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Before the Subcommittee on National Security and Foreign Affairs, 
Committee on Oversight and Government Reform, House of Representatives: 

United States Government Accountability Office: 

For Release on Delivery: 
Expected at 10:00 a.m. EDT:
Tuesday, June 29, 2010: 

Warfighter Support: 

Cultural Change Needed to Improve How DOD Plans for and Manages 
Operational Contract Support: 

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


[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss the challenges the Department 
of Defense (DOD) faces in institutionalizing operational contract 
support throughout the department. The institutionalization of 
operational contract support includes planning for the use of 
contractors, training of military personnel on the use of contractor 
support, accurately tracking contractor use, and establishing measures 
to ensure that contractors are accountable. For decades, DOD has 
relied on contractors to support contingency operations and has long 
considered them a part of the total force. For example, in its 2006 
Quadrennial Defense Review the department reiterated that contractors 
were part of a total force that includes active and reserve military 
components, civilians and contractors. Additionally, in 2008 the 
Deputy Under Secretary of Defense for Logistics and Materiel Readiness 
testified that the structure of the U.S. military had been adapted to 
an environment in which contractors were an important part of the 
force. Further, an Army commission chaired by Dr. Jacques Gansler 
acknowledged that contractors were a significant part of the 
military's total force.[Footnote 1] 

While DOD joint guidance recognizes contractors as part of its total 
workforce, we have previously reported that DOD has not yet developed 
a strategy for determining the appropriate mix of contractor and 
government personnel.[Footnote 2] In addition, we recently testified 
that several long-standing challenges have hindered DOD's ability to 
manage and oversee contractors at deployed locations. [Footnote 3] For 
example, DOD has not followed long-standing planning guidance, ensured 
that there is an adequate number of contract oversight and management 
personnel, and comprehensively trained non-acquisition personnel, such 
as military commanders. Since 1992, we have designated DOD contract 
management as a high-risk area, in part due to concerns over the 
adequacy of the department's acquisition and contract oversight 
workforce.[Footnote 4] As we have previously testified, many of the 
long-standing problems we have identified regarding managing and 
overseeing contractor support to deployed forces stem from DOD's 
reluctance to plan for contractors as an integral part of the total 
force.[Footnote 5] We have also testified that DOD's long-standing 
problems in managing and overseeing contractors at deployed locations 
make it difficult for the department to ensure that it is getting the 
services it needs on time and at a fair and reasonable price. We have 
found numerous instances where poor oversight and management of 
contractors have led to negative monetary and operational outcomes. As 
a result, since the advent of our work on contractor support to 
deployed forces in 1997,[Footnote 6] we have made numerous 
recommendations to improve DOD's management of contractors in deployed 
locations. While DOD has taken some actions to address these 
challenges, it has not addressed all of them, as I will discuss in 
further detail. 

My statement today will focus on the extent to which DOD has 
institutionalized operational contract support. My statement is based 
on recently published reports and testimonies that examined planning 
for operational contract support and the department's efforts to 
manage and oversee contractors in Iraq and Afghanistan as well as our 
ongoing work involving operational contract support related issues in 
Iraq and Afghanistan. Our work was conducted in accordance with 
generally accepted government auditing standards.[Footnote 7] 


The U.S. military has long used contractors to provide supplies and 
services to deployed U.S. forces. However, the scale of contractor 
support DOD relies on today has increased considerably from what DOD 
relied on during previous military operations. In Iraq and Afghanistan 
contractor personnel now outnumber deployed troops. For example, 
according to DOD, as of March 2010, there were more than 95,000 DOD 
contractor personnel operating in Iraq and more than 112,000 DOD 
contractor personnel operating in Afghanistan. While the number of 
troops fluctuates based on the drawdown in Iraq and the troop increase 
in Afghanistan, as of June 2010 there were approximately 88,000 troops 
in Iraq and DOD estimates that the number of troops in Afghanistan 
will increase to 98,000 by the end of fiscal year 2010. DOD 
anticipates that the number of contractor personnel will grow in 
Afghanistan as the department increases its troop presence in that 
country. However, these numbers do not reflect the thousands of 
contractor personnel located 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. 

