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DEPARTMENT OFHOMELAND SECURITY
Ken Cuccinelli

PRIMARY RECOMMENDATION

Our primary recommendation is that the President pursue legislation to dismantle the Department of Homeland Security (DHS). After 20 years, it has notgelled into “One DHS.” Instead, its various components’ different missions haveoutweighed its decades-long attempt to function as one department, rendering
the whole disjointed rather than cohesive. Breaking up the department along its
mission lines would facilitate mission focus and provide opportunities to reduce
overhead and achieve more limited government. In lieu of a status quo DHS, we
recommend that:ll

U.S. Customs and Border Protection (CBP) be combined with
Immigration and Customs Enforcement (ICE); U.S. Citizenshipand Immigration Services (USCIS); the Department of Health andHuman Services (HHS) Office of Refugee Resettlement (ORR); andthe Department of Justice (DOJ) Executive Office for Immigration
Review (EOIR) and Office of Immigration Litigation (OIL) into a standalone border and immigration agency at the Cabinet level (more than
100,000 employees, making it the third largest department measured
by manpower).
The Cybersecurity and Infrastructure Security Agency (CISA) be moved to
the Department of Transportation.

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The Federal Emergency Management Agency (FEMA) be moved to the
Department of the Interior or, if combined with CISA, to the Department ofTransportation.
The U.S. Coast Guard (USCG) be moved to DOJ and, in time of full-scalewar (i.e., threatening the homeland), to the Department of Defense (DOD).
Alternatively, USCG should be moved to DOD for all purposes.
The U.S. Secret Service (USSS) be divided in two, with the protective
element moved to DOJ and the financial enforcement element moved to the
Department of the Treasury.
The Transportation Security Administration (TSA) be privatized.
The Science and Technology Directorate (S&T) be moved to DOD and the
Office of Countering Weapons of Mass Destruction be moved to the FBI.

All of the remaining supporting components could be dismantled because
their functions already exist in the moving components as well as the receiving departments. Cutting these costs would save the American taxpayers
significant sums.
Unless and until this dismantling recommendation is pursued and achieved,
however, DHS will statutorily continue to exist, and it needs many reforms. Accordingly, we now turn to recommended changes in DHS as it exists now.
MISSION STATEMENTThe Department of Homeland Security protects the American homeland fromand prepares for terrorism and other hazards in both the physical and cyber realms,
provides for secure and free movement of trade and travel, and enforces U.S. immigration laws impartially.
OVERVIEWThe Department of Homeland Security (DHS) was created in the aftermath of
the terrorist attacks of September 11, 2001, and subsequent mailings of anthrax
spores. The Homeland Security Act of 2002,1 which created the department, statesthat DHS’s primary mission is to prevent terrorist attacks within the U.S.; reduce
the nation’s vulnerability to terrorism; minimize the damage from and assist in therecovery from any terrorist attacks; prepare and respond to natural and manmade
crises and emergencies; and monitor connections between illegal drug trafficking
and terrorism, coordinate efforts to sever such connections, and interdict illegal
drug trafficking.

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Unfortunately for our nation, the federal government’s newest department
became like every other federal agency: bloated, bureaucratic, and expensive. It also
lost sight of its mission priorities. DHS has also suffered from the Left’s wokeness andweaponization against Americans whom the Left perceives as its political opponents.
To truly secure the homeland, a conservative Administration needs to returnthe department to the right mission, the right size, and the right budget. This would
include reorganizing the department and shifting significant resources away fromseveral supporting components to the essential operational components. Prioritizing border security and immigration enforcement, including detention anddeportation, is critical if we are to regain control of the border, repair the historicdamage done by the Biden Administration, return to a lawful and orderly immigration system, and protect the homeland from terrorism and public safety threats.
This also includes consolidating the pieces of the fragmented immigration system
into one agency to fulfill the mission more efficiently.
The Cybersecurity and Infrastructure Security Agency (CISA) is a DHS component that the Left has weaponized to censor speech and affect elections at theexpense of securing the cyber domain and critical infrastructure, which are threatened daily.2 A conservative Administration should return CISA to its statutory andimportant but narrow mission.
The bloated DHS bureaucracy and budget, along with the wrong priorities,
provide real opportunities for a conservative Administration to cut billions inspending and limit government’s role in Americans’ lives. These opportunities
include privatizing TSA screening and the Federal Emergency Management
Agency (FEMA) National Flood Insurance Program, reforming FEMA emergency
spending to shift the majority of preparedness and response costs to states andlocalities instead of the federal government, eliminating most of DHS’s grant programs, and removing all unions in the department for national security purposes.
A successful DHS would:lSecure and control the border;l

Thoroughly enforce immigration laws;

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Correctly and efficiently adjudicate immigration benefit applications while
rejecting fraudulent claims;
Secure the cyber domain and collaborate with critical infrastructure sectors
to maintain their security;
Provide states and localities with a limited federal emergency response andpreparedness;— 135 —

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Secure our coasts and economic zones;
Protect political leaders, their families, and visiting heads of state or
government; andOversee transportation security.

OFFICE OF THE SECRETARY (SEC)

In the next Administration, the Office of the Secretary should take on the following key issues and challenges to ensure the effective operation of DHS.
Expansion of Dedicated Political Personnel. The Secretary of Homeland
Security is a presidentially appointed and Senate-confirmed political appointee,
but for budgetary reasons, he or she has historically been unable to fund a dedicated team of political appointees. A key first step for the Secretary to improve
front-office functions is to have his or her own dedicated team of political appointees selected and vetted by the Office of Presidential Personnel, which is not reliant
on detailees from other parts of the department, to help ensure the completion of
the next President’s agenda.
An Aggressive Approach to Senate-Confirmed Leadership Positions.
While Senate confirmation is a constitutionally necessary requirement forappointing agency leadership, the next Administration may need to take a novel
approach to the confirmations process to ensure an adequate and rapid transition.
For example, the next Administration arguably should place its nominees for key
positions into similar positions as “actings” (for example, putting in a person toserve as the Senior Official Performing the Duties of the Commissioner of CBP
while that person is going through the confirmation process to direct ICE or
become the Secretary). This approach would both guarantee implementation of
the Day One agenda and equip the department for potential emergency situations
while still honoring the confirmation requirement. The department should also
look to remove lower-level but nevertheless important positions that currently
require Senate confirmation from the confirmation requirement, although thiseffort would require legislation (and might also be mooted in the event of legislation that closes portions of the department that currently have Senate-confirmed
leadership).
Clearer, More Durable, and Political-Only Line of Succession. Based on
previous experience, the department needs legislation to establish a more durable
but politically oriented line of succession for agency decision-making purposes.
The ideal sequence for line of succession is certainly debatable, except that in circumstances where a career employee holds a leadership position in the department,that position should be deemed vacant for line-of-succession purposes and the next
eligible political appointee in the sequence should assume acting authority. Further,— 136 —

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individuals wielding acting Secretary authority should have explicit authority to
finalize agency actions, including regulations, to ensure that the department’s
homeland security mission is fulfilled.
Soft Closure of Unnecessary Offices. Pending a possible presidential decision to shrink or eliminate DHS itself, the next Administration will still have theobligation to protect the homeland as required by law. The Secretary therefore
can and should use his or her inherent, discretionary leadership authority to “softclose” ineffective and problematic corners of the department. While those corners
are to be determined, the Secretary could shift personnel, funding, and operational responsibility to mission-essential components of the department, including
the Office of the Secretary itself. This effort not only would make the department
more efficient, but also would support a legislative move to shrink or dismantle
the department by showing that the agency can fulfill national security–critical
functions without its current bloated bureaucracy.
Restructuring and Redistribution of Career Personnel. To strengthen
political decision-making and ensure that taxpayer dollars are being used legallyand efficiently, the Secretary should make major changes in the distribution ofcareer personnel throughout the department. For example, personnel from partsof the department undergoing soft closure could be redistributed to what will beworkload-intensive corners of the department, including national security–criticaland transparency functions. All personnel with law enforcement capacity should
be removed immediately from office billets and deployed to field billets to maximize law enforcement capacity.
Compliance for Grants and Other Federal Funding. The next Administration should take steps to restore lawfulness and integrity to the department’s
massive regimen of federal grant programs, most of which are managed and distributed by the Federal Emergency Management Agency. The Secretary should
direct FEMA to ensure that all FEMA-issued grant funding for states, localities,
and private organizations is going to recipients who are lawful actors, can demonstrate that they are in compliance with federal law, and can show that their mission
and actions support the broader homeland security mission. All applicants andpotential recipients of such grant funding should be required to meet certain preconditions for eligibility (except for receipt of post-disaster or nonhumanitarianfunding) or should simply be considered ineligible for funding. Such preconditions
should include at least the following:llCertification by applicants that they comply with all aspects of federal
immigration laws, including the honoring of all immigration detainers.
Certification by applicants that they are both registered with E-Verify
and using E-Verify in a transparent and nonevasive manner. For states— 137 —

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and localities, that would include certification that all components of thatgovernment, and not just the applicant agency, are registered with anduse E-Verify.
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If the applicant is a state or locality, commitment by that state or locality tototal information-sharing in the context of both federal law enforcement
and immigration enforcement. This would include access to department ofmotor vehicles and voter registration databases.

Non-Use of Discretionary Guest Worker Visa Authorities. To stop facilitating the availability of cheap foreign labor in order to support American workers(particularly poor and middle-class American workers) and follow congressional
intent, the Secretary should explicitly cease using at least two discretionary authorities as part of his or her broader effort to support American workers.
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The Secretary should make it clear that he or she will not use the Secretary’s
existing discretionary authority to increase the number of H-2B (seasonal
non-agricultural) visas above the statutorily set cap.
The Secretary should not issue any regulations in support of the “H-2
eligible” country list, the effect of which would prevent favoring certain
foreign nationals seeking an H-2 guest worker visa based simply on theirnationality.

