Homeland Security Restoration Act¶
Policy Brief¶
Published March 2026¶
Problem Diagnosis¶
The Design Failure¶
The Department of Homeland Security was not designed. It was assembled. In the months following September 11, 2001, Congress consolidated 22 agencies from across the federal government into a single new Cabinet department under the Homeland Security Act of 2002. The consolidation logic was simple: agencies with any connection to "homeland security" should report to a single Secretary who could coordinate their efforts. This logic was intuitively appealing and structurally catastrophic.
The agencies absorbed into DHS had fundamentally different missions, professional cultures, legal authorities, and accountability structures. The Secret Service (founded 1865) investigated financial crimes. The Coast Guard (founded 1790) saved lives at sea. The Federal Emergency Management Agency coordinated disaster response. Customs collected tariffs and facilitated trade. The Immigration and Naturalization Service adjudicated citizenship applications and enforced immigration law. The Transportation Security Administration screened airline passengers. None of these missions are naturally related. Placing them under a single political appointee did not create coordination -- it created a sprawling apparatus whose internal incoherence guaranteed that some missions would be subordinated to others based on political priority rather than institutional design.
The post-9/11 emergency also meant that the department's dominant institutional culture was enforcement and security. Agencies whose missions were fundamentally non-coercive -- disaster relief, maritime safety, citizenship services, cybersecurity research -- were absorbed into an organizational culture that prioritized threat prevention and border control. FEMA's "all-hazards" disaster response capability was diluted by the department's focus on counter-terrorism. The Coast Guard's search-and-rescue mission was subordinated to enforcement operations. The consolidation did not elevate non-security missions to security-level priority. It subordinated non-security missions to a security framework that had no use for them.
The Risk Profile¶
No Cabinet position combines this much coercive authority with this little institutional resistance. That claim is not rhetorical -- it is structural.
The DHS Secretary commands Immigration and Customs Enforcement (ICE), Customs and Border Protection (CBP), the Secret Service, the Coast Guard, the Transportation Security Administration (TSA), FEMA, and the Cybersecurity and Infrastructure Security Agency (CISA). These agencies collectively possess broad arrest, detention, and border authority exercised with reduced judicial oversight; immigration enforcement operating in a civil rather than criminal framework with fewer constitutional protections; surveillance capabilities over domestic communications infrastructure; access to biometric databases, travel records, and domestic surveillance systems; jurisdiction touching every person entering or leaving the country, every port, every airport, and every coastal waterway; and the ability to execute immigration raids, travel bans, border closures, and disaster relief withholding immediately and simultaneously.
The "100-mile border zone" doctrine -- under which CBP claims expanded authority within 100 miles of any U.S. border or coastline -- covers roughly two-thirds of the American population. A single political appointee's authority thus extends, with reduced constitutional protections, over approximately 200 million Americans.
Compare this to the two Cabinet positions with comparable coercive profiles. The Department of Justice has prosecutorial power and law enforcement reach -- but it also has more than a century of evolved independence norms, a professional prosecutorial culture, and a deep institutional resistance to direct political control. The Department of Defense commands the most powerful military force in human history -- but it operates under the Posse Comitatus Act, the Uniform Code of Military Justice, and a command culture that treats civilian-military separation as a foundational value. DHS has none of these constraints. It is the youngest major department in the government, and its institutional culture -- to whatever extent one has developed in twenty-three years -- is enforcement-first, built around a post-9/11 emergency frame that was never updated for normal governance.
The result is a department purpose-built for rapid action and constitutional corner-cutting, with the weakest institutional friction of any major Cabinet agency, placed under the direct command of a single political appointee who serves at the pleasure of the President. That is not a governance design. It is a capture waiting to happen.
The Empirical Record¶
The structural vulnerabilities are not theoretical. They have been activated -- systematically, rapidly, and across every dimension of the department's authority.
