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Before the Subcommittee on Defense, Committee on Appropriations, House 
of Representatives: 

United States Government Accountability Office: 

For Release on Delivery: 
Expected at 1:30 p.m. EDT:
Wednesday, March 17, 2010: 

Warfighter Support: 

Continued Actions Needed by DOD to Improve and Institutionalize 
Contractor Support in Contingency Operations: 

Statement of William M. Solis, Director:
Defense Capabilities and Management: 


GAO Highlights: 

Highlights of GAO-10-551T, a testimony before the Subcommittee on 
Defense, Committee on Appropriations, House of Representatives. 

Why GAO Did This Study: 

The Department of Defense (DOD) relies greatly on contractors to 
support its current operations and is likely to continue to depend on 
contractors in support of future operations. As of December 2009, DOD 
estimated that over 207,000 contractor personnel were supporting 
operations in Iraq and Afghanistan. DOD expects to increase the number 
of contractors as more troops deploy to Afghanistan. The use of 
contractors in contingencies has challenged DOD in overseeing and 
managing contractors. 

This testimony addresses (1) the challenges DOD faces when trying to 
provide management and oversight of contractors in Iraq and 
Afghanistan, and (2) the extent to which DOD has made progress in 
institutionalizing a department-wide approach to managing and 
overseeing operational contract support. 

Today’s testimony is based on GAO’s ongoing audit work in Iraq and 
Afghanistan, looking at planning for operational contract support and 
at DOD’s efforts to manage and oversee contractors, as well as on 
recently published related GAO reports and testimonies. 

What GAO Found: 

DOD continues to face a number of challenges overseeing and managing 
contractors in ongoing operations. These challenges include: 

* Providing an adequate number of personnel to conduct oversight and 
management of contractors. 

* Training personnel, including non-acquisition personnel such as unit 
commanders, on how to work effectively with contractors in operations. 

* Ensuring that local and third-country nationals have been properly 
screened, given the lack of standardized documents, the lack of 
national police agencies in many countries, and poor record keeping in 
many countries. 

* Compiling reliable data on the number of contractor personnel 
supporting U.S. forces in contingencies. 

* Identifying requirements for contractor support in ongoing 
operations, although GAO notes that some steps have been taken at the 
individual unit level. 

GAO has made many recommendations in the past aimed at addressing each 
of these challenges. While DOD has implemented some of our 
recommendations, it has been slow to implement others. For example, 
DOD has not developed agency-wide procedures to screen foreign 
national contractor personnel. In addition, the department has not 
fully addressed congressional direction to include operational 
contract support in predeployment training. Until DOD has fully 
implemented GAO’s recommendations and congressional direction, it will 
not be in a position to ensure adequate management and oversight of 
contractors in contingency operations. Furthermore, inattention to 
these challenges may negatively affect the military’s mission through 
the inefficient use of personnel, may increase the risk to U.S. 
personnel through inadequate background screenings, and may result in 
increased waste of taxpayer dollars. 

While DOD has taken some actions to institutionalize operational 
contract support, significant work remains to be done. For example, in 
2006 DOD established the Assistant Deputy Under Secretary of Defense 
(Program Support) to act as a focal point for DOD’s efforts to improve 
contract management and oversight at deployed locations. In addition, 
the department has issued a variety of contractor-related guidance, 
including the Joint Contingency Contracting Handbook and a Joint 
Publication that establishes doctrine for operational contract 
support; however, other guidance, including an Expeditionary 
Contracting Policy and an update of the DOD Instruction on Contractors 
Accompanying the Force, has yet to be finalized. Our ongoing work has 
also shown that the department continues to face challenges 
identifying contractor requirements in its plans for future 
operations. Until DOD institutionalizes operational contract support 
by incorporating it into its guidance, training, and planning, the 
department may continue to confront the challenges it faces in Iraq 
and Afghanistan in future operations. 

View [hyperlink,] or key 
components. For more information, contact William Solis, 202-512-8365, 

[End of section] 

Mr. Chairman and Members of the Committee: 

I appreciate the opportunity to be here today to discuss a number of 
issues regarding the oversight and management of contracts used to 
support U.S. forces in contingency operations, which constitute a key 
portion of the broader issues the department refers to as operational 
contract support.[Footnote 1] As you know, the Department of Defense 
(DOD) relies greatly on contractors to support its missions and 
operations, due in part to such factors as the reductions in DOD's 
civilian and military personnel following the collapse of the Soviet 
Union, the increasing complexity of weapons systems, and more 
recently, the increased demands related to overseas contingency 
operations, such as the need for large numbers of Arabic speakers. DOD 
officials have stated that without a significant increase in its 
civilian and military workforce, the department is likely to continue 
to rely on contractors both in the United States and overseas in 
support of future deployments. For example, the Deputy Under Secretary 
of Defense for Logistics and Materiel Readiness testified in 2008 that 
the structure of the U.S. military had been adapted to an environment 
in which contractors were an indispensable part of the force. In that 
regard, DOD estimates that more than 207,000 contractor personnel were 
supporting operations in Iraq and Afghanistan as of December 2009, and 
DOD anticipates that this number will grow as the department increases 
its troop presence in Afghanistan. 

Congress has enacted legislation requiring DOD to take specific 
actions to improve its management and oversight of contractors in 
contingencies, such as (1) improving contractor accountability; (2) 
developing joint policies for requirements definition, contingency 
program management, and contingency contracting during combat and post-
conflict operations; and (3) developing policies and procedures for 
the use of private security contractors in contingency operations. Our 
previous work has highlighted long-standing problems regarding the 
oversight and management of contractors supporting deployed forces. 
Since the advent of our work on contractor support to deployed forces 
in 1997, we have made many recommendations to improve DOD's management 
of contractors in deployed locations.[Footnote 2] While the department 
has implemented some of our recommendations, it has been to slow to 
implement others, including those recommendations related to 
operational contract support training for commanders and other 
personnel responsible for the management and oversight of contractors. 
Further, in part because of the lack of an adequate number of trained 
acquisition and contract oversight personnel, GAO has designated DOD 
contract management as a high-risk area. 

The government contracting process consists of three phases: contract 
planning, contract formation, and contract management. The contract 
planning phase includes requirements determination, in which specific 
requirements and specifications for contracted products and services 
are identified and validated. The contract formulation phase typically 
involves solicitation and evaluation of offers and the award of a 
contract. Finally, the contract management phase begins after the 
contract is awarded. Post-award activities include contract oversight 
and management, contract completion and close-out activities. The 
contracting process is governed by contracting laws, rules, and 
guidance, such as the Federal Acquisition Regulation, as well as 
specific policies established by DOD on how to administer and manage 
contracts that support contingency operations, such as Joint 
Publication 4-10 and DOD Instruction 3020.41. DOD has acknowledged 
shortcomings in how the role of contractors was addressed in its 
planning for Iraq and Afghanistan, and has taken some recent actions 
to improve contracting and issue guidance. 

