OMB Circular A-11 (2025), Section 51 - Basic Justification MaterialsStratML rendition of Section 51 guidance. Captures general and program justification requirements; IT and capital asset information; account structure alignment; evidence, evaluation, and analytical expectations; and special topics (tax, receipts, user charges, IG funding, spectrum, tribal consultation). Includes the key directives that (1) budget submissions to OMB may be in the form of a performance plan (§51.1) and (2) an agency’s budget submission may be structured as the Agency Performance Plan such that a separate APP is not required if statutory requirements are met (§51.7).Provenance: OMB Circular A-11 (2025), Section 51. Summary of Changes: Conforming edits to Part 6 references (51.1, 51.3, 51.7, 51.9); removes IT CPIC milestones (51.3) and shifts to product-agnostic terminology (51.19); removes Evidence Submission requirement as part of budget submissions (51.9); removes reference to revoked E.O. 14112 (51.17); moves real property guidance to new section 56 (formerly 51.22). Assistant: ChatGPT (StratML rendering). PublicationDate: 2025-09-18.Office of Management and BudgetOMB51a11-omb-2025Executive Office of the President; issues government-wide budget justification guidance.Executive Branch AgenciesAgencies preparing and submitting budget justifications and related materials to OMB and the Congress.Performance.govPublishes agency performance information and plans as applicable.Evaluation.govPublishes Evidence Plans and Capacity Assessments.Clear, evidence-informed, and aligned budget justifications that support decisions and improve outcomes.vision-51-2025To provide requirements and expectations for agency budget submissions, including performance integration, analytical rigor, and capital planning.mission-51-2025General RequirementsInitial September budget submission includes leadership summary, policy/strategy, resource requests, alignment to OMB planning guidance, differences from Administration policy, and evidence supporting proposals; addresses current-year changes, outyear impacts, additional funding proposals with offsets, and significant FTE changes with justification.51-1-general51.1Policies and Resources SummarySummarize broad policies and strategies and the total amounts of discretionary and mandatory budgetary resources requested.51-1-policies-resources51.1.1OMB Planning Guidance AlignmentExplain how proposed policies, strategies, and requested resources align with OMB planning guidance for budgetary resources.51-1-omb-alignment51.1.2Policy DifferencesIdentify any significant proposed differences from current Administration policies.51-1-policy-differences51.1.3Evidence BasisProvide a thorough discussion of evidence for major proposed policies, including evaluation results, program performance indicators and goals, and other relevant data analytics and research studies—both positive and negative.51-1-evidence-basis51.1.4Current-Year ChangesDescribe significant proposals for changes in the current year budget and how they relate to the budget year and outyear requests.51-1-cy-changes51.1.5Outyear Spending ChangesDescribe significant proposals or changes in spending patterns for the 5–10 year period beyond the budget year and their relationship to outyear planning guidance and current/budget-year policies.51-1-outyear-changes51.1.6Above-Guidance Proposals and OffsetsProvide a separate submission proposing and justifying additional funding for individual programs above guidance levels to meet Presidential priorities and identify potential discretionary offsets in lower-priority programs.51-1-above-guidance-offsets51.1.7FTE ChangesPresent significant changes in full-time equivalent employment and justify them relative to projected workload, strategic planning initiatives, and reengineering efforts.51-1-fte-changes51.1.8Performance Plan FormBudget submissions to OMB may be in the form of a performance plan; Part 6 (sections 200–290) provides instructions for developing and submitting updated Agency Strategic Plans and Agency Performance Plans.51-1-pp-form51.1.9Program Justification RequirementsProvide concise, specific written justifications covering all programs and activities; include full program costs and align accounts/program activities to strategic objectives; coordinate on shared programs; include appropriations language proposals and legislative proposal analyses; present benefit–cost comparisons and marginal analyses; respond to OMB-specified formats and timelines.51-2-program-justification51.2_f1b756e2-94c3-11f0-91c7-55d9f782ea00Information Technology InvestmentsDo not submit an IT Resources Statement with the budget; provide IT portfolio and budget data per Section 55. Align budget accounts with programs and strategic objectives.51-3-it51.3_f1b75908-94c3-11f0-91c7-55d9f782ea00Account Structure RelationshipWhere major programs do not coincide with account structure, include a table mapping programs to accounts (budgetary resources and FTE) and explanatory narrative; requirement applies to major programs and activities.51-4-account-structure51.4_f1b75a34-94c3-11f0-91c7-55d9f782ea00Restructuring and Process RedesignIdentify restructuring or reengineering that yields savings and improves management/service delivery, including from IT and other investments.51-5-restructuring51.5_f1b75aa2-94c3-11f0-91c7-55d9f782ea00Grants and Infrastructure InformationInclude systematic economic analyses of expected benefits and costs