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GAO-12-854R: 

United States Government Accountability Office: 
Washington, DC 20548: 

August 1, 2012: 

The Honorable Claire McCaskill:
Chairman:
The Honorable Kelly Ayotte:
Ranking Member:
Subcommittee on Readiness and Management Support:
Committee on Armed Services:
United States Senate: 

The Honorable Jim Webb:
United States Senate: 

Subject: Contingency Contracting: Agency Actions to Address 
Recommendations by the Commission on Wartime Contracting in Iraq and 
Afghanistan: 

Over the past decade, the Department of Defense (DOD), Department of 
State (State), and U.S. Agency for International Development (USAID) 
have relied extensively on contractors to help carry out their 
missions in Iraq and Afghanistan. Between fiscal year 2002 and fiscal 
year 2011, these agencies reported combined obligations of 
approximately $159 billion for contracts with a principal place of 
performance in either country. Contractor personnel have provided a 
range of services related to supporting troops and civilian personnel 
and to overseeing and carrying out reconstruction efforts, such as 
interpretation, security, weapon systems maintenance, intelligence 
analysis, facility operations support, advice to Iraqi and Afghan 
ministries, and road and infrastructure construction. The use of 
contractors in contingency operations such as these is not new, but 
the number of contractors and the type of work they are performing in 
Iraq and Afghanistan represent an increased reliance on contractors to 
support agency missions. 

Congress established the Commission on Wartime Contracting in Iraq and 
Afghanistan (CWC) in 2008 to assess contracting in Iraq and 
Afghanistan and provide recommendations to Congress to improve the 
contracting process.[Footnote 1] The CWC was directed by Congress to 
assess contracting in Iraq and Afghanistan for reconstruction, 
logistics, and security functions; examine the extent of waste, fraud, 
and abuse; and provide recommendations to Congress to improve various 
aspects of contingency contracting, including defining requirements 
and identifying, addressing, and providing accountability for waste, 
fraud, and abuse. 

Led by six commissioners appointed by congressional leadership and two 
commissioners appointed by the president, the CWC conducted its work 
between 2008 and 2011.[Footnote 2] In a series of interim and special 
reports and in a culminating final report, the CWC made multiple 
recommendations about contracting practices in current and future 
contingency environments.[Footnote 3] The recommendations in the final 
report were organized into 15 strategic areas related to improvements 
in contingency contracting. Some recommendations were made 
specifically to DOD, State, USAID; others were made to Congress; and 
the remaining recommendations were not made to a specific entity. Only 
one recommendation from the final report included a date by which 
implementation should be completed, with the CWC noting that some 
reforms will take many years for agencies to fully implement because 
of the complexity of the issues involved. 

DOD, State, and USAID have taken different management approaches for 
addressing the CWC's recommendations. For example, at DOD, the Under 
Secretary of Defense (Acquisition, Technology, and Logistics) 
established a senior-level board that used a formal process for 
determining which recommendations DOD would address and assigning 
responsibility for addressing them to specific DOD offices. The board 
also monitors the status of efforts to implement the recommendations. 
At State, officials told us that the Office of the Under Secretary for 
Management has general responsibility for coordinating the 
department's efforts to address the CWC's recommendations. These 
officials explained that when the CWC's final report was issued, the 
Office of the Under Secretary for Management assigned responsibility 
to bureaus and offices with related portfolios for determining and 
reporting on how the department was addressing the recommendations at 
a strategic level. They explained, however, that State does not have a 
formal process for assigning responsibility for or monitoring the 
implementation of the specific recommendations. USAID has taken a 
decentralized approach to the CWC recommendations. The agency does not 
have an office designated for addressing or monitoring the efforts to 
address the CWC's recommendations. According to a senior USAID 
official, the Office of Acquisition and Assistance is responsible for 
addressing recommendations related to agencywide procurement policy. 
However, USAID officials explained that efforts to respond to other 
CWC recommendations are more appropriately addressed at the individual 
mission level, as each country has specific needs and circumstances. 

In response to your request, we determined whether DOD, State, and 
USAID have taken or planned actions that directly align with 
recommendations the CWC made in its final and last two special 
reports--including those recommendations directed to one or more of 
the agencies and those recommendations not directed to a specific 
entity but that one or more of the agencies considered applicable to 
them. We also described agency positions on recommendations the CWC 
made to Congress when the agencies provided their positions to us. 

For our review, we analyzed the CWC's final report and last two 
special reports to identify the total number of recommendations made. 
That total comprises the (1) 48 recommendations that the CWC made in 
the August 2011 final report, some of which were based on 
recommendations the CWC made in its interim and special reports and 
(2) 3 recommendations that the CWC made in Special Report 4 (issued in 
March 2011) that related to the transition to a civilian-led presence 
in Iraq.[Footnote 4] Of these 51 total recommendations, 19 were 
directed to DOD, State, and/or USAID; 15 were directed to Congress; 
and 17 were not directed to a specific entity. For the recommendations 
not directed to a specific entity, we relied on each agency to 
identify which recommendations were applicable to it. In total, 30 
recommendations were identified as applicable to DOD; 27 as applicable 
to State; and 25 as applicable to USAID. We did not evaluate the CWC's 
recommendations; our focus was on the actions the agencies took 
related to the recommendations. Specifically, we categorized the 
agencies' respective efforts to address each applicable recommendation 
as either (1) "actions taken or planned that directly align with the 
specific recommendation" or (2) "no actions taken or planned that 
directly align with the specific recommendation." To determine whether 
each agency had taken or planned actions that directly aligned with 
each applicable recommendation, we collected the agencies' self-
reported information using a data collection template; 
corroborated reported actions with related documentation, when 
available; and conducted structured interviews with knowledgeable 
agency officials to clarify responses. We categorized the agencies' 
efforts as "actions taken or planned that directly align with the 
specific recommendation" even when the agencies' actions (1) were 
started or completed before the issuance of the CWC's final or last 
two special reports or (2) only partially addressed the 
recommendation, such as when an agency took an action that directly 
aligned with the recommendation in either Iraq or Afghanistan but not 
agencywide, or when an agency took an action that directly aligned 
with a portion of a recommendation but did not address another portion 
of the recommendation. For instances in which agencies reported not 
having taken or planned actions that directly align with a specific 
recommendation, we documented the rationale for this course of action 
and reviewed available documentation. However, we did not assess the 
appropriateness or sufficiency of any actions taken or planned by the 
agencies. Finally, we did not assess the agencies' positions on the 
CWC's recommendations to Congress, although we included the agencies' 
positions on those recommendations when the agencies provided them to 
us. 

We conducted this performance audit from February 2012 to August 2012 
in accordance with generally accepted government auditing standards. 
These 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. 

In summary, DOD reported having taken or planned actions that directly 
align with about half of the CWC recommendations applicable to it, and 
State and USAID each reported having taken or planned actions that 
directly align with about one-third of the recommendations applicable 
to each of them. Officials from the three agencies explained that for 
the remaining recommendations no actions were taken or planned that 
directly aligned with the specific recommendation. This was because, 
for example, the agencies had determined that existing policies or 
practices already meet the intent of the recommendations or had 
disagreed with the recommendations. The following are examples of 
actions that DOD, State, and USAID have taken or planned that directly 
align with specific CWC recommendations: 

* DOD issued a final rule to amend the Defense Federal Acquisition 
Regulation Supplement (DFARS) in February 2012 to improve the 
oversight of contractor business systems, including the ability to 
withhold a percentage of payments on certain covered contracts when a 
contractor's business systems contain significant deficiencies. This 
action aligns with the CWC's recommendation to strengthen authority to 
withhold contract payments for inadequate business systems.[Footnote 5] 

* State issued guidance in October 2011 describing a process for 
drafting a determination memorandum each time the potential need to 
suspend or debar a contractor arises, including for those cases in 
which no action against the contractor is ultimately recommended. This 
guidance aligns with a CWC recommendation to strengthen enforcement 
tools by requiring a written rationale for not pursuing a proposed 
suspension and debarment.[Footnote 6] 

* USAID issued guidance in January 2012 that requires sustainability 
analysis for all projects and developed a tool that contains 
questions, issues, and examples to help USAID project design teams 
think through project sustainability objectives and maximize 
sustainable outcomes. This guidance aligns with a CWC recommendation 
related to project sustainability (i.e., ensuring that host nations 
will be able to operate and maintain U.S.-funded projects on their 
own).[Footnote 7] 

The following are examples of instances in which DOD, State, and USAID 
reported not having taken or planned actions that directly align with 
specific CWC recommendations: 

* The three agencies generally have not and do not plan to elevate the 
positions and expand the authority of officials responsible for 
contingency contracting as recommended by the CWC. Officials from DOD, 
State, and USAID explained that they regard existing organizational 
structures as meeting the recommendations' intent. For example, DOD 
officials stated that the CWC's recommendation to create a new 
directorate for contingency contracting is not needed because DOD 
already has a significant amount of senior leadership involvement and 
support for operational contract support. Similarly, State officials 
stated that there were no plans to establish a separate bureau led by 
an Assistant Secretary for Acquisition as recommended by the CWC 
because their current organizational structure, in which contingency 
contracting is overseen by the Assistant Secretary for Administration 
in coordination with the Under Secretary for Management, is sufficient 
to meet the department's needs. USAID officials stated that there were 
no plans to make the chief acquisition officer position a non-career 
appointment as recommended because they believe that having a career 
foreign service officer in that role provides the necessary knowledge 
of the agency's unique mission and acquisition needs. 

