oversight

Operational Contract Support: Management and Oversight Improvements Needed in Afghanistan

Published by the Government Accountability Office on 2012-03-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office

GAO          Report to Congressional Committees




March 2012
             OPERATIONAL
             CONTRACT
             SUPPORT
             Management and
             Oversight
             Improvements Needed
             in Afghanistan




GAO-12-290
                                               March 2012

                                               OPERATIONAL CONTRACT SUPPORT
                                               Management and Oversight Improvements Needed in
                                               Afghanistan
Highlights of GAO-12-290, report to
congressional committees




Why GAO Did This Study                         What GAO Found
In fiscal year 2011, DOD reported              The Department of Defense (DOD) has taken steps to enhance its existing
obligating over $16 billion for contracts      training program for contracting officer’s representatives (CORs), but the required
that were executed primarily in                training does not fully prepare them to perform their contract oversight duties in
Afghanistan. GAO has previously                contingency areas such as Afghanistan. DOD requires that CORs be qualified by
identified the need for DOD to improve         training and experience commensurate with the responsibilities to be delegated
its oversight of contractors by non-           to them. DOD took several actions to enhance its training program, such as
acquisition personnel, such as CORs,           developing a CORs training course with a focus on contingency operations.
and Congress has addressed this                However, GAO found that CORs are not prepared to oversee contracts because
issue in legislation. CORs act as the          the required training does not include specifics on how to complete written
liaisons between the contractor, the           statements of work and how to operate in Afghanistan’s unique contracting
contracting officer, and the unit              environment. For example, DOD contracting personnel told GAO about opening
receiving support.                             delays and additional expenses related to the construction of a dining facility,
Following up on previous GAO work on           which was originally constructed without a kitchen because it was not included in
this topic, GAO determined the extent          the original statement of work. In some cases, contract-specific training was not
to which (1) DOD’s required training           provided at all. In addition, not all oversight personnel such as commanders and
prepares CORs to perform their                 senior leaders receive training to perform contract oversight and management
contract management and oversight              duties in Afghanistan because such training is not required of them. Because
duties, (2) CORs have the subject              DOD’s required training does not prepare CORs and other oversight personnel to
area-related technical expertise               oversee contracts, units cannot be assured that they receive what they paid for.
needed to oversee contracts, and (3)
the number of CORs is sufficient to            CORs do not always have the necessary subject area-related technical expertise
oversee the contracts in Afghanistan.          to oversee U.S. Central Command (CENTCOM) contracts they were assigned to.
GAO conducted field work in                    Contracting officials noted, for example, that the staircases on guard towers at a
Afghanistan and the United States and          forward operating base were poorly constructed and unsafe to climb. The COR
focused on the preparedness of CORs            assigned to that contract had inadequate subject area-related technical
to manage and oversee contracts in             expertise, preventing the early identification of the defective welding on the
the CENTCOM area of responsibility.            staircases. According to contracting officials, situations like this often occurred
                                               due to the shortage of CORs with expertise in construction. Also, at the time of
What GAO Recommends                            GAO’s field work, CORs for contracts written by CENTCOM contracting officers
GAO recommends that DOD enhance                did not have access to subject matter experts, particularly those with construction
the current strategy for managing and          experience. According to contracting personnel, because CORs do not have the
overseeing contracts in contingency            subject area-related technical expertise needed to oversee contracts or access to
areas such as Afghanistan by, for              subject matter experts, facilities were sometimes deficient and had to be
example, developing training standards         reconstructed at great additional expense to the taxpayer.
for providing operational contract
support (OCS), fully institutionalizing        DOD does not have a sufficient number of CORs to oversee the numerous
OCS in professional military education,        contracts in Afghanistan. CENTCOM requires CORs to be nominated for all
and developing standards regarding             service contracts over $2,500 that, unless exempted, require significant ongoing
the number of contracts that CORs can          technical advice and surveillance from requirements personnel. However, there
oversee based on the technical nature          is no guidance on the number of contracts a single COR should oversee.
and complexity of the contract. DOD            According to contracting officials and CORs GAO interviewed in Afghanistan,
concurred with all of GAO’s                    some CORs were responsible for providing oversight to multiple contracts in
recommendations.                               addition to carrying out their primary military duty. For example, one COR GAO
                                               interviewed was assigned to more than a dozen construction projects. According
                                               to that COR, it was impossible to be at each construction site during key phases
                                               of the project because the projects were occurring almost simultaneously at
View GAO-12-290. For more information,         different locations. Consequently, according to officials, in situations like these,
contact Cary B. Russell at (404) 679-1808 or
russellc@gao.gov
                                               construction was completed without sufficient government oversight and
                                               problems were sometimes identified after facilities had been completed.
                                                                                        United States Government Accountability Office
Contents


Letter                                                                                      1
               Background                                                                   6
               DOD Took Steps to Enhance Existing Training Program, but
                 Existing Training Does Not Fully Prepare CORs for Contract
                 Management and Oversight Duties                                            9
               CORs Do Not Always Have the Subject Area-Related Technical
                 Expertise Needed to Oversee Some Contracts                               18
               Number of CORs Is Not Sufficient to Adequately Oversee the
                 Contracts in Afghanistan                                                 23
               Conclusions                                                                26
               Recommendations for Executive Action                                       27
               Agency Comments and Our Evaluation                                         28

Appendix I     Scope and Methodology                                                      32



Appendix II    Comments from the Department of Defense                                    36



Appendix III   GAO Contact and Staff Acknowledgments                                      39



Figures
               Figure 1: Shower/Toilet Facility Constructed without Holes in the
                        Walls or Flooring for Plumbing and Drain                          13
               Figure 2: Poor-Quality Materials—Crumbling Cement Blocks                   13
               Figure 3: Unstable Staircase for Guard Towers                              20
               Figure 4: Cement Block Wall with Large Holes That Remained
                        When Scaffolding Was Removed                                      21
               Figure 5: Compound Comprising Five Buildings Constructed in a
                        Non-Secure Location outside the Perimeter of a Base               25




               Page i                                  GAO-12-290 Operational Contract Support
Abbreviations

C3                CENTCOM Contracting Command
C-JTSCC           CENTCOM Joint Theater Support Contracting Command
CORs              contracting officer’s representatives
COIN              counterinsurgency
DCMA              Defense Contract Management Agency
DOD               Department of Defense
FAR               Federal Acquisition Regulation
LOGCAP            Logistics Civil Augmentation Program
OCS               Operational Contract Support
SCO-A             Senior Contracting Official-Afghanistan
USD AT&L          Under Secretary of Defense for Acquisition, Technology
                  and Logistics
CENTCOM           U.S. Central Command




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Page ii                                           GAO-12-290 Operational Contract Support
United States Government Accountability Office
Washington, DC 20548




                                   March 29, 2012

                                   Congressional Committees

                                   The Department of Defense (DOD) reported that it had obligated over $16
                                   billion in fiscal year 2011 for contracts that were executed primarily in
                                   Afghanistan and that, as of October 2011, contractors made up 49
                                   percent of the department’s workforce there—101,789 DOD contractors 1
                                   compared with approximately 104,900 U.S. military personnel.
                                   Contractors support the military during contingency operations 2 by, for
                                   example, managing dining facilities; washing uniforms; guarding military
                                   bases; constructing roads to schools; transporting supplies; and building
                                   facilities, such as guard towers, water treatment plants, and hospitals.
                                   Since 1997, we have reported on DOD’s use of contractors to support
                                   contingency operations. For example, we reported in July 2004 that DOD
                                   did not always have sufficient contract oversight personnel to manage
                                   and oversee its logistics support contracts in Iraq and Afghanistan. 3 In
                                   December 2006, we noted that without an adequate number of trained
                                   oversight personnel DOD could not be assured that contractors could
                                   meet contract requirements efficiently and effectively. 4 Effective contract
                                   management is essential for ensuring that U.S. military personnel receive


                                   1
                                    Office of the Deputy Assistant Secretary of Defense (Program Support), Contractor
                                   Support of U.S. Operations in the USCENTCOM Area of Responsibility, Quarterly
                                   Contractor Census Reports, October 2011. As we have noted in previous reports,
                                   however, agency-reported census data should not be used to identify trends or draw
                                   conclusions about the number of contractor personnel due to limitations such as
                                   incomplete and inaccurate data. See GAO, Iraq and Afghanistan: DOD, State, and USAID
                                   Cannot Fully Account for Contracts, Assistance Instruments, and Associated Personnel,
                                   GAO-11-886 (Washington, D.C.: Sept. 15, 2011).
                                   2
                                    A “contingency operation” is a military operation that either (a) is designated by the
                                   Secretary of Defense as an operation in which members of the armed forces are or may
                                   become involved in military actions, operations, or hostilities against U.S. enemies or
                                   against an opposing military force or (b) results in the call or order to, or retention on,
                                   active duty of members of the uniformed services under certain statutory provisions or any
                                   other provision of law during a war or during a national emergency declared by the
                                   President or Congress. See 10 U.S.C. § 101(a)(13).
                                   3
                                    GAO, Military Operations: DOD’s Extensive Use of Logistics Support Contracts Requires
                                   Strengthened Oversight, GAO-04-854 (Washington, D.C.: July 21, 2004).
                                   4
                                    GAO, Military Operations: High-Level DOD Action Needed to Address Long-standing
                                   Problems with Management and Oversight of Contractors Supporting Deployed Forces,
                                   GAO-07-145 (Washington, D.C.: Dec. 18, 2006).




