On June 10, 2026, President Trump signed the Secure America Act (S. 2) into law following its passage by both the U.S. Senate and House of Representatives. The legislation provides approximately $70 billion in funding for immigration enforcement activities through September 30, 2029. 

While the law does not change existing immigration eligibility requirements, visa categories, or employment authorization rules, it significantly increases funding for federal immigration enforcement agencies, including U.S. Immigration and Customs Enforcement (ICE) and U.S. Customs and Border Protection (CBP). 

For employers—particularly federal government contractors—the legislation serves as a reminder that immigration compliance remains an important business risk area. 

What Does the New Law Do? 

The Secure America Act allocates funding for: 

• Additional ICE and CBP personnel 

• Immigration enforcement technology and equipment 

• Detention and removal operations 

• Expanded partnerships between federal, state, and local law enforcement agencies 

• Enhanced compliance and enforcement activities 

Because the funding remains available through fiscal year 2029, employers should anticipate a sustained increase in immigration enforcement efforts rather than a short-term initiative. 

Potential Impact on Government Contractors 

Many small and mid-sized government contractors already operate in a highly regulated environment. While the Secure America Act does not create new employment eligibility requirements, increased enforcement resources could result in: 

• More I-9 audits 

• Increased worksite inspections 

• Additional requests for employment records 

• Greater scrutiny of federal contractor compliance practices 

• Increased enforcement actions against employers with deficient hiring records 

Organizations that employ foreign nationals under employer-sponsored visa programs should also ensure that visa-related documentation, job descriptions, payroll records, and work authorization records are accurate and up to date. 

Why Proper I-9 and E-Verify Compliance Matters 

Federal contractors subject to the Federal Acquisition Regulation (FAR) E-Verify clause are already required to verify employment eligibility through the E-Verify system for covered employees.

As part of C2 Essentials' onboarding process, newly hired employees complete their Form I-9 through the employee portal, and C2 administers E-Verify services for clients that are subject to federal E-Verify requirements. These processes help establish consistent employment eligibility verification procedures and support compliance with federal regulations. 

Looking Ahead 

The Secure America Act does not automatically change immigration laws or work authorization requirements. However, the substantial increase in enforcement funding signals that immigration compliance will remain a federal priority for the foreseeable future.

Government contractors that maintain strong hiring, onboarding, and recordkeeping practices will be better positioned to respond to audits, inspections, and compliance reviews should enforcement activity increase.  

On June 9, 2026, the U.S. Department of Justice (DOJ) announced a $21.3 million settlement involving allegations that federal contracts reserved for Service-Disabled Veteran-Owned Small Businesses (SDVOSBs) and other small businesses were improperly obtained through a pass-through arrangement.

Although the settlement does not constitute a determination of liability, it highlights the federal government's continuing focus on the integrity of small business contracting programs and compliance with SBA requirements. 

A pass-through arrangement occurs when a small or certified business wins a government contract but does not meaningfully perform or control the work required under the contract. Instead, most of the work is subcontracted to another entity—often a larger or ineligible company—that effectively manages performance, staffing, and delivery.

In these situations, the certified small business may function primarily as a “front” for contract eligibility while another company carries out the actual work and receives the majority of contract value.   

According to the DOL, “The civil settlement includes the resolution of claims brought under the qui tam provisions of the False Claims Act by two whistleblowers, a veteran of the United States Air Force and an executive with an SDVOSB firm.

The False Claims Act allows private individuals to file suit on behalf of the United States for false claims and share in any recovery. Under the settlement agreement, the relators will receive $3,674,250. The case is captioned United States ex rel. Welch, et al. v. American First Contracting Inc., et al., No. 3:23-cv-0525 (N.D.N.Y.).” 

Federal agencies rely on programs such as the 8(a) Business Development Program, HUBZone Program, Women-Owned Small Business (WOSB) Program, and Veteran Contracting Programs to help eligible small businesses compete for federal contracts.

These programs create significant opportunities for small businesses but also impose strict requirements regarding ownership, control, performance of work, and subcontracting. 

A common area of enforcement involves allegations that a certified small business serves primarily as a vehicle for a larger or otherwise ineligible company to obtain set-aside work.

Government investigators may review whether the certified firm truly controls contract performance, manages day-to-day operations, makes key business decisions, and performs the required percentage of contract work. Contractors should pay particular attention to: 

• Joint venture and mentor-protégé arrangements 

• Teaming agreements and subcontracting relationships 

• SBA size and certification requirements 

• Limitations on subcontracting rules 

• Documentation demonstrating operational control and management authority 

• Internal records supporting compliance with program eligibility requirements 

The SBA's limitations on subcontracting rules are designed to ensure that small businesses—not larger partners or subcontractors—perform the required share of work under set-aside contracts. These requirements vary depending on whether the contract is for services, supplies, general construction, or specialty construction and can have a significant impact on contract performance planning.

Contractors should ensure that project managers, contracts personnel, and business development teams understand these requirements before submitting proposals.  SBA guidance explains that limitations on subcontracting are intended to prevent ineligible businesses from using small businesses merely as vehicles to access set-aside contracts and outlines minimum performance requirements applicable to many set-aside awards. 

Potential consequences of noncompliance may include contract termination, suspension or debarment, loss of certification status, False Claims Act investigations, financial penalties, and repayment obligations. 

