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    Subject Term: "Defense contractors"

    3 publications with a total of 10 open recommendations including 1 priority recommendation
    Director: Marie A. Mak
    Phone: (202) 512-4841

    3 open recommendations
    Recommendation: To provide greater compliance with the GIDEP reporting requirement among the DOD components and their defense supplier-base, the Undersecretary of Defense for Acquisition, Technology and Logistics should establish mechanisms for department-wide oversight of defense agencies' compliance with the GIDEP reporting requirement.

    Agency: Department of Defense: Office of the Secretary of Defense: Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics
    Status: Open

    Comments: In providing comments to this report DOD concurred with this recommendation but has not completed actions to implement it. DOD stated that it will issue new DOD Instruction covering the use of GIDEP, as well as a companion DOD manual, to include identification of roles and responsibilities for submission of reports and oversight of such submission. Both documents are expected to be completed by the end of the second quarter fiscal year 2018.
    Recommendation: To provide greater compliance with the GIDEP reporting requirement among the DOD components and their defense supplier-base, the Undersecretary of Defense for Acquisition, Technology and Logistics should develop a standardized process for determining the level of evidence needed to report a part as suspect counterfeit in GIDEP, such as a tiered reporting structure in GIDEP that provides an indication of where the suspect part is in the process of being assessed.

    Agency: Department of Defense: Office of the Secretary of Defense: Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics
    Status: Open

    Comments: In providing comments to this report DOD concurred with this recommendation but has not completed actions to implement it. DOD stated that it will issue new DOD Instruction covering the use of GIDEP, as well as a companion DOD manual, to include identification of roles and responsibilities for submission of reports and oversight of such submission. Both documents are expected to be completed by the end of the second quarter of fiscal year 2018.
    Recommendation: To provide greater compliance with the GIDEP reporting requirement among the DOD components and their defense supplier-base, the Undersecretary of Defense for Acquisition, Technology and Logistics should develop guidance for when access to GIDEP reports should be limited to only government users or made available to industry.

    Agency: Department of Defense: Office of the Secretary of Defense: Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics
    Status: Open

    Comments: In providing comments to this report DOD concurred with this recommendation but has not completed actions to implement it. DOD stated that it will issue new DOD Instruction covering the use of GIDEP, as well as a companion DOD manual, to include identification of roles and responsibilities for submission of reports and oversight of such submission. Both documents are expected to be completed by the end of the second quarter of fiscal year 2018.
    Director: Cary Russell
    Phone: (202) 512-5431

    6 open recommendations
    including 1 priority recommendation
    Recommendation: To enable AFRICOM's component commands to better plan, advise, and coordinate for OCS, the AFRICOM Commander, as part of AFRICOM's ongoing efforts to update related guidance and emphasize the importance of OCS integration at the subordinate command level, should direct the service components to designate elements within their respective staffs to be responsible for coordinating OCS, and consider the establishment of an OCS Integration Cell or similar structure with these dedicated OCS personnel, as needed.

    Agency: Department of Defense: U.S. Africa Command
    Status: Open

    Comments: In July 2016, AFRICOM officials stated that there are clear advantages and benefits to establishing an OCSIC at Service-component level. USAFRICOM, as a geographic combatant command, assigns operational missions to subordinate commands for execution, including operational contract support (OCS) tasks. Joint Pub 4-10, as augmented by AFRICOM Command Instruction (ACI) 4800.01 A, specifies the tasks and functions in support of OCS that Service Components must execute. Service Components determine the most appropriate organizational structure best suited to meet its assigned mission. i.e. establishment of an OCSlC as deemed necessary. However, service components have indicated that guidance clarifying the circumstances under which they should establish OCSICs would be helpful. As such, this recommendation will remain open at this time.
    Recommendation: To enable AFRICOM's component commands to better plan, advise, and coordinate for OCS, the AFRICOM Commander, as part of AFRICOM's ongoing efforts to update related guidance and emphasize the importance of OCS integration at the subordinate command level, should clarify under what conditions a subordinate joint force command, such as Combined Joint Task Force-Horn of Africa, should establish an OCS Integration Cell.

    Agency: Department of Defense: U.S. Africa Command
    Status: Open

    Comments: AFRICOM officials told us that USAFRICOM J4 conducted a staff assistance visit (SA V) at CJTF-HOA from 16-19 August 2015. It was recommended that ClTF-HOA establish an OCS Working Group (OCSWG) that is owned b) the ClTF-HOA J4. The OCSWG is a doctrinal working group and would contain designated cross-functional staff members to enable OCS planning and policy generation as well as Oversee contractor management issues. Other OCS recommendations were made to the CJTF-HOA J4 that included adding permanent OCS billets to the J4 and executing OCSIC tasks. This recommendation will remain open at this time.
    Recommendation: To enable AFRICOM to better identify, address, and mitigate OCS readiness gaps at its component commands before inaccurate information is incorporated into formal defense readiness reporting systems, the AFRICOM Commander should clarify the scorecard process, including assessment standards, for OCS Readiness Scorecards to ensure that evaluators can accurately assess subordinate commands' OCS capabilities.