                                   Page 1                                            GAO-12-290 Operational Contract Support
the support they need and that controls are in place to prevent fraud,
waste, and abuse. Ultimately, failure to manage contracts effectively
could undermine U.S. policy objectives and threaten the safety of U.S.
forces.

It takes a wide range of people to execute an acquisition from start to
finish including personnel outside of the acquisition workforce such as
contracting officer’s representatives (CORs). CORs are military or civilian
DOD personnel that manage and oversee contracts by acting as the eyes
and the ears of DOD’s contracting officers and by serving as the liaisons
between the contractor, the contracting officer, and the unit receiving
support or services. The contracting officer is ultimately responsible for
ensuring that contractors meet the requirements as set forth in the
contract. However, the CORs are non-acquisition personnel that have
acquisition-related responsibilities—particularly those related to contract
management and oversight of service and product acquisitions.

We and other oversight entities have identified the need for DOD to
improve the management and oversight of contractors by non-acquisition
personnel, such as the CORs. Congress addressed the need to improve
the management and oversight of non-acquisition personnel, in
legislation. Specifically, Congress included provisions relating to
contingency contracting in the John Warner National Defense
Authorization Act for Fiscal Year 2007 5 and the National Defense
Authorization Act for Fiscal Year 2008, 6 codified at section 2333 of Title




5
Pub. L. No. 109-364 (2006).
6
Pub. L. No. 110-181 (2008).




Page 2                                   GAO-12-290 Operational Contract Support
10, United States Code. 7 The National Defense Authorization Act for
Fiscal Year 2008 amended section 2333 to require that certain DOD joint
policy provide for training of military personnel outside the acquisition
workforce expected to have acquisition responsibility, including oversight
duties during combat operations, post-conflict operations, and
contingency operations. 8 Further, section 2333 requires that the training
be sufficient to ensure that such military personnel understand the scope
and scale of contractor support that they will experience in contingency
operations and are prepared for their roles and responsibilities in regard
to requirements definition, program management (including contractor
oversight), and contingency contracting, 9 which are aspects of operational
contract support (OCS). Specific concerns have been raised about the
training, expertise, and the sufficiency of the number of CORs providing
contract management and oversight. For example, in 2007, the
Commission on Army Acquisition and Program Management in
Expeditionary Operations (known as the Gansler Report) found that
CORs usually had no experience managing contracts and received
contract management training that was not relevant to the Afghanistan
contracting environment. 10 Further, in June 2009, the Commission on
Wartime Contracting reported shortfalls in the number of qualified
oversight personnel in Afghanistan, specifically CORs, and a general lack



7
 See Pub. L. No. 109-364, § 854(a)(1); Pub. L. No. 110-181, § 849. The provision in the
John Warner National Defense Authorization Act for Fiscal Year 2007 required the
Secretary of Defense to develop joint policies addressing contingency contracting, among
other matters. See Pub. L. No. 109-364, § 854(a)(1) (codified as amended at 10 U.S.C. §
2333(d)). Section 2333, as enacted by the provision, also defines “contingency
contracting” as all stages of the process of acquiring property or services by the
Department of Defense during a contingency operation. See 10 U.S.C. § 2333(f)(2). We
reported in June 2010 that DOD had not yet finalized the joint policies required by
Congress in the National Defense Authorization Acts for Fiscal Years 2007 and 2008. On
December 20, 2011, DOD reissued Department of Defense Instruction 3020.41 with a
new title—Operational Contract Support. The revised instruction establishes policy,
assigns responsibilities, and provides procedures for OCS. DOD issued regulations with
similar content in an interim final rule published in the Federal Register shortly thereafter.
See Operational Contract Support, 76 Fed. Reg. 81,807 (Dec. 29, 2011) (to be codified at
32 C.F.R. pt. 158). We did not assess the recent issuances in this report.
8
 See Pub. L. No. 110-181, § 849(a)(2) (codified at 10 U.S.C. § 2333(e)).
9
 See § 2333(e)(2).
10
  Report of the “Commission on Army Acquisition and Program Management in
Expeditionary Operations”, Urgent Reform Required: Army Expeditionary Contracting,
(Oct. 31, 2007).




Page 3                                              GAO-12-290 Operational Contract Support
of COR training. 11 Then, in August 2011, the Commission on Wartime
Contracting reported that poor planning and oversight by the government
and poor performance by contractors had resulted in wasted resources,
missions not being achieved, and the loss of lives. 12 A recent U.S. Army
Contracting Command article 13 noted that many deploying units were
either unaware of, or simply ignored, a certain Army road map for units to
follow to successfully integrate OCS training, including training CORs into
its pre-deployment preparations; the article concluded that units
continued to deploy unprepared to execute their OCS mission. We
testified in June 2011 that, though DOD had taken some actions to better
prepare CORs for their management and oversight duties, improving
CORs’ performance remained a challenge. 14

Although CORs are non-acquisition personnel, they have acquisition-
related responsibilities—particularly those related to contract
management and oversight. In October 2010, in response to a mandate
in the National Defense Authorization Act for Fiscal Year 2010, 15 we
reported on training provided by the Defense Acquisition University to the
acquisition workforce. 16 This review supplements the 2010 and other
reports focusing on the preparedness of CORs, one such group of non-


11
 Commission on Wartime Contracting in Iraq and Afghanistan, At What Cost?
Contingency Contracting in Iraq and Afghanistan, Interim Report to Congress (June 2009).
12
  Commission on Wartime Contracting in Iraq and Afghanistan: Transforming Wartime
Contracting: Controlling Cost and Reducing Risks, Final Report to Congress (Aug. 31,
2011).
13
  U.S. Army Contracting Command, ACC Today, Professional Workforce Gansler Report
Findings Help Prioritize Pre-deployment Contracting Planning, by Major Hurcel I. Williams,
412th Contracting Support Brigade, summer 2011.
14
  GAO, Operational Contract Support: Actions Needed to Address Contract Oversight and
Vetting of Non-U.S. Vendors in Afghanistan, GAO-11-771T (Washington, D.C.: June 30,
2011).
15
 See Pub. L. No. 111-84, § 1108(b)(2) (2009).
16
  GAO, Defense Acquisition Workforce: DOD’s Training Program Demonstrates Many
Attributes of Effectiveness, but Improvement Is Needed, GAO-11-22 (Washington, D.C.:
Oct. 28, 2010). In GAO-11-22, the acquisition workforce was described with reference to
the Defense Acquisition Workforce Improvement Act, Pub. L. No. 101-510, §§ 1201-1211
(1990) (codified as amended at 10 U.S.C. ch. 87); GAO, Defense Acquisition Workforce:
Better Identification, Development, and Oversight Needed for Personnel Involved in
Acquiring Services, GAO-11-892 (Washington, D.C.: Sept. 27, 2011). Following this work,
in GAO-11-892 we examined personnel outside the workforce defined under the Defense
Acquisition Workforce Improvement Act who are involved with acquiring services.




Page 4                                           GAO-12-290 Operational Contract Support
acquisition personnel, tasked with contract management and oversight
responsibilities in Afghanistan. Specifically, our objectives were to
determine the extent to which (1) DOD’s required training prepares CORs
to perform their contract management and oversight duties, (2) CORs
have the subject area-related technical expertise needed to oversee
contracts, and (3) the number of CORs is sufficient to oversee the
contracts in Afghanistan.

To address our objectives, we assessed training requirements, technical
qualifications, and workload requirements for CORs by reviewing
guidance such as the Joint Publication 4-10, 17 the U.S. Central Command
(CENTCOM) Joint Theater Support Contracting Command 18 Standard
Operating Procedures addressing the Contracting Officer’s
Representative Program, 19 the Defense Contingency Contracting Officer’s
Representative Handbook, and the Joint Contingency Contracting
Officer’s Representative Handbook. We interviewed senior contracting
personnel from the Office of the Secretary of Defense, the Joint Staff, the
combatant commands, service headquarters, the Defense Contract
Management Agency (DCMA), and defense universities to obtain a
comprehensive understanding of what training was available for CORs
performing contract-related duties in Afghanistan. To assess the content
of the training, we attended a weeklong training course for CORs at Fort
Carson, Colorado, and completed the Defense Acquisition University’s
online CORs contingency courses. We also reviewed the program of
instructions (course syllabus) for the training curriculum. In Afghanistan,
we conducted interviews with over 150 DOD personnel (commanders,
senior leaders, contracting personnel, and CORs) from over 30 defense
organizations and units in Bagram, Kabul, Kandahar, and Camp
Leatherneck to identify the extent to which DOD’s required training had
prepared CORs to perform their management and oversight duties, CORs
had the subject area-related technical expertise needed to oversee
contracts, and the number of CORs was sufficient to oversee the
contracts in Afghanistan. We selected defense organizations and units to


17
  Joint Chiefs of Staff, Joint Pub. 4-10, Operational Contract Support (Oct. 17, 2008)
(Hereinafter cited as Joint Pub. 4-10 (Oct. 17, 2008)). According to senior Army officials,
Joint Publication 4-10 is doctrine, not policy and it is prescriptive in nature.
18
  Also known as CENTCOM Contracting Command (C3)
19
 CENTCOM Contracting Command Standard Operating Procedure No. 10-02:
Contracting Officer’s Representative (COR) Program (Rev. 2, June 2010).




