$99,999 DHS Contracts Balloon Under Kristi Noem’s Directive

In June, Department of Homeland Security (DHS) Secretary Kristi Noem issued a directive requiring her sign-off on any department obligations above $100,000. Since then, several contract awards have seemingly skirted that obstacle.

Once in August and again in September, Immigration and Customs Enforcement (ICE) made contract awards of $99,999 related to law enforcement training to Team Carney, a management consulting company.

September also saw the Secret Service award MacGyver Solutions with $99,999.99 for Polaris 1000 all-terrain vehicles, the Border Patrol award $99,999.96 to Quantico Tactical for “chemical munitions,” and ICE award Impres Technology Solutions with $99,999.98 for information technology to enable “AI-driven analytics,” among other capabilities.

In October, U.S. Citizenship and Immigration Services inked a deal with Palantir Technologies for $99,999.99 for just over a month of work “to implement phase 0 of the vetting of wedding-based schemes (VOWS) platform.”

While the value of these DHS contracts is relatively low, that foot in the door for Palantir at the early stage of this project could grow into a more lucrative opportunity, as agencies often award incumbent contractors with continuing work. “A 1 month phase for $100k let’s see what it turns into,” wrote one social media commentator who focuses on Palantir and who flagged that October 28 award.

And there are five other contract awards by DHS components since August that fit the pattern of falling between $99,999 and $99,999.99. All of these contracts fall within one dollar below the threshold set by Noem in her June directive.

There are no other DHS contract awards falling in this range this year prior to August, according to the Project On Government Oversight’s (POGO) analysis of federal data. The months before September 30 are a particularly busy time for federal agencies to award contracts before funding for the fiscal year expires.

Moreover, stretching back to the beginning of fiscal year 2016 — October 1, 2015 — DHS components have only made seven other awards in this range, according to the data at USAspending.gov. That’s a period encompassing parts of or the entirety of the Obama, first Trump, Biden, and second Trump administrations.

Out of 18 DHS contract awards falling between $99,999 and $99,999.99 that were made over this period of just more than a decade, 11 — over half — have occurred in the last few months.

Five of the 11 are from ICE, and one is from the Border Patrol — two agencies at the center of President Donald Trump’s immigration enforcement agenda.

“These contracts were for routine operational needs,” DHS Assistant Secretary for Public Affairs Tricia McLaughlin told POGO. “Under Secretary Noem’s leadership, DHS is rooting out waste, fraud, abuse, and is reprioritizing appropriated dollars — saving taxpayers more than $13.2 billion in her first 7 months.”

“Her contract policy works, clearly,” McLaughlin said.

While DHS under Noem has claimed significant savings, the department obligated $171.2 billion in taxpayer dollars in fiscal year 2025 — that’s about $30 billion more than fiscal year 2024.

Noem’s June policy, first reported by Federal News Network, requires that DHS “requests for approval of obligations above the $100,000 threshold must be submitted via memo through the Executive Secretary process. As with any request for secretarial approval, please allow a minimum of five days for front office review.” The June directive dramatically lowered the review threshold from $20 million, set in May, and an earlier limit of $25 million from March.

This directive caused a backlog of “mission critical” contracts across the sprawling department awaiting her approval, including delays to Federal Emergency Management Agency (FEMA) contract awards, according to an August report in the New York Times. Republican and Democratic lawmakers have raised concerns about adverse impacts to the FEMA response to flash floods that hit Central Texas earlier this year, which claimed 138 lives, as well as post-hurricane recovery efforts in Puerto Rico.

None of the 11 DHS awards between $99,999 and $99,999.99 were made by FEMA.

DHS has denied that Noem’s reviews have had any adverse impacts and has said her reviews have been fast. “Since taking office, Secretary Noem has reviewed more than 5,000 contracts and reviews all contracts within 24 hours,” DHS said in an August statement.

Regarding FEMA, McLaughlin told POGO that “since President Trump took office on January 20, 2025, FEMA is 126% faster on average in getting federal grant funding to states and communities that request it.”

Experts have warned that Noem’s personal involvement in DHS spending could increase ethical risks and conflicts of interest. Indeed, after a Naples, Florida-based political donor to Noem asked for her assistance, Noem “fast-tracked” FEMA funds to rebuild a pier in Naples that was damaged during a prior year’s hurricane, according to a ProPublica report.

Noem and McLaughlin have also faced accusations that a firm with ties to them, including McLaughlin’s husband, is benefiting from a $220 million DHS ad campaign contract through a subcontract. McLaughlin said she is recused, and DHS has said in a statement that the department “has no involvement with the selection of subcontractors.” DHS invoked “the ‘national emergency’ at the border as it awarded contracts for the campaign, bypassing the normal competitive bidding process designed to prevent waste and corruption,” according to ProPublica.

These instances, the ballooning number of contracts worth $99,999, and other matters previously reported by POGO lead to an emerging picture of DHS spending being significantly shaped by high-level administration directives. And given the big boost in DHS spending — especially to ICE — from the One Big Beautiful Bill Act over the next several years, the total value of DHS contracts will likely grow.