Federal officers shot a U.S. citizen during an immigration enforcement operation in Chicago; the department's initial public statements were contradicted by body-camera footage reviewed in federal court.[1] Two U.S. citizens were fatally shot by federal immigration officers in Minneapolis.[2] U.S. District Judge Jeffrey Cummings found that ICE arrested at least 22 individuals without warrants in violation of a federal consent decree -- a decree ICE's own legal team then attempted to declare void by email to all agency employees nationwide.[3] ICE conducted military-style raids on residential buildings, detaining U.S. citizens, military veterans, and seniors for hours without documentation of probable cause.[4] Federal court filings revealed that hundreds -- potentially thousands -- of arrests during a single enforcement operation were made without warrants or with forms filled out after detention had already occurred.[5]
DHS agents used facial recognition technology and license plate readers to monitor legal observers exercising First Amendment rights. More than 750 Coast Guard flights were redirected from maritime patrols and search-and-rescue missions to immigration deportation operations.[6] Secretary Noem verbally ordered the diversion of a Coast Guard C-130 from an active search-and-rescue mission for a 23-year-old service member who had gone overboard -- while the guardsman, Seaman Bryan K. Lee, was still missing at sea.[7] He was never found.
Over 2,000 FEMA employees departed in a single year, leaving the nation's disaster response agency more than 35 percent below its target staffing level.[8] CISA lost roughly one-third of its workforce through buyouts, layoffs, and forced reassignments, gutting the agency responsible for defending U.S. critical infrastructure against cyberattack.[9] Senior career leadership at ICE was purged to achieve political alignment.[10] DHS implemented a policy requiring seven days' advance notice for congressional oversight visits to immigration detention facilities; Members of Congress who arrived without prior approval were turned away at the door.[11] A federal court ruled the policy violated federal law and ordered it enjoined -- after which Secretary Noem issued a nearly identical policy under different budget authority.[12] During a partial government shutdown, DHS announced the suspension of the Global Entry program and the TSA PreCheck system -- programs funded by user fees with no operational connection to the funding lapse -- before reversing the PreCheck decision within hours under pressure from the travel industry.[13]
Every dimension of the department's risk profile has been confirmed. The department has demonstrated the fastest time-to-damage of any Cabinet agency and the least internal resistance. The question is no longer whether this can happen. It is happening now.
The Compounding Loop¶
DHS does not operate in isolation. Its coercive capabilities combine with those of other departments to create a self-reinforcing enforcement loop: DHS conducts enforcement operations; the Department of Justice provides legal cover and prosecutorial authority; the Department of Defense contributes military assets and logistical support; the Department of the Treasury enables financial surveillance and sanctions power. When all four departments are aligned under loyalist leadership, the constitutional system of friction between departments collapses into unified command.
The Homeland Security Restoration Act (HSRA) addresses this loop at its most vulnerable node -- the youngest, least institutionally anchored, and most recently consolidated department. It is paired with APAI's Federal Law Enforcement Council Act (FLECA), which addresses the loop at DOJ by replacing the single Attorney General with a multi-member Federal Law Enforcement Council, structurally resistant to capture through staggered terms, partisan balance requirements, and for-cause removal protections. Together, HSRA and FLECA target the two civilian enforcement pillars of the loop simultaneously. Decomposing DHS while leaving DOJ's single-officer structure intact would be incomplete. Reforming DOJ while leaving DHS's consolidated authority in place would be incomplete. The two proposals are a coordinated architecture, not independent items.
The decomposition breaks the DHS node because it is the only department in the enforcement triad that was assembled within living memory, lacks evolved institutional culture, and can be disassembled without disrupting functions that have always been organizationally unified.
Mechanism Design¶
Guiding Principles¶
Adversarial architecture. The Act assumes that any single department may be captured by loyalist leadership, and designs for structural isolation that limits the speed and scope of damage when capture occurs. This inverts the logic that created DHS. The 2002 consolidation assumed good-faith actors coordinating shared missions. Adversarial architecture assumes the design must function even when actors operate in bad faith.
Proportional structural protection. Not every agency requires the same governance safeguard. The Act calibrates protections to actual risk: independent governance structures where coercive power and civil liberties exposure are highest, existing departmental homes where the risk profile is lower. This proportionality is essential to legislative viability -- the Act creates two new independent entities and restores one, rather than proliferating nine or more new federal bodies.