In view of this, my statement today will focus on (1) the challenges 
DOD faces when trying to provide management and oversight of 
contractors in Iraq and Afghanistan; and (2) the extent to which DOD 
has made progress in institutionalizing a department-wide approach to 
managing and overseeing operational contract support. I will conclude 
with some observations about further actions the department could take 
to improve its use of contractors in contingency operations. My 
statement is based on recently published related reports and 
testimonies and reflects preliminary observations drawn from ongoing 
work looking at planning for operational contract support and the 
department's efforts to manage and oversee contractors in Afghanistan 
and Iraq. Our work was conducted in accordance with generally accepted 
government auditing standards.[Footnote 3] 


The U.S. military has long used contractors to provide supplies and 
services to deployed U.S. forces, and more recently contractors have 
been involved in every major military operation since the 1991 Gulf 
War. However, the scale of contractor support DOD relies on today in 
Iraq and throughout Southwest Asia has increased considerably from 
what DOD relied on during previous military operations, such as 
Operations Desert Shield/Desert Storm and those in the Balkans. At the 
end of the first quarter of fiscal year 2010, DOD estimated the number 
of contractors in Iraq to be about 100,000 and the number in 
Afghanistan about 107,000. In both Iraq and Afghanistan, U.S. citizens 
constitute a minority of the total contractor workforce. In Iraq, 
approximately 72,000 contractors are third country or Iraqi nationals, 
and in Afghanistan approximately 81,000 contractors, or 75 percent, 
are Afghan nationals. However, these numbers do not reflect the 
thousands of contractors in Kuwait and elsewhere who support 
operations in Iraq and Afghanistan. By way of contrast, an estimated 
9,200 contractor personnel supported military operations in the 1991 
Gulf War. Factors that have contributed to the increase include 
reductions in the size of the military, an increase in the number of 
operations and missions undertaken, and DOD's use of increasingly 
sophisticated weapons systems. 

DOD uses contractors to meet many of its logistical and operational 
support needs during combat operations, peacekeeping missions, and 
humanitarian assistance missions. Today, contractors located 
throughout the Middle East and Southwest Asia provide U.S. forces with 
such services as linguistic support, equipment maintenance, base 
operations support, and security support. In Iraq and Afghanistan, 
contractors provide deployed U.S. forces with communication services; 
interpreters who accompany military patrols; base operations support 
(e.g., food and housing); weapons systems maintenance; intelligence 
analysis; and a variety of other types of support. Contractors provide 
logistics support that includes parts and equipment distribution, 
ammunition accountability and control, port support activities, and 
support to weapons systems and tactical vehicles. For example, in 
Kuwait, Iraq, Qatar, and Afghanistan, the Army uses contractors to 
refurbish, repair, and return to the warfighters a variety of military 

Oversight of contracts--which can refer to contract administration 
functions, quality assurance surveillance, corrective action, property 
administration, and past performance evaluation--ultimately rests with 
the contracting officer, who has the responsibility for ensuring that 
contractors meet the requirements as set forth in the contract. 
Frequently, however, contracting officers are not located in the 
contingency area or at the installations where the services are being 
provided. As a result, contracting officers appoint contract monitors, 
who are responsible for monitoring contractor performance. For some 
contracts, such as LOGCAP,[Footnote 4] AFCAP,[Footnote 5] or theater- 
wide service contracts like the Afghan trucking contract, contracting 
officers may delegate contract oversight to the Defense Contract 
Management Agency (DCMA) to monitor contractor performance. In Iraq 
and Afghanistan, these teams include administrative contracting 
officers, who direct the contractor to perform work, and quality 
assurance representatives, who ensure that the contractors perform 
work to the standards written in the contracts and oversee the 
Contracting Officer's Representatives (CORs) assigned to DCMA-
administered contracts.[Footnote 6] The DCMA team also includes 
property administrators and subject matter experts who advise the 
agency on technical issues such as food service, electrical 
engineering, and air traffic control procedures.[Footnote 7] These 
subject matter experts augment the DCMA staff and provide expertise 
not inherent to DCMA's workforce and normally outside of DCMA's core 
competency area of oversight responsibilities. Unless the contracting 
officer delegates the administrative contract management and oversight 
functions to DCMA, the contracting officer is responsible for the 
administrative oversight and management of the contract. 

Regardless of whether or not DCMA provides administrative oversight of 
a contract, contracting officers generally appoint CORs. These 
individuals provide much of the day-to-day oversight of a contract 
during a contingency operation. They are typically drawn from units 
receiving contractor-provided services, they are not normally 
contracting specialists, and often their service as contracting 
officer's representatives is an additional duty. They cannot direct 
the contractor by making commitments or changes that affect price, 
quality, quantity, delivery, or other terms and conditions of the 
contract. Instead, they act as the eyes and ears of the contracting 
officer and serve as the liaison between the contractor and the 
contracting officer. In Iraq and Afghanistan, CORs who have been 
appointed as contracting officer's representatives for contracts 
administered by DCMA report their oversight results to DCMA personnel. 
For contracts not administered by DCMA, CORs provide oversight 
information to the contracting officer, who may be located in Iraq, 
Afghanistan, or outside the theater of operations. 

DOD guidance requires that trained CORs be appointed prior to the 
award of a service contract. In Iraq and Afghanistan, the Joint 
Contracting Command requires that its contracting officers appoint 
CORs for all contracts valued at more than $2,500 and having 
significant technical requirements that require on-going advice and 
surveillance from technical/requirements personnel. The contracting 
officer may exempt service contracts from this requirement when the 
following three conditions are all met: 

1. The contract is awarded using simplified acquisition procedures; 

2. The requirement is not complex; and: 

3. The contracting officer documents the file, in writing, as to why 
the appointment of a COR is unnecessary. 

DOD Continues to Face Challenges in Providing Management and Oversight 
of Contractors in Ongoing Operations: 

Based on preliminary observations from our ongoing work in Iraq and 
Afghanistan, we found that DOD continues to be faced with five 
challenges related to providing management and oversight of 
contractors in ongoing operations. First, DOD continues to be 
challenged in having an adequate number of personnel to provide 
oversight and management of contracts. While DOD has acknowledged 
shortages of personnel and has made some efforts to address them, 
these efforts are in the early stages of implementation. Second, 
training non-acquisition personnel such as CORs and unit commanders to 
work with contractors continues to be a problem. For example, we found 
some instances in which a lack of training raised concerns over the 
potential risk of military commanders directing contractors to perform 
work outside the scope of the contract--something commanders lack the 
authority to do. Third, DOD continues to face badging and screening 
challenges, particularly of local national and third-country national 
contractor personnel. Fourth, DOD lacks reliable tracking data on 
contractor personnel in Iraq and Afghanistan. Fifth, DOD faces 
challenges in identifying its operational contract support 
requirements for ongoing operations in Iraq and Afghanistan. For 
instance, officials from U.S. Forces-Afghanistan's logistics staff 
appeared to be unaware of their responsibility as defined by DOD 
guidance to identify contractor requirements or develop the contract 
management and support plans required by guidance. 

Challenges in Providing an Adequate Number of Contract Oversight and 
Management Personnel in Deployed Locations Are Likely to Continue to 
Hinder DOD's Oversight of Contractors: 

As we noted in several of our previous reports, having the right 
people with the right skills to oversee contractor performance is 
crucial to ensuring that DOD receives the best value for the billions 
of dollars spent on contractor-provided services supporting 
contingency operations. Additionally, as our previous work has shown, 
poor contract oversight and the poor contractor performance that may 
result can negatively affect the military's mission. Although we could 
find no DOD guidelines regarding the appropriate number of personnel 
needed to oversee and manage DOD contracts at a deployed location, 
several reviews by GAO and DOD organizations have consistently found 
significant deficiencies in DOD's oversight of contractors due to 
having an inadequate number of personnel to carry out these duties. In 
2004,[Footnote 8] 2006,[Footnote 9] and again in 2008,[Footnote 10] we 
reported on DOD's inability to provide an adequate number of oversight 
personnel in CENTCOM's theater of operation, and our ongoing work in 
Afghanistan and Iraq demonstrates that this problem has not been 
resolved. For example, 

* During our December 2009 trip to Afghanistan, officials at a 
contracting command told us that their workload required them to 
devote all their efforts to awarding contracts, and as a result they 
could not provide contract oversight. 

