SIGAR
1177

Special Inspector General for
Afghanistan Reconstruction

SIGAR 20-44 Audit ReportAfghan National Army: DOD Did Not Conduct
Required Oversight or Assess the Performanceand Sustainability of the $174 Million ScanEagle
Unmanned Aerial System Program

JULY

2020
SIGAR 20-44-AR/DOD ScanEagle ProgramSIGAR

July 2020

Afghan National Army: DOD Did Not Conduct Required Oversight or Assess
the Performance and Sustainability of the $174 Million ScanEagle
Unmanned Aerial System Program

Special Inspector General for
Afghanistan Reconstruction

SIGAR 20-44-AR AUDIT REPORT

WHAT SIGAR REVIEWEDSIGAR found that Naval Air Systems Command (NAVAIR)—responsible foroverseeing the ScanEagle contracts and Insitu—is unable to determine theextent to which Insitu met the terms of the contracts because NAVAIR did
not meet U.S. government requirements for conducting contract oversight.
First, NAVAIR did not designate a Contracting Officer’s Representative(COR) for all of the ScanEagle contracts, as DOD guidance required.
NAVAIR’s Contracting Officer did not perform COR duties for thosecontracts, as US guidance suggests for firm-fixed-price contracts where a
COR is not assigned. Second, NAVAIR did not have an in-country sponsor
in Afghanistan responsible for validating contract requirements, as DOD
required. Third, NAVAIR could not produce evidence that Insitu completedmany of the deliverables required to determine if the contractor met theterms of the contracts. NAVAIR provided no evidence to SIGAR that Insitu
completed 122 of the total 403 known deliverables required (about 30
percent). For the evidence that NAVAIR could not provide, SIGAR asked
Insitu to address the gap in records. Insitu provided evidence that itcompleted 4 of the 122 deliverables that NAVAIR did not have.

In a March 2015 Department of Defense(DOD) memorandum, the Combined
Security Transition Command–Afghanistan(CSTC-A) helped identify an impending
capability gap related to the ANA’s (Afghan
National Army) ability to conduct
intelligence, surveillance, andreconnaissance (ISR) operations that would
result from a drawdown of coalition forces.
To increase the ANA’s ISR capabilities, DOD
funded the purchase of 16,000 ISR assets,such as night vision devices andsurveillance unmanned aerial vehicles, likethe ScanEagle Unmanned Aerial System(UAS). The 2019 Afghanistan Compact
states that ANA’s ISR capabilities support
the U.S. and Afghan governments’ broader
goals for the Afghan National Defense andSecurity Forces (ANDSF) to plan andexecute special, conventional, and police
operations, using Afghan-derived
intelligence to counter current and future
threats to Afghanistan.
This audit examined the implementationand oversight of five firm-fixed-price
ScanEagle contracts awarded to Insitu Inc.
valued at more than $174 million, and thebroader ScanEagle program from November
2015 through November 2019. The
objectives of this audit were to determine
the extent to which (1) the contractor,
Insitu, met the terms of the contracts and
DOD performed the required oversight of
the ScanEagle program; (2) DOD measured
and evaluated the ScanEagle program’s
performance; and (3) DOD planned for theAfghan government’s sustainment of the
ScanEagle program, and the ANA developed
the capabilities necessary to operate andsustain the program.

WHAT SIGAR FOUND

NAVAIR acknowledged that it had gaps in its contract records and told usthat these gaps resulted, in part, from losing electronic records withNAVAIR’s update to Windows 10 in February 2018. However, Insitu did
not explain why it could not provide evidence for the missing deliverables
it was required to produce. Per Federal Acquisition Regulation 4.703,
contractors are required to retain all contract records related to pricing,proposals, negotiations, and performance of the contract andsubcontract. The generally accepted time period for retaining records is
not less than 3 years after final payment.
NAVAIR and Insitu’s records gaps also meant NAVAIR lacked important
information on the numbers of ANA soldiers Insitu trained (i.e., training
summation reports), hours ANA operated ScanEagle vehicles flew (i.e.,monthly flight readiness reports), spare parts purchased and used tomaintain the ScanEagle systems (i.e., parts usage reports), and ScanEagle
vehicle crashes or failures (i.e., MISHAP reports). In January 2020, NAVAIR
stated that the situation reports the command provided to SIGAR include
all of this information. However, SIGAR’s review and analysis of thereports found that they did not contain much of the required performance
information. It appears that NAVAIR is using the Situation Reports to fulfill
requirements of other deliverables, such as training summation and
MISHAP reports. However, the situation reports do not include all
information required by the various deliverables; each deliverable is aseparate and distinct requirement from the Situation Reports.
Moreover, based on SIGAR’s analysis of the performance reporting
received, such as the monthly flight readiness reports and situation
reports, SIGAR found that the actual number of flight hours Insitu

For more information, contact SIGAR Public Affairs at (703) 545-5974 or sigar.pentagon.ccr.mbx.public-affairs@mail.mil.

reported for the operating sites was 12,413 hours, less than half of the 27,261 flight hours NAVAIR estimated would benecessary to support ScanEagle missions during that specified time. NAVAIR lacks the performance informationnecessary to determine the extent to which the ScanEagle equipment and training services it procured is used. This also
raises concerns about how NAVAIR justified procuring 105 ScanEagle vehicles totaling over $32 million and spare parts
totaling over $52 million, and future planned procurements.
DOD did not measure and evaluate ScanEagle program performance. SIGAR found that DOD and CSTC-A did not
implement performance management guidance required in DOD Instruction 5132.14, Assessment, Monitoring, andEvaluation Policy for the Security Cooperation Enterprise. For example, DOD did not provide SIGAR a performance
management plan or a centralized independent evaluation of significant security cooperation initiatives, such as the
ScanEagle program, to examine their relevance, effectiveness, and sustainability. In May 2020, after reviewing a draft ofthis report, DOD officials provided us a statement explaining their interpretation of the DOD instruction and stated it istheir opinion that they do not need to, or plan to, measure and evaluate ScanEagle program performance in accordancewith DOD Instruction 5132.14. Specifically, DOD officials stated that (1) the guidance did not apply to the ScanEagle
program because activities funded with the Afghanistan Security Forces Fund prior to fiscal year 2019 were exemptedfrom DOD Instruction 5132.14; and (2) DOD has resource limitations, considers ScanEagle to be an activity, not a
program, and DOD will decide whether there is any value of evaluating the performance of the intelligence, surveillance,and reconnaissance program in Afghanistan in two or three years. As a result, DOD currently lacks a formal plan formeasuring the performance of the ScanEagle program. A senior CSTC-A official told SIGAR in January 2019 that CSTC-A’s
only means for measuring ScanEagle program performance is using the Afghanistan Compact—a U.S. and Afghan
initiative managed by U.S. Forces–Afghanistan to track the Afghan government’s commitments and implementation of
U.S. development assistance—and collecting anecdotal evidence from ANA operations. Despite previous assertions thatit used the Compact to measure ScanEagle outcomes, CSTC-A told SIGAR in September 2019 that it no longer uses theCompact. CSTC-A officials told SIGAR that examples of ScanEagle program performance successes include ANA’s ability
to occasionally fly a ScanEagle vehicle without Insitu’s support, identify enemy sites while flying (e.g., locating two
Taliban prisoner of war camps), and provide ANA forces video to assist in aerial strikes of terrorist targets.
Furthermore, DOD did not implement DOD Instruction 5132.14 requirements to assess the sustainability of the
ScanEagle program. For example, the January 2017 DOD Instruction 5132.14 requires DOD—to perform a “rigorous”
evaluation of a security cooperation initiative to examine its relevance, effectiveness, and sustainability; and to conduct
an initial assessment that describes the Afghan government’s willingness and propensity to implement and sustain the
program, improve institutional capacity, build capabilities as needed by its government, and to identify requirements,
gaps, and potential risks. SIGAR found that DOD did not assess the sustainability of the ScanEagle program, or the ANA’s
ability to sustain the ISR capabilities it developed and acquired using the ScanEagle systems. Additionally, in May 2020,
DOD officials told us that the agency is not required to, and is not, applying the DOD instruction to the $174 million
ScanEagle program.
CSTC-A and NAVAIR have encountered delays and challenges in developing the ANA’s capability to independently
operate and maintain the ScanEagle program due to (1) inadequate training of ANA soldiers, (2) insufficient manning of
ANA ScanEagle operations, (3) insufficient fielding of operational ANA ScanEagle sites, and (4) the ANA’s inability tooperationalize intelligence obtained through the program. For example, the ANA is not tracking the real-time location ofequipment across Afghanistan. CSTC-A officials told us they are concerned that the ANA does not know where theequipment it owns is located or whether it is being used appropriately. As a result of these delays and challenges, DOD
lacks information necessary to track, understand, and improve the return on its $174 million investment in the program,and is poorly positioned to transfer responsibilities to the ANA.

For more information, contact SIGAR Public Affairs at (703) 545-5974 or sigar.pentagon.ccr.mbx.public-affairs@mail.mil.

WHAT SIGAR RECOMMENDS
To improve ScanEagle contract oversight, SIGAR recommends that the Secretary of Defense:
Direct NAVAIR personnel managing and overseeing the ScanEagle contracts to ensure the Contracting
Officer’s Representative (COR) on the current contract is performing all required COR duties, including
documenting and maintaining records such as reporting deliverables.
Direct NAVAIR, in coordination with appropriate coalition partners, to immediately designate and announce
an in-country sponsor and an in-country COR, Contracting Officer Technical Representative, or Government
Technical Product Representation for the current ScanEagle contract.
To better understand the performance of the ScanEagle program, and the Afghan government’s ability to sustain the
program, SIGAR recommends that the Secretary of Defense:
Direct NAVAIR to immediately share existing Insitu performance reporting information and related contract
deliverables with appropriate coalition partners responsible for the current ScanEagle contracts; and agree toa plan with CSTC-A for sharing future contract performance information.
To help ensure that U.S. investments in training ANA soldiers to perform the ScanEagle mission are protected, SIGAR
recommends that the Secretary of Defense:
Work with the ANA to develop requirements to help ensure that recently certified ANA soldiers will be placedin positions that take advantage of their newly acquired skills.
To help ensure that U.S. procurements in ScanEagle equipment are protected and used as intended, SIGAR
recommends that the Secretary of Defense:
Direct responsible DOD departments to work with the ANA to establish a system for tracking the location of
ScanEagle equipment across Afghanistan.
SIGAR received written comments from (1) the Deputy Assistant Secretary of Defense for Afghanistan, Pakistan, andCentral Asia; (2) the Combined Security Transition Command–Afghanistan; and (3) the United States Forces–
Afghanistan Deputy Chief of Staff for Intelligence, Train, Advise, and Assist, which are reproduced in appendices IV, V,
and VI respectively. The Deputy Assistant Secretary concurred with four of SIGAR’s recommendations, and partiallyconcurred with the second recommendation.
Additionally, the Deputy Chief of Staff for Intelligence, Train, Advise, and Assist, CSTC-A, Navy Air Systems Command,and the Office of the Under Secretary of Defense for Policy provided technical comments which were integrated into
the report as appropriate. For example, SIGAR added language to the report to reflect a statement by the Deputy Chiefof Staff for Intelligence, Train, Advise, and Assist that the ScanEagle program has made accomplishments in the trainthe-trainer program, and that DOD’s stated goal remains for the ANA to take over all ScanEagle training in 2021.
In its comments, CSTC-A stated that because the program transitioned to Deputy Chief of Staff for Intelligence, Train,
Advise, and Assist, CSTC-A would provide support in implementing the recommendations.
SIGAR will follow-up with DOD within 60 days to identify its actions to address the five recommendations.

For more information, contact SIGAR Public Affairs at (703) 545-5974 or sigar.pentagon.ccr.mbx.public-affairs@mail.mil.

July 13, 2020

The Honorable Dr. Mark T. Esper
Secretary of Defense
The Honorable Kenneth J. Braithwaite
Secretary of the Navy
General Kenneth F. McKenzie Jr.
Commander, U.S. Central Command
General Austin Scott Miller
Commander, U.S. Forces–Afghanistan
Commander, Resolute Support
Lieutenant General E. John Deedrick Jr.
Commanding General, Combined Security Transition Command–Afghanistan

This report discusses the results of SIGAR’s audit of the Department of Defense’s (DOD) implementation andoversight of the ScanEagle Unmanned Aerial System (UAS) contracts and program to train the Afghan National
Army (ANA) to use the system in Afghanistan. Since November 2015, DOD has awarded five contracts valued
at more than $174 million to Insitu Inc. to procure ScanEagle UAS, establish operational sites throughout
Afghanistan, train the ANA to operate and maintain the system, and procure spare parts for the systems’continuing operations.
We are making five recommendations. We recommend that the Secretary of Defense: (1) direct Naval Air
Systems Command (NAVAIR) personnel managing and overseeing the ScanEagle contracts to ensure that theContracting Officer’s Representative (COR) on the current contract is performing all required COR duties,
including documenting and maintaining records such as reporting deliverables; (2) direct NAVAIR, in
coordination with appropriate coalition partners, to immediately designate and announce an in-country
sponsor and an in-country COR, Contracting Officer’s Technical Representative, or Government Technical
Product Representation for the current ScanEagle contract; (3) direct NAVAIR to immediately share existing
Insitu performance reporting information and related contract deliverables with appropriate coalition partners
for the current ScanEagle contracts, and, agree to a plan with CSTC-A for sharing future contract performance
information;; (4) work with the ANA to develop requirements to help ensure that recently certified ANA soldiers
will be placed in positions that take advantage of their newly acquired skills; and (5) direct responsible DOD
departments to work with the ANA to establish a system for tracking the location of ScanEagle equipment
across Afghanistan.
We received written comments from (1) the Deputy Assistant Secretary of Defense for Afghanistan, Pakistan,and Central Asia; (2) the Combined Security Transition Command–Afghanistan; and (3) the United States
Forces–Afghanistan Deputy Chief of Staff for Intelligence, Train, Advise, and Assist, which are reproduced inappendices IV, V, and VI respectively. The Deputy Assistant Secretary concurred with four of SIGAR’s
recommendations, and partially concurred with the second recommendation.

