This is the accessible text file for GAO report number GAO-10-187 
entitled 'Contingency Contracting: Further Improvements Needed in 
Agency Tracking of Contractor Personnel and Contracts in Iraq and 
Afghanistan' which was released on November 2, 2009. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as part 
of a longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Statement Before the Commission on Wartime Contracting in Iraq and 

United States Government Accountability Office:

For Release on Delivery: 
Expected at 9:30 a.m. EST:
Monday, November 2, 2009: 

Contingency Contracting: 

Further Improvements Needed in Agency Tracking of Contractor Personnel 
and Contracts in Iraq and Afghanistan: 

Statement of John P. Hutton, Director: 
Acquisition and Sourcing Management: 


[End of section] 

Chairman Thibault, Chairman Shays, and Commissioners: 

Thank you for inviting me here today to discuss ongoing efforts by the 
Department of Defense (DOD), the Department of State (State), and the 
U.S. Agency for International Development (USAID) to track information 
on contractor personnel and contracts in Iraq and Afghanistan. 
Reliable, meaningful data on contractors and the services they provide 
are necessary to inform agency decisions on when and how to effectively 
use contractors, provide support services to contractors, and ensure 
that contractors are properly managed and overseen. The importance of 
such data is heightened by the unprecedented reliance on contractors in 
Iraq and Afghanistan and the evolving U.S. presence in the two 

My statement focuses on (1) how information on contractor personnel and 
contracts can assist agencies in managing and overseeing their use of 
contractors and (2) the status of DOD, State, and USAID's efforts to 
track statutorily-required information on contractor personnel and 
contracts in Iraq and Afghanistan, as well as our recent 
recommendations to address the shortcomings we identified in their 
efforts. This statement is drawn from our October 2009 report on 
contracting in Iraq and Afghanistan,[Footnote 1] which was mandated by 
section 863 of the National Defense Authorization Act for Fiscal Year 
2008 (NDAA for FY2008),[Footnote 2] and a related April 2009 testimony. 
[Footnote 3] Our prior work was prepared in accordance with generally 
accepted government auditing standards. Those standards require that we 
plan and perform the audits 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 


Section 861 of the NDAA for FY2008 directed the Secretary of Defense, 
the Secretary of State, and the USAID Administrator to sign a 
memorandum of understanding (MOU) related to contracting in Iraq and 
Afghanistan.[Footnote 4] The law specified a number of issues to be 
covered in the MOU, including the identification of common databases to 
serve as repositories of information on contract and contractor 
personnel. The NDAA for FY2008 required the databases to track at a 

* for each contract, 

- a brief description of the contract, 

- its total value, and: 

- whether it was awarded competitively, and: 

* for contractor personnel working under contracts in Iraq or 

- total number employed, 

- total number performing security functions, and: 

- total number who have been killed or wounded. 

In July 2008, DOD, State, and USAID signed an MOU in which they agreed 
the Synchronized Predeployment and Operational Tracker (SPOT) would be 
the system of record for the statutorily-required contract and 
contractor personnel information. The MOU specified SPOT would include 
information on DOD, State, and USAID contracts with more than 14 days 
of performance in Iraq or Afghanistan or valued at more than the 
simplified acquisition threshold, which the MOU stated was $100,000, as 
well as information on the personnel working under those contracts. 

While DOD is responsible for all maintenance and upgrades to the SPOT 
database, each agency agreed in the MOU to ensure that data elements 
related to contractor personnel, such as the number of personnel 
employed on each contract in Iraq or Afghanistan, are accurately 
entered into SPOT by its contractors. SPOT is designed to track 
contractor personnel by name and record information such as the 
contracts they are working under, deployment dates, and next of kin. 
Contract data elements, such as value and extent of competition, are to 
be imported into SPOT from the Federal Procurement Data System - Next 
Generation (FPDS-NG), the federal government's system for tracking 
information on contracting actions. 