* None of the three agencies agree with the recommendation requiring 
performance incentives and performance assessments as tools for 
preventing human trafficking by contractors. Officials from each 
agency explained that contractors should not need incentives to comply 
with anti-trafficking laws and other ongoing initiatives, such as 
training for contract administration personnel, were better tools to 
help combat human trafficking. 

In enclosure I, we list the 51 CWC recommendations and describe and 
categorize DOD's, State's, and USAID's specific efforts to address 
each applicable recommendation as either (1) "actions taken or planned 
that directly align with the specific recommendation" or (2) "no 
actions taken or planned that directly align with the specific 
recommendation." We also summarize the positions provided by the 
agency for these recommendations and for the recommendations to 
Congress for which the agencies provided positions. 

Agency Comments: 

We requested comments on a draft of this report from DOD, State, and 
USAID. The three agencies informed us that they had no comments on the 
draft's findings and provided us with technical comments that we 
incorporated into the final report as appropriate. 

We are sending copies of this report to the Secretary of Defense, the 
Secretary of State, and the Administrator of the U.S. Agency for 
International Development, as well as interested congressional 
committees. In addition, the report will be available at no charge on 
the GAO website at [hyperlink http://www.gao.gov]. 

If you or your staff have any questions, please contact us at (202) 
512-4841 or huttonj@gao.gov or (202) 512-5431 or russellc@gao.gov. 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. Key contributors 
to this report are listed in enclosure II. 

Signed by: 

John P. Hutton: 
Director: 
Acquisition and Sourcing Management: 

Signed by: 

Cary B. Russell:
Acting Director Defense Capabilities and Management: 

Enclosures--2: 

[End of section] 

Enclosure I: Summary of Agency Actions Related to Commission on 
Wartime Contracting Recommendations: 

Between March 2011 and August 2011 the Commission on Wartime 
Contracting in Iraq and Afghanistan (CWC) issued two special reports 
and a culminating final report to Congress, making multiple 
recommendations about contracting practices in current and future 
contingency environments.[Footnote 8] In the March 2011 Special Report 
4, the CWC addresses the transition to a civilian-led presence in Iraq 
and makes 3 recommendations. In August 2011, the CWC issued its final 
report in which it built on recommendations made in the interim and 
special reports it had issued since 2009, including recommendations 
made in Special Report 5, which it issued in June 2011.[Footnote 9] In 
the final report, the CWC made 48 recommendations across 15 strategic 
areas. Of the 51 total recommendations that the CWC made in Special 
Report 4 and in the final report, 19 were directed to the Department 
of Defense (DOD), the Department of State (State), and/or the U.S. 
Agency for International Development (USAID); 15 were directed to 
Congress; and the remaining 17 were not directed to a specific entity. 
For the recommendations not directed to a specific entity, we relied 
on each agency to identify which recommendations were applicable to 
it. In total, 30 recommendations were identified as applicable to DOD; 
27 as applicable to State; and 25 as applicable to USAID. 

In this enclosure, we summarize the actions that DOD, State, and USAID 
took that are related to the CWC recommendations. We did not evaluate 
the CWC's recommendations; our focus was on the actions the agencies 
took related to the recommendations. Specifically, we categorize the 
agencies' efforts as either: (1) "actions taken or planned that 
directly align with the specific recommendation" or (2) "no actions 
taken or planned that directly align with the specific 
recommendation." To determine whether each agency had taken or planned 
actions that directly aligned with each applicable recommendation, we 
collected the agencies' self-reported information using a data 
collection template; corroborated reported actions with related 
documentation, when available; and conducted structured interviews 
with knowledgeable agency officials to clarify responses. We 
categorized the agencies' efforts as "actions taken or planned that 
directly align with the specific recommendation" even when the 
agencies' actions (1) were started or completed before the issuance of 
the CWC's final or last two special reports or (2) only partially 
addressed the recommendation, such as when an agency took an action 
that directly aligned with the recommendation in either Iraq or 
Afghanistan but not agencywide, or when an agency took an action that 
directly aligned with a portion of a recommendation but did not 
address another portion of the recommendation. For instances in which 
agencies reported not having taken or planned actions that directly 
align with a specific recommendation, we documented the rationale for 
this course of action and reviewed available documentation. However, 
we did not assess the appropriateness or sufficiency of any actions 
taken or planned by the agencies. We also summarize any agency 
positions on recommendations the CWC made to Congress if they were 
provided to us, but we did not assess these positions. 

In tables 1 through 15, below, we: 

* list the 48 recommendations the CWC made in its final report, 
grouped by the 15 strategic areas identified by the CWC; 

* note the entity to which the recommendation is directed; 

* indicate when a recommendation is not applicable to a particular 
agency, either because the recommendation was directed to Congress, 
the recommendation was specifically directed to another agency, or the 
agency reported the recommendation was not applicable to it; 
and: 

* summarize related information provided by the agencies. 

Table 1: CWC Strategic Area 1--Use Risk Factors in Deciding whether to 
Contract in Contingencies: 

Recommendation directed to agency heads involved in a contingency: 1a; 
Issue and ensure implementation of policy guidance for using risk 
factors such as those listed above, as well as those described in the 
Office of Federal Procurement Policy (OFPP) draft policy letter of 
March 2010 and Department of Defense Instruction 1100.22 to provide 
guidance on what functions are appropriate to contract for in a 
contingency setting[A]; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
DOD has issued guidance for operational contract support planning 
applicable to contingency settings, providing for risk assessments as 
part of the operational planning process. Specifically, considerations 
for contracting risks, such as proper vetting, are included in joint 
doctrine and DOD instructions.[B] DOD also established the Joint 
Contingency Acquisition Support Office in part to assist combatant 
commands in planning for and assessing risk of contracted support; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials did not identify actions taken or planned that 
directly align with this recommendation but stated that existing 
guidance and practice meets the intent. State issued guidance in May 
2012 on inherently governmental functions that the department 
considers applicable to both non-contingency and contingency 
contracting, although the guidance does not directly address the risk 
factors cited by the CWC.[C] Department officials further noted that 
measures have been incorporated into contract terms and operating 
procedures that address risk factors. For example, State officials 
noted that the department's Worldwide Protective Services contract, 
awarded in September 2010, includes contract terms, such as standards 
of conduct and training, aimed at improving professionalism and 
lessening the risk of offending the sensibilities of the local 
population; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation. According to USAID officials, 
the agency is reviewing its policies on inherently governmental 
functions in light of the OFPP policy letter. However, USAID officials 
stated that they do not expect any changes to their policies will be 
specific to contingency settings. 

Recommendation directed to agency heads involved in a contingency: 1b; 
Provide funding and direction for agencies involved in contingency 
operations to identify a trained, experienced, and deployable cadre 
for stabilization-and-reconstruction functions in areas of contingency 
operations so that the government has an alternative to contracting 
for performance of critical or sensitive functions; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated that the department established a working group 
in February 2012 to address deployable cadre manpower requirements 
using civilians in support of contingency operations. The goal is for 
this civilian workforce to be pre-identified, trained, cleared, 
equipped, and ready to deploy to the extent practical in support of 
combat operations by the military; contingencies; emergency operations; 
humanitarian missions; disaster relief; restoration of order; drug 
interdiction; and stability operations. Implementation of this 
civilian program model is set to begin in fiscal year 2013; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials did not identify actions taken or planned that 
directly align with this recommendation but stated that the 
department's existing organizational structure meets the intent. State 
identified its establishment of the Bureau of Conflict and 
Stabilization Operations in November 2011 to focus on conflict 
prevention, crisis response, and stabilization activities as 
responsive to the recommendation, although officials noted that State 
does not plan to formally establish a deployable cadre as recommended 
by the CWC. State officials added that they do not believe that the 
department's contracting for support in Iraq or Afghanistan has 
resulted in a loss of organic capability; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation but stated that the agency's 
existing organizational structure meets the intent. Specifically, a 
senior official noted that USAID's Bureau for Democracy and 
Humanitarian Assistance's Office of Civilian Response provides for 
reconstruction and stabilization support. 

