๐Ÿ› U.S. Department of Labor ยท FLAG System ยท Full Contract History dol.gov โ†—
Federal Government ยท USASpending.gov Data ยท August 12, 2026

Who Actually Built the H-1B Application System?

A drill-down from our Custom Computer Programming report: the full contracting history behind FLAG โ€” the Foreign Labor Application Gateway that OFLC uses to process every H-1B, H-2A, H-2B, and PERM case. Tracing every award back to 2018 turns up 7 contracts across 3 prime vendors, one subcontractor, and a near-unbroken run by a single company since mid-2019.

7 Contracts, 2018โ€“2026 $21.7M Obligated $24.2M Ceiling 1 Vendor, 6 of 7 Awards Source: USASpending.gov
Contracts Traced
7
Obligated to Date
$21.69M
Ceiling Value
$24.23M
Prime Vendors
3
Subcontractor
1
$834.5K to date
Contract Vehicles
4
๐ŸŽฏ How this started: Our 2026 Custom Computer Programming report flagged a single $1.4M Booz Allen Hamilton task order for FLAG. Pulling the thread โ€” searching USASpending for every DOL award mentioning "FOREIGN LABOR APPLICATION GATEWAY" back to 2007 โ€” surfaces the system's entire paper trail: an original 2019 build-out, three rounds of enhancements, an operations-and-maintenance contract, a competitor's brief requirements-documentation task, and a predecessor quality-assurance contract dating to 2018. Booz Allen Hamilton has held the core FLAG work continuously since June 2019.

Methodology

Started from the specific award identified in our NAICS 541511 report (PIID 1605TA26F00001) and worked outward. USASpending's award-detail API exposes each contract's parent_award (the underlying IDV/BPA it was ordered against) โ€” following that chain back showed the current task order sits under BPA 1605TA22A0001 ("Executive Order Support Services"), itself a successor to an older BPA, DOL-OPS-17-A-001, signed with Booz Allen in December 2016. Separately, a keyword search across all DOL contracts and all years for "FOREIGN LABOR APPLICATION GATEWAY" and related phrasing (not limited to any NAICS code or date range) surfaced every award that named the system directly, plus one 2018 predecessor contract for "OFLC case management" quality-assurance work that pre-dates the FLAG name. Subcontractor data comes from USASpending's subaward records attached to the two most recent Booz Allen task orders.

Full Timeline

Aug 2018 โ€“ Aug 2020 ยท PIID 1605DC18F00319
GRAY MATTERS TECHNOLOGY SERVICE, LLC
$1,275,400 obligated ($3,117,793 ceiling w/ options)
"CNT - OFLC CMQA" โ€” quality assurance services for OFLC's case management system, ordered under IDIQ 1605DC-17-D-0002 (a change-management/QA vehicle Gray Matters held since 2017). Firm-fixed-price, base year + 3 option years. This is the earliest identifiable ancestor of what became FLAG โ€” QA work on the system, not core development.
Full & Open Competition After Exclusion of Sources ยท Gray Matters is an 8(a), Black American-owned, woman-owned, veteran-owned small business (Bowie, MD)
Jun 2019 โ€“ Dec 2020 ยท PIID 1605DC19F00191
BOOZ ALLEN HAMILTON INC โ€” first FLAG award
$7,847,790 obligated
"Task order against Booz Allen Hamilton BPA: DOL-OPS-17-A-001 for continuation of DOL case management platform ETA/OFLC application modernization: Foreign Labor Application Gateway (FLAG) and Apprenticeship Expansion and Modernization (AEM) support." This order funded two systems together โ€” FLAG and a separate apprenticeship-modernization platform (AEM) โ€” so not all $7.85M is attributable to FLAG alone.
Full & Open Competition ยท Time & Materials
Aug 2020 โ€“ Aug 2021 ยท PIID 1605TA20F00032
BOOZ ALLEN HAMILTON INC
$1,001,228 obligated
"Foreign Labor Application Gateway (FLAG) Enhancements." Follow-on order under the same BPA, this one exclusively FLAG-scoped.
Full & Open Competition ยท Time & Materials
May 2021 โ€“ Nov 2021 ยท PIID 1605TA21F00039
INSIGNIA FEDERAL GROUP, LLC โ€” different vendor, narrow scope
$369,318 obligated
"Documenting PERM requirements for Foreign Labor Application Gateway (FLAG) modernization." A short, narrowly-scoped requirements-gathering task specific to the PERM (employment-based green card labor certification) module โ€” not a development or O&M contract, and not awarded to Booz Allen. Ordered under a separate IDIQ (1605DC18D0007) Insignia held for web content management services.
Full & Open Competition After Exclusion of Sources ยท Insignia is an 8(a), Asian Pacific American-owned, woman-owned small business (McLean, VA)
Aug 2022 โ€“ Aug 2023 ยท PIID 1605TA22F00097
BOOZ ALLEN HAMILTON INC
$1,169,543 obligated
"Follow-on order for OFLC enhancements for the Foreign Labor Application Gateway (FLAG)." Booz Allen back as sole vendor on FLAG-specific work, still under the original DOL-OPS-17-A-001 BPA.
Full & Open Competition ยท Labor Hours
Apr 2024 โ€“ Feb 2026 ยท PIID 1605TA24F00028
BOOZ ALLEN HAMILTON INC โ€” largest single order
$8,597,787 obligated ($9,300,166 ceiling w/ options)
"Order issued to provide operation and maintenance support services for the Employment and Training Administration (ETA) Office of Foreign Labor Certification (OFLC), Foreign Labor Application Gateway (FLAG), Permanent Online and Case Management System." The full O&M contract โ€” DOL's single largest FLAG-specific award โ€” now ordered under the newer BPA, 1605TA22A0001. One subcontractor: Allora Consulting Inc ($658,564 for "software engineering and technology consulting services").
Full & Open Competition ยท Labor Hours
Feb 2026 โ€“ Jul 2026 ยท PIID 1605TA26F00001
BOOZ ALLEN HAMILTON INC โ€” current, from our 2026 report
$1,426,317 obligated
"Foreign Labor Application Gateway (FLAG) Permanent Online and Case Management Systems." Begins the day after the prior O&M order expires โ€” a direct continuation, not a re-compete. Runs only through July 31, 2026, meaning another order (renewal or re-compete) is likely imminent. Same subcontractor: Allora Consulting Inc ($175,968 so far).
Full & Open Competition ยท Labor Hours