Restoration of Honesty and Transparency. The Secretary should use his or
her inherent authority as leader of the department to follow up with congressionaland other partners to disclose information and provide the transparency that has
been obstructed during the Biden Administration. The Secretary should proceedfrom the assumption that congressional inquiries and public information requests
were unfulfilled and then seek to fulfill them.
Replacement of the Entire Homeland Security Advisory Committee. The
Secretary should plan to quickly remove all current members of the Homeland
Security Advisory Committee and replace them as quickly as is feasible.
U.S. CUSTOMS AND BORDER PROTECTION (CBP)

If all immigration agencies are not merged, including USCIS and ORR, thenan appropriate third alternative would be to consolidate ICE and CBP to form
a combined Border Security and Immigration Agency (BSIA). This would integrate critical interdiction, enforcement, and investigative resources, enhancing
coordination and refocusing collective efforts on the vast and complex cross-border threats impacting our nation’s health, safety, and national security. It would— 138 —

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also simultaneously add efficiencies to our nation’s capacity to facilitate lawful
trade and travel.
The BSIA should establish clear mission requirements, responsibilities, andmandates under existing law regarding the persistent need for and utilization of
U.S. military personnel and resources to assist BSIA with increasing whole-of-government efforts and long-term strategy to secure our nation’s borders effectively.
In addition, appropriate elements within the newly created BSIA should be designated as part of the U.S. National Security and Intelligence Community.
A conservative Administration should eliminate any prohibitive guidance,
direction, or mandate from DHS or the Administration that curtails or limits CBPfrom publishing detailed border security and enforcement data not impacting
intelligence, interdiction, and investigative operations, methods, or sources. DHS
should issue a regulation mandating that CBP publish accurate and timely bordersecurity data, readily available to the public, on a regular basis that avoid WhiteHouse and DHS leadership review and approval.
The White House should grant the authority for CBP and DHS executives toutilize component aviation assets under the Office of Air and Marine (OAM). CBP
and DHS have worldwide missions with personnel and facilities that are deployed
across the globe and in every state in the U.S. With a CBP workforce alone of morethan 60,000 people (240,000-plus for DHS) encompassing more than a thousandsea, land, and airports, it is essential that the Commissioner, Deputy Commissioner,
Secretary, and Deputy Secretary can travel efficiently to facilities to maintainappropriate situational awareness across the department’s vast mission set andinteract with the expansive workforce. Although CBP operates one of the largest
aviation components of any domestic U.S. law enforcement agency, executives areprohibited from utilizing the agency’s aviation assets to facilitate official travel.
Executives are required to fly on commercial airlines, and this requirement significantly limits their ability to have classified communications and takes themoffline for extended periods of time.
Border Patrol (BP) and OAM should be combined within CBP. BP has more than
20,000 personnel, and OAM has approximately 1,800. OAM’s assets are dedicatedin support of BP operations the vast majority of the time, yet redundant approvals, strategies, and independent hierarchal commands serve as impediments toefficient and practical resource deployments.
CBP should restart and expand use of the horseback-mounted Border Patrol. As
part of this announcement, the Secretary should clear the records and personnel
files of those who were falsely accused by Secretary Alejandro Mayorkas of whipping migrants and issue a formal apology on behalf of DHS and CBP.
The Secretary should combine the Office of Trade (OT) and Trade Relations
with the Office of Field Operations (OFO). The OT is the smallest of CBP’s components, and its operational counterpart, OFO, has a workforce of more than 30,000.

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OT’s function is interwoven with that of its OFO operational counterpart. Combining OT with OFO would achieve streamlined operations and increase OT’s capacity
and capability by leveraging OFO’s expansive resources.
CBP, ICE, and USCIS all have authority to issue Notices to Appear (NTA) toremovable aliens in their presence, which begins removal proceedings. In most
instances, CBP should turn illegal aliens over to ICE for detention, and ICE canthen issue any needed NTA. CBP should issue NTAs only in limited situations
for humanitarian reasons, such as medical emergencies. In addition, CBP should
eliminate use of Notices to Report (NTR) altogether.
CBP’s established national standards of Transport, Escort, Detention, andSearch (TEDS) have been widely interpreted and expanded by lower courts. This
has resulted in unrealistic and differing detention standards for CBP facilities basedon the jurisdiction within which they fall, negatively impacting operations. ICE has
suffered similarly. A single nationwide detention standard should be codified thatprevents individual states from mandating that federal government agencies adhere
to widely expansive and ever-changing sets of standards. Such standards should allow
the flexibility to use large numbers of temporary facilities such as tents.
The annual costs associated with establishing and maintaining temporary facilities to address the flow of illegal migration and associated care, transportation,and processing are prohibitive, and CBP’s budget is inadequate. CBP is forced toforgo critical mission-essential endeavors to fund the additional associated costs.
Often, this requires the reprogramming of funding at the DHS level, which has anegative impact on other DHS components’ operations. This predictable cost thathas to be paid from existing CBP and DHS funding levels reduces CBP’s operational
readiness and ability to accomplish its diverse and critical missions to protect theAmerican people. The next President should request a realistic budget that fully
pays for these costs.
Increased funding is needed for BP to hire additional support personnel, which
would relieve uniformed BP agents from administrative duties associated withprocessing aliens and allow them to return to their national security mission.
Congress should increase funding for facility upgrades at strategic land Ports ofEntry (POEs), including expanding state-of-the-art technology such as Non-Intrusive Inspection equipment. Today, the cartels exploit the aging facilities and lackof adequate technology to smuggle illicit drugs, contraband, and more successfully
through our nation’s POEs.
U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT (ICE)
Needed Reforms

Since the formation of DHS, ICE has increasingly been tasked with auxiliary
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enforcement. To return ICE to its primary mission, any new Administration thatwishes to restore the rule of law to our immigration enforcement efforts should:
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Order ICE to stop closing out pending immigration cases and apply
the Immigration and Nationality Act (INA) as written by Congress.3
The Biden Administration closed out tens of thousands of immigration
cases that had already been prepared and were slated for expedited removal
processing or hearings before the U.S. Immigration Court. This misguided
action constituted an egregious example of lawlessness that allowed
thousands of illegal aliens and other immigration violators to go free in the
United States.
Direct ICE to stop ignoring criminal aliens identified through the287(g) program.4 Ultimately, Congress should prevent ICE from ignoring
criminal aliens identified by local law enforcement agencies that are partners
in the 287(g) program. However, before congressional action, ICE should
be directed to take custody of all aliens with records for felonies, crimes ofviolence, DUIs, previous removals, and any other crime that is considered anational security or public safety threat as defined under current laws.
Eliminate T and U visas. Victimization should not be a basis for an
immigration benefit. If an alien who was a trafficking or crime victim is
actively and significantly cooperating with law enforcement as a witness,
the S visa is already available and should be used. Pending elimination of the
T and U visas, the Secretary should significantly restrict eligibility for eachvisa to prevent fraud.
Issue clear guidance regarding detention and bond for aliens.
Thousands of illegal aliens are allowed to bond out of immigration detention
only to disappear into the interior of the United States where many commit
crimes and many others disappear, never to be heard from again. Thisoccurs primarily because of poorly worded bond regulations, contradictorybond policy memoranda, and poor practices for managing releasedaliens and the Alternatives to Detention (ATD) Program, which requires
significant reform.
Prioritize national security in the Student and Exchange Visitor
Program (SEVP). ICE should end its current cozy deference to educational
institutions and remove security risks from the program. This requires
working with the Department of State to eliminate or significantly reduce
the number of visas issued to foreign students from enemy nations.

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Mandate for Leadership: The Conservative Promise

Most of the foregoing can be accomplished rapidly and effectively through executive action that is both lawful and appropriate. Additionally, ICE should clarify
who is responsible for enforcing its criminal and civil authorities. It should also
remove self-imposed limitations on its nationwide jurisdiction.
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Homeland Security Investigations (HSI) Special Agents in the 1811
series should enforce Title 8 and 18 crimes as the biggest part of theirportfolio. Alien smuggling, trafficking, and cross-border crime as defined
under Title 85 and Title 186 should be the focus of ICE operations.
The role of ICE Deportation Officers should be clarified. ICE
Enforcement and Removal Operations (ERO) should be identified as being
primarily responsible for enforcing civil immigration regulations, including
the civil arrest, detention, and removal of immigration violators anywherein the United States, without warrant where appropriate, subject only to thecivil warrant requirements of the INA where appropriate.
All ICE memoranda identifying “sensitive zones” where
ICE personnel are prohibited from operating should be
rescinded. Rely on the good judgment of officers in the field to avoid
inappropriate situations.
To maximize the efficient use of its resources, ICE should make fulluse of existing Expedited Removal (ER) authorities. The agency has
limited the use of ER to eligible aliens apprehended within 100 miles of theborder. This is not a statutory requirement.

New Policies

U.S. national security and public safety interests would be well-served if ICE
were to be combined with CBP and USCIS, as mentioned above. Additionally, ICE/
HSI, along with CBP, should be full participants in the Intelligence Community.
The use of Blackies Warrants should be operationalized within ICE. These civil
search warrants are commonly used for worksite enforcement when agents haveprobable cause that illegal aliens are employed at a business. This would streamline investigations.
Safeguarding Americans will require not just securing the border, but continuous vetting and investigations of many aliens who exploited President
Biden’s open border for potentially nefarious purposes, including some Afghanevacuees sent directly to the U.S. during America’s disastrous withdrawal fromAfghanistan.