Page 5                                             GAO-12-290 Operational Contract Support
             interview that would be in Afghanistan and available during the time of our
             visit based on input from service officials as well as status reports from
             the U.S. Army, the U.S. Air Force, and the U.S. Army National Guard. To
             facilitate our meetings with CORs and contracting personnel in
             Afghanistan, we developed a set of structured questions that we pre-
             tested and coordinated with service contracting experts to ensure that we
             solicited the appropriate responses. See appendix I for our scope and
             methodology and a list of defense organizations and units we visited
             during the course of this engagement.

             We conducted our work from April 2010 to March 2012 in accordance
             with generally accepted government auditing standards. Those standards
             require that we plan and perform the audit to obtain sufficient and
             appropriate evidence to serve as a basis for our findings and conclusions.
             We believe that the evidence that we have obtained serves as a
             reasonable basis for our findings and conclusions based on our audit
             objectives.


             “Oversight of a contract”—which can refer to contract administration
Background   functions, quality assurance surveillance, corrective action, property
             administration, and past performance evaluation—ultimately rests with
             the contracting officer who has the responsibility for ensuring that
             contractors meet the requirements set forth in the contract. However,
             contracting officers are frequently not located in the area or at the
             installation where the services are being provided. For that reason,
             contracting officers designate CORs via an appointment letter 20 to assist
             with the technical monitoring or administration of a contract on their
             behalf. CORs serve as the eyes and ears for the contracting officer and
             act as the liaisons between the contractor, the contracting officer, and the
             unit receiving support or services. CORs are responsible for tasks
             identified in the contracting officer’s appointment letter that may include
             (1) providing daily contract oversight, (2) performing quality assurance
             reviews, (3) monitoring contract performance, and (4) assessing technical
             performance. CORs cannot direct the contractor by making commitments
             or changes that affect price, quality, quantity, delivery, or other terms and



             20
               An appointment letter, or letter of designation, specifies among other things the extent of
             the COR’s authority to act on behalf of the contracting officer, identifies limitations on the
             COR’s authority, and specifies the period covered by the designation.




             Page 6                                             GAO-12-290 Operational Contract Support
conditions of the contract. 21 In addition to their oversight duties, CORs
have also been tasked with other contract-related duties such as
preparing statements of work, which provide the requirements or
specifications of the contract, developing requirements approval
paperwork, and preparing funding documents. Although CORs are non-
acquisition personnel, they can have acquisition-related responsibilities—
particularly those related to contract oversight. CORs are not usually
contracting specialists and often perform contract management and
oversight duties on a part-time basis in addition to performing their
primary military duties, such as those performed by an infantryman or a
quartermaster specialist.

The Office of the Under Secretary of Defense for Acquisition, Technology,
and Logistics (USD AT&L) has responsibility for developing overarching
DOD policy for the management and oversight of contingency contracts. 22
For some contracts, including all contracts under the Logistics Civil
Augmentation Program (LOGCAP), 23 according to officials, contracting
officers may delegate contract administration to DCMA to monitor
contractor performance. The DCMA teams in Afghanistan include (1)
administrative contracting officers who administer contracts and often
direct contractors to perform work and (2) quality assurance
representatives who ensure that the contractors perform work to the
standards written in the contracts and who oversee certain aspects of the
performance of CORs assigned to DCMA-administered contracts. The
DCMA team also includes property administrators and subject matter
experts who advise the agency on technical issues such as food service,
electrical engineering, and fire safety. However, construction contracts in
Afghanistan are generally administered by personnel from the Army
Corps of Engineers, or they may be administered by CENTCOM Joint



21
  CORs may also not be delegated responsibility to perform functions at a contractor’s
location that have been delegated to a contract administration office. See 48 C.F.R. §
201.602-2(2)(iii) (Defense Federal Acquisition Regulation Supplement).
22
  DOD defines the term “contingency contract” as a legally binding agreement for
supplies, services, and construction let by government contracting officers in the
operational area, as well as other contracts that have a prescribed area of performance
within a designated operational area. These contracts include theater support, external
support, and systems support contracts.
23
  LOGCAP is a program that provides worldwide logistics and base and life support
services in contingency environments and provides the majority of base and life support
services to U.S. forces in Iraq and Afghanistan.




Page 7                                           GAO-12-290 Operational Contract Support
Theater Support Contracting Command contracting officers assisted by
CORs. When DCMA is not designated responsibility for administrative
oversight of a contract, the contracting officer who awarded the contract is
responsible for the administration, management, and oversight of the
contract. These contracting officers, such as those from the CENTCOM
Joint Theater Support Contracting Command often appoint CORs to
monitor contractor performance. 24 CORs appointed by the CENTCOM
Joint Theater Support Contracting Command are typically drawn from
units receiving contractor-provided services. In Afghanistan, CORs that
have been appointed to contracts administered by DCMA report oversight
results to DCMA personnel. For contracts not administered by DCMA,
CORs provide oversight information to the contracting officer. In
Afghanistan, the CENTCOM Joint Theater Support Contracting
Command directs requiring activities (units receiving contractor-provided
goods and services) to nominate CORs for all service contracts valued at
more than $2,500 with significant technical requirements that require
ongoing advice and surveillance from technical/requirements personnel.
The contracting officer may exempt service contracts from this
requirement when the following three conditions are all met:

(1) The contract will be awarded using simplified acquisition procedures;

(2) The requirement is not complex; and

(3) The contracting officer documents the file, in writing, as to why the
appointment of a COR is unnecessary. 25




24
  Although the CENTCOM Joint Theater Support Contracting Command (C-JTSCC )
commander is accountable for contract administration of all DOD contracts requiring
contractors to deploy to theater to support operations, non-C-JTSCC theater support
contracts that are not delegated to DCMA may be re-delegated back to the originator. See
CENTCOM Joint Theater Support Contracting Command Acquisition Instruction §
25.7700(a) (Sept. 1, 2011).
25
  See CENTCOM Contracting Command Standard Operating Procedure No. 10-02:
Contracting Officer’s Representative (COR) Program ¶ 4(A) (Rev. 2, June 2010). A
revised version of this guidance was released while this report was in its final stages; we
did not have the opportunity to assess this guidance. As such, we refer in this report to the
guidance that was in effect during the period of our review.




Page 8                                             GAO-12-290 Operational Contract Support
                            Although DOD requires CORs to receive training and took some actions
DOD Took Steps to           to enhance training programs, CORs we met with in Afghanistan do not
Enhance Existing            always receive adequate training to prepare them for their contract
                            management and oversight duties. DOD requires that CORs be qualified
Training Program, but       by training and experience commensurate with the responsibilities to be
Existing Training           delegated to them. According to DOD officials, the current training might
Does Not Fully              qualify CORs to monitor contractor performance generally, but it does not
                            necessarily make them sufficiently capable for their particular
Prepare CORs for            assignments. DOD officials have acknowledged gaps in training. For
Contract Management         example, required DOD training taken by CORs did not fully address the
                            unique contracting environment that exists in Afghanistan, which includes
and Oversight Duties        large numbers of Afghan contractors with limited experience and
                            qualifications. Further, the instability and security aspects of remote
                            locations throughout Afghanistan coupled with an undeveloped
                            infrastructure impedes the CORs’ ability to communicate with and rely
                            upon acquisition personnel, such as contracting officers, for support and
                            guidance. Additionally, not all of the required training for CORs was
                            conducted, and some other oversight personnel were not being trained.


CORs Are Required to        In Afghanistan, much of the daily surveillance of contractors supporting
Receive Training and DOD    military operations is performed by CORs. The Federal Acquisition
Took Some Actions to        Regulation (FAR) requires that quality assurance, such as surveillance,
                            be performed at such times and places as may be necessary to
Enhance Existing Training   determine that the supplies or services conform to contract requirements.
Programs                    26
                               DOD guidance requires CORs to be trained and assigned prior to
                            award of a contract. DOD training is intended to familiarize the CORs with
                            the duties and responsibilities of contract management and oversight.
                            Contracting organizations such as the CENTCOM Joint Theater Support
                            Contracting Command require that personnel nominated to be CORs
                            complete specific online training courses 27 (referred to as Phase I), as
                            well as locally developed CORs overview training, and contract-specific
                            training provided by contracting officers in theater (the latter referred to as


                            26
                              This surveillance generally involves government oversight of contractors with the
                            purpose of ensuring that the contractor (the service provider) performs the requirements of
                            the contract and the government (the service receiver or customer) receives the service
                            as intended.
                            27
                              Online CORs training was provided by the Defense Acquisition University; and the Army
                            offers an on-line course for deployed CORs, which covered the same information as the
                            40-hour course provided by the Army Logistics University.




                            Page 9                                           GAO-12-290 Operational Contract Support
                           Phase II) before they can serve as CORs in Afghanistan. The guidance
                           notes that, at a minimum, Phase II training will consist of contract specific
                           responsibilities, including file documentation; terms and conditions of the
                           contract; specifics of the performance work statement; acceptance of
                           services procedures; invoice procedures; technical requirements; monthly
                           reporting procedures, and contractor evaluation—all specific to their
                           assigned contract.