* During that same trip, the commander of a maintenance battalion in 
Afghanistan expressed concern over having an inadequate number of 
personnel available to provide oversight of a key maintenance contract 
used to support the increase of troops in Afghanistan. He noted that 
the lack of sufficient quality assurance personnel and technical 
experts was an identified problem they were working to correct, but 
that the additional civilian personnel were slow to arrive. 
Furthermore, he expressed concern that the expanding U.S. mission in 
Afghanistan would require additional technical experts and quality 
assurance personnel to oversee the increased number of contractors 
expected to be needed to support the increased vehicle maintenance and 
repair requirements. 

* In preliminary findings concerning the drawdown of forces from Iraq, 
we noted that an Army unit in Kuwait that was responsible for ensuring 
the steady flow of equipment out of Kuwait and for conducting certain 
maintenance tasks had 32 government personnel to provide oversight for 
more than 3,000 contractor personnel. In January 2010, Army Materiel 
Command requested funding to double to approximately 800 the number of 
this unit's contractor personnel assigned to conduct retrograde- 
specific tasks--for example, receiving, accounting for, sorting, and 
moving equipment--necessary to prevent equipment backlogs in Kuwait. 
In July 2009 this unit identified the lack of oversight personnel as a 
significant concern with respect to successfully moving equipment out 
of Kuwait. According to contracting officials, the unit had requested 
an increase in civilian oversight personnel. However, we have 
previously reported on the Army's difficulties in filling civilian 
personnel vacancies in Kuwait.[Footnote 11] 

* In a June 2009 report, the Commission on Wartime Contracting in Iraq 
and Afghanistan found that DOD had insufficient logistics subject 
matter experts in Iraq and Afghanistan.[Footnote 12] In the 
department's response to the June 2009 report, DOD noted that DCMA had 
in March 2009 requested 57 subject matter experts for food, water, 
medical, fire, and petroleum services, but only 40 of the 57 positions 
had been filled. Furthermore, according to DCMA as of January 2010, 
only 19 of the 40 personnel had arrived in theater. During our 
December 2009 trip to Afghanistan, DCMA officials stressed to us the 
need for more subject matter experts, and they have requested an 
additional 47 subject matter experts, but officials do not know when 
these positions will be filled. To help mitigate the shortfall of 
subject matter experts, DCMA intends to use contractors to provide the 
needed expertise, according to DCMA officials. 

Since 2004, we and others have reported that DOD has a lack of 
contract oversight officials, including CORs, to provide contract 
oversight and management in contingency operations. During operations 
in Iraq and Afghanistan, the shortage of CORs has been particularly 
acute for DCMA-administered contracts. For example, in June 2009 DCMA 
had a requirement for 1,252 CORs in Iraq but had only 985 in place. 
Similarly, in June 2009 DCMA in Afghanistan had a COR requirement of 
576 but had less than half (or 253) of the needed CORs in place. In 
October 2009 DCMA announced a new risk-based approach toward assigning 
CORs. According to DCMA officials, it had been DCMA's policy that a 
COR would be designated for each contractor-provided service at the 
location of the service. According to DCMA officials and 
documentation, DCMA now recommends that units assign CORs only to key 
services--which they define as high-and medium-risk services that 
could put health, life, and safety at risk if not executed in a manner 
consistent with the contract. Examples of high-and medium-risk 
services include food service, power generation, and postal services. 
Services such as morale, welfare and recreation are considered low 
risk. Services that are not designated as "key services" do not 
require CORs, but are monitored on a quarterly basis by a quality 
assurance representative. Since implementing this policy, DCMA has 
reduced the requirement for CORs to oversee its contracts in Iraq from 
1,100 in October 2009 to 580 in January 2010, and DCMA officials in 
Iraq anticipate that they will be able to reduce the COR requirement 
further as they continue to designate additional services as low-risk. 
In January 2010 DCMA reported that it had 88 percent of its required 
CORs in place in Afghanistan. We have not evaluated the effectiveness 
of this risk-based management program at this time. 

In an effort to build economic capacity within Iraq and Afghanistan, 
Congress has authorized and DOD has developed programs to encourage 
the use of local contractor firms. However, these programs, the Iraq 
First Program and the Afghan First Program, further strain the 
availability of personnel to provide contract management and 
oversight. According to officials from the Joint Contracting Command-
Iraq/Afghanistan local national contractors frequently require more 
oversight than U.S. firms because they lack experience, have limited 
capacity, are frequently less capable then their U.S. counterparts, 
are unfamiliar with U.S. quality standards and expectations, and lack 
the quality control processes that U.S. firms have in place. For 
example, according to DOD officials, buildings constructed by Afghan 
contractors have had to be re-wired when the LOGCAP program assumed 
responsibility for them because the LOGCAP contractors responsible for 
maintenance lacked assurance that the electrical work was done 
correctly. Other officials described receiving poor quality office 
furniture, while still others noted that trucking companies contracted 
to move U.S. goods often failed to meet delivery schedules. Without a 
sufficient number of contract oversight personnel in place, including 
subject matter experts, DOD may not be able to obtain reasonable 
assurance that contractors are meeting their contract requirements 
efficiently and effectively at each location, and that health and 
safety concerns have been addressed. 

Actions to Improve Availability of Oversight Personnel: 

Several individual organizations or services within DOD have taken 
actions to help mitigate the problem of not having enough personnel to 
oversee and manage contractors in Afghanistan and Iraq. For example, 
the Army issued an Execution Order on CORs in December 2009. In the 
order, the Army Chief of Staff directed the commanders of deploying 
units to coordinate with the unit they will replace in theater to 
determine the number of CORs they will need to designate prior to 
deployment. The order states that if the commander is unable to 
determine specific COR requirements, each deploying brigade should 
designate and train 80 CORs prior to deployment. 

In addition, a deploying Marine Expeditionary Force has created an 
operational contracting support cell within the logistics element of 
its command headquarters. The members of the cell will assist 
subordinate units with contracting oversight and guidance on policy, 
and they will act as contracting liaisons to the Joint Contracting 
Command-Iraq/Afghanistan and as conduits to the regional contracting 
commands should any issue arise. The Marines were prompted to set up 
this cell by lessons learned from their deployment to Operation Iraqi 
Freedom, where problems arose as a result of a lack of expertise and 
personnel to help oversee and manage contractors. In addition, the 
Marine Expeditionary Force trained approximately 100 Marines as CORs 
prior to its deployment to Afghanistan this spring. While not all 
personnel have been designated as CORs for the upcoming deployment, 
all could be called upon to serve as CORs should the need arise. 

While we recognize the efforts DOD has under way to develop long-term 
plans intended to address its personnel shortages, the problems we 
have identified in the past continue. In previous reports we have 
recommended that DOD develop strategies to address its oversight 
problems, and noted that unless DOD takes steps to address its current 
shortages, the department will continue to be at risk with regard to 
its assurance that contractors are providing their required services 
in an effective and efficient manner. 

Training of CORs and Non-Acquisition Personnel, Such as Unit 
Commanders, to Provide Contract Oversight and Management Remains an 

Equally important as having enough CORs is having CORs who are 
properly trained to provide contract oversight. According to the Army 
Chief of Staff's Execution Order, the lack of personnel in theater who 
are sufficiently trained in COR responsibilities is hindering 
effective oversight and management of contracts in support of 
operations in Afghanistan and Iraq. In addition, a lack of CORs with 
the right skills can make it more difficult to resolve contractor 
performance issues. 

