Joseph Hof
Mar 29, 2025
DOGE 17.0
FOR IMMEDIATE RELEASE
March 29, 2025
Cottleville, Missouri – Hof Law, LLC has officially submitted its seventeenth proposal to the Bipartisan House Department of Government Efficiency (DOGE) Caucus, marking another step in the firm’s ongoing efforts to enhance governmental efficiency and ethical oversight. This latest proposal underscores critical policy concerns regarding Post-Government Employment (PGE) regulations, the evolving alignment between the White House and Office of Management and Budget (OMB) DOGE team and the Bipartisan House DOGE Caucus, and the need for knowledge retention in Federal agencies, including the Federal Emergency Management Agency (FEMA).
Key Elements of the Proposal
OGE PGE Guidance and Ethical Considerations
The proposal examines whether Office of Government Ethics (OGE) PGE guidance appropriately allows recently removed Federal employees to engage with the Bipartisan House DOGE Caucus and Executive Branch without violating ethical restrictions. Hof Law highlights how a divergence in guidance interpretation could create the appearance of compliance risks for former Federal employees, particularly those who continue contributing expertise post-tenure.
Managing Attorney Joseph Hof emphasized the significance of this issue:
If guidance is not clarified, we risk a future where well-intentioned former Federal officials—who have been encouraged by the White House and OMB to engage with DOGE—could face unforeseen regulatory scrutiny years down the line. This would not only be unjust but could also fuel public distrust in government institutions, Joe said.
Divergence Between the Bipartisan House DOGE Caucus and the Executive Branch DOGE Team
Hof Law’s proposal highlights an apparent discrepancy between the Bipartisan House DOGE Caucus and the White House/OMB DOGE team—a shift that may have surfaced on or after March 6, 2025—indicator of this divergence was the change in language on Co-Chairman Aaron Bean’s website regarding DOGEs.
The proposal raises the key question of whether the divergence is a result of a March 6, 2025 meeting involving President Trump and Executive DOGE leadership. If so, the shift could be material to an OGE analysis of the ethical obligations of key figures, such as Special Government Employee (SGE) Elon Musk, who currently serves as a Senior Advisor and the leader of the the Executive DOGE team. Mr. Musk may be asked to disclose his finances publicly if he continues to serve in his SGE role after May 5, 2025.
To maintain continuity, Hof Law suggests that if Musk were to transition out of his SGE role, another prominent industry leader—such as a Jeff Bezos or a Sam Altman—could step in as DOGE team lead, with Musk serving in a vice coach/mentorship capacity. This structured leadership transition resembles FEMA Region 2’s historical approach, where multiple regional administrators rotated between 2020 and 2022.
Institutional Knowledge Retention – The Case of FEMA’s Chief Counsel’s Office
As part of DOGE 14.0, Hof Law stresses the importance of capturing in-house legal reporting through use of Artificial Intelligence (AI). A key example cited is the abrupt departure of the Chief Counsel and Deputy Chief Counsel of FEMA’s Office of Chief Counsel, both of whom had several decades' of legal expertise in an influential agency component critical to the country's national security.
The firm’s proposal suggests that it behooves the Federal government to try to preserve vital institutional wisdom, ensuring that new leadership inherits the strategic insights of their predecessors.
A Call for Action and Collaboration
Hof Law, LLC urges the Bipartisan House DOGE Caucus to take these considerations seriously and engage in further discussions to refine ethical guidance, address structural realignments, and ensure continuity of expertise, so we can fortify public trust in our government institutions. If requested, Hof looks forward to collaborating with The Hill and The Executive to advance these necessary reforms, Joe added.
Media Contact:
Joseph Hof, MCM, CEM
Managing Attorney, Hof Law, LLC