OPERATIONAL 

CONTRACT 

SUPPORT

Actions Needed to 

Enhance Capabilities 

in the Pacific Region

Report to the Subcommittee on 

Readiness, Committee on Armed 

Services, House of Representatives

June 2017

GAO-17-428

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-428, a report to the 

Subcommittee on Readiness, Committee on 

Armed Services, House of Representatives 

June 2017

OPERATIONAL CONTRACT SUPPORT

Actions Needed to Enhance Capabilities in the Pacific 

Region

What GAO Found

U.S. Pacific Command (PACOM) does not fully account for contractor personnel 

in a steady-state, or peacetime, environment and lacks a process to vet foreign 

vendors. Department of Defense (DOD) guidance requires the accounting of 

certain contractor personnel during contingency operations, but is unclear for 

steady-state environments. PACOM issued limited guidance in November 2016 

to address accountability processes in contingency and steady-state

environments, and PACOM and some of its components use multiple 

mechanisms to account for contractor personnel, resulting in inconsistencies in

the numbers of contractor personnel accounted for, which could present 

difficulties in an emergency or contingency operation. Additionally, PACOM lacks 

a foreign vendor vetting process due to a lack of DOD guidance identifying what 

vendor vetting processes should be established at combatant commands. 

PACOM has taken some action on vendor vetting, such as including vetting in 

exercises and screening some contractor personnel, but it lacks a process that 

includes details, such as under what circumstances a vetting cell should be 

established. DOD guidance specifying under what circumstances a vetting cell 

should be established would better position PACOM to avoid contracting with the 

enemy in high-threat areas.

PACOM established an interim operational contract support (OCS) 

organizational structure through a pilot program that ends in June 2017. PACOM 

officials stated that, upon completion of the pilot, they intend to establish the 

structure as an enduring OCS capability within the command’s logistics 

directorate. The intent is to provide the combatant command, subordinate unified 

commands, and service components a central entity to integrate OCS across 

joint functions, such as directorates dealing with personnel or intelligence. 

However, service component officials stated that PACOM’s OCS organizational 

structure might have been more effective if it engaged all joint staff functions, 

including directorates beyond logistics. DOD, Joint Staff, and PACOM guidance 

identify the important role that directorates beyond logistics should play as 

stakeholders in OCS. Similarly, GAO has previously reported on the challenges 

DOD has faced integrating OCS in functional areas beyond logistics. By 

considering ways to expand its OCS organizational structure beyond the logistics 

directorate and better integrate the equities of other directorates, PACOM could 

be better positioned to build on the progress made during the pilot program.

PACOM has integrated OCS into key planning documents, as required by 

guidance, by developing OCS annexes for 6 of its 11 operational, concept, and 

campaign plans. Officials added that they will continue to update the remaining 

plans as planning cycles and resources allow. However, the annex appendixes 

generally lack key details, such as contractor management and support 

estimates. PACOM officials told GAO that such details are determined through 

requirements development at the service component commands, but challenges 

exist related to these issues due to unclear guidance. Without guidance that 

clarifies the requirements-development process for OCS annexes, PACOM will 

continue to lack important details that are needed to determine OCS 

requirements for operations. View GAO-17-428. For more information, 

contact Cary Russell at (202) 512-5431 or 

russellc@gao.gov. 

Why GAO Did This Study

A key element of DOD military strategy 

since 2012 has been a rebalance of 

U.S. presence and capabilities toward 

the Asia-Pacific region, PACOM’s area 

of responsibility. U.S. military 

personnel in this region rely on 

contracted services to provide support 

to military operations. PACOM’s 

humanitarian and disaster-relief efforts 

in response to a May 2015 earthquake 

in Nepal highlighted the importance of 

OCS in the Asia-Pacific region. 

GAO was asked to assess PACOM’s 

processes to plan for, manage, and 

oversee contractors that support 

military operations in the Asia-Pacific 

region. This report assesses the extent 

to which PACOM (1) has accounted for 

contractor personnel and has a 

process to vet foreign vendors; (2) has 

established an organizational structure 

to manage and oversee OCS; and (3) 

has integrated OCS into key planning 

documents. GAO reviewed documents 

and data, interviewed relevant officials 

involved in OCS activities in the region, 

and analyzed OCS annexes to certain 

plans.