Furthermore, the composition of the contractor workforce in Iraq and 
Afghanistan differs. For example, in Iraq the majority of contractor 
personnel are U.S. citizens or third-country nationals (82 percent), 
whereas in Afghanistan the majority of contractor personnel are local 
Afghan nationals (70 percent). The difference becomes even more 
apparent when looking at the subset of private security contractor 
personnel who perform personal security, convoy security, and static 
security missions. In Iraq, 90 percent of private security contractors 
are U.S. citizens or third-country nationals, whereas in Afghanistan 
93 percent of private security contractors are Afghans. Today, 
contractors located throughout the Middle East and Southwest Asia 
provide U.S. forces with such services as linguist support, equipment 
maintenance, and support for base operations and security. Contractors 
are an integral part of DOD's operations, and DOD officials have 
stated that without a significant increase in the department's 
civilian and military workforce, DOD is likely to continue to rely on 
contractors both in the United States and overseas in support of 
future deployments. 

DOD defines operational contract support as 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. According to DOD joint guidance, 
successful operational contract support is the ability to orchestrate 
and synchronize the provision of integrated contracted support and 
management of contractor personnel providing that support to the joint 
force in a designated operational area. 

DOD Has Taken Some Steps to Institutionalize Operational Contract 
Support, though Challenges Remain: 

In response to congressional direction and GAO recommendations, DOD 
has taken some actions to institutionalize operational contract 
support, such as establishing a focal point to lead the department's 
effort to improve contingency contractor management and oversight at 
deployed locations, issuing new guidance, and beginning to assess its 
reliance on contractors. However, DOD still faces challenges in eight 
areas related to operational contract support. 

(1) Developing guidance. DOD has yet to finalize joint policies 
required by Congress in the National Defense Authorization Acts for 
Fiscal Years 2007 and 2008.[Footnote 8] 

(2) Planning for contractors in ongoing operations. The department has 
not fully planned for the use of contractors in support of ongoing 
operations in Iraq and Afghanistan, although some efforts are underway 
at the individual unit level. 

(3) Planning for contractors in future operations. DOD needs to take 
additional actions to improve its planning for operational contract 
support in future operations. For example, while DOD has started to 
institutionalize operational contract support into combatant commands' 
operation plans, it has not yet made significant progress. 

(4) Tracking contractor personnel. While DOD has developed a system to 
collect data on contractors deployed with U.S. forces, our reviews of 
this database have highlighted significant shortcomings in its 
implementation in Iraq and Afghanistan. 

(5) Providing oversight personnel. DOD continues to face challenges in 
providing an adequate number of personnel to oversee and manage 
contractors in contingency operations, such as Iraq and Afghanistan. 

(6) Training non-acquisition personnel. DOD faces challenges in 
ensuring that non-acquisition personnel, such as unit commanders, have 
been trained on how to work effectively with contractors in 
contingency operations. 

(7) Screening contractor personnel. DOD has yet to develop a 
departmentwide policy for screening the significant number of local 
and third-country national contractor personnel who support deployed 
U.S. forces. 

(8) Capturing lessons learned. DOD has not implemented previous GAO 
recommendations to develop a departmentwide lessons learned program to 
capture the department's institutional knowledge regarding all forms 
of contractor support to deployed forces in order to facilitate a more 
effective working relationship between contractors and the military. 

Given the contractor-related challenges DOD continues to face, a 
cultural change is necessary to integrate operational contract support 
throughout the department. Without such a change, DOD is likely to 
continue to face these challenges in ongoing and future contingency 

Some Departmentwide Steps Taken 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 contingency contractor management 
and oversight at deployed locations. Among the office's 
accomplishments is the establishment of a community of practice for 
operational contract support comprising of subject matter experts from 
the Office of the Secretary of Defense, the Joint Staff, and the 
services. In March 2010 the office issued 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 and other guidance to 
improve contracting and contract management in deployed locations. For 

* In 2007 the department introduced the Joint Contingency Contracting 
Handbook, Contingency Contracting: A Joint Handbook for the 21st 
Century, which provides tools, templates, and training that enable a 
contingency contracting officer to be effective in any contracting 
environment. The handbook is currently being updated and the 
department expects the revised edition 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 to use in conjunction with formal contracting officer's 
representative (COR) training and 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, and information on, 
planning, conducting, and assessing operational contract support 
integration, contractor management functions, and contracting command 
and control organizational options in support of joint operations. 
[Footnote 9] 

Finally, in 2008, the Joint Staff (J-4, Logistics), at the direction 
of the Chairman of the Joint Chiefs of Staff, undertook a study to 
determine how much the department relied 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; and (3) guide the 
development of future contingency planning and force development. The 
Joint Staff's initial findings suggest that in Iraq the department was 
highly dependent on contractors in four of the nine joint capability 
areas, including Logistics.[Footnote 10] 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. 

