting, providing feedback for policies, or making recommendations.
Policy Pathway. GSA should encourage federal Agencies to develop guidance that delineates the differences between permanent and temporary Advisory Committee members, as well as their roles and responsibilities depending on if they’re providing feedback for policies or providing recommendations for policy decision-making.
Recommendation 7. Utilize and engage expertise and the public outside of public meetings
In an effort to continue receiving the best evidence-based advice, federal Agencies should develop alternate ways to receive advice outside of public Committee meetings. Allowing additional opportunities for engagement and feedback from Committee experts or the public will allow Agencies to expand their knowledge base and gather information from communities who their decisions will affect.
Policy Pathway. The General Services Administration should encourage federal Agencies to create opportunities outside of scheduled Advisory Committee meetings to engage Committee members and the public on areas of concern and interest as one form of engagement.
Recommendation 8. Standardize representation from Committee representatives (i.e., industry), as well as representation limits
The Federal Advisory Committee Act (FACA) does not specify the types of expertise that should be represented on all federal Advisory Committees, but allows for many types of expertise. Incorporating various sets of expertise that are representative of the American public will ensure the government is receiving the most accurate, innovative, and evidence-based recommendations for issues and products that affect Americans.
Policy Pathway. Congress should include standardized language in the FACA that states all federal Advisory Committees should include various sets of expertise depending on their charge. This change should then be enforced by the GSA.
Support a Vibrant and Functioning Advisory Committee System
Recommendation 9. Decrease the burden to creating an Advisory Committee and make sure Advisory Committees are meeting per their charters
The process to establish an Advisory Committee should be simplified in an effort to curtail the amount of onerous processes that lead to a delay in the government receiving evidence based advice.
Advisory Committee charters state the purpose of Advisory Committees, their duties, and all aspirational aspects. These charters are developed by agency staff or DFOs with consultation from their agency Committee Management Office. Charters are needed to forge the path for all FACs.
Policy Pathway. Designated Federal Officers (DFOs) within federal agencies should work with their Agency head to review and modify steps to establishing FACs. Eliminate the requirement for FACs to require consultation and/or approval from GSA for the formation, renewal, or alteration of Advisory Committees.
Recommendation 10. Bolster agency budgets to support FACs on critical issues where regular engagement and trust building with the public is essential for good policy
Federal Advisory Committees are an essential component to receive evidence-based recommendations that will help guide decisions at all stages of the policy process. These Advisory Committees are oftentimes the single entry point external experts and the public have to comment and participate in the decision-making process. However, FACs take considerable resources to operate depending on the frequency of meetings, the number of Advisory Committee members, and supporting FDA staff. Without proper appropriations, they have a diminished ability to recruit and retain top talent for Advisory Committees. The Government Accountability Office (GAO) reported that in 2019, approximately $373 million dollars was spent to operate a total of 960 federal Advisory Committees. Some Agencies have experienced a decrease in the number of Advisory Committee convenings. Individual Agency heads should conduct a budget review of average operating and projected costs and develop proposals for increased funding to submit to the Appropriations Committee.
Policy Pathway. Congress should consider increasing appropriations to support FACs so they can continue to enhance federal decision-making, improve public policy, boost public credibility, and Agency morale.
Conclusion
Advisory Committees are necessary to the federal evidence-based decision-making ecosystem. Enlisting the advice and recommendations of experts, while also including input from the American public, allows the government to continue making decisions that will truly benefit its constituents. Nonetheless, there are areas of FACs that can be improved to ensure it continues to be a participatory, evidence-based process. Additional funding is needed to compensate the appropriate Agency staff for Committee support, provide potential incentives for experts who are volunteering their time, and finance other expenditures.
With reform of Advisory Committees, the process for receiving evidence-based advice will be streamlined, allowing the government to receive this advice in a faster and less burdensome manner. Reform will be implemented by reducing the administrative burden for federal employees through the streamlining of recruitment, financial disclosure, and reporting processes.
A Federal Center of Excellence to Expand State and Local Government Capacity for AI Procurement and Use
The administration should create a federal center of excellence for state and local artificial intelligence (AI) procurement and use—a hub for expertise and resources on public sector AI procurement and use at the state, local, tribal, and territorial (SLTT) government levels. The center could be created by expanding the General Services Administration’s (GSA) existing Artificial Intelligence Center of Excellence (AI CoE). As new waves of AI technologies enter the market, shifting both practice and policy, such a center of excellence would help bridge the gap between existing federal resources on responsible AI and the specific, grounded challenges that individual agencies face. In the decades ahead, new AI technologies will touch an expanding breadth of government services—including public health, child welfare, and housing—vital to the wellbeing of the American people. An AI CoE federal center would equip public sector agencies with sustainable expertise and set a consistent standard for practicing responsible AI procurement and use. This resource ensures that AI truly enhances services, protects the public interest, and builds public trust in AI-integrated state and local government services.