What GAO Recommends

GAO is making six recommendations,

including that DOD and PACOM 

develop or update guidance related to 

contractor personnel accountability,

vendor vetting, and OCS

organizational structure; and that

PACOM develop guidance that clarifies

requirements development for plans. 

DOD concurred with two 

recommendations and partially

concurred with four. GAO continues to 

believe the recommendations are valid, 

as discussed in the report.
Page i GAO-17-428 Operational Contract Support

Letter 1

Background 4

PACOM Does Not Fully Account for Contractor Personnel in a 

Steady-State Environment and Does Not Have a Process to Vet 

Foreign Vendors 9

PACOM Established an Interim Organizational Structure to 

Manage and Oversee OCS, but the Future Organizational 

Structure Is Focused in the Logistics Directorate 18

PACOM Has Integrated OCS Annexes into Operational and 

Concept Plans, but the Information Lacks Details on Contractor 

Management and Support Estimates 23

Conclusions 26

Recommendations for Executive Action 27

Agency Comments and Our Evaluation 28

Appendix I Objectives, Scope, and Methodology 33

Appendix II Operational Contract Support Features and Practices Included 

in U.S. Pacific Command Exercises 38

Appendix III Comments from the Department of Defense 41

Appendix IV GAO Contact and Staff Acknowledgments 45

Related GAO Products 46

Table

Table 1: Operational Contract Support Features and Practices 

Included in U.S. Pacific Command Exercises 2015–2016 38

Contents
Page ii GAO-17-428 Operational Contract Support

Figures

Figure 1: Operational Contract Support Functions and Associated 

Tasks 5

Figure 2: Operational Contract Support Integration Cell’s Staff 

Integration Function within a Command 20

Abbreviations

DOD Department of Defense

JCASO Joint Contingency Acquisition Support Office

OCS operational contract support

OSD Office of the Secretary of Defense

PACOM U.S. Pacific Command

SPOT Synchronized Predeployment and Operational Tracker

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Page 1 GAO-17-428 Operational Contract Support

441 G St. N.W.

Washington, DC 20548

June 23, 2017

The Honorable Robert Wittman

Chairman

The Honorable Madeleine Z. Bordallo

Ranking Member

Subcommittee on Readiness

Committee on Armed Services

House of Representatives

A key element of Department of Defense (DOD) military strategy since 

2012 has been a rebalance of U.S presence and capabilities toward the 

Asia-Pacific region, U.S. Pacific Command’s (PACOM) area of 

responsibility. U.S. military personnel have deployed to locations within 

this region, where they rely on a variety of contracted services to provide 

needed support to conduct military operations, including exercises, 

humanitarian responses, and contingency operations. DOD describes the 

process of planning for and obtaining supplies, services, and construction 

from commercial sources in support of joint operations as operational 

contract support (OCS).1 One example that highlights the importance of 

OCS in the Asia-Pacific region is PACOM’s foreign humanitarian 

assistance efforts in response to the May 2015 earthquake in Nepal. As 

part of that effort, PACOM established a joint task force that provided 

aviation capabilities to enable delivery of relief supplies and executed 

OCS to provide logistical support to deployed U.S. forces.

According to data from the Federal Procurement Data System–Next 

Generation, DOD obligated more than $40 billion between fiscal years 

2011 and 2015 within PACOM’s area of responsibility, including for 

contracts supporting deployed forces.2 DOD joint doctrine projects that 

the continual introduction of high-tech equipment, combined with military 

 1

Joint Chiefs of Staff, Joint Pub. 4-10, Operational Contract Support, at GL-8 (July 16, 

2014) (hereafter cited as Joint Pub. 4-10 (July 16, 2014). DOD regulation defines OCS as 

the ability to orchestrate and synchronize the provision of integrated contract support and 

management of contractor personnel providing support to the joint force within a 

designated operational area. 32 C.F.R. § 158.3; Department of Defense Instruction 

3020.41, Operational Contract Support (OCS), at 49 (Dec. 20, 2011) (hereafter cited as 

DODI 3020.41 [Dec. 20, 2011]).

2

Federal Procurement Data System–Next Generation provides agencies with a 

comprehensive web-based tool to report contract actions. 