Recommendation directed to agency heads involved in a contingency: 1c; 
Provide a strategic plan for deploying these cadres that includes 
provisions for mandatory deployability of civilian members, and is 
supported by a back-up capability for rapidly making temporary hires 
for large-scale or long-term contingency operations; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated that the development of this strategic plan would 
be considered as part of the related effort identified above in 1b; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials did not identify actions taken or planned that 
directly align with this recommendation but stated that the 
department's existing practices meet the intent. State officials noted 
that while the department is not developing a specific strategic plan, 
all foreign service personnel can be deployed to contingency locations; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 

USAID officials did not identify actions taken or planned that 
directly align with this recommendation but stated that the agency's 
existing organizational structure meets the intent. Specifically, a 
senior official noted that USAID's Bureau for Democracy and 
Humanitarian Assistance's Office of Civilian Response provides for 
reconstruction and stabilization support. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[A] In its final report, the CWC outlined characteristics of risk in 
contracting for a contingency, focusing on the broad areas of 
operational, political, and financial risk. According to the CWC, 
operational, political, and financial risk factors include risks to: 
(1) maintaining agencies' critical organic or core capabilities; (2) 
U.S. goals and objectives, such as from behavior that injures innocent 
members of the local population or outrages their sensibilities; (3) 
the government's ability to control costs, waste, fraud, abuse, and 
conflicts of interest, among others. In its final report, the CWC also 
outlined situational risks, which it described as factors that could 
affect risk assessment and should be considered by the government 
along with operational, political, and financial risks. Situational 
risks include: (1) operating in a combat zone or insurgent-threat area; 
(2) lack of effective federal oversight in the area of operations; 
and (3) inadequate accounting, financial, and business systems among 
contractors and subcontractors, among others. See also, OFPP Policy 
Letter 11-01: Performance of Inherently Governmental and Critical 
Functions, 76 Fed. Reg. 56,227 (Sept. 12, 2011). Department of Defense 
Instruction 1100.22, Guidance for Determining Workforce Mix, April 6, 
2007. 

[B] International Security Assistance Force Joint Command Operations 
in Afghanistan, Construction Contracting Guidelines for Afghanistan 
(Oct. 9, 2010); Chairman, Joint Chiefs of Staff, Joint Publication 4-
10, Operational Contract Support (Washington, D.C.: Oct. 17, 2008); 
Chairman of the Joint Chiefs of Staff Notice 4130.01, Guidance for 
Combatant Commander Employment of Operational Contract Support 
Enabler--Joint Contingency Acquisition Support Office (Dec. 20, 2011). 

[C] Department of State Office of the Procurement Executive, 
Procurement Information Bulletin No. 2012-11, Preventing Contractor 
Performance of Inherently Governmental Functions, May 9, 2012. 

[End of table] 

Table 2: CWC Strategic Area 2--Develop Deployable Cadres for 
Acquisition Management and Contractor Oversight: 

Recommendation directed to agency heads: 2a; 
Provide funding and direction to establish a trained, experienced, and 
deployable cadre for acquisition-management and contractor-oversight 
functions in areas of contingency operations so that the government 
has an alternative to relying on contractors for acquisition 
management and oversight; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated that resourcing and direction to establish a 
deployable cadre for acquisition-management and contractor-oversight 
functions is currently being considered as part of the related effort 
identified in 1b above and will be addressed in a comprehensive 
operational contract support action plan, scheduled for completion in 
September 2012, to guide capital planning and budget preparation; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials stated the department does not plan to implement this 
recommendation. A State official testified in September 2011 that the 
department does not see a separate contingency contracting acquisition 
cadre as an efficient or necessary model and the department's existing 
acquisition structure and working capital fund provide sufficient 
expertise and funding for contingency operations; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation but stated that the agency's 
existing organizational structure meets the intent. USAID officials 
stated that the agency's contracting and agreement officers currently 
have the capability to be deployed and work in contingency 
environments. The Office of Acquisition and Assistance maintains a 
foreign operations unit responsible for supporting overseas 
contracting efforts, and USAID's preference is to strengthen this unit 
rather than direct resources elsewhere. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[End of table] 

Table 4: CWC Strategic Area 3--Phase out the Use of Private Security 
Contractors for Certain Functions: 

Recommendation not directed to specific entity: 3a; 
Phase out the use of host-nation private security contractors in 
Afghanistan for the convoys on high-volume roads that the insurgency 
controls or contests; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
Pursuant to Afghan government requirements, the department is in the 
process of transitioning selected private convoy security contracts to 
the Afghan Public Protection Force.[A] Additionally, DOD officials 
stated that U.S. Central Command and U.S. Forces-Afghanistan policies 
and guidance require consideration of the likelihood of private 
security contractors becoming involved in combat or situations likely 
to escalate into combat when determining the appropriateness of using 
contractors; 
State: Not applicable; 
State officials stated that this recommendation is not applicable 
because they interpreted it being directed towards DOD; 
USAID: Actions taken or planned that directly align with the specific 
recommendation;
Officials from the Office of Acquisition and Assistance/Afghanistan 
reported that as of March 20, 2012, all USAID awardees are required to 
use the Afghan Public Protection Force for all security services.[A]. 

Recommendation not directed to specific entity: 3b; 
Evaluate each static-security site to assess the risk associated with 
the use of contractors. Where the military commander determines there 
is a high risk, use military forces. Where the commander determines 
the high risk is specifically the result of using local-national 
contractors, use military forces or third-country national private 
security contractors for security; DOD: No actions taken or planned 
that directly align with the specific recommendation; DOD officials 
did not identify actions taken or planned that directly align with 
this recommendation. While DOD officials stated that the department 
expects contract static security guards to transition to the Afghan 
Public Protection Force in 2013 and that U.S. Forces-Afghanistan is 
monitoring the transition effort, officials did not identify specific 
efforts to evaluate each static security site to determine whether 
military forces should provide security at specific, high-risk sites; 
State: Not applicable; 
State officials stated that this recommendation is not applicable 
because they interpreted it being directed towards DOD; 
USAID: Not applicable; 
USAID officials stated that this recommendation is not applicable. 
They explained that the protection of USAID personnel and facilities 
is managed by State's Bureau of Diplomatic Security, and the agency 
does not directly contract for security services. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[A] In August 2010, the President of Afghanistan issued Presidential 
Decree 62 (PD 62), which directed the dissolution of private security 
contractors. In the wake of the decree, a bridging strategy was 
developed to facilitate the transition away from private security 
contractors in Afghanistan to the Afghan Public Protection Force 
(APPF), which existed within the Ministry of Interior prior to PD 62. 
The APPF is a Ministry of Interior security force organized under the 
Deputy Minister and consists of a national headquarters and seven zone 
headquarters. As a fee-for-service government owned and operated 
security force, it secures international, governmental, and non-
governmental operations, sites, and facilities. 

[End of table] 

Table 4: CWC Strategic Area 4--Improve Interagency Coordination and 
Guidance for Using Security Contractors in Contingency Operations: 

Recommendation directed to entity specified: 4a; 
Hold the ambassador, USAID mission director, and military commanders 
responsible for making, publicizing, and revising their determinations 
of security-contracting appropriateness as conditions change, giving 
particular consideration to the geographic, temporal, and 
organizational proximity to armed conflict; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
In July 2009, DOD published guidance for all U.S. government private 
security contractors working in contingency operations. The guidance, 
updated in August 2011, requires Geographic Combatant Commanders in 
contingency environments to issue guidance and procedures for the 
selection, training, accountability, and equipping of private security 
personnel[A]; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials stated the department does not plan to implement this 
recommendation. Department officials explained that contracting 
decisions are made with input from across the department, including 
the ambassador and the Bureau of Diplomatic Security; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation. Officials explained that 
security issues at the mission level are the responsibility of State's 
Bureau of Diplomatic Security. 

Recommendation directed to entity specified: 4b; 
When private security or other contractors are to be armed, they 
should be overseen by government employees and tracked in a 
centralized system, as is done in Iraq; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
In 2007, DOD designated the Synchronized Predeployment and Operational 
Tracker system as its primary system for collecting data on contractor 
personnel deployed with U.S. forces. Currently, DOD requires the use 
of the system for all personnel performing private security functions 
in Iraq or Afghanistan. Additionally, DOD policies generally discuss 
the oversight of private security and other contractors by military or 
DOD civilian personnel; 
State: Actions taken or planned that directly align with the specific 
recommendation; 
Under State policy, all applicable contracts for private security in 
Iraq and Afghanistan are required to include a clause requiring 
personnel to be entered into the Synchronized Predeployment and 
Operational Tracker system.[B] State contract oversight planning 
documents also call for these contractors to be operationally 
supervised by direct hire government personnel; 
USAID: Not applicable; 
USAID officials stated that this recommendation is not applicable 
because the agency does not directly contract for security services. 

Recommendation directed to entity specified: 4c; 
Reliance on private security contractors should be accompanied by 
greater use and emphasis on vetting, training, authorizing arms, and 
weapons control; 
post-convoy debriefing, locational tracking, and video monitoring; 
and more thorough and comprehensive management; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
DOD has issued and updated DOD Instruction 3020.50, which provides 
instructions to geographic combatant commanders on their requirements 
to address some of the issues specified in the recommendation.[A] 
Additionally, DOD directed use of a new quality management standard 
for private security contractor operations that includes specific 
measurable elements for vetting, training, and procurement and 
management of weapons. Further, in June 2012, DOD finalized a 
regulation that establishes minimum processes and requirements for the 
selection, accountability, training, equipping and conduct of 
personnel performing private security functions under DOD contracts[C]; 
State: Actions taken or planned that directly align with the specific 
recommendation; 
Officials from State's Bureau of Diplomatic Security stated that all 
of State's private security contractor personnel working under its 
Worldwide Protective Services contract are vetted and must be trained 
in accordance with the terms of the contract. According to the 
department, operational control and monitoring exceeds the CWC 
recommendation; 
USAID: Not applicable; 
USAID officials stated that this recommendation is not applicable 
because the agency does not directly contract for security services. 