                           DOD has taken some actions to enhance training programs to prepare
                           CORs to manage and oversee contracts in contingency operations, such
                           as in Afghanistan. For example, DOD developed a new training course for
                           CORs, with a focus on contingency operations and developed a more
                           general certification program for CORs, including the contingency
                           operations course as a training requirement when it is applicable. 28 DOD
                           also took steps to institutionalize operational contract support by including
                           some CORs-related training in professional military education programs
                           and by emphasizing the need for qualified CORs by discussing their
                           responsibilities in joint doctrine and other guidance with the publication of
                           Joint Publication 4-10—Operational Contract Support and the Defense
                           Contingency Contracting Officer’s Representative Handbook and
                           memoranda issued by the Deputy Secretary of Defense.


Available DOD Training     Our analysis of DOD’s CORs training and interviews with over 150 CORs
Does Not Fully Prepare     and contracting personnel from over 30 defense organizations like the
CORs to Oversee            regional contracting centers 29 and the DCMA in Bagram, Kabul,
                           Kandahar, and Camp Leatherneck, Afghanistan, indicated that some
Contracts in Afghanistan
                           gaps and limitations existed in DOD’s training programs leaving CORs
                           not fully prepared to perform their contract management and oversight


                           28
                              In addition to DOD actions, there are other similar government-wide efforts to revamp
                           federal CORs policies. In September 2011, the Office of Federal Procurement Policy
                           issued a memorandum describing revisions to the Federal Acquisition Certification for
                           CORs. The purpose of the program, which applies to all executive agencies except DOD,
                           is to establish general training, experience, and development requirements for CORs that
                           reflect the various types of contracts they manage. See Memorandum from Daniel I.
                           Gordon, Administrator, Office of Federal Procurement Policy, Revisions to the Federal
                           Acquisition Certification for Contracting Officer’s Representatives (FAC-COR) (Sept. 6,
                           2011).
                           29
                             Regional Contracting Centers are involved in planning, coordinating, and managing
                           theater support contracting for deployed U.S. forces and multinational forces support in
                           Afghanistan.




                           Page 10                                           GAO-12-290 Operational Contract Support
duties. For example, the training for CORs is generally focused on low-
risk contract operations in Afghanistan and does not fully address the
unique contracting environment that exists there, such as the extent of
inexperience of Afghan contractors, the remote and insecure locations of
project sites, the underdeveloped infrastructure, and constraints on the
movement and deployment of oversight personnel, especially acquisition
personnel. More specifically, the required CORs training does not include
information about important issue areas like the Afghan First Program,
which encourages an increased use of local personnel and vendors for
supplies and services as part of the U.S. counterinsurgency 30 strategy,
and working with private security contractors. Some CORs in Afghanistan
told us they were unaware of the challenges in working with Afghan
contractors and thought contracting with them would be similar to
contracting with U.S. vendors. However, according to some of the CORs
and other contracting personnel we interviewed, providing oversight of
Afghan contractors was more challenging than was the case with other
vendors because the Afghan contractors often did not meet the timelines
specified in the contract, did not provide the quality products and the
services the units had anticipated, and did not necessarily have a working
knowledge of English. Further, these officials told us that Afghan
contractors were not always familiar with the business standards and
processes of the U.S. government. For example, one COR told us during
our visit in February 2011 that a unit was still waiting for barriers that it
had contracted for in May 2010. According to that COR, while some of the
barriers had been delivered, the unit had not received all of the barriers it
required even though the contract delivery date had passed. Other CORs,
contracting officials, and commanders described similar situations in
which services were either not provided as anticipated or were not
provided at all. Because of gaps in training, CORs did not always
understand the full scope of their responsibilities and did not always
ensure that the contractor was meeting all contract requirements. As a
result, according to contracting officials, items such as portable toilets,
gates, water, and other items or services were not available when
needed, raising concerns about security, readiness, and morale.

Contracting officials from over 30 defense organizations and units in
Bagram, Kabul, Kandahar, and Camp Leatherneck whom we spoke with


30
  Commander, International Security Assistance Force/United States Forces—
Afghanistan, COMISAF’s Counterinsurgency (COIN) Contracting Guidance (Sept. 8,
2010).




Page 11                                      GAO-12-290 Operational Contract Support
noted similar problems with construction contracts awarded to Afghan
contractors. For example, according to another COR, an Afghan
contractor was awarded a $70,000 contract to build a latrine, shower, and
sink unit. The COR told us that the contractor was unable to satisfactorily
complete the project and so another contract was awarded for
approximately $130,000 to bring the latrine, shower, and sink unit to a
usable condition. Because of inadequacies in training, CORs did not
always understand that they had the responsibility to ensure that the
terms of the contract were met and therefore did not bring contractors’
performance issues to the contracting officer’s attention for resolution.
Similarly, DOD contracting officials provided us with documentation of
other construction problems, including a shower/toilet facility built without
holes in the walls or floors for plumbing and drain (fig. 1), and facilities
that were constructed with poor-quality materials such as crumbling
cement blocks (fig. 2). 31 The Special Inspector General for Afghanistan
Reconstruction 32 has also reported significant construction deficiencies
related to contracting in Afghanistan, including poorly formed and
crumbling cement structures attributable to the lack of CORs training and
oversight.




31
  The photographs in this report were selected from photographs provided by DOD
personnel and were not necessarily a representation of the contract environment in
Afghanistan. Any construction problems or other defects identified in the photographs are
derived from statements from officials or DOD documentation.
32
  Special Inspector General Afghanistan Reconstruction, ANP District Headquarters
Facilities in Helmand and Kandahar Provinces Have Significant Construction Deficiencies
Due to Lack of Oversight and Poor Contractor Performance (Oct. 27, 2010).




Page 12                                          GAO-12-290 Operational Contract Support
Figure 1: Shower/Toilet Facility Constructed without Holes in the Walls or Flooring
for Plumbing and Drain




Figure 2: Poor-Quality Materials—Crumbling Cement Blocks




Page 13                                       GAO-12-290 Operational Contract Support
Because of the nature and sensitivity of security contracts, CORs for
private security contractors’ contracts have unique responsibilities. For
example, during the period of our review, under guidance in place prior to
June 2011, CORs were responsible for compiling a monthly weapons
discharge report and for ensuring contractor adherence to contractual
obligations on topics such as civilian arming requirements, personnel
reporting systems, property accountability, and identification badges.
According to a senior military officer with U.S. Forces Afghanistan’s
private security contractor task force, because of gaps in training, CORs
did not always understand the full scope of their responsibilities and so
did not always ensure that a contractor was meeting all contract
requirements. He noted that CORs did not always understand that they
had the responsibility to ensure that the terms of the contract were met
and therefore did not bring contractors’ performance issues to the
contracting officer’s attention for resolution. As a result, DOD may pay
contractors for poor performance and installations might not receive the
level of security contracted for.

Further, we found that the training programs lacked specifics on the
preparation of statements of work or documents required for acquisition
review boards—two contract management responsibilities that CORs in
Afghanistan were routinely tasked to do. Although the development of a
statement of work involves a variety of participants from the contracting
process, a COR may be uniquely suited to have an early impact on the
development of a complete and accurate statement of work. The Defense
Contingency Contracting Officer’s Representative Handbook describes
statements of work as specifying the basic top-level objectives of the
acquisition as well as the detailed requirements of the government. The
statement of work can provide the contractor with “how to” instructions to
accomplish the required work. It could provide a detailed description of
what is expected of the contractor and forms part of the basis for
successful performance by the contractor and effective oversight of
contracts by the government. Well-written statements of work are needed
to ensure that units get the services and goods needed in the required
time frame. As we reported in 2000 and 2004, poorly written statements
of work can also increase costs and the number of substandard supplies
and services provided by the contractor. 33 Based on discussions with



33
 GAO, Military Operations: DOD’s Extensive Use of Logistics Support Contracts
Requires Strengthened Oversight, GAO-04-854 (Washington, D.C.: July 19, 2004).




Page 14                                       GAO-12-290 Operational Contract Support
contracting personnel from four major bases in Afghanistan responsible
for reviewing these documents, statements of work prepared by CORs
were vague and lacked the specifics needed to provide units with what
they wanted. We were told by multiple DOD officials that some CORs
routinely cut and paste information from previous statements of work into
their current document without adapting it as needed, resulting in errors
that have to be corrected and further extending the time involved in
procuring a good or service. Contracting personnel told us of instances in
which statements of work had to be rewritten because the original
statements of work did not include all the required contractor actions, or
because they included incorrect requirements. Although there are other
DOD contracting personnel involved in the requirement and procurement
process, CORs can help to ensure that well-articulated needs are more
fully documented at an early stage. DOD contracting personnel
responsible for reviewing and approving requests for contract support told
us that poorly written statements of work were a principal reason units do
not receive the operational contract support they need for sustaining
military operations. Because of gaps in training, CORs were unable to
prepare well-articulated statements of work that clearly define the
warfighters’ needs. For example, DOD contracting personnel told us
about a dining facility in Afghanistan that was built without a kitchen
because it was not included in the original statement of work, resulting in
DOD having to generate a separate statement of work for the kitchen.
According to contracting officials and commanders, poorly written
statements of work increase the procurement process time, the workload
burden on the DOD contracting personnel, and delays and disruptions in
critical supplies and services needed for the mission.

