Noem's DHS Restricted Bidding for Nearly $220 Million in Ads; She Told Senators It Was Competitive
Chapter 1 — Public Money, Restricted Bidding, Political Connections
Chapter 2 — What Noem Told Congress, and What DHS Has Not Answered
Chapter 3 — Trump Praised Noem After the Hearings and Announced Another Appointment
1 · Public Money, Restricted Bidding, Political Connections
1.1 — Nearly $220 Million Through a Pool DHS Chose
1.2 — The Production Firm Had Worked for Noem's Political Campaign
DHS committed nearly $220 million through two advertising contracts after restricting the initial bidding to a pool it chose. Three offers came in; the opportunity was never publicly announced. DHS said the campaign prompted more than 2.2 million self-deportations, but its published totals do not separate the effect of advertising from enforcement and incentives.
An announcement for this action will not be published at SAM.gov. It is exempt from the requirement per the exception at FAR 5.202(a)(2).
The Strategy Group, which had managed Noem's gubernatorial advertising, acknowledged $226,137.17 in production fees through a subcontract on March 3. The senators later reported an accounting that included a $60,000 signing bonus benefiting the firm. DHS said contractors chose their own subcontractors and that Tricia McLaughlin, the DHS official married to the firm's CEO, recused herself. The payment establishes a political connection in the spending.
Read the full chapter — all the detail, fully footnoted →
2 · What Noem Told Congress, and What DHS Has Not Answered
2.1 — Competitive Bidding Without the Restrictions
2.2 — Who Approved the Contracts
The answer quoted in the referral described competitive bidding without mentioning the restricted pool or the lack of a public announcement. Congress permits an urgency exception, and three offers were received, so her description could be literally true. Two Judiciary ranking members requested an investigation; a Justice Department spokesperson called the referral a political stunt, ABC News reported.
Yes, they did. They went out to a competitive bid, and career officials at the Department chose who would do those advertising commercials.
Read the full chapter — all the detail, fully footnoted →
Noem reserved personal approval of awards over $100,000 after the original awards, and four new advertising orders followed the implementing instruction, including a $65 million domestic campaign order. Senate minority staff found 1,034 awards delayed or awaiting approval under the rule. Noem denied that Corey Lewandowski had a contract-approval role; ProPublica reported internal records and officials' accounts contradicting that denial, and DHS repeated it. By September 14, the senators investigating said the department had produced no responsive records to their March request.
3 · Trump Praised Noem After the Hearings and Announced Another Appointment
3.1 — The President Kept and Publicly Praised Her
3.2 — The Impeachment Argument
Trump announced her replacement eleven and a half months after House Democrats demanded the campaign's documents and two days after her Senate testimony. He publicly praised her performance and announced a new envoy appointment in the same post. Trump reportedly denied knowing about the campaign, while Noem said he approved the spending.
The charge is restricted public contracting and publicity for a Cabinet Secretary, followed by inadequate accounting to Congress. A politically connected firm acknowledged production fees, and senators later reported a signing bonus benefiting the firm. In September, two senators said DHS had provided no substantive response and no responsive records to their March contracting inquiry. The impeachment argument against Trump concerns his responsibility for keeping and publicly praising Noem after scrutiny of that spending.
Read the full chapter — all the detail, fully footnoted →
Full Source Index
Primary Sources
- [2]Letter from Ranking Member Richard J. Durbin (Senate Committee on the Judiciary) and Ranking Member Jamie Raskin (House Committee on the Judiciary) to Attorney General Pamela J. Bondi, referring Secretary Noem for investigation under 18 U.S.C. §§1001 and 1621 · primary (for what the Ranking Members wrote and referred); a congressional rendering of the hearing record for the testimony it quotes
- [3]U.S. Department of Homeland Security, Justification and Approval for Other Than Full and Open Competition, solicitation 70RDA225R00000015 (redacted version), published by DHS as an attachment to SAM.gov Special Notice 70RDA225-FY25-JA · a signed departmental document, published by the department that wrote it
- [4]Federal Procurement Data System — Next Generation, public ATOM feed of every contract action recorded for SAFE AMERICA MEDIA LLC (12 actions, complete: two pages, the second short of the page size, so neither is truncated) · the government's own contract-action record, raw XML, deterministic pull
- [5]Federal Procurement Data System — Next Generation, public ATOM feeds for the two advertising contracts and every order under them, captured again on October 10, 2026 · the government's own contract-action record, raw XML
- [6]United States Senate Committee on the Judiciary, official hearing page, 'Oversight of the Department of Homeland Security' · the committee's own record of its own proceeding