Recommendation directed to entity specified: 4d; 
Execute an interagency agreement to provide guidance on security 
contracting; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials did not identify actions taken or planned that directly 
align with this recommendation. However, DOD officials stated that the 
recommendation has been addressed through Section 159 of Title 32 of 
the Code of Federal Regulations, which requires coordination between 
DOD and State to establish processes for the selection, training, 
equipping, and conduct of private security personnel in combat 
operations or other significant military operations.[D] These 
provisions are applicable to all future areas of operations that 
require enhanced coordination of private security contactor personnel; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials stated the department does not plan to implement this 
recommendation. Officials explained that State does not concur that an 
interagency agreement is necessary to provide guidance on security 
contracting. Department officials stated that the Overseas Security 
Policy Board, which State chairs and of which both DOD and USAID are 
members, was a more appropriate forum for addressing the use of 
security contractors in future contingencies; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation. 

Recommendation directed to entity specified: 4e; 
DOD, State, and USAID should develop and enter into a standing 
interagency memorandum of agreement, incorporating lessons and best 
practices learned in Iraq and Afghanistan, to provide guidance in use 
of private security contractors in future contingencies; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials did not identify actions taken or planned that directly 
align with this recommendation. However, DOD officials stated that the 
recommendation has been addressed through Section 159 of Title 32 of 
the Code of Federal Regulations, which requires coordination between 
DOD and State to establish processes for the selection, training, 
equipping, and conduct of private security personnel in combat 
operations or other significant military operations.[D] These 
provisions are applicable to all future areas of operations that 
require enhanced coordination of private security contactor personnel;
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials stated the department does not plan to implement this 
recommendation. According to officials, a specific memorandum of 
agreement is not necessary to share best practices, lessons learned, 
or other information between agencies colocated overseas. The 
department stated that existing mechanisms, such as the Overseas 
Security Policy Board, and standing working groups integral to 
overseas missions, such as the Country Team and Emergency Action 
Committees, provide effective forums for the sharing of information, 
best practices, and lessons learned; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation. 

Recommendation directed to entity specified: 4f; 
This standing memorandum of agreement should be modified within 90 
days of a declared combat operation or other contingency to 
specifically address the needs and circumstances of that operation; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials did not identify actions taken or planned that directly 
align with this recommendation. However, DOD officials stated that the 
recommendation has been addressed through Section 159 of Title 32 of 
the Code of Federal Regulations, which requires coordination between 
DOD and State to establish processes for the selection, training, 
equipping, and conduct of private security personnel in combat 
operations or other significant military operations.[D] These 
provisions are applicable to all future areas of operations that 
require enhanced coordination of private security contactor personnel; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials stated the department does not plan to implement this 
recommendation. As noted above, department officials stated that a 
specific memorandum of agreement is not necessary to share best 
practices, lessons learned, or other information between agencies 
colocated overseas and that existing mechanisms for sharing of 
information, best practices, and lessons learned are sufficient; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[A] DOD Instruction 3020.50, Private Security Contractors (PSCs) 
Operating in Contingency Operations, Humanitarian or Peace Operations, 
or Other Military Operations or Exercises, July 22, 2009. The 
regulation was updated in August 2011 to incorporate changes made in 
the Duncan Hunter National Defense Authorization Act for Fiscal Year 
2009, Pub. L. No. 110-417, § 853 (2008) and the Ike Skelton National 
Defense Authorization Act for Fiscal Year 2011, Pub. L. No. 111-383, § 
832. 

[B] Department of State Office of the Procurement Executive, 
Procurement Information Bulletin No. 2008-15, Use of Synchronized 
Predeployment and Operational Tracker (SPOT) for Contractors 
Supporting and Diplomatic or Consular Mission Outside the United 
States, March 25, 2008. 

[C] Defense Federal Acquisition Regulation Supplement (DFARS); 
Contractors Performing Private Security Functions (Case 2011-D023). 
Final Rule, 77 Fed. Reg. 35,883 (June 15, 2012). 

[D] 32 C.F.R. § 159. 

[End of table] 

Table 5: CWC Strategic Area 5--Take Actions to Mitigate the Threat of 
Additional Waste from Unsustainability: 

Recommendation directed to officials at DOD, State, and USAID: 5a; 
Examine both completed and current projects for risk of sustainment 
failure and take appropriate action to cancel or redesign programs and 
projects that have no credible prospect of being sustained; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials did not identify actions taken or planned that directly 
align with this recommendation but stated that existing policies meet 
the intent. For example, while it has not examined completed or 
current projects, DOD has addressed sustainability considerations in 
joint doctrine published between 2009 and 2011 on stability 
operations, counterinsurgency, and foreign humanitarian assistance[A]; 
State: Actions taken or planned that directly align with the specific 
recommendation; 
Although State did not identify any departmentwide efforts that 
directly align with this recommendation, the Embassy in Kabul has 
taken such actions. Specifically, the Embassy has taken steps to 
identify projects that need to be sustained in order to position 
itself to make decisions about which projects will be sustained and 
how they will be sustained going forward. Department officials stated 
that State does not generally have large construction or 
infrastructure projects that would lend themselves to an analysis of 
sustainability; 
USAID: Actions taken or planned that directly align with the specific 
recommendation; 
According to a senior development official at the Embassy in Kabul, in 
response to Afghan-specific sustainability guidance issued in June 
2011, USAID conducted an analysis of 67 different projects for 
sustainability in Afghanistan, which should be finalized by the summer 
of 2012.[B] For this sustainability analysis, officials from USAID's 
Office of Afghanistan and Pakistan Affairs reported that the agency 
identified operating and maintenance costs, prospects for 
sustainability by the Afghan government, and options for cost 
recovery. These officials stated that if projects did not appear 
sustainable, USAID considered options to cancel or provide additional 
assistance. Officials from the Office of Iraq and Arabian Peninsula 
Affairs reported on a recent analysis the Iraq Mission completed for 
Congress that highlights Government of Iraq contributions to ongoing 
USAID projects. 

Recommendation directed to officials at DOD, State, and USAID: 5b; 
Ensure that any new requirements and acquisition strategies for 
projects or services to be handed over to a host nation include a 
detailed assessment of long-term costs and of host nations' ability 
and willingness to meet those costs; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated that by early 2013 the department plans to 
establish clarifying policy and guidance for setting acquisition 
strategies that must include long-term project sustainability for the 
host nation. Additionally, DOD officials stated that the department 
follows International Security Assistance Force Contracting Guidelines 
issued in October 2010 that require Afghan National Security Forces 
facilities to be sustainable in accordance with Afghan construction 
and maintenance capabilities; 
State: Actions taken or planned that directly align with the specific 
recommendation; 
Although State did not identify any departmentwide efforts that 
directly align with this recommendation, the department has taken such 
actions in Iraq. Specifically, guidance was implemented in Iraq in 
2009 that generally required cost-sharing with the Government of Iraq 
for new projects. The guidance also generally required the development 
of advance agreements with the Government of Iraq to ensure the host 
nation is able and willing to contribute financially to projects and 
to establish plans for transitioning responsibility for projects to 
the Government of Iraq or other Iraqi entities. Embassy officials in 
Afghanistan stated that they do not have such guidance; 
USAID: Actions taken or planned that directly align with the specific 
recommendation; 
USAID updated its agencywide project design guidance in January 2012 
to require sustainability analysis for all projects.[C] It also 
developed a tool that contains questions, issues, and examples to help 
USAID project design teams think through project sustainability 
objectives and maximize sustainable outcomes. 

Recommendation directed to officials at DOD, State, and USAID: 5c; 
Report to Congress by December 31, 2011, and annually thereafter, on 
analysis and proposed actions for mitigating sustainability risks; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated the department does not plan to implement this 
recommendation unless directed to do so by Congress, citing concern 
over the number of existing reporting requirements and congressional 
inquiries; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials stated the department does not plan to implement this 
recommendation unless directed to do so by Congress. Department 
officials stated that State does not generally have large construction 
or infrastructure projects that would lend themselves to an analysis 
of sustainability; 
USAID: Actions taken or planned that directly align with the specific 
recommendation; 
USAID is currently required to certify to the Committees on 
Appropriations before certain funds appropriated in the Consolidated 
Appropriations Act, 2012 may be obligated for assistance to 
Afghanistan.[D] Also, according to officials, USAID briefed its 
committees of jurisdiction on analysis and proposed actions for 
mitigating sustainability risks in its Afghanistan programs in 2011 
and in its Iraq programs in May 2012. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

Note: The CWC's Special Report 5, Sustainability: Hidden Costs Risk 
New Waste included the same recommendations. Therefore, we have not 
listed recommendations from Special Report 5 separately. 