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Budgetll

Congress should mandate and fund additional bed space for aliendetainees. ICE should be funded for a significant increase in detention
space, raising the daily available number of beds to 100,000.
Congress should fund ICE for at least 20,000 ERO officers and 5,000
Office of the Principal Legal Advisor (OPLA) attorneys.

U.S. CITIZENSHIP AND IMMIGRATION SERVICES (USCIS)

U.S. Citizenship and Immigration Services (USCIS) is the agency tasked withadministering the legal immigration and certain temporary visa programs.
Needed Reforms

Since January 2021, USCIS’s priorities have been misaligned, and this has transformed it into an open-borders agency, ignoring the critical role that it plays innational security, public safety, and safeguarding the integrity of our immigration
system. USCIS should be returned to operating as a screening and vetting agency.
Regulatory efforts have focused on easing asylum eligibility in a manner that is
guaranteed to exacerbate asylum fraud as people surge at the border. Emphasis
also has been placed on removing legal barriers to immigration, such as the useof public benefits. These actions violate statutes, erode congressional intent, andprovide a significant magnet for continued illegal immigration.
Additionally, USCIS resources have been misappropriated to focus more on
creating and expanding large-scale parole and temporary status programs that
violate the law and are otherwise contrary to congressional intent instead of focusing on a more secure and efficient process for those who are seeking benefits. The
ever-increasing number of applications filed has made it difficult to vet applications adequately for eligibility, fraud, and specific national security and public
safety problems.
The Fraud Detection and National Security Directorate (FDNS) is currently asmall directorate with assigned officers reporting through the chain of command in
the field, and this has led to stovepiping, lack of coordination in national policy, andinconsistencies throughout the agency. To prioritize vetting and fraud detection,
FDNS should undergo a structural shift focused on direct reporting from the fieldto headquarters, reclassification of leadership, and FDNS directives taking precedence over those of other component entities. Correcting the current misalignmentof agency priorities and resources should begin with this primary shift in focus tovetting and fraud detection. These actions would reform the agency, returning it
to its screening and vetting mission in protecting the homeland.
Other structural changes should include reimplementation of the USCIS denaturalization unit—an effort to maintain integrity in the system by identifying and— 143 —

Mandate for Leadership: The Conservative Promise

prosecuting criminal and civil denaturalization cases, in combination with the
Department of Justice, for aliens who obtained citizenship through fraud or otherillicit means. Additionally, USCIS should create a criminal enforcement component within the agency to investigate immigration benefits fraud under Title 8(perhaps requiring additional legislative and regulatory authorities for the officers themselves) and to prosecute cases through Special Assistant U.S. Attorneys(SAUSAs) with substantive knowledge in the field. Particular attention should begiven to addressing increasing incidents of forced labor trafficking in temporary
work visa programs.
While the Biden regulatory agenda has focused on at least two major rules—thecredible fear rule and the public charge rule—USCIS has utilized other policy andinternal procedural mechanisms to extend employment authorization to large
groups of people who are in the country without legal status. The agency hastaken quiet steps to cut corners and lessen adjudicatory standards. During a transition period, a complete audit of agency policies, memoranda, and management
directives issued during the Biden Administration should be completed, and rescission documents should be prepared for issuance within the first few days of theincoming Administration. Additionally, regulatory documents should be drafted
to review or reverse all regulations promulgated during the Biden Administration.
New Policies

To advance the national interest, the three core immigration agencies—USCIS,
ICE, and CBP—should remerge and have immigration elements outside of DHS(such as ORR of HHS) included. The fragmented immigration enforcement framework that developed in the wake of the Homeland Security Act has weakened
each agency and should be remediated. Combining these critical agencies would
strengthen their capabilities, ensure cooperation, and promote information-sharing. Agency responsibilities and the delineation of authorities, such as inconsistentuse of deferred action and issuance of NTAs by each agency, have long been a pointof contention that would be addressed much more easily if they were recombined
into a single entity.
Alternatively, new policies for USCIS as it currently exists should focus on matters that can be addressed through administrative action.
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The workforce should be realigned and, as necessary, retrained on baseeligibility and fraud detection rather than speed in processing.
Training should be returned to Federal Law Enforcement Training Centers(FLETC), which would underscore the enforcement role of USCIS as avetting agency, and be rebranded accordingly.

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2025 Presidential Transition ProjectlManagement Directives and policies should realign to ensure that theworkforce, while adaptable and able to handle the bulk of the USCIS mission,
is not allowed to be pulled off mission work to focus on unlawful programs(DACA, mass parole for Afghans, Ukrainians, Venezuelans, etc.), which
divert resources away from nuclear family and employment programs.

The regulatory agenda should include the immediate submission of notices of
proposed rulemaking for the Trump Administration’s public charge rule (including aspects from its original notice of proposed rulemaking), temporary work
visa reform, employment authorization reform rules, asylum bars rule, and athird-country transit rule. At a minimum, an enhanced regulatory agenda should
include rules strengthening the integrity of the asylum system, parole reform, andU visa reform that prioritizes relief for victims of heinous crimes and ensures that
we protect the truest and most deserving victims of crime.
Not all policy changes require formal rulemaking, however, as internal guidance
documents are generally exempt under the Administrative Procedure Act (APA).7
In this subregulatory space, USCIS policy memos and operational guidance should
reduce the validity of employment authorization documents and end the COVID
flexibilities, including the reliance on biometrics reuse. USCIS should also enforce
existing regulations by rejecting incomplete applications and petitions, ensuring
both that they are completed before accepted for filing and that FDNS signs off on
all approved applications and petitions before approval notices are sent to the alienor petitioner. Other efforts should be focused on adjudication standards returningto nearly 100 percent interview requirements for all appropriate cases.
The incoming Administration should spearhead an immigration legislative
agenda focused on creating a merit-based immigration system that rewards highskilled aliens instead of the current system that favors extended family–based andluck-of-the-draw immigration. To that end, the diversity visa lottery should be
repealed, chain migration should be ended while focusing on the nuclear family,
and the existing employment visa program should be replaced with a system toaward visas only to the “best and brightest.”
Internal efforts to limit employment authorization should be matched by congressional action to narrow statutory eligibility to work in the United States andmitigate unfair employment competition for U.S. citizens. The oft-abused H-1B
program should be transformed into an elite program through which employers
are vying to bring in only the top foreign workers at the highest wages so as not todepress American opportunities. Additionally, Congress should:lImprove the integrity of the temporary work visa programs;lRepeal Temporary Protected Status (TPS) designations;— 145 —

Mandate for Leadership: The Conservative PromiselPermanently authorize and make mandatory E-Verify; andlEnd parole abuse by legislating specific parole standards.

USCIS should make it clear that where no court jurisdiction exists, it will nothonor court decisions that seek to undermine regulatory and subregulatory efforts.
Finally, USCIS still requires access to all relevant national security and law enforcement databases in the same vein as any other agency in the intelligence space. Thisis a key concept that should be addressed as USCIS is returned to functioning
primarily as a vetting agency.
Budget

USCIS is primarily fee-funded, operating on revenue derived by those who areseeking immigration benefits, work permits, and naturalization. The total agency
budget requested for fiscal year (FY) 2023, including both fees and a small appropriation, is slightly less than $6 billion.8 The bulk of funds are derived from application
fees through the Immigrant Examinations Fee Account. As a general principle, adjudication of applications and petitions should be paid by applicants, not American
taxpayers. It is critical that any changes in the budget, even in the wake of a realigned
agency combined with ICE and CBP, should retain a fee-funded model.
Given the Obama and Biden Administrations’ lack of will, fees should be
increased agencywide to keep in step with inflation and the true cost of the adjudications. The incoming Administration should immediately submit a fee rulethat reflects such an increase. Aside from an increase in all fees, the rule should
drastically limit the availability for fee waivers and should implement a fee forasylum applications. Additionally, Congress should allow for a 10 percent acrossthe-board increase in all fees for all fee rules to account for the fact that new fee
rules always lag behind budget requirements.
USCIS should strive to increase opportunities for premium processing, a benefit by which applicants can expedite their processing times. While this places
time burdens on adjudicators, it provides an opportunity for a significant influxof money into the agency, which is not currently available. While simply raising
fees to the necessary levels to make the agency run efficiently would be preferable, without the need for expanded premium processing, this short-term measure
should be utilized, particularly if longer-term fee rules are unsuccessful.
At least until USCIS is caught up on all case backlogs, all applicants rejected forany benefit or status adjudication should be required to leave the U.S. immediately.
Ordinary process can resume once all case backlogs have been adjudicated.
Finally, USCIS should pause the intake of applications in a benefit category
when backlogs in that category become excessive. Once USCIS adjudicators candecrease that caseload to a manageable number, application intake should resume.