Moreover, according to DOD, one of the acquisition review boards in
Afghanistan, known as the Joint Acquisition Review Board, reviews and
recommends approval or disapproval of proposed acquisitions to ensure
efficiency and cost effectiveness. 34 DOD contracting personnel
responsible for reviewing acquisition proposals told us that delays and
disruptions in supplies and services needed by the unit have been



34
  As described in Joint Publication 4-10, the Joint Acquisition Review Board’s main role is
to make specific approval and prioritization recommendations for all geographic
combatant commander directed, subordinate joint force commander controlled, high-value
and/or high-visibility common user logistics requirements, and to include
recommendations on the proper source of support for these requirements. See Joint Pub.
4-10 (Oct. 17, 2008).




Page 15                                           GAO-12-290 Operational Contract Support
                       attributed to incomplete or incorrect documents, such as statements of
                       work. Since CORs in Afghanistan are heavily relied upon by their units
                       and the acquisition personnel in the development of these documents, it
                       is important that they understand what paperwork is required and how to
                       properly complete it in order to obtain needed goods and services in a
                       timely manner. Contracting officials acknowledge the challenges with
                       preparing complete/correct statements of work and DOD is making some
                       effort to address the gaps in training. For example, the Defense
                       Acquisition University provides a training course on preparing
                       requirements documents such as statements of work; however, it is not a
                       DOD requirement for CORs and contracting personnel to complete this
                       training before assuming their contract-related roles and responsibilities.


Not All CORs Receive   DOD contracting personnel and CORs in Afghanistan told us that the
Required Training      CENTCOM Joint Theater Support Contracting Command contracting
                       officers were frequently unable to provide the required contract-specific
                       training (Phase II) for CORs because they were busy awarding contracts.
                       For instance, a COR whom we interviewed in Afghanistan was directing a
                       contractor to perform construction work or correct deficiencies in
                       performance without authorization from or communication with the
                       contracting officer. Because the COR had never received the required
                       training from the contracting officer, he was not aware that this practice
                       was potentially unauthorized. Without the follow-on Phase II training from
                       the contracting officer, CORs may lack a clear and full understanding of
                       the scope of their contract duties and responsibilities. In contrast, DCMA’s
                       contracting personnel provide specific contract training and mentoring to
                       its CORs because DCMA has full-time quality assurance personnel who
                       have been tasked with providing COR training and assistance. According
                       to DCMA officials, certified quality assurance representatives continue to
                       mentor CORs after their formal training has been completed.

                       Moreover, in addition to CORs, other personnel expected to perform
                       contract oversight and management duties in Afghanistan are not always
                       being trained. Joint Publication 4-10 states that military departments are
                       responsible for ensuring that military personnel outside the acquisition
                       workforce who are expected to have acquisition responsibility, including
                       oversight duties associated with contracts or contractors are properly
                       trained. 35 The Joint Publication also highlights the key role of


                       35
                        See Joint Pub. 4-10 at II-8 (Oct. 17, 2008).




                       Page 16                                         GAO-12-290 Operational Contract Support
commanders and senior leaders in operational contract support oversight.
However, contracting personnel that we interviewed in Afghanistan told
us that military personnel such as commanders and senior leaders did not
always receive training on their contract management and oversight
duties in Afghanistan and that commanders, particularly those in combat
units, do not perceive operational contract support as a warfighter task. 36
Although some contracting-related training is available for commanders
and senior leaders, it is not required before deployment. DOD has not
expanded the professional military education curriculum by increasing the
number of training offerings on operational contract support with a
particular emphasis on contingency operations to fully institutionalize
operational contract support in professional military education. Based on
our previous findings, it is essential that commanders and senior leaders
complete operational contract support training before deployment to avoid
confusion regarding their contract role and responsibilities in managing
and overseeing contractors, and nominating qualified CORs. In 2006, we
recommended that operational contract support training be included in the
professional military education to ensure that all military personnel
expected to perform contract management duties, including commanders
and senior leaders, receive training prior to deployment. DOD has taken
some actions to implement this recommendation by developing some
Programs of Instruction on contingency acquisition for their non-
acquisition workforce to be taught at some of the military and senior staff
colleges. However, commanders and senior leaders are not required to
take these courses before assuming their contract management and
oversight roles and responsibilities.




36
  Commanders and senior leaders generally lack the authority to enter into contracts or
otherwise direct contractors or contract performance. However, as noted in Joint
Publication 4-10, these personnel play a key role in determining specific contracted
support requirements, contracting planning, and execution of OCS oversight, which we
include here in the term “contract management and oversight.”




Page 17                                          GAO-12-290 Operational Contract Support
                      CORs did not always have the subject area-related technical expertise or
CORs Do Not Always    access to subject matter experts with those skills to manage and oversee
Have the Subject      contracts in Afghanistan, especially those contracts of a highly technical
                      and complex nature. The Defense Contingency Contracting Officer’s
Area-Related          Representative Handbook indicates that CORs are responsible for
Technical Expertise   determining whether products delivered or services rendered by the
Needed to Oversee     contractor conform to the requirements for the service or commodity
                      covered under the contract. Further, the Contracting Officer’s
Some Contracts        Representative Handbook notes that CORs should have technical
                      expertise related to the requirements covered by the contract.

                      However, according to CORs and contracting personnel we interviewed in
                      Afghanistan, CORs did not have the subject area-related technical
                      expertise necessary to monitor contract performance for the contracts
                      they were assigned to oversee. For example, many of these CORs were
                      appointed to oversee construction contracts without the necessary
                      engineering or construction experience, in part because their units lacked
                      personnel with those technical skills. While DCMA had subject matter
                      experts in key areas such as fire safety available for CORs needing
                      technical assistance, CORs for contracts written by the CENTCOM Joint
                      Theater Support Contracting Command did not have subject matter
                      experts to turn to for assistance, particularly in the construction trades
                      during the time of our visit. As a result, according to officials, there were
                      newly constructed buildings that had to be repaired or rebuilt before being
                      used by U.S. and Afghan troops because the CORs providing the
                      oversight were not able to adequately ensure proper construction.
                      According to personnel we interviewed, these practices resulted in
                      wasted resources, low morale, and risks to the safety of base and
                      installation personnel where the deficient guard towers, fire stations, and
                      gates were constructed. Officials stated that it is not uncommon for a
                      COR to accept a portion of the contractor’s work only to find later upon
                      further examination that the work was not in accordance with the contract
                      and substandard. Similarly, officials stated that the LOGCAP personnel
                      did not accept responsibility for maintenance of a facility that had been
                      constructed by Afghan contractors until LOGCAP contractors first
                      repaired or replaced wiring and plumbing to meet building codes.
                      Although the CORs were not solely responsible for contract oversight, or
                      for the implications identified above, they could have provided an early
                      verification of contractor performance. More importantly, in the
                      Afghanistan contracting environment the DOD contracting personnel
                      ultimately responsible for oversight—such as contracting officers—were
                      often removed or absent from the remote locations where the work was
                      performed and had no ability to communicate electronically. This results


                      Page 18                                   GAO-12-290 Operational Contract Support
in greater reliance on CORs and reduces the opportunity for CORs to
identify problems early in the process. The following were cases that
further illustrate the impact of CORs not having the technical skills or
support needed to perform contract management and oversight. Although
the CORs did not necessarily bear the sole responsibility for
consequences identified below, a well-trained COR might have been able
to prevent or mitigate the effects of the problems.

•    According to officials, a COR prepared a statement of work for a
     contract to build floors and install tents but failed to include any power
     requirements necessary to run air conditioners, heaters, and lights
     because the COR and unit personnel did not have the electrical
     technical expertise to properly and safely specify the correct power
     converter package 37 with the original request. Thus, the tents were
     unusable until the unit used a field ordering officer to order, at an
     additional cost, the correct power converters so that the tents were
     usable and completed in a timely fashion.
•    Contracting officials told us that guard towers at a forward operating
     base were poorly constructed and unsafe to occupy. As shown in
     figure 3, the staircase was unstable and not strong enough for
     climbing; it had to be torn down and reconstructed. The COR’s
     inadequate subject area-related technical expertise or access to
     subject matter experts prevented the early identification of defective
     welding on the staircase that rendered it unsuitable to use to climb up
     the guard tower.




37
  A power converter package comprises a fuse box, electrical wiring and other electrical
materials enabling connection to a power supply such as a generator, to run air
conditioners, heaters, and lights in the tents.




Page 19                                          GAO-12-290 Operational Contract Support
Figure 3: Unstable Staircase for Guard Towers




•   A senior engineer inspector official told us the cement block walls that
    had been accepted by a COR were poorly constructed. The COR did
    not have the subject area-related technical expertise or access to
    subject matter experts necessary to properly inspect and reject
    substandard cement block walls. For example, the contracting official
    noted large holes in a cement block wall that remained after the wood
    scaffolding was removed, which rendered the wall unstable (fig. 4).