Foreign-domestic domain separation. As a secondary organizing principle, the Act distinguishes between agencies whose missions face outward (border security, trade enforcement, external threat prevention) and those facing inward (disaster response, transportation safety, domestic cybersecurity, citizenship services). This prevents enforcement-oriented institutional cultures from subordinating service-oriented missions through institutional neglect.
Major Component Reassignments¶
ICE Enforcement and Removal Operations -- Independent Immigration Enforcement Commission. ICE's enforcement arm is the single most consequential structural decision in the Act. It operates in a civil legal framework with reduced constitutional protections; the border-zone doctrine extends its reach to two-thirds of the American population; and its career leadership has been systematically purged and replaced with political loyalists. The institutional default -- the Department of Justice -- is already the highest-risk civilian enforcement agency in the Cabinet. Adding ICE's coercive power to DOJ's portfolio worsens the concentration problem. The Act establishes an independent commission with staggered six-year terms, partisan balance requirements, for-cause removal protections, and documented use-of-force protocols.
CBP -- Department of the Treasury. Revenue collection, tariff enforcement, and port-of-entry operations have a direct historical lineage at Treasury, where the Customs Service resided for over two centuries before the 2003 merger. Air and Marine Operations follows CBP.
Homeland Security Investigations (carved out of ICE) -- Department of the Treasury or Department of Commerce. HSI's portfolio -- financial crimes, trade fraud, intellectual property, cybercrime -- has no operational connection to immigration enforcement. HSI agents themselves have repeatedly requested separation.
USCIS -- Department of State. Reunifies the immigration benefits pipeline with consular visa processing. Does not recreate the dysfunctional Immigration and Naturalization Service model. The Ombudsman for Immigration Services follows USCIS.
Coast Guard -- Department of Transportation. Returns to its pre-2003 home. The Act includes a statutory mission priority clause preventing subordination of search-and-rescue to enforcement operations.
TSA -- Department of Transportation. Unanimous across all analytical perspectives. Reunifies aviation security with the Federal Aviation Administration.
Secret Service -- Department of the Treasury. Returns to its 138-year institutional home. Core missions (counterfeiting, financial crimes) align with Treasury's mandate.
FEMA -- Independent Agency (restored). Fixed-term director (six years) with for-cause removal protections. Objective-metrics funding triggers tied to National Oceanic and Atmospheric Administration damage assessments create a structural barrier to disaster aid withholding -- removing the Secretary's ability to use emergency response as a political instrument.
CISA -- Standalone Cyber Security Board (National Transportation Safety Board model). Investigative and standard-setting authority without law enforcement power. Non-enforcement mandate. Strict statutory separation from the enforcement triad and the intelligence community. An agency whose purpose is defending civilian infrastructure has no business operating inside a department whose primary culture is enforcement.
Minor Components¶
The Act dissolves the Office of Intelligence and Analysis (transferring foreign-threat analysis to the Office of the Director of National Intelligence and eliminating the domestic intelligence function) and the Office of Strategy, Policy, and Plans (whose coordination function has no purpose without a department to coordinate). The Federal Protective Service moves to the General Services Administration. Countering Weapons of Mass Destruction and the Domestic Nuclear Detection Office move to the Department of Energy. The Science and Technology Directorate moves to the National Science Foundation. The Federal Law Enforcement Training Centers move to the Department of Justice. Bioforensic and health functions move to the Department of Health and Human Services. Civil rights compliance and Inspector General functions distribute to successor agencies under existing frameworks.
Targeting and Safeguards¶
The Coordination Objection¶
The strongest counterargument to decomposition is that pre-9/11 coordination failures -- agencies that did not share information across institutional boundaries -- enabled the September 11 attacks. Decomposing DHS appears to recreate the fragmentation that produced those failures.
This objection conflates coordination with consolidation. Coordination means agencies share information and communicate across boundaries. Consolidation means agencies report to a single political appointee who can direct their combined capabilities. DHS achieved consolidation but never reliably achieved coordination -- twenty-three years later, its component agencies have never fully integrated their information systems, institutional cultures, or operational procedures.
The federal government already has a functioning model for coordination without consolidation: the National Security Council. The Department of Defense, the Department of State, the CIA, and the intelligence community coordinate through the NSC framework without being merged into a single department. The Act preserves interagency coordination through statutory information-sharing mandates and joint operational protocols while eliminating the single political appointee who can direct combined capabilities simultaneously.
