Reports / Federal agency restructuring / Court records

DHS to FEMA: who ordered the staffing cut?

A federal court reconstructed the instruction chain behind a plan to reduce FEMA staffing by about half. Its evidence includes officials' sworn testimony, diary notes, agency staffing assessments, a December 2025 staffing proposal, and lost Signal messages.

Updated November 11, 2026. The Story remains unchanged. A 50% staffing proposal was not a finding that half the FEMA workforce was actually dismissed.

The reconstructed chain

Named people and the contemporaneous documents

  1. January–March 2025 — OPM guidance followed by DHS restrictions. Amanda Scales of OPM told DHS personnel chief Roland Edwards and deputy Mischell Navarro on January 21 that DHS was exempt from the federal civilian hiring freeze. DHS's separate March 14 internal hiring-verification memorandum nonetheless meant FEMA had to seek DHS permission to extend certain Cadre of On-Call Response/Recovery (CORE) term appointments. FEMA human-capital officials sought clarification and DHS confirmed a waiver requirement for positions not classified as mission-critical. The court later found that DHS had improperly usurped protected FEMA personnel authority. [1]
  2. Early December 2025 — direction from DHS. Joseph Guy was DHS deputy chief of staff and Kara Voorhies was understood by FEMA leadership to advise the DHS secretary on FEMA. Then-FEMA acting leader Karen Evans testified Guy told her to include an option for a 50% staffing reduction. Her December 2–4 personal planner documented discussions with Guy and Voorhies. The court found the instruction came from DHS, likely through those two officials. [1]
  3. December 4, 2025 — a numerical target submitted. Evans sent DHS an annual FY2026 staffing plan projecting 11,383 employees, roughly half FEMA's prior staffing. Her contemporaneous note referred to a conversation with Voorhies about that exact figure. The court found FEMA's managers and human-capital officer had not recommended that reduction. [1]
  4. December 2025–January 2026 — actions followed. FEMA staff prepared renewal requests for CORE employees. The court found Evans did not send the relevant request to restore independent renewal authority. At the beginning of January, notices were sent to some CORE employees whose terms expired. The court did not find that the entire proposed 50% cut had taken effect. [1]

Evidence grade: Court findings and deposition testimony cited in a partial summary-judgment order. A judge's finding that Guy and Voorhies likely transmitted the instruction does not establish who first invented the 50% target or that any of Thiel, Musk, Miller and Vought personally issued this particular instruction.

Did OMB and OPM know about the target?

Yes, a contemporaneous email identifies prior high-level notification. The September 11 court order quotes a December 17, 2025 email from Evans explaining that the approximate 11,500 staffing figure had been provided to OPM and OMB at a high level, although it had not been made public. That connects the FEMA staffing proposal to the central personnel and budget offices under examination. [1]

What this does not show: The email does not name the OMB or OPM recipients, identify a written approval, show whether either office proposed the number, or prove it was adopted as an approved Agency RIF and Reorganization Plan (ARRP). Those are still missing links in the decision chain.

The February 26, 2025 OMB–OPM memorandum, signed by Russell Vought and Charles Ezell, required agency plans to be submitted to both offices for review and approval by March and April deadlines, with progress reports. In separate litigation, the July 18, 2025 court ordered production of submitted and approved agency ARRPs and addressed the government's claim that the plans were internal deliberations. The Supreme Court stayed a preliminary injunction but did not decide the legality of any individual agency plan. The December FEMA plan and earlier ARRP procedures should not be equated without the underlying filings and approvals. [3] [4] [5]

See the Project 2025–OMB–DOGE decision-chain report.

Newly traced directive · November 5, 2025

A separate annual staffing process: Vought and Kupor

Two different approval systems must not be collapsed. The February 26, 2025 Vought–Ezell guidance required Phase 1 and Phase 2 Agency RIF and Reorganization Plans to be reviewed and approved by OMB and OPM in March and April. A later October 15 executive order (EO 14356) established annual staffing plans. Under a November 5, 2025 joint memorandum signed by OMB Director Russell Vought and OPM Director Scott Kupor, agencies had to submit fiscal-year 2026 Annual Staffing Plans to OMB and OPM by December 1, 2025. [8] [9]

The November guidance required a Strategic Hiring Committee by November 17, led by senior agency officials including the deputy agency head and chief of staff, with limited permitted substitutions. The memorandum lists workforce@omb.eop.gov and staffing@opm.gov for committee membership notices and potential plan amendments and requires quarterly updates. These are documented record repositories, not evidence that FEMA's December proposal or a particular OMB/OPM official used them. The February 2025 RIF guidance used a different OPM submission address, tracking@opm.gov. [8]

Timing question: Evans sent FEMA's 11,383-position proposal to DHS on December 4, three days after the general annual-plan deadline. The public court order does not establish when DHS sent an agency-level plan to OMB/OPM, whether FEMA was included in a consolidated DHS submission, or whether central officials signed an approval. A December 17 email confirms high-level communication of a rounded 11,500 figure, not an approval. [1]

A further missing link: testimony summarized by the court says that during a May 19, 2026 FEMA staff meeting, agency leaders told employees DHS had not yet approved FEMA's most recent staffing plan. This is an attributed statement about DHS approval status in May, not a finding about OMB/OPM approval of the December proposal. [1]