Page 20                                     GAO-12-290 Operational Contract Support
Figure 4: Cement Block Wall with Large Holes That Remained When Scaffolding
Was Removed




•     A dining facility expected to service 1,000 military personnel was
      unused for a year due to emergent construction deficiencies such as
      electrical and plumbing issues. Contracting officials attributed the
      construction issues to the shortage of oversight personnel with subject
      area-related technical expertise or access to subject matter experts in
      construction. As a result, according to contracting personnel, repair
      work to correct the deficiencies was acquired under LOGCAP for
      $190,000 in addition to the original cost of the contract.
The issue of CORs not having adequate subject area-related technical
expertise has been a longstanding problem in DOD. For example, we
have previously reported in 2006, 2008, and again in 2010 that CORs do
not always have the subject area-related technical expertise necessary to
oversee contracts. 38 More recently in November and August 2011, the
Congressional Research Service and the Commission on Wartime
Contracting in Iraq and Afghanistan reported that DOD is still in need of
non-acquisition personnel with the necessary technical and subject matter



38
    GAO-07-145, GAO-08-1087, and GAO-10-472.




Page 21                                        GAO-12-290 Operational Contract Support
expertise to perform contractor oversight, respectively. 39 The Special
Inspector General for Afghanistan Reconstruction 40 has also reported
significant construction deficiencies with contracting in Afghanistan as a
result of inadequate subject area-related technical expertise on the part of
CORs and other contract oversight personnel. Problem areas identified
by the Inspector General included low-quality concrete (similar to
conditions depicted in fig. 2 and fig. 4) and inadequate roofing
installations, which were similar to other deficiencies we identified.

Further, based on DOD documentation, the nature of contract work in
Afghanistan has become more technical and complex, increasing the
number of CORs needed, the amount of time needed to award contracts,
and the number of errors during the early stages of the contracting
process (e.g., the requirements determination process). Due to the
complexity of construction projects in Afghanistan, DOD established an
initiative in April 2011 to assign construction inspectors to assist CORs in
managing and overseeing construction projects. According to a DOD
memorandum, 41 contracting officers should appoint construction
inspectors, in addition to CORs, when the nature of the project requires
technical assistance to ensure proper performance of work and when
such assistance is available. Because this program was not in effect
during the time of our visit in February 2011, we are unable to assess the
effectiveness of the use of construction inspectors. However, based on
our observations in Afghanistan, there is a shortage of subject area-
related technical experts that can serve as construction inspectors in
Afghanistan. CORs and other personnel that we interviewed in
Afghanistan acknowledged the benefit of having subject matter experts in
construction as well as other specialty areas such as food-, fuel-, and
electricity-related services.




39
  Congressional Research Service, Report Number R42084, Wartime Contracting in
Afghanistan: Analysis and Issues for Congress, by Moshe Schwartz, November 14, 2011
and Commission on Wartime Contracting in Iraq and Afghanistan, Transforming Wartime
Contracting: Controlling Cost and Reducing Risks, Final Report to Congress, August
2011.
40
  Special Inspector General Afghanistan Reconstruction, ANP District Headquarters
Facilities in Helmand and Kandahar Provinces Have Significant Construction Deficiencies
Due to Lack of Oversight and Poor Contractor Performance, October 27, 2010.
41
 Senior Contracting Official-Afghanistan (SCO-A), Memorandum for SCO-A Contracting
Officers-Inspector Duties for Construction Contractors (Apr. 27, 2011).




Page 22                                         GAO-12-290 Operational Contract Support
                     DOD does not have a sufficient number of CORs to oversee the
Number of CORs Is    numerous contracts in Afghanistan 42 and, according to some government
Not Sufficient to    officials, there are not enough CORs in theatre to conduct adequate
                     oversight. 43 The CENTCOM Joint Theater Support Contracting Command
Adequately Oversee   requires the nomination of CORs for all service contracts worth over
the Contracts in     $2,500 with significant technical requirements that require on-going
Afghanistan          advice and surveillance from technical or requirements personnel, unless
                     exempted by the contracting officer. 44 Although there is no specific
                     guidance on the number of contracts a single COR should manage, the
                     CENTCOM Joint Theater Support Contracting Command requires that
                     CORs nominations signed by the unit commander contain a statement
                     verifying that the CORs will have sufficient time to perform assigned
                     tasks. Similarly, the Defense Contingency Contracting Officer’s
                     Representative Handbook states that the requiring unit must allow
                     adequate resources (time, products, equipment, and opportunity) for the
                     CORs to perform their functions. In 2004, 2006, and again in 2010, we
                     reported that the DOD did not have a sufficient number of trained
                     oversight personnel, and during the course of our review we noted that
                     this situation persisted. Further, we found that CORs do not always have
                     the time needed to complete their oversight responsibilities. While
                     available data do not enable us to determine the precise number of
                     contracts that require CORs, in fiscal year 2011, DOD completed over
                     35,000 contracting actions on over 24,600 contracts and orders that were




                     42
                       We did not review every contract in Afghanistan managed by CORs. Our findings were
                     based on information obtained from DOD contracting personnel in Afghanistan—units that
                     we selected based on availability.
                     43
                       Congressional Research Service, Report Number R42084, Wartime Contracting in
                     Afghanistan: Analysis and Issues for Congress, by Moshe Schwartz, November 14, 2011,
                     p.5.
                     44
                       Contracting officers may exempt service contracts from the requirement when the
                     following three conditions are met: (1) the contract will be awarded using simplified
                     acquisition procedures; (2) the requirement is not complex; and (3) the contracting officer
                     documents the file, in writing why the appointment of a COR is unnecessary.




                     Page 23                                           GAO-12-290 Operational Contract Support
executed primarily in Afghanistan. 45 According to contracting officials and
CORs we interviewed in Afghanistan, some CORs are responsible for
providing oversight to multiple contracts in addition to performing their
primary military duty. For example, one COR we interviewed was
assigned to more than a dozen construction projects. According to the
COR, it was impossible to be at each construction site during key phases
of the project, such as for the concrete pouring of building footings, wiring
installation, or plumbing. Consequently, according to contracting officials,
construction on these multiple projects was completed without sufficient
government oversight and problems were not always identified until the
building was completed. This often resulted in significant rework, at a cost
to the U.S. taxpayer.

In another instance, an entire compound of five buildings was built in the
wrong location. According to DOD, based on the statement of work, the
compound should have been constructed on base behind the security
walls but instead was constructed outside the perimeter of the base in a
non-secure location. Contracting officials we spoke with in Afghanistan
attributed the problem to the numerous contracts managed by the COR
and the lack of time to perform contract oversight duties. As a result,
according to officials, the buildings (shown in fig. 5) could not be used.
The cost of the compound including the five buildings was $2.4 million.




45
  Data based on GAO analysis of Federal Procurement Database System-Next
Generation Data as of January 2012. The number of contracts includes stand-alone
contracts for goods and services, as well as purchase, delivery, and task orders; Blanket
Purchase Agreements and Indefinite Delivery/Indefinite Quantity contracts are not
included, but the orders under them are. The number of contract actions includes
contracts and orders awarded or modified where the place of performance was identified
as Afghanistan. Federal Procurement Database System-Next Generation Data includes
unclassified contracts that are estimated to be $3,000 or more and any modifications to
these contracts regardless of dollar value. Although modifications do not themselves
necessarily require the appointment of a new COR, they may indicate contract activity that
would necessitate continued COR involvement.




Page 24                                          GAO-12-290 Operational Contract Support
Figure 5: Compound Comprising Five Buildings Constructed in a Non-Secure
Location outside the Perimeter of a Base




In addition, in some cases units did not assign enough CORs to provide
oversight. For example, we were told by one unit that it did not have a
sufficient number of CORs to provide proper oversight of dining facility
services, including ordering and inspecting food and supplies. Although
the unit was able to provide one COR for each dining facility, the dining
facilities operate 24 hours a day. Contracting officials expressed concern
that there were not enough CORs to provide sufficient oversight of the
dining facilities 24 hours a day during all shifts of operation.

A significant factor that might contribute to a shortage of CORs is that
contract oversight is often assigned a lower priority for units than tasks
associated with their primary missions. Army officials stated that
commanders, particularly those in combat units, do not perceive contract
management and oversight as a warfighter task. In a March 2010 report,
we noted that commanders and senior leaders often view operational
contract support as a logistics problem or a contracting problem and not
as a responsibility of the entire force. Most of the CORs we interviewed
performed their contract duties as an additional duty to their military
responsibilities. As a result, these CORs said they did not always have
the time to complete their oversight responsibilities or that not enough
CORs were assigned to a contract to provide sufficient oversight. In fact,
some commanders and other personnel we interviewed questioned the
idea that units should be responsible for contract oversight, and believed


Page 25                                   GAO-12-290 Operational Contract Support
              that contract oversight should be provided by other organizations. While
              DOD is experiencing a shortage of CORs in Afghanistan, the amount of
              money spent on contracts has increased as evidenced by the increase in
              reported DOD obligations for contracts—from $11 billion in fiscal year
              2010 to $16 billion in fiscal year 2011. Additionally, the turnover rate of
              CORs is high due to unit rotations, frequently leaving gaps in contract
              coverage. Based on guidance from the Commander of the International
              Security Assistance Force and United States Forces-Afghanistan issued
              in September 2010, 46 even more personnel are needed to oversee
              contracts as a result of this increase.