[A] Chairman, Joint Chiefs of Staff, Joint Publication 3-07, Stability 
Operations (Washington, D.C.: Sept. 29, 2011); 
Joint Publication 3-24, Counter-insurgency Operations (Washington, 
D.C.: Oct. 5, 2009); 
Joint Publication 3-29, Foreign Humanitarian Assistance (Washington, 
D.C.: Mar. 17, 2009). 

[B] USAID, Administrator's Sustainability Guidance for USAID in 
Afghanistan (June 2011). 

[C] USAID Automated Directives System Section 200.3.1.5, Policy 
Directives and Required Procedures, Build in Sustainability from the 
Start (Feb. 10. 2012). 

[D] Consolidated Appropriations Act, 2012, Pub. L. No. 112-74 § 7046 
(2011). 

[End of table] 

Table 6: CWC Strategic Area 6--Elevate the Positions and Expand the 
Authority of Civilian Officials Responsible for Contingency 
Contracting at DOD, State, and USAID: 

Recommendation directed to entities as specified below: 6a; 
The CWC endorsed the House version of the National Defense 
Authorization Act for Fiscal Year 2012, which would have amended 
section 138(b) of Title 10 U.S.C, in part by (1) establishing an 
Assistant Secretary of Defense for Contingency Contracting; 
and (2) establishing an Office for Contingency Contracting headed by 
the Assistant Secretary of Defense for Contingency Contracting; 
DOD: Not applicable; 
While this recommendation relates to a congressional action, DOD 
officials stated they do not believe that consolidation of operational 
contract support responsibility in an Office for Contingency 
Contracting or an Assistant Secretary of Defense for Contingency 
Contracting is necessary because each DOD organization brings unique 
subject matter expertise to the oversight of contingency contracting. 
Additionally, DOD officials stated that senior leadership acknowledge 
the importance of operational contract support and are taking steps to 
communicate that message throughout the organization, with the 
Undersecretary of Defense (Acquisition, Technology, and Logistics) 
monitoring progress; 
State: Not applicable; 
USAID: Not applicable. 

Recommendation directed to entities as specified below: 6b; 
State should: (1) establish a separate Bureau of Acquisition led by an 
assistant secretary for acquisition who has a background as a 
qualified acquisition professional and who would be designated as the 
agency's chief acquisition officer, (2) ensure that the new bureau 
would have acquisition as its singular focus and primary mission, and 
(3) establish additional Senior Executive Service positions to support 
the bureau's work; 
DOD: Not applicable; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials stated the department does not plan to implement this 
recommendation. Officials explained that the department's current 
structure, in which contingency contracting is overseen by the 
Assistant Secretary for Administration in coordination with the Under 
Secretary for Management, is sufficient to meet the department's needs; 
USAID: Not applicable. 

Recommendation directed to entities as specified below: 6c; 
The chief acquisition officer within USAID should be a non-career 
appointment at an organizational level so as to facilitate advising 
and assisting the agency head; 
DOD: Not applicable; 
State: Not applicable; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials stated the agency does not plan to implement this 
recommendation. The USAID chief acquisition officer is a career 
appointment, and officials reported on no plans to change this 
arrangement, citing the institutional expertise, overseas experience, 
and organizational continuity provided by a senior foreign service 
career designation. 

Recommendation directed to entities as specified below: 6d; 
Congress should amend 41 USC 1702 to provide that the chief 
acquisition officer's duties include managing policy and monitoring 
contingency contracting; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Not applicable; 
While this recommendation is directed to Congress, USAID officials 
noted that the chief acquisition officer currently manages policy and 
monitors contingency contracting in practice. A senior USAID official 
disagreed with codifying the acquisition organization of USAID in 
statute, explaining that doing so would reduce the agency's 
flexibility to make future adjustments. 

Recommendation directed to entities as specified below: 6e; 
To elevate the role of contingency contracting within USAID, the chief 
acquisition officer should be identified as a "direct adviser" to the 
Administrator, a similar position to that of the chief financial 
officer and the chief information officer; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Actions taken or planned that directly align with the specific 
recommendation; 
According to officials, USAID plans to update its organizational chart 
to formally reflect the "dotted line" reporting relationship in which 
the chief acquisition officer is a direct advisor to the USAID 
Administrator, similar to the reporting relationships for the chief 
financial officer and chief information officer. Officials noted, 
however, that the chief acquisition officer will continue to formally 
report to the Assistant Administrator for Management. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[End of table] 

Table 7: CWC Strategic Area 7--Elevate and Expand the Authority of 
Military Officials Responsible for Contingency Contracting on the 
Joint Staff, the Combatant Commanders' Staffs, and in the Military 
Services: 

Recommendation directed to DOD: 7a; 
Extract operational contract support and other contract-support duties 
and responsibilities from J4 (Logistics) and create a J10 Directorate 
of Contingency Contracting at the Joint Staff in order to better 
support contracting in other directorates and missions such as 
intelligence, communications, linguistic support, and security; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials did not identify actions taken or planned that directly 
align with this recommendation but stated that the department's 
existing organizational structure meets the intent. The department 
stated it does not believe additional staff structure is needed due to 
already having a significant amount of senior leadership involvement 
and support for operational contract support. According to DOD, this 
leadership and support has resulted in guidance on operational 
planning, doctrine, policy, and resources being applied to 
institutionalization of operational contract support; 
State: Not applicable; 
USAID: Not applicable. 

Recommendation directed to DOD: 7b; 
Create functional alignment by establishing similar J10 organizations 
at the combatant commands and in the four military services; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated the department does not plan to implement this 
recommendation; 
State: Not applicable; 
USAID: Not applicable. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[End of table] 

Table 8: CWC Strategic Area 8--Establish a New, Dual-Hatted Senior 
Position at the Office of Management and Budget (OMB) and the National 
Security Council (NSC) Staff to Provide Oversight and Strategic 
Direction: 

Recommendation directed to Congress: 8a; 
Congress should create a position in the Administration for a single 
dual-hatted official to serve at OMB and on the NSC staff; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Not applicable. 

Recommendation directed to Congress: 8b; 
Congress should create a position in the Administration for a single 
dual-hatted official to ensure that each relevant agency has the 
necessary financial resources and policy oversight, as appropriate, to 
carry out its contingency-related mission, and that agencies' budgets 
are complementary rather than duplicative or conflicting. In OMB, this 
official should be a deputy director and thus a presidential appointee 
confirmed by the Senate; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Not applicable. 

Recommendation directed to Congress: 8c; 
Congress should create a position in the Administration for a single 
dual-hatted official to oversee and ensure coordination of interagency 
contingency operations, including contracting-related matters. At NSC, 
this senior official shall attend and participate in the meetings of 
the NSC as the principal advisor to the NSC on interagency contingency 
operations. This official should be a deputy national security adviser 
and deputy assistant to the President; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Not applicable. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[End of table] 

Table 9: CWC Strategic Area 9--Create a Permanent Office of Inspector 
General for Contingency Operations: 

Recommendation directed to Congress: 9a; 
Congress should establish and fund a permanent inspector general for 
contingency operations to operate with a small staff in collaboration 
with agency inspectors general to regularly assess the adequacy of 
agency planning and readiness for contingencies, to be ready to deploy 
at the outset of a new contingency, and to expand as necessary; 
DOD: Not applicable; 
State: Not applicable; 
While this recommendation is directed to Congress, State officials 
reported that they have concerns about the establishment of a new 
inspector general with responsibilities that overlap existing 
oversight entities because the same functions can be performed more 
effectively and efficiently through the coordinated efforts of 
existing agency inspectors general; 
USAID: Not applicable; 
While this recommendation is directed to Congress, USAID officials 
stated that other agencies can provide the necessary oversight, and as 
such, a new inspector general office would serve a redundant function. 

Recommendation directed to Congress: 9b; 
Congress should establish and fund a permanent inspector general for 
contingency operations to exercise audit and investigative authority 
over all functions (such as logistics, security, and reconstruction) 
and across DOD, State, USAID, and other agencies participating in 
contingency operations; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Not applicable. 