The diversion of Coast Guard flights to deportation missions, the use of CISA surveillance to monitor legal observers, and the suspension of TSA PreCheck as political leverage all represent coordination in reverse -- the subordination of one agency's mission to another's political objectives, enabled by consolidation. Fragmentation would have prevented each of these abuses.
Structural Safeguards¶
The Immigration Enforcement Commission's multi-member governance makes simultaneous capture of leadership impossible within a single presidential term. The Cyber Security Board's non-enforcement mandate prevents weaponization of surveillance capabilities. FEMA's fixed-term director and objective funding triggers prevent aid withholding. The Civil Service Accountability Act's (CSAA) career workforce protections -- applied to every successor agency -- make mass leadership purges procedurally impossible. The CSAA requires that reduction-in-force actions affecting more than 5 percent of any component's workforce trigger automatic Government Accountability Office review and congressional notification.
Congressional Oversight Simplification¶
DHS currently answers to over 100 congressional committees and subcommittees -- a number that grew from the 86 the 9/11 Commission identified in 2004, despite the Commission's recommendation for consolidation.[14] This fragmentation is a direct product of the 2002 merger: Congress consolidated 22 agencies without reorganizing its own committee structure. The result is an oversight architecture so diffuse that it provides cover rather than accountability.
Decomposition resolves this by aligning each agency with the committee structure matching its mission. TSA and the Coast Guard at Transportation answer to the transportation committees. The Secret Service and CBP at Treasury answer to the finance committees. The oversight architecture simplifies from over 100 fragmented jurisdictional claims to established committee relationships -- creating two new jurisdictional questions (the independent entities) instead of perpetuating over twenty unresolved ones.
Political Economy¶
Who Benefits from the Status Quo¶
The President benefits from a single phone call reaching a single Secretary who commands immigration enforcement, border security, disaster relief, cybersecurity, transportation screening, and federal protection services simultaneously. That is not an accident. It is precisely what makes the current structure dangerous, and precisely why executives of both parties have resisted decomposition.
The DHS Secretary holds a scope of authority unmatched in the Cabinet. No other single appointee commands this combination of coercive, surveillance, and operational capacity -- and no other position offers this much institutional leverage to a loyalist willing to use it.
Congressional committee chairs with jurisdictional claims over DHS components benefit from oversight authority that translates into hearing calendars, subpoena power, and influence over grant funding. Over 90 chairs and ranking members currently claim a piece of DHS oversight. These members have a direct personal incentive to resist any reorganization that reduces their jurisdictional reach -- and they have exercised that incentive successfully for two decades.
Defense and security contractors benefit from DHS's $60 billion annual budget flowing through a single procurement and contracting apparatus. Decomposition means renegotiating contracting relationships across multiple agencies.
Who Is Harmed by the Status Quo¶
DHS career professionals serve in a department whose institutional culture, oversight structure, and career protections are the weakest of any major Cabinet department. The agencies with the longest institutional histories -- Coast Guard, Secret Service, Customs -- have seen their professional cultures subordinated to an enforcement-first department they never organically belonged to. The result is documented: over 2,000 FEMA employees departed in 2025 alone; CISA lost a third of its workforce; Coast Guard morale has been described by insiders as "terrible."[15]
The American public is subject to the concentrated coercive authority of a department operating with reduced constitutional protections, minimal internal checks, and the fastest time-to-damage of any federal agency. This is not a partisan observation. It is an institutional design problem that will exist under any administration and will be exploited by any loyalist Secretary willing to use the tools the structure provides.
Congress as an institution is hampered by an oversight structure that the 9/11 Commission called "dysfunctional" and that has only worsened since.[16] The Commission on the Prevention of Weapons of Mass Destruction gave Congress a grade of "F" for failing to consolidate DHS oversight; its former leader later said he would issue "an F-minus."[17]
Blocking Power and Coalition Dynamics¶
The primary blocking power resides in congressional committee chairs who would lose jurisdictional claims. This is the same dynamic that has defeated every oversight consolidation attempt since 2004. The Act mitigates this through two mechanisms. First, agencies placed in existing departments automatically fall under those departments' established committee relationships, making jurisdictional realignment a structural consequence rather than a separate legislative fight. Second, the Act can be pursued as modular legislation -- individual agency transfers can proceed independently if the full decomposition faces resistance, with each successfully passed component reducing DHS's scope and making remaining transfers politically easier.
