ASSESSED: Pass-Through Contracting Is Hollowing Out National Security Funding

The $142.5 Million Question

On February 6, 2025, Safe America Media LLC was incorporated in Delaware. It had no website, no headquarters, no employees, and no prior federal contracting experience. It was registered to the home address of Michael McElwain, a political operative who formerly served as political director of the National Republican Congressional Committee. Eight days later, on February 14, the Department of Homeland Security awarded the company $142.8 million as part of a $220 million campaign to produce advertisements promoting the administration’s immigration enforcement agenda.

The contract was awarded under “other than full and open competition.” DHS invoked President Trump’s declaration of a national emergency at the US-Mexico border as justification for bypassing standard competitive bidding — a circumstance permitting what the Federal Acquisition Regulation terms “unusual and compelling urgency.” Four companies were permitted to bid. The turnaround from solicitation to award was approximately three days.

One of the four invited bidders was Knox Strategies, the firm of Erica Knight, a former spokeswoman for now-FBI Director Kash Patel. Knox Strategies appears to have been included to meet the minimum threshold for what procurement regulations consider a competitive process. Its inclusion in a nine-figure advertising contract solicitation raises the question of whether the bidding pool was constructed to manufacture the appearance of competition rather than to identify the most capable contractor.

Follow the Money: Where $142.5 Million Disappeared

Of the $142.8 million awarded to Safe America Media, the traceable subcontracting chain accounts for a fraction of the total:

• People Who Think LLC — a Louisiana-based firm owned by Jay Connaughton, a political consultant who served as media adviser for Trump’s 2016 campaign — received $77 million as a subcontractor.
• The Strategy Group — run by Ben Yoho, the husband of DHS Assistant Secretary for Public Affairs Tricia McLaughlin — received $226,137 for production services covering five film shoots and 45 video advertisements.

That leaves approximately $65.5 million in the pass-through entity alone — Safe America Media — with no public accounting of where it went. Federal contracting databases do not require disclosure of subcontractors, which means the money enters what procurement experts describe as an untraceable network. The prime contractor takes its cut, subcontractors take theirs, and the public record shows only the top-line award.

ProPublica confirmed The Strategy Group’s role in the subcontracting chain. Procurement experts who reviewed the structure flagged what they described as serious structural concerns: the emergency designation bypassed competitive bidding, and the contracting paperwork does not explain why Safe America Media or its subcontractors were selected, or how funds were allocated below the prime contract level.

The DOGE Exemption: A Firewall Around Political Contracting

The executive order establishing DOGE’s cost-efficiency mandate contains a carve-out that exempts contracts and grants “directly related to the enforcement of federal criminal or immigration law,” as well as CBP and ICE specifically. Agency heads may also exempt contracts “in writing from all or part of this order.”

This means the $220 million DHS advertising campaign — and the contracting apparatus around it — was structurally immunized from the same efficiency reviews that DOGE applied to virtually every other category of federal spending. While DOGE personnel terminated contracts, cut agency budgets, and reduced headcounts across the federal government, the immigration enforcement carve-out created a protected zone where procurement decisions were subject to less scrutiny, not more.

The operational effect: DOGE reviews eliminated spending across agencies while simultaneously exempting the category of spending most susceptible to the pass-through contracting pattern described here.

The Approval Chain: An Unpaid Adviser With Signing Authority

Corey Lewandowski’s role at DHS illustrates a structural vulnerability in federal ethics architecture. His title — “special government employee” — designates an unpaid, temporary adviser. Special government employees are subject to fewer ethics requirements than regular federal employees and are permitted to maintain undisclosed sources of outside income.

Despite this limited formal status, internal DHS routing sheets reviewed by ProPublica show Lewandowski personally approved multimillion-dollar contracts and was typically the final signature before Secretary Noem’s on any contract above $100,000. When Senator Richard Blumenthal asked Noem under oath whether Lewandowski has “a role in approving contracts” at DHS, Noem answered “No.” Internal records contradict that testimony.

Lewandowski has declined to disclose whether he receives compensation from any outside companies. The special government employee designation does not require the same financial disclosure as regular government employees, creating what amounts to an institutional blind spot: an individual with contract approval authority and no obligation to reveal who else pays him.