The Defense Federal Acquisition Regulation Supplement requires that 
CORs be qualified by training and experience commensurate with the 
responsibilities to be delegated to them. Specifically, DOD requires 
that potential CORs complete courses (which are available on line) 
that include training on specific COR duties, an awareness course on 
trafficking in persons to help combat this practice and ethics 
training. In 2006 we reported that individuals deployed without 
knowing that they would be assigned as CORs, thus precluding their 
ability to take the required training prior to deployment. Individuals 
we spoke with noted that it was difficult to set aside the time 
necessary to complete the training once they arrived in Iraq.[Footnote 
13] During our recent visit to Afghanistan we found that units 
continue to deploy without nominating CORs beforehand, and as a result 
the personnel assigned to serve as CORs have to take the required 
training upon arrival in theater. Because training is offered through 
online courses, staff officers at a combined joint command as well as 
at an Army sustainment command in Afghanistan told us that technical 
limitations, including a lack of bandwidth, make it difficult to 
access the training from Afghanistan. In November 2009 DOD 
acknowledged concerns regarding web-based COR training due to 
connectivity issues. 

We also found that although CORs and other oversight personnel are 
responsible for evaluating the technical aspects of a contractor's 
performance, these oversight personnel often lack the technical 
knowledge and training needed to effectively oversee certain 
contracts. For example, in Afghanistan, officials from various 
organizations expressed concern to us that there were not enough CORs 
trained in trades such as electrical wiring and plumbing to provide 
oversight over all the construction contracts, and that this problem 
will only worsen as the number of construction projects continues to 
grow. Also, in a November 2009 analysis, a DOD task force acknowledged 
the importance of having CORs with the right skills, noting that units 
nominating CORs should consider the technical aspects, monitoring 
frequency, and monetary value of the contract to ensure that CORs' 
subject matter expertise and availability are commensurate with the 

An additional, long-standing training challenge hindering management 
and oversight of contractors supporting deployed forces is the lack of 
training for military commanders and other non-acquisition personnel, 
such as senior leaders who need contractors to execute their mission. 
As we testified in 2008, limited or no pre-deployment training on the 
use of contractor support can cause a variety of problems for military 
commanders in a deployed location, such as being unable to adequately 
plan for the use of those contractors, or confusion regarding the 
military commanders' roles and responsibilities in managing and 
overseeing contractors.[Footnote 14] Currently, military commanders 
and other unit leaders are not required to complete operational 
contract support training prior to deployment.[Footnote 15] In 
Afghanistan we continued to find that some commanders had to be 
advised by contract oversight personnel that they had to provide 
certain support, such as housing, force protection, and meals to the 
contractors they were overseeing. In addition, having limited or no 
pre-deployment training for military commanders on the use of 
contractor support to deployed forces can result in confusion 
regarding their roles and responsibilities in managing and overseeing 
contractors. For example, we found some instances in which a lack of 
training raised concerns over the potential risk of military 
commanders directing contractors to perform work outside the scope of 
the contract--something commanders lack the authority to do. 

According to several contract oversight personnel, some commanders did 
not understand the command and control relationship between themselves 
and the contractor, and were unclear as to whether they could direct 
the contractor to perform work. Similarly, in a January 2010 
acquisition conference, DCMA noted as a challenge the education of 
unit commanders on working with contractors. These challenges include 
educating the commanders on the value of contractors as a force 
multiplier, the unit's role in providing oversight, and distinguishing 
between command and contractual authority. The commander of the 
operational contract support cell at a Marine Expeditionary Force 
headquarters noted that he considered educating commanders to be one 
of his key challenges as his unit prepared to deploy. Without a clear 
understanding of the command and control relationship for contractors, 
commanders and other key leaders run the risk of directing the 
contractor to perform work beyond what was called for in the contract. 
As Army guidance makes clear, when military commanders try to direct 
contractors to perform activities outside the scope of the contract, 
this can cause the government to incur additional charges because 
modifications would need to be made to the contract. In some cases, 
the direction may potentially result in a violation of competition 

While we continue to observe issues regarding training on the use of 
contractor support, initiatives have been taken to implement and 
emphasize enhanced training for contract management and oversight 
personnel. For example, the Army's December 2009 Execution Order 
directs the Army's Training and Doctrine Command to develop additional 
training, including training to familiarize CORs with LOGCAP. It also 
requires brigade commanders to identify and train individuals as CORs 
prior to deployment, and it requires that training scenarios for CORs 
be incorporated into mission rehearsal and mission readiness 
exercises. In an independent effort in Afghanistan, two sustainment 
units provided training that incorporated a set of contract-related 
scenarios prior to their deployment to Afghanistan. One of the units 
also sent an officer to the new 2-week Operational Contract Support 
course conducted by the Army Logistics Management College. Ninety 
soldiers from one of the units also attended COR training, either 
through the Defense Acquisition University or through equivalent 
training. In another example, one of the Marine Corps' expeditionary 
forces preparing to deploy to Afghanistan identified Marines who may 
have contract oversight roles in Afghanistan and brought in an 
instructor from the Defense Acquisition University to provide three 
sessions of COR training prior to their deployment. In addition, DCMA 
has begun reaching out to deploying units to provide them with pre-
deployment training on what to expect when they arrive in Afghanistan, 
particularly with regard to LOGCAP. Officials responsible for 
overseeing a contract for linguist services also stated that their 
CORs received contract-specific training prior to deployment. However, 
these efforts do not address the concerns about CORs lacking the 
technical skills required to provide oversight on more technical 
contracts, specifically construction-related contracts. While these 
training efforts are promising, they have been driven by individual 
services and units. 

We have been discussing the need for better pre-deployment training on 
the use of contractors to support deployed forces since the mid-1990s, 
and have accordingly made several recommendations that DOD improve its 
training. For example, in 2003 we recommended that DOD develop 
training courses for commanding officers and other senior leaders who 
are deploying to locations with contractor support, and in 2006 we 
expanded on our recommendation and recommended that operational 
contract support be included in professional military education and 
pre-deployment training. [Footnote 16]In both instances DOD agreed 
with our recommendations but has not fully implemented them. 
Furthermore, in 2008, Congress mandated that DOD policies provide for 
contingency contracting training for certain non-acquisition 
personnel, including operational commanders expected to have 
acquisition or contract oversight responsibilities.[Footnote 17] 
However, these policies have not yet been finalized, and consequently 
the training required has not been institutionalized throughout DOD. 
[Footnote 18] 

DOD Continues to Face Badging and Screening Challenges: 

In Iraq and Afghanistan military commanders and other military 
officials have expressed concerns about the risks that contractor 
personnel, particularly third country and local nationals, pose to 
U.S. forces due to limitations in the background screening process. In 
2006 we first reported on the challenges that DOD faced in ensuring 
that contractor personnel had been thoroughly screened and vetted. 
[Footnote 19] In July 2009 we reported that DOD had not developed 
department-wide procedures to screen local national and third-country 
national contractor personnel, in part because two offices within the 
department---that of the Under Secretary of Defense for Intelligence 
and that of the Under Secretary of Defense for Acquisition, 
Technology, and Logistics--could not agree on the level of detail that 
should be included in background screening for third country and local 
national employees, and therefore lacked assurance that all contractor 
personnel were properly screened. To resolve this issue we recommended 
that the Secretary of Defense designate a focal point at a 
sufficiently senior level and possessing the necessary authority to 
ensure that the appropriate offices in DOD coordinate, develop, and 
implement policies and procedures to conduct and adjudicate background 
screenings in a timely manner.[Footnote 20] 