Letter
Page 2 GAO-17-428 Operational Contract Support

force structure reductions, mission-specific force cap restrictions, and 

high operating tempo means that contract support will continue to be 

relied upon to augment military forces in most operations.3 A growing 

reliance on contractors to provide logistical, transportation, intelligence, 

and other support to the combatant command’s missions in this region 

requires advanced planning, rapid response, flexible procedures, and 

integration of efforts.

Since 2010, we have reported on challenges DOD has experienced in 

managing OCS and made recommendations to strengthen its efforts in 

this area, including incorporating OCS into planning, ensuring 

accountability for contractor personnel, and properly vetting contractors 

and contractor employees.4 For example, in March 2010 we 

recommended that DOD incorporate the potential need for contractor 

support into plans for military operations and that it include assumptions 

about the use and role of contractors. In February 2013 we recommended 

that the Joint Staff provide training for OCS planners and, in March 2015, 

we recommended that DOD revise existing guidance and the services 

issue service-wide guidance related to collecting OCS lessons learned. 

Most recently, in December 2015 we recommended that DOD clarify 

guidance on contractor accountability and issue department-wide 

guidance on foreign vendor vetting. DOD generally concurred with these 

recommendations and, in response, has issued and updated DOD and 

Joint Staff OCS guidance related to OCS roles and responsibilities, 

planning for OCS requirements, ensuring accountability of contractors 

authorized to accompany the force, and implementing OCS within the 

combatant commands’ area of responsibility.5

You asked us to review the processes PACOM uses to plan for, manage, 

and oversee contractors that support military operations in the AsiaPacific region. This report addresses the extent to which PACOM has: (1) 

 3

Joint Pub. 4-10, at I-1 (July 16, 2014). 

4

GAO, Operational Contract Support: Additional Actions Needed to Manage, Account for, 

and Vet Defense Contractors in Africa, GAO-16-105 (Washington, D.C.: Dec. 17, 2015);

Warfighter Support: DOD Needs Additional Steps to Fully Integrate Operational Contract 

Support into Contingency Planning, GAO-13-212 (Washington, D.C.: Feb. 8, 2013); 

Operational Contract Support: Sustained DOD Leadership Needed to Better Prepare for 

Future Contingencies, GAO-12-1026T (Washington, D.C.: Sept. 12, 2012); Warfighter 

Support: DOD Needs to Improve Its Planning for Using Contractors to Support Future 

Military Operations, GAO-10-472 (Mar. 30, 2010). 

5

32 C.F.R. pt. 158; DODI 3020.41 (Dec. 20, 2011); Joint Pub. 4-10 (July 16, 2014).
Page 3 GAO-17-428 Operational Contract Support

accounted for contractor personnel and has a process to vet foreign 

vendors in its area of responsibility, (2) established an organizational 

structure to manage and oversee OCS, and (3) integrated OCS into key 

planning documents.

To determine the extent to which PACOM accounts for contractor 

personnel and has a process to vet foreign vendors in its area of 

responsibility, we reviewed and analyzed DOD and PACOM guidance as 

well as the Defense Federal Acquisition Regulation Supplement and other 

guidance on requirements for the use of contractors. We collected and 

analyzed data from 2015 and 2016 on the use of contractors, and 

assessed the reliability of the data by interviewing knowledgeable officials 

about the data and the steps that they had taken to verify the data’s 

accuracy. We determined that the data were sufficiently reliable, and 

compared the data to criteria related to contractor personnel 

accountability found in DOD guidance and federal regulations, and 

interviewed key officials at various organizational levels.6 We reviewed 

guidance and documentation and interviewed officials to determine the 

processes in place to vet non-U.S. contractors and their employees, 

including requirements and screenings.

To determine the extent to which PACOM has established an 

organizational structure to manage and oversee OCS, we reviewed and 

analyzed key criteria related to OCS roles and responsibilities found in 

DOD, PACOM, and other guidance and compared them to the OCS 

organizational structure at PACOM and its subordinate commands, and 

interviewed relevant officials.7 Finally, to determine the extent to which 

PACOM has integrated OCS into key planning documents, we reviewed 

and analyzed planning criteria found in DOD and PACOM guidance, and 

compared them to PACOM planning documents, including the OCS 

annex in the theater campaign plan and select operation and contingency 

 6

DODI 3020.41 (Dec. 20, 2011); Joint Pub. 4-10 (July 16, 2014); 32 C.F.R. pt. 158; 

PACOM Instruction 0601.7, Operational Contract Support (Aug. 21, 2012). 

