DHS reported using its Other Transaction Authority to work with non-traditional contractors, DHS did not always follow statutory requirements when entering, modifying, and overseeing its agreements. Inadequate internal policies contributed to DHS falling short of meeting all statutory requirements for using OTAs. In addition, DHS acquisition policy staff reported that competing priorities prevented timely reporting to Congress. As a result, DHS may have taken on more risks and costs than necessary and impeded Congress’ ability to oversee DHS’ use of OTAs.