DOD has still not developed a department-wide policy on how to screen 
local national and third-country national contractor personnel, and as 
a result it continues to face challenges in conducting background 
screening of these personnel. As we reported in July 2009, absent a 
DOD-wide policy, commanders develop their own standards and processes 
to ensure that contractor personnel have been screened. In Iraq, U.S. 
Forces-Iraq, the U.S. led military organization responsible for 
conducting the war in Iraq, has developed a command-wide policy for 
screening and badging contractors. However, in Afghanistan, U.S. 
Forces-Afghanistan (USFOR-A)[Footnote 21] has not established a 
command-wide policy for screening and badging contractors. Instead, 
each base is responsible for developing its own background screening 
and base access procedures, resulting in a variety of different 
procedures. Moreover, requirements differ between U.S. bases and NATO 
bases. The lack of guidance also affects the ability of force 
protection officials to determine the sufficiency of their background 
screening procedures. For example, at one base, force protection 
officials told us that while they require contractor personnel to 
provide valid background screening from their home countries, they had 
not received guidance on how to interpret those screenings, and did 
not know whether the screenings they received were valid or not. 
Officials stated that they rely on a biometric system, also used in 
Iraq, to screen local national and third-country national contractor 
personnel. However, as we reported in July 2009, the name-checks and 
biometric data collection associated with issuing badges rely 
primarily upon U.S.-based databases of criminal and terrorist 
information. In 2006, we reported that background checks that are 
reliant upon U.S.-based databases, such as the biometric system used 
in Iraq and Afghanistan, may not be effective in screening foreign 
nationals who have not lived or traveled to the U.S.[Footnote 22] 
Further, some DOD contracts require contractors to conduct background 
screenings of their personnel. In July 2009 we reported that contracts 
for private security services often contained unrealistic background 
screening requirements.[Footnote 23] For example, the requirements 
directed contractors to use data sources to which private firms may 
not have access, such as databases maintained by the Federal Bureau of 
Investigation and the Central Intelligence Agency. We continue to find 
that some DOD contracts include unrealistic background screening 
requirements similar to those identified in our July 2009 report. As 
we concluded in July 2009, without a coordinated DOD-wide effort to 
develop and implement standardized policies and procedures to ensure 
that contractor personnel--particularly local nationals and third- 
country nationals--have been screened, DOD cannot be assured that it 
has taken all reasonable steps to thoroughly screen contractor 
personnel and minimize any risks to the military posed by these 

DOD Lacks Reliable Data on the Number of Contractor Personnel in Iraq 
and Afghanistan: 

Since 2002, we have reported on the challenges faced by commanders and 
other leaders to obtain accurate information on the number of 
contractors and the services they are providing in contingencies and 
have made recommendations to improve DOD's ability to obtain 
contractor information. For example, in December 2006 we reported that 
commanders had limited visibility of contractors because information 
on the number of contractors at deployed locations or the services 
they provide was incomplete, unreliable, and not aggregated within any 
one DOD organization, a limitation that can inhibit planning, increase 
costs, and introduce unnecessary risks.[Footnote 24] Although DOD has 
recognized the need for commanders and other leaders to have reliable 
data on the number of contractors and the services they provide, DOD 
continues to face challenges in tracking contracts and contractor 
personnel in Iraq and Afghanistan. Absent complete and accurate 
information on contractors supporting contingency operations, the 
agencies are limited in their ability to develop a complete picture of 
their reliance on contractors, the tasks being performed, and their 
associated costs. Reliable and meaningful data on contractors and the 
services they provide are a starting point for agency discussions 
about when and how to effectively use contractors; support contractors 
in terms of housing, security, and other services; and ensure that 
contractors are properly managed and overseen. 

In January 2007, DOD designated the Synchronized Pre-deployment and 
Operational Tracker (SPOT) as its primary system for collecting data 
on contractor personnel deployed with U.S. forces, and it directed 
contractor firms to enter personnel data for contracts performed in 
Iraq and Afghanistan.[Footnote 25] The SPOT database is designed to 
provide accountability of contractor personnel by name, a summary of 
the services being provided, and information on government-provided 

Our reviews of SPOT have highlighted shortcomings in DOD's 
implementation of the system in Iraq and Afghanistan.[Footnote 26] 
Most important, we found that as a result of diverse interpretations 
as to which contractor personnel should be entered into the system, 
the information in SPOT does not present an accurate picture of the 
total number of contractor personnel in Iraq and Afghanistan. For 
example, in Iraq, DOD officials stated that the primary determinant of 
whether contractor personnel were entered into SPOT was a contractor's 
need or lack of need for a SPOT-generated letter of authorization. 
Contractor personnel need SPOT-generated letters of authorization to, 
among other things, enter Iraq, receive military identification cards, 
travel on U.S. military aircraft, or, for security contractors, 
receive approval to carry weapons.[Footnote 27] However, not all 
contractor personnel in Iraq, and particularly local nationals, need 
letters of authorization, and agency officials informed us that such 
personnel were not being entered into SPOT. Similarly, officials with 
one contracting office in Afghanistan stated that the need for a 
letter of authorization determined whether someone was entered into 
SPOT, resulting in Afghans not being entered. However, officials from 
another office stated that office was following DOD's 2007 guidance 
[Footnote 28] on the use of SPOT and entering local nationals into the 

Because of the varying practices for entering personnel into SPOT, 
there are inconsistencies and gaps in the data generated by the 
system. For example, while DOD officials expressed confidence that the 
SPOT data were relatively complete for contractor personnel who need a 
letter of authorization, they acknowledged that SPOT does not fully 
reflect the number of local nationals working on contracts. Tracking 
local nationals in SPOT presents particular challenges because their 
numbers tend to fluctuate due to the use of day laborers, and because 
local firms do not always keep track of the individuals working on 
their projects. DOD officials also explained that they have had to 
develop workarounds to get around the SPOT requirement of a first and 
last name to be entered for each individual, along with a birth date 
and unique identification number. The officials noted that many Afghan 
laborers have only one name, do not know their birth dates, and lack 
identification numbers. 

Because of the short-comings of SPOT, DOD has conducted quarterly 
censuses to obtain information on the number of contractor personnel 
in Iraq and Afghanistan.[Footnote 29] DOD officials have regarded the 
census as the most complete source of contractor personnel data, but 
they acknowledged that the census numbers represent only a rough 
approximation of the actual number of contractor personnel working in 
either country. We found that census data were sometimes incomplete, 
while in other cases personnel were doubly counted.[Footnote 30] 
Because of these and related limitations, we determined that the 
census data should not be used to identify trends or draw conclusions 
about the number of contractor personnel in either Iraq or Afghanistan. 

Challenges in Identifying Operational Contract Support Requirements in 
Iraq and Afghanistan: 

DOD guidance highlights the need to plan for operational contract 
support early in an operations planning process because of the 
challenges associated with using contractors in contingencies. These 
challenges include overseeing and managing contractors in contingency 
operations. In previous reports and testimonies we have noted that DOD 
has not followed long-standing guidance on planning for operational 
contract support.[Footnote 31] Specifically, joint guidance calls for 
DOD to identify contract support requirements as early as possible, to 
ensure that the military receives contract support at the right place, 
at the right time, and for the right price. Other guidance directs the 
combatant commander or joint task force commander to identify 
operational contract support requirements as well as develop plans to 
obtain and manage contract support and include them in operation 
plans, operation orders, or fragmentary orders. Our preliminary 
observations from ongoing work continue to show that DOD has not fully 
planned for the use of contractors in support of ongoing contingency 
operations in Iraq and Afghanistan. 