7

DODI 3020.41 (Dec. 20, 2011); Joint Pub. 4-10 (July 16, 2014); PACOM Instruction 

0601.7, Operational Contract Support (Aug. 21, 2012).
Page 4 GAO-17-428 Operational Contract Support

plans.8 For a more detailed discussion on our objectives, scope, and 

methodology, see appendix I.

We conducted this performance audit from December 2015 to June 2017 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The Commander of U.S. Pacific Command (PACOM) is the primary U.S. 

military authority in the Pacific area of responsibility. PACOM’s area of 

responsibility spans approximately half the earth’s surface and 

encompasses 36 countries, including Australia, China, India, Japan, the 

Philippines, and South Korea.9 PACOM is supported by four service 

component commands: U.S. Army Pacific; U.S. Pacific Air Forces; U.S. 

Marine Forces, Pacific, and the U.S. Pacific Fleet. Each component 

command is generally responsible for its service’s actions and missions 

within the PACOM area of responsibility. In addition, PACOM has two 

subordinate unified commands, which help support the combatant 

command’s presence in the region. In Japan, U.S. Forces Japan supports 

U.S. forward presence and ensures bilateral defense cooperation with the 

government of Japan. In Korea, U.S. Forces Korea coordinates U.S. 

military operations and activities in South Korea.

 8

DODI 3020.41 (Dec. 20, 2011); Joint Pub. 4-10 (July 16, 2014); Chairman of the Joint 

Chiefs of Staff Manual 3130.03, Adaptive Planning and Execution (APEX) Planning 

Formats and Guidance (Oct. 18, 2012); PACOM Instruction 0601.7, Operational Contract 

Support (Aug. 21, 2012).

9

A combatant command is a unified or specified command with a broad continuing mission 

under a single commander established and so designated by the President, through the 

Secretary of Defense and with the advice and assistance of the Chairman of the Joint 

Chiefs of Staff. DOD has six geographic combatant commands responsible for missions in 

specific areas of the world: U.S. Africa Command, U.S. Central Command, U.S. European 

Command, U.S. Northern Command, U.S. Pacific Command, and U.S. Southern 

Command.

Background
Page 5 GAO-17-428 Operational Contract Support

DOD describes OCS as the process of planning for and obtaining 

supplies, services, and construction from commercial sources in support 

of joint operations.10 OCS encompasses three functions: contract support 

integration, contracting support, and contractor management.11 These 

functions and their associated tasks are described in figure 1.

Figure 1: Operational Contract Support Functions and Associated Tasks

Determining OCS requirements, as well as conducting the initial planning 

for and coordination of these tasks, is primarily an operational, versus a 

contracting, function. As a result, and according to joint doctrine, all of the 

directorates within a command have OCS roles or responsibilities.12 The 

2014 update to Joint Publication 4-10 introduced the concept of an OCS 

Integration Cell as a central coordination point that can, among other 

 10Joint Pub. 4-10, at GL-8 (July 16, 2014).

11In the context of OCS, “contractor management” refers to the oversight and integration of 

contractor personnel and associated equipment providing support to the joint force in a 

designated operational area. 32 C.F.R. § 158.3; Joint Pub. 4-10, at I-3 (July 16, 2014). 

12See, e.g., Joint Pub. 4-10, at III-3 to III-5 (July 16, 2014). 

OCS Functions, Roles, 

and Responsibilities
Page 6 GAO-17-428 Operational Contract Support

things, provide staff integration by assisting and advising the directorates 

on these issues.

The Defense Logistics Agency’s Joint Contingency Acquisition Support 

Office provides support to combatant command OCS planning efforts and 

training events, and, when requested, advises, assists, and supports joint 

force command oversight of OCS operations. Additionally, the Joint 

Contingency Acquisition Support Office provides the combatant 

commander joint OCS planners embedded within the combatant 

command staff, including as part of their OCS Integration Cells.