Additionally, the Deputy Chief of Staff for Intelligence, Train, Advise, and Assist, CSTC-A, Navy Air Systems
Command, and the Office of the Under Secretary of Defense for Policy provided technical comments whichwere integrated into the report as appropriate. For example, we added language to the report to reflect astatement by the Deputy Chief of Staff for Intelligence, Train, Advise, and Assist that the ScanEagle program
has made accomplishments in the train-the-trainer program, and DOD’s goal remains for the ANA to take over
all ScanEagle training in 2021.
In its comments, CSTC-A stated that because the program transitioned to Deputy Chief of Staff for Intelligence,
Train, Advise, and Assist, CSTC-A would provide support in implementing the recommendations.
SIGAR conducted this work under the authority of Public Law No. 110‐181, as amended, and the Inspector
General Act of 1978, as amended; and in accordance with generally accepted government auditing standards.
We are requesting documentation of the corrective actions taken and/or target dates for completion of therecommendations. Please provide your responses on the corrective actions to be taken tosigar.pentagon.audits.mbx.recommendation-follow-up@mail.mil within 60 days from the issue date of thisreport.

John F. Sopko
Special Inspector Generalfor Afghanistan Reconstruction

TABLE OF CONTENTS

Background .................................................................................................................................................................. 2
DOD Is Unable to Determine the Extent to Which Insitu Met the Terms of the ScanEagle Contracts
Because DOD Did Not Conduct Required Oversight.................................................................................................. 7
DOD Did Not Measure and Evaluate the ScanEagle Program’s Performance Because DOD Asserted
Established Performance Measurement Requirements Did Not Apply Prior to 2019 and Are Too
Costly to Apply Now ................................................................................................................................................... 14
DOD Did Not Assess the Sustainability of the ScanEagle Program and Encountered Delays in
Developing the ANA’s Operational Capability .......................................................................................................... 16
Conclusion.................................................................................................................................................................. 22
Recommendations .................................................................................................................................................... 22
agency Comments ..................................................................................................................................................... 24
Appendix I - Scope and Methodology ....................................................................................................................... 27
Appendix II - SIGAR 19-44-AL, Alert Letter: DOD ScanEagle Program, July 5, 2019 ............................................. 29
Appendix III - Department of the Navy, Response to SIGAR’s Alert Letter, August 1, 2019 ................................. 32
Appendix IV - response from the Deputy Assistant Secretary of Defense for Afghanistan, Pakistan,and Central Asia......................................................................................................................................................... 35
Appendix V - Response from the Combined Security Transition Command – Afghanistan .................................. 40
Appendix VI - Response From United States Forces – Afghanistan, July 8, 2020 ................................................. 42
Appendix VII - Acknowledgments .............................................................................................................................. 47

TABLES
Table 1 - ScanEagle Contracts Completed from November 2015 to March 2019 ................................................. 3
Table 2 - ScanEagle Contract Awarded in April 2019 and Future Options .............................................................. 3
Table 3 - Contract Deliverables Required Versus Deliverables Provided ............................................................... 12

PHOTOS
Photo 1 - ScanEagle Vehicle Being Launched ........................................................................................................... 4
Photo 2 - ScanEagle Vehicle Being Recovered .......................................................................................................... 4

SIGAR 20-44-AR/DOD ScanEagle Program

Page vABBREVIATIONS
ANA

Afghan National Army

ANDSF

Afghan National Defense and Security Forces

AROC

Afghanistan Resource Oversight Council

CO

Contracting Officer

COR

Contracting Officer’s Representative

CSTC-A

Combined Security Transition Command-Afghanistan

DOD

Department of Defense

DFAR

Defense Federal Acquisition Regulation Supplement

FAR

Federal Acquisition Regulation

ISR

Intelligence, surveillance, and reconnaissance

NAVAIR

Naval Air Systems Command

OUSD-P

Department of Defense Office of the Under Secretary of Defense for Policy

QASP

Quality Assurance Surveillance Plan

UAS

Unmanned Aerial System

SIGAR 20-44-AR/DOD ScanEagle Program

Page vi

Since fiscal year 2005, the U.S. Department of Defense (DOD) has spent nearly $47.5 billion on equipment,
transportation, infrastructure, training, operations, and sustainment for the Afghan National Defense andSecurity Forces (ANDSF), which is comprised of the Afghan National Army (ANA) and Afghan National Police.1 In
a March 2015 DOD memorandum of record, the Combined Security Transition Command–Afghanistan (CSTCA) identified an impending capability gap related to the ANA’s ability to conduct intelligence, surveillance, andreconnaissance (ISR) operations that would result from a drawdown of coalition forces. Specifically, CSTC-A
determined the ANA forces would be limited to stationary ISR assets, including aerostats, surveillance towers,
and hand-held systems, which are either constrained to protecting an immediate area or effective only within a“few kilometers” of a designated location.2 CSTC-A expressed concern that without the support of a long-range
mobile asset, the ANA would experience a decrease in mission effectiveness with a corresponding increase inloss of life and destruction of property.
To increase the ANA’s ISR capabilities, DOD funded the purchase of 16,000 ISR assets, such as night vision
devices and surveillance unmanned aerial vehicles, including the ScanEagle Unmanned Aerial System (UAS),3
and more than 200 aircraft, such as helicopters, light attack aircraft, and cargo airplanes.4 The 2019
Afghanistan Compact states that ANA’s ISR capabilities support the U.S. and Afghan governments’ broader
goals for the ANDSF to plan and execute special, conventional, and police operations, using Afghan-derived
intelligence to counter current and future threats to Afghanistan.5 From November 2015 through November
2019, DOD, through its Naval Air Systems Command (NAVAIR), awarded Insitu Inc. five firm-fixed-pricecontracts to procure ScanEagle UAS, establish operational sites throughout Afghanistan, provide the ANA
training to operate and maintain the system, and procure spare parts for continuing UAS operations.6
This audit examined the implementation and oversight of the ScanEagle program, including five firm-fixed pricecontracts valued at more than $174 million implemented from November 2015 through November 2019.
Specifically, our objectives were to determine the extent to which: (1) the contractor, Insitu, met the terms ofthe contracts and DOD performed the required oversight of the ScanEagle program; (2) DOD measured andevaluated the ScanEagle program’s performance; and (3) DOD planned for the Afghan government’s
sustainment of the ScanEagle program, and the ANA developed the capabilities necessary to operate andsustain the program.7
To accomplish our objectives, we reviewed the five NAVAIR ScanEagle contracts and supporting documents
including modifications, contract deliverables, and communications between the U.S. government and Insitu,
and CSTC-A’s periodic reporting on the ScanEagle program. We interviewed officials within DOD’s Office of theUnder Secretary of Defense for Policy (OUSD-P); the Defense Security Cooperation Agency; CSTC-A’sIntelligence and Train, Advise, and Assist, and U.S. Forces–Afghanistan’s Train, Advise, and Assist Command–
South; and, NAVAIR’s contracting and program office support. In addition, we interviewed Insitu personnel at

1 SIGAR, Quarterly Report to the United States Congress, January 30, 2020.
2 An aerostat is an aircraft, such as a balloon, that uses gas to float in the air. It can be tethered to the ground or

untethered. Aerostats and surveillance towers provide watch and protection over designated facilities, and are designed tocounter explosive devices and aerial attacks.
3 A ScanEagle UAS is comprised of a ScanEagle unmanned aerial vehicle, a ground control system, a vehicle launcher, andvehicle recovery equipment.
4 GAO, Afghan Security, Some Improvements Reported in Afghan Forces’ Capabilities, but Actions Needed to Enhance DOD
Oversight of U.S. Purchased Equipment, GAO-19-116, October 2018.
5 The 2019 Afghanistan Compact is a U.S. and Afghan initiative, managed by U.S. Forces–Afghanistan, to track the Afghan
government’s commitments to and implementation of U.S. development assistance.
6 Insitu is a wholly owned subsidiary of The Boeing Company, and is headquartered in Bingen, Washington. Insitu designed,
developed, and produced the ScanEagle UAS.
7 As part of the audit, we issued an alert letter to DOD in July 2019 highlighting a significant lapse in NAVAIR’s oversight of
the ScanEagle contracts (see SIGAR, Alert Letter: DOD ScanEagle Program, SIGAR 19-44-AL, July 5, 2019). This reportaddresses DOD’s August 2019 response to the letter and our remaining concerns.

SIGAR 20-44-AR/DOD ScanEagle Program

Page 1their headquarters in Bingen, Washington, and at the ScanEagle Schoolhouse at Kandahar Airfield in
Afghanistan; and we interviewed ANA officers managing the ScanEagle program for the Afghan government.
We conducted our work in Arlington, Virginia; Patuxent River, Maryland; Lakehurst, New Jersey; Bingen,Washington; and Kabul and Kandahar, Afghanistan, from August 2018 to February 2020, in accordance withgenerally accepted government auditing standards. Appendix I has a more detailed discussion of our scopeand methodology.

BACKGROUND
In 2015, CSTC-A defined requirements to address the ANA capability gaps and determined that the ANA
needed a mobile ISR asset. In a CSTC-A memorandum of request, CSTC-A stated that the ANA needed aneffective ISR asset that would8
1. be able to operate independently of airfields;
2. allow for long-term and undetected full motion video operations;
3. have wide and effective geographic range for surveillance;
4. have the flexibility to be tailored to specific ANA mission needs;
5. be cost effective for the ANA both in operations and sustainment; and6. be ready and operational for the battlefield in 2016.
In early 2015, the Army Materiel Systems Analysis Activity assessed six potential ISR system options anddetermined that the ScanEagle UAS best met the ANA’s mobile ISR needs.9 CSTC-A concurred with the Army
Materiel Systems Analysis Activity and determined in March 2015 that the ScanEagle UAS best met the six
requirements in the memorandum of request.
Following U.S. Forces–Afghanistan’s selection of the ScanEagle UAS as an appropriate option, CSTC-A
proposed a 5-year plan to the Afghanistan Resource Oversight Council (AROC), requesting approval to use the
DOD Afghanistan Security Forces Fund to purchase ScanEagle UAS, spare parts, contractor field support
representatives, and a training program.10 In March 2015 the AROC approved the initial funding for ANA’s
ScanEagle program.11
AROC then determined NAVAIR had responsibility for developing statements of work and contracts that
addressed CSTC-A’s memorandum of request. Between November 2015 and March 2019, NAVAIR awarded
four contracts to Insitu to procure ScanEagle UAS, establish operational sites throughout Afghanistan, provide
the ANA training to operate and maintain the system, and procure spare parts for continuing UAS operations.
These contracts were completed by March 2019.
Table 1 lists the four completed ScanEagle contracts, their periods of performance, and their costs.

8 Navy International Programs Office, Memorandum for the Department of the Navy, March 20, 2015.
9 The Army Materiel Systems Analysis Activity organization provides analysis to the Army and DOD to support and inform the“equipping” and “sustaining” of weapons and equipment for soldiers.
10 DOD established the AROC on August 3, 2011. It is a senior level body that provides appropriate executive oversight of

DOD funds appropriated for training, equipping and sustainment of the Afghanistan security forces. The Under Secretaries
of Defense for Policy, and Acquisition, Technology, and Logistics are the chairmen of the AROC.
11 In January 2020, after we discussed our preliminary audit findings with OUSD-P, a senior OUSD-P official told us that
DOD then received approval from the National Security Council in April 2015 to proceed with the ScanEagle procurement.
SIGAR 20-44-AR/DOD ScanEagle Program

Page 2

Table 1 - ScanEagle Contracts Completed from November 2015 to March 2019
Contract Number

Period of Performance

Amount

N68335-11-G-0009, Delivery Order 0011

Nov 25, 2015 – Nov 23, 2016

$67,998.061.89

N68335-16-G-0046, Delivery Order 0001

Jan 20, 2017 – Nov 19, 2017

$5,036,996.98

N68335-16-G-0046, Delivery Order N6833517F0079

Jul 25, 2017 – Apr 12, 2018$25,764,659.97

N68335-16-G-0046, Delivery Order N6833518F0050

Mar 28, 2018 – Mar 25, 2019$58,609,870.18

Total$157,409,589.02

Source: NAVAIR contract documents.
Note: This table reports a total cost for the four completed contracts in our audit scope from November 2015 through March
2019. On page one of this report, we state that more than $174 million was spent to implement the four completed
contracts; this figure includes a portion of a new fifth contract that began in April 2019.

In March 2019, NAVAIR awarded a fifth contract to Insitu. Unlike the previous contracts, the fifth contract has abase year with options for 2 additional years. In addition to providing ScanEagle equipment, training, andoperation and maintenance support like the previous four contracts, the fifth contract introduces a train-thetrainer program. According to NAVAIR officials, the ANA recruited three former ScanEagle pilots to work
alongside Insitu trainers and eventually be certified to train ANA students. These former pilots were trained andcertified by Insitu, and are actively performing at an operational ANA ScanEagle site. A CSTC-A senior official
told us that the goal of the train-the-trainer program is to help the ANA develop and eventually conduct
ScanEagle training independent of Insitu.12
Table 2 lists the ongoing ScanEagle contract’s planned periods of performance, and potential overall cost.

Table 2 - ScanEagle Contract Awarded in April 2019 and Future Options
Contract and Option Year

Period of Performance

Amount

N68335-16-G-0046,
Delivery Order N6833519F0434

April 01, 2019 – March 31, 2020

Option Year 1

April 01, 2020 – March 31, 2021

$17,031,908.36**

Option Year 2

April 01, 2021 – March 31, 2022

$24,259,050.59

Total$34,431,159.14*$75,722,118.09

Source: NAVAIR contract documents.
*This is the total contract award as of March 31, 2020, and includes $7,187,793.47 exercised by NAVAIR in Option Year 1.
**Option Years 1 and 2 include additional supplies and services that NAVAIR could choose to exercise during the periods ofperformance.