On December 1, 2009, the President announced that an additional 30,000 
U.S. troops would be sent to Afghanistan to assist in the ongoing 
operations there, and the Congressional Research Service estimates 
that between 26,000 and 56,000 additional contractors may be needed to 
support the additional troops. However, during our December 2009 trip 
to Afghanistan, we found that only limited planning was being done 
with regard to contracts or contractors. Specifically, we found that 
with the exception of planning for the increased use of LOGCAP, USFOR-
A had not begun to consider the full range of contractor services that 
might be needed to support the planned increase of U.S. forces. More 
important, officials from USFOR-A's logistics staff appeared to be 
unaware of their responsibility as defined by DOD guidance to identify 
contractor requirements or develop the contract management and support 
plans required by guidance.[Footnote 32] However, we did find some 
planning being done by U.S. military officials at Regional Command- 
East. According to planners from Regional Command-East, the command 
had identified the types of units that are being deployed to their 
operational area of Afghanistan and was coordinating with similar 
units already in Afghanistan to determine what types of contract 
support the units relied on. Furthermore, according to operational 
contract support personnel associated with a Marine Expeditionary 
Force getting ready to deploy to Afghanistan, the staff offices within 
the Marine Expeditionary Force headquarters organization were directed 
to identify force structure gaps that could be filled by contractors 
prior to deployment and begin contracting for those services.[Footnote 
33] For example, one section responsible for civil affairs identified 
the need to supplement its staff with contractors possessing 
engineering expertise because the needed engineers were not available 
from the Navy. 

In addition, although U.S. Forces-Iraq[Footnote 34] has taken steps to 
identify all the LOGCAP support they will need for the drawdown, they 
have not identified the other contracted support they may need. 
According to DOD joint doctrine and service guidance, personnel who 
plan, support, and execute military operations must also determine the 
contracted support needed to accomplish their missions. Such personnel 
include combat force commanders, base commanders, and logistics 
personnel. In particular, these personnel are responsible for 
determining the best approach to accomplish their assigned tasks and-- 
if the approach includes contractors--identifying the types and levels 
of contracted support needed. Multi-National Force-Iraq's (MNF-I) 
drawdown plan, however, delegated the responsibility for determining 
contract support requirements to contracting agencies, such as the 
Joint Contracting Command-Iraq/Afghanistan, rather than to operational 
personnel. Joint Contracting Command-Iraq/Afghanistan officials told 
us, however, that they could not determine the theater-wide levels of 
contracted services required, or plan for mandated reductions based on 
those needs, because they lack sufficient, relevant information on 
future requirements for contracted services--information that should 
have been provided by operational personnel. For example, according to 
MNF-I documentation, during an October 2009 meeting between 
operational personnel and contracting officials, MNF-I reiterated that 
the levels of contracted service ultimately needed in Iraq during the 
drawdown were unknown. This is consistent with an overarching weakness 
identified by a Joint Staff task force, which recognized limited, if 
any, visibility of contractor support and plans, and a lack of 
requirements definition. As a result, rather than relying on 
information based on operationally driven requirements for contracted 
services, MNF-I planned for, and U.S. Forces-Iraq (USFOR-I) is 
subsequently tracking, the reduction of contracted support in Iraq 
using historical ratios of contractor personnel to servicemembers in 
Iraq, which may not accurately reflect the actual levels of contracted 
support needed during the drawdown. 

Insufficient planning may also lead to shortages in contractor 
personnel available to perform key functions affecting contractor 
responsiveness. For instance, during our December visit to 
Afghanistan, multiple DOD officials, including the commander of a 
base, told us that the current LOGCAP contractor had pulled many of 
its skilled workers off the job, which led to issues such as 
electrical problems that remained unresolved for longer than desired 
periods of time. Furthermore, a maintenance battalion commander told 
us that without the assistance of soldiers and civilian mechanics from 
the Red River Army Depot, the contractor would not have had enough 
personnel to maintain and repair the vehicles and equipment necessary 
to meet the mission. Additionally, in December 2009, an official from 
USFOR-A-South told us that in Kandahar military personnel were called 
upon to augment the operations of a supply facility because the 
contractor had not fully staffed the operation. In response to a DCMA 
letter of concern regarding contractor personnel shortages, the 
contractor agreed to have a full complement of contractor personnel in 
place by the middle of February 2010. 

Timely planning is critical to avoiding potential waste and ensuring 
that critical services are available when needed as the United States 
increases troops in Afghanistan and withdraws them from Iraq. In a 
January 2008 statement before Congress we again highlighted the need 
for the department to follow its long-standing planning guidance 
regarding the use of contractors to support deployed forces.[Footnote 
35] In that testimony we called upon DOD leadership to take steps to 
ensure compliance with existing guidance. Insufficient planning for 
requirements may lead to other poor outcomes, such as increased cost, 
lengthened schedules, underperformance, and delays in receiving 
services. We continue to believe that the department should take steps 
to ensure that it adheres to the guidance detailed in both joint and 
service publications. 

While DOD Has Taken Some Actions to Institutionalize Operational 
Contract Support, Much Remains to Be Done: 

In response to congressional direction and GAO recommendations, DOD 
has taken some actions to institutionalize operational contract 
support, however much remains to be done. The department has appointed 
a focal point to lead in these efforts, has issued some new guidance, 
and has begun to determine its reliance on contractors, but it has yet 
to finalize the policies required by Congress in the National Defense 
Authorization Acts for Fiscal Years 2007 and 2008. In addition, the 
department needs to take additional actions to improve its planning 
for operational contract support for future operations. 

DOD Has Taken Some Department-wide Steps to Institutionalize 
Operational Contract Support: 

In October 2006, the Deputy Under Secretary of Defense for Logistics 
and Materiel Readiness established the office of the Assistant Deputy 
Under Secretary of Defense (Program Support) to act as a focal point 
for leading DOD's efforts to improve contract management and oversight 
at deployed locations. That office has, for example established a 
community of practice for operational contract support comprising 
subject matter experts from the Office of the Secretary of Defense, 
the Joint Staff, and the services, and this community may be called 
upon to work on a specific task or project. Additionally, the office 
has established a Council of Colonels, which serves as a "gatekeeper" 
for initiatives, issues, or concepts, as well as a Joint Policy 
Development General Officer Steering Committee, which includes senior 
commissioned officers or civilians designated by the services. The 
committee's objective is to guide the development of Office of the 
Secretary of Defense, Joint Staff, and service policy, doctrine, and 
procedures to adequately reflect situational and legislative changes 
as they occur within operational contract support. The Program Support 
office is also developing an Operational Contract Support Concept of 
Operations, and it has provided the geographic combatant commanders 
with operational contract support planners to assist them in meeting 
contract planning requirements. 

To provide additional assistance to deployed forces, the department 
and the Army introduced several handbooks to improve contracting and 
contract management in deployed locations. For example, 

* In 2007 the department introduced the Joint Contingency Contracting 
Handbook, which provides tools, templates, and training that enable a 
contingency contracting officer to be effective in any contracting 
environment. The handbook also contains resources for contracting 
officers to promote uniform contracting practices, including 
standardized contract forms and language for terms and conditions The 
handbook is currently being updated and the department expects it to 
be issued in July 2010. 

* In 2008 the Army issued the Deployed Contracting Officer's 
Representative Handbook. This handbook provides the basic tools and 
knowledge needed for use in conjunction with formal COR training. The 
handbook was designed to address the realities that CORs face when 
operating outside the United States in a contingency operation. 

* Additionally in October 2008, the department issued Joint 
Publication 4-10, "Operational Contract Support," which establishes 
doctrine and provides standardized guidance for planning, conducting, 
and assessing operational contract support integration, contractor 
management functions, and contracting command and control 
organizational options in support of joint operations. 

