The Last 17 Days of FY2026: 10 of the 12 Largest Obligations Were Modifications, Not New Competitions
Sep 14-30 obligated $43.25B, 78% of September. The 12 largest checks: 10 modifications, 2 task orders. TriWest $1.20B, AMI Metals $547M for CBP steel, Clark $332M to design-build in Laredo. None of them was a competition a new bidder could have entered that week.
Short answer: 10 of the 12 largest federal contract obligations from Sep 14-30, 2026 were modifications on contracts the recipient already held. The other two are base delivery orders, TriWest at $1.20B and Clark Construction at $332M, and both sit on a parent vehicle.
The last 17 days of FY2026 obligated $43.25B. That is 78% of September.
It was not a wave of new competitions. Of the 12 largest obligations in that window, 10 are modifications on contracts the company already held. The other two are base delivery orders on a parent vehicle. If you were not the incumbent, and you were not on the vehicle, you could not have bid any of them that week.
Look up the Clark task order · September, the full month · FY2027 contracts you can still bid
The 12 largest checks, Sep 14-30
Transaction obligation, not the lifetime value of the contract. Sorted by the dollars obligated on that action. Source: USASpending spending_by_transaction, pulled Oct 3, 2026.
| Obligated | Date | Recipient | Agency | NAICS | Mod | Kind | What it is | PIID |
|---|---|---|---|---|---|---|---|---|
| $1.20B | Sep 23 | TriWest Healthcare Alliance | VA | 524114 | 0 | Base delivery order | August 2026 express report | 36C10G26K0300 |
| $547.3M | Sep 24 | AMI Metals | CBP | 541614 | P00004 | Modification | Option: 200,000 tons of steel | 70B01C26C00000006 |
| $519.4M | Sep 18 | SpaceX | NASA | 336414 | 72 | Modification | Commercial crew, additional work | NNK17MA01T |
| $507.9M | Sep 17 | Bechtel National | Energy | 234930 | 627 | Modification | Funding only | DEAC2701RV14136 |
| $482.0M | Sep 30 | TOTE Services | MARAD | 336611 | P00001 | Modification | Deliver NSMV VI | 693JF726F00030N |
| $445.9M | Sep 29 | PCL Construction | State (IBWC) | 237110 | P00012 | Modification | Progressive design-build, within scope | 191BWC24C0008 |
| $439.9M | Sep 17 | Oracle Health | VA | 541512 | P00021 | Modification | VISN 15 EHRM deployments | 36C10B22N0051EHRM |
| $420.4M | Sep 25 | General Atomics Aeronautical | CBP | 488190 | P00036 | Modification | UAS operations and maintenance | 70B02C22C00000016 |
| $401.6M | Sep 30 | Maximus Federal | CMS | 561422 | P00032 | Modification | Contact center, funding only | 75FCMC22C0038 |
| $342.2M | Sep 30 | Leidos Biomedical Research | NIH | 541715 | P00014 | Modification | NCI task order, FY26-FY27 | 75N91025F00016 |
| $332.0M | Sep 26 | Clark Construction | CBP | 236220 | 0 | Base delivery order | Design-build, Laredo, Texas | 70B01C26F00000874 |
| $311.4M | Sep 22 | Frequentis USA | FAA | 334210 | P00009 | Modification | Project LIFT voice-switch modernization | 693KA825C00011 |
"What it is" is the agency's own transaction description, shortened. Click the PIID to see the award.
The two new actions are still not open bids
TriWest, $1.20B, mod 0. The description is "Express report: August 2026." NAICS 524114 is direct health and medical insurance. The order sits under parent vehicle 36C10G19D0038. A new firm could not have proposed on an August report against a vehicle it does not hold.
Clark, $332.0M, mod 0. This one is real construction: a design-build task order in Laredo, Texas, NAICS 236220. It is also a task order. The parent IDIQ is 70B01C26D00000021. No seat on that vehicle, no bid.
CBP wrote $5.39B, and the close was incumbents
DHS was the largest civilian buyer in September at $11.36B. Customs and Border Protection was $5.39B of it. Three of the 12 checks above are CBP, and they show the pattern in one bureau:
ICE obligated $1.43B in September and Coast Guard $1.40B. Neither bureau placed a check in this top 12. Their September was a lot of smaller actions, which is a different capture problem than losing one $500M option.
What to do if one of these is your target
Caveats
Related: September, final, $55.26B · FY2027 by NAICS · Score a recompete
Related Guides
More from the Federal Spending Trends FY2026 series