12 In June 2020, the Deputy Chief of Staff for Intelligence, Train, Advise, and Assist told us that in addition to the three pilot

instructors, the train-the trainer program has certified three maintenance personnel and three mission coordinator
instructors. Although the program has been delayed and reduced in scope due to COVID-19 restrictions, the goal remains
for the ANA to take over all ScanEagle training in 2021.
SIGAR 20-44-AR/DOD ScanEagle Program

Page 3

According to CSTC-A, the ScanEagle UAS allows the ANA to provide real-time aerial video of battlefield
operations to its forces and intelligence collection to support counterterrorism and counterinsurgency
operations. A ScanEagle UAS is comprised of a ScanEagle unmanned aerial vehicle, a ground control system, avehicle launcher, and vehicle recovery equipment. Photo 1 shows the vehicle and launcher, and photo 2 shows
the vehicle and recovery equipment.

Photo 1 - ScanEagle Vehicle Being Launched

Source: Insitu, December 12, 2018.

Photo 2 - ScanEagle Vehicle Being Recovered

Source: Insitu, December 12, 2018.

SIGAR 20-44-AR/DOD ScanEagle Program

Page 4

ScanEagle Program Stakeholders and Their Roles and Responsibilities
The Afghanistan Security Forces Fund, which funds the ScanEagle program, grants DOD the authority to
implement Building Partner Capacity programs using a process known as “pseudo Foreign Military Sales.”13
The Defense Security Cooperation Agency’s Security Assistance Management Manual defines specific roles
and responsibilities for implementing a Building Partner Capacity program and pseudo Foreign Military Sales
cases. The ScanEagle program is a pseudo Foreign Military Sales case and subject to the manual. Multiple
DOD entities have a role in implementing or overseeing the ScanEagle program, with CSTC-A and NAVAIR
having the largest roles. CSTC-A is broadly responsible for overseeing the ANA’s progress in acquiring anddeveloping ISR capabilities using the ScanEagle systems, and NAVAIR is responsible for overseeing the
ScanEagle contracts and Insitu.
The roles and responsibilities of various DOD entities as they pertain to the ScanEagle program are as follows:CSTC-A is both the requesting authority and the requirement owner for the ScanEagle program.14 In
these roles, CSTC-A is responsible for planning the program’s capacity-building activities for the ANA
and communicating detailed ScanEagle program requirements to NAVAIR. CSTC-A must also remain
actively engaged with NAVAIR to, for example, ensure NAVAIR has the necessary information to
implement the ScanEagle program, and communicate and justify CSTC-A’s highest priorities for the
program. CSTC-A’s Security Assistance Office is responsible for handling CSTC-A’s management of the
program, along with other pseudo Foreign Military Sales cases for the ANDSF. CSTC-A’s Intelligence–
Train, Advise, Assist directorate is responsible for the overall management of the ScanEagle program,supporting the ANA and its ISR capabilities.15 In April 2020, in response to our draft report, CSTC-A
noted that its Intelligence–Train, Advise, Assist directorate—the requirement owner for the ScanEagle
program—was moved out of CSTC-A in January 2020, and realigned under Resolute Support’s Deputy
Chief of Staff for Intelligence.



NAVAIR is the implementing agency for the ScanEagle program and provides its training, services,
equipment, and supplies in accordance with CSTC-A’s request.16 NAVAIR is responsible for awarding
and overseeing Insitu’s implementation of the ScanEagle contracts.



The Defense Security Cooperation Agency is responsible for administering pseudo Foreign Military
Sales cases, such as ScanEagle, under the direction of the OUSD-P, and provides guidance to DOD
components and the Security Cooperation Organization on the administration and execution of
Building Partner Capacity program activities. Defense Security Cooperation Agency assists CSTC-A indeveloping and implementing ScanEagle program policies and objectives, logistics planning, andfinancial management.



A Security Cooperation Organization is a U.S. organization permanently located in a foreign country thatis responsible for carrying out security cooperation management functions, such as equipment andservices sales case management. A senior Defense Security Cooperation Agency official told us that

13 The 1968 Foreign Military Sales Act authorizes the U.S. government to sell military equipment and defense services toforeign countries. DOD’s Security Assistance Management Manual states that the U.S. government first introduced Building
Partner Capacity programs in 2005. Under these programs, sales of military equipment are funded with U.S. defense funds,
rather than foreign operations appropriations.
14 The requesting authority is an organization with responsibility for planning regional or country capacity building activities,
while the requirement owner is the military organization within DOD authorized to request the equipment or services to beobtained through the pseudo Foreign Military Sales case.
15 In January 2020, a senior OUSD-P official noted that during the first 2 years of the ScanEagle program, CSTC-A’sIntelligence–Train, Advise, Assist did not exist. During this time, planning for ANA’s ISR requirements fell under Resolute
Support’s Deputy Chief of Staff for Intelligence, also referred to as Essential Function 7.
16 The implementing agency is the military service assigned responsibility for implementing aspects of a pseudo Foreign
Military Sales case that requires contracting actions.

SIGAR 20-44-AR/DOD ScanEagle Program

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there is no Security Cooperation Organization for Afghanistan, and that CSTC-A fills this role by managing
pseudo Foreign Military Sales cases through its Security Assistance Office for Foreign Military Sales.
Insitu and the Afghan government are also ScanEagle program stakeholders.


Insitu is responsible for implementing and complying with the ScanEagle contractual requirements,
such as providing the ScanEagle UAS, field support representatives, trainers, and the ANAschoolhouse training facility.



The Afghan government—in this case, the ANA—is the partner nation, or benefitting country, thatreceives ScanEagle equipment and services through the pseudo Foreign Military Sales process. CSTC-A
advises the ANA on the program.17

DOD Contract and Program Oversight Requirements
The Federal Acquisition Regulation (FAR) requires DOD to “designate and authorize, in writing and inaccordance with agency procedures, a contracting officer’s representative (COR) on all contracts and orders
other than those that are firm-fixed-price, and for firm-fixed-price contracts and orders as appropriate, unlessthe Contracting Officer [CO] retains and executes the COR duties.”18 FAR also requires that the COR “assists inthe technical monitoring or administration of a contract” and maintains contract files documenting actions
taken in the performance of COR duties.19 In addition, the January 2015 DOD Theater Business Clearance
Update for Afghanistan requires all DOD contracts with contractor personnel performing work in Afghanistan tohave an “in-country sponsor” who “is responsible for validating requirements for contract performance inAfghanistan,” and an “in-country contracting officer[’s] representative (COR), an in-country Contracting Officer
Technical Representative, and/or an in-country Government Technical Product Representation.”20
DOD’s Defense Contingency COR Handbook provides guidance on the roles and responsibilities of CORs, andtheir importance to contract oversight. For example, the handbook states that because there is critical relianceon contractor support in Afghanistan and large expenditures involved, contract surveillance is vital to ensurethat contractors provide timely, high-quality services and supplies; mitigate contractor performance problems;and ensure that the U.S. government “receives best value for the warfighter.”21
In addition, DOD has guidance for measuring the performance of its security cooperation programs andcontractors. For example, the January 2017 DOD Instruction 5132.14, Assessment, Monitoring, andEvaluation Policy for the Security Cooperation Enterprise, requires CSTC-A to do such things asdevelop a comprehensive document that specifies measurable, attainable, relevant, and time-boundobjectives to guide a program and to help ensure that it is effectively implemented;

develop a performance management plan that monitors program progress toward desired outcomesby tracking inputs; anddetermine whether program milestones are achieved within anticipated timeframes, budgets, andoutcomes.

17 Although NAVAIR oversees the contracts for the program, it does not have an advisory role with the ANA.
18 FAR 1.602-2, Contracting Officer’s Responsibilities.
19 FAR Subpart 1.6, Career Development, Contracting Authority, and Responsibilities.
20 Richard Ginman, Director Defense Procurement and Acquisition Policy, Theater Business Clearance Update for
Afghanistan, memorandum for Commander, United States Special Operations Command (Acquisition Executive), UnitedStates Transportation Command (Acquisition Executive), Deputy Assistant Secretary of the Army (Procurement), Deputy
Assistant Secretary to the Navy (Acquisition & Procurement), Deputy Secretary of the Air Force (Contracting), Directors of
Defense Agencies, Directors of DOD Field Activities, January 21, 2015, p. 2.
21 Defense Contingency COR Handbook, Version 2, September 2012, p. 1.

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DOD also has guidance to conduct evaluations and assessments on security cooperation programs to help
ensure they are sustainable. For example, DOD Instruction 5132.14 requires DOD to evaluate, track, andreport on a program’s sustainability.

DOD IS UNABLE TO DETERMINE THE EXTENT TO WHICH INSITU MET THE
TERMS OF THE SCANEAGLE CONTRACTS BECAUSE DOD DID NOT CONDUCTREQUIRED OVERSIGHT
DOD cannot determine the extent to which Insitu met the terms of its contracts because NAVAIR did not meetrequirements for conducting contract oversight. First, NAVAIR did not designate a COR for all of the ScanEagle
contracts as DOD instructed, and NAVAIR’s CO did not perform COR duties for those contracts, as U.S.
regulations suggest. Second, NAVAIR did not have an in-country sponsor in Afghanistan responsible forvalidating contract requirements, as DOD required. Third, NAVAIR and Insitu could not produce evidence that
Insitu completed many of the contract deliverables required to determine if the contractor met the terms of thecontracts. Because of these gaps in deliverables, NAVAIR does not know the extent to which Insitu met theperformance terms of the contracts.

NAVAIR Did Not Have a COR for Three of the Contracts and the CO Did Not Perform
COR Duties, As Required
In approving resources for the ScanEagle program in 2015, DOD’s AROC specifically stated that the ScanEagle
contracts need to have CORs and responsible DOD parties needed to “ensure CORs are in the right place tomonitor performance.”22 In addition, FAR 1.602-2, Contracting Officer’s Responsibilities, requires the CO “todesignate and authorize, in writing and in accordance with agency procedures, a [COR] on all contracts andorders other than those that are firm-fixed-price, and for firm-fixed price contracts and orders as appropriate,
unless the contracting officer retains and executes the COR duties.”
We found that NAVAIR did not have a COR assigned to three of the five firm-fixed-price contracts we reviewed—
contracts 1, 3, and 4—as the AROC directed. The NAVAIR CO told us that CORs were not required for thesethree contracts. However, when we asked the CO to explain his justification for not having CORs, we received
multiple explanations without a clear answer. For example, in our initial interview with NAVAIR personnel, theCO stated that a COR was not required for these contracts because less than 35 percent of each contract
involved services. In a follow-up interview, when we asked for documentation supporting the requirement thata COR was not needed on contracts that were less than 35 percent services, the CO stated that there was no
documentation for this rule. Rather, he said that he made the determination that a COR was not needed
because the majority of the ScanEagle contracts involved procurement of goods rather than services. The CO
further noted that only services contracts need CORs. We again asked NAVAIR for documentation supporting
this justification, but it provided none.
In December 2019, after we discussed our preliminary audit findings with NAVAIR officials, NAVAIR told us that
pursuant to the Defense Federal Acquisition Regulation Supplement (DFAR) Procedures, Guidance, andInformation 201.602-2, a CO “shall designate a COR for all service contracts…” and that the three contracts
were not service contracts and therefore did not need CORs. Nevertheless, NAVAIR was required to have a COR
on the three ScanEagle contracts due to the AROC’s 2015 direction, and that the FAR called for either
assigning a COR, or having the CO perform COR duties.

22 AROC, Meeting Summary, Afghanistan National Army (ANA) Airborne Intelligence, Surveillance, and Reconnaissance (ISR)(ScanEagle), March 19, 2015.

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In May 2020, in response to our draft report, NAVAIR again emphasized that the FAR and DFAR did not require
NAVAIR to assign CORs to the supply contracts. However, over the course of the audit NAVAIR could not explain
or articulate why it was in the best interest of the government to not assign a COR to the three, multi-million
dollar contracts executed in a theater beyond the purview of the CO, per contract guidance.23
Moreover, the AROC specifically stated that the ScanEagle contracts needed to have CORs. NAVAIR officials
told us that it was not aware of the AROC’s 2015 determination prior to our bringing it to their attention.
Furthermore, because NAVAIR said it was not aware of the AROC’s determination, and that it views the meetingsummary document only as “meeting minutes,” NAVAIR said it did not need to comply with the AROC’s
direction. NAVAIR told us in May 2020 that it was not “bound to comply with any of its contents as part of the
ScanEagle contract awards. Further, NAVAIR disagrees as a general matter that meeting minutes areauthoritative requirements documents.” In May 2020, DOD’s Defense Pricing and Contracting officeacknowledged the AROC’s direction.24 SIGAR disagrees with the notion that since NAVAIR was not aware of the
AROC’s direction that the requirement is therefore not applicable, and we are concerned that NAVAIR does notbelieve it needs to comply with the direction of the Deputy Director of Procurement and Acquisition Policy, asenior official of the AROC, which both OUSD-P and CSTC-A acknowledged was a requirement.
CSTC-A was aware that NAVAIR had not assigned CORs to three of the ScanEagle contracts.25 A senior CSTC-A
official contacted NAVAIR directly on multiple occasions to express his concern about the lack of contractor
oversight. The CSTC-A official requested that NAVAIR assign a COR or an alternative COR in Afghanistan to help
address ScanEagle program execution, contractor oversight, and a problematic relationship between CSTC-A
officials and Insitu personnel. On another occasion, the same CSTC-A official stated in an email to NAVAIR thatthe lack of a COR “is not acceptable to my CSTC-A chain of command.” NAVAIR initially responded that it was
willing to address CSTC-A’s concern but never assigned CORs. NAVAIR eventually disagreed with CSTC-A’sconcern regarding the lack of a COR because, according to NAVAIR’s CO, the Program Manager provided
proper contract oversight and monitoring from the United States.
In January 2020, after we discussed our preliminary audit findings with NAVAIR officials, NAVAIR told us that it
responded to CSTC-A’s request for a COR in August 2018 by providing CSTC-A with guidance on how tonominate a COR. NAVAIR stated that it was CSTC-A’s responsibility to nominate a COR, but CSTC-A did not do
so. In May 2020, in response to our draft report, NAVAIR provided us the guidance explaining how CSTC-A is
responsible for nominating a COR and NAVAIR is responsible for then appointing that COR. We agree that both
NAVAIR and CSTC-A had responsibilities to help address the AROC’s requirements and expect that both
agencies will work to meet these requirements to help ensure appropriate contractor oversight.
Separately, FAR 1.602-2 allows a CO to perform the duties of a COR if no COR is assigned to a firm-fixed-pricecontract. We received no evidence of the CO performing these COR duties on the three contracts. NAVAIR did
not provide evidence that the CO performed COR duties, such as determining the extent to which Insitu met
ScanEagle contract requirements, and did not have evidence of required contract records, such as a Quality
Assurance and Surveillance Plan (QASP), records of inspections performed and their results, or a surveillance

23 DODI 5000.72, DOD Standard for Contracting Officer’s Representative (COR) Certification, paragraph 3.b. states that it is
DOD policy that, “Contracting officers will designate a COR for all service contracts, including construction, unless thecontracting officer retains and executes contract oversight responsibilities when the conditions of subpart 201.602-2 of the
DFARS Procedures, Guidance, and Information (Reference (g)) exist. CORs may be required for any other contract when theneed for a COR is determined by the contracting officer. The contracting officer always has the right to designate a COR
when it is in the best interest of the U.S. Government.”
24 In May 2020, DOD’s Defense Pricing and Contracting office offered comments on a draft of this report. The office is

responsible for all pricing, contracting, and procurement policy matters in DOD.
25 CSTC-A officials told us they first became aware of a COR being assigned to ScanEagle contracts when NAVAIR started

the fifth contract in April 2019.