- [7]Letter from Sens. Peter Welch and Richard Blumenthal to an individual they asked about his role at Safe America Media LLC · for what the senators asserted and asked; NOT primary for the underlying facts it recites, which it footnotes to reporting, to SAM.gov, to USAspending and to a state search 'on file with the Office'
- [8]The Strategy Group Co., public statement, March 3, 2026 · the subcontractor's own account of its payment and services
- [9]The White House, presidential action, 'President Trump Announces Cabinet and Cabinet Level Appointments' · the President's own publication
- [10]Post by @realDonaldTrump announcing the succession, Truth Social status 116178030946996760 — the platform's own API record (raw JSON) · the speaker's own platform record
- [11]USAspending.gov award record for indefinite-delivery contract 70RDA225D00000004 (Safe America Media LLC), U.S. Department of the Treasury · a second, independent government rendering of the same award
- [12]
- [13]
- [14]
- [15]
- [16]
- [17]Federal Procurement Data System — Next Generation, public ATOM feed of every contract action recorded under indefinite-delivery contract 70RDA225D00000003 (13 actions across two pages, complete) · the government's own contract-action record, raw XML
- [19]
- [21]Department of Homeland Security, CBP Home stipend release, January 21, 2026 · for DHS's claims and announced incentives
- [22]Edward Kissam, Center for Migration Studies of New York, January 12, 2026, analysis of self-deportation estimates · for the author's own analysis and estimate
- [23]41 U.S.C. §3301 — full and open competition (Office of the Law Revision Counsel, United States Code) · governing statutory text
- [24]41 U.S.C. §3304 — exceptions to full and open competition, including unusual and compelling urgency · governing statutory text
- [25]
- [26]
- [27]
- [28]
- [29]
- [30]SAM.gov exclusions index, searched on Safe America Media LLC's unique entity identifier R64SJRYFDKM7 · a government index, cited for a zero result
- [31]
- [32]
- [33]
- [34]
- [35]
- [36]
- [38]Minority staff report of the United States Senate Committee on Homeland Security and Governmental Affairs on the Federal Emergency Management Agency, prepared for Ranking Member Gary Peters and Ranking Member Andy Kim, reproducing the Secretary's memorandum of June 11, 2025 and a June 24, 2025 memorandum from the Acting Director of Acquisition Policy and Legislation implementing it · for the committee's own findings, and for the two departmental instruments it reproduces and transcribes
- [39]U.S. Department of Homeland Security press release claiming savings at 200 days · the agency's own words about its own rule
- [40]
- [42]Office of Sen. Richard Blumenthal, press release publishing the senator's exchange with Secretary Noem in transcript form · for what the senator's office published
- [44]Letter from Sen. Richard Blumenthal to Secretary Noem demanding that she amend her testimony · for the demand and its date
- [45]Letter from the Inspector General of the U.S. Department of Homeland Security to the chairs and ranking members of three congressional committees, 'Re: Department of Homeland Security obstruction of OIG work', with two attachments · an inspector general's own written notification to Congress
- [47]
- [48]United States Senate, roll-call vote record No. 17 of the 119th Congress, first session, on nomination PN11-11 (structured XML) · the Senate's own record of its own vote
- [49]House Committee on Oversight and Government Reform Democrats, press release announcing that Ranking Members Gerald E. Connolly and Bennie G. Thompson had written to the Secretary about the advertising campaign · primary for the fact and date of the demand; the committee's own rendering of its own letter for anything the release quotes
- [50]U.S. Department of Homeland Security, 'Message from Secretary Kristi Noem' to departmental employees · the department's own publication of the Secretary's own words
- [51]
- [52]U.S. Department of Homeland Security press release announcing the successor's confirmation and swearing-in · the department's own announcement
- [53]U.S. Department of State, Office of the Spokesman, media note 'Deputy Secretary Landau’s Travel to Costa Rica', May 6, 2026 · an official government release
- [54]
- [55]
- [56]U.S. Const. art. II, §4 — National Archives transcription of the Constitution · the binding constitutional text
- [57]The Federalist No. 65 (Alexander Hamilton), Library of Congress research guide text of Federalist Papers 61–70 · primary (the founding-era text), carried as interpretation and not as law
Secondary Sources
- [1]Fox News Digital, Alexandra Koch, March 3, 2026, DHS defense of advertising outcomes · named official's on-record claims
- [18]Fox News Digital report of March 4, 2026 carrying an on-record statement from Department of Homeland Security General Counsel James Percival about the advertising contracts · news reporting, carrying a named senior official on the record
- [20]PBS News, Joshua Barajas, March 3, 2026, Kennedy questioning Noem on advertising spending · reporting on the hearing
- [37]ABC News, 'Top Democrats refer Noem to DOJ for alleged perjury', March 16, 2026 · reliable secondary (attributed)
- [41]Associated Press dispatch carried by NBC News reporting the rescission of the $100,000 approval rule · news reporting, carrying a departmental spokesperson on the record
- [43]
- [46]ABC News, April 2, 2026, Inspector General investigation of DHS contracting · sourced reporting, not an Inspector General finding