Recommendation directed to Congress: 9c; 
Congress should establish and fund a permanent inspector general for 
contingency operations to develop, plan, and, as appropriate, deliver 
investigative and oversight training targeted to contingency 
operations; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Not applicable. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[End of table] 

Table 10: CWC Strategic Area 10--Set and Meet Annual Increases in 
Competition Goals for Contingency Contracts: 

Recommendation directed to agency heads: 10a; 
Require competition reporting and goals for contingency contracts; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
In February 2012, DOD established the contingency competition goals as 
required by Section 844 of the National Defense Authorization Act for 
Fiscal Year 2012.[A] To facilitate the tracking of contingency 
contracts and ability to report on competition, DOD recently 
established a unique code in the Federal Procurement Data System-Next 
Generation for capturing contractual actions in support of DOD's 
efforts in Afghanistan. According to DOD officials, the department 
also has an interagency memorandum of agreement that enables it to 
create other such unique codes for any future contingencies; 
State: Actions taken or planned that directly align with the specific 
recommendation; 
Pursuant to a requirement in Section 835 of the Ike Skelton National 
Defense Authorization Act for Fiscal Year 2011, State reports jointly 
with DOD and USAID on the extent of competition for its Iraq and 
Afghanistan contracts.[B] State officials stated the department does 
not plan to implement the section of the recommendation that pertains 
to competition goals. Officials stated they have and track competition 
goals throughout the department but do not think a specific breakout 
for contingency contracts is necessary; 
USAID: Actions taken or planned that directly align with the specific 
recommendation; 
Pursuant to a requirement in Section 835 of the Ike Skelton National 
Defense Authorization Act for Fiscal Year 2011, USAID reports jointly 
with DOD and State on the extent of competition for its Iraq and 
Afghanistan contracts.[B] USAID officials stated the agency does not 
have or plan to establish separate competition goals for contingency 
contracts since the agency's existing policy on exceptions to 
competition applies across the majority of USAID's operating 
environments, including Critical Priority Countries such as Iraq and 
Afghanistan, with limited exceptions. 

Recommendation directed to agency heads: 10b; 
Break out and compete major subcontract requirements from omnibus 
support contracts; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
In February 2012, DOD mandated a review of omnibus contingency 
contracts in support of Operation Enduring Freedom as required by 
Section 844 of the National Defense Authorization Act for Fiscal Year 
2012[A]; 
State: Not applicable; 
State officials stated that this recommendation is not applicable 
because the department does not have large omnibus support contracts. 
Department officials noted, however, that contingency operations 
require the flexibility to craft a contracting strategy that fits the 
existing environment rather than mandating a single solution such as 
"compete major subcontracts"; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation but stated that the agency's 
existing policies meet the intent. Officials reported that the 
agency's current acquisition planning policies and practices are 
sufficient to guide decisions related to contract scope. Officials 
further explained that the agency does not regularly use omnibus 
support contracts in practice. 

Recommendation directed to agency heads: 10c; 
Limit contingency task-order performance periods; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated the department does not plan to implement this 
recommendation. Officials explained that a statutory limit of 10 years 
for task order contracts with defined exceptions already exists[C]; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials stated the department does not plan to implement this 
recommendation. Officials explained that State awards task order 
contracts with option periods and determinations are made to exercise 
contract options based on the best interests of the government. 
According to department officials, mandating shorter periods than 
required would increase the amount of contracting effort in 
contingency operations when resources are most constrained, resulting 
in a continuous cycle of solicitation and award; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials stated the agency does not plan to implement this 
recommendation. USAID acquisition officials reported task order 
performance periods are generally determined on a case-by-case basis 
based on the conditions of the specific situation in conjunction with 
longer-term development goals. 

Recommendation directed to agency heads: 10d; 
Reduce one-offer competitions; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials did not identify actions taken or planned that directly 
align with this recommendation. While DOD recently revised regulations 
to address acquisitions using competitive procedures in which only one 
offer is received, exemptions to this regulation include acquisitions 
in support of contingency operations.[D] Officials stated they plan to 
assess the impact that the revised regulatory coverage has on 
competition in fiscal year 2012 to determine if additional changes are 
needed for contingency operations or otherwise; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials did not identify actions taken or planned that 
directly align with this recommendation. According to State officials, 
State's Bureau of Administration is still discussing the best approach 
on this issue; 
USAID: Actions taken or planned that directly align with the specific 
recommendation; 
USAID developed a Vendor Communication Plan in 2012 that establishes 
greater outreach efforts to the partner community to, in part, 
increase the number of potential offerors and build in competition at 
the early stages of designing requirements and solicitations.[E]. 

Recommendation directed to agency heads: 10e; 
Expand competitions when only one task-order offer is received; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials did not identify actions taken or planned that directly 
align with this recommendation. While DOD recently revised regulations 
to address acquisitions using competitive procedures in which only one 
offer is received, exemptions to this regulation include acquisitions 
in support of contingency operations.[D] Officials stated they were 
unaware of any forthcoming guidance that would address contingencies; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials stated the department does not plan to implement this 
recommendation. State reported in its June 2011 response to the CWC's 
interim report that the determination to award a task order should be 
left to the contracting officer. The department noted that when all 
task order contract holders have been offered a fair opportunity to 
bid on a task order and only a single offer is received, re-
solicitation of the task order is unlikely to result in additional 
offers; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials stated the agency does not plan to implement this 
recommendation. Officials reported that such a policy would be 
disruptive in a contingency environment and is unnecessary in fair and 
open competitions. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[A] Pub. L. No. 112-81 (2011). Office of the Under Secretary of 
Defense (Acquisition, Technology, and Logistics) Contingency 
Competition Goals and Competition Reviews of Certain Omnibus 
Contracts, February 17, 2012. 

[B] Pub. L. No. 111-383. 

[C] 10 U.S.C. § 2304a(f). 

[D] DFARS; 
Only One Offer (Case 2011-D013). 77 Fed. Reg. 39,126 (June 29, 2012). 

[E] USAID, USAID Partner Community Outreach Plan, September 2011 to 
September 2012. 

[End of table] 

Table 11: CWC Strategic Area 11--Improve Contractor Performance-Data 
Recording and Use: 

Recommendation for Congress to direct agency heads to: 11a; 
Allow contractors to respond to, but not appeal, agency performance 
assessments; 
DOD: Not applicable; 
While this recommendation is directed to Congress, DOD officials 
stated that a contractor should have some right of appeal to a past 
performance assessment at a level above the contracting officer, 
especially to protect against an erroneous assessment; 
State: Not applicable; 
While this recommendation is directed to Congress, State officials 
noted that they agreed with the recommendation but suggested that any 
change to the performance assessment appeal process should be 
governmentwide; 
USAID: Not applicable; 
While this recommendation is directed to Congress, USAID officials 
stated that they agreed with the recommendation but that 
implementation would require a governmentwide change. 

Recommendation for Congress to direct agency heads to: 11b; 
Align past-performance assessments with contractor proposals; 
DOD: Not applicable; 
While this recommendation is directed to Congress, DOD officials 
stated they are concerned that the CWC's intent to limit the 
consideration of contractors' past-performance references to only 
those contracts that have been recorded in the government's past 
performance database would disadvantage certain groups of contractors, 
such as non-incumbent contractors, and prevent consideration of all 
relevant past performance information; 
State: Not applicable; 
While this recommendation is directed to Congress, State officials 
noted that they were concerned that the CWC's intent to limit the 
consideration of contractors' past-performance references to only 
those contracts that have been recorded in the government's past 
performance database may prevent consideration of relevant past 
performance, such as work conducted by contractors for foreign 
governments; 
USAID: Not applicable; 
While this recommendation is directed to Congress, USAID officials 
noted that they have concerns that implementation of this 
recommendation may negatively affect the ability of contractors 
without past performance on U.S. government contracts to compete for 
new contract awards. 

Recommendation for Congress to direct agency heads to: 11c; 
Require agencies to certify use of past-performance database; 
DOD: Not applicable; 
While this recommendation is directed to Congress, DOD noted that it 
is unclear who would certify the use of this data or the value that 
certification would provide. However, officials agreed that contractor 
past performance data need substantial improvement and plan to measure 
compliance with existing past performance reporting requirements; 
State: Not applicable; 
While this recommendation is directed to Congress, State officials 
noted that contractor past performance reporting must first be 
improved so the database is usable. State officials added that the 
department has taken steps to improve data inputs by centralizing its 
past performance reporting process; 
USAID: Not applicable; 
While this recommendation is directed to Congress, USAID officials 
stated that they were not certain who would certify use of the past 
performance database or the benefits that certification would provide. 
They noted that overall, they agreed with the need to improve the past 
performance assessment process and data. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[End of table] 

Table 12: CWC Strategic Area 12--Strengthen Enforcement Tools: 

Recommendation not directed to specific entity: 12a; 
(1) Revise regulations to lower procedural barriers to suspensions and 
debarments and (2) require a written rationale for not pursing 
proposed suspensions and debarments; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated the department does not plan to implement this 
recommendation. While DOD reported it supports strengthened 
enforcement tools, officials stated that they disagreed with the CWC's 
specific recommendation. DOD officials noted that they have concerns 
about requiring a written rationale for not pursuing proposed 
suspension and debarments, stating this provision might have a 
negative effect on the suspension and debarment official's discretion 
or result in de facto debarments, thereby potentially increasing the 
risk of litigation; 
State: Actions taken or planned that directly align with the specific 
recommendation; 
State issued guidance in October 2011 describing a process for 
drafting a determination memorandum each time the potential need to 
suspend or debar a contractor arises, including for those cases in 
which no action against the contractor is ultimately recommended.[A] 
State reported it disagrees that procedural barriers are an issue but 
suggested any related actions should be taken through the Interagency 
Suspension and Debarment Committee to ensure consistency across 
agencies; 
USAID: Actions taken or planned that directly align with the specific 
recommendation; 
Officials reported that in February 2011, USAID established the 
Compliance Division within its Office of Acquisition and Assistance to 
handle suspensions and debarments and work with USAID's Inspector 
General to address procedural barriers the agency had identified 
related to evidence gathering for potential suspensions or debarments. 
Officials reported that USAID's practice is to prepare a memo for all 
administrative actions, including for decisions not to pursue 
suspensions, proposed debarments, and debarments but did not cite a 
specific policy that required documenting such decisions. 

