The Office of Management and Budget’s updated Circular A-11 with new requirements and deadlines for customer experience, real property and much more.
If the update to Office of Management and Budget Circular A-11 was a box of sugar cereal, the details about the planned pay raise for fiscal 2026 is the toy at the bottom of the box.
The rest of A-11, then, is all the sugary goodness leading up to the prize.
OMB issued its annual Circular A-11 update in late July and the 1,079 page tome is filled with dates and instructions for how agencies should put the final touches on their 2026 budget requests.
Digging deeper into the primer, agencies will find an extensive treatise on everything from improving customer experience to managing federal real property to updated requirements for using evidence and evaluation in programs.
But since everyone just wants to get to the toy at the bottom of the box, let’s start with that.
OMB told agencies to prepare for a 3% civilian pay raise as part of their 2026 budget planning.
“Agencies should consult with their OMB representative on the provisional estimate for the military pay raise for January 2026,” OMB wrote in A-11. “In making their final estimates for the fiscal 2026 budget, agencies should anticipate revising pay raise amounts after the President makes a pay raise decision. Your OMB representative will provide additional guidance during budget season.”
Before you get too excited, or depressed, keep in mind this is just the first step in a long process. But it’s a signal for what the Biden administration is thinking about for 2026.
In fact, the White House just completed one of the final steps for the 2025 pay raise last Friday when President Joe Biden issued his alternative pay plan. He will make the 2% raise final in December when he issues an executive order, assuming Congress doesn’t make any changes to the appropriations bill.
Now that you’ve received the fun toy at the bottom of the box, let’s eat through all the Froot Loops or Honeycombs that is A-11.
Here are five changes or interesting parts of A-11 that agencies should know about:
Before OMB started expanding A-11 in the 2000s, the circular has been mostly known as a budget planning document. So in keeping with its history, there are several dates agencies need to be aware of:
All of these dates tend to slip based on a number of factors, including the expected continuing resolution to start 2025 from Congress, possible partial government shutdown should the White House and Congress not agree on a CR and, of course, this being an election year, the new president will want to put their own stamp on any budget request for 2025.
And speaking of CRs and a possible partial shutdown, OMB included in A-11 updated lapse in appropriations plans. Agencies had to submit those documents to OMB by Aug. 1.
“Plans should be updated in 2025. Agencies must also submit an updated lapse plan to OMB for review whenever there is a change in the source of funding for an agency program or any significant modification, expansion, or reduction in agency program activities,” A-11 states. “Additional guidance on lapse plan submission and review for each potential lapse will be communicated with agencies, as needed.”
OMB added customer experience to A-11 back in 2018 under Section 280 and the requirements for agencies are ever expanding. With the Biden administration’s focus on customer experience, OMB added a few important updates starting with high impact service providers, which must, in collaboration with OMB, by May 31, designate at least two priority services for focused assessment that could include post-transaction customer feedback survey(s).
“Feedback surveys may be deployed at key touchpoints between the customers and the service provider along the service journey, or at the end of the customer journey, for each current designated service,” A-11 states. “Submit the dataset(s) for the post-transaction customer feedback survey(s) of each current designated service on time for each quarter.”
Additionally, OMB says agencies should conduct an annual CX capacity assessment and submit it to OMB by Feb. 21 for both HISPs and HISP-maintaining departments and discuss the resulting findings with OMB at an annual CX Deep Dive by April 23.
By May 30, agencies must develop a draft CX Action Plan and submit it to OMB. A final CX Action Plan will be part of annual budget for each designated HISP and HISP-maintaining department, with a focus on improvement actions for designated services.
Beyond high impact service providers, OMB also is telling agencies to include employee experience as an overarching component of CX. Though there isn’t much other details about what this means and how agencies should go about doing this.
A third item of note in Section 280 is OMB is trying to reduce the burden of the now dreaded Paperwork Reduction Act (PRA).
To capture near real-time customer feedback, agencies have found the requirements under the PRA have gotten in the way because it requires agencies to have certain information collection activities approved by Office of Information and Regulatory Affairs (OIRA).
But in A-11, OMB specifically details how agencies can collect citizen feedback without initiating PRA requirements. One way is research with nine or fewer members of the public or by using open ended questions and conducting non-scripted conversations.
In fact, the US Digital Service just released new user research about some common user research approaches that do not require PRA clearance because they do not qualify as an information collection under PRA regulations.
Beyond the ones mentioned in A-11, USDS also highlighted efforts that fall outside of the PRA such as directly observing someone using a product like filling out a form or finding information on a website.
Another big focus by OMB in A-11 was on real property.
We know in OMB’s recent telework report to Congress, the administration said agencies plan to shed millions of square feet of office space in the coming years. For example, the Department of Housing and Urban Development is expected to get rid of about 60% of its office space by 2038.
In A-11, OMB says each agency will need to provide a real property budget exhibit for all 2027 funding. In order to help agencies collect and report this information in an automated fashion, the Federal Real Property Council developed a new method to track budget and expenditure items using budget sub-object class codes in agency financial management systems.
“Agencies are encouraged to adopt the sub-object class codes to better track real property spend categories. However, it should be noted that adoption of the sub-object class codes is not mandatory,” A-11 states. “ Agencies, in their 2027 budget submissions, will have the discretion to follow this method or determine other ways to populate the exhibit.”
Agencies set up their first program inventories in February after more than a decade of starts and stops. The initial database included spending and performance data on 2,388 programs.
In A-11, OMB told agencies to continue to update that effort. By Nov. 15, 2024, agencies must complete an initial assessment of their current assistance listings and a preliminary plan to work toward establishing a single assistance listing, where appropriate, for each program.
Over the next 10 months, agencies have to update their strategic plan for 2026-2030. Those initial ideas are due to OMB by June.
“Agencies should update as applicable their strategic plans by applying information learned from strategic reviews and other data-driven performance reviews as they are conducted, as well as reflect organizational plans and learning related to the agency’s evidence and evaluation building efforts,” A-11 states. “Additionally, the fiscal 2026-2030 strategic plans will also include a separate section on evidence-building and capacity, implementing requirements aimed at advancing agency evaluation and evidence-building activities identified in the Evidence Act.”
OMB offered some high-level guidance to create new strategic plans and goals, including using language that the public will understand and avoiding technical terms as well as the goals should express future direction or vision.
The final draft version of the new strategic plans are due by September as part of the 2027 budget submission and then after OMB review and agency updates, the expectation is for agencies to publish the new documents along with the 2027 budget request to Congress in February 2026.
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Jason Miller is executive editor of Federal News Network and directs news coverage on the people, policy and programs of the federal government.
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