SIGAR 20-44-AR/DOD ScanEagle Program

Page 8schedule.26 Specifically, NAVAIR did not develop a QASP for any of the four completed contracts to use toassess Insitu’s performance.
The CO stated that to meet COR oversight responsibilities, he relied on NAVAIR’s ScanEagle Program Manager
in the United States to provide the required oversight. However, when questioned by us, the program manager
acknowledged that she was not a COR and thus not responsible for conducting contract oversight, and relies
on Insitu and CSTC-A for in-theater monitoring.
In January 2020, NAVAIR told us it is important to note that NAVAIR did conduct contract oversight “throughvarious means, primarily through report tracking, daily/weekly phone calls and emails with CSTC-A and Insitu.”
Although we agree that NAVAIR did communicate with CSTC-A and Insitu, this communication alone does notsatisfy the AROC requirements to assign CORs.
Also in January 2020, NAVAIR also told us that per the DFAR 246.401, QASPs are required only on service
contracts, and that four of the five ScanEagle contracts were supply contracts, and therefore, not required tohave QASPs. The supplement states
The requirement for a quality assurance surveillance plan shall be addressed and documented in thecontract file for each contract except for those awarded using simplified acquisition procedures. For
contracts for services, the contracting officer should prepare a [QASP] to facilitate assessment ofcontract performance, see 237.172. For contracts for supplies, the [CO] should address the need fora [QASP].27
We not only disagree with NAVAIR’s assertion that QASPs are not required for the completed contracts, but also
note that NAVAIR did not follow the DFAR guidance it referred to when responding to a preliminary draft of ouraudit findings. First, NAVAIR provided evidence of ScanEagle contract records requiring NAVAIR to develop
QASPs. Specifically, we found that NAVAIR’s acquisition plans for contracts 2, 3, and 4 included a requirementthat a QASP be used to assess and document the performance of the contract. Second, NAVAIR did not follow
DFAR 246.401 concerning its supply contracts. NAVAIR has not provided any evidence of CO records
addressing the need, or lack thereof, to have QASPs for any of the supply contracts.
Finally, although NAVAIR provided documentation that it had assigned a COR to contracts 2 and 5, it did notprovide any evidence that the COR performed any oversight over these contracts. We requested an interview
with the NAVAIR COR—the same individual was assigned to both contracts—on multiple occasions to verify that
she was the COR and to understand her role in conducting oversight of those contracts. However, NAVAIR and
the COR did not respond to our initial requests for an interview.
In July 2019, we sent an alert letter to NAVAIR stating our concerns that a COR had not been assigned and thatproper contract oversight was not conducted (see appendix III). In December 2019, NAVAIR made the COR
available for an interview. The COR stated that she performed some COR duties for contract 2 but could not
26 FAR 46.401 states that

Government quality assurance shall be performed at such times (including any stage of manufacture or
performance of services) and places (including subcontractors’ plants) as may be necessary to determine thatthe supplies or services conform to contract requirements. Quality assurance surveillance plans should be
prepared in conjunction with the preparation of the statement of work.
In addition, NAVAIR Instruction 4200.57, Contract Requirements and Use of Contracting Officer’s Representatives, statesthat a COR should use a QASP to assess the contractor’s performance, and NAVAIR’s acquisition plan asserts that the
QASP should identify the government individuals responsible for monitoring the performance and performance standards,
acceptable quality levels, and method of surveillance of each critical service area and product delivered under thiscontract. A surveillance schedule, which a QASP establishes, states the methods and extent to which the government will
evaluate the contractor throughout the performance of the contract. In May 2020, in response to our draft report, DOD’s
Defense Pricing and Contracting office requested we note that QASPs are typically used on service contracts.
27 Defense Federal Acquisition Regulation Supplement 246.401, Government Contract Quality Assurance, General,
December 21, 2018. In May 2020, in response to our draft report, DOD’s Defense Pricing and Contracting office said weare correct that the CO should evaluate whether a QASP is needed and document his or her findings in the contract file.

SIGAR 20-44-AR/DOD ScanEagle Program

Page 9remember specifics because NAVAIR lost its electronic contract records due to a Windows 10 update in May
2018. The COR also stated that she performed COR duties for contract 5, such as reviewing Insitu’s daily ormonthly reporting, frequently communicating with NAVAIR’s technical point of contact, and documenting her
acknowledgment of COR duties.
DOD’s Defense Contingency COR Handbook states that because there is critical reliance on contractor support
in Afghanistan and large expenditures involved, contract surveillance is vital to ensure that contractors areproviding timely, high-quality services and supplies; to mitigate contractor performance problems; and toensure that the U.S. government “receives best value for the warfighter.”28 Because NAVAIR did not have CORs
on three of the ScanEagle contracts, we determined that NAVAIR did not adhere to DOD guidance, and did notprovide the required level of contract oversight.
In May 2020, in response to our draft report, NAVAIR provided documents to show it is taking steps to ensurethat a QASP is used on the current contract and that NAVAIR has implemented a surveillance plan. We
appreciate NAVAIR taking these important steps and look forward to receiving documentation identifying theappropriate designated official responsible for monitoring and assessing the performance of the contract.

NAVAIR Did Not Provide Required Contract Oversight in Afghanistan
A January 2015 DOD policy, Theater Business Clearance Update for Afghanistan, requires all DOD contracts
with contractor personnel performing work in Afghanistan to have an “in-country sponsor” who “is responsible
for validating requirements for contract performance in Afghanistan,” and an “in-country contracting officer[’s]representative (COR), an in-country Contracting Officer Technical Representative, and/or an in-country
Government Technical Product Representation.”29 This DOD policy states also that the “in-country sponsor may
also serve as the in-country COR/COTR [Contracting Officer Technical Representative]/GTPR [Government
Technical Product Representation],” and that “the in-country sponsor organization will provide an in-country
COR/COTR [Contracting Officer Technical Representative]/GTPR [Government Technical ProductRepresentation] if the requiring activity is not able to provide one.”30 The policy clarified that this in-country
sponsor could be in addition to a primary COR, Contracting Officer Technical Representative, or Government
Technical Product Representation based in the United States.
As we stated in our July 2019 alert letter to DOD, we found that NAVAIR did not have personnel performing therequired oversight of the ScanEagle contracts in Afghanistan.31 Since it began implementing the ScanEagle
program in November 2015, NAVAIR has not designated an in-country sponsor in Afghanistan to validate anyof the five ScanEagle contract performance requirements, pursuant to DOD policy. For four of the contracts,
NAVAIR identified five personnel with CSTC-A assigned to be in-country sponsors. However, when weinterviewed these officials to confirm their appointment or designation and inquire about any in-country
oversight responsibilities they were conducting, four officials told us they never received an appointment fromNAVAIR, nor were they aware that NAVAIR had assigned them any contractor oversight responsibilities for the
ScanEagle program.32 Furthermore, the four officials said they did not have access to all of NAVAIR’s contract
records, which they would have needed to perform a contract oversight role.
In response to our July 2019 letter, NAVAIR said it complied with the January 2015 DOD policy for contracts 1
and 5, and did not refute our conclusion that it did not adhere to the policy for contracts 2, 3, and 4.33 In thesame response, NAVAIR disagreed with our conclusion that there was a significant lapse in oversight, but
28 DOD, Director, Defense Procurement and Acquisition Policy, COR Handbook, September 2012, p. 1.
29 Richard Ginman, Theater Business Clearance Update for Afghanistan, memorandum, January 21, 2015, p. 2.
30 Richard Ginman, Theater Business Clearance Update for Afghanistan, memorandum, January 21, 2015, p. 2.
31 SIGAR, DOD ScanEagle Program, SIGAR 19-44-AL, July 5, 2019.
32 One of the CSTC-A officials that NAVAIR identified as an in-country sponsor did not respond to our requests to speak andwe could not verify what in-country sponsor roles she performed, if any.
33 Department of the Navy, Response to SIGAR Alert Letter 19-44 “DOD ScanEagle Program,” August 1, 2019.

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acknowledged that there was a potential disconnect between NAVAIR and CSTC-A in communications on the
ScanEagle contracts. NAVAIR noted that it should work with CSTC-A to gain a clearer understanding of contract
oversight roles and responsibilities. NAVAIR stated that it would conduct a meeting with CSTC-A personnel byAugust 2019 to discuss details of the ScanEagle contracts, including addressing any differences between
NAVAIR’s and CSTC-A’s objectives and contract requirements; clarifying contract oversight roles andresponsibilities; and establishing more effective communications regarding program expectations, Insitu’s
performance, and contract oversight. NAVAIR also stated that it would invite CSTC-A to future quarterly
meetings tentatively scheduled for October 2019 with NAVAIR and Insitu to facilitate “recurring dialogue…
[and] to ensure that all parties understand the objectives, requirements, and challenges to implementing the
ScanEagle program.”34
In October 2019, CSTC-A officials told us they conducted an initial meeting in August 2019 with NAVAIR anddescribed it as a “good first step.” However, the officials also noted that there had not been any further
communication, and that NAVAIR still was “unwilling” to provide in-country personnel to conduct ScanEagle
contract oversight in Afghanistan. In January 2020, NAVAIR told us that it has conducted additional
communications with CSTC-A since August 2019.
In January 2020, NAVAIR also told us that “it is the responsibility of the requiring organization, in this case
CSTC-A, to provide in country [sic] resources to perform in-country contract surveillance/oversight functions.”35
While we agree that CSTC-A has responsibility, we disagree with NAVAIR’s assertion that it is solely CSTC-A’s
responsibility to provide resources in Afghanistan and note that DOD’s Theater Business Clearance Update for
Afghanistan states that “all contracting organizations, regardless of any command relationship with
USCENTCOM [United States Central Command], awarding contracts with performance or delivery in
Afghanistan shall coordinate through the TBC [Theater Business Clearance] process.”36 A senior DOD official
with Army Contracting Command–Afghanistan emphasized that NAVAIR does have responsibility to follow theTheater Business Clearance. Based on the official’s comments and our review, we believe NAVAIR did not meet
the Theater Business Clearance as required.
In May 2020, in response to our draft report, NAVAIR reiterated that it identified CSTC-A personnel assigned to
be in-country sponsors on the government forms required per the Theater Business Clearance. However, those
purported in-country sponsors told us that they never received an appointment from NAVAIR, nor were theyaware that NAVAIR had assigned them any contractor oversight responsibilities for the ScanEagle program. We
believe the intent of the Theater Business Clearance is not to simply list names on forms but to ensure theidentified personnel actually perform the in-country sponsor duties.
Nevertheless, we are encouraged that DOD appears to be taking initial steps to address our report’s second
recommendation and fulfill the intent of the Theater Business Clearance. In May 2020, in response to ourreport, Resolute Support’s Deputy Chief of Staff for Intelligence told us that it has tentatively agreed to a planwith NAVAIR to assign two in-country CORs starting in June or July 2020. In May 2020, in a separate response
to our report, NAVAIR told us that it expects Resolute Support’s Deputy Chief of Staff for Intelligence to provide
a COR nomination package sometime after mid-June 2020.

NAVAIR and Insitu Did Not Have Evidence for Many Required Contract Deliverables
The ScanEagle contracts required Insitu to produce written reports defined in each contract by the Contractor
Data Requirement List. However, NAVAIR did not know how many deliverables Insitu completed, providing
further evidence of its lack of oversight. Because of these gaps in deliverables, NAVAIR does not know theextent to which Insitu met the performance terms of the contracts. To determine the total number of required
34 Department of the Navy, Response to SIGAR Alert Letter 19-44 “DOD ScanEagle Program”, August 1, 2019.
35 NAVAIR, NAVAIR Comments on SIGAR Audit 127A Draft SOF, January 10, 2020.
36 Richard Ginman, Theater Business Clearance Update for Afghanistan, memorandum, January 21, 2015, p. 1.

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deliverables for each of the four completed contracts, we reviewed the Contract Data Requirement Lists, which
define the requirements for each deliverable and provide information, such as the name and type of reports to
produce, the dates reports should be initiated and submitted, and the frequency of reporting, with somerequired monthly and others on an ad hoc basis.37 Based on our analysis, we found that the four completed
contracts required NAVAIR and Insitu to produce at least 403 deliverables from November 2015 to March
2019. However, NAVAIR provided no evidence that Insitu completed 122 of the 403 deliverables—or 30
percent of all the deliverables. We found significant gaps in NAVAIR’s deliverables and that oversight worsened
from one contract to the next. NAVAIR had evidence for 86 percent of deliverables for the first contract, but just58 percent for the fourth contract.
We requested NAVAIR send us copies of all deliverables required for each contract as part of our analysis. In
addition, for the deliverables that NAVAIR could not provide, we asked Insitu to address the gap in records.
Insitu provided evidence that it completed 4 of the 122 deliverables that NAVAIR did not have.
Table 3 shows how many deliverables each of the first four ScanEagle contracts required NAVAIR and Insitu to
produce versus how many deliverables they provided us.