In addition, in July 2009, DOD provided Congress with a report 
containing an inventory of contracts for fiscal year 2008, including 
but not limited to service contracts supporting contingency 
operations.[Footnote 11] According to Army officials, the Army is 
using information derived from this effort to help inform discussions 
on the appropriate mix of DOD civilian, military and contractor 
personnel in future contingency operations. However, DOD has 
acknowledged and we have reported limitations associated with the 
methodologies used to develop this initial inventory.[Footnote 12] 

Operational Contract Support Guidance Has Not Been Finalized: 

DOD has developed some policies and guidance as described above, but 
has not finalized other key operational contract support guidance 
directed by Congress. In 2006, Congress amended title 10 of the United 
States Code by adding section 2333, which 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 postconflict operations.[Footnote 13] In 
January 2008, the National Defense Authorization Act for Fiscal Year 
2008 amended section 2333 by adding a new subsection directing that 
these joint policies also provide for training of military personnel 
outside the acquisition workforce who are expected to have acquisition 
responsibility, including oversight duties associated with contracts 
or contractors, during combat operations, postconflict operations, and 
contingency operations.[Footnote 14] In 2008 we reported that DOD was 
developing an Expeditionary Contracting Policy to address the 
requirement to develop a joint policy on contingency contracting. 
[Footnote 15] In addition, we reported that DOD was revising the 
October 2005 version of DOD Instruction 3020.41, Contractor Personnel 
Authorized to Accompany the U.S. Armed Forces, to strengthen the 
department's joint policies and guidance on requirements definition; 
program management, including the oversight of contractor personnel 
supporting a contingency operation; and training. As of June 2010, the 
department has 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. Further, the department has determined that it will not issue 
the Expeditionary Contracting Policy because the practitioners do not 
believe a joint policy is necessary. 

Identifying and Planning for Operational Contract Support Requirements 
in Current Operations: 

DOD guidance highlights the need to plan for operational contract 
support early in an operation's planning process, in part because of 
the challenges associated with using contractors in contingencies. 
These challenges include overseeing and managing contractors in 
contingency operations. However, in previous reports and testimonies 
we have noted that DOD has not followed long-standing guidance on 
planning for operational contract support. Our work continues to show 
that DOD has not fully planned for the use of contractors in support 
of ongoing contingency operations in Iraq and Afghanistan, although 
some efforts are under way at the individual unit level. 

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 has estimated 
that from 26,000 to 56,000 additional contractors may be needed to 
support the additional troops. Despite the additional contractors who 
will be needed to support the troop increase, U.S. Forces-Afghanistan 
(USFOR-A),[Footnote 16] with the exception of planning for the 
increased use of the Army's Logistics Civil Augmentation Program 
(LOGCAP),[Footnote 17] was engaged in very little planning for 
contractors. We did, however, identify several individual unit efforts 
to plan for contractors. 

For example, we found 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 its 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. 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. 

Additionally, in April 2010 we reported that while U.S. Forces-Iraq 
(USF-I)[Footnote 18] had taken steps to identify all the LOGCAP 
support it needed for the drawdown, it had not identified the other 
contracted support it may need to support the drawdown.[Footnote 19] 
We reported that according to DOD joint guidance and Army regulations, 
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--for identifying the types 
and levels of contracted support needed. As we reported in April 2010, 
Multi-National Force-Iraq's (MNF-I) May 2009 drawdown plan delegated 
the responsibility for determining contract support requirements to 
contracting agencies, such as the Joint Contracting Command-Iraq/ 
Afghanistan, rather than to operational personnel. However, Joint 
Contracting Command-Iraq/Afghanistan officials told us that they could 
not determine the theaterwide levels of contracted services required, 
or plan for 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 noted 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 USF-I is 
subsequently tracking, the reduction of contracted support in Iraq by 
using historical ratios of contractor personnel to servicemembers in 
Iraq. Such ratios may not accurately reflect the levels of contracted 
support needed during the drawdown. 