Contractor and Contractor Personnel Information Can Help Agencies 
Address Management and Oversight Challenges: 

The need for information on contracts and contractor personnel to 
inform decisions and oversee contractors is critical given DOD, State, 
and USAID's extensive reliance on contractors to support and carry out 
their missions in Iraq and Afghanistan. We have reported extensively on 
the management and oversight challenges of using contractors to support 
contingency operations and the need for decision makers to have 
accurate, complete, and timely information as a starting point to 
address those challenges. Although much of our prior work has focused 
on DOD, the lessons learned can be applied to other agencies relying on 
contractors to help carry out their missions. The agencies' lack of 
complete and accurate information on contractors supporting contingency 
operations may inhibit planning, increase costs, and introduce 
unnecessary risk, as illustrated in the following examples: 

* Limited visibility over contractors obscures how extensively agencies 
rely on contractors to support operations and help carry out missions. 
In our 2006 review of DOD contractors supporting deployed forces, we 
reported that a battalion commander in Iraq was unable to determine the 
number of contractor-provided interpreters available to support his 
unit.[Footnote 5] Such a lack of visibility can create challenges for 
planning and carrying out missions. Further, knowledge of who is on 
their installation, including contractor personnel, helps commanders 
make informed decisions regarding force protection and account for all 
individuals in the event of hostile action. 

* Without incorporating information on contractors into planning 
efforts, agencies risk making uninformed programmatic decisions. As we 
noted in our 2004 and 2005 reviews of Afghanistan reconstruction 
efforts, when developing its interim development assistance strategy, 
USAID did not incorporate information on the contractor resources 
required to implement the strategy.[Footnote 6] We determined this 
impaired USAID's ability to make informed decisions on resource 
allocations for the strategy. 

* A lack of accurate financial information on contracts impedes 
agencies' ability to create realistic budgets. As we reported in July 
2005, despite the significant role of private security providers in 
enabling Iraqi reconstruction efforts, neither State, DOD, nor USAID 
had complete data on the costs associated with using private security 
providers.[Footnote 7] Agency officials acknowledged such data could 
help them identify security cost trends and their impact on the 
reconstruction projects, as increased security costs resulted in the 
reduction or cancellation of some projects. 

* Lack of insight into the contract services being performed increases 
the risk of paying for duplicative services. In the Balkans, where 
billions of dollars were spent for contractor support, we found in 2002 
that DOD did not have an overview of all contracts awarded in support 
operations.[Footnote 8] Until an overview of all contractor activity 
was obtained, DOD did not know what the contractors had been contracted 
to do and whether there was duplication of effort among the contracts 
that had been awarded. 

* Costs can increase due to a lack of visibility over where contractors 
are deployed and what government support they are entitled to. In our 
December 2006 review of DOD's use of contractors in Iraq, an Army 
official estimated that about $43 million was lost each year to free 
meals provided to contractor employees at deployed locations who also 
received a per diem food allowance.[Footnote 9] 

Many recommendations from our prior work on contractors supporting 
contingency operations focused on increasing agencies' ability to track 
contracts and contractor personnel so that decision makers--whether out 
in the field or at headquarters--can have a clearer understanding of 
the extent to which they rely on contractors, improve planning, and 
better account for costs. While actions have been taken to address our 
recommendations, DOD, State, and USAID officials have told us that 
their ability to access information on contracts and contractor 
personnel to inform decisions still needs improvement. Specifically, 
information on contracts and the personnel working on them in Iraq and 
Afghanistan may reside solely with the contractors, be stored in a 
variety of data systems, or exist only in paper form in scattered 
geographical regions. These officials indicated that the use of SPOT 
has the potential to bring some of this dispersed information together 
so that it can be used to better manage and oversee contractors. 

Despite Some Progress, SPOT Not Yet Fully Implemented to Track 
Contractor Personnel and Contracts: 

DOD, State, and USAID have made progress in implementing SPOT. However, 
as we reported last month, DOD, State, and USAID's on-going 
implementation of SPOT currently falls short of providing agencies with 
information that would help facilitate oversight and inform decision 
making, as well as fulfill statutory requirements. Specifically, we 
found that the agencies have varying criteria for deciding which 
contractor personnel are entered into the system and, as a result, not 
all required contractor personnel have been entered. While the agencies 
have used other approaches to obtain personnel information, such as 
periodic contractor surveys, these approaches have provided incomplete 
data that should not be relied on to identify trends or draw 
conclusions. In addition, SPOT, which was intended to serve as a 
central repository of information on contracts performed in Iraq or 
Afghanistan, currently lacks the capability to track required contract 
information as agreed to in the MOU. 