Recommended Employer Actions 

While no immediate action is required, government contractors participating in SBA programs should consider: 

• Reviewing ownership and management structures to confirm continued eligibility 

• Evaluating subcontracting and teaming arrangements for compliance risks 

• Confirming that key personnel and decision-making authority remain with the certified business 

• Reviewing contract performance to ensure compliance with subcontracting limitations 

• Maintaining documentation supporting certification eligibility and contract compliance 

• Providing periodic compliance training to contracts, program management, and business development personnel 

Category FY 2024 Awards 

According to SBA procurement data, Service-Disabled Veteran-Owned Small Businesses received a record $32.8 billion in federal prime contract awards during FY 2024, accounting for 5.15% of eligible federal contracting dollars and exceeding the federal government's 5% SDVOSB contracting goal. 

• Small Businesses (all categories) - $183.3 billion 

• Small Disadvantaged Businesses - $78.1 billion 

• Service-Disabled Veteran-Owned Small Businesses (SDVOSBs) - $32.8 billion 

• Women-Owned Small Businesses - $31.7 billion 

• HUBZone Small Businesses - $17.5 billion 

Helpful SBA Resources 

• Federal Contracting Overview: https://www.sba.gov/federal-contracting 

• Contracting Assistance Programs: https://www.sba.gov/federal-contracting/contracting-assistance-programs 

• Prime Contracting and Subcontracting Guidance: https://www.sba.gov/federal-contracting/contracting-guide/prime-subcontracting 

• Federal Contracting Rules and Responsibilities: https://www.sba.gov/federal-contracting/contracting-guide/governing-rules-responsibilities 

Did you know approximately 540,000 spouses are married to active-duty service members, yet military spouses experience unemployment rates nearly four times higher than civilian spouses?  

Military spouses are among the most educated, resilient, and adaptable members of the American workforce. Yet despite their qualifications, military spouses continue to experience unemployment rates significantly higher than those of civilian workers. Recent research found that active-duty military spouses have an unemployment rate of approximately 8.8%, nearly four times higher than the civilian spouse rate of 2.5%. Despite strong workforce participation, many military spouses face employment interruptions, underemployment, and reduced earnings due to the unique demands of military life.  

According to the U.S. Chamber of Commerce, many industries continue to face labor shortages in fields such as healthcare, education, administration, finance, customer service, human resources, and information technology. At a time when employers across industries are struggling to fill positions, this highly educated and resilient talent pool remains significantly underutilized and often-overlooked source of skilled professionals.  

Military Spouses by the Numbers 

According to statistics tracked by the U.S. Department of Defense, U.S. Government Accountability Office, and U.S. Department of Labor Veterans' Employment and Training Service approximately 540,000 civilian spouses are married to active-duty service members, nearly 70% participate in the labor force, about 90% are women, and Military spouses earn approximately 38% less than their civilian counterparts.  

The Impact on Military Families 

Employment remains one of the top concerns identified by military spouses in Department of Defense surveys. Military families increasingly rely on dual incomes to achieve financial stability. When a military spouse struggles to find meaningful employment, the effects extend well beyond lost wages. Employment barriers can contribute to: 

• Reduced household income and financial stress 

• Delayed career advancement and lower lifetime earnings 

• Difficulty maintaining professional licenses and certifications 

• Challenges securing affordable childcare 

• Increased stress during deployments and relocations 

• Lower satisfaction with military life, which can influence service member retention decisions 

Why Military Spouses Face Higher Unemployment 

Frequent Relocations - Military families often relocate every few years through Permanent Change of Station (PCS) assignments. Each move can disrupt careers, create employment gaps, and force spouses to rebuild professional networks from scratch. 

Licensing and Credentialing Challenges - Many professions—including healthcare, education, counseling, and social services—require state-specific licenses. Military spouses frequently encounter delays and costs associated with transferring credentials after each move. 

Childcare Availability - Access to affordable childcare remains a significant challenge for many military families. Limited childcare options can make it difficult for spouses to pursue full-time employment or career advancement opportunities. 

Employer Misconceptions - Some employers assume military spouses will not remain with the organization long enough to justify hiring or training investments. In reality, military spouses often bring exceptional adaptability, resilience, and remote-work experience. 

Underemployment - Even when employed, many military spouses accept positions below their education level or outside their preferred career field because relocation limits available opportunities. 

What Employers Can Do 

Organizations seeking qualified talent can take practical steps to support military spouse employment while strengthening their own workforce. 

1. Expand Remote and Hybrid Opportunities - Remote work allows military spouses to maintain employment despite relocations and reduces turnover associated with PCS moves. 

2. Focus on Skills Rather Than Employment Gaps - Military spouses often have resumes that reflect multiple relocations. Hiring managers should evaluate candidates based on skills, accomplishments, and potential rather than assuming employment gaps indicate a lack of commitment. 

3. Partner with Military Spouse Hiring Programs - Many organizations specialize in connecting employers with military spouse talent and can help streamline recruiting efforts. 

4. Support Professional Licensing Portability - Where feasible, employers can assist with licensing reimbursements, credential transfers, and onboarding support for relocated employees. 

5. Create Military-Friendly Recruiting Practices - Including military spouse hiring initiatives within workforce development and diversity strategies can expand access to highly qualified candidates. 

Recruitment Resources for Employers 

Employers interested in recruiting military spouses can leverage several established organizations and programs that specialize in connecting businesses with military-affiliated talent. 

Final Thoughts 

Military spouses possess many of the qualities employers seek: adaptability, resilience, professionalism, and the ability to thrive in changing environments. By adopting military-spouse-friendly hiring practices, employers can access a highly capable talent pool while helping military families achieve greater financial stability and career success.

As workforce shortages continue across many industries, supporting military spouse employment is both a smart business decision and a meaningful way to support those who serve alongside America's military members. 

The question is no longer whether employers can afford to support military spouse employment—it's whether they can afford to overlook this talent pool.