In our April 2010 report we recommended, among other things, that DOD 
direct the appropriate authorities to ensure that joint doctrine 
regarding operational planning for contract support is followed and 
that operational personnel identify contract support requirements in a 
timely manner to avoid potential waste and abuse and facilitate the 
continuity of services. DOD concurred with this recommendation and 
noted that it recognized that improvements could be made to DOD's 
planning for contractor support and stated that the Joint Staff is 
working to improve strategic guidance, processes, and tools available 
to plan for contracted support through the Chairman's Operational 
Contract Support Task Force. DOD also commented that it recognized the 
need for better synchronization between operational needs and 
contractor activities and, to that end, U.S. Central Command has taken 
steps to increase visibility and synchronization of operational 
contract support through initiatives such creating the Joint Theater 
Support Contracting Command, instituting a Joint Contracting Support 
Board, and collaborating with the Joint Staff to improve guidance. 
Also, in our April report, we recommended that DOD direct the 
appropriate authorities to conduct an analysis of the benefits, costs, 
and risks of transitioning from LOGCAP III to LOGCAP IV and other 
service contracts in Iraq under current withdrawal timelines to 
determine the most efficient and effective means for providing 
essential services during the drawdown. DOD concurred with this 
recommendation and as of May of this year, has canceled the transition 
from LOGCAP III to LOGCAP IV for base life support in Iraq due partly 
to concerns about the interruption of essential services. The decision 
to continue LOGCAP III rather than transition to LOGCAP IV for base 
life support services was based on three main factors: input from 
military commanders in Iraq, the projected cost of the transition, and 
contractor performance. Commanders in Iraq had raised concerns that a 
transition from LOGCAP III to LOGCAP IV would strain logistics and 
transportation assets in Iraq at the same time that a massive 
withdrawal of U.S. forces, weapons, and equipment is under way. 

In the past, we have repeatedly reported on DOD's failure to fully 
plan for contract support and the impact that this can have on 
operations. Several units that recently returned from Afghanistan 
discussed how a lack of planning for contract support resulted in 
service shortages and diminished operational capability. For example, 
officials from several battalions told us that when they arrived at 
locations that were intended to be their combat outposts, they found 
the area largely unprepared, including a lack of housing, heating, 
washing machines, showers and food. These bases were too small or too 
remote to be serviced by LOGCAP, and therefore the units had to make 
their own contract support arrangements through the appropriate 
regional contracting command to build, equip and maintain their bases. 
Because the units were unaware they would have to take on this 
responsibility prior to deploying, they did not plan for and allocate 
adequate personnel to handle the extensive contract management and 
oversight duties associated with building and maintaining their combat 
outpost. As a result, these units had to take military personnel away 
from their primary missions in order to handle these contract 
management duties. Other units faced different challenges as a result 
of a lack of planning for contract support. For example, another unit 
that recently returned from Afghanistan stated that the lack of 
planning for an increased requirement for linguists due to increased 
troop levels led to shortages that resulted in the delaying of some 

Limited Progress Integrating Contractors into Combatant Commands' 
Operation Plans: 

DOD guidance recognizes the need to include the role of contractors in 
its operation plans. For example, joint guidance indicates that 
military commanders must ensure that requisite contract planning and 
guidance are in place for any operations where significant reliance on 
contractors is anticipated, and planning for contractors should be at 
a level of detail on par with that for military forces. To provide 
greater details on contract services needed to support an operation 
and the capabilities that contractors would bring, DOD's guidance for 
contingency planning was revised in February 2006 to require planners 
to include an operational contract support annex--known as Annex W--in 
the combatant commands' most detailed operation plans, if applicable 
to the plan.[Footnote 20] In addition, joint guidance gives the 
combatant commanders the discretion to require Annex Ws for 
additional, less detailed plans. Incorporating operational contract 
support into these types of plans represents a critical opportunity to 
plan for the use of contractors at the strategic and tactical levels. 

Although DOD guidance has called for the integration of an operational 
contract support annex--Annex W--into certain combatant command 
operation plans since February 2006, the department has made limited 
progress in meeting this requirement. We reported in March 2010 that 
while planners identified 89 plans that may require an Annex W, only 
four operation plans with Annex Ws had been approved by the Secretary 
of Defense or his designee, and planners had drafted Annex Ws for an 
additional 30 plans.[Footnote 21] According to combatant command 
officials, most of the draft Annex Ws developed restated broad 
language from existing DOD guidance on the use of contractors to 
support deployed forces, and they included few details on the types of 
contractors needed to execute a given plan, despite guidance requiring 
Annex Ws to list contracts likely to be used in theater. As a result, 
DOD risks not fully understanding the extent to which it will be 
relying on contractors to support combat operations and being 
unprepared to provide the necessary management and oversight of 
deployed contractor personnel. Moreover, the combatant commanders are 
missing a chance to fully evaluate their overall requirements for 
reliance on contractors. 