The Act's relationship to the Federal Elections Modernization Act (FEMA) and the Office of Congressional Procedure Act (OCP) also matters. The expanded House reduces the scarcity of committee slots that makes jurisdiction valuable. The OCP's proportional committee leadership distribution eliminates winner-take-all committee control. Together, they dissolve the incentive structure that makes turf wars rational. Without these companion reforms, the decomposition faces the same jurisdictional resistance that has blocked every prior attempt. With them, the resistance structure itself is transformed.
Fiscal Framework¶
Order-of-Magnitude Costs¶
The decomposition involves transferring approximately 240,000 employees and $60 billion in annual budget authority across the federal government. The primary costs are transitional rather than ongoing:
Transition costs include IT system migration, facilities reallocation, personnel processing, union contract transfers, and administrative restructuring. The 2002 consolidation cost approximately $4.5 billion in transition expenses (inflation-adjusted). The decomposition's transition costs are likely comparable in scale -- estimated at $3 billion to $6 billion over the implementation period -- though the absence of a new headquarters construction requirement (the 2002 Act required building the DHS campus at St. Elizabeths) may reduce the total.[18]
New entity establishment costs for the Immigration Enforcement Commission and the Cyber Security Board include governance infrastructure, administrative systems, and initial staffing for board support. Comparable independent commissions operate with annual administrative budgets of $20 million to $50 million each.
Ongoing savings are structurally real but difficult to quantify precisely. DHS's administrative overhead as a centralized department -- duplicative management layers, the DHS headquarters apparatus, the congressional liaison burden of responding to 100-plus oversight committees -- represents costs that do not transfer to successor agencies. The fiscal case for the Act does not rest on cost savings. It rests on structural risk reduction. The decomposition may be approximately budget-neutral in ongoing costs while requiring significant one-time transition investment.
Open Design Questions¶
HSI placement -- Treasury or Commerce? Homeland Security Investigations' portfolio spans financial crimes (Treasury alignment) and trade fraud and intellectual property (Commerce alignment). The final placement depends on which investigative portfolio is prioritized. This is a decision that benefits from input from HSI leadership and the receiving departments.
FEMA funding trigger design. The objective-metrics funding trigger concept -- tying disaster relief disbursement to NOAA damage assessments -- requires detailed technical specification. What damage thresholds trigger what funding levels? How are NOAA's preliminary damage assessments converted into disbursement authorities? This mechanism is architecturally sound but requires collaboration with emergency management professionals and fiscal policy experts to operationalize.
Transition sequencing. Should the decomposition proceed as a single omnibus bill or a series of targeted statutes? The omnibus approach preserves conceptual coherence but creates a larger legislative target. The modular approach gains flexibility but risks leaving the most politically difficult transfers (ICE) for last. The sequencing strategy is a political judgment that depends on the legislative environment at the time of introduction.
Independent entity committee jurisdiction. The Immigration Enforcement Commission and the Cyber Security Board require new committee oversight assignments. The most natural homes are the Judiciary Committees (immigration enforcement) and the Commerce/Science Committees (cybersecurity). These assignments cannot be mandated by statute and must be negotiated within each chamber's rules process. The Act can structure reporting requirements and appropriations pathways to create functional primary oversight relationships, but formal jurisdiction is ultimately a chamber-internal decision.
Interagency coordination architecture. The Act replaces DHS consolidation with interagency coordination protocols. The specific design of these protocols -- which agencies participate, what information-sharing mandates apply, what joint task force structures are created -- requires detailed development. The NSC model provides a structural template, but homeland security coordination involves different agencies and different operational tempos than national security coordination. Domain expertise in interagency operations is needed to specify the coordination architecture.