Challenge and Opportunity
State, local, tribal, and territorial (SLTT) governments provide services that are critical to the welfare of our society. Among these: providing housing, child support, healthcare, credit lending, and teaching. SLTT governments are increasingly interested in using AI to assist with providing these services. However, they face immense challenges in responsibly procuring and using new AI technologies. While grappling with limited technical expertise and budget constraints, SLTT government agencies considering or deploying AI must navigate data privacy concerns, anticipate and mitigate biased model outputs, ensure model outputs are interpretable to workers, and comply with sector-specific regulatory requirements, among other responsibilities.
The emergence of foundation models (large AI systems adaptable to many different tasks) for public sector use exacerbates these existing challenges. Technology companies are now rapidly developing new generative AI services tailored towards public sector organizations. For example, earlier this year, Microsoft announced that Azure OpenAI Service would be newly added to Azure Government—a set of AI services that target government customers. These types of services are not specifically created for public sector applications and use contexts, but instead are meant to serve as a foundation for developing specific applications.
For SLTT government agencies, these generative AI services blur the line between procurement and development: Beyond procuring specific AI services, we anticipate that agencies will increasingly be tasked with the responsible use of general AI services to develop specific AI applications. Moreover, recent AI regulations suggest that responsibility and liability for the use and impacts of procured AI technologies will be shared by the public sector agency that deploys them, rather than just resting with the vendor supplying them.
SLTT agencies must be well-equipped with responsible procurement practices and accountability mechanisms pivotal to moving forward given the shifts across products, practice, and policy. Federal agencies have started to provide guidelines for responsible AI procurement (e.g., Executive Order 13960, OMB-M-21-06, NIST RMF). But research shows that SLTT governments need additional support to apply these resources.: Whereas existing federal resources provide high-level, general guidance, SLTT government agencies must navigate a host of challenges that are context-specific (e.g., specific to regional laws, agency practices, etc.). SLTT government agency leaders have voiced a need for individualized support in accounting for these context-specific considerations when navigating procurement decisions.
Today, private companies are promising state and local government agencies that using their AI services can transform the public sector. They describe diverse potential applications, from supporting complex decision-making to automating administrative tasks. However, there is minimal evidence that these new AI technologies can improve the quality and efficiency of public services. There is evidence, on the other hand, that AI in public services can have unintended consequences, and when these technologies go wrong, they often worsen the problems they are aimed at solving. For example, by increasing disparities in decision-making when attempting to reduce them.
Challenges to responsible technology procurement follow a historical trend: Government technology has frequently been critiqued for failures in the past decades. Because public services such as healthcare, social work, and credit lending have such high stakes, failures in these areas can have far-reaching consequences. They also entail significant financial costs, with millions of dollars wasted on technologies that ultimately get abandoned. Even when subpar solutions remain in use, agency staff may be forced to work with them for extended periods despite their poor performance.
The new administration is presented with a critical opportunity to redirect these trends. Training each relevant individual within SLTT government agencies, or hiring new experts within each agency, is not cost- or resource-effective. Without appropriate training and support from the federal government, AI adoption is likely to be concentrated in well-resourced SLTT agencies, leaving others with fewer resources (and potentially more low income communities) behind. This could lead to disparate AI adoption and practices among SLTT agencies, further exacerbating existing inequalities. The administration urgently needs a plan that supports SLTT agencies in learning how to handle responsible AI procurement and use–to develop sustainable knowledge about how to navigate these processes over time—without requiring that each relevant individual in the public sector is trained. This plan also needs to ensure that, over time, the public sector workforce is transformed in their ability to navigate complicated AI procurement processes and relationships—without requiring constant retraining of new waves of workforces.
In the context of federal and SLTT governments, a federal center of excellence for state and local AI procurement would accomplish these goals through a “hub and spoke” model. This center of excellence would serve as the “hub” that houses a small number of selected experts from academia, non-profit organizations, and government. These experts would then train “spokes”—existing state and local public sector agency workers—in navigating responsible procurement practices. To support public sector agencies in learning from each others’ practices and challenges, this federal center of excellence could additionally create communication channels for information- and resource-sharing across the state and local agencies.