The System Actively Resists Cost Efficiency

In a previously unreported incident, then-ICE deputy chief of staff Madison Sheahan called an ICE employee to her office and, according to sources familiar with the exchange, threatened the employee’s job. The employee’s offense: suggesting that DHS consider a contractor that had offered to do the same work for a lower price.

Sheahan told the employee the contract award was “a decision made by the secretary.” The employee acquiesced and processed the award to the secretary’s preferred contractors. This is not a system that failed to find a cheaper option. This is a system that identified a cheaper option and actively suppressed it.

NBC News subsequently reported that Noem handpicked contractors to lead a separate $100 million ICE recruitment campaign instead of allowing competitive bidding, with internal communications confirming the selection was directed from the secretary’s office rather than through procurement channels.

Structural Enablers: This Is Not New

The pass-through contracting pattern has historical precedent. During the Iraq War, emergency procurement authorities enabled the rapid expansion of private military and logistics contractors — Blackwater, KBR, Halliburton — through mechanisms structurally identical to those used here:

• Emergency procurement authorities that bypass competitive bidding
• Pass-through entities that obscure the ultimate recipients of federal funds
• Subcontractor opacity that prevents public tracking of where money goes
• Political relationships between contractors and the officials who select them

What distinguishes the current pattern is the brazenness of the timeline (eight days from incorporation to nine-figure award), the domestic rather than warzone context, and the deliberate exemption from the administration’s own cost-efficiency apparatus. In the Iraq era, emergency contracting was justified by active combat operations in a foreign theater. Here, the emergency justification is a policy declaration about the southern border — an ongoing condition that has persisted across administrations.

The Noem Outcome: Consequences Without Reform

On March 5, 2026, Trump fired Noem as DHS Secretary, naming Senator Markwayne Mullin as her replacement. An administration official cited “a culmination of her many unfortunate leadership failures including the fallout in Minnesota, the ad campaign, the allegations of infidelity, the mismanagement of her staff, and her constant feuding with the heads of other agencies.”

Trump himself stated he “absolutely” did not sign off on the $220 million ad campaign — directly contradicting Noem’s Senate testimony two days earlier that the president had approved it.

Noem’s firing addresses the personnel problem. It does not address the structural problem. The emergency procurement authority remains intact. The immigration law enforcement exemption from DOGE review remains intact. The subcontractor opacity that makes federal funds untraceable below the prime contract level remains intact. The special government employee designation that permits individuals with contract approval authority to maintain undisclosed outside income remains intact.

Assessment

The pass-through contracting scheme at DHS is not an aberration. It is a predictable outcome of structural enablers that have existed in federal procurement for decades, now operating in a domestic context with reduced oversight.

Who benefits:

• Political operatives who incorporate shell entities to capture federal contracts (McElwain, Safe America Media)
• Campaign-connected consultants who receive subcontracts through personal relationships rather than competitive merit (Connaughton/People Who Think, Yoho/Strategy Group)
• Unpaid advisers who maintain contract approval authority without financial disclosure obligations (Lewandowski)

What enables it:

• Emergency proclamations that convert policy positions into procurement shortcuts
• Categorical DOGE exemptions that firewall political contracting from efficiency review
• Subcontractor opacity that makes funds untraceable below the prime contract
• The special government employee loophole that separates approval authority from disclosure requirements

What it costs:

• $142.5 million in public funds with no traceable accounting
• DHS procurement integrity — career employees threatened for suggesting cheaper alternatives
• Congressional oversight capacity — testimony under oath contradicted by internal records
• National security funding that could have gone to actual security capabilities

The machinery that made this possible will outlast the individuals involved. Firing Noem removes one operator from a system designed to run without accountability. The next secretary inherits the same emergency authorities, the same exemptions, and the same opacity. The question is not whether the pattern will recur. It is whether the structural enablers will be reformed before it does.

This is a YNTK red cell assessment. It represents analytical judgment based on publicly reported facts, not insider knowledge. Sourced claims are attributed inline. Structural analysis and pattern identification are the assessment of the YNTK Intelligence Desk.