              DOD and the services have taken some steps, such as developing a new
Conclusions   CORs training course with a focus on contingency operations to improve
              oversight of contracts in contingency operations, such as in Afghanistan;
              other more general efforts, such as the COR certification program for
              services’ acquisitions, may also lead to improvement. However, in our
              work in Afghanistan we found that CORs are still not fully prepared to
              oversee the multitude of contracts for which they are assigned, potentially
              resulting in a significant waste of taxpayer dollars and an increased risk to
              the success of operations. The current mechanism for training CORs that
              also perform duties related to the requirements determination process
              and to the development of requirements documentation continues to have
              weaknesses because DOD has not yet developed training standards to
              ensure that these personnel fully understand Joint Operational Area
              specific issues such as the Afghan First program, the Counterinsurgency
              Contracting Guidance, and the details on the preparation of statements of
              work and documents required by the contract review boards. As noted in
              an Army Contracting Command publication, what contracting
              organizations do and how they do it cannot be foreign to the warfighter.
              Military personnel such as commanders, senior leaders, CORs, and other
              personnel expected to have a role in operational contract support are
              often not familiar with their contract roles and responsibilities until they
              reach theater because DOD has not sufficiently expanded the
              professional military education curriculum and provided more training on
              contract support with a particular emphasis on contingency operations.
              Further, having an insufficient number of CORs with the appropriate


              46
                 Commander, International Security Assistance Force/United States Forces -
              Afghanistan, COMISAF’s Counterinsurgency (COIN) Contracting Guidance (Sept. 8,
              2010).




              Page 26                                      GAO-12-290 Operational Contract Support
                      subject area-related technical expertise or access to dedicated subject
                      matter experts in specialty areas hinders DOD’s ability to ensure that
                      operational units obtain vital supplies and services when needed.
                      Moreover, contract management and oversight has become more
                      challenging due to a shortage of oversight personnel, an increase in the
                      number of contracts, a high personnel turnover rate, training burden
                      challenges, and an increase in the complexity of the work contracted. All
                      of these have resulted in delays and errors in the procurement process.
                      Further, as a result of these workload constraints, military personnel
                      serving as CORs are limited in the number of contracts that they can
                      reasonably manage and oversee considering the technical nature and
                      complexity of each contract. Given DOD’s heavy reliance on contractors
                      during operations in Afghanistan and given the unpredictability of
                      potential future contingencies, it is critical that DOD address these
                      challenges as soon as possible to mitigate the risk to the success of
                      operations, to obtain reasonable assurance that contractors are meeting
                      their contract requirements and that troops are getting what they need to
                      support contingency operations, and to help ensure that tax dollars are
                      not being wasted.


                      To provide for improved oversight of operational contract support, we are
Recommendations for   recommending that DOD enhance the current strategy for providing
Executive Action      contract management and oversight in Afghanistan and other areas of
                      operations. Specifically, we recommend that the Secretary of Defense
                      take the following four actions:

                      •   Direct the CENTCOM Commander in consultation with the
                          Secretaries of the military departments to develop standards for
                          training to ensure that CORs are fully trained on the contract support
                          in Afghanistan, to include information on the Afghan First program,
                          Counterinsurgency Contracting Guidance, and details on the
                          preparation of statements of work and documents required by the
                          contract review boards.
                      •   Direct the Chairman of the Joint Chiefs of Staff and the Secretaries of
                          the military departments to fully institutionalize operational contract
                          support in professional military education to ensure that CORs,
                          commanders, senior leaders, and other personnel expected to
                          perform operational contract support duties are prepared to do so by
                          integrating and expanding the curriculum and by increasing the
                          number of training offerings on operational contract support with a
                          particular emphasis on contingency operations.




                      Page 27                                  GAO-12-290 Operational Contract Support
                     •   Direct the Under Secretary of Defense for Acquisition, Technology,
                         and Logistics in consultation with the appropriate CENTCOM officials
                         to establish and maintain a sufficient number of subject matter experts
                         in specialty areas dedicated to the CENTCOM Joint Theater Support
                         Contracting Command to assist CORs with providing contract
                         oversight.
                     •   Direct the Under Secretary of Defense for Acquisition, Technology,
                         and Logistics to develop standards regarding the number of contracts
                         that a COR can manage and oversee based on the technical nature
                         and complexity of the contract.

                     We provided a draft of this report to DOD for comment. In written
Agency Comments      comments, DOD concurred with our recommendations. DOD’s comments
and Our Evaluation   are reprinted in their entirety in appendix II. DOD also provided technical
                     comments, which we incorporated into the report as appropriate.

                     DOD concurred with our recommendation that the Secretary of Defense
                     direct the CENTCOM Commander in consultation with the Secretaries of
                     the military departments to develop standards for training to ensure that
                     CORs are fully trained in contract support in Afghanistan, to include
                     information on the Afghan First program, Counterinsurgency Contracting
                     Guidance, and details on the preparation of statements of work and
                     documents required by the contract review boards. DOD stated that
                     CENTCOM has identified COR training in its pre-deployment requirement
                     for units and personnel being deployed to Afghanistan, referring to
                     fragmentary order 09-1700, which lists theater training requirements for
                     forces deploying to the CENTCOM area of responsibility. Although the
                     fragmentary order identifies COR training as a training requirement for
                     certain personnel, the wording in this order lacks the specificity to
                     adequately prepare CORs for contract support in Afghanistan. For
                     example, the fragmentary order does not require that CORs be trained on
                     how to use the Afghan First Program and the Counterinsurgency
                     Contracting Guidance and on how to prepare the statements of work and
                     other documents required by the contract review boards. DOD further
                     stated that CENTCOM reviewed and updated pre-deployment training
                     requirements during a conference in early January 2012, but did not
                     provide any specific information on what those updates entailed. DOD
                     also stated that the COR training requirement will remain as required pre-
                     deployment training and that an updated version of the pre-deployment
                     requirement will be finalized and released no later than April 2012.
                     Because DOD did not provide any specific details on what, if any,
                     changes to training requirements will be included in its April 2012 update,



                     Page 28                                  GAO-12-290 Operational Contract Support
we are unable evaluate the extent to which DOD’s proposed actions
would address our recommendations.

DOD concurred with our recommendation that the Secretary of Defense
direct the Chairman of the Joint Chiefs of Staff and the Secretaries of the
military departments to fully institutionalize OCS in professional military
education by increasing the number of training offerings with a particular
emphasis on contingency operations to ensure that CORs, commanders,
senior leaders, and other personnel expected to perform OCS duties are
prepared to do so. DOD stated that the Deputy Assistant Secretary of
Defense for Program Support in the Office of the Under Secretary of
Defense for Acquisition, Technology and Logistics and the Director of
Logistics in the Joint Staff are currently engaged in a study to develop a
strategy for OCS professional military education and that DOD recognizes
the need for a holistic view of the entire OCS education requirement.
DOD said it will assess existing professional military education to
recommend OCS learning objectives for appropriate places in existing
curricula. Additionally, DOD stated that the Army has recently taken major
steps to improve training for commanders, senior leaders, and personnel
expected to perform OCS duties. However, DOD did not describe what
specific steps DOD has taken to fully institutionalize OCS in professional
military education. Further, while it is commendable that DOD is
developing a strategy for the OCS professional military education, DOD
did not indicate when its strategy would be completed. Until DOD
expands the curriculum and increases the number of training offerings on
OCS, contract management and oversight in Afghanistan will continue to
be hindered.

DOD concurred with our recommendation that the Secretary of Defense
direct the Under Secretary of Defense for Acquisition, Technology, and
Logistics in consultation with the appropriate CENTCOM officials to
establish and maintain a sufficient number of subject matter experts in
specialty areas dedicated to the CENTCOM Joint Theater Support
Contracting Command to assist CORs with providing contract oversight.
DOD stated that the Undersecretary of Defense for Acquisition,
Technology, and Logistics will work through the Joint Staff to have
CENTCOM identify the requirements for dedicated subject matter experts
and the military departments to source these positions within budget
constraints, and that the subject matter experts will be sourced through
the normal requirements process. We agree that this proposed strategy
has the potential to address our recommendation to establish and
maintain a sufficient number of subject matter experts in specialty areas.



Page 29                                  GAO-12-290 Operational Contract Support
DOD concurred with our recommendation that the Secretary of Defense
direct the Under Secretary of Defense for Acquisition, Technology, and
Logistics develop standards regarding the number of contracts that a
COR can manage and oversee based on the technical nature and
complexity of the contract. DOD agreed that there is a limit to the number
of contracts that a COR can support. Further, DOD stated that the Under
Secretary of Defense for Acquisition, Technology, and Logistics will
develop and publish appropriate standards based on the technical nature
and complexity of the contract. We agree that these actions, if fully
implemented, would address the intent of our recommendation.


We are sending copies of this report to interested congressional
committees, the Secretary of Defense, the Chairman of the Joint Chief of
Staff, the Under Secretary of Defense for Personnel and Readiness, the
Under Secretary of Defense for Acquisition, Technology & Logistics,
Secretaries of the Army, Navy and Air Force, the Commandant of the
Marine Corps, and the Commander of CENTCOM. This report will be
available at no charge on GAO’s website, http://www.gao.gov.

If you or your staff have any questions about this report, please contact
me at (404) 679-1808 or russellc@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this letter. GAO staff who made key contributions are listed in
appendix III.