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Personnel

USCIS should be classified as a national security–sensitive agency, and all of
its employees should be classified as holding national security–sensitive positions. Leaks must be investigated and punished as they would be in a national
security agency, and the union should be decertified. Any employees who cannot
accept that change and cannot conform their behavior to the standards requiredby such an agency should be separated. USCIS’s D.C. personnel presence should
be skeletal, and agency employees with operational or security roles should be
rotated out to offices throughout the United States. These USCIS employees
should live and work in the communities that are most affected by their daily
duties and decisions.
NECESSARY BORDER AND IMMIGRATION STATUTORY,REGULATORY, AND ADMINISTRATIVE CHANGESThe current border security crisis was made possible by glaring loopholes
in our immigration system. The result was a preventable and predictable historic increase in illegal and inadmissible encounters along our southern border.
This pulled limited resources from the front lines of our nation’s borders andaway from their national security mission, releasing a vast and complex setof threats into our country. To regain our sovereignty, integrity, and security,
Congress must pass meaningful legislation to close the current loopholes andprevent future Administrations from exploiting them for political gain or personal ideology.
Legislative Proposalslll

Title 42 authority in Title 8. Create an authority akin to the Title 42
Public Health authority that has been used during the COVID-19 pandemic
to expel illegal aliens across the border immediately when certain nonhealth conditions are met, such as loss of operational control of the border.
Mandatory appropriation for border wall system infrastructure. The
monies appropriated would be used to fund the construction of additional
border wall systems, technology, and personnel in strategic locations inaccordance with the Border Security Improvement Plan (BSIP).

Appropriation for Port of Entry infrastructure. Border security is notaddressed solely by systems in between the ports of entry. POEs require
technology and physical upgrades as well as an influx of personnel to meetcapacity demands and act as the literal gatekeepers for the country. This is
the first line of defense against drug and human smuggling operations.

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Mandate for Leadership: The Conservative PromiselUnaccompanied minors
1.

Congress should repeal Section 235 of the William Wilberforce
Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA),9
which provides numerous immigration benefits to unaccompaniedalien children and only encourages more parents to send their children
across the border illegally and unaccompanied. These children too often
become trafficking victims, which means that the TVPRA has failed.

2. If an alternative to repealing Section 235 of the TVPRA is necessary,
the section should be amended so that all unaccompanied children,
regardless of nationality, may be returned to their home countries in asafe and efficient manner. Currently, the TVPRA allows only children
from contiguous countries (Canada and Mexico) to be returned while
every other unaccompanied minor must be placed into a lengthy
process that usually results in the minor’s landing in the custody of anillegal alien family member.
3. Congress must end the Flores Settlement Agreement by explicitly
setting nationwide terms and standards for family and unaccompanied
detention and housing. Such standards should focus on meeting humanneeds and should allow for large-scale use of temporary facilities (forexample, tents).
4. Congress should amend the Homeland Security Act and portions of
the TVPRA to move detention of alien children expressly from the
Department of Health and Human Services to DHS.
l

Asylum reform
1.

The standard for a credible fear of persecution should be raised andaligned to the standard for asylum. It should also account specifically forcredibility determinations that are a key element of the asylum claim.

2. Codify former asylum bars and third-country transit rules.
3. Congress should eliminate the particular social group protected groundas vague and overbroad or, in the alternative, provide a clear definition
with parameters that at a minimum codify the holding in Matter of A-Bthat gang violence and domestic violence are not grounds for asylum.10— 148 —

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Parole reform. Congress should end the widespread abuse of parole incontravention of statute and return it to its origins as an extraordinary
remedy for very limited purposes.
NGOs and processing. Congress should halt funds given to
nongovernmental organizations (NGOs) to process and transport
illegal aliens into and throughout the United States. Such funds andinfrastructure, including the DHS joint processing centers, should be
redirected to secure the border, detain aliens, and provide space for
immigration court proceedings.
Other pathways for border crossers. While Congress should use its
oversight authority to ensure that Expedited Removal is used to the fullest
extent and followed to the letter of the law, other paths for border crossers
should be included in a legislative package.
1.

Migrant protection protocols. Update the statutory language
providing the basis for the Remain in Mexico program as needed towithstand judicial scrutiny and executive inaction.

2. Asylum Cooperative Agreements. While the agreements themselves
must be negotiated, Congress should mandate that the executive branchwork faithfully to negotiate and execute ACAs and set parameters
to ensure that an unwilling executive cannot renege on an existing
agreement or abandon the effort.
3. Other expedited pathways. Congress should explicitly permit
programs akin to the Prompt Asylum Claim Review (PACR) andHumanitarian Asylum Review Process (HARP) programs.
lEmployment authorization
1.

Congress should reassert control of employment authorization, which is
subject to rampant regulatory abuse, and limit it to certain categories oflegal immigrants and non-immigrants.

2. Congress should also permanently authorize E-Verify and makeit mandatory.
lState and local law enforcement— 149 —

Mandate for Leadership: The Conservative Promise

1.

Congress should unequivocally authorize state and local law
enforcement to participate in immigration and border security actions
in compliance with Arizona v. United States.11

2. Congress should require compliance with immigration detainers to
the maximum extent consistent with the Tenth Amendment and set
financial disincentives for jurisdictions that implement either official or
unofficial sanctuary policies.
llProsecutorial discretion. Congress should restrict the authority forprosecutorial discretion to eliminate it as a “catch-all” excuse for limiting
immigration enforcement.
Mandatory detention. Congress should eliminate ambiguous
discretionary language in Title 8 that aliens “may” be detained and clarify
that aliens “shall” be detained. This language, which contrasts with other“shall detain” language in statute, creates unhelpful ambiguity and allows theexecutive branch to ignore the will of Congress.

RegulationslWithdraw Biden Administration regulations and reissue new
regulations in the following areas:
1.

Credible Fear/Asylum Jurisdiction for Border Crossers.

2. Public Charge.
lll

T-Visa and U-Visa reform. Unless and until T and U visas are repealed,each program needs to be reformed to ensure that only legitimate victimsof trafficking and crimes who are actively providing significant material
assistance to law enforcement are eligible for spots in the queue.
Repeal TPS designations.
H-1B reform. Transform the program into an elite mechanism
exclusively to bring in the “best and brightest” at the highest wages while
simultaneously ensuring that U.S. workers are not being disadvantaged by
the program. H-1B is a means only to supplement the U.S. economy and tokeep companies competitive, not to depress U.S. labor markets artificially incertain industries.

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2025 Presidential Transition Projectl

Employment authorization. Along with the legislative proposal, takeregulatory action to limit the classes of aliens eligible for work authorization.

Executive Ordersl

Pathways for border crossers

1.

Direct the Department of State and the Department of Homeland
Security to reinstate Asylum Cooperative Agreements with Northern
Triangle Countries immediately.

2. Recommence negotiations with Mexico to fully implement the Remain
in Mexico Protocols.
3. Reinstate, to the extent possible, expedited pathways with full credible
fear/immigration court process (PACR and HARP).
4. Prohibit the use of Notices to Report, the use of any funds for travel
into the interior of the United States, and government flights ortransportation for aliens.
5. Mandate that ICE use all detention space in full compliance with
Section 235 of the INA, issue weekly reports on detention capacity, andprovide authority for low-level temporary capacity (for example, tents)
once permanent space is full.
6. Eliminate the use of ATD for border crossers except in rare cases andonly with the explicit authority of the Secretary.
7.

lProhibit the use of parole except in matters that are certified by the
Secretary of Homeland Security as requiring action for humanitarian orsignificant public benefit reasons, and prohibit the use of parole in any
categorical circumstance.

Enforcement
1.

Restrict prosecutorial discretion to eliminate it as a “catch-all” excuse
for limiting immigration enforcement.

2. Mandate the use of E-Verify for anyone doing business withthe government.

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3. Designate USCIS as Intelligence Community–adjacent, ensuring that it
has access to national security and law enforcement databases.
4. Rescind all memoranda limiting enforcement of immigration laws
including those identifying sensitive zones.
5. End ICE’s widespread use of termination and administrative closure ofcases in immigration court.
lAverting or curtailing a mass migration event
1.

Provide that whenever the Secretary of Homeland Security determinesthat an actual or anticipated mass migration of aliens en route to or
arriving off the coast of the U.S. presents urgent circumstances requiring
an immediate federal response, the Secretary may make, subject to theapproval of the President, rules and regulations prohibiting in whole orin part the introduction of persons from such countries or places as heor she shall designate in order to avert or curtail such mass migrationand for such period of time as is deemed necessary, including throughthe expulsion of such aliens. Such rule and regulation making shall not
be subject to the requirements of the Administrative Procedures Act.

2. Provide that notwithstanding any other provision of law, when the
Secretary makes such a determination and then promulgates, subject tothe approval of the President, such rules and regulations, the Secretaryshall have the authority to waive all legal requirements of Title 8 that
the Secretary, in his or her sole discretion, determines are necessary to
avert or curtail the mass migration.
Subregulatory Mattersl

USCIS priorities/structural changes

1.

Ensure that focus is returned to vetting, base eligibility of applicants,
and fraud detection.

2. Realign the Fraud Detection and National Security Directorate (FDNS)
to ensure agencywide consistency on implementation of fraud detection
and vetting policies.
3. Review and repeal any internal agency memo that is inconsistent withthe priorities described in this chapter.

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287(g) program. Issue a memo prohibiting any jurisdiction that applies
from being denied access to the program unless good cause is shown.
Homeland Security Investigations (HSI) priorities. Issue Department
Management Directive (and ICE companion Directive) to refocus HSI
on immigration offenses and criminal offenses typically associated withimmigration (for example, human trafficking). All criminal investigative
work without a clear nexus to the border or otherwise to Title 8 should beturned over to the appropriate federal agency.
Blackie’s Warrants. ICE OPLA, ERO, and HSI should issue a joint internal
memo on operationalizing Blackie’s Warrants for immediate use on
worksite enforcement and other appropriate investigations and operations.

FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA)
Needed Reforms

FEMA is the lead federal agency in preparing for and responding to disasters,
but it is overtasked, overcompensates for the lack of state and local preparedness
and response, and is regularly in deep debt. After passage of the 1988 Stafford Act,12the number of declared federal disasters rose dramatically as most disaster costs
were shifted from states and local governments to the federal government. In
addition, state-friendly FEMA regulations, such as a “per capita indicator,” failed
to maintain the pace of inflation and made it easy to meet disaster declarationthresholds. This combination has left FEMA unprepared in both readiness andfunding for the truly catastrophic disasters in which its services are most needed.
Reform of FEMA requires a greater emphasis on federalism and state and local
preparedness, leaving FEMA to focus on large, widespread disasters.
Under the Stafford Act, FEMA has the authority to adjust the per capita indicator for damages, which creates a threshold under which states and localities are
not eligible for public assistance. FEMA should raise the threshold because the percapita indicator has not kept pace with inflation, and this over time has effectively
lowered the threshold for public assistance and caused FEMA’s resources to be
stretched perilously thin. Alternatively, applying a deductible could accomplish
a similar outcome while also incentivizing states to take a more proactive role intheir own preparedness and response capabilities. In addition, Congress shouldchange the cost-share arrangement so that the federal government covers 25 percent of the costs for small disasters with the cost share reaching a maximum of 75
percent for truly catastrophic disasters.
FEMA is also responsible for the National Flood Insurance Program (NFIP),
nearly all of which is issued by the federal government. Washington provides— 153 —

Mandate for Leadership: The Conservative Promise

insurance at prices lower than the actuarially fair rate, thereby subsidizing flood
insurance. Then, when flood costs exceed NFIP’s revenue, FEMA seeks taxpayer-funded bailouts. Current NFIP debt is $20.5 billion, and in 2017, Congresscanceled $16 billion in debt when FEMA reached its borrowing authority limit.
These subsidies and bailouts only encourage more development in flood zones,
increasing the potential losses to both NFIP and the taxpayer. The NFIP should
be wound down and replaced with private insurance starting with the least risky
areas currently identified by the program.
Budget Issues

FEMA manages all grants for DHS, and these grants have become pork for states,
localities, and special-interest groups. Since 2002, DHS/FEMA have provided
more than $56 billion in preparedness grants for state, local, tribal, and territorial
governments. For FY 2023, President Biden requested more than $3.5 billion forfederal assistance grants.13 Funds provided under these programs do not provide
measurable gains for preparedness or resiliency. Rather, more than any objective
needs, political interests appear to direct the flow of nondisaster funds.
The principles of federalism should be upheld; these indicate that states better
understand their unique needs and should bear the costs of their particularized
programs. FEMA employees in Washington, D.C., should not determine how billions of federal tax dollars should be awarded to train local law enforcement officers
in Texas, harden cybersecurity infrastructure in Utah, or supplement migrant
shelters in Arizona. DHS should not be in the business of handing out federal tax
dollars: These grants should be terminated. Accomplishing this, however, will
require action by Members of Congress who repeatedly vote to fund grants forpolitical reasons. The transition should focus on building resilience and returnon investment in line with real threats.
Personnel

FEMA currently has four Senate-confirmed positions. Only the Administrator
should be confirmed by the Senate; other political leadership need not be confirmed by the Senate. Additionally, FEMA’s “springing Cabinet position” should be
eliminated, as this creates significant unnecessary challenges to the functioning of
the whole of DHS at points in time when coordinated responses are most needed.
CYBERSECURITY AND INFRASTRUCTURE SECURITY AGENCY (CISA)
Needed Reforms

CISA is supposed to have two key roles: (1) protection of the federal civilian
government networks (.gov) while coordinating the execution of national cyberdefense and sharing information with non-federal and private-sector partners— 154 —

2025 Presidential Transition Projectand (2) national coordination of critical infrastructure security and resilience. Yet
CISA has rapidly expanded its scope into lanes where it does not belong, the mostrecent and most glaring example being censorship of so-called misinformationand disinformation.
CISA’s funding and resources should align narrowly with the foregoing two
mission requirements. The component’s emergency communications and Chemical Facility Anti-Terrorism Standards (CFATS) roles should be moved to FEMA;
its school security functions should be transferred to state homeland security
offices; and CISA should refrain from duplicating cybersecurity functions done
elsewhere at the Department of Defense, FBI, National Security Agency, and U.S.
Secret Service.
Of the utmost urgency is immediately ending CISA’s counter-mis/disinformation efforts. The federal government cannot be the arbiter of truth. CISA began
this work because of alleged Russian misinformation in the 2016 election, which
in fact turned out to be a Clinton campaign “dirty trick.” The Intelligence Community, including the NSA or DOD, should counter foreign actors. At the time of thiswriting, release of the Twitter Files has demonstrated that CISA has devolved into
an unconstitutional censoring and election engineering apparatus of the political
Left. In any event, the entirety of the CISA Cybersecurity Advisory Committee
should be dismissed on Day One.
For election security, CISA should help states and localities assess whether
they have good cyber hygiene in their hardware and software in preparation for
an election—but nothing more. This is of value to smaller localities, particularly by
flagging who is attacking their websites. CISA should not be significantly involved
closer to an election. Nor should it participate in messaging or propaganda.
U.S. COAST GUARD (USCG)
Needed Reforms

The U.S. Coast Guard fleet should be sized to the needs of great-power competition, specifically focusing efforts and investment on protecting U.S. waters, allwhile seeking to find (where feasible) more economical ways to perform USCG
missions. The scope of the Coast Guard’s mission needs to be focused on protecting
U.S. resources and interests in its home waters, specifically its Exclusive Economic
Zone (200 miles from shore). USCG’s budget should address the growing demandfor it to address the increasing threat from the Chinese fishing fleet in home waters
as well as narcotics and migrant flows in the Caribbean and Eastern Pacific. Doing
this will require reversing years of shortfalls in shipbuilding, maintenance, andupgrades of shore facilities as well as seeking more cost-effective ship and facility
designs. In wartime, the USCG supports the Navy, but it has limited capability andcapacity to support wartime missions outside home waters.

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New Policies

The Coast Guard’s mission set should be scaled down to match congressional budgeting in the long term, with any increased funding going to acquisitions
based on an updated Fleet Mix Analysis. The current shipbuilding plan is insufficient based on USCG analysis, and the necessary numbers of planned Offshore
Patrol Cutters and National Security Cutters are not supported by congressional
budgets. The Coast Guard should be required to submit to Congress a long-range
shipbuilding plan modeled on the Navy’s 30-Year Shipbuilding Plan. Ideally thisshould become part of the Navy plan in a new comprehensive naval long-range
shipbuilding plan to ensure better coherency in the services’ requirements.
Outside of home waters, and following the Caribbean and Eastern Pacific, theCoast Guard should prioritize limited resources to the nation’s expansive Pacificwaters to counter growing Chinese influence and encroachment. Expansion offacilities in American Samoa and basing of cutters there is one clear step in thisdirection and should be accelerated; looking to free association states (Palau, theFederated States of Micronesia, and the Republic of the Marshall Islands) for
enhanced and persistent presence, assuming adequate congressional funding, isanother such step.
The Secretary of the Navy should convene a naval board to review and reset
requirements for Coast Guard wartime mission support. To inform and validate
these updated requirements, the Chief of Naval Operations and the Coast Guard
Commandant should execute dedicated annual joint wartime drills focused on
USCG’s wartime missions in the Pacific (the money for these activities should beallocated from DOD). An interagency maritime coordination office focused on
developing and overseeing comprehensive efforts to advance the nation’s maritime interests and increase its military and commercial competitiveness shouldbe established.
Given the USCG’s history of underfunded missions, if the Coast Guard is to continue to maintain the Arctic mission, money to do so adequately will be required
over and above current funding levels. Consideration should be given to shifting
the Arctic mission to the Navy. Either way, the Arctic mission should be closely
coordinated with our Canadian, Danish, and other allies.
Personnel

USCG is facing recruitment challenges similar to those faced by the military
services. The Administration should stop the messaging on wokeness and diversity
and focus instead on attracting the best talent for USCG. Simultaneously, consistent with the Department of Defense, USCG should also make a serious effort tore-vet any promotions and hiring that occurred on the Biden Administration’swatch while also re-onboarding any USCG personnel who were dismissed fromservice for refusing to take the COVID-19 “vaccine,” with time in service credited— 156 —

2025 Presidential Transition Projectto such returnees. These two steps could be foundational for any improvementsin the recruiting process.
U.S. SECRET SERVICE (USSS)
Needed Reforms

The U.S. Secret Service must be the world’s best protective agency. Currently, theagency is distracted by its dual mission of protection and financial investigations.
The result has been a long series of high-profile embarrassments and security failures, perhaps most notably its allowing of then-Vice President-elect Kamala Harris
to be inside the Democratic National Committee office on January 6, 2021, whilea pipe bomb was outside. Despite the great size and scope of the January 6 investigation, this high-profile incident of danger to a protectee remains unresolved.
The failures of the USSS protective mission are too numerous to list here. A
December 2015 bipartisan report from the House Oversight Committee listed
dozens of such incidents as well as needed recommendations for reform.14 This
chapter adopts those findings and recommendations in whole, especially thefinding that USSS’s dual-mission structure detracts from the agency’s protective
capabilities.
At the time of that report, USSS agents spent only one-third of their work hours
on protection-related activities as opposed to investigative activities. USSS wasestablished initially to investigate counterfeit currency, but its mission has evolved
over the decades to prioritize electronic financial crimes. For example, as this chapter was being written, all 15 of the USSS’s most wanted individuals were wanted
for financial crimes, many of them international in nature.
Notably, the last head of the agency left not for a protection-related job, but to be
the Chief Security Officer of social media company SnapChat. This is a pattern thathas developed over the years, with agents seeking to burnish their online financial
crimes credentials to secure corporate security jobs. Coupled with some of thelowest morale in the federal government, the agency has completely lost sight ofthe primacy of its protective mission.
New Policies

USSS should transfer to the Department of Justice and Department of theTreasury all investigations that are not related to its protective function. It should
begin the logistical operation of closing all field offices throughout the country andinternationally to the extent they are not taken over by Treasury or Justice. USSS
agents stationed outside of Washington, D.C., should be transferred to work in
Immigration and Customs Enforcement field offices where they would continue tobe the “boots on the ground” to follow up on threat reports throughout the country
and liaise with local law enforcement for visits by protectees.