Recommendation not directed to specific entity: 12b; 
Make consent to U.S. civil jurisdiction a condition of contract award; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated that due to the complexity of the legal issues 
related to this recommendation, they have tasked a team to consider 
the recommendation. They also noted that Section 834 of the Ike 
Skelton National Defense Authorization Act for Fiscal Year 2011 
provided the Secretary of Defense authority to apply contract remedies 
in certain cases where contractors are not subject to U.S. 
jurisdiction[B]; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State has not taken or planned actions that directly align with this 
recommendation and officials stated a governmentwide change would be 
required. The officials added that they are not sure how this 
recommendation, which the CWC noted would allow for private parties to 
recover on certain claims arising out of conduct related to government 
contracts, would be enforced if implemented; 
USAID: Not applicable; 
USAID officials stated that they interpret this recommendation as 
being directed to Congress based on the direction of the same 
recommendation to Congress in the CWC's second interim report. USAID 
officials added that, assuming the intent of the recommendation is to 
establish jurisdiction beyond what is currently in place for 
contractors and sub-contractors, implementing it will require 
governmentwide changes. 

Recommendation not directed to specific entity: 12c; 
Expand the power of inspectors general; 
DOD: Not applicable; 
DOD officials stated that this recommendation is not applicable 
because they interpret it as being directed to Congress; 
State: Not applicable; 
State officials stated that this recommendation is not applicable 
because they interpret it as being directed to Congress; 
USAID: Not applicable; 
USAID Office of Inspector General officials stated that this 
recommendation is not applicable because a formal expansion of the 
inspectors' general powers would require congressional action. They 
explained their office has engaged both USAID and congressional staff 
on issues related to suspension and debarment and trafficking in 
persons and proposed ways to enhance oversight by the inspector 
general when necessary. 

Recommendation not directed to specific entity: 12d; 
Amend acquisition regulations to require contracting officer consent 
for the award of subcontracts valued at or above $300,000 to foreign 
companies when performance will predominately be conducted overseas in 
support of contingency operations; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated the department does not plan to implement this 
recommendation. Officials reported that DOD has considered the topic 
of subcontracting limits and concluded such limits would not be 
workable and have the potential to increase contracting actions, which 
could negatively impact the workload of the contracting and oversight 
workforce; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State has not taken or planned actions that directly align with this 
recommendation as State officials stated a governmentwide change would 
be required. The officials explained that they agree that contracting 
officers should require that a contractor obtain consent to 
subcontract under certain conditions and a change to the 
governmentwide Federal Acquisition Regulation should be made; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation but stated that the agency's 
existing practices meet the intent. Officials reported the agency 
adheres to relevant Federal Acquisition Regulation provisions related 
to consent to subcontract. In addition, as part of the Accountable 
Assistance for Afghanistan initiative, contracting officers in 
Afghanistan may restrict implementing partners from having more than 
two subcontract tiers without USAID approval. 

12e; 
Incentivize contingency contractors to end trafficking in persons by 
labor brokers and subcontractors by requiring prime contracts to 
include performance incentives and mandate that performance 
assessments include management of trafficking in persons; 
DOD: No actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated the department does not plan to implement this 
recommendation. Officials stated that the department is committed to 
combating trafficking in persons and implementing the department's 
"zero tolerance" policy but does not intend to incentivize contractors 
to do so. DOD identified numerous initiatives underway in this area, 
including policy mandates and awareness initiatives. For example, in 
November 2011, DOD published additional contract administration duties 
to maintain surveillance over contractor compliance with trafficking 
in persons requirements for all DOD contracts[C]; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State officials stated the department does not plan to implement this 
recommendation. Officials stated that State does not agree that 
incentivizing contractors with additional payments is the best way to 
accomplish the goals of the recommendation. Instead, State issued 
additional guidance and took action to strengthen anti-trafficking 
efforts. For example, State issued detailed contract administration 
guidance and developed training for contracting officer 
representatives on how to monitor contractor compliance with 
countering trafficking in persons requirements[D]. State also 
collaborated on the development of governmentwide training on 
trafficking in persons prevention responsibilities for acquisition 
professionals. Further, State created and issued a new contract clause 
on recruitment and housing of non-professional third country 
nationals.[E] The clause requires recruitment plans, fair recruitment 
practices, and, as appropriate, a plan to provide adequate housing 
conditions for workers; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials stated the agency does not plan to implement this 
recommendation. Officials explained that while they would support 
assessing contractor performance as it pertains to management of 
trafficking in persons, there is no need to incentivize contractors to 
comply with the law. They explained that all USAID contracts and 
grants already contain the standard Federal Acquisition Regulation 
provisions related to human trafficking and that the agency has issued 
additional guidance and directives. Also, USAID established a working 
group for continued oversight of trafficking issues and enforcement, 
which is developing updated training for contracting officers and 
contracting officer representatives. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[A] Department of State Office of the Procurement Executive, 
Procurement Information Bulletin 2012-01, Contractor Suspension and 
Debarment, October 3, 2011. 

[B] Pub. L. No. 111-383. 

[C] DFARS § 242.302. 

[D] Department of State Office of the Procurement Executive, 
Procurement Information Bulletin 2011-09, Combating Trafficking in 
Persons, March 24, 2011. 

[E] Department of State Office of the Procurement Executive, 
Procurement Information Bulletin 2012-10, Contractor Recruitment of 
Third Country Nationals, February 28, 2012. 

[End of table] 

Table 13: CWC Strategic Area 13--Provide Adequate Staffing and 
Resources, and Establish Procedures to Protect the Government's 
Interests: 

Recommendation not directed to specific entity: 13a; 
Strengthen authority to withhold contract payments for inadequate 
business systems; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
In February 2012, DOD issued a final rule to amend the DFARS to 
improve the oversight of contractor business systems, including the 
ability to withhold a percentage of payments on certain covered 
contracts when a contractor's business systems contain significant 
deficiencies.[A] Additionally, DOD reported that Defense Contract 
Audit Agency business system audits have identified deficiencies that 
have been or are in the process of being corrected; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State has not taken or planned actions that directly align with this 
recommendation, and officials stated a governmentwide change would be 
required. According to State officials, consistent governmentwide 
rules are required in this area since, unlike DOD, other agencies lack 
specific authority to withhold payments for inadequate business 
systems; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation. According to officials, they 
are reviewing USAID's current authority to withhold contract payments 
for inadequate business systems. 

Recommendation not directed to specific entity: 13b; 
Amend access-to-records authority to permit broader government access 
to contractor records; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
Section 842 of the National Defense Authorization Act for Fiscal Year 
2012 provides a mechanism for the department to obtain access to 
certain contractor and subcontractor records in the U.S. Central 
Command's theater of operations.[B] According to DOD officials, the 
department worked with Congress to obtain this statutory provision; 
State: No actions taken or planned that directly align with the 
specific recommendation; 
State has not taken or planned actions that directly align with this 
recommendation, and officials stated a governmentwide change would be 
required. Officials stated that the government should be consistent in 
this area, since standards need to be clear for agencies to deal with 
multiple layers of subcontractors in overseas environments; 
USAID: No actions taken or planned that directly align with the 
specific recommendation; 
USAID officials did not identify actions taken or planned that 
directly align with this recommendation. According to officials, they 
are reviewing specific limitations on USAID's current authority to 
access contractors' records. 

Recommendation not directed to specific entity: 13c; 
Increase agencies' staff and resources to enable adequate management 
of all aspects of contingency contracting: financial management, 
acquisition planning, business-system reviews, source selection, 
incurred-cost audits, performance management, property management, 
contract payment, and contract close-outs; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
DOD officials stated in February 2012 that the department was 
establishing a working group to address staffing and resource 
challenges related to contingency contracting. Officials noted that 
staffing and resourcing continue to be the department's biggest 
challenges and they are concerned that future budget cuts could affect 
progress made to date; 
State: Actions taken or planned that directly align with the specific 
recommendation; 
State is using resources from the Defense Contract Management Agency 
and the Defense Contract Audit Agency to augment its contract 
management and administration capabilities. Officials also stated that 
since its working capital fund was established in February 2008, in 
part to fund the hiring of contracting personnel, State has hired 66 
direct-hire employees and was in the process of hiring another 19 
government employees as of June 2012[C]; 
USAID: Actions taken or planned that directly align with the specific 
recommendation; 
USAID officials stated that the agency will have added 95 contracting 
officers by the summer of 2012, more than doubling the number of field 
contracting officers in the last 3 years under the Development 
Leadership Initiative program. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[A] DFARS; 
Business Systems-Definition and Administration (Case 2009-D038). 77 
Fed. Reg. 11,355 (Feb. 24, 2012). 