Data Collected by DOD's System to Track Contractor Personnel in Iraq 
and Afghanistan Are Unreliable: 

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 the 
use of a contract clause that requires contractor firms to enter 
personnel data for contracts performed in Iraq and Afghanistan into 
this system.[Footnote 22] In July 2008, DOD signed a memorandum of 
understanding with the Department of State (State) and the U.S. Agency 
for International Development (USAID) 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.[Footnote 23] Although the SPOT database is designed to 
provide accountability of all U.S., local, and third-country national 
contractor personnel by name; a summary of the services being 
provided; and information on government-provided support, our reviews 
of SPOT have highlighted shortcomings in DOD's implementation of the 
system in Iraq and Afghanistan.[Footnote 24] For example, we found 
that as a result of diverse interpretations by DOD officials 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. While one of 
the functions of SPOT is to generate letters of authorization, 
[Footnote 25] not all contractor personnel in Iraq, particularly local 
nationals, need such letters, and agency officials informed us that 
such personnel were not being entered into SPOT. Similarly, officials 
at 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. Additionally, tracking 
local nationals in SPOT presents particular challenges because their 
numbers tend to fluctuate because of the use of day laborers and 
because local firms do not always keep track of the individuals 
working on their projects.[Footnote 26] 

We made several recommendations to DOD, State, and USAID in October 
2009 to better ensure consistency in requirements for data entry in 
SPOT and to ensure that the use and reporting capabilities of SPOT are 
fulfilling statutory requirements among other things.[Footnote 27] 
DOD, State, and USAID agreed that coordination among the three 
agencies is important, but DOD and State disagreed that they needed a 
new plan to address the issues we identified. They cited their ongoing 
coordination efforts and anticipated upgrades to SPOT as sufficient. 
However, we believe continued coordination among the three agencies is 
important as they attempt to obtain greater visibility into their 
reliance on contractors, grantees, and cooperative agreement 
recipients in dynamic and complex environments. Otherwise, the 
agencies not only risk not collecting the information they need but 
also risk collecting detailed data they will not use. 

Lack of Adequate Numbers of Contract Oversight and Management 
Personnel in Deployed Locations: 

One important aspect of operational contract support is the oversight 
of contracts--which can refer to contract administration functions, 
quality assurance surveillance, corrective action, property 
administration, and past performance evaluation. Our work has found, 
however, that DOD frequently did not have a sufficient number of 
trained contracting and oversight personnel to effectively manage and 
oversee its contracts. While 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, these efforts have been driven by individual 
services and units and are not part of a systematic approach by DOD. 

Ultimately, the responsibility for contract oversight 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, 
known as CORs, who are responsible for providing much of the day-to-
day oversight of a contract during a contingency operation. CORs are 
typically drawn from units receiving contractor-provided services and 
are not normally contracting specialists. [Footnote 28] Often their 
service as CORs 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. 

The Defense Federal Acquisition Regulation Supplement requires that 
CORs be qualified by training and experience commensurate with the 
responsibilities to be delegated to them; however, we have reported in 
the past that individuals have been deployed without knowing that they 
would be assigned as CORs, thus precluding their ability to take COR 
training prior to deployment. This can be a problem because although 
the courses are offered online, there is limited Internet connectivity 
in theater--particularly in Afghanistan. During our recent visits with 
deployed and recently returned units,[Footnote 29] we found that units 
continue to deploy to Afghanistan without designating CORs beforehand. 
As a result, the personnel assigned to serve as CORs have to take the 
required training after arriving in theater, which provides technical 
challenges. Several recently returned units told us that it could take 
days to complete the 2-hour online training because of poor Internet 
connectivity in Afghanistan. 

We also found that although CORs and other oversight personnel are 
responsible for assisting in the technical monitoring or 
administration of a contract, these oversight personnel often lack the 
technical knowledge and training needed to effectively oversee certain 
contracts. Several units that have recently returned from Afghanistan 
told us that CORs with no engineering background are often asked to 
oversee construction projects. These CORs are unable to ensure that 
the buildings and projects they oversee meet the technical 
specifications required in the drawing plans. An additional 
complication is that the plans are not always provided in English for 
the CORs or in the appropriate local language (Dari or Pashto) for the 
Afghan contractors. 