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The only investigations not related to USSS’s protective function that agentsshould pursue would be directed by HSI and relate to tracking the financial crimes
associated with illegal immigration. This should include tracing remittances, any
funds that are used to pay coyotes or the cartels, and payments by businesses toillegal aliens and all other crimes associated with illegal immigration.
USSS should keep visitor logs for all facilities where the President works orresides. The Biden Administration has evaded such transparency with President
Biden spending a historic amount of time for a President at his Delaware residence.
This has left the American people in the dark as to who is influencing the highest
levels of their own government.
BudgetThe suggested reforms would result in a significant USSS budget reduction,
primarily because the agency would relinquish dozens of physical offices throughout the U.S. and internationally. Some amount of savings should be used to fix thepersonnel problems and for recruitment initiatives aimed at individuals who are
inclined to join a protection-focused agency.
Personnel

As documented extensively in the above-referenced 2015 bipartisan congressional report, low morale and high turnover are key drivers of USSS problems. With
their mission focused on protection, agents would no longer spend the bulk of
their time developing unrelated skillsets. Instead, USSS agents could hone theirprotection skills and pursue a protection career path in the agency rather thanquickly leaving USSS for high-paying corporate security jobs.
The Uniform Division (UD) of USSS requires a significant staffing increase.
As documented in the bipartisan report, understaffing results in unpredictable
and long hours, which in turn result in high turnover, which only compounds
the problem.
Another key issue is that UD officers lack the ability to enforce criminal laws
outside the immediate vicinity of the White House. As the District of Columbia
is a federal jurisdiction and currently is beholden to the trend of progressive procrime policies, UD officers should enforce all applicable laws. The result would
be to allow UD officers to gain more law enforcement experience—an attractive
credential that would improve morale.
TRANSPORTATION SECURITY ADMINISTRATION (TSA)The TSA model is costly and unwisely makes TSA both the regulator and theregulated organization responsible for screening operations. As part of an effort
to shrink federal bureaucracies and bring private-sector know-how to government programs, TSA is ripe for reform. The U.S. should look to the Canadian and— 158 —

2025 Presidential Transition Project

European private models of providing aviation screening manpower to lower TSA
costs while maintaining security. Until it is privatized, TSA should be treated as anational security provider, and its workforce should be deunionized immediately.
TSA could privatize the screening function by expanding the current Screening
Partnership Program (SPP) to all airports. TSA would turn screening operations
over to airports that would choose security contractors that meet TSA regulations
and would oversee and test airports for compliance. Alternatively, it could adopt
a Canadian-style system, turning over screening operations to a new government
corporation that contracts screening service to private contractors. Contractors
would bid to provide their services to a set of airports in a particular region, likely
with around 10 regions nationally. TSA would continue to set security regulations
and test airports for compliance, and the new corporation would establish any operating procedures or customer service standards. With either model, the intelligence
function for domestic travel patterns should remain with the U.S. government.
The federal government could expect to save 15 percent–20 percent from theexisting aviation screening budget, but savings could be significantly larger. Service
to travelers should also improve.
MANAGEMENT DIRECTORATE (MGMT)The Management Directorate is unnecessarily large because each individualcomponent also maintains its own respective management office. Too much overlap and red tape exist between headquarters (HQ) and components with regard
to such functions as hiring, information technology, and procurement. Financeis unique given that HQ needs to address reprogramming, and component budgets need to roll up into all-department budgets. The Directorate requires intensereform, the specifics of which should be further assessed given its expansive nature.
Front Office (FO). Immediately place a small team of advisers with a deep
understanding of operational management—but who have some experience ingovernment because they will need to understand the nuance of Reduction in Force(RIF), appropriations hurdles when dealing with U.S. government reorganization,
etc.—to sit in the MGMT FO (reporting to the Secretary, ultimately either S1 or S2).
One of these advisers should understand U.S. government employment law andbe prepared to relocate personnel and downsize offices accordingly. This includes
reverting to the original understanding of the function of individuals appointed
to the Senior Executive Service: competent managers who can work capably withany subject matter and in any location.
Over the first few months of the Administration, the advisers’ role should be
to assess what structural and procedural changes are appropriate. They should
dissect the current standing Management Directives and the approval processes
in place to implement and/or change them; Office of the Chief Human Capital
Officer’s processes and procedures; hurdles to the Office of Chief Procurement— 159 —

Mandate for Leadership: The Conservative Promise

Officer’s procurement of innovative technology; and the facilities plan, including
the consolidation into the St. Elizabeth’s campus. They should also be preparedto help implement any end to unionization of DHS components in response to an
executive order pursuant to 5 U.S.C. 7103.15
Office of the Chief Financial Officer (OCFO). DHS responsibilities to work with
Congress have been split between the Office of Legislative Affairs (OLA) and OCFO.
OLA deals with the authorizing committees on policy issues, and OCFO works withthe appropriations committees on budget planning, execution, and reprogramming.
This split creates communication and visibility issues within DHS and inconsistency inanswers to Congress. This is an issue not only within the HQ model, but also throughout the components. Either appropriations personnel should be moved to OLA andthere should be a “dotted line” reporting structure to OCFO, or a policy that OLA personnel must be included on communications to Congress should be implemented.
To avoid “answer shopping” by congressional staff, particularly appropriations
staff, all budget communications from the OCFO, including from the CFO him/
herself, should first be provided to the Director of OLA to ensure consistency of
information, messaging, and answers. This may be deemed awkward given that the
OCFO is a Senate-confirmed position, but it is necessary to avoid inaccuracies andinconsistencies in messaging.
Federal Protective Service (FPS). FPS needs federal agents to develop, share,
and receive operational information and maintain direct contact with the Secretaryin the midst of heightened threats. Before the summer 2020 civil unrest, positioning FPS under MGMT was justified, but given the current climate, they should not
be reporting through MGMT. This may be especially problematic if a Management
Directorate Under Secretary lacking law enforcement or military experience is in placewhen a situation like summer 2020 arises. FPS should report to the Secretary as othercomponents (e.g., FLETC) do. This would add little to the Secretary’s current burden
unless or until civil unrest arises, at which point reporting to the Secretary creates adirect line between the primary DHS decision-maker (S1 or S2) and the FPS Director.
Regarding operational communication, there should be information-sharing
mandates (MOAs)—which are applicable under specific circumstances where federal facilities are involved—between FPS and the U.S. Marshals, U.S. Park Police,
and FBI. Agreements with U.S. Capitol Police and Supreme Court Police should
also be considered, but it is noteworthy that those entities are jurisdictionally outside of the executive branch.
OFFICE OF STRATEGY, POLICY, AND PLANS (PLCY)

Department-Level Reforms. PLCY should perform a complete inventory,
analysis, and reevaluation of the department’s domestic terrorism lines of effort
to ensure that they are consistent with the President’s priorities, congressional
authorization, and Americans’ constitutional rights.

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PLCY should likewise do a complete inventory, analysis, and evaluation of anyof the department’s work, in coordination with social media outlets, to censor orotherwise change or affect Americans’ speech. PLCY should comprehensively
report on and publish this history in full so that the American people can know
the facts. The department should remove all personnel who participated in anyof this activity.
The department has significant authority and budget to provide grants for various purposes. This effort is diffused across components and lacks central policy
thought and coordination. PLCY should set a departmentwide policy that establishes how granting choices are to be made and is consistent with the President’s
priorities. PLCY should clear all granting decisions to ensure that they are consistent with the new policy.
PLCY-Wide Reforms. PLCY should work with Congress to streamline thedepartment’s reporting requirements. Because there has not been a departmental reauthorization bill and these requirements have been added piecemeal overtwo decades, they significantly overlap and even conflict—wasting resources anddistracting from the department’s mission. PLCY should seek the elimination of
the Quadrennial Homeland Security Review.
Issue-Area Reforms. PLCY should bolster its Immigration Statistics programand make it the one-stop shop for the timely production of all department immigration statistics and analysis.
OFFICE OF INTELLIGENCE AND ANALYSIS (I&A)

The Office of Intelligence and Analysis should be eliminated both because
it has not added value and because it has been weaponized for domestic political purposes.
The Intelligence Community (IC) already provides raw intelligence to DHS
components. In addition, the FBI, National Counter Terrorism Center, and otheragencies where necessary already provide holistic threat assessment products tofederal, state, local, tribal, and territorial governments as well as to private-sector
entities at both the classified and unclassified levels where appropriate. I&A’s work
as an interlocuter between the IC and DHS components’ individual intelligence
operations on the one hand and government and the private sector on the other,
as well as between the IC and the components, is at best duplicative. At worst, it
is used and discussed in the media as a political tool, resulting in more harm than
good to the U.S. government and IC writ large.
The Cybersecurity and Infrastructure Security Agency, which is not a memberof the IC, should create cyber intelligence products in a collaborative fashion with
the National Security Agency and U.S. Cyber Command. Such efforts would leadto timelier usable classified and unclassified products for stakeholders that exceed
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components as well: CBP, TSA, etc. all have their own intelligence operations andare better situated with their subject-matter experts to make their own assessments.
The National Operations Center (NOC) within the Office of Operations Coordination (OPS) should absorb those select I&A functions and tactically proficientpersonnel that need to be maintained (for example, technical support to the
National Vetting Center). The remainder of I&A should be eliminated. The OPS
entity should maintain IC status, and the only intelligence mission set should be
to provide situational awareness and the dissemination of operational information
or raw intelligence (no analysis or products) at classified and unclassified levels to
executive leadership across the department, not outside of DHS.
OFFICE OF THE GENERAL COUNSEL (OGC)
Needed Reforms