All 7 Contracts โ€” Summary Table

PIIDVendorObligatedPeriodContract VehicleCompetitionPricing
1605DC18F00319Gray Matters Technology Service$1,275,4002018-09 to 2020-08IDIQ 1605DC17D0002Full & Open (excl. sources)Firm Fixed Price
1605DC19F00191Booz Allen Hamilton$7,847,7902019-06 to 2020-12BPA DOL-OPS-17-A-001Full & OpenTime & Materials
1605TA20F00032Booz Allen Hamilton$1,001,2282020-08 to 2021-08BPA DOL-OPS-17-A-001Full & OpenTime & Materials
1605TA21F00039Insignia Federal Group$369,3182021-05 to 2021-11IDIQ 1605DC18D0007Full & Open (excl. sources)Labor Hours
1605TA22F00097Booz Allen Hamilton$1,169,5432022-08 to 2023-08BPA DOL-OPS-17-A-001Full & OpenLabor Hours
1605TA24F00028Booz Allen Hamilton$8,597,7872024-04 to 2026-02BPA 1605TA22A0001Full & OpenLabor Hours
1605TA26F00001Booz Allen Hamilton$1,426,3172026-02 to 2026-07BPA 1605TA22A0001Full & OpenLabor Hours
Total obligated$21,687,383

Contract Vehicle Lineage

FLAG-related work has run through four different underlying vehicles over its history โ€” two of them Booz Allen BPAs (one succeeding the other), and two IDIQs held by the other two vendors for narrower, non-development work.

VehicleTypeHolderSignedPurpose
DOL-OPS-17-A-001BPABooz Allen Hamilton2016-12-21OCIO portfolio, program & project management and technical support services โ€” the broad umbrella FLAG's first 3 orders were called against
1605DC17D0002IDIQGray Matters Technology Service2017-08-10Change management & quality assurance services
1605DC18D0007IDIQInsignia Federal Group2018-06-28Web content management services
1605TA22A0001BPABooz Allen Hamilton2021-11-24"Executive Order Support Services" โ€” successor umbrella BPA, single-award, running through 2026-11-23; FLAG's two most recent orders sit here

Subcontractor

Booz Allen has used the same subcontractor on both of its most recent FLAG task orders, for the same scope of work.

SubcontractorPrime Task OrderAmountAction DateWork
ALLORA CONSULTING INC1605TA24F00028 (2024 O&M)$658,5642025-10-07Software engineering & technology consulting services
ALLORA CONSULTING INC1605TA26F00001 (2026, current)$175,9682026-02-24Software engineering & technology consulting services

Executive Compensation & Ownership

None of the 7 task/delivery orders in this history have FFATA executive-compensation data reported against them in USASpending โ€” including the Booz Allen awards, despite Booz Allen being a large, publicly-traded company (its officer comp does appear on other DOL contracts, per our NAICS 541511 report, so its absence here reflects per-award reporting gaps rather than the company being below any threshold). Insignia Federal Group and Gray Matters Technology Service are both certified small businesses with SBA socio-economic designations โ€” Insignia is 8(a) and Asian Pacific American-owned; Gray Matters is 8(a), Black American-owned, and veteran-owned. These are legitimate federal set-aside certifications, not the officer-name-pattern signal used elsewhere on this site, and are noted here for transparency rather than as a flag.

Investigative Assessment

Notable Booz Allen Hamilton has held FLAG's core development and O&M work almost continuously since June 2019 โ€” 6 of 7 traced contracts, $20.04M of the $21.69M obligated (92%). The single-award BPA structure (both DOL-OPS-17-A-001 and its successor 1605TA22A0001) means FLAG work isn't competed order-by-order; it's called directly against Booz Allen's standing agreement.
Watch The current task order (1605TA26F00001) runs only through 2026-07-31 โ€” a roughly 5.5-month order, short compared to the 2024 contract's 22 months. A follow-on order or re-compete is likely due imminently; worth checking USASpending again after that date for what comes next.
Watch 5 of the 6 Booz Allen orders are priced Time & Materials or Labor Hours rather than Firm Fixed Price โ€” cost grows with hours billed rather than being capped up front, a structure worth tracking if FLAG's costs continue rising order over order (they roughly doubled from the ~$1M enhancement orders of 2020โ€“2023 to the $8.6M O&M order in 2024).
Positive Every contract in this history was fully and openly competed (two "after exclusion of sources," which restricts but doesn't eliminate competition) โ€” no sole-source awards anywhere in FLAG's 8-year paper trail.

Help Support This Research

This investigation is produced independently โ€” one person, 23 years of data work, living on $1,419/month Social Security. If this work matters to you, a small donation makes a real difference.

♥ Donate via Square More Reports

💬 Comments