    Agency: Department of Defense: U.S. Africa Command
    Status: Open

    Comments: In July 2016, AFRICOM officials stated that while the OCS score card may be considered a best practice in the OCS execution in the AFRICOM AOR, it is not a replacement for the Defense Readiness Reporting System (DRRS) to report OCS. This recommendation will remain open at this time.
    Recommendation: To enable AFRICOM to comprehensively and consistently account for contractor personnel in Africa, the Secretary of Defense, in coordination with the Chairman of the Joint Chiefs of Staff, should direct Joint Staff to clarify what types of contractor personnel should be accounted for in its guidance on personnel status reports.

    Agency: Department of Defense
    Status: Open

    Comments: DOD has taken steps to clarify what types of contractor personnel should be accounted for in its guidance on personnel status reports, but revision of that guidance is ongoing. According to Joint Staff officials in August 2016, USAFRICOM has not yet incorporated its local policies and standards into the CJCSM 3150.13C as the manual is up for review by the Joint Staff and is projected to be completed by Spring 2017. Additionally, in February 2016, a class deviation became effective for the USAFRICOM area of responsibility (AOR). This deviation superseded Class Deviations 2014-O0005, and 2015-O0003. The deviation stated that contracting officers shall incorporate clause 252.225-7980, Contractor Personnel Performing in the United States Africa Command Area of Responsibility, in lieu of the clause at DFARS 252.225-7040, Contractor Personnel Supporting U.S. Armed Forces Deployed Outside the United States, in all solicitations and contracts, including solicitations and contracts using FAR part 12 procedures for the acquisition of commercial items that will require contractor personnel to perform in the United States Africa Command (USAFRICOM) area of responsibility. In addition, to the extent practicable, contracting officers shall modify current, active contracts with performance in the USAFRICOM AOR to include the clause 252.225-7980. The USAFRICOM Commander has identified a need to utilize the Synchronized Pre-deployment and Operational Tracker for all contracts performed in the AOR during all operational phases (including Phase 0), not limited to declared contingency operations. However, until guidance clarifying what types of contractor personnel is finalized, this recommendation will remain open.
    Recommendation: To enable AFRICOM to comprehensively and consistently account for contractor personnel in Africa, the AFRICOM Commander should develop area of responsibility-wide contractor personnel accountability guidance on or before December 2015, when the current guidance expires, that clarifies which types of contractor personnel should be accounted for using SPOT, and when SPOT accountability requirements should be incorporated into contracts.

    Agency: Department of Defense: U.S. Africa Command
    Status: Open

    Comments: In July 2016, AFRICOM officials told us Defense Federal Acquisition Regulation Supplement (DFARS) 252.225-7980 (Class Deviation 2016-00008), Contractor Personnel Performing in the United States Africa Command Area of Responsibility was published in June 2016. This clause requires the use of the Synchronized Pre-Deployment and Operational Tracker (SPOT) to account for all Contractor Authorized to Accompany the Force (CAAF), United States and third-country national contractors (TCNs), all private security contractors. and all other contractor personnel authorized to carry weapons when performing in the AFRICOM AOR on all DoD contracts, regardless of the contract amount or period of performance. Furthermore. the DoD contractor is required to submit to the cognizant contracting officer for SPOT reporting and aggregate count of all local national employees performing in the AFRICOM AOR. by country of performance, for 30 days or longer under a contract valued at or above $150.000. This recommendation will remain open at this time.
    Recommendation: To ensure that combatant commands are not contracting with entities that may be connected to or supporting prohibited organizations, the Secretary of Defense, in coordination with the Chairman of the Joint Chiefs of Staff, should develop guidance that clarifies the conditions under which combatant commands should have a foreign vendor vetting process or cell in place to determine whether potential vendors actively support any terrorist, criminal, or other sanctioned organizations, including clarifying when combatant commands should develop procedures for transmitting the names of any vendors identified through this process for inclusion in prohibited entities lists in the appropriate federal contracting databases, such as the System for Award Management.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: As of October 2016, DOD has taken steps to develop foreign vendor vetting guidance, but that guidance is in the process of being drafted. According to Joint Staff officials in August 2016, as required by NDAA for FY2015, Section 841(d)(1), the Director, Defense Procurement & Acquisition Policy, issued Class Deviation 2015-O0016, Prohibition on Providing Funds to the Enemy and Authorization of Additional Access to Records, effective September 15, 2015. Also, Joint Staff has drafted a Directive Type Memorandum (DTM)on foreign vendor vetting. When issued, the DTM will assign responsibility to each of the Combatant Commanders to establish a foreign vendor program in their respective Areas of Responsibility in accordance with NDAA for FY2015, Sections 841, 842 and 843. However, until the DTM is issued, this recommendation will remain open.
    Director: Timothy J. DiNapoli
    Phone: (202) 512-4841

    1 open recommendations
    Recommendation: To maximize the potential value of the MPNDI pilot program, the Under Secretary of Defense for Acquisition, Technology and Logistics should identify whether there are opportunities to test flexibilities or streamlined procedures that are not otherwise available under existing authorities.

    Agency: Department of Defense: Office of the Under Secretary of Defense for Acquisition, Technology and Logistics
    Status: Open

    Comments: Congress expanded the applicability of the pilot program in Section 892 of the National Defense Authorization Act for Fiscal Year 2016. DOD has not yet identified if opportunities exist to test flexibilities or streamlined procedures that are not otherwise available under existing authorities, including under the expanded pilot program.