Frequently Asked Questions
Q: How does this legislation affect current DHS immigration enforcement contracts?
The bill proposes redirecting $175 billion from ICE, CBP, and border security operations, which could trigger contract modifications, early terminations, or non-exercise of option years on existing immigration enforcement vehicles. Contractors should review termination for convenience clauses in current DHS contracts and assess financial exposure. The Armed Services and Homeland Security committee referrals suggest potential transition contracts for facilities decommissioning, detention center closures, or equipment disposition. Contractors with diversified portfolios spanning both immigration enforcement and housing/facilities management are best positioned to pivot. Review your Winning Federal Contracts Guide (/insights/winning-federal-contracts) for strategies on portfolio diversification during policy shifts.
Q: What new contracting opportunities could emerge if this bill passes?
Expect significant HUD and GSA solicitations for affordable housing construction, property acquisition and management, facilities engineering, and program administration services. The $175 billion reallocation could fund large-scale IDIQ (Indefinite Delivery/Indefinite Quantity) vehicles for multifamily housing construction (NAICS 236116), property management services (NAICS 531110), and engineering design services (NAICS 541330). GSA may issue task orders under existing vehicles for rapid property acquisition. DOJ could require legal services contracts for immigration court restructuring. Contractors should position for both prime opportunities on new housing IDIQs and subcontracting roles with established construction firms. The cross-committee referral suggests potential for joint DOD-HUD military housing initiatives.
Q: What compliance requirements should contractors prepare for on housing contracts?
Housing construction contracts trigger Davis-Bacon Act prevailing wage requirements, requiring certified payroll reporting and wage determination compliance. Service Contract Act applies to property management and facilities support services, mandating specific wage rates and fringe benefits. FAR Part 22 compliance becomes critical, with potential for DOL audits on wage and hour practices. Contractors new to housing work must establish Davis-Bacon compliance programs, including payroll systems, certified payroll reporting, and employee classification protocols. GSA Schedule contractors may need to add housing-related SINs. For contractors handling sensitive immigration data during transition, CMMC (Cybersecurity Maturity Model Certification) Compliance Guide (/insights/cmmc-compliance-guide) and CUI (Controlled Unclassified Information)-Safe CRM Guide (/insights/cui-safe-crm-guide) protocols remain essential during contract closeout.
Definitions
- Davis-Bacon Act: Federal law requiring contractors on government construction projects over $2,000 to pay workers prevailing wages and fringe benefits as determined by the Department of Labor for the locality where work is performed. Applies to all construction, alteration, and repair contracts funded by federal appropriations.
- Service Contract Act (SCA): Federal statute requiring contractors providing services to the federal government to pay service employees no less than prevailing wage rates and fringe benefits as determined by DOL. Applies to contracts exceeding $2,500 for services including property management, facilities support, and administrative functions.
- IDIQ (Indefinite Delivery, Indefinite Quantity): Contract vehicle providing for indefinite quantity of supplies or services during a fixed period, with ordering through task or delivery orders. Commonly used for large-scale, multi-year housing and construction programs where exact quantities cannot be predetermined.
- Termination for Convenience (T4C): FAR clause allowing the government to terminate all or part of a contract when it determines termination is in the government's best interest, even without contractor default. Contractors receive payment for work performed plus reasonable termination costs, but not anticipated profits on unperformed work.
- Option Year: Contract period beyond the base period that the government may unilaterally exercise, extending contract performance and funding. Immigration enforcement contracts with unexercised option years are vulnerable if appropriations are redirected under this legislation.
Intelligence Response
Cabrillo Signals War Room detected this legislative event through continuous monitoring of congressional committee referrals, appropriations language, and cross-agency policy signals. The system flagged the Armed Services and Homeland Security committee assignments as anomalous for housing legislation, triggering elevated priority analysis. War Room's legislative tracking correlated the $175 billion figure with prior immigration enforcement appropriations, identifying the funding reallocation mechanism. The platform automatically segmented affected NAICS codes, contract vehicles, and agencies based on the bill's committee jurisdictions and appropriations targets.
Immediate Platform Configuration:
- Cabrillo Signals Intelligence Hub: Activate saved searches for HUD, GSA, and DOJ solicitations in NAICS 236115-236118, 531110-531190, and 541330. Configure alerts for new IDIQ vehicles containing keywords "affordable housing," "property management," "facilities transition," or "detention facility decommissioning." Monitor SAM.gov (System for Award Management) for modifications to existing DHS immigration enforcement contracts, particularly option year non-exercises or scope reductions. Track committee hearing schedules and markup sessions for bill text amendments affecting procurement language.
- Cabrillo Signals Match Engine: Rescore existing pipeline opportunities against updated agency priorities. Downweight DHS immigration enforcement opportunities pending appropriations clarity; upweight HUD and GSA housing opportunities. Recalculate win probability for contractors with relevant past performance in housing construction or facilities management. Flag opportunities requiring Davis-Bacon Act compliance for teams lacking wage determination experience.
- Proposal Studio (Proposal OS): Update compliance matrices to include Davis-Bacon Act and Service Contract Act requirements for housing-related proposals. Populate win theme library with housing affordability policy alignment, workforce development for construction trades, and sustainable building practices. Configure bid/no-bid decision engine to evaluate Davis-Bacon compliance capability as gate criterion for housing construction opportunities.
- Proposal Studio Workflow Tracker: Establish capture gate reviews for housing opportunities requiring new compliance capabilities. Route Davis-Bacon compliance assessments to HR and contracts teams at Gate 3 (Qualify). Require legal review of termination for convenience exposure on existing DHS contracts at Gate 2 (Identify). Configure audit-ready documentation for any contract modifications resulting from appropriations changes.
Notification Chain:
