[konklone]

I wouldn't use the word "illegal" - it's a directive of OMB (the White House's management and budget office), not a law or a regulation or an executive order. The only true enforcers are OMB themselves.

But to answer your other question, as part of the Department of Commerce, a "CFO Act" agency, USPTO would not be exempt.

[kakarot]

Thank you for clearing that up. Are you aware of what kind of consequences might be incurred at the expense of disobeying the OMB as a government entity?