Minibus Implementation Safeguards Bill (2027) - Adam Neil Arafat for Congress

Will this slow down urgent work?

No. Urgent safety work and court ordered compliance continue with narrow and renewable certifications.

Is there new bureaucracy?

No. The approach is simple. It uses short certifications and public notice backed by independent checks.

Does this change taxes?

No. The focus is on standards, fairness, and better execution. Any costs are covered by savings and recovery of waste.

TITLE I - DEFINITIONS AND COVERED PERIOD
SEC. 101. COVERED PERIOD.
Covered period begins on adoption of articles of impeachment against a sitting President or principal officer and ends 90 days after final Senate disposition.
SEC. 102. KEY TERMS.
Executive action
includes rules, orders, directives, guidance, policies, adjudications, personnel actions, procurements, grants, and agreements first initiated in a covered period.
Funds
means money and all federal resources: supplies, equipment, staff time, contractor services, IT systems, facilities, seals, and stationery.
Compliance identifier
is a unique Office of Management and Budget ID confirming required submissions and certifications.
Explanation:
Tight definitions close common workarounds and make audits straightforward.
TITLE II - COMPLIANCE IDENTIFIER AND PUBLICATION INTEGRITY
SEC. 201. Office of Management and Budget COMPLIANCE IDENTIFIER.
Office of Management and Budget issues an ID only after the agency submits legal authority, a plain-language impact summary, the certification in Title III, and an internal control checklist. Office of Management and Budget maintains a public, machine-readable index.
SEC. 202. FEDERAL REGISTER AND GPO CONTROLS.
OFR refuses publication and GPO withholds printing or hosting for actions lacking a valid compliance ID or life-safety certification.
SEC. 203. AUTHENTICATION AND SEALS.
GSA withholds official seals, stationery, and certificates for non-compliant actions.
SEC. 204. IT ROUTING BLOCKS.
The Federal CIO Council publishes routing and deployment controls to prevent hosting of non-compliant actions on .gov systems.
Explanation:
Creates a single checkpoint and gives OFR/GPO/GSA/CIO clear rules to stop unlawful publication and hosting.
TITLE III - CERTIFICATION, EXCEPTIONS, AND USE OF FUNDS
SEC. 301. CONDITION ON USE OF FUNDS.
No funds or resources may be used to implement, publish, host, or authenticate an executive action first initiated in a covered period unless it has a valid Office of Management and Budget ID or a life-safety certification.
SEC. 302. AGENCY HEAD CERTIFICATION.
The agency head certifies under penalty of law that the action is authorized, consultations occurred, and submissions are complete and accurate.
SEC. 303. LIFE-SAFETY EXCEPTION.
Allows immediate action only for imminent threats to life, disaster, or national security. Time-limited to 30 days unless renewed with findings. Office of Management and Budget tags such IDs with an “-LS” suffix.
SEC. 304. PERSONNEL ACTIONS.
OPM refrains from onboarding or transfers whose primary duties would implement a non-compliant action.
Explanation:
Simple guardrail: no compliance, no spending or staffing.
TITLE IV - TRANSPARENCY AND AUDITS
SEC. 401. Office of Management and Budget PUBLIC DASHBOARD.
Public, machine-readable dashboard listing compliance IDs, life-safety certifications, agencies, and status updates.
SEC. 402. Government Accountability Office AUDITS.
Government Accountability Office audits compliance and reports to Appropriations, Oversight, and authorizing committees within 60 days after each covered period ends.
SEC. 403. inspector general HOTLINES AND ADVISORIES.
Agency inspectors general stand up a dedicated hotline for non-compliance and issue advisories when patterns emerge.
TITLE V - ENFORCEMENT AND REMEDIES
SEC. 501. APPORTIONMENT AND OBLIGATION CONTROLS.
Office of Management and Budget withholds apportionment to prevent obligation for non-compliant actions.
SEC. 502. CLAWBACK AUTHORITY.
Agencies de-obligate unobligated balances and pursue recovery of improper payments where permitted by law.
SEC. 503. KNOWING VIOLATIONS.
Knowing violations trigger Antideficiency Act referrals and other applicable consequences.