Some steps have been taken to address these challenges. For example, 
the Army issued an execution order on CORs in December 2009, in which 
the Army Chief of Staff directed the commanders of deploying units to 
coordinate with the units 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 must identify and train 80 
COR candidates. In addition, the Army order directs the Army's 
Training and Doctrine Command to develop training scenarios and 
include COR contract oversight scenarios in mission rehearsal 
exercises by March 30, 2010. The order also directed the Training and 
Doctrine Command to ensure that contingency contracting 
responsibilities are included in appropriate professional military 
education courses. 

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 issues 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 
these personnel have been designated as CORs for the upcoming 
deployment, all could be called upon to serve as CORs should the need 

While we recognize the efforts DOD has under way to develop long-term 
plans intended to address its personnel shortages, many of 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 Non-Acquisition Personnel to Provide Contract Oversight 
and Management: 

Currently, military commanders and other unit leaders are not required 
to complete operational contract support training prior to deployment. 
[Footnote 30] We have previously reported on the potential issues that 
can arise when commanders are unaware of their responsibility toward 
contractors and are unclear about the difference between command 
authority and contract authority. 

During our December 2009 trip to Afghanistan and in conversations with 
personnel from recently redeployed units, 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, and 
concerns were raised about the potential risk of military commanders 
directing contractors to perform work outside the scope of the 
contract--something commanders lack the authority to do.[Footnote 31] 
In addition, officials within several units we spoke with that have 
just redeployed from Afghanistan told us that lack of knowledge about 
contracting resulted in the failure to include the right mix of 
personnel in their manpower planning document. This led to shortfalls 
in critical oversight areas, such as in the badging and screening 
office for contractor employees coming on base. Units that had 
recently returned from Afghanistan whose personnel we spoke with also 
did not anticipate the sheer volume of contractors and the time and 
manpower they would need to devote to properly process and oversee 
these contractor personnel. This led to the use of soldiers and 
Marines to perform contract-related duties such as escort duty, which 
had not been adequately planned for prior to deployment. 

Contractors in contingency operations are integrated into a wide 
spectrum of activities and support a diverse range of military 
functions and operations that are not confined to the logistics world, 
and therefore all military personnel should be aware of contractors 
and how to work with them. We have previously recommended that DOD 
develop training standards for the services to integrate basic 
familiarity with contractor support to deployed forces into their 
professional military education to ensure that military commanders and 
other senior leaders who may deploy to locations with contractor 
support have the knowledge and skills needed to effectively manage 
contractors. DOD concurred with this recommendation and recognizes the 
need for broad training for non-acquisition personnel in order for 
them to understand the basics regarding contractor personnel. However, 
as DOD reported in November of 2009, the effort to incorporate 
operational contract support into professional military education was 
still ongoing. We continue to believe that integrating operational 
contract support into professional military education is an important 
step in institutionalizing the concept throughout DOD. 

Screening and Providing Badges to Contractors: 

In Iraq and Afghanistan, military commanders and other military 
officials have expressed concerns about the security risks that 
contractor personnel, particularly third-country and local nationals, 
pose to U.S. forces because of 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 32] In July 2009, we reported that DOD had not 
developed departmentwide procedures to screen local national and third-
country national contractor personnel in part because two offices 
within the department---those of the Under Secretary of Defense for 
Intelligence and 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.[Footnote 33] As a result, 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. DOD partially concurred with our 
recommendation and responded that the Office of the Assistant Deputy 
Under Secretary of Defense (Program Support) has been given 
responsibility for monitoring the registration, processing, and 
accounting of private security contractor personnel in the area of 
contingency operations. We noted that while we did not dispute this 
office's role, we did not believe it was the correct office to resolve 
disagreements among the offices responsible for developing DOD's 
background screening policy. DOD has still not developed a 
departmentwide 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, USF-I, the U.S.-led military organization responsible for 
conducting the war in Iraq, has a commandwide policy for screening and 
badging contractors. However, in Afghanistan, USFOR-A has not 
established a commandwide policy for screening and badging 
contractors. Instead, we found that each base develops its own 
background screening and base access procedures, resulting in a 
variety of different procedures. 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 screenings 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. Officials stated that they rely on a biometric system, also 
used in Iraq, to screen local and third-country national contractor 
personnel. However, as we have previously reported, the name checks 
and biometric data collection associated with issuing badges rely 
primarily upon U.S.-based databases of criminal and terrorist 
information and background checks that rely on 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 United States.[Footnote 34] 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 personnel. 