Tracking Information on Contractor Personnel in Iraq and Afghanistan: 

DOD, State, and USAID have been phasing in the MOU requirement to use 
SPOT to track information on contracts and the personnel working on 
them in Iraq and Afghanistan. In January 2007, DOD designated SPOT as 
its primary system for collecting data on contractor personnel deployed 
with U.S. forces and directed contractor firms to enter personnel data 
for contracts performed in Iraq and Afghanistan. State started 
systematically entering information for both Iraq and Afghanistan into 
SPOT in November 2008. In January 2009, USAID began requiring 
contractors in Iraq to enter personnel data into SPOT. However, USAID 
has not yet imposed a similar requirement on its contractors in 
Afghanistan and has no time frame for doing so. 

In implementing SPOT, DOD, State, and USAID's criteria for determining 
which contractor personnel are entered into SPOT varied and were not 
consistent with those contained in the MOU, as the following examples 

* Regarding contractor personnel in Iraq, DOD, State, and USAID 
officials stated the primary factor for deciding to enter contractor 
personnel into SPOT was whether a contractor needed a SPOT-generated 
letter of authorization (LOA).[Footnote 10] However, not all contractor 
personnel, particularly local nationals, in Iraq need LOAs and agency 
officials informed us that such personnel were not being entered into 

* For Afghanistan, DOD offices varied in their treatment of which 
contractor personnel should be entered into SPOT. Officials with one 
contracting office stated the need for an LOA determined whether 
someone was entered into SPOT. As a result, since local nationals 
generally do not need LOAs, they are not in SPOT. In contrast, DOD 
officials with another contracting office stated they follow DOD's 2007 
guidance on the use of SPOT. According to that guidance, contractor 
personnel working on contracts in Iraq and Afghanistan with more than 
30 days of performance and valued over $25,000 are to be entered into 
SPOT--as opposed to the MOU threshold of 14 days of performance or a 
value over $100,000. 

These varying criteria and practices stem, in part, from differing 
views on the agencies' need to collect and use data on certain 
contracts and the personnel working on them. For example, some DOD 
officials we spoke with questioned the need to track contractor 
personnel by name as opposed to their total numbers given the cost of 
collecting detailed data compared to the benefit of having this 
information. However, DOD officials informed us that the agencies did 
not conduct any analyses of what the appropriate threshold should be 
for entering information into SPOT given the potential costs and 
benefits of obtaining such information prior to establishing the MOU 
requirements. As a result of the varying criteria, the agencies do not 
have an accurate or consistent picture of the total number of 
contractor personnel in Iraq and Afghanistan. 

Although officials from all three agencies expressed confidence that 
SPOT data were relatively complete for contractor personnel who need 
LOAs, they acknowledged SPOT does not fully reflect the number of local 
nationals working on their contracts. Agency officials further 
explained ensuring SPOT contains information on local nationals is 
challenging because their numbers tend to fluctuate due to the use of 
day laborers and local firms do not always track the individuals 
working for them. 

Absent robust contractor personnel data in SPOT, DOD, State, and USAID 
have relied on surveys of their contractors to obtain information on 
the number of contractor personnel. However, we determined the 
resulting data from these surveys are similarly incomplete and 
unreliable and, therefore, should not be used to identify trends or 
draw conclusions about the number of contractor personnel in each 
county. Additionally, officials from all three agencies stated that 
they lack the resources to verify the information reported by the 
contractors, particularly for work performed at remote sites where 
security conditions make it difficult for U.S. government officials to 
regularly visit. 

* According to DOD officials, the most comprehensive information on the 
number of DOD contractor personnel in Iraq and Afghanistan comes from 
the U.S. Central Command's (CENTCOM) quarterly census.[Footnote 11] As 
shown in table 1, DOD's census indicated there were 200,807 contractors 
working in Iraq and Afghanistan as of the second quarter of fiscal year 
2009, which is 83,506 more than what was reported in SPOT. However, DOD 
officials acknowledged the census numbers represent only a rough 
approximation of the actual number of contractor personnel in each 
country. For example, an Army-wide review of fiscal year 2008 third 
quarter data determined approximately 26,000 contractors were not 
previously counted. Information on these contractors was included in a 
subsequent census. As a result, comparing third and fourth quarter data 
would incorrectly suggest that the number of contractors increased, 
while the increase is attributable to more accurate counting. 
Conversely, there have also been instances of contractor personnel 
being double counted in the census. 