Honest Limitations¶
This is a structural reform, not a guarantee. Adversarial architecture slows the speed of damage and limits its scope. It does not prevent all damage. A sufficiently determined political movement with sustained popular support and control of Congress can override any statutory structure. The Act buys time and creates friction -- it does not create permanence.
The transition period is a vulnerability window. Moving 240,000 employees and $60 billion in budget authority creates operational disruption. Coordination may degrade before it improves as interagency protocols mature. The conforming amendments problem is real -- federal law contains thousands of references to DHS and the Secretary of Homeland Security, and identifying every reference is a massive technical undertaking.
Political will is the binding constraint. The policy case for decomposition is strong. The structural design is sound. None of these matter without political will to act. The same congressional turf wars that have blocked oversight consolidation for twenty years will resist decomposition. The Act is designed to be technically and constitutionally viable. Whether it is politically viable depends on forces beyond its text.
Works Cited¶
[1] NBC News / NPR Illinois. "Court scrutiny of ICE mounts as judge rules warrantless arrests violated order." October 8, 2025. Reporting on the shooting of Marimar Martinez during an ICE enforcement operation in Chicago, and federal proceedings in which a defendant's attorney stated body-camera footage contradicted DHS's public narrative about the circumstances. https://www.nprillinois.org/illinois/2025-10-08/court-scrutiny-of-ice-mounts-as-judge-rules-warrantless-arrests-violated-order
[2] CNN Politics. "DHS reverses course on TSA PreCheck suspension after confusion." February 22, 2026. Notes the fatal shootings of two U.S. citizens by federal immigration officers in Minneapolis as context for the DHS partial government shutdown standoff. https://www.cnn.com/2026/02/22/politics/shutdonw-tsa-precheck-global-entry-suspended-hnk
[3] Block Club Chicago / NPR Illinois. "ICE Violated Consent Decree With Warrantless Arrests, Federal Judge In Chicago Says." October 7-8, 2025. U.S. District Judge Jeffrey Cummings found that ICE arrested at least 22 individuals without warrants in violation of the Castaon Nava consent decree, and that a top ICE attorney emailed all agency employees declaring the decree void. https://blockclubchicago.org/2025/10/07/ice-violated-consent-decree-with-warrantless-arrests-federal-judge-in-chicago-says/
[4] American Immigration Council. "How ICE Went Rogue: Analysis of the Legal Authorities Governing ICE." February 2026. Documents ICE enforcement raids on residential buildings, vehicle stops based on apparent racial profiling, and arrests of U.S. citizens and community members without individualized probable cause determinations. https://www.americanimmigrationcouncil.org/fact-sheet/ice-cbp-legal-analysis/
[5] Borderless Magazine. "Federal Judge Rules Against ICE Over Memo That Expanded Power To Make Warrantless Arrests." February 18, 2026. Court filings reviewed by attorneys showed hundreds to thousands of arrests during Operation Midway Blitz were made without warrants or with administrative warrant forms completed after detention. https://borderlessmag.org/2026/02/18/federal-judge-rules-against-ice-over-memo-that-expanded-power-to-make-warrantless-arrests/
[6] NBC News / Juneau Independent. "Noem's use of Coast Guard resources strains her relationship with the military branch, sources say." February 17, 2026. ICE Flight Monitor data compiled by Human Rights First shows more than 750 Coast Guard flights redirected from maritime patrols and search-and-rescue to immigration deportation operations. https://www.juneauindependent.com/post/report-noem-s-shift-of-coast-guard-resources-to-alien-expulsion-operations-sinking-other-duties
[7] NBC News. "Noem's use of Coast Guard resources strains her relationship with the military branch, sources say." February 17, 2026. Four current and former officials confirmed that Secretary Noem verbally instructed Acting Commandant Admiral Kevin Lunday to divert a C-130 from the active search for Seaman Bryan K. Lee, 23, who had gone overboard in the Pacific Ocean from the cutter Waesche on February 4, 2025. DHS disputed the account; four independent government sources confirmed it. https://www.nbcnews.com/politics/immigration/noems-use-coast-guard-resources-strains-relationship-military-branch-s-rcna258904