OGC should advise principals as to how DHS can execute its missions within
the law instead of advising principals as to why they cannot execute regulations,policies, and programs.
Instead of each component’s chief counsel reporting to the Headquarters General Counsel (with a solid line) and indirectly to his or her component head (witha dotted line), the accountability should be reversed. Due to the different missions
throughout the department, the components can better manage the legal issuesof their specific mission than headquarters can. Thus, the chief counsel (or equivalent) of each component should report directly to the component head, reportindirectly to the DHS General Counsel, and be accountable to the component head.
The report to the General Counsel is to ensure consistency of advice across DHS.
OGC should hire significantly more Schedule C/political appointees who inturn supervise career staff and manage their output. DHS’s mission is politicallycharged, and the legal function cannot be allowed to thwart the Administration’s
agenda by providing stilted or erroneous legal positions and decision-making.
OGC should serve as the center of the response to the legal challenges facing thedepartment to ensure a streamlined, consistent response to a litany of issues facing
the department. It is important to ensure consistency across all potential legal
positions taken by the department, including those arising in litigation, congressional oversight, and inquiries received from the Inspector General, U.S. Government
Accountability Office (GAO), and Congressional Research Service and pursuant to
the Freedom of Information Act.
OGC should invest in e-discovery software and contract with a vendor to manage
the department’s e-discovery. This would be beneficial both in litigation and in
responding to congressional oversight. Removing delays in e-discovery processing
would also reduce the issuance of subpoenas to the department and the generationof negative press for the Administration that comes from delayed responses.

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2025 Presidential Transition Project

The old practice of relying on Executive Secretary taskings to pull documents forcongressional requests does not work: It is slow, the metrics for what documents
are gathered and how are unclear, and the components do not gather responsive
material in an efficient manner. Document gathering should come from the Officeof the Chief Information Officer or a relevant technological element within thedepartment that can pull responsive communications quickly.
OFFICE OF LEGISLATIVE AFFAIRS (OLA); OFFICE
OF PUBLIC AFFAIRS (OPA); AND OFFICE OFPARTNERSHIP AND ENGAGEMENT (OPE)

DHS’s external communications function should be consolidated and reformed
so that the President’s agenda can be implemented more effectively. The Office ofPartnership and Engagement should be merged into the Office of Public Affairs.
In many Cabinet agencies, outreach to companies and partner organizations issimilarly performed by the Office of Public Affairs. This would also accomplish aneeded DHS organizational and management reform to decrease the number of
direct reports to the Secretary.
Both public and legislative affairs staff in the components should report directly
to their respective headquarters equivalent. This would help to avoid a failure by
the department to speak with one voice. It would also allow the component staff toperform more efficiently, overseen by expert managers in their trade. This would
also allow DHS to respond to crises effectively by shifting staff as needed to themost pressing issues and better use underutilized staff at less active components.
Only political appointees in OLA should interact directly with congressional staff
on all inquiries, including budget and appropriations matters. To prevent congressional staff from answer shopping among HQ OLA, the DHS OCFO, and components,
DHS legislative affairs appropriations staff should be moved from MGMT OCFO
into OLA. Regarding components, budget/appropriations staff should move fromcomponent budget offices into component legislative affairs offices.
Because dozens of congressional committees and subcommittees either have or
claim to have jurisdiction over some DHS function, DHS staff from the Secretaryon down spend so much time responding to congressional hearing and briefing
requests, letters, and questions for the record that they are left with little time
to do their assigned job of protecting the homeland. The next President shouldreach an agreement with congressional leadership to limit committee jurisdiction
to one authorizing committee and one appropriations committee in each chamber. If congressional leadership will not limit their committees’ jurisdiction over
DHS, DHS should identify one authorizing and appropriations committee in eachchamber and answer only to it.
To focus more precisely on the DHS mission, OLA staff should also identify
outdated and needless congressional reporting requirements and notify Congress— 163 —

Mandate for Leadership: The Conservative Promisethat DHS will cease reporting on such matters. For other congressional reports,
OLA should implement a sunset date so that Congress must regularly demonstrate
the need for specific data.
In both OPA and OLA, a change in mission and culture is needed. The clientsof both components are the President and the Secretary, not the media, externalorganizations, or Congress. OPA and OLA should change from being compliancecorrespondents for outside entities airing grievances to serving as messengers andadvocates for the President and the Secretary.
OFFICE OF OPERATIONS COORDINATION (OPS)OPS was originally conceived by then-Secretary Jeh Johnson as an entity tasked
with coordinating cross-DHS assets on an as-needed basis using a joint operations
approach. This role is particularly challenging because of the disparate nature of
mission sets across DHS.
OPS should absorb a very small number of tactical intelligence professionals from
I&A as the rest of I&A is shut down. Such intelligence officers would be a subordinate
element within OPS placed within the National Operations Center. The intelligence
officers would provide tactical intelligence support for upcoming or ongoing operations in addition to liaising with their agency/component counterparts. There would
be no strategic intelligence analysis done as part of OPS or its new I&A sub-element.
In addition to facilitating all-of-DHS coordination on a task-by-task basis, OPS
would be responsible for ongoing situational awareness for the Secretary and
Deputy Secretary.
In addition to long-term staffing, OPS would have cycling billets from each of
the major agencies and components to facilitate its most effective working relationships across DHS.
OFFICE FOR CIVIL RIGHTS AND CIVIL LIBERTIES(CRCL) AND PRIVACY OFFICE (PRIV)

The Homeland Security Act established only an Officer of CRCL, not an office.
The only substantive function Congress then assigned to the officer was to review
and assess information alleging abuses of civil rights. Since then, Congress and
CRCL itself have significantly expanded CRCL’s scope and size well beyond its
original intent or helpful purpose. CRCL now operates and views itself as a quasiDHS Office of Inspector General. This results in a considerable waste of limited
component resources, which are routinely tasked to address redundant, overly
burdensome, and uninformed demands from CRCL. It is therefore important torecalibrate CRCL’s scope and reach.
The organizational structure of both CRCL and the Privacy Office should bechanged to ensure proper alignment with the department’s mission. The Officeof General Counsel should absorb both CRCL’s and PRIV’s necessary functions— 164 —

2025 Presidential Transition Projectand staff. Although the CRCL Officer and the Freedom of Information Act (FOIA)
Officer/Privacy Officer are statutory, their offices are not mandatory. CRCL and
PRIV Officers and employees should report to a Deputy General Counsel, who
would be a political appointee.
The CRCL Officer should focus on equal employment opportunity (EEO)
compliance and the civil liberties function and investigate matters only within
Headquarters or support components. Operational components’ civil liberties officers should investigate incidents regarding their own agencies. The CRCL Officer
should ensure that all civil liberties or civil rights complaints are sent to the Officeof Inspector General (OIG) for review. If the OIG chooses not to investigate, the
CRCL Officer should only provide supportive information on possible courses ofaction for complainants.
The PRIV Officer and FOIA Officer should focus on FOIA, Privacy Compliance
Policy, and Privacy Incident Response. The Deputy General Counsel should provide
guidance to DHS leadership regarding Privacy Compliance and Privacy Incident
Response. To ensure that only U.S. persons and Lawful Permanent Residents areprovided protections as required by the Privacy Act, all DHS issuances should be
updated to reflect that DHS protects the privacy of individuals as required by thePrivacy Act (U.S. persons and lawful permanent residents);16 the Judicial Redress
Act of 2015;17 and any U.S.–European Union Data Protection and Privacy Agreement.
Because of the lack of public trust in the Office of Intelligence and Analysis,
CRCL and PRIV staff should no longer review intelligence products or provide
guidance on any intelligence products or reports.
A consistent, clear, and singular message is necessary for DHS’s mission.
Therefore, all communications and/or meetings with any federal, state, local, or
nongovernment groups should be limited to the Deputy General Counsel. In addition, given the narrower scope of work, OGC should disband the outside advisoryboards and the more than 50 working groups in which CRCL and PRIV currently
participate. Finally, CRCL and PRIV should no longer issue bulletins or periodicals.
OFFICE OF THE IMMIGRATION DETENTION OMBUDSMAN(OIDO) AND OFFICE OF THE CITIZENSHIP AND
IMMIGRATION SERVICES OMBUDSMAN (CISOMB)OIDO. The Office of the Immigration Detention Ombudsman should be
eliminated. This requires a statutory change in Section 106 of the Consolidated
Appropriations Act of 2020.18
OIDO was designed to create another impediment to detention through an
additional layer of so-called oversight. Several agencies already perform detention
oversight. ICE conducts internal audits of facilities and investigates complaints
against ICE agents through the Office of Professional Responsibility. Similarly, CBP
accepts individual complaints regarding facilities through the Joint Intake Center— 165 —