Procured AI technologies in government will serve as the backbone of local public services for decades to come. Upskilling government agencies to make smart decisions about which AI technologies to procure (and which are best avoided) would not only protect the public from harmful AI systems but would also save the government money by decreasing the likelihood of adopting expensive AI technologies that end up getting dropped.
Plan of Action
A federal center of excellence for state and local AI procurement would ensure that procured AI technologies are responsibly selected and used to serve as a strong and reliable backbone for public sector services. This federal center of excellence can support both intra-agency and inter-agency capacity-building and learning about AI procurement and use—that is, mechanisms to support expertise development within a given public sector agency and between multiple public sector agencies. This federal center of excellence would not be deliberative (i.e., SLTT governments would receive guidance and support but would not have to seek approval on their practices). Rather, the goal would be to upskill SLTT agencies so they are better equipped to navigate their own AI procurement and use endeavors.
To upskill SLTT agencies through inter-agency capacity-building, the federal center of excellence would house experts in relevant domain areas (e.g., responsible AI, public interest technology, and related topics). Fellows would work with cohorts of public sector agencies to provide training and consultation services. These fellows, who would come from government, academia, and civil society, would build on their existing expertise and experiences with responsible AI procurement, integrating new considerations proposed by federal standards for responsible AI (e.g., Executive Order 13960, OMB-M-21-06, NIST RMF). The fellows would serve as advisors to help operationalize these guidelines into practical steps and strategies, helping to set a consistent bar for responsible AI procurement and use practices along the way.
Cohorts of SLTT government agency workers, including existing agency leaders, data officers, and procurement experts, would work together with an assigned advisor to receive consultation and training support on specific tasks that their agency is currently facing. For example, for agencies or programs with low AI maturity or familiarity (e.g., departments that are beginning to explore the adoption of new AI tools), the center of excellence can help navigate the procurement decision-making process, help them understand their agency-specific technology needs, draft procurement contracts, select amongst proposals, and negotiate plans for maintenance. For agencies and programs with high AI maturity or familiarity, the advisor can train the programs about unexpected AI behaviors and mitigation strategies, when this arises. These communication pathways would allow federal agencies to better understand the challenges state and local governments face in AI procurement and maintenance, which can help seed ideas for improving existing resources and create new resources for AI procurement support.
To scaffold intra-agency capacity-building, the center of excellence can build the foundations for cross-agency knowledge-sharing. In particular, it would include a communication platform and an online hub of procurement resources, both shared amongst agencies. The communication platform would allow state and local government agency leaders who are navigating AI procurement to share challenges, learned lessons, and tacit knowledge to support each other. The online hub of resources can be collected by the center of excellence and SLTT government agencies. Through the online hub, agencies can upload and learn about new responsible AI resources and toolkits (e.g., such as those created by government and the research community), as well as examples of procurement contracts that agencies themselves used.
To implement this vision, the new administration should expand the U.S. General Services Administration’s (GSA) existing Artificial Intelligence Center of Excellence (AI CoE), which provides resources and infrastructural support for AI adoption across the federal government. We propose expanding this existing AI CoE to include the components of our proposed center of excellence for state and local AI procurement and use. This would direct support towards SLTT government agencies—which are currently unaccounted for in the existing AI CoE—specifically via our proposed capacity-building model.
Over the next 12 months, the goals of expanding the AI CoE would be three-fold:
1. Develop the core components of our proposed center of excellence within the AI CoE.
- Recruit a core set of fellows with expertise in responsible AI, public interest technology, and related topics from government, academia, and civil society for a 1-2 year placement;
- Develop a centralized onboarding and training program for the fellows to set standards for responsible AI procurement and use guidelines and goals;
- Create a research strategy to streamline documentation of SLTT agencies’ on-the-ground practices and challenges for procuring new AI technologies, which could help prepare future fellows.
2. Launch collaborations for the first sample of SLTT government agencies. Focus on building a path for successful collaborations:
- Identify a small set of state and local government agencies who desire federal support in navigating AI procurement and use (e.g., deciding which AI use cases to adopt, how to effectively evaluate AI deployments through time, what organizational policies to create to help govern AI use);
- Ensure there is a clear communication pathway between the agency and their assigned fellow;
- Have each fellow and agency pair create a customized plan of action to ensure the agency is upskilled in their ability to independently navigate AI procurement and use with time.