SEC. 504. LIMITED PRIVATE RIGHT OF ACTION.
Injured parties may seek declaratory and injunctive relief to compel compliance. No monetary damages.
Appropriations Tools: Surgical Riders & Holman Reductions
When policy compliance is defied, Congress may use tightly scoped appropriations tools to condition spending or right‑size positions. These tools complement the safeguards above and should be drafted narrowly to the specific activity.
(a) Narrow Spend Limits (Surgical Riders)
Prohibit or condition the use of funds for a
specific
action unless a measurable compliance condition is met.
(b) Compliance Triggers & Certifications
Pair riders with agency head certifications (and Federal Register publication) to verify that legal and procedural conditions are satisfied before funds flow.
(c) Holman Reductions (Position/Grade/FTE)
Where persistent non‑compliance is tied to identifiable roles, apply Holman language to reduce or eliminate positions or salaries narrowly related to the defiant activity.
(d) Examples (Paste‑Ready)
Rider - Conditional Spend.
None of the funds appropriated or otherwise made available by this Act may be used to implement or enforce
<Specific Action> unless the head of the agency certifies to the Committees on Appropriations and <Authorizing>
that <Measurable Condition> is satisfied and publishes such certification in the Federal Register.
Rider - Prohibition with Life‑Safety Carve‑Out.
None of the funds made available by this Act may be used to <Specific Action>, except to the extent necessary to address
an imminent threat to life or court‑ordered compliance, with written notice to the Committees within 7 days.
Holman - Position Adjustment.
For the fiscal year covered by this Act, the position of <Title/Office> within <Bureau/Program> is hereby reduced to a salary
rate of $<Amount> and the number of FTEs assigned to <Unit/Project> is reduced by <N>, effective upon enactment, solely with
respect to duties related to <Non‑Compliant Activity>.
Open Riders & Holman Templates
Oversight Toolkit: Appropriations Play
TITLE VI - JUDICIAL REVIEW
SEC. 601. THREE-JUDGE DISTRICT COURT; DIRECT APPEAL.
Cases are heard by a three-judge district court with a target resolution of 60 days and direct appeal to the Supreme Court.
SEC. 602. STANDARD AND SCOPE.
Courts determine whether Titles II or III were violated. Deference applies only to exigency facts in life-safety certifications, not legality.
SEC. 603. NO AUTOMATIC STAY.
Filing does not stay enforcement. Courts may grant temporary relief on the usual showing.
TITLE VII - WHISTLEBLOWERS AND ANTI-RETALIATION
SEC. 701. PROTECTIONS.
Employees and contractors who report non-compliance to inspectors general, Government Accountability Office, Office of Management and Budget, or Congress are protected under existing whistleblower laws.
SEC. 702. INCENTIVES.
inspectors general may recommend commendations or awards for disclosures that prevent unlawful obligations.
TITLE VIII - GENERAL PROVISIONS; SUNSET; SEVERABILITY
SEC. 801. COORDINATION AND GUIDANCE.
Office of Management and Budget, OFR, GPO, GSA, OPM, and the CIO Council issue joint guidance within 14 days of enactment.
SEC. 802. SUNSET.
Applies to actions first initiated during covered periods beginning within 4 years after enactment.
SEC. 803. SEVERABILITY AND EFFECTIVE DATE.
Severable. Takes effect on enactment.
Results & ROI
Clean process:
One compliance ID at Office of Management and Budget gives OFR, GPO, GSA, and CIO clear rules to accept or refuse actions.
Real accountability:
A public dashboard plus a 60-day Government Accountability Office audit window makes non-compliance visible fast.
No loopholes:
“Funds” includes staff time, IT, and facilities, not just money.
Safety protected:
Narrow, time-boxed life-safety carveout with documentation.
Fast resolution:
Three-judge court with direct appeal keeps disputes from dragging out.
Enforceable appropriations tools:
Narrow riders and targeted Holman adjustments align spending with compliance.
Back to All Bills

• Clear standards and faster resolution.
• Lower waste and better outcomes.
• Transparent processes that the public can see.
• Enforceable duties with quick court review.