Table 3 - Contract Deliverables Required Versus Deliverables Provided
Contract

Required Deliverables

Deliverables Provided% Deliverables Provided

Contract 1

112

96

86%

Contract 2

66

46

70%

Contract 3

81

55

68%

Contract 4

144

80

58%

Total

403

281

70%

Source: SIGAR analysis of data provided by NAVAIR and Insitu.

For example, contract 2 required Insitu to submit Monthly Master Inventory Management Reports to help track
assets and parts usage; however, NAVAIR provided no evidence these reports were ever generated or
submitted. In another example, contracts 3 and 4 required Insitu to submit Training Summation Reportssummarizing training conducted with ANA soldiers. However, NAVAIR provided us only 5 of the 22 reports.
Additionally, contract 4 required Insitu to submit a Monthly Situation Report for each of the five ScanEagle
operational sites. These reports would describe accomplishments, events to be completed, and potential risks.
However, Insitu could provide only 27 of the 57 required reports.38

37 Our review did not include contract 5, which started in April 2019, to assess the extent to which Insitu completed thedeliverables as required, because the contract is not yet complete. We could not determine an exact total number ofdeliverables across the first four contracts because of inconsistencies in the contract language.
38 In January 2020, NAVAIR told us that our analysis of the contract deliverables was incorrect. For example, NAVAIR
suggested we incorrectly calculated the number of required Monthly Situation Reports and that only one report was
required each month across all of the sites instead of one report for each site. However, NAVAIR did not provide any
documentation or evidence to support its claim. Moreover, although the contract language may be vague, NAVAIR provided
us evidence that Insitu produced the Monthly Situation Reports for each site for some of the contracts.

SIGAR 20-44-AR/DOD ScanEagle Program

Page 12NAVAIR acknowledged that it had gaps in its contract records and told us that these gaps resulted, in part,from losing electronic records during NAVAIR’s update to Windows 10 in February 2018.39 However, Insitu did
not explain why it could not produce evidence for the missing deliverables it was required to produce.
Per FAR 4.703, contractors shall make available records, which includes books, documents,
accounting procedures and practices, and other data, regardless of type and regardless of whether
such items are in written form, in the form of computer data, or in any other form, and othersupporting evidence to satisfy contract negotiation, administration, and audit requirements of thecontracting agencies and the Comptroller General for [at least] 3 years after final payment.”40
Although we do not have documentation for contract 1’s close out, Insitu should be retaining records forcontracts 2, 3, and 4.
As a result of the inability of NAVAIR and Insitu to provide evidence for completing 30 percent of the requireddeliverables, we determined that NAVAIR lacks significant information to determine whether Insitu completed
the work it was paid to perform.
NAVAIR and Insitu’s records gaps also means NAVAR lacked important contract performance reporting
deliverables on the numbers of ANA soldiers Insitu trained (i.e., training summation reports), hours ANA
operated ScanEagle vehicles flew (i.e., monthly flight readiness reports), spare parts purchased and used tomaintain the ScanEagle systems (i.e., parts usage reports), and ScanEagle vehicle crashes or failures (i.e.,
MISHAP reports). In January 2020, NAVAIR commented that the Situation Reports it provided to us include allof this information. We reviewed the reports and determined they do not. We believe NAVAIR is conflating the
Situation Reports to represent all of the other required deliverables, such as training summation and MISHAP
reports. The examples we provide above are distinct deliverables from the Situation Reports.
In May 2020, in response to our draft report, NAVAIR provided us three new tables of “salient contract
performance statistics” from November 2015 through April 2020, including a “cumulative flight summary
across all contracts,” a “cumulative spare part summary across all contracts,” and a “cumulative student
summary across all contracts.” However, NAVAIR did not provide original source evidence or explain how thetables were populated. Without the supporting information such as monthly flight readiness reports, parts
usage reports, and mishap reports, which NAVAIR was unable to provide when we requested, it is unclear how
these tables could be created without the missing deliverables. As a result, we view the information provided
as insufficient to include in this report.41
Moreover, based on our analysis of performance reporting we received, such as the monthly flight readiness
reports and situation reports, we found that the actual number of flight hours Insitu reported for the operatingsites was 12,413 hours, less than half of the 27,261 flight hours NAVAIR estimated would be necessary tosupport ScanEagle missions during that specified time.
NAVAIR lacked the performance information necessary to determine the extent to which the ScanEagle
equipment and training services it procured is used. This also raises concerns about how NAVAIR justified
procuring 105 ScanEagle vehicles totaling over $32 million and spare parts totaling over $52 million, andfuture planned procurements.42 CSTC-A officials have also raised similar concerns. For example, a CSTC-A
official told us that based on the performance information of the ScanEagle’s flight hours, they believe the U.S.
government is overpaying for the ScanEagle contracts.

39 Prior to issuing our alert letter a NAVAIR official told us NAVAIR’s Windows update occurred in May 2018.
40 FAR Subpart 4.703, Contractor Records Retention Policy.
41 In May 2020, NAVAIR also told us that its request for an exit conference with our team remains outstanding. However,
we held an exhaustive and thorough exit conference with NAVAIR on December 19, 2019.
42 In January 2020, NAVAIR said our calculations of the number of ScanEagle procured and their total cost was incorrect.
However, NAVAIR did not provide evidence to support this claim or new figures. We based our analysis on evidence provided.

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DOD DID NOT MEASURE AND EVALUATE THE SCANEAGLE PROGRAM’SPERFORMANCE BECAUSE DOD ASSERTED ESTABLISHED PERFORMANCEMEASUREMENT REQUIREMENTS DID NOT APPLY PRIOR TO 2019 AND ARETOO COSTLY TO APPLY NOW
DOD and CSTC-A have not implemented DOD performance management guidance to measure and to evaluate
ScanEagle program performance. The January 2017 DOD Instruction 5132.14, Assessment, Monitoring, andEvaluation Policy for the Security Cooperation Enterprise, requires CSTC-A to, for example
1. Develop an initiative design document, a comprehensive document that specifies measurable,attainable, relevant, and time-bound objectives to guide all security cooperation initiatives and help
ensure the program is effectively implemented; and maintain and retain the document to makeupdates as needed, to then share among stakeholders.
2. Develop a performance management plan for the security cooperation initiative, which includes alogical framework that maps program goals and objectives to the activities necessary to achieve
desired change, to monitor program progress toward desired outcomes by tracking inputs (e.g.,funding, manpower, and expertise), and then determine whether programmatic milestones areachieved within anticipated timeframes, budgets, and outcomes.
3. Conduct centralized, independent, and rigorous evaluations of significant security cooperation
initiatives to examine their relevance, effectiveness, and sustainability.
DOD did not provide evidence that CSTC-A prepared an initiative design document, a performance
management plan, or a centralized independent and rigorous evaluation, as the 2017 instruction requires. A
senior OUSD-P official told us that DOD has not yet implemented the 2017 instruction and that DOD’s Office ofDefense Security Cooperation plans to work with CSTC-A over the next year to do so. In an October 2018
report, SIGAR recommended that DOD comply with all DOD policies regarding security cooperation assistance,
including DOD Instruction 5132.14. DOD concurred with the recommendation and stated that OUSD-P planned
to submit a plan to Congress to assess, monitor, and evaluate security cooperation programs implemented
under the Afghanistan Security Forces Fund for fiscal year 2019.43
In December 2019, the same senior OUSD-P official told us that he interpreted the DOD instruction as applying
broadly to the Afghanistan Security Forces Fund programs and not to any one specific program, such as
ScanEagle. However, DOD did not provide us any documentation to support this new interpretation.
In May 2020, after reviewing a draft of our report, DOD provided us a copy of the plan it sent to Congress toassess, monitor, and evaluate security cooperation programs, but noted that the plan did not specificallyaddress ScanEagle. DOD later “determined that this approach [plan] would not be sufficient to meet
Congressional intent because it would cover barely a fraction of the total Afghanistan Security Forces Fundappropriation.”44
In May 2020, OUSD-P and the Office of the Deputy Assistant Secretary of Defense for Security Cooperation also
told us they do not need to, nor do they plan to, measure and evaluate ScanEagle program performance under
the January 2017 DOD Instruction 5132.14. These DOD officials noted that the instruction only began to apply
to Afghanistan Security Forces Fund programs and activities starting in fiscal year 2019 as a result of the
FY2019 National Defense Appropriation Act, and therefore, the instruction did not apply to ScanEagle efforts
that began before the start of fiscal year 2019. In addition, the same DOD officials told us that they interpret the
43 SIGAR, Afghanistan National Defense and Security Forces: DOD Lacks Performance Data to Assess, Monitor, andEvaluate Advisors Assigned to the Ministries of Defense and Interior, SIGAR 19-03-AR, October 2018.
44 DOD, Fiscal Year 2019 Plan for Assessment, Monitoring, and Evaluation of Security Cooperation Activities of the
Department of Defense: Submitted pursuant to Section 1211 of the John S. McCain National Defense Authorization Act for
Fiscal Year 2019 (Public Law 115-232), March 2019.

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DOD instruction as breaking security cooperation initiatives down by programs, projects, and then activities.
DOD officials told us that ScanEagle is an activity under the Afghanistan Security Forces Fund program, and the
project “might be” the “development of ISR [intelligence, surveillance, and reconnaissance] capability.”
The DOD officials further stated that it would be a “massive undertaking” to apply the instruction to initiatives
below the project level, and would require “dozens of teams” and “extra millions if not tens of millions ofdollars of funding” to expand the instruction to evaluate the performance of activities such as ScanEagle. To
address the DOD instruction for the Afghanistan Security Forces Fund program, DOD hired the Center for Naval
Analyses to conduct the required assessments, monitoring, and evaluation. However, this work does not
currently include, and does not plan to include, ScanEagle. The DOD officials said DOD would need about twoto three years to determine if there is any value in expanding the scope of work to include intelligence,
surveillance, and reconnaissance projects as a whole, as well as possible aspects of ScanEagle. As such, DOD
does not plan to apply DOD Instruction 5132.14 to the ScanEagle program in Afghanistan for at least three
years, and even then, any assessment, monitoring, or evaluation would not be focused specifically on
ScanEagle nor formally measure the performance of the ScanEagle program.
A senior CSTC-A official told us in January 2019 that CSTC-A’s only means for measuring the ScanEagle
program’s performance is using the January 2019 Afghanistan Compact and collecting anecdotal evidence
from ANA operations.45 The compact includes tasks for CSTC-A to field ScanEagle UAS to ANA Corps, train ANA
ScanEagle detachment personnel, and develop a training sustainment plan for the ScanEagle UAS. CSTC-A
reported that it has not met these goals but plans to complete them by December 2020. Despite previous
assertions that it used the compact to measure ScanEagle outcomes, CSTC-A told SIGAR in September 2019that it no longer uses the compact.46 As a result, it appears CSTC-A no longer measures against the compact’s
ScanEagle outcomes.47
CSTC-A officials provided examples of ScanEagle program performance successes that include the ANA
occasionally flying a ScanEagle UAS without Insitu’s support, the ANA identifying enemy sites while flying (e.g.,
locating two Taliban prison of war camps), and the ANA providing other ANA forces video to assist with
conducting aerial strikes on terrorist targets.48 In January 2020, CSTC-A officials told us that the ScanEagle
program helped identify 900 enemy locations in 1 year. CSTC-A also commented that “while we do not have
day-to-day visibility on all their successes or failures, we do know that ScanEagle is considered ‘highly effective’by the Afghan Chief of General Staff and his GSG2 [intelligence staff].” Although anecdotal assertions ofsuccess can help inform decision making, they are not a replacement for a formal, specific, fact-based
assessment, monitoring, and evaluation of ScanEagle. In June 2020, in response to our draft report, theDeputy Chief of Staff for Intelligence, Train, Advise, and Assist told us that with the exception of theschoolhouse, all seven ScanEagle hubs are operating without Insitu personnel due to COVID-19; however,Insitu personnel were available virtually to provide assistance.49 Moreover, during this time, the ANA fielded

45 DOD describes the Afghanistan Compact as a U.S. and Afghan government initiative owned by U.S. Forces–Afghanistanthat attempts to track and measure the performance of various activities conducted to improve the capacity of the ANDSF
and ANA, such as ANA security and ISR capabilities.
46 The CSTC-A official stated that CSTC-A no longer uses the Afghanistan Compact Task Tracker, which outlines criticalareas, goals, and associated tasks to achieve a desired end state. The CSTC-A official noted that the U.S. Department ofState uses the compact, while CSTC-A relies on bilateral commitment letters with the Afghan government. However, CSTC-A
stopped using commitment letters in early 2020.
47 In May 2020, a senior OUSD-P official questioned why a CSTC-A official said this, and told us he believes the compact“was not a means by which DOD tracks its programs.”
48 In January 2020, after we discussed our preliminary audit findings with CSTC-A officials, CSTC-A commented that the ANA
now “frequently” has the capability to achieve these types of successes. However, CSTC-A did not provide additional
evidence to support this improvement.
49 The schoolhouse has one Insitu personnel on site to provide on-the-job training for newly qualified personnel.

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Page 15three spokes and a landing recovery system without hands-on assistance from Insitu.50 The ANA is also
conducting distance learning education to qualify new mission coordinators.
CSTC-A does not have access to all of NAVAIR’s detailed ScanEagle contract records to understand what Insitu
is specifically supposed to accomplish or to measure overall program performance. CSTC-A officials told us that
NAVAIR did not always grant access to detailed ScanEagle contract records. Although CSTC-A personnel
occasionally visited operational ScanEagle sites and observed ANA and Insitu activities, without contract
records detailing the requirements Insitu must perform, CSTC-A personnel could not fully understand what
Insitu was supposed to do, verify the extent to which Insitu performed required tasks, or determine how CSTCA’s own efforts enhanced overall program performance. CSTC-A said it made multiple requests to NAVAIR forthe contract records and deliverables, including MISHAP reports, but NAVAIR did not provide them or simply did
not respond to the requests. A CSTC-A official told us that because NAVAIR did not provide requested contract
documents, it was difficult for CSTC-A to advise the ANA, as the command did not know what equipment andservices Insitu was required to provide. Another CSTC-A official told us that she was especially concerned about
the lack of information on the number of ScanEagle crashes and why they occurred.
In May 2020, in response to our draft report, NAVAIR told us it has begun taking steps to provide CSTC-A
access to contract deliverables and records for the current contract. We are encouraged that NAVAIR is taking
initial steps to address our report’s third recommendation.
As a result of DOD’s new May 2020 interpretation of DOD Instruction 5132.14 and the explanation that DOD
does not need to apply the instruction’s requirements to ScanEagle, we deleted a recommendation containedin a draft of this report that called for DOD OUSD-P to provide guidance to NAVAIR and CSTC-A on theimplementation of DOD Instruction 5132.14 for the ScanEagle program, including requirements to measureperformance and assess sustainability of the program. However, we maintain that DOD would benefit fromformally measuring the performance and sustainability of the ScanEagle program.