The department uses contingency planning to develop its operation plans, 

which describe how DOD will respond to a potential event that might 

require the use of military force, such as terrorism, hostile foreign nations, 

and natural disasters. An operation plan generally consists of a base plan 

and annexes. The base plan describes the concept of operations, major 

forces, sustainment concept, and anticipated timelines for completing the 

mission. The annexes of an operational plan provide further details on 

areas such as logistics (Annex D), personnel (Annex E), and OCS (Annex 

W). Chairman of the Joint Chiefs of Staff Manual 3130.03, Adaptive 

Planning and Execution (APEX) Planning Formats and Guidance, 

provides more detailed guidance on the format of plans, including 

templates for the base plan and annexes.13

As described in Joint Publication 5-0, Joint Operation Planning, the 

framework for military operational planning generally encompasses six 

phases, ranging from Phase 0 to Phase V.14 Phases are distinct in time, 

space, or purpose from one another. According to Joint Publication 5-0, 

Phase 0 or steady-state operations encompass normal and routine 

military activities performed to dissuade or deter potential adversaries and 

to assure or solidify relationships with allies. In general, terms such as 

steady-state operations, steady-state environment, and Phase 0 are used 

in reference to peacetime operations or to denote the absence of a 

declared contingency operation. Phases I through V generally involve the 

demonstration and use of military forces to deter an adversary, seize the 

 13Chairman of the Joint Chiefs of Staff Manual 3130.03, Adaptive Planning and Execution 

(APEX) Planning Formats and Guidance (Oct. 18, 2012). 

14See, e.g., Joint Chiefs of Staff, Joint Pub. 5-0, Joint Operation Planning, at III-41 to III-44 

(Aug. 11, 2011).

OCS in Combatant 

Command Planning for 

Contingencies
Page 7 GAO-17-428 Operational Contract Support

initiative, dominate the adversary, participate in stability operations

subsequent to combat operations, and support civil authorities, 

respectively.

Personnel accountability is the general process by which commanders 

identify, capture, and record information about the number and type of 

personnel, including contractor personnel, in their area of operations.15 To 

help commanders improve their ability to account for contractor personnel 

(which may include U.S. citizen, third-country, and local national 

personnel, depending on the circumstances), DOD uses a database—

Synchronized Predeployment and Operational Tracker (SPOT)—to serve 

as the department’s central repository for contractor personnel 

accountability data in contingency operations. Specifically, SPOT assists 

the combatant commander in ensuring that accountability, visibility, force 

protection, medical support, personnel recovery, and other related 

support can be accurately forecasted and provided for the contractor 

personnel in the command’s area of responsibility. When specified by 

contract, vendors are responsible for inputting and maintaining their 

employees’ personnel data in SPOT throughout the employees’ periods 

of performance.

Personnel accountability is also conducted by means of the Joint 

Personnel Status Report database. According to PACOM guidance, 

PACOM headquarters and subordinate activities are to report the total 

number of DOD-affiliated personnel assigned to PACOM (inclusive of all 

applicable active-duty service members, selected reservists, DOD civilian 

employees, and DOD contractors [excluding foreign nationals]), as well 

as other DOD personnel physically present in the PACOM area of 

responsibility.16 Personnel status reports are to be submitted weekly. This 

information, along with SPOT and service-specific accountability systems, 

typically feed information into DOD’s primary accountability system—Joint 

Personnel Accountability Reconciliation and Reporting—to produce joint 

personnel status reports, which include military, civilian, and contractor 

employees.

 15GAO-16-105.

16See PACOM Instruction 0250.1, Personnel Accountability, Visibility, and Strength 

Reporting in the United States Pacific Command (USPACOM) Area of Responsibility 

(AOR), paras. 1.2, 3.2 (Nov. 10, 2016).

Contractor Personnel 

Accountability
Page 8 GAO-17-428 Operational Contract Support

Vendor vetting and contractor employee screening are processes by 

which DOD conducts intelligence-based threat mitigation to minimize 

operational risks potentially posed by contracted companies and their 

employees.

Vendor Vetting: DOD contracting officers are required to check 

prospective contractors’ names against a list of prohibited, restricted, or 

otherwise ineligible entities in a U.S. government contracting database 

called the System for Award Management.17 The database contains a list 

of sanctioned and other prohibited entities identified by the Department of 

the Treasury, Department of State, DOD, and other U.S. agencies. 

Additionally, Joint Staff guidance discusses the establishment of a 

foreign-vendor vetting cell within a combatant command to vet selected 

local national and third-country national companies to prevent DOD from 

awarding contracts to companies having ties to insurgents or other 

inappropriate entities.18 Generally, such vetting consists of researching 

the principal owners and connections of the company using information 

provided by owners and then cross-checking this information against 

various intelligence sources.