Later framework—not retroactive proof: On November 10, 2026 Kupor circulated OPM's new staffing-governance rules, published October 29 and effective November 30, 2026. They require chief human capital officer oversight and agency-head written certifications during staffing reviews and specify joint OMB/OPM evaluation of plans. These rules were not yet effective when FEMA prepared the disputed 2025 plan and cannot be retroactively applied to that decision. [11]

A later operational control point: a July 30, 2026 OPM staffing-plan bulletin instructed agencies to submit FY2027 staffing information through Collect.opm.gov by September 30. OPM warned that an agency's USA Staffing system access would be locked beginning October 1 if the required submission was missing, pending submission and OMB/OPM approval. The bulletin identified Matthew Davis as a contact for access to the portal, not as an individual plan approver. This is a written enforcement mechanism; the bulletin is not proof a particular agency's system was locked and is not evidence of FEMA's 2025 approval. [12]

Documents still needed: DHS's complete FY2026 staffing submission, any FEMA annex and revisions, OMB/OPM intake/assignment records and email headers, Strategic Hiring Committee roster/minutes, written clearance or rejection, DHS sign-off or lack of it, and the original creator and spreadsheet methodology for the figure 11,383.

FEMA managers challenged the numbers

Two FEMA program and regional workforce assessments estimated FY2026 staffing needs of 24,812 and 23,146, respectively. The submitted proposal instead targeted 11,383. FEMA chief human capital officer La’Toya Prieur recommended holding staff steady and was not informed before the 50% proposal was submitted. The court cited her December 2025 memo explaining the mission impacts of losing CORE employees. [1]

The court found that the number appeared unsupported by reasoned agency analysis. The independent assessments are an important counterpoint to any suggestion that every government actor supported the cut.

Independent audit of actual outcomes

What workforce losses actually occurred?

An August 4, 2026 Government Accountability Office (GAO) audit found FEMA averaged roughly 25,134 employees in fiscal 2025 and experienced more than 4,300 separations during that fiscal year, 55% more separations than in fiscal 2024. Those 2025 separations preceded FEMA's December 2025 proposed FY2026 halving and must not be attributed to that proposal. GAO also reported that 152 of 778 CORE terms that came up for renewal between January 1 and April 4, 2026, had not been renewed. The agency later offered new appointments to some affected employees. [10] [1]

GAO concluded that FEMA had not based its 2025–26 workforce changes on a forward-looking workforce analysis and warned of mission-readiness risks. In its audit, GAO recommended a new strategic plan and documented workforce planning. These are audited consequences of wider workforce decisions, not an audit attributing each loss to any particular member of the four-person research hypothesis. [10]

What happened to the communications?

September 11, 2026 brought a separate evidence-preservation ruling. The court found that Karen Evans intentionally deleted relevant Signal chats and shortened the expiration timer for a group chat involving Guy and Voorhies after discovery orders had been issued. The court authorized a presumption that missing messages were unfavorable to defendants, barred hindsight testimony denying particular elements of the plan, and awarded plaintiffs litigation-related fees. [2]

Joseph Guy's phone also lost relevant messages after Signal was reinstalled while the discovery dispute was ongoing. The judge called the circumstances highly suspicious but did not make the same intentional-destruction finding against Guy. The court record also identifies chat groups with names including FEMA RIF, DOGE-FEMA and FEMA 2.0. The existence of such chats does not by itself establish that any named DOGE leader personally instructed the FEMA reduction. [2]

The earlier DOGE–DHS personnel report separately documents Voorhies's reported paid subcontracting arrangement through a DOGE operative's business. This creates a personnel-and-contracting context, but the subcontract did not automatically confer lawful agency authority. [7]

What the court decided—and what remains pending

On September 11, 2026, Judge Susan Illston granted plaintiffs partial summary judgment on Administrative Procedure Act claims. The court found DHS violated FEMA's statutory independence under the Post-Katrina Emergency Management Reform Act by taking control of CORE renewals and ordering a 50% staffing plan. It also found the January nonrenewals violated the applicable funding restriction and were arbitrary and capricious. The court declined to decide separate ultra vires claims because of its APA rulings. [1]

The remedies phase remained unresolved in the reviewed chronology. The court did not hold that all planned reductions occurred: the government later offered new appointments to affected CORE employees, and the final FEMA Review Council report removed the draft's 50% recommendation. Later court orders or appellate action can change the procedural posture; the underlying September findings are dated accordingly. [1] [6]

The next documents needed

  1. Source of 11,383: the complete submitted December 4 staffing plan, its creation/edit history and any prior DHS, OMB, OPM or DOGE target worksheets.
  2. Who saw it: the December 17 notification, named OMB/OPM recipients and any comment, sign-off or rejection.
  3. Who gave approvals: signed FEMA/other agency ARRPs, waiver and exemption requests, OMB/OPM responses and resulting employee actions.
  4. Who communicated: surviving Signal records, contemporaneous calendars and memoranda, with court-ordered adverse inferences identified separately from produced communications.
  5. Who was paid and assigned: Voorhies's contract terms and government access authorization, plus any formal DOGE detail agreements relevant to FEMA.

We are investigating whether the same authority and personnel channels recur across agencies. The court proves a specific DHS-to-FEMA decision chain; it does not by itself prove a four-person private command structure.