Table 1: DOD-Reported Data on the Number of Contractor Personnel in 
Iraq and Afghanistan, Second Half of Fiscal Year 2008 and First Half of 
Fiscal Year 2009: 

Fiscal year 2008, third quarter: 162,428; 
Fiscal year 2008, fourth quarter: 163,446; 
Fiscal year 2009, first quarter: 148,050; 
Fiscal year 2009, second quarter: 132,610. 

Fiscal year 2008, third quarter: 41,232; 
Fiscal year 2008, fourth quarter: 68,252; 
Fiscal year 2009, first quarter: 71,755; 
Fiscal year 2009, second quarter: 68,197. 

Fiscal year 2008, third quarter: 203,660; 
Fiscal year 2008, fourth quarter: 231,698; 
Fiscal year 2009, first quarter: 219,805; 
Fiscal year 2009, second quarter: 200,807. 

Source: GAO analysis of CENTCOM census data. 

[End of table] 

* Although State reported most of its contractor personnel are 
currently entered into SPOT, the agency relied on periodic inquiries of 
its contractors to obtain a more complete view of contractor personnel 
in the two countries. State reported 8,971 contractor personnel were 
working on contracts in Iraq and Afghanistan during the first half of 
fiscal year 2009. Even relying on a combination of data from SPOT and 
periodic inquiries, it appeared State underreported its contractor 
personnel numbers. For example, although State provided obligation data 
on a $5.6 million contract for support services in Afghanistan, State 
did not report any personnel working on this contract. 

* USAID relied entirely on contractor surveys to determine the number 
of contractor personnel working in Iraq and Afghanistan. The agency 
reported 16,697 personnel worked on its contracts in Iraq and 
Afghanistan during the first half of fiscal year 2009. However, we 
identified a number of contracts for which contractor personnel 
information was not provided, including contracts to refurbish a 
hydroelectric power plant and to develop small and medium enterprises 
in Afghanistan worth at least $6 million and $91 million, respectively. 

Tracking Information on Contracts with Performance in Iraq and 

Although some information on contracts is being entered into SPOT, the 
system currently lacks the capability to accurately import and track 
the contract data elements as agreed to in the MOU. While the MOU 
specifies contract values, competition information, and descriptions of 
the services being provided would be pulled into SPOT from FPDS-NG, 
this capability is not expected to be available until 2010. Once the 
direct link is established, pulling FPDS-NG data into SPOT may present 
challenges because of how data are entered. While contract numbers are 
the unique identifiers that will be used to match records in SPOT to 
those in FPDS-NG, SPOT users are not required to enter the numbers in a 
standardized manner. In our review of SPOT data, we identified that at 
least 12 percent of the contracts had invalid contract numbers and, 
therefore, could not be matched to records in FPDS-NG.[Footnote 12] 
Additionally, using contract numbers alone may be insufficient since 
specific task orders are identified through a combination of the 
contract and task order numbers. However, SPOT users are not required 
to enter task order numbers. For example, for one SPOT entry that only 
had the contract number without an order number, we found that DOD had 
placed 12 different orders--ranging from a few thousand dollars to over 
$129 million--against that contract. Based on the information in SPOT, 
DOD would not be able to determine which order's value and competition 
information should be imported from FPDS-NG. 

As SPOT is not yet fully operational as a repository of information on 
contracts with performance in Iraq and Afghanistan, DOD, State, and 
USAID relied on a combination of FPDS-NG, agency-specific databases, 
and manually compiled lists of contract actions to provide us with the 
contract information necessary to fulfill our mandate. None of the 
agencies provided us with a cumulative listing of all their contract 
actions for Iraq and Afghanistan. Instead, they provided a total of 48 
separate data sets that we then analyzed to identify almost 85,000 
contracts with performance in Iraq and Afghanistan that totaled nearly 
$39 billion in obligations in fiscal year 2008 and the first half of 
fiscal year 2009. Our analyses involved compiling the data from the 
multiple sources, removing duplicate entries, and standardizing the 
data that were reported. 

Prior Recommendation for Executive Action and Concluding Observations: 

To address the shortcomings we identified in the agencies' 
implementation of SPOT, we recommended in our October 200[Footnote 13]9 
report that the Secretaries of Defense and State and the USAID 
Administrator jointly develop and execute a plan with associated 
timeframes for their continued implementation of the NDAA for FY2008 
requirements, specifically: 

* ensuring that the agencies' criteria for entering contracts and 
contractor personnel into SPOT are consistent with the NDAA for FY2008 
and with the agencies' respective information needs for overseeing 
contracts and contractor personnel; 

* revising SPOT's reporting capabilities to ensure that they fulfill 
statutory requirements and agency information needs; and: 

* establishing uniform requirements on how contract numbers are to be 
entered into SPOT so that contract information can accurately be pulled 
from FPDS-NG as agreed to in the MOU. 