DOD DID NOT ASSESS THE SUSTAINABILITY OF THE SCANEAGLE PROGRAM
AND ENCOUNTERED DELAYS IN DEVELOPING THE ANA’S OPERATIONALCAPABILITY
DOD has not assessed whether the ANA can sustain the ScanEagle program. Furthermore, DOD has
encountered delays in developing the ANA’s capability to independently operate the program due to several key
challenges, specifically issues related to (1) training ANA soldiers, (2) manning ScanEagle operations, (3)fielding operational ScanEagle sites, and (4) operationalizing intelligence obtained through the ScanEagle
program. As a result, DOD lacks information necessary to track, understand, and improve the return on its $174
million investment in the program, and is poorly positioned to transfer program responsibilities to the ANA.

DOD Did Not Assess the Sustainability of the ScanEagle Program
The January 2017 DOD Instruction 5132.14, Assessment, Monitoring, and Evaluation Policy for the Security
Cooperation Enterprise, requires DOD to accurately report on the sustainability of programs, maintaintransparency with key stakeholders, and track programs to make necessary adjustments on the investment.
The instruction also requires DOD to perform a “rigorous” evaluation of a security cooperation program to
examine its relevance, effectiveness, and sustainability, and to conduct an initial assessment that describes
the Afghan government’s willingness and propensity to implement and sustain the program, improve
institutional capacity, build its capabilities as needed, and identify requirements, gaps, and potential risks.

50 The ScanEagle system operates ANA “hub” and “spoke” locations. A hub is a primary ANA operational site that includes

the ScanEagle ground control system. A spoke is a support site.
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We found that DOD did not assess the sustainability of the ScanEagle program or the ANA’s ability to sustain
the ISR capabilities it developed and acquired using the ScanEagle UAS. OUSD-P and CSTC-A officials told usthat there is no documented sustainability plan for how the ANA will maintain and sustain the ScanEagle
program without U.S. government support. Despite the absence of a sustainability assessment, senior officials
with CSTC-A and the ANA said the program will fail if the U.S. government stops funding it.
OUSD-P acknowledged in May 2019 that it had not yet implemented the DOD instruction. A senior OUSD-P
official at the time also confirmed that there are no documents outlining the Afghan government’s capacity toabsorb and maintain any progress made under the ScanEagle program, sustain the program over the longterm, or establish an appropriate number of personnel to staff and field ANA ScanEagle sites acrossAfghanistan to be mission ready. The official further confirmed that there is no transition plan with milestones
detailing how DOD will hand the program over to the ANA.
As we reported above, in May 2020, DOD officials told us that it is not required to, and is not, applying the DOD
instruction to the ScanEagle program. As a result, we conclude that DOD does not plan to perform a “rigorous”
evaluation of ScanEagle to examine its relevance, effectiveness, and sustainability, nor will DOD conduct anassessment that (1) describes the Afghan government’s willingness and propensity to implement and sustain
the program, improve institutional capacity, build needed capabilities; and (2) identifies requirements, gaps,
and potential risks.51
CSTC-A officials told us that the command could not measure the progress and performance of the ScanEagle
program to determine the program’s overall sustainability because CSTC-A had limited access to contract
documents describing the work that Insitu should have conducted. In addition, DOD did not measure theprogram’s performance. As a result, CSTC-A officials told us they could not identify accomplishments against
which it could assess the sustainability of the program.
Although DOD says it is not required to meet the requirements in the 2017 DOD instruction for ScanEagle, it
did consider the sustainability of the ScanEagle program to some extent. For example, a senior CSTC-A official
stated that CSTC-A and the ANA’s intelligence command responsible for ISR capabilities have discussed that
the ANA should, at some undefined point in the future, take over a portion of the program’s “auxiliary
expenses”—such as supplying food to ANA students during training classes, providing some of their own
security, and providing air traffic control—which the U.S. government currently provides. However, neither CSTCA nor the ANA has developed any specific plans to transition those activities. In June 2020, in response to ourdraft report, the Deputy Chief of Staff for Intelligence, Train, Advise, and Assist stated that the schoolhouse
located at Kandahar Airfield will transition to Afghan government control next year, at which point the ANA will
pay the cost of auxiliary expenses.
In May 2020, in response to the draft report, an official within the Resolute Support’s Office of the Deputy
Chief of Staff for Intelligence told us that the “ANA ScanEagle program is as sustainable as any other FMS or
pseudo FMS program in the world,” and that the ANA will require continued U.S. government financial andtechnical support to sustain the ScanEagle program. However, we believe these comments misinterpret or
redefine the purpose of sustainability. Although DOD says it is not required to implement the DOD instruction
and its sustainability requirements, the instruction specifically defines sustainability as “the partner country’s[Afghanistan] ability to maintain capability, capacity, or other results of a security cooperation intervention at
the desired level of effectiveness and efficiency.”52 Furthermore, one of DOD’s original justifications forlaunching the ScanEagle program in March 2015 was that the program would be “cost-effective for both
51 In June 2020, in response to our draft report, the Deputy Chief of Staff for Intelligence, Train, Advise, and Assist told usthat the ScanEagle program is being operated by the ANA with minimal assistance from Insitu personnel and militaryadvisors, and the program no longer requires a transition plan. However, despite the reported progress, we maintain that atransition plan is required to document how the Afghan government plans to absorb the cost of the program and maintain it
in the future.
52 DOD, DOD Instruction 5132.14, Assessment, Monitoring, and Evaluation Policy for the Security Cooperation Enterprise,

January 2017, p.23.

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Page 17operations and sustainment, allowing GIRoA [the Afghan government] to develop independent operations andconduct material sustainment.”53

DOD Has Encountered Delays and Challenges in Developing the ANA’s Capability to
Operate and Maintain the ScanEagle Program
CSTC-A and NAVAIR have encountered delays and challenges in developing the ANA’s capability to
independently operate and maintain the ScanEagle program due to (1) inadequate ANA training and Personnel
to conduct ScanEagle operations, (2) insufficient fielding of operational ANA ScanEagle sites and ANA’s
inability to account for ScanEagle equipment, and (3) the ANA’s inability to operationalize intelligence obtained
through the program.

NAVAIR and CSTC-A Did Not Meet Early Training Goals, Lacked Important Training Information, and Did Not
Have Enough ANA Personnel for ScanEagle Operations
CSTC-A and NAVAIR officials told us that the first ScanEagle contract underperformed in meeting ANA training
goals for the following reasons: the ANA initially selected unqualified students to go through training; Insitu
conducted training at insecure ANA locations; and Insitu was required to use U.S. military security andtransportation, which was not available consistently, to move its personnel between U.S. and ANA military sites.
For example, CSTC-A, NAVAIR, Insitu, and Afghan officials told us that the first ANA ScanEagle training group
was poorly selected because most of the students the ANA chose did not have basic English language skills ornecessary computer skills to understand Insitu’s training. CSTC-A, NAVAIR, and Insitu officials also stated thatearly in the ScanEagle program, DOD relied on Insitu personnel being able to move daily in Mazar-i-Sharif
between a U.S. military base and the offsite ANA ScanEagle schoolhouse. However, due to the security
situation in Mazar-i-Sharif and limited access to U.S. “Guardian Angel” assets required to escort Insitu
personnel to the schoolhouse, they often could not get to the ANA schoolhouse to conduct training classes.54
We also found that NAVAIR and Insitu did not continuously track and document the number of students
enrolled in the ScanEagle training, or the number of students who drop out, fail, or are expelled.55 As a result,
NAVAIR and CSTC-A are missing important information to assess the extent to which ANA soldiers complete thetraining required to take over the ScanEagle program.
CSTC-A took steps to address some of the challenges impacting ANA training by moving the ScanEagle
schoolhouse to a U.S. military base, giving Insitu personnel easier access to the training location and removing
the need for Guardian Angel support. In addition, beginning with the second contract, the ANA started to better
identify more qualified ANA soldiers for training by requiring potential ScanEagle students to first take a 6month preliminary course to learn English and the basic computer literacy skills necessary to understand the
ScanEagle training. NAVAIR also replaced a contract requirement for Insitu to train a specific number ofstudents within a specific timeframe with a requirement to conduct a specific number of training hours per
week. For example, we found that NAVAIR significantly revised training requirements in the contract fromtraining 12 to 20 students in 11 weeks, to training “no more than” 28 students in 50 weeks because of the

53 DOD, Memorandum for Record: Afghanistan Security Forces Funds (ASFF) Letter of Justification for ScanEagle UAS
Purchase, March 2015, p.1.
54 Guardian Angels are personnel who are part of a security force team. The personnel are in the room with advisors during
interactions with ANSDF personnel and trained to protect the advisors and themselves from insider threats.
55 In January 2020, NAVAIR commented that it disagrees with our statement, but it did not provide any additional
information or evidence to support its opinion.

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aforementioned training challenges.56 As a result, NAVAIR and Insitu are no longer responsible for the numberof ANA staff trained each year, but rather for ensuring that training is offered each year.
In addition, a responsible CSTC-A official told us the ANA faces significant challenges manning ScanEagle
operational sites and equipment because of attrition of certified ANA soldiers capable of performing ScanEagle
missions and absenteeism of ANA soldiers from sites. As of October 2018, CSTC-A reported a 31 percent
attrition rate in the ScanEagle program.57 Of the 87 ANA soldiers certified to operate the ScanEagle UAS, the
ANA reported only 60 of those soldiers performing the ScanEagle mission. ANA cannot account for the other 27
soldiers. Furthermore, the CSTC-A official told us it is a challenge to have the appropriate number of ANA
soldiers to staff the ScanEagle program at a given time because the ANA does not offer soldiers a career
progression plan as ScanEagle operators. Because of this, certified ANA soldiers opt to transfer or relocate toother missions that offer opportunities for career advancement soon after starting the ScanEagle mission. In
addition, a CSTC-A official told us that senior ANA leadership prioritizes staffing other missions and programs
over ScanEagle, and relocates capable soldiers who had been trained and certified on the ScanEagle system.
As a result, although the U.S. government has invested approximately $24.4 million as of March 2019 to train
ANA soldiers to operate the ScanEagle, some soldiers leave without ever supporting or operating them.
According to CSTC-A officials, it takes almost 1 year to train one soldier to operate the ScanEagle system.
In addition, NAVAIR, CSTC-A, and Insitu officials told us that it is a challenge to get ANA soldiers to actively
participate in ScanEagle missions. CSTC-A reported that on average, 17, or almost 28 percent, of the 60 active
soldiers are absent from operational sites each day because of sickness, annual leave, or unknown reasons.
In January 2020, after we discussed our preliminary audit findings with NAVAIR officials, NAVAIR commented
that it “disagrees that it has a formal role in effectuating transfer of ownership to the ANA. CSTC-A, as therequirements owner, is primarily responsible for execution of the ScanEagle program.”58 However, we believethat NAVAIR does have a role by working with Insitu to train ANA soldiers, one of the key challenges we note intransferring ownership of the program to the ANA. For example, the fifth contract’s statement of work says
Training will be conducted six (6) days per week. Upon completion of the initial qualification training, allcertified students will transition to On-the-Job (OJT) training provided by the Contractor. This will include
Site Operations training that consists of hands on training to conduct site surveys, prepare, and executesite setup, complete flight events that include launch, handoff, recovery, ground crew duties, mission
coordination, video exploitation, scheduled and unscheduled maintenance and site teardown.59
Furthermore, according to officials from CSTC-A, U.S. Forces–Afghanistan, and the ANA, training and staffing
challenges also directly affect the ANA’s ability to meet ScanEagle program targets for fielding ANA-operated
ScanEagle sites. In DOD’s December 2015 Enhancing Security and Stability in Afghanistan report to Congress,
DOD stated that the ANA would operate all of the required “hub” (primary) and “spoke” (support) sites byAugust 2018 and that the ANA would operate the sites as Afghan “government owned, government operated,”
which would require limited to no contractor operation and maintenance support.60 As of December 2019,56 In January 2020, NAVAIR told us we were incorrect to report that the training requirements are capped at a maximum of
28 students per 50 week period. NAVAIR also said CSTC-A revised the training requirements in the contract. However,
NAVAIR did not provide evidence to support either of these statements.
57 The most recent, unclassified documentation available to us was from October 2018.
58 NAVAIR, SOF NAVAIR Edits, January 10, 2020.
59 NAVAIR, Statement of Work, ScanEagle Unmanned Aircraft System (UAS), Spares, Training and support Procurement
Follow on Support for Afghanistan, Contract No. N68335-16-G-0046, Delivery Order N6833519F0434, awarded to Insitu
Inc., March 19, 2019, p. 4.
60 DOD, Enhancing Security and Stability in Afghanistan, December 2015. The ScanEagle system operates at ANA “hub”
and “spoke” locations. A hub is a primary ANA operational site that includes the ScanEagle ground control system.
According to NAVAIR, a government owned, government operated site assumes all ANA personnel are proficient in daily
ScanEagle operator roles and responsibilities. A government owned, government operated site should have three or fewer
Insitu field support representatives who only provide subject matter expert assistance in support of the ANA [ScanEagle]
UAS operations.