per Executive Order 12893.51-6-grants-infrastructure51.6_f1b75bce-94c3-11f0-91c7-55d9f782ea00Performance Goals, Measures, and IndicatorsAgency budget submissions for the FY 2025 Budget may be structured as the Agency Performance Plan required by GPRAMA (31 U.S.C. 1115); a separate APP is not required if the submission covers all programs and addresses statutory APP requirements; see Section 240 for APP requirements and Section 22 for posting/notification details.51-7-performance-integration51.7_f1b75c3c-94c3-11f0-91c7-55d9f782ea00Other Analytical InformationProvide workload analyses, unit costs, productivity trends, enterprise risk management profiles, and capital-investment productivity impacts; use productivity measurement and ERM to justify staffing and requirements; be prepared with allocation bases and geographic distribution data.51-8-analytics51.8_f1b75caa-94c3-11f0-91c7-55d9f782ea00Evidence and EvaluationUse evidence and data, including evaluation findings, to inform FY 2027 budget requests; see Section 290 for Evidence Plan requirements; Evidence Submission as part of budget submissions is removed.51-9-evidence51.9_f1b75d18-94c3-11f0-91c7-55d9f782ea00Supplemental Appropriations ExplanationsExplain why needs were not in regular estimates; justify urgency; propose offsets and show effects on programs, FTE, and financing.51-10-supplementals51.10_f1b75d90-94c3-11f0-91c7-55d9f782ea00Taxes and Tax ExpendituresReflect tax expenditures and incentives; consult Treasury’s Office of Tax Analysis on tax proposals; provide problem statements, subsidy need, non-tax alternatives, and rationale for tax approach; evaluate tax expenditures akin to spending programs and develop data/methods to assess effects.51-11-tax51.11_f1b75e08-94c3-11f0-91c7-55d9f782ea00Receipts Estimate ChangesExplain major year-to-year receipt changes and trends; notify OMB of large proprietary receipt increases to Treasury accounts 1435.00 and 3220.00; align explanations with legislative programs and outyear estimates.51-12-receipts51.12_f1b75e80-94c3-11f0-91c7-55d9f782ea00User ChargesReflect biennial review results; for new charges needing legislation, justify the proposal, enactment strategy, administrative plans, and prospects; follow Circular A–25.51-13-user-charges51.13_f1b75f02-94c3-11f0-91c7-55d9f782ea00Unobligated Balances in Liquidating AccountsTransfer unobligated balances to the general fund at year-end unless exempted; justify any balances to carry forward (see Section 185.3(l)).51-14-liquidating51.14_f1b75f84-94c3-11f0-91c7-55d9f782ea00Direct Loans and Loan GuaranteesInclude proposed changes to technical assumptions, methodology, or source data underlying credit subsidy estimates and provide justification; consult Circular A–129 and Section 185.51-15-credit51.15_f1b76006-94c3-11f0-91c7-55d9f782ea00Funding for Inspectors GeneralInclude IG-submitted estimates/requests and agency-head aggregates per 5 U.S.C. 406(g); treat pre-decisional information as confidential under Section 22 until the President’s Budget is submitted; note which items are required to be included in the Budget.51-16-ig51.16_f1b76092-94c3-11f0-91c7-55d9f782ea00Tribal Consultation ProcessDescribe the agency’s tribal consultation process and input received for budget development or state that no consultation is required if no programs have tribal implications; grounded in EO 13175 and the Presidential memorandum on nation-to-nation relationships.51-17-tribal51.17_f1b76128-94c3-11f0-91c7-55d9f782ea00Spectrum-Dependent SystemsDemonstrate spectrum value/availability considerations for new or modified systems, addressing non-spectrum or commercial alternatives, reuse of existing Federal systems, and collaboration with similar users.51-18-spectrum51.18_f1b761b4-94c3-11f0-91c7-55d9f782ea00Capital Asset BudgetingProvide business cases to justify acquisition/operation of capital assets; follow the Capital Programming Guide (CPG) and related appendices; submit business cases with the budget.51-19-capital51.19Information TechnologyReport IT portfolio/budget data per Section 55 (including major investment requirements); see A-130 and CPG; agencies not required to report to OMB still apply internal IT capital planning; technical specs at https://github.com/GSA/ITDB-schema.51-19-it51.19.1Non-Information TechnologyProvide business cases per Section 25 templates; definitions in the CPG; include instructions, deadlines, and exemptions.51-19-nonit51.19.2AircraftUse the aircraft-specific business case template (links in Section 25 Table 1) with applicable submission requirements.51-19-aircraft51.19.3FacilitiesFor major facility investments, be prepared to provide materials identified in Section 31.8(a) upon OMB request.51-19-facilities51.19.4Reception and Representation AllowancesWhen requesting increases above FY 2026 or current levels, include proposed increase amount, account info/appropriations language, and rationale for inclusion in the FY 2027 Budget.51-20-rr51.20_f1b7624a-94c3-11f0-91c7-55d9f782ea00Low-Value Spending PrioritiesIdentify opportunities to redirect resources from lower- to higher-priority activities and eliminate unnecessary spending, including duplicative efforts, improper/no-longer-needed Federal roles, restructuring, and reducing high-cost administrative spending; follow OMB spring guidance.51-21-low-value51.21_f1b762ea-94c3-11f0-91c7-55d9f782ea002025-09-18https://www.whitehouse.gov/wp-content/uploads/2025/08/a11.pdfOwen AmburOwenAmburOwen.Ambur@verizon.net