Finally, in 2008, the Joint Staff (J-4), at the direction of the 
Chairman, undertook a study to determine how reliant the department 
was on contractors in Iraq. The intent of the study was to (1) better 
understand contracted capabilities in Iraq, to determine areas of high 
reliance or dependence; (2) determine where the department is most 
reliant, and in some cases dependent, on contractor support, to inform 
longer-term force structure and potential "buy back" implications; and 
(3) guide the development of future contingency planning and force 
development. According to the Joint Staff their initial findings 
suggest that in Iraq the department was highly dependent on 
contractors in four of the nine joint capability areas, including 
Logistics.[Footnote 36] For example, the study showed that in the 
third quarter of fiscal year 2008, over 150,000 contractors were 
providing logistical support, while slightly more than 31,000 military 
personnel were providing similar support. Having determined the level 
of dependency and reliance on contractors in Iraq, the Joint Staff 
plans to examine ways to improve operational contract support 
planning, including the development of tools, rules, and refinements 
to the existing planning process. 

DOD Has Yet to Finalize Operational Contract Support Guidance to Meet 
Congressional Direction: 

In 2006 Congress directed the Secretary of Defense, in consultation 
with the Chairman of the Joint Chiefs of Staff, to develop joint 
policies by April 2008 for requirements definition, contingency 
program management, and contingency contracting during combat and post-
conflict operations.[Footnote 37] In 2008, Congress amended this 
requirement by directing that the joint policies also provide for the 
training of military personnel outside the acquisition workforce who 
are expected to have acquisition responsibilities, including oversight 
of contracts or contractors during combat operations, post-conflict 
operations, and contingency operations.[Footnote 38] It also directed 
that GAO review DOD's joint policies and determine the extent to which 
those policies and the implementation of such policies comply with the 
statutory requirements. In November 2008 we reported that the 
department had yet to finalize several key documents designed to meet 
the requirements established by Congress.[Footnote 39] We also noted 
that DOD was developing an Expeditionary Contracting Policy to address 
the requirement to develop a joint policy on contingency contracting, 
and was revising the October 2005 version of DOD Instruction 3020.41, 
Contractor Personnel Authorized to Accompany the US Armed Forces, to 
meet the congressional direction to develop a joint policy on 
requirements definition; program management, including the oversight 
of contractor personnel supporting a contingency operation; and 
training. At the time of our 2008 report, the draft Instruction 
directed combatant commanders and service component commanders to 
conduct planning to identify military capability shortfalls that 
require acquisition solutions in commanders' operational plans, and 
combatant commanders to integrate operational contract support issues 
into training simulations, mission rehearsals, and exercises. The 
draft Instruction also directed the service to include requirements of 
the Instruction in their training. 

As of March 2010, the department had yet to issue either of these 
documents. According to the Assistant Deputy Under Secretary of 
Defense (Program Support), the revisions to DOD Instruction 3020.41 
have been held up in the review process. The current plan is to post 
the proposed revisions in the Federal Register and issue the revised 
instruction in the summer of 2010. Until the DOD instruction is 
revised and issued, the department's overarching policy document will 
not reflect the department's current approach to operational contract 
support. Furthermore, the provisions of the draft instruction that 
were intended to meet the congressional requirement for joint policy 
applicable to combatant commanders and the military services have not 
been established. Regarding the expeditionary contracting policy, the 
department has determined that it will not issue the expeditionary 
policy because the practitioners do not believe a joint policy is 

Plans for Future Operations Lack Information on Contractor Support 

DOD also faces challenges incorporating operational contract support 
issues in its operation plans for potential future contingencies. 
Since 2003, we have identified the need for the department to ensure 
that specific information on the use and roles of contract support to 
deployed forces is integrated into its plans for future contingency 
operations.[Footnote 40] DOD guidance has long recognized the need to 
include the role of contractors in operation plans and, since early 
2006, this guidance has required planners to include an operational 
contract support annex--known as Annex W--in the combatant commands' 
most detailed operation plans. Our ongoing work has found that the 
department has made some progress in both meeting this specific 
guidance and, more generally, in incorporating contract requirements 
in its operation plans. However, additional steps are needed to fully 
implement DOD guidance. 

First, we found that four operation plans with Annex Ws have been 
approved, and planners have drafted Annex Ws for an additional 30 
plans. However, according to combatant command officials, most of the 
annexes drafted to date restate broad language from existing DOD 
guidance on the use of contractors to support deployed forces and 
included few details on the type of contractors needed to execute a 
given plan--despite guidance requiring Annex Ws to list contracts 
likely to be used in theater. This was due to several factors, 
including a lack of information within the operation plans on matters 
such as the size and capabilities of the military force involved. 
According to combatant command planners, this information is needed to 
enable them to identify the details on contracted services and 
capabilities needed to support an operation. In addition, shortcomings 
in guidance on how and when to develop these annexes have resulted in 
a mismatch in expectations between senior DOD leadership and combatant 
command planners regarding the degree to which Annex Ws will contain 
specific information on contract support requirements. We found that 
several senior DOD officials have the expectation that most combatant 
command plans should at least identify the capabilities that 
contractors may provide, regardless of the level of plan. However, the 
contract support planners and other officials responsible for 
developing the Annex Ws disagreed, stating that given the limited 
amount of information on military forces in most operation plans, the 
expected level of detail was difficult if not impossible to achieve. 
In most cases, we found that Annex Ws did not contain the level of 
detail expected by senior DOD leadership and envisioned in current 
guidance, thus limiting the utility of the Annex W as a planning tool 
to assess and address contract support requirements. 

Second, in discussion with combatant command officials responsible for 
developing operation plans, we found that detailed information on 
operational contract support requirements is generally not included in 
other sections or annexes of these plans. Although the Annex W is 
intended to be the focal point within an operation plan for discussing 
operational contract support, DOD guidance underscores the importance 
of addressing contractor requirements throughout an operation plan. 
However, we found that non-logistics personnel tend to assume that the 
logistics community will address the need to incorporate operational 
contract support throughout operation plans. For example, combatant 
command officials told us they were not aware of any assumptions 
specifically addressing the potential use or role of operational 
contract support in their base plans. Assumptions are used to focus 
attention of senior DOD leadership on factors that could present risks 
to mission success. Similarly, according to DOD planners, there is a 
lack of details on contract support in other parts of most base plans 
or in the non-logistics (e.g., communication or intelligence) annexes 
of operation plans. DOD guidance for these annexes directs planners to 
identify the means or capabilities necessary for meeting mission 
requirements. Although this guidance does not specifically mention 
contractors, contractors provide significant support in these areas. 

The lack of details on contract support requirements in Annex Ws, 
along with the limited discussion of contractors in other portions of 
operation plans, can hinder the ability of combatant commanders to 
understand the extent to which their plans are reliant on contractors. 
Moreover, senior decision makers may incorrectly assume that operation 
plans have adequately addressed contractor requirements. As a result, 
they risk not fully understanding the extent to which the combatant 
command will be relying on contractors to support combat operations, 
and being unprepared to provide the necessary management and oversight 
of deployed contractor personnel. 

Concluding Observations: 

In closing, DOD has taken positive steps in recognizing its reliance 
on contractors to support operations both now and in the future, and 
it has emphasized the need for increased oversight and management over 
these contractors. However, more work is needed to address the long- 
standing challenges I have discussed today. Many of the challenges I 
have identified, particularly those related to contract management, 
oversight, and planning, stem from DOD's inability to institutionalize 
operational contract support by accepting contractors as an integral 
part of the total force. Reforming the way DOD approaches operational 
contract support will require a fundamental cultural change for the 
department. As part of the effort to bring about such changes, DOD 
will need to continue to evaluate the role that contractors play in 
contingency operations to determine the appropriate balance of 
contractors and military forces and institutionalize operational 
contract support at all levels of professional military education as 
well as in predeployment training and exercises. 

Mr. Chairman, this concludes my statement. I would be happy to answer 
any questions. 