Collecting and Distributing Lessons Learned: 

Although DOD has policy requiring the collection and distribution of 
lessons learned to the maximum extent possible, we found in our 
previous work that no procedures were in place to ensure that lessons 
learned are collected and shared. Many issues that we continue to 
report result from the failure to share lessons learned from previous 

The lack of a lessons learned program means that the knowledge that is 
gained by a currently or previously deployed unit is not fully 
leveraged to DOD's advantage. Personnel we spoke to from units that 
were deployed or had just returned from deployment told us that they 
left for their deployment not knowing the extent to which they would 
have to rely on contractors or how to staff their manpower planning 
document and, as a result, were short handed in several critical 
oversight areas and had to use troops to perform functions other than 
their primary duties. 

We have previously recommended developing a departmentwide lessons 
learned program to capture the experiences of military units that have 
used logistics support contracts and establishing a focal point within 
the Office of the Under Secretary of Defense for Acquisition, 
Technology and Logistics, to lead and coordinate the implementation of 
the departmentwide lessons learned program to collect and distribute 
the department's institutional knowledge regarding all forms of 
contractor support to deployed forces. DOD concurred with this 
recommendation but as of November 2009 these efforts were still 
ongoing. Implementing these recommendations would facilitate a more 
effective working relationship between contractors and the military. 

Concluding Observations: 

DOD has acknowledged that operational contract support plays an 
integral role in contingency operations and that successful execution 
of operational contract support requires significant planning and 
management. While some efforts have been made within the department 
and the individual services to improve the planning for and management 
of contractors, these efforts do not fully work toward integrating 
operational contract support throughout DOD. As we have discussed, 
many of the operational contract support challenges the department 
continues to face are long-standing and while the department has 
acknowledged many of these challenges, and taken some actions, it has 
not systematically addressed them. 

Looking toward the future, the challenges we have discussed 
demonstrate the need for DOD to consider how it currently uses 
contractors in contingency operations, how it will use contractors to 
support future operations, and the impact that providing management 
and oversight of these contractors has on the operational 
effectiveness of deployed units. These considerations would also help 
shift the department's culture as it relates to operational contract 
support. As DOD doctrine recognizes, operational contract support is 
more than just logistical support. Therefore, it is important that a 
significant culture change occur, one that emphasizes operational 
contract support throughout all aspects of the department, including 
planning, training, and personnel requirements. It is especially 
important that these concepts be institutionalized among those serving 
in leadership positions, including officers, noncommissioned officers, 
and civilians. Only when DOD has established its future vision for the 
use and role of contractors supporting deployed forces and fully 
institutionalizes the concepts of operational contract support can it 
effectively address its long-term capability to oversee and manage 
those contractors. 

Mr. Chairman, this concludes my statement. I would be happy to answer 
any questions you or other members of the subcommittee may have at 
this time. 

Contacts and Acknowledgments: 

For further information about this statement, please contact William 
M. Solis at (202) 512-8365 or 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 F. Coffey, Assistant 
Director; James A. Reynolds, Assistant Director; Vincent Balloon; 
Melissa L. Hermes; Charles Perdue; Michael Shaughnessy; Cheryl 
Weissman; and Natasha Wilder. 

[End of section] 


[1] Report of the Commission on Army Acquisition and Program 
Management in Expeditionary Operations (Washington, D.C. September 

[2] GAO, Contingency Contracting: Improvements Needed in Management of 
Contractors Supporting Contract and Grant Administration in Iraq and 
Afghanistan, [hyperlink,] 
(Washington, D.C.: April 12, 2010). 

[3] GAO, Warfighter Support: Continued Actions Needed by DOD to 
Improve and Institutionalize Contractor Support in Contingency 
Operations, [hyperlink,] 
(Washington, D.C.: Mar. 17, 2010). 

[4] GAO, High-Risk Series: An Update, [hyperlink,] (Washington, D.C.: January 22, 

[5] 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, 

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

[7] 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. 

