Memorandum M-25-25, issued by the Office of Management and Budget (OMB) on April 21, 2025, provides guidance for federal agencies to implement the **Utilizing Space Efficiently and Improving Technologies Act (USE IT Act)**. The primary goal is to shrink the federal real estate footprint by eliminating unused office space and ensuring compliance with “Return to Office” directives.

Key Requirements and Deadlines

• Mandatory Monitoring: All federal agencies (including those beyond the statutory requirements of the CFO Act) must begin monitoring utilization at public and leased buildings no later than May 4, 2025.
• First Reporting Deadline: The initial report must be submitted via OMB Collect by May 19, 2025, covering the period from May 4 to May 17, 2025.
• Ongoing Reporting: After the initial report, agencies must continue to report occupancy data every two weeks, aligned with their pay schedules.

Monitoring Technologies

Agencies must use standardized methodologies specified by the General Services Administration (GSA).

• PIV Card Data: Agencies are encouraged to use PIV card reader data from turnstiles or space access points. This data must protect personally identifiable information and only count the first credential use of the day per person.
• Alternative Tools: If PIV data is unavailable, agencies can use sensors, laptop occupancy tracking, or a “Daily Check-in Tool” provided in GSA playbooks.

Utilization Benchmarks and Metrics

• Occupancy Utilization: Defined as total usable square footage (USF) divided by the number of full-time employees assigned to a location.
• Building Utilization: Agencies are compared against a benchmark of 150 USF per person, with a target of 60% utilization of that benchmark.
• New Design Standard: Any office space acquired after the issuance of this memorandum must not exceed a design standard of 150 USF per person (excluding public-facing spaces).

Annual Reporting Requirements

In addition to biweekly updates, agencies must report annually on:

• Utilization broken down by individual building and lease.
• A comparison of each asset against the 60% utilization target.
• The methodology used for calculations.
• Updated office space design standards, which must be finalized within 12 months.

Sources

• https://www.whitehouse.gov/wp-content/uploads/2025/02/M-25-25-Implementation-of-the-Utilizing-Space-Efficiently-and-Improving-Technologies-Act.pdf
• https://www.congress.gov/crs-product/R48718
• https://www.gsa.gov/real-estate/use-it-act-and-occupancy-data