Contractor Employee Screening: According to joint doctrine, 

subordinate and individual base commanders are responsible for the 

security of military facilities within the combatant commander’s area of 

responsibility. Joint doctrine notes that part of this process is the 

screening and badging of contractor personnel who are authorized to 

have base access.19 A contractor employee screening process can 

mitigate the potential security risk that third-country and local national 

contractor personnel may pose when they have access to DOD facilities.

 17See Class Deviation 2015-O0016, Prohibition on Providing Funds to the Enemy and 

Authorization of Additional Access to Records, attachment 3 (Sept. 15, 2015); 48 C.F.R. 

(FAR) § 9.405(d).

18See Joint Pub. 4-10, at III-27 to III-28 (July 16, 2014).

19Joint Pub. 4-10, at V-25 (July 16, 2014).

Vendor Vetting and 

Contractor Employee 

Screening
Page 9 GAO-17-428 Operational Contract Support

PACOM does not fully account for contractor personnel in a steady-state 

environment, and does not have a process to vet foreign vendors. DOD 

guidance requires accountability for certain contractor personnel during 

contingency operations, but contractor accountability guidance in steadystate environments is unclear. In the absence of clear guidance from 

DOD, PACOM has used multiple mechanisms for contractor personnel 

accountability, which has resulted in inconsistent reporting. PACOM 

subsequently issued accountability guidance in November 2016, but it is 

limited in that it excludes foreign-national contractors. Additionally, 

PACOM does not have a process in place to vet foreign vendors in 

contingency operations due to a lack of DOD guidance that clarifies what 

foreign-vendor vetting steps or process should be established at each 

combatant command.

DOD guidance provides procedures for identifying, capturing, and 

recording information about certain contractor personnel in combatant 

command areas of operation during applicable contingency operations 

outside the United States.20 For example:

• DOD Instruction 3020.41 states contractor visibility and accountability 

shall be maintained in applicable contingency operations through a 

common joint database, SPOT, or its successor.21

• Joint Publication 4-10 states that DOD policy requires accountability 

of all contractors authorized to accompany the force, as well as other 

contractor employees designated by the Office of the Secretary of 

Defense (OSD) or combatant commander, in SPOT. It notes that 

contractor personnel visibility and accountability are essential to 

determine and resource government support requirements in 

uncertain, hostile, or austere operational environments, and that 

 20See e.g., DODI 3020.41, encl. 2, para. 3.c (Dec. 20, 2011). The DOD guidance applies 

to contingency, humanitarian assistance, and other peace operations outside the United 

States, as well as other military operations as determined by a combatant commander or 

as directed by DOD, collectively referred to as “applicable contingency operations” in the 

guidance. Id. para. 2.b.

21DODI 3020.41, para. 4.e (Dec. 20, 2011); see also id. encl. 2, para. 3.c(2); 32 C.F.R. §§ 

158.4(e), 158.6(c)(3)(ii).

PACOM Does Not 

Fully Account for 

Contractor Personnel 

in a Steady-State 

Environment and 

Does Not Have a 

Process to Vet 

Foreign Vendors

DOD Guidance Requires 

Accountability for Certain 

Contractor Personnel 

during Contingencies, but 

the Accountability Is 

Unclear for Steady-State 

Environments
Page 10 GAO-17-428 Operational Contract Support

accountability of contractor personnel may be a critical information 

requirement for commanders in some operations.22

• A Defense Federal Acquisition Regulation Supplement clause, to be 

used in certain contracts, requires the contractor to use SPOT to enter 

and maintain data for all contractors authorized to accompany the 

force and, as designated, other contractor employees supporting U.S. 

armed forces deployed outside the United States in applicable 

operations, including contingency operations, or other designated 

military operations or exercises.23

In addition, PACOM has issued guidance regarding contractor personnel 

accountability during contingencies. For example, PACOM Instruction 

0601.7 indicates that personnel-directorate officials are to provide status 

reports via SPOT for contractors authorized to accompany the force.24

Similarly, PACOM Instruction 0250.1 states that subordinate commands 

are to implement the use of SPOT for the tracking and accountability of 

contractors authorized to accompany the force, as directed by PACOM 

headquarters.25

Both Chairman of the Joint Chiefs of Staff and PACOM guidance on 

personnel accountability call for the use of Joint Personnel Status 

Reports, which are meant, in part, to authenticate the total number of 

 22Joint Pub. 4-10, at V-18 (July 16, 2014). Contractor personnel who are authorized to 

accompany the force in applicable contingency operations outside the United States and 

have been afforded that status through letters of authorization are referred to as 