[8] John Warner National Defense Authorization Act for Fiscal Year 
2007, Pub. L. No. 109-364, § 854 (2006) (codified at 10 U.S.C. § 
2333); National Defense Authorization Act for Fiscal Year 2008, Pub. 
L. No. 110-181, § 849 (2008). 

[9] Joint Publication 4-10 expressly does not pertain to contracting 
support of routine, recurring (i.e., noncontingency) DOD operations. 

[10] Joint capability areas are collections 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 

[11] Section 2330a of title 10 of the United States Code, as amended 
by the National Defense Authorization Act for Fiscal Year 2008, 
requires DOD to submit an annual inventory of the activities performed 
pursuant to contracts for services for or on behalf of DOD during the 
preceding fiscal year. These inventories are to contain a number of 
different elements for the service contracts listed, including 
information on the functions and missions performed by the contractor, 
the funding source for the contract, and the number of full-time 
contractor employees or its equivalent working under the contract. 

[12] GAO, Defense Acquisitions: Observations on the Department of 
Defense Service Contract Inventories for Fiscal Year 2008, [hyperlink,] (Washington, D.C.: January 
29, 2010). 

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

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

[15] 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) 

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

[17] LOGCAP provides 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 Afghanistan. 

[18] MNF-I and its subordinate headquarters merged into a single 
headquarters, 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. 

[19] GAO, Operation Iraqi Freedom: Actions Needed to Facilitate the 
Efficient Drawdown of U.S. Forces and Equipment from Iraq, [hyperlink,] (Washington, D.C.: April 19, 

[20] Chairman of the Joint Chiefs of Staff Manual 3122.03B, Joint 
Operation Planning and Execution System (JOPES), Volume II, Planning 
Formats (Feb. 28, 2006), superseded by Chairman of the Joint Chiefs of 
Staff Manual 3122.03C, Joint Operation Planning and Execution System 
(JOPES), Volume II, Planning Formats (Aug. 17, 2007). 

[21] GAO, Warfighter Support: DOD Needs to Improve Its Planning for 
Using Contractors to Support Future Military Operations, [hyperlink,] (Washington, D.C. Mar. 30, 

[22] This guidance was implemented in DFARS clause 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. Class Deviation 2007-O0010 (Oct. 17, 2007) provided a new 
clause for contracts with performance in the U.S. Central Command area 
of responsibility that were not already covered by DFARS clause 
252.225-7040. However, the class deviation excluded contracts that did 
not exceed $25,000 and had a period of performance of less than 30 

[23] Section 861 of the National Defense Authorization Act for Fiscal 
Year 2008 directed the Secretary of Defense, the Secretary of State, 
and the USAID Administrator to enter into a memorandum of 
understanding (MOU) related to contracting in Iraq and Afghanistan. 
The law specified a number of matters to be covered in the MOU, 
including the identification of common databases to serve as 
repositories of information on contract and contractor personnel. Pub. 
L. No. 110-181, § 861 (2008). 

[24] GAO, Iraq and Afghanistan: Agencies Face Challenges in Tracking 
Contracts, Grants, Cooperative Agreements, and Associated Personnel, 
[hyperlink,] (Washington, 
D.C.: Mar. 23, 2010); Contingency Contracting: DOD, State, and USAID 
Continue to Face Challenges in Tracking Contractor Personnel and 
Contracts in Iraq and Afghanistan, [hyperlink,] (Washington, D.C.: October 1, 
2009); and Contingency Contracting: DOD, State, and USAID Contracts 
and Contractor Personnel in Iraq and Afghanistan, [hyperlink,] (Washington, D.C: October 1, 

[25] A letter of authorization 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 identifies any 
additional authorizations, privileges, or government support the 
contractor is entitled to under the contract. Contractor personnel 
need SPOT-generated letters of authorization, among other things, to 
enter Iraq, receive military identification cards, travel on U.S. 
military aircraft, or, for security contractors, receive approval to 
carry weapons. 

[26] [hyperlink,]. 

[27] [hyperlink,]. 

[28] We recently reported that DOD also makes extensive use of 
contractors to help perform contract and grant administration 
functions in Iraq and Afghanistan. See [hyperlink,]. 

[29] We spoke with officials from a variety of military units, 
including officials at the headquarters element and at the brigade and 
battalion levels. 

[30] 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. 

[31] [hyperlink,]. 

[32] 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). 

[33] 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). 

[34] [hyperlink,]. 

[End of section] 

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