In commenting on our recommendation, DOD and State disagreed with the 
need for a plan to address the issues we identified. They cited ongoing 
coordination efforts and anticipated upgrades to SPOT as sufficient. 
While USAID did not address our recommendation, it similarly noted 
plans to continue meeting with DOD and State regarding SPOT. We believe 
continued coordination among the three agencies is important. They 
should work together to implement a system that is flexible across the 
agencies but still provides detailed information to better manage and 
oversee contractors. However, they also need to take the actions 
contained in our recommendation if the system is to fulfill its 
potential. By jointly developing and executing a plan with time frames, 
the three agencies can identify the concrete steps they need to take 
and assess their progress in ensuring the data in SPOT are sufficiently 
reliable to fulfill statutory requirements and their respective agency 
needs. Absent such a plan and actions to address SPOT's current 
shortcomings, the agencies will be reliant on alternative sources of 
data--which are also unreliable and incomplete. As a result, they will 
continue to be without reliable information on contracts and contractor 
personnel that can be used to help address some longstanding contract 
management challenges. 

Messrs. Chairmen, this concludes my prepared statement. I would be 
happy to respond to any questions you or the other commissioners may 

GAO Contacts and Acknowledgement: 

For further information about this statement, please contact John P. 
Hutton (202) 512-4841 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 include Johana R. Ayers, Assistant Director; Noah 
Bleicher; Raj Chitikila; Christopher Kunitz; Heather Miller; and Morgan 
Delaney Ramaker. 

[End of section] 


[1] GAO, Contingency Contracting: DOD, State, and USAID Continue to 
Face Challenges in Tracking Contractor Personnel and Contracts in Iraq 
and Afghanistan, [hyperlink,] 
(Washington, D.C.: Oct. 1, 2009). 

[2] Pub. L. No. 110-181, § 863. 

[3] GAO, Contingency Contracting: DOD, State, and USAID Are Taking 
Actions to Track Contracts and Contractor Personnel in Iraq and 
Afghanistan, [hyperlink,] 
(Washington, D.C.: Apr. 1, 2009). 

[4] Pub. L. No. 110-181, § 861, as amended by Pub. L. No. 110-417, § 
854 (2008). 

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

[6] GAO, Afghanistan Reconstruction: Deteriorating Security and Limited 
Resources Have Impeded Progress; Improvements in U.S. Strategy Needed, 
[hyperlink,] (Washington, D.C.: 
June 2, 2004) and Afghanistan Reconstruction: Despite Some Progress, 
Deteriorating Security and Other Obstacles Continue to Threaten 
Achievement of U.S. Goals, [hyperlink,] (Washington, D.C.: July 28, 

[7] GAO, Rebuilding Iraq: Actions Needed to Improve Use of Private 
Security Providers, [hyperlink,] 
(Washington, D.C.: July 28, 2005). 

[8] GAO, Defense Budget: Need to Strengthen Guidance and Oversight of 
Contingency Operations Costs, [hyperlink,] (Washington, D.C.: May 21, 

[9] [hyperlink,]. 

[10] An 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. Contractor personnel need SPOT-generated LOAs 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. 

[11] CENTCOM is one of DOD's unified combatant commands. It is 
responsible for overseeing U.S. security interests in 20 countries-- 
including Iraq and Afghanistan--that stretch from the Arabian Gulf 
region into Central Asia. CENTCOM initiated its quarterly census of 
contractor personnel in June 2007 as an interim measure until SPOT is 
fully implemented. The census relies on contractor firms to self-report 
their personnel data to DOD components, which then aggregate the data 
and report them to CENTCOM at the end of each quarter. 

[12] Contract numbers consist of 13 alphanumeric characters. We 
considered a contract number invalid if the contract number entered 
into SPOT had a different number of characters. 

[13] [hyperlink,]. 

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink,]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink,] 
and select "E-mail Updates." 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO’s Web site, 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional 

To Report Fraud, Waste, and Abuse in Federal Programs: 


Web site: [hyperlink,]: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: