University of Miami National Security & Armed Conflict Law Review

Document Type



Increasingly, the U.S. federal government is turning to the use of private-­public sector partnerships (“PPP”), especially in the area of homeland security. Although these partnerships have numerous benefits, there are several problems that arise in their practice, particularly when they are used in homeland security.

This note will outline and detail these problems, including deputization, excessive congressional oversight, and management and accountability. In addition, this note will present solutions to resolving the issue of centralization. In other words, this note will advocate for a single agency that implements, manages, and creates rules for all PPPs within the Department of Homeland Security. Finally, this note will argue that not only is there a need for this one managing agency, but that the agency should be governed under the principals of the Administrative Procedure Act (“APA”).