3. Build a path for our proposed center of excellence to grow and gain experience. If the first few collaborations show strong reviews, design a scaling strategy that will:
- Incorporate the center of excellence’s core budget into future budget planning;
- Identify additional fellows for the program;
- Roll out the program to additional state and local government agencies.
Conclusion
Expanding the existing AI CoE to include our proposed federal center of excellence for AI procurement and use can help ensure that SLTT governments are equipped to make informed, responsible decisions about integrating AI technologies into public services. This body would provide necessary guidance and training, helping to bridge the gap between high-level federal resources and the context-specific needs of SLTT agencies. By fostering both intra-agency and inter-agency capacity-building for responsible AI procurement and use, this approach builds sustainable expertise, promotes equitable AI adoption, and protects public interest. This ensures that AI enhances—rather than harms—the efficiency and quality of public services. As new waves of AI technologies continue to enter the public sector, touching a breadth of services critical to the welfare of the American people, this center of excellence will help maintain high standards for responsible public sector AI for decades to come.
This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.
PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.
Federal agencies have published numerous resources to support responsible AI procurement, including the Executive Order 13960, OMB-M-21-06, NIST RMF. Some of these resources provide guidance on responsible AI development in organizations broadly, across the public, private, and non-profit sectors. For example, the NIST RMF provides organizations with guidelines to identify, assess, and manage risks in AI systems to promote the deployment of more trustworthy and fair AI systems. Others focus on public sector AI applications. For instance, the OMB Memorandum published by the Office of Management and Budget describes strategies for federal agencies to follow responsible AI procurement and use practices.
Research describes how these forms of resources often require additional skills and knowledge that make it challenging for agencies to effectively use on their own. A federal center of excellence for state and local AI procurement could help agencies learn to use these resources. Adapting these guidelines to specific SLTT agency contexts necessitates a careful task of interpretation which may, in turn, require specialized expertise or resources. The creation of this federal center of excellence to guide responsible SLTT procurement on-the-ground can help bridge this critical gap. Fellows in the center of excellence and SLTT procurement agencies can build on this existing pool of guidance to build a strong theoretical foundation to guide their practices.
The hub and spoke model has been used across a range of applications to support efficient management of resources and services. For instance, in healthcare, providers have used the hub and spoke model to organize their network of services; specialized, intensive services would be located in “hub” healthcare establishments whereas secondary services would be provided in “spoke” establishments, allowing for more efficient and accessible healthcare services. Similar organizational networks have been followed in transportation, retail, and cybersecurity. Microsoft follows a hub and spoke model to govern responsible AI practices and disseminate relevant resources. Microsoft has a single centralized “hub” within the company that houses responsible AI experts—those with expertise on the implementation of the company’s responsible AI goals. These responsible AI experts then train “spokes”—workers residing in product and sales teams across the company, who learn about best practices and support their team in implementing them.
During the training, experts would form a stronger foundation for (1) on-the-ground challenges and practices that public sector agencies grapple with when developing, procuring, and using AI technologies and (2) existing AI procurement and use guidelines provided by federal agencies. The content of the training would be taken from syntheses of prior research on public sector AI procurement and use challenges, as well as existing federal resources available to guide responsible AI development. For example, prior research has explored public sector challenges to supporting algorithmic fairness and accountability and responsible AI design and adoption decisions, amongst other topics.
The experts who would serve as fellows for the federal center of excellence would be individuals with expertise and experience studying the impacts of AI technologies and designing interventions to support more responsible AI development, procurement, and use. Given the interdisciplinary nature of the expertise required for the role, individuals should have an applied, socio-technical background on responsible AI practices, ideally (but not necessarily) for the public sector. The individual would be expected to have the skills needed to share emerging responsible AI practices, strategies, and tacit knowledge with public sector employees developing or procuring AI technologies. This covers a broad range of potential backgrounds.
For example, a professor in academia who studies how to develop public sector AI systems that are more fair and aligned with community needs may be a good fit. A socio-technical researcher in civil society with direct experience studying or developing new tools to support more responsible AI development, who has intuition over which tools and practices may be more or less effective, may also be a good candidate. A data officer in a state government agency who has direct experience procuring and governing AI technologies in their department, with an ability to readily anticipate AI-related challenges other agencies may face, may also be a good fit. The cohort of fellows should include a balanced mix of individuals coming from government, academia, and civil society.