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Page 19there were six ScanEagle primary locations, three support locations, and a schoolhouse. At that time, CSTC-A
reported that all the ANA ScanEagle sites were still heavily reliant on Insitu’s support and remained“government owned, contractor operated” sites.61
CSTC-A commented in January 2020 that all sites were converted to “government owned, government
operated” and that no site has more than two Insitu field support representatives. However, CSTC-A did notprovide evidence to support this change and acknowledged that the ANA are still heavily reliant on Insitu’s
support, even though CSTC-A now considers the sites to be government operated. Moreover, per NAVAIR
contracts, a “government owned, government operated” site should use Insitu personnel only to provide
subject matter expert assistance to the ANA, and all ANA personnel at the site should be proficient in dailyroles and responsibilities. It is not clear based on CSTC-A’s January 2020 response to us whether thecommand also thinks ANA personnel are proficient and in what particular roles and responsibilities.
Furthermore, being “government owned, government operated” site does not, on its own, mean ANA personnel
on site are independently operating ScanEagle missions or independently maintaining ScanEagle equipment.
In May 2020, in response to our draft, an official within the Resolute Support’s Office of the Deputy Chief ofStaff for Intelligence told us that as of April 2020, two ScanEagle sites each have two Insitu field support
representatives. The official also told us that, for example, all seven ANA ScanEagle hubs now operate daily
flights with no Insitu personnel on site. Furthermore, the official said the current ScanEagle contract scope was
reduced in January 2020 and April 2020, and now only one ScanEagle site has Insitu contractors on site tosupport on-the-job training for newly qualified ANA personnel. The remaining Insitu contractors support the ANA
sites virtually through telephone and other applications, and have helped the ANA field three new spokes
without providing on-site assistance. The official also noted that the “vast majority of ANA personnel are
proficient in ScanEagle roles and responsibilities” and the Insitu field support representatives are only
providing subject matter expertise at the “government owned, government operated” sites.62

ANA Logistical Challenges Have Impacted the ANA’s Ability to Maintain Accountability over Its ScanEagle
Equipment
CSTC-A and Insitu officials told us they have concerns regarding the ANA’s logistics capabilities to move anddeliver essential ScanEagle equipment to the appropriate operational sites in a timely manner, which also
affects fielding needs. According to a senior CSTC-A official, the ANA is responsible for the logistics of moving
equipment from the warehouse to the operational sites, but the ANA does not treat this as an important task.
Another CSTC-A official added that it can take more than 3 weeks to move equipment from the warehouse to an
operational sites because of security impediments. To address the security issue, the ANA relies on airborne
logistics support. However, the ANA only has two C-130 transport aircrafts in its fleet to move all ANA equipment,
and therefore has limited resources to move ScanEagle equipment. The CSTC-A official also said that ANA
ScanEagle personnel are not well trained on inventory management and logistics, and rely heavily on an Insitu
logistician. Without Insitu, the official added, the ANA would not be able to ship the correct equipment to theappropriate sites because soldiers are not familiar with ScanEagle parts and their corresponding serial numbers.

61 A government owned, contractor operated ScanEagle site should have four or more Insitu field support representatives,and be capable of conducting daily flight operations regardless of the number of ANA personnel manning the site. Insitu
support should include “all phases” of ANA ScanEagle UAS operations including launch, mission execution, recovery, andpost flight maintenance. In January 2020, CSTC-A clarified that ANA support, or spoke, sites do not have Insitu field support
representatives and were established to not have these personnel present, and that CSTC-A has no plans to assign Insitu
personnel to the next three support locations.
62 In June 2020, in response to our draft report, the Deputy Chief of Staff for Intelligence, Train, Advise, and Assist told us
the following: due to COVID-19 conditions, Insitu personnel were providing support to the ANA remotely with the use ofvarious electronic applications; in April 2020, the ANA was able to complete the complex task of setting up a Mark 3
Skyhook through remote support; in May 2020, the ANA’s 203rd Corps announced that its ANA maintainers had
independently returned two damaged ScanEagle aircraft to service; and the ANA successfully completed a training class atCamp Hero in June 2020, graduating 7 new ScanEagle Mission Coordinators by utilizing Afghan instructors and remote
Insitu personnel support.

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Logistical challenges also directly impact the ANA’s ability to maintain accountability over the ScanEagle
equipment it owns. CSTC-A and NAVAIR said the ANA is responsible for ScanEagle system logistics. However,the ANA is not tracking the real-time location of ScanEagle equipment across Afghanistan. CSTC-A officials told
us they are concerned that the ANA does not know where the equipment it owns is located or whether it isbeing used appropriately. Furthermore, a senior U.S. official told us that U.S. officials have had concerns abouta ScanEagle system falling into the wrong hands and potentially becoming weaponized. For example, welearned from a U.S. official that in October 2019, Afghan law enforcement seized a stolen ScanEagle vehicle
that a criminal intended to sell to a suspected terrorist organization for $400,000. CSTC-A senior officials said
they were aware of this incident.

ANA Is Unable to Operationalize the Intelligence Collected Through the ScanEagle Program
CSTC-A officials told us that although the ScanEagle program is building the ANA’s capability to perform ISR
missions, such as conducting ScanEagle flights to collect surveillance and reconnaissance video forintelligence, the program is not focused on developing the ANA’s capability to produce and process actionable
intelligence. A CSTC-A official said the program is not responsible for training the ANA on how to analyze andprocess the surveillance and reconnaissance information it collects from ScanEagle UAS. In addition, Insitu
and CSTC-A personnel are not responsible for teaching the ANA how to apply the analyzed intelligence to larger
military combat and targeting operations. In June 2020, in response to our draft report, the Deputy Chief ofStaff for Intelligence, Train, Advise, and Assist confirmed that the contractor, Insitu, does not advise on how totarget enemy forces because that is considered an inherently governmental task. However, they added that the
Ministerial Advisory Group for Defense Intelligence Advisors, as well as advisors at each Train, Advise, andAssist Command, Task Force, and NATO Special Operations Component Command–Afghanistan’s Regional
Targeting Teams, do advise the ANA daily on how to use the ISR collected to call for helicopter support, attack
aircraft, or artillery fires.63
A CSTC-A official said the ANA’s ability to use intelligence collected by the ScanEagle UAS to plan and, to alesser extent, control combat operations is limited. This official added that the ANA soldiers operating thesystems may be able to launch, fly, and retrieve ScanEagle vehicles, but they do not understand how tointegrate the information collected from missions into intelligence to guide ANA operations and targeting. The
official added that the ANA is dependent upon the U.S. military for technical assistance to prepare weekly
ScanEagle flight schedules for ANA ISR targeting efforts.
A U.S. Forces–Afghanistan official said in January 2019 that CSTC-A is hesitant to train and counsel the ANA on
intelligence analysis, partly because of concerns that some of the ANA ScanEagle pilots enrolled in the training
program are on a watch list for having ties to the Taliban. He said he feared that “the training is going straightto the Taliban.”64
In January 2020, after we discussed our preliminary audit findings with CSTC-A officials, CSTC-A commented
that the ScanEagle program is addressing a key ANA ISR gap in that it is providing the ANA with an aerial
vehicle to help it locate enemy forces and then call in artillery fire or airstrikes against those targets. CSTC-A
reiterated that the ANA lacks the ability to integrate multiple forms of intelligence information, such as signal
and imagery intelligence, into longer term analysis, and that Insitu and CSTC-A personnel are not responsible
for teaching this to the ANA.

63 Ministerial Advisory Groups are U.S. or Coalition General Officers who serve as senior advisors to the Afghan Minster ofDefense or Minister of Interior. General Officers and their staff coordinate and align advising efforts across the Resolute
Support Mission.
64 In May 2020, in response to our draft report, an official within the Resolute Support’s Office of the Deputy Chief of Staff

for Intelligence told us that DOD “rigorously” vets all ANA ScanEagle personnel. DOD did not provide any evidence tosupport this statement.
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CONCLUSION
From November 2015 through November 2019, DOD spent at least $174 million to (1) procure ScanEagle
UAS; (2) train the ANA on operating and maintaining the systems; and (3) purchase spare parts for continuing
ScanEagle operations. Despite this significant investment in time and resources, DOD does not know theimmediate or longer-term impact of this investment due to basic contract and program management
shortcomings, and a failure to adhere to U.S. government and DOD requirements.
DOD did not conduct required contract oversight. Specifically, NAVAIR did not designate a COR for three of thefour ScanEagle contracts, or identify DOD personnel in Afghanistan to help oversee Insitu’s implementation of
the contracts and validate the work performed. Moreover, NAVAIR was unable to show that Insitu completed
required deliverables. If DOD does not improve its contract oversight in the United States and in Afghanistan, it
will continue to lack critical information to determine whether Insitu met the terms of the contracts, andwhether the contracts are addressing CSTC-A’s requirements for the ANA.
In addition, DOD is unable to evaluate the performance of the ScanEagle program because CSTC-A did notmeasure the program’s performance. Although CSTC-A provided anecdotal examples of program successes it
observed, the command does not specifically know what DOD’s $174 million investment has accomplished.
Moreover, CSTC-A does not have accurate information to justify or continue to fund the ScanEagle program due
to lapses in NAVAIR’s oversight of Insitu and a lack of information necessary to determine the impact of the
ScanEagle program. Unless DOD improves its measurement and evaluation of the ScanEagle program’s
performance, DOD cannot make informed decisions or properly plan for the future of the program.
Although DOD has taken steps to transfer the management and operation of the ScanEagle systems to theAfghan government, the department has not assessed the extent to which the ANA can sustain the program.
For example, DOD said it is not required to follow DOD requirements to develop a sustainability plan, evaluate
the sustainability of the program, or conduct an initial assessment of the Afghan government’s willingness tosustain the program. Moreover, DOD and the ANA have identified delays and challenges in developing the
ANA’s capability to independently operate and maintain the ScanEagle program that threaten the ANA’s ability
to sustain it. By not performing sustainability assessments to address critical challenges, DOD’s 5-year
investment in the ScanEagle program will remain at risk of not delivering the intended ISR capabilities to the
ANA. Furthermore, unless DOD and the ANA work together to better ensure that trained ANA soldiers use theiracquired ScanEagle skills, DOD may risk wasting money invested in extensive training that is barely or neverused. Finally, unless DOD and the ANA work together to better ensure the ANA soldiers can better track where
the equipment it owns is located, the ANA will continue to risk losing its critical, costly, ScanEagle assets.

RECOMMENDATIONSTo improve ScanEagle contract oversight, we recommend that the Secretary of Defense:
Direct NAVAIR personnel managing and overseeing the ScanEagle contracts to ensure the Contracting
Officer’s Representative (COR) on the current contract is performing all required COR duties, including
documenting and maintaining records such as reporting deliverables.
Direct NAVAIR, in coordination with appropriate coalition partners, to immediately designate andannounce an in-country sponsor and an in-country COR, Contracting Officer Technical Representative,
or Government Technical Product Representation for the current ScanEagle contract.
To better understand the performance of the ScanEagle program, and the Afghan government’s ability tosustain the program, we recommend that the Secretary of Defense:

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Direct NAVAIR to immediately share existing Insitu performance reporting information and related
contract deliverables with appropriate coalition partners responsible for the current ScanEagle
contracts, and agree to a plan with CSTC-A for sharing future contract performance information.
To ensure that U.S. investments in training Afghan National Army (ANA) soldiers to perform the ScanEagle
mission are protected, we recommend that the Secretary of Defense:
Work with the ANA to develop requirements to help ensure that recently certified ANA soldiers will beplaced in positions that take advantage of their newly acquired skills on the ScanEagle UAS.
To help ensure that U.S. procurements in ScanEagle equipment are protected and used as intended, SIGAR
recommends that the Secretary of Defense:
Direct responsible DOD departments to work with the ANA to establish a system for tracking thelocation of ScanEagle equipment across Afghanistan.