Mandate for Leadership: The Conservative Promiseand manages complaints against agents through the OPR. In addition, CRCL, OIG,GAO, and Congress all perform detention oversight. These multiple bodies place
unmanageable and unreasonable burdens on ICE to manage several sometimes
inconsistent audits/inspections at the same time.
If OIDO remains a DHS component, the Secretary should immediately issue a directive stripping CRCL of its immigration portfolio. OIDO is in a better position withdedicated resources and immigration experts to perform this function than CRCL is.
Allowing both offices to conduct detention oversight is duplicative and wasteful.
The Secretary should conduct a thorough review of the effectiveness of Directive 0810.1,19 which is widely interpreted as requiring a wholesale referral of cases
to OIG. In reality, OIG investigates only a small fraction of them and often sits on
cases for longer than the five-day window specified in the directive. Meanwhile,
the other agencies wait in limbo to execute their duties.
CISOMB. The Office of the Citizenship and Immigration Services Ombudsman
should be eliminated. The DHS bureaucracy is too large, and the Secretary has too
many direct reports. CISOMB’s policy functions can be performed (and sometimes
already are) by OIG and GAO. The specialized case work can be moved into USCIS
as a special unit, much like the IRS Taxpayer Advocate. This would require a statutory change to Section 452 of the Homeland Security Act of 2002.20
If CISOMB continues as a DHS component, a policy should be issued thatprohibits CISOMB from assisting illegal aliens to obtain benefits. Currently,
approximately 15 percent–20 percent of CISOMB’s workload consists of helping
DACA applicants obtain and renew benefits, including work authorization. This
is not the role of an ombudsman. In addition, the government should be a neutral
adjudicator, not an advocate for illegal aliens.
AGENCY RELATIONSHIPS

It is critical to the achievement of the President’s policy objectives that all agencies and departments touching immigration policy work in sync with one another.
While there are numerous areas in which such cooperation is critical, immigration
has proven to be the most difficult. Accordingly, several objectives will be necessaryfor each of the following departments.
ll

Department of Health and Human Services: Agree to move the Officeof Refugee Resettlement (ORR) to DHS or, alternatively, implement an
aggressive and regular effort by the Secretary of HHS to ensure that ORR is
fully pursuing presidential objectives in support of DHS.
Department of Defense: Assist in aggressively building the border wall
system on America’s southern border. Additionally, explicitly acknowledge
and adjust personnel and priorities to participate actively in the defense— 166 —

2025 Presidential Transition Projectof America’s borders, including using military personnel and hardware toprevent illegal crossings between ports of entry and channel all cross-border
traffic to legal ports of entry.
l

l

l

l

l

l

l

Department of Justice: Agree to move the Executive Office for
Immigration Review and the Office of Immigration Litigation to DHS
and/or, alternatively, to treat the administrative law judges (immigration
judges and Board of Immigration Appeals) as national security personnel,
decertify their union, and move to increase hiring significantly to enable theprocessing of more immigration cases.
Department of State: Allow DHS to lead international engagement in
the Western Hemisphere on issues of security and migration. Additionally,
quickly and aggressively address recalcitrant countries’ failure to accept
deportees by imposing stiff sanctions until deportees are in fact accepted for
return (not just promised to be taken).
Department of Housing and Urban Development: Ensure that only
U.S. citizens and lawful permanent residents utilize or occupy federally
subsidized housing.
Department of Education: Deny loan access to those who are not U.S.
citizens or lawful permanent residents, and deny loan access to students at
schools that provide in-state tuition to illegal aliens.
Department of Labor: Eliminate the two (of four) lowest wage levels forforeign workers.
Department of the Treasury: Implement all necessary regulations both toequalize taxes between American citizens and working visa holders and toprovide DHS with all tax information of illegal aliens as expeditiously as possible.
Intelligence Community: Cooperate in the shrinking or eliminationof the I&A role in the IC while replacing it with CBP and HSI
representation to the IC.

AUTHOR’S NOTE: I had the honor of coordinating the efforts of the experts listed as contributors to thisbook, nearly all of whom have spent more time inside or interacting with the Department of Homeland Security
than myself. I wrote only a small portion of the chapter and relied on the contributors’ experience and expertiseto give the chapter both its depth and policy impact. No views expressed herein should be attributed to any
single contributor.

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Mandate for Leadership: The Conservative Promise
ENDNOTES

1.
2.

3.

4.

5.
6.
7.
8.

9.

10.
11.
12.

13.

14.

15.
16.
17.
18.

H.R. 5005, Homeland Security Act of 2002, Public Law No. 107-296, 107th Congress, November 25, 2002, §101(b)(1), https://www.congress.gov/107/plaws/publ296/PLAW-107publ296.pdf (accessed March 14, 2023).
See, for example, “Elon Musk Slams CISA Censorship Network as ‘Propaganda Platform,’” Kanekoa News,
December 28, 2022, https://kanekoa.substack.com/p/elon-musk-slams-cisa-censorship-network (accessed
March 14, 2023).
H.R. 2680, An Act to Amend the Immigration and Nationality Act, and for Other Purposes, Public Law No.
89-236, 89th Congress, October 3, 1965, https://www.govinfo.gov/content/pkg/STATUTE-79/pdf/STATUTE-79Pg911.pdf (accessed March 14, 2023).
Added to the Immigration and Nationality Act by the Illegal Immigration Reform and ImmigrantResponsibility Act of 1996. See H.R. 3610, Omnibus Consolidated Appropriations Act, 1997, Public Law No.
104-208, 104th Congress, September 30, 1996, Division C, https://www.congress.gov/104/plaws/publ208/
PLAW-104publ208.pdf (accessed March 14, 2023).
8 U.S. Code, https://www.law.cornell.edu/uscode/text/8 (accessed March 14, 2023).
18 U.S. Code, https://www.law.cornell.edu/uscode/text/18 (accessed March 14, 2023).
5 U.S. Code §§ 551–559, https://www.law.cornell.edu/uscode/text/5/part-I/chapter-5/subchapter-II (accessed
March 14, 2023).
Table, “United States Citizenship and Immigration Services Budget Comparison and Adjustments
Appropriation and PPA Summary,” in U.S. Department of Homeland Security, United States Citizenshipand Immigration Services, Department of Homeland Security, United States Citizenship and Immigration
Services, Budget Overview, Fiscal Year 2023 Congressional Justification, p. CIS-4, https://www.uscis.gov/
sites/default/files/document/reports/U.S._Citizenship_and_Immigration_Services%E2%80%99_Budget_
Overview_Document_for%20Fiscal_Year_2023.pdf#:~:text=The%20FY%202023%20Budget%20includes%20%24913.6M%2C%204%2C001%20positions%3B,of%20%24444.1M%20above%20the%20FY%202022%20
President%E2%80%99s%20Budget (accessed March 14, 2023), and Table, “United States Citizenship andImmigration Services Comparison of Budget Authority and Request,” in ibid., p. CIS-5.
H.R. 7311, William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008, Public Law No.
110-457, 110th Congress, December 23, 2008, § 235, https://www.congress.gov/110/plaws/publ457/PLAW110publ457.pdf (accessed March 15, 2023).
Matter of A-B-, Respondent, 27 I&N Dec. 316 (A.G. 2018), https://www.justice.gov/eoir/page/file/1070866/
download (accessed January 18, 2023).
Arizona v. United States, 567 U.S. 387 (2012), https://supreme.justia.com/cases/federal/us/567/387/ (accessed
January 18, 2023).
Robert T. Stafford Disaster Relief and Emergency Assistance Act [Public Law 93–288; Approved May 22, 1974][As Amended Through P.L. 117–328, Enacted December 29, 2022], https://www.govinfo.gov/content/pkg/
COMPS-2977/pdf/COMPS-2977.pdf (accessed March 15, 2023).
U.S. Department of Homeland Security, Federal Emergency Management Agency, Department of Homeland
Security, Federal Emergency Management Agency, Budget Overview, Fiscal Year 2023 Congressional
Justification, p. FEMA-24, https://www.dhs.gov/sites/default/files/2022-03/Federal%20Emergency%20
Management%20Agency_Remediated.pdf (accessed March 15, 2023).
Report, United States Secret Service: An Agency in Crisis, Committee on Oversight and Government Reform,
U.S. House of Representatives, 114th Congress, December 9, 2015, https://republicans-oversight.house.gov/
wp-content/uploads/2015/12/Oversight-USSS-Report.pdf (accessed January 18, 2023).
5 U.S. Code § 7103, https://www.law.cornell.edu/uscode/text/5/7103 (accessed March 15, 2023).
S. 3418, Privacy Act of 1974, Public Law No. 93-579, 93rd Congress, December 31, 1974, https://www.govinfo.
gov/content/pkg/STATUTE-88/pdf/STATUTE-88-Pg1896.pdf (accessed March 15, 2023).
H.R. 1428, Judicial Redress Act of 2015, Public Law No. 114-126, 114th Congress, February 24, 2016, https://www.
congress.gov/114/plaws/publ126/PLAW-114publ126.pdf (accessed March 15, 2023).
H.R. 1158, Consolidated Appropriations Act, 2020, Public Law No. 116-93, 116th Congress, December 20, 2019,https://www.congress.gov/bill/116th-congress/house-bill/1158 (accessed January 18, 2023).

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2025 Presidential Transition Project
19. U.S. Department of Homeland Security, Office of Inspector General, Management Directive No. 0810.1, June 10,2004, https://www.dhs.gov/xlibrary/assets/foia/mgmt_directive_0810_1_the_office_of_inspector_general.
pdf (accessed March 15, 2023).
20. H.R. 5005, Homeland Security Act of 2002, Public Law No. 107-296, 107th Congress, November 25, 2002,
https://www.congress.gov/bill/107th-congress/house-bill/5005 (accessed January 18, 2023).

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