[B] Pub. L. No. 112-81 (2011). 

[C] 22 U.S.C. § 2684. 

[End of table] 

Table 14: CWC Strategic Area 14--Congress Should Provide or Reallocate 
Resources for Contingency Contracting Reform to Cure or Mitigate the 
Numerous Defects Described by the Commission: 

Recommendation directed to Congress: 14a; 
Congress should provide or reallocate resources for contingency 
contracting reform to cure or mitigate the numerous defects described 
by the CWC; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Not applicable. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[End of table] 

Table 15: CWC Strategic Area 15--Congress Should Enact Legislation 
Requiring Regular Assessment and Reporting of Agencies' Progress in 
Implementing Reform Recommendations: 

Recommendation directed to Congress: 15a; 
This legislation should require the Secretaries of Defense and State 
and the Administrator of USAID to submit reports detailing their plans 
for implementation of CWC recommendations, commencing 180 days from 
enactment of the legislation, with annual reporting thereafter; 
DOD: Not applicable; 
While this recommendation is directed to Congress, DOD reported that 
it does not intend to submit a report to Congress but plans to 
integrate applicable recommendations into a comprehensive operational 
contract support action plan and continue to track implementation 
progress and have working groups and forums to further address 
contracting issues in current and future contingency operation; 
State: Not applicable; 
USAID: Not applicable. 

Recommendation directed to Congress: 15b; 
This legislation should require that agencies' reports shall be 
submitted to congressional committees of jurisdiction; 
to the inspectors general of the Departments of Defense and State, and 
of USAID; 
and to the officials holding the proposed new positions at OMB/NSC and 
the permanent inspector general for contingency operations, all of 
whom would be required to review and validate the reports; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Not applicable. 

Recommendation directed to Congress: 15c; 
This legislation should require reporting requirements that include: 
(1) actions taken or planned to implement recommendations, including 
an implementation schedule with milestones and assignments of 
responsibility; (2) explanations for non-implementation of 
recommendations, including counter-measures for barriers to 
implementation; and (3) evaluation within 120 days by the Comptroller 
General and agency inspectors general (and the permanent contingency 
IG when available) of the agencies' reports and their compliance with 
requirements; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Not applicable. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[End of table] 

In table 16, we list the recommendations that the CWC made to 
Congress, State, and DOD in Special Report 4, which related to the 
transition to a civilian-led presence in Iraq, and summarize agency 
positions on them if the agencies provided their position to us. 

Table 16: CWC's Recommendations in Special Report 4: 

Recommendation directed to entity specified: 1; 
Congress ensure adequate funding to sustain State operations in 
critical areas of Iraq, including its greatly increased needs for 
operational contract support; 
DOD: Not applicable; 
State: Not applicable; 
USAID: Not applicable. 

Recommendation directed to entity specified: 2; 
State expand its organic capability to meet heightened; 
needs for acquisition personnel, contract management, and contractor 
oversight; 
DOD: Not applicable; 
State: Actions taken or planned that directly align with the specific 
recommendation; 
In 2008, State began using a working capital fund to fund increases in 
the acquisition workforce.[A] Officials stated that since February 
2008 when the fund was established, the department has hired 66 direct-
hire employees, and was in the process of hiring another 19 government 
employees as of June 2012. The department also noted that its Bureaus 
of International Narcotics and Law Enforcement Affairs and Diplomatic 
Security, the two bureaus most heavily involved in overseas 
contingency contracting, have both significantly increased resources 
to support contract administration; 
USAID: Not applicable. 

Recommendation directed to entity specified: 3; 
The Secretaries of State and Defense extend and intensify their 
collaborative planning for the transition, including executing an 
agreement to establish a single, senior-level coordinator and decision-
maker to guide progress and promptly address major issues whose 
resolution may exceed the authorities of departmental working groups; 
DOD: Actions taken or planned that directly align with the specific 
recommendation; 
According to DOD officials, the Secretary of Defense appointed a 
senior-level Iraq Transition Coordinator and the Chairman, Joint 
Chiefs of Staff also appointed a senior military officer as his Iraq 
Transition Coordinator. For the Iraq transition effort, in September 
2010 DOD and State established a Senior Executive Steering Group 
focused on coordinating the materiel and support aspects of the 
transition. According to DOD officials, this group reported to the 
Under Secretary of State for Management and the Acting Under Secretary 
of Defense (Acquisition, Technology, and Logistics) on a regular basis 
to ensure that milestones were met and address any issues that may 
impact the transition. The officials noted that this group also 
established working groups as necessary; 
State: Actions taken or planned that directly align with the specific 
recommendation; 
In February 2011, the Secretary of State appointed an Iraq Transition 
Coordinator. According to the department, the Iraq Transition 
Coordinator has been responsible for coordinating all State-related 
aspects of the U.S. transition from military to civilian operations in 
Iraq, working closely with the U.S. Ambassador to Iraq, the U.S. 
military, and other U.S. departments and agencies. DOD and State also 
established a Senior Executive Steering Group to focus on coordinating 
and synchronizing the materiel and support aspects of the transition; 
USAID: Not applicable. 

Source: GAO analysis of agency documents and interviews with agency 
officials. 

[A] 22 U.S.C. § 2684. 

[End of table] 

[End of section] 

Enclosure II: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

John P. Hutton, (202) 512-4841 or huttonj@gao.gov: 

Cary B. Russell, (202) 512-5431 or russellc@gao.gov: 

Acknowledgments: 

In addition to the contacts named above, Johana R. Ayers, Assistant 
Director; Alissa Czyz, Assistant Director; Jacob Leon Beier; Carole 
Coffey; Jennifer Dougherty; David Hancock; Melissa L. Hermes; Mae 
Jones; Hynek Kalkus; Julia Kennon; Anne McDonough-Hughes; Christopher 
J. Mulkins; Alyssa Weir; and Natasha Wilder made key contributions to 
this report. 

[End of section] 

Footnotes: 

[1] National Defense Authorization Act for Fiscal Year 2008, Pub. L. 
No. 110-181, § 841. 

[2] The CWC ceased operations on September 30, 2011, 30 days after 
issuing its final report. 

[3] Commission on Wartime Contracting in Iraq and Afghanistan, Interim 
Report--At What Cost? Contingency Contracting in Iraq and Afghanistan 
(June 10, 2009); Interim Report 2--At What Risk? Correcting Over-
Reliance on Contractors in Contingency Operations (Feb. 24, 2011); 
Special Report 1: Defense Agencies Must Improve Their Oversight of 
Contractor Business Systems to Reduce Waste, Fraud, and Abuse (Sept. 
21, 2009); Special Report 2: Lowest-Priced Security Not Good Enough 
for War-Zone Embassies (Oct. 1, 2009); Special Report 3: Better 
Planning for Defense-to-State Transition in Iraq Needed to Avoid 
Mistakes and Waste (July 12, 2010); Special Report 4: Iraq--A 
Forgotten Mission? (Mar. 1, 2011); Special Report 5: Sustainability: 
Hidden Costs Risk New Waste (June 3, 2011); and Transforming Wartime 
Contracting: Controlling Costs, Reducing Risks, Final Report to 
Congress (Aug. 31, 2011). 

[4] The recommendations from the CWC's Special Report 5 were 
incorporated into the final report. Therefore, we have not counted 
recommendations from Special Report 5 separately. 

[5] DFARS; Business Systems-Definition and Administration (Case 2009-
D038). 77 Fed. Reg. 11,355 (Feb. 24, 2012). 

[6] Department of State Office of the Procurement Executive, 
Procurement Information Bulletin 2012-01, Contractor Suspension and 
Debarment, October 3, 2011. 

[7] USAID Automated Directives System Section 200.3.1.5, Policy 
Directives and Required Procedures, Build in Sustainability from the 
Start (Feb. 10. 2012). 

[8] Commission on Wartime Contracting in Iraq and Afghanistan, Special 
Report 4: Iraq--A Forgotten Mission? (Mar. 1, 2011); Special Report 5: 
Sustainability: Hidden Costs Risk New Waste (June 3, 2011); and 
Transforming Wartime Contracting: Controlling Costs, Reducing Risks, 
Final Report to Congress (Aug. 31, 2011). 

[9] Commission on Wartime Contracting in Iraq and Afghanistan, Interim 
Report--At What Cost? Contingency Contracting in Iraq and Afghanistan 
(June 10, 2009); Interim Report 2--At What Risk? Correcting Over-
Reliance on Contractors in Contingency Operations (Feb. 24, 2011); 
Special Report 1: Defense Agencies Must Improve Their Oversight of 
Contractor Business Systems to Reduce Waste, Fraud, and Abuse (Sept. 
21, 2009); Special Report 2: Lowest-Priced Security Not Good Enough 
for War-Zone Embassies (Oct. 1, 2009); Special Report 3: Better 
Planning for Defense-to-State Transition in Iraq Needed to Avoid 
Mistakes and Waste (July 12, 2010). 

[End of section] 

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