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AGENCY COMMENTS
We provided a draft of this report to DOD for review and comment. We received written comments from (1) the
Deputy Assistant Secretary of Defense for Afghanistan, Pakistan, and Central Asia; (2) the Combined Security
Transition Command–Afghanistan; and (3) the United States Forces–Afghanistan Deputy Chief of Staff forIntelligence, Train, Advise, and Assist, which are reproduced in appendices IV, V, and VI respectively.
Additionally, the Deputy Chief of Staff for Intelligence, Train, Advise, and Assist, CSTC-A, Navy Air Systems
Command, and the Office of the Under Secretary of Defense for Policy provided technical comments whichwere integrated into the report as appropriate.
The Deputy Assistant Secretary of Defense for Afghanistan, Pakistan, and Central Asia, stated that although
DOD disagreed with some of the key findings and conclusions, the audit process helped the various DOD
stakeholders closely examine the ScanEagle effort. The Deputy Assistant Secretary concurred with four of
SIGAR’s recommendations, and partially concurred with the second recommendation. SIGAR responses to the
key findings are noted below.
With regard to the first recommendation, DOD concurred and stated that NAVAIR has reviewed theperformance of the ScanEagle contract currently being executed and is “satisfied that the designated CONUS[Continental United States] COR is performing all required functions.” DOD also stated that NAVAIR has
confirmed receipt of all monthly COR surveillance reports and completion of contractor assessment reports
defined under the QASP. DOD requested that SIGAR close this recommendation. However, we will keep therecommendation open until we receive documentation identifying the official responsible for monitoring andassessing the performance of the contract, as well as additional information pertaining to DOD’s determinationthat NAVAIR’s actions satisfactorily fulfill oversight responsibilities.
With regard to the second recommendation, DOD partially concurred and stated that NAVAIR has identified an
in-country sponsor, and provided SIGAR with supporting documentation. DOD also stated that “DCOS INT[Deputy Chief of Staff for Intelligence] and NAVAIR are working on nominating and designating primary andalternate in-country CORs.” In addition, DOD stated that because the ScanEagle contract is a DOD contract,
there is no reason for NAVAIR to coordinate with other countries on its oversight. However, because the
Resolute Support mission, and Office of “DCOS INT,” is a coalition activity staffed by DOD personnel, thelanguage in the recommendation is appropriate. As we reported, we are encouraged that DOD appears to be
taking initial steps to address our report’s second recommendation and fulfill the intent of the Theater
Business Clearance. However, this recommendation will remain open until we receive documentation showing
the nominated and designated primary and alternate in-country sponsors.
With regard to the third recommendation, DOD concurred and stated that NAVAIR and CSTC-A agreed tomaintain “the practice of daily situation reports to communicate current contract performance/execution
status to document the contract performance information.” DOD also stated that NAVAIR provided CSTC-A
access to ScanEagle contract deliverables.” In addition, DOD stated that because the ScanEagle contract is a
DOD contract, there is no reason for NAVAIR to coordinate with other countries in its oversight. However, as
stated above, because the Resolute Support mission, and Office of “DCOS INT,” is a coalition activity staffed by
DOD personnel, the language in the recommendation is appropriate. Nevertheless, DOD has addressed theintent of our recommendation. Upon issuance of this report, we will close the recommendation as
implemented.
With regard to the fourth recommendation, DOD concurred and stated that DOD’s AROC “will provide guidance
to CSTC-A and DCOS INT to implement the recommendations to the extent possible, while taking into
consideration the status of the COVID-19 pandemic and the reduced U.S. presence in Afghanistan.” Therecommendation will remain open until DOD provides the guidance to CSTC-A and the Deputy Chief of Staff forIntelligence, Train, Advise, and Assist, and sends SIGAR evidence.
With regard to the fifth recommendation, DOD concurred and stated that DOD’s AROC “will provide guidance to
CSTC-A and DCOS INT to implement the recommendations to the extent possible, while taking into
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consideration the status of the COVID-19 pandemic and the reduced U.S. presence in Afghanistan.” Therecommendation will remain open until DOD provides the guidance to CSTC-A and the Deputy Chief of Staff forIntelligence, Train, Advise, and Assist, and sends SIGAR evidence.
In the Deputy Assistant Secretary of Defense for Afghanistan, Pakistan, and Central Asia’s comments, hestated that he wanted to “thank the members of your [SIGAR] team who worked on this audit for theircollaboration and for incorporating some of our comments and feedback into the draft,” and appreciated “your[SIGAR’s] continued efforts to ensure the Department is a good steward of Federal resources as we implement
the President’s strategy for the region.” However, the Deputy Assistant Secretary disagreed with some of thereport’s key findings noting that the title is “conclusory.” SIGAR reports typically provide titles that capture areport’s findings and support the overall conclusion. Given the evidence in this report, we believe the title isappropriate and does not need to be changed. In addition, the Deputy Assistant Secretary stated the reportcontained “factual inaccuracies.” For example, the Deputy Assistant Secretary stated that “DOD provided
oversight of the contract in accordance with the requirements set forth in the Defense Federal Acquisition
Regulation Supplement.” In addition, he noted that, “the assertion that there is a requirement to ‘assess theperformance and sustainability’ of the ScanEagle activity pursuant to DoD Instruction 5132.14…is based on [a]mis-interpretation of the DoD Instruction, which, as detailed below, does not apply the ScanEagle-related
activity.” We disagree with DOD’s summary of our work or that we have presented factual inaccuracies. As westated in our report, on multiple occasions, DOD officials provided us different and evolving explanations on
how they interpreted the DOD instruction as applying (or not applying) to the ScanEagle program. We did notinterpret the DOD instruction, but did rely on DOD’s interpretation, which changed throughout the course of ourwork. We presented that chronology in the report (see report pages 14-17).
In addition, we added language in our report to address the Deputy Assistant Secretary of Defense for
Afghanistan, Pakistan, and Central Asia’s comments that
following the enactment of Section 1211 of the National Defense Authorization Act for Fiscal Year2019, which made clear that Congress intends for DoD’s statutory AM&E requirements to apply to
ASFF-funded security cooperation programs, DoD embarked on a strategic evaluation of ASFF.
We also added language in our report to address the Deputy Assistant Secretary’s comments that “DCOS INT
notes that a ‘train-the-trainer’ program is up and running…”
In their comments, the Deputy Chief of Staff for Intelligence, Train, Advise, and Assist concurred with the fifth
recommendation, but did not address the other four recommendations. We addressed their technicalcomments in the report as appropriate. For example, we added language on page 3 of the report to reflect theirstatement that the ScanEagle program has made accomplishments in the train-the-trainer program (seeAppendix V Deputy Chief of Staff for Intelligence, Train, Advise, and Assist comment 3.b.). We also noted on
page 3 of the report that the Deputy Chief of Staff for Intelligence, Train, Advise, and Assist stated DOD’s goal
remains for the ANA to take over all ScanEagle training in 2021 (see Appendix V Deputy Chief of Staff forIntelligence, Train, Advise, and Assist comment 3.b.). In addition, we added language on page 18 of the report
to reflect a statement that the Kandahar Airfield schoolhouse is located on the American base for security
reasons, and is scheduled to transition to Afghan government control within the next year, at which point the
ANA will transition to providing its own food and accommodations (see Appendix V Deputy Chief of Staff forIntelligence, Train, Advise, and Assist comment 3.e.). We also added language on page 21 of the report thatthe Deputy Chief of Staff for Intelligence, Train, Advise, and Assist stated that Insitu, as a contractor, does notadvise on how to target enemy forces because that is an inherently a governmental task (see Appendix V
Deputy Chief of Staff for Intelligence, Train, Advise, and Assist comment 3.g). However, we did not update thereport to reflect a technical comment that “The ScanEagle program requires USG support only to purchase the
US made/ITAR [International Traffic in Arms Regulations] restricted items and occasional technical support.”
The ScanEagle UAS is not an International Traffic in Arms Regulations restricted item.

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In its comments, CSTC-A acknowledged all five recommendations, but added that because the programtransitioned to Deputy Chief of Staff for Intelligence, Train, Advise, and Assist, CSTC-A would provide support in
implementing the recommendations as needed.
We will follow-up with DOD within 60 days to identify its actions to address the five recommendations.

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APPENDIX I - SCOPE AND METHODOLOGYThis audit examined the Department of Defense’s (DOD) implementation of contracts and efforts to train andequip the Afghan National Army (ANA) with the ScanEagle Unmanned Aerial System (UAS), which is intended to
improve the ANA’s intelligence, surveillance, and reconnaissance (ISR) capabilities. This audit covered the time
period from November 2015 through November 2019, which included the periods of performance of four
completed ScanEagle contracts and a fifth contract that is still ongoing as of the date of this report. These fivefirm-fixed-price contracts were valued at more than $174 million and implemented by Insitu Inc. The Combined
Security Transition Command–Afghanistan (CSTC-A) and the Department of the Navy’s Naval Air Systems
Command (NAVAIR) were responsible for overseeing the program and the contracts. 65
The objectives of this audit were to determine the extent to which (1) the contractor, Insitu, met the terms ofthe contracts and DOD performed the required oversight of the ScanEagle program; (2) DOD measured andevaluated the ScanEagle program’s performance; and (3) DOD planned for the Afghan government’s
sustainment of the ScanEagle program, and the ANA developed the capabilities necessary to operate andsustain the program.
For all of our objectives, we reviewed
five ScanEagle contracts between NAVAIR and Insitu, and supporting documents, including Letters of
Acceptance, Memoranda of Request, Statements of Work, modifications, contract deliverables (e.g.,Contract Data Requirement Lists, Situation Reports, and monthly flight readiness reports), and reportfrom the Contractor Performance Assessment Reporting System;

U.S. government and DOD contract oversight, monitoring, performance measurement, andsustainability requirements and guidance, such as the Federal Acquisition Regulation (FAR); DOD’s
Security Assistance Management Manual, the January 2015 Theater Business Clearance Update for
Afghanistan, the Defense Contingency COR Handbook, and DOD Instruction 5132.14, Assessment,
Monitoring, and Evaluation Policy for the Security Cooperation Enterprise; and NAVAIR Instruction
4200.57, Contract Administration and Use of Contracting Officer’s Representatives; andemail communications between NAVAIR, CSTC-A, and Insitu.

In addition, we interviewed


officials in DOD’s Office of the Under Secretary of Defense for Policy (OUSD-P), the Defense Security
Cooperation Agency, and the Afghanistan Resource Oversight Council (AROC);



officials in CSTC-A’s Intelligence and Train, Advise, Assist, and Train, Advise, Assist Command–South;

officials in NAVAIR responsible for ScanEagle contract management;

officials in Army Contracting Command–Afghanistan;

ANA officers managing the ScanEagle program for the Afghan government; andInsitu personnel at their headquarters in Bingen, Washington, and at the ScanEagle Schoolhouse at
Kandahar Airfield in Afghanistan.

To determine the extent to which Insitu met the terms of the contracts and DOD performed the required
oversight of the ScanEagle program, we reviewed the five ScanEagle contracts, contract modifications, anddeliverables detailing the work Insitu was to perform. We reviewed U.S. government and DOD requirements
and guidance for contract management and oversight. We then compared these requirements to evidence of
Insitu’s implementation of the ScanEagle requirements during interviews and as demonstrated in
documentation, such as reporting deliverables. Finally, we compared the requirements to evidence of NAVAIR’s
65 Insitu is a wholly owned subsidiary of The Boeing Company and is headquartered in Bingen, Washington. Insitu designed,
developed, and produced the ScanEagle UAS.

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oversight of the ScanEagle contracts during interviews and as demonstrated in documentation, such as
NAVAIR Contracting Officer records.
To determine the extent to which Insitu completed the required reporting deliverables we analyzed deliverables
under the four completed contracts. We did not analyze reporting deliverables for the fifth contract because it
was ongoing at the time of our review.
To determine the extent to which DOD measured and evaluated the ScanEagle program’s performance, we
reviewed DOD’s and CSTC-A’s periodic reporting on the program through documentation, such as DOD’s
reports on Enhancing Security and Stability in Afghanistan, CSTC-A’s Performance Management Review
presentations, AROC meeting minutes, and Intelligence–Train, Advise, Assist emails and reporting updates to
CSTC-A command. We reviewed Insitu periodic performance reporting to NAVAIR. We interviewed Insitu, CSTCA, and ANA staff who conducted and observed ScanEagle training sessions, and active missions within
Afghanistan. We also interviewed NAVAIR officials who coordinated and communicated with Insitu staff on
ScanEagle contract performance.
To determine the extent to which DOD planned for Afghan sustainment of the ScanEagle program, and the ANA
developed the capabilities necessary to operate and sustain the program, we interviewed ANA personnel in
ScanEagle training and ANA officers conducting and commanding ScanEagle missions, to understand theextent to which they are acquiring the necessary capabilities. We also interviewed OUSD-P, NAVAIR, CSTC-A,
and ANA officials to identify challenges to sustaining the ScanEagle program and how, if at all, they haveaddressed these challenges.
We did not use or rely on computer-processed data for the purpose of our audit objectives. We assessed DOD
internal controls to determine the extent to which NAVAIR had systems in place to oversee Insitu and its
implementation of the ScanEagle contracts. We also determined the extent to which CSTC-A had systems inplace to measure and report on the performance and sustainability of the ScanEagle program and the ANA’s
progress in acquiring required ISR capabilities. In addition, we assessed the extent to which Insitu met thecontract terms. The results of our assessment are included in the body of the report.
We conducted our audit work in Arlington, Virginia; Patuxent River, Maryland; Lakehurst, New Jersey; Bingen,Washington; Hood River, Oregon; and Kabul and Kandahar, Afghanistan, from October 2018 to February 2020in accordance with generally accepted government auditing standards. Those standards require that we planand 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 reasonablebasis for our findings and conclusions based on our audit objectives. SIGAR performed this audit under theauthority of Public Law No. 110-181, as amended, and the Inspector General Act of 1978, as amended.

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APPENDIX II - SIGAR 19-44-AL, ALERT LETTER: DOD SCANEAGLE PROGRAM,JULY 5, 2019

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SIGAR 20-44-AR/DOD ScanEagle Program

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APPENDIX IV - RESPONSE FROM THE DEPUTY ASSISTANT SECRETARY OF
DEFENSE FOR AFGHANISTAN, PAKISTAN, AND CENTRAL ASIA

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APPENDIX VI - RESPONSE FROM UNITED STATES FORCES – AFGHANISTAN,JULY 8, 2020

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APPENDIX VII - ACKNOWLEDGMENTS
Eugene Gray, Senior Program Manager
John Schenk, Analyst-in-Charge
Suzana Chowdhury, Senior Program Analyst
Evan Ward, Program Analyst

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This performance audit was conductedunder project code SIGAR-127A.

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SIGAR’s Mission

The mission of the Special Inspector General for Afghanistan
Reconstruction (SIGAR) is to enhance oversight of programs for thereconstruction of Afghanistan by conducting independent andobjective audits, inspections, and investigations on the use of
taxpayer dollars and related funds. SIGAR works to provide accurate
and balanced information, evaluations, analysis, andrecommendations to help the U.S. Congress, U.S. agencies, andother decision-makers to make informed oversight, policy, andfunding decisions to:

improve effectiveness of the overall reconstruction
strategy and its component programs;



improve management and accountability over funds
administered by U.S. and Afghan agencies and theircontractors;



improve contracting and contract management
processes;

prevent fraud, waste, and abuse; andadvance U.S. interests in reconstructing Afghanistan.

Obtaining Copies of SIGAR
Reports and Testimonies

To obtain copies of SIGAR documents at no cost, go to SIGAR’s Web
site (www.sigar.mil). SIGAR posts all publicly released reports,
testimonies, and correspondence on its Web site.

To Report Fraud, Waste, andAbuse in Afghanistan
Reconstruction Programs

To help prevent fraud, waste, and abuse by reporting allegations offraud, waste, abuse, mismanagement, and reprisal, contact SIGAR’s
hotline:Public Affairs

Web: www.sigar.mil/fraudEmail: sigar.pentagon.inv.mbx.hotline@mail.milPhone Afghanistan: +93 (0) 700-10-7300



Phone DSN Afghanistan: 318-237-3912 ext. 7303



Phone International: +1-866-329-8893



Phone DSN International: 312-664-0378



U.S. fax: +1-703-601-4065

Public Affairs OfficerPhone: 703-545-5974

Email: sigar.pentagon.ccr.mbx.public-affairs@mail.mil



Mail: SIGAR Public Affairs
2530 Crystal Drive
Arlington, VA 22202