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Overview of the DHS Balanced Workforce Strategy for Federal Contractors

The Balanced Workforce Strategy (BWS) refers to the Department of Homeland Security's (DHS) effort to identify the appropriate balance of federal and contractor employees required to achieve the DHS mission. The DHS BWS was established in 2010 in response to statutory requirements, including section 736 of the 2009 Omnibus Appropriates Act1, guidance from the President, Office of Management and Budget (OMB) policy, and Government Accountability Office (GAO) recommendations.


The BWS was created to ensure DHS:

  • Complies with applicable statutes, regulations, and policies, through a repeatable, documented decision-making process;
  • Determines the proper balance of federal and contractor employees for programs and functions; and
  • Reduces mission risk, while as practicable, reducing or controlling cost.


The BWS process takes DHS Components through a three-step review of proposed requirements for services (formerly new work and re-competed requirements). Each DHS Component has a BWS Component Working Group composed of experts from finance, human capital, procurement, and legal that coordinates with program officials to conduct each BWS review. The ultimate outcome of BWS Component Working Group’s efforts is the determination of an appropriate number of federal and/or contractor employees for a particular function.

The first step, Identify the Work, involves reviewing a description of the function, such as a service contract's statement of work or other supporting document, to isolate and accurately describe each discrete function that should undergo analysis.

The second step, Analyze the Work, relies on an electronic questionnaire entitled Balanced Workforce Assessment Tool2 (BWAT), which leads the These questions ensure compliance with law, regulations, and relevant policy. Items in the questionnaire address issues including, but not limited to, the relationship of a function to the Department’s core missions; the risk to a function if all contractors were to leave suddenly; and the likelihood that a function might evolve into an inherently governmental function (work that cannot legally be performed by contractors), work outside of the scope, or work that is otherwise restricted. The BWAT produces a suggested ratio of federal employees to contractor personnel, which the Component uses as it considers the issue of mission control and how a function should be sourced.

As prescribed by section 736 of the 2009 Omnibus Appropriations Act, if a Component’s answers to the questionnaire in the BWS Tool indicate that a function can be performed by federal or contractor personnel, the Component proceeds with a cost comparison analysis. The result of the cost comparison analysis helps to inform the Component’s final decision on the most efficient source of support for the function under review.

During the final step of review, Implement the Sourcing Decision, the Component considers the recommended action and works to implement the sourcing strategy reached at the conclusion of the second step. In the event the Component decides not to accept the recommended action, they are required to address concerns about mission control by providing a risk mitigation strategy, such as substantially enhancing contract oversight or increasing reporting requirements.


The Balanced Workforce Division, within the Office of the Strategic Workforce Planning and Analysis (formerly the Balanced Workforce Program management Office – BW PMO), leads execution of the Department’s Balanced Workforce Strategy (BWS).  Given the complexity of decisions related to the sourcing of programs and functions, DHS also established the BWS Change Control Board ( formerly the BWS Departmental Working Group) composed of senior representatives from the Office of the Chief Human Capital Officer, the Office of the Chief Financial Officer, the Office of the Chief Procurement Officer, the Office of the General Counsel, the Office of Small and Disadvantage Business Utilization, and the Office of Program Accountability and Risk Management (PARM). The  BWS Change Control Board uses its multi-disciplinary expertise to ensure consistent Department-wide application of the BWS and reviews and approves major changes to the BWS and Balanced Workforce Assessment Tool (BWAT).


The Balanced Workforce Strategy Guidance document outlines the BWS process for Components and serves as the overarching policy governing all BWS reviews. The Guidance is revisited periodically and updated based on lessons learned, Component feedback, and changes to law, regulation, or government-wide policy.

Non-critical Functions

DHS has developed a list of functions that do not pose a significant risk to the DHS mission and therefore are not required to undergo full-scale analysis using the BWAT.  Examples of functions include copier machine maintenance, credit reporting services, lawn maintenance, pest control, etc. 

Small and Disadvantaged Business Contracting

DHS remains committed to small and disadvantaged businesses, and in accordance with Government-wide policy, small businesses receive primary consideration among commercial sources on planned contracts regardless of dollar value. DHS has taken several steps to ensure that small and disadvantaged businesses are not unfairly affected by the BWS.

In keeping with Office of Management and Budget (OMB) Office of Federal Procurement Policy (OFPP) guidance in Policy Letter 11-01, DHS is not applying the BWS to any contracts with total dollar values below $150,000, given that the values of such contracts suggest that they do not pose a significant risk to mission control and should be reserved for small and disadvantaged businesses, when possible.3

The Office of Small and Disadvantaged Business Utilization advises the BWS Departmental Working Group, and reviews any Component sourcing decisions that have the potential to affect small and disadvantaged businesses. DHS also encourages Components to include their Small Business Specialists in the deliberations of their BWS Component Working Group as well as any discussions concerning proposed procurements that will be reviewed using the BWS process.

OFPP Policy Letter 11-01 provides specific instructions on the importance of small businesses, with respect to ensuring performance of inherently governmental and critical functions. In implementing the BWS, DHS Components have been instructed to:

  • Place a lower priority on reviewing work performed by small businesses when the work is not inherently governmental and where continued contractor performance does not put the Department at risk of losing control of its mission or operations;
  • Involve its Component-level small business advocate if considering the insourcing of work currently being performed by small businesses; and
    • Apply the “Rule of Two,” if it is determined that the function can be performed by a combination of federal and contractor personnel. The Rule of Two requires that acquisitions be reserved for award to small businesses, or certain subsets of small businesses, if there are two or more responsible small businesses capable of performing the work at fair market prices.


Please direct any initial questions you might have about BWS to your Contracting Officer’s Representative (COR). Small businesses may also reach out to the appropriate DHS small business specialist. If are unable to resolve your questions about the DHS BWS or are concerned about how BWS reviews may be affecting your work with DHS, contact the Balanced Workforce Program Management Office via email at OCHCOBalancedWorkforceTeam@hq.dhs.gov.

1 Section 736 of the FY 2009 Omnibus Appropriations Act, P.L. 111-8, Div. D, § 736.

2 The Balanced Workforce Assessment Tool is the new system that will replace the automated BWS Tool. It is scheduled to deploy by the end of FY 2013.

3 Office of Federal Procurement Policy, Policy Letter 11-01, Performance of Inherently Governmental and Critical Functions (Sept. 2011).

Last Updated: 03/07/2019
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