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




Page 30                                  GAO-12-290 Operational Contract Support
List of Committees

The Honorable Carl Levin
Chairman
The Honorable John McCain
Ranking Member
Committee on Armed Services
United States Senate

The Honorable Daniel Inouye
Chairman
The Honorable Thad Cochran
Ranking Member
Subcommittee on Defense
Committee on Appropriations

United States Senate
The Honorable Howard P. McKeon
Chairman
The Honorable Adam Smith
Ranking Member
Committee on Armed Services
House of Representatives

The Honorable C.W. Bill Young
Chairman
The Honorable Norman D. Dicks
Ranking Member
Subcommittee on Defense
Committee on Appropriations
House of Representatives




Page 31                          GAO-12-290 Operational Contract Support
Appendix I: Scope and Methodology
             Appendix I: Scope and Methodology




             To determine the extent to which the required Department of Defense
             (DOD) training prepares contracting officer’s representatives (COR) to
             perform their management and oversight duties in Afghanistan, we
             examined guidance, evaluated the content of the required training, and
             interviewed CORs and senior contracting personnel from over 30 defense
             organizations and units in Bagram, Kabul, Kandahar, and Camp
             Leatherneck, Afghanistan. We examined guidance such as the Joint
             Publication 4-10, the Defense Contingency Contracting Officer’s
             Representative Handbook and the U.S. Central Command (CENTCOM)
             Joint Theater Support Contracting Command Standard Operating
             Procedures addressing the CORs program 1 to identify training
             requirements for CORs in contingency areas such as Afghanistan. To
             evaluate the content of the training, we attended training for CORs at Fort
             Carson, Colorado, and completed the Defense Acquisition University’s
             online CORs contingency courses. We reviewed documents such as the
             program of instructions or course syllabus and other related training
             documents on the curriculum. We interviewed commanders, senior
             leaders, and contracting personnel from the Office of the Secretary of
             Defense, the Joint Staff, the combatant commands, service headquarters,
             the Defense Contract Management Agency, and defense universities to
             obtain a comprehensive understanding of what training was available for
             CORs in Afghanistan. To help determine what knowledge CORs needed
             to perform their management and oversight responsibilities, we reviewed
             contract-related documents such as contracts, purchase requisitions, and
             statements of work.

             To determine the extent to which CORs have the appropriate subject
             area-related technical expertise to oversee contracts in Afghanistan, we
             reviewed the CENTCOM Joint Theater Support Contracting Command
             Standard Operating Procedure addressing the CORs program and the
             Defense Contingency Contracting Officer’s Representative Handbook.
             We spoke with commanders, senior leaders, senior contracting
             personnel, and CORs in Afghanistan to understand the degree of subject
             area-related technical expertise possessed by CORs for contracts they
             were assigned to manage and the extent to which subject matter experts
             were available to provide technical support to CORs. We examined
             contract-related documents such as contracts and training transcripts to



             1
              CENTCOM Contracting Command Standard Operating Procedure No.10-02: Contracting
             Officer’s Representative (COR) Program (Rev. 2, June 2010).




             Page 32                                    GAO-12-290 Operational Contract Support
                         Appendix I: Scope and Methodology




                         assess the technical requirements of the contract as well as the technical
                         background of CORs.

                         To determine the extent to which the number of CORs is sufficient to
                         manage the contracts in Afghanistan, we examined the CENTCOM Joint
                         Theater Support Contracting Command guidance and the Defense
                         Contingency Contracting Officer’s Representative Handbook to identify
                         requirements related to the workload of CORs. We interviewed senior
                         DOD contracting personnel and CORs to determine whether there was a
                         sufficient number of CORs to manage the contracts in Afghanistan. In
                         addition, we met with CORs to identify their contract workload and the
                         nature of contracts they were assigned to manage.

                         We selected units to interview that would be in Afghanistan and available
                         during the time of our visit based on input from service officials as well as
                         status reports from the U.S. Army, the U.S. Air Force, and the U.S. Army
                         National Guard. To facilitate our meetings with CORs and contracting
                         personnel in Afghanistan, we developed a set of structured questions that
                         were pre-tested and coordinated with service contracting experts to help
                         ensure that we had solicited the appropriate responses. We selected and
                         examined photographs of supplies and services provided to us by the
                         DOD personnel to best illustrate the nature of the contract support issues
                         we encountered in Afghanistan.

                         During our review, we visited or contacted key officials, CORs, senior
                         contracting and other contracting personnel from DOD components and
                         entities in the United States and in Afghanistan.


DOD Components and       •   Office of the Under Secretary of Defense for Personnel and
Entities in the United       Readiness, Arlington, Virginia
                         •   Office of the Under Secretary of Defense for Acquisition, Technology,
States                       and Logistics, Defense Procurement Acquisition Policy, Arlington,
                             Virginia
                         •   U.S. Central Command, MacDill Air Force Base, Tampa, Florida
                         •   U.S. Joint Forces Command, Suffolk, Virginia
                         •   U.S. Army
                             •     Assistant Secretary of the Army for Acquisition, Logistics, and
                                   Technology, Arlington, Virginia
                             •     U.S. Army Material Command, Fort Belvoir, Virginia
                             •     U.S. Army Expeditionary Contracting Command, Fort Belvoir,
                                   Virginia
                             •     U.S. Army Forces Command, Fort McPherson, Georgia


                         Page 33                                    GAO-12-290 Operational Contract Support
                          Appendix I: Scope and Methodology




                              •     U.S. Army Training and Doctrine Command, Fort Monroe, Virginia
                              •     U.S. Army Budget Office, Arlington, Virginia
                              •     U.S. Army Acquisition, Logistics, and Technology Integration
                                    Office, Fort Lee, Virginia
                          •   U.S. Air Force
                              •     U.S. Air Force, Air Force Contracting, Arlington, Virginia
                          •   U.S. Navy
                              •     Navy Expeditionary Combat Command, Joint Expeditionary Base
                                    Little Creek-Fort Story, Virginia Beach, Virginia
                          •   U.S. Marine Corps
                              •     U.S. Marine Corps Headquarters, Installation and Logistics
                                    Contracting Division, Arlington, Virginia
                              •     National Guard Bureau, Arlington, Virginia
                              •     Defense Contract Management Agency, Alexandria, Virginia

DOD Components and        Kandahar
Entities in Afghanistan
                          •   U.S. Forces Afghanistan, South
                          •   Joint Sustainment Command Afghanistan
                          •   Defense Contract Management Agency
                          •   Logistics Civil Augmentation Program
                          •   Regional Contracting Center
                          •   101th Combat Aviation Brigade
                          •   3rd Naval Construction Regiment
                          •   451st Air Expeditionary Wing
                          •   1st Brigade Combat Team/4th Infantry Division
                          Camp Leatherneck

                          •   Defense Contract Management Agency
                          •   Logistics Civil Augmentation Program
                          •   Regional Support Command
                          •   Logistics Civil Augmentation Program
                          •   Division/Marine Headquarters Group, I Marine Expeditionary Force
                          •   Marine Aircraft Wing Marine Logistics Group, I Marine Expeditionary
                              Force
                          •   Operational Contract Support team, I Marine Expeditionary Force
                          •   C-8 Comptroller, I Marine Expeditionary Force
                          •   Camp Leatherneck Commandant, I Marine Expeditionary Force




                          Page 34                                     GAO-12-290 Operational Contract Support
Appendix I: Scope and Methodology




Kabul

•   U.S. Central Contracting Command
•   Defense Contract Management Agency
•   Logistics Civil Augmentation Program
•   Senior Contracting Officer – Afghanistan
•   Task Force Spotlight
•   Task Force 2010
•   717th Expeditionary Air Support Operations Squadron
Bagram

•   Regional Contracting Center
•   Combined Joint Task Force Four
•   Defense Contract Management Agency
•   Defense Contract Audit Agency
•   2nd Brigade, 34th Infantry Division
•   17th Combat Support Sustainment Brigade
•   Combined Joint Task Force-101 CJ 4 & 8
•   46th Military Police
We performed our audit work from April 2010 to March 2012 in
accordance with generally accepted government auditing standards.
Generally accepted government auditing standards require that we plan
and perform the audit to obtain sufficient, appropriate evidence to provide
a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable
basis for this assessment based on our audit objectives.




Page 35                                  GAO-12-290 Operational Contract Support
Appendix II: Comments from the Department
             Appendix II: Comments from the Department
             of Defense



of Defense




             Page 36                                     GAO-12-290 Operational Contract Support
Appendix II: Comments from the Department
of Defense




Page 37                                     GAO-12-290 Operational Contract Support
Appendix II: Comments from the Department
of Defense




Page 38                                     GAO-12-290 Operational Contract Support
Appendix III: GAO Contact and Staff
                  Appendix III: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Cary B. Russell, (404) 679-1808 or russellc@gao.gov.
GAO Contact
                  In addition to the contact named above, William Solis, Director; David
Staff             Schmitt, Assistant Director; Carole Coffey, Assistant Director; Tracy
Acknowledgments   Burney, Alfonso Garcia, Christopher Miller, Michael Shaughnessy and
                  Natasha Wilder made key contributions to this report. Peter Anderson,
                  Kenneth Cooper, Branch Delaney, Mae Jones and Amie Steele provided
                  assistance in report preparation.




(351474)
                  Page 39                                GAO-12-290 Operational Contract Support
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