[8] CNN Politics. "DHS begins slashing FEMA disaster response staff as 2026 begins." January 2, 2026. More than 2,000 FEMA employees departed in 2025 through layoffs and buyouts, leaving the agency more than 35 percent below its Government Accountability Office-identified staffing target. https://www.cnn.com/2026/01/01/politics/dhs-cutting-fema-disaster-response-staff
[9] Axios / Federal News Network. "U.S. cyber agency faces another round of layoffs amid government shutdown." October 14, 2025; "For DHS workforce, 2025 marked a year of major change." December 30, 2025. CISA lost approximately one-third of its workforce -- roughly 900 to 1,000 staff -- through voluntary buyouts, early retirements, layoffs, and forced reassignments to ICE and other enforcement agencies. https://www.axios.com/2025/10/14/trump-administration-cyber-agency-layoffs-dhs; https://federalnewsnetwork.com/hiring-retention/2025/12/for-dhs-workforce-2025-marked-a-year-of-major-change/
[10] NBC News / FedAgent. "DHS Firings Hit FEMA, CISA as Secretary Noem Orders Lie Detector Tests." February 2025. DHS initiated a centralized plan to remove senior leaders across every DHS component to achieve political alignment; ICE career leadership was specifically targeted. https://www.fedagent.com/news/dhs-firings-hit-fema-cisa-as-secretary-noem-orders-lie-detector-tests
[11] Roll Call. "Judge halts DHS policy on oversight visits to ICE detention facilities." December 17, 2025. U.S. District Judge Jia Cobb temporarily blocked DHS guidance requiring members of Congress to provide seven days' advance notice before visiting immigration detention facilities, finding the policy "contrary to law and in excess of DHS's statutory authority." https://rollcall.com/2025/12/17/judge-halts-dhs-policy-on-oversight-visits-to-ice-detention-facilities/
[12] CBS News. "Trump administration again restricts when members of Congress can inspect ICE facilities." January 11, 2026. Within weeks of the December court order, Secretary Noem issued a new, nearly identical seven-day notice requirement purportedly funded under a different budget authority; three Minnesota members of Congress were subsequently denied access to a Minneapolis ICE facility. https://www.cbsnews.com/news/ice-facilities-homeland-security-lawmakers-visit-inspections/
[13] ABC News / Washington Post / NBC News. "DHS reverses decision to suspend TSA PreCheck and Global Entry due to shutdown." February 22, 2026. DHS announced the suspension of both programs -- funded entirely by user fees -- during a partial government shutdown over immigration policy; the PreCheck suspension was reversed within hours following industry pressure, while Global Entry remained suspended. https://abcnews.com/US/dhs-suspending-tsa-precheck-global-entry-due-shutdown/story?id=130380172; https://www.washingtonpost.com/nation/2026/02/21/tsa-precheck-global-entry-shutdown/
[14] The 9/11 Commission Report. National Commission on Terrorist Attacks Upon the United States. July 2004. The Commission identified 88 congressional committees and subcommittees with DHS oversight jurisdiction and recommended dramatic consolidation. That number has grown in the two decades since. https://govinfo.library.unt.edu/911/report/index.htm
[15] Federal News Network. "For DHS workforce, 2025 marked a year of major change." December 30, 2025. Documents workforce losses across DHS components; NBC News reporting on the Noem-Coast Guard tensions notes that morale at Coast Guard headquarters is described by insiders as "terrible." https://federalnewsnetwork.com/hiring-retention/2025/12/for-dhs-workforce-2025-marked-a-year-of-major-change/
[16] See note 14.
[17] Commission on the Prevention of Weapons of Mass Destruction Proliferation and Terrorism. "Letter to Congress on DHS Oversight." 2010. Former co-chair Bob Graham stated Congress deserved "an F-minus" for failing to consolidate DHS oversight in the years following the Commission's 2008 report. The Commission's formal 2008 assessment gave Congress a grade of "F" on this specific reform. Multiple press accounts confirm the "F-minus" quote.
[18] The $4.5 billion transition cost figure for the 2002 DHS consolidation is drawn from Congressional Budget Office and Government Accountability Office analyses of the department's first several years of operation, adjusted for inflation. The figure is illustrative; a formal CBO score of HSRA would be required for legislative consideration.
Prepared by Albert Ramos for The American Policy Architecture Institute