“contractors authorized to accompany the force.” These contractor personnel generally 

include all U.S. citizen and third-country national employees not normally residing within 

the operational area whose area of performance is in the direct vicinity of U.S. forces and 

who are routinely colocated with U.S. forces. In some cases, commanders may designate 

mission-essential host-nation or local national contractor employees, such as interpreters, 

as contractors authorized to accompany the force. DODI 3020.41, at 47 (Dec. 20, 2011); 

32 C.F.R. § 158.3.

2348 C.F.R. Defense Federal Acquisition Regulation Supplement (DFARS) 252.225-

7040(g)(1) (Oct. 2015); see also DFARS § 225.371-5(a) (requiring use of the clause for 

solicitations and contracts with performance in a designated operational area that 

authorize contractor personnel to support U.S. armed forces deployed outside the United 

States in contingency operations, peace operations, or other designated military 

operations or exercises). 

24PACOM Instruction 0601.7, Operational Contract Support, para. 10.a(1) (Aug. 21, 2012) 

(listing the responsibility among the recommended planning considerations for OCS).

25PACOM Instruction 0250.1, Personnel Accountability, Visibility, and Strength Reporting 

in the United States Pacific Command (USPACOM) Area of Responsibility (AOR), para. 

2.2.g (Nov. 10, 2016). 
Page 11 GAO-17-428 Operational Contract Support

personnel, including military, DOD civilian, and DOD contractor 

personnel, who are physically present in a geographic combatant 

commander’s area of responsibility.26 According to PACOM guidance, 

PACOM headquarters and subordinate activities are to report on a weekly 

basis via joint personnel status reports the total number of DOD-affiliated 

personnel assigned to PACOM (inclusive of all applicable active-duty 

service members, selected reservists, DOD civilian employees, and DOD 

contractors [excluding foreign nationals]), as well as DOD personnel 

physically present in the PACOM area of responsibility.27

Although the Joint Staff updated Joint Publication 1-0 in May 2016 to 

clarify, among other things, accountability of DOD contractor personnel 

overseas, it does not clearly specify the types of contractor personnel 

(U.S., third-country national, or local national) that are to be accounted for 

in a steady-state environment.28 We have previously reported that DOD 

guidance is unclear with regard to the types of contractor personnel that 

should be accounted for in a steady-state environment. For example, as 

we reported in 2015, the Joint Staff guidance is unclear as to what types 

of contractor personnel should be accounted for in the Joint Personnel 

Status Report.29 Specifically, we found confusion among U.S. Africa 

Command officials regarding the types of contractor personnel—including 

U.S., local national, host-nation, and third-country nationals—to be 

included in the joint personnel status report as compared with SPOT, as 

well as unclear guidance regarding the relationship between information 

in SPOT and reporting through the Joint Personnel Status Report. 

 26Chairman of the Joint Chiefs of Staff Manual 3150.13C, Joint Reporting Structure –

Personnel Manual, encl. A, para. 1 (Mar. 10, 2010) (current as of Nov. 6, 2012).

27PACOM Instruction 0250.1, Personnel Accountability, Visibility, and Strength Reporting 

in the United States Pacific Command (USPACOM) Area of Responsibility (AOR), paras. 

1.2.a, 3.2.a, 3.2.d (Nov. 10, 2016).

28Joint Chiefs of Staff, Joint Pub. 1-0, Joint Personnel Support (May 31, 2016). Although 

Joint Publication 1-0 discusses visibility of contractors authorized to accompany the force 

(CAAF), that category of contractor personnel is generally associated with OCS and 

generally includes U.S. citizen and third-country national employees not normally residing 

in the operational area, whose area of performance is in the direct vicinity of U.S. forces, 

and who routinely are colocated with U.S. forces. See, e.g., Joint Pub. 1-0, at III-5 (May 

31, 2016); DODI 3020.41, at 47 (Dec. 20, 2011) (defining CAAF).