GAO Contacts and Acknowledgments: 

For further information about this statement, please contact William 
Solis at (202) 512-8365 or In addition, contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this statement. Individuals who made key 
contributions to this statement are Carole Coffey, Assistant Director; 
Vincent Balloon, Laura Czohara, Melissa Hermes, Guy LoFaro, Emily 
Norman, Jason Pogacnik, James Reynolds, and Cheryl Weissman. 

[End of section] 


[1] Operational contract support is the process of planning for and 
obtaining supplies, services, and construction from commercial sources 
in support of joint operations, along with the associated contractor 
management functions. Operational contract support includes planning 
for contracted support, requirements development, contract execution, 
oversight of contractors, accountability and support of contractors, 
property management, and retrograde of contractors and equipment. In 
the past, DOD has used the phrase "contractors accompanying the force" 
to encompass the process the department now refers to as operational 
contract support. 

[2] GAO, Contingency Operations: Opportunities to Improve the 
Logistics Civil Augmentation Program, [hyperlink,] (Washington, D.C.: Feb. 
11, 1997) 

[3] Generally accepted government auditing standards require that we 
plan and perform the audit to obtain sufficient, appropriate evidence 
to provide a reasonable basis for our findings and conclusions based 
on our audit objectives. We believe that the evidence obtained 
provides a reasonable basis for our findings and conclusions based on 
our audit objectives. 

[4] The Logistics Civil Augmentation Program, commonly referred to as 
LOGCAP, is a program to provide worldwide logistics and base and life 
support services in contingency environments and provides the majority 
of base and life support services to U.S. forces in Iraq and 

[5] The Air Force Contract Augmentation Program (AFCAP) is a logistics 
and engineering support contract used to support contingency 

[6] The administrative contracting officer is a certified contracting 
officer with specialized training and experience. Administrative 
contracting officers may be responsible for many duties including 
ensuring contractor compliance with contract quality assurance 
requirements, approving the contractor's use of subcontractors, 
reviewing the contractor's management systems, reviewing and 
monitoring the contractor's purchasing system, and ensuring that 
government personnel involved with contract management have the proper 
training and experience. 

[7] The responsibilities of the property administrator include 
administering the contract clauses related to government property in 
the possession of the contractor, developing and applying a property 
systems analysis program to assess the effectiveness of contractor 
government property management systems, and evaluating the 
contractor's property management system to ensure that it does not 
create an unacceptable risk of loss, damage, or destruction of 

[8] GAO, Military Operations: DOD's Extensive Use of Logistics Support 
Contracts Requires Strengthened Oversight, [hyperlink,] (Washington, DC: July 19, 

[9] GAO, Military Operations: High-Level DOD Action Needed to Address 
Long-standing Problems with Management and Oversight of Contractors 
Supporting Deployed Forces, [hyperlink,] (Washington, DC: Dec. 18, 

[10] GAO, Military Operations: DOD Needs to Address Contract Oversight 
and Quality Assurance Issues for Contracts Used to Support Contingency 
Operations, [hyperlink,] 
(Washington, DC: Sept. 26, 2008). 

[11] [hyperlink,]. 

[12] Commission on Wartime Contracting in Iraq and Afghanistan, "At 
What Cost? Contingency Contracting in Iraq and Afghanistan" Interim 
Report, June 2009. 

[13] GAO, Military Operations: High-Level DOD Action Needed to Address 
Long-standing Problems with Oversight and Management of Contractors, 
[hyperlink,] (Washington, DC: 
Dec. 18, 2006). 

[14] GAO, Military Operations: Implementation of Existing Guidance and 
Other Actions Needed to Improve DOD's Oversight and Management of 
Contractors in Future Operations, [hyperlink,] (Washington, D.C.: Jan. 24, 

[15] While DOD does not require military commanders to take 
operational contract support courses, Joint Forces Command has two 
operational contract support courses available online and other 
courses are available through the Defense Acquisition University and 
the Army. 

[16] [hyperlink,] and 

[17] National Defense Authorization Act for Fiscal Year 2008, Pub. L. 
No. 110-181, § 849 (2008). 

[18] Section 849 of the 2008 NDAA. 

[19] GAO, Military Operations: Background Screenings of Contractor 
Employees Supporting Deployed Forces May Lack Critical Information, 
but U.S. Forces Take Steps to Mitigate the Risk Contractors May Pose, 
[hyperlink,] (Washington, 
D.C.: Sept. 22, 2006). 

[20] GAO, Contingency Contract Management: DOD Needs to Develop and 
Finalize Background Screening and Other Standards for Private Security 
Contractors, [hyperlink,] 
(Washington D.C.: July 31, 2009). 

[21] U.S. Forces-Afghanistan (USFOR-A), is the headquarters for U.S. 
forces operating in Afghanistan and was established in October 2008. 

[22] [hyperlink,]. 

[23] [hyperlink,]. 

[24] [hyperlink,]. 

[25] In July 2008, DOD signed a memorandum of understanding with the 
Department of State and the U.S. Agency for International Development 
in which the three agencies agreed to track information on contracts 
meeting specified thresholds performed in Iraq or Afghanistan and the 
personnel working on those contracts. 

[26] GAO, Contingency Contracting: Further Improvements Needed in 
Agency Tracking of Contractor Personnel and Contracts in Iraq and 
Afghanistan, [hyperlink,] 
(Washington D.C.: Nov. 2, 2009). 

[27] A letter of authorization (LOA) is a document issued by a 
government contracting officer or designee that authorizes contractor 
personnel to travel to, from, and within a designated area and to 
identify any additional authorizations, privileges, or government 
support the contractor is entitled to under the contract. 

[28] This guidance was implemented in the Defense FAR Supplement, § 
252.225-7040(g), which specifies that contractors are to enter 
information into SPOT for all personnel authorized to accompany the 
U.S. Armed Forces during contingency operations and certain other 
actions outside the United States. However, Class Deviation 2007-O0010 
excluded contracts with performance in the U.S. Central Command's area 
of responsibility that did not exceed $25,000 and had a period of 
performance of less than 30 days. 

[29] In January 2010 the Under Secretary of Defense for Acquisition, 
Technology and Logistics issued a memo stating that the department 
would begin transitioning from the manual quarterly census to an 
automated report generated from SPOT. However, U.S.Forces-Iraq has 
decided to continue its monthly census instead of relying on SPOT to 
help manage the drawdown. 

[30] [hyperlink,]. 

[31] [hyperlink,] and 

[32] Joint Publication 3-33, "Joint Task Force Headquarters," 16 
February 2007, pg. C-7 and C-9. 

[33] Examples of staff sections include Comptroller, Civil Affairs, 
Engineering, and Communications. 

[34] Multi-National Force-Iraq (MNF-I) and its subordinate 
headquarters merged into a single headquarters called United States 
Forces-Iraq (USF-I) in January 2010. Documents obtained and 
discussions held prior to January 2010 will be attributed to MNF-I or 
one of its subordinate commands as appropriate. Discussions held and 
documents obtained after January 2010 will be attributed to USF-I. 

[35] [hyperlink,]. 

[36] Joint capability areas are a collection of like DOD capabilities 
functionally grouped to support capability analysis, strategy 
development, investment decision making, capability portfolio 
management, and capabilities-based force development and operational 

[37] John Warner National Defense Authorization Act for Fiscal Year 
2007, Pub. L. No. 109-364, § 854 (2006) (codified at 10 U.S.C. § 2333). 

[38] National Defense Authorization Act for Fiscal Year 2008, Pub. L. 
No. 110-181, § 849 (2008). 

[39] GAO, Contract Management: DOD Developed Draft Guidance for 
Operational Contract Support but Has Not Met All Legislative 
Requirements, [hyperlink,] 
(Washington, D.C.: Nov. 20, 2008) 

[40] [hyperlink,]. 

[End of section] 

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