29See GAO-16-105 for a discussion of the specificity in the guidance regarding the types of 

contractor personnel to be included in SPOT as compared with the joint personnel status 

report, as well as unclear guidance regarding the relationship between information in 

SPOT and reporting through the Joint Personnel Status Report.
Page 12 GAO-17-428 Operational Contract Support

Similarly, during this engagement, PACOM personnel-directorate officials 

told us they report the total number of DOD-affiliated personnel assigned 

to PACOM by means of the Joint Personnel Status Report database, as 

required by PACOM guidance. As part of this process, officials told us 

they account for some contractor personnel. Specifically, they account for 

contractors authorized to accompany the force, but they do not report 

numbers on third-country nationals or local nationals.

DOD officials responsible for OCS issues stated in May 2017 that, when 

requested by combatant commands, they have facilitated the use of 

SPOT in Phase 0 or steady-state environments to capture accountability 

data on all types of contractor personnel (U.S., third-country national, and 

local national).30 Hence, the commanders of U.S. Africa Command and 

U.S. Southern Command identified the need to use SPOT in steady-state 

environments, even though that is not currently required under DOD 

guidance. To support these efforts, DOD issued guidance for the use of 

clauses in solicitations and contracts with performance in these 

combatant command areas of responsibility, which require contractors to 

use SPOT to enter and maintain data for certain contractor personnel.31

However, without guidance clarifying the types of contractor personnel to 

be accounted for in a steady-state environment, DOD may continue to 

have limited visibility over contractor personnel for whom it may be 

responsible in the event of a contingency operation or an emergency.

 30 According to Joint Publication 5-0, Phase 0 or steady-state operations encompass 

normal and routine military activities performed to dissuade or deter potential adversaries 

and to assure or solidify relationships with allies. In general, terms such as steady-state 

operations, steady-state environment, and Phase 0 are used in reference to peacetime 

operations or to denote the absence of a declared contingency operation.

31See Class Deviation 2014-O0016, Requirements for Contractor Personnel Performing in 

the U.S. Southern Command Area of Responsibility (Oct. 6, 2014) (requiring use of clause 

252.225-7987 when DFARS clause 252.225-7040 does not apply); Class Deviation 2016-

O0008, Contractor Personnel Performing in the United States Africa Command Area of 

Responsibility (June 10, 2016) (requiring use of clause 252.225-7980 in lieu of DFARS 

clause 252.225-7040).
Page 13 GAO-17-428 Operational Contract Support

PACOM and some of its components use multiple mechanisms to 

account for contractor personnel in a steady-state environment.32 For 

example, although PACOM headquarters officials stated they do not use 

SPOT to track contractor personnel in a steady-state environment, we 

determined that some PACOM contractor personnel were accounted for 

in SPOT. According to data obtained from the SPOT Program Office, in 

September 2016 approximately 1,400 contractor personnel in the 

PACOM area of responsibility were recorded in SPOT. Four hundred of 

these contractor personnel were third-country nationals or local nationals 

who would not be required to be reported in PACOM’s Joint Personnel 

Status Reports based on its accountability guidance. We also found that 

some PACOM service components and subordinate unified commands 

use their own accountability systems—as well as SPOT—to account for 

contractor personnel. Further, the collected data included third-country 

and local national contractor personnel, information that similarly would 

not be required to be reported in Joint Personnel Status Reports.

The use of multiple mechanisms to account for various types of contractor 

personnel have in some cases resulted in inconsistent and incomplete 

outcomes regarding the total numbers of contractor personnel accounted 

for in a steady-state environment. For example:

• U.S. Forces Japan collects data on personnel who are full-time 

contract employees permitted to be in Japan in accordance with the 

terms of the Status of Forces Agreement between the two nations. 

However, the number of contractor personnel accounted for by U.S. 

Forces Japan in the first quarter of fiscal year 2016 (1,485) was not 

consistent with the number of contractor personnel reported in SPOT 

(approximately 900).

• III Marine Expeditionary Force on Okinawa relies on three information 

systems, including SPOT, to account for contractors and contractor 

personnel in a steady-state environment, but the numbers found in 

these systems are inconsistent. Specifically, the number of contractor 

personnel accounted for by III Marine Expeditionary Force as of June 

2016 (approximately 500) was not consistent with the number of 

contractor personnel in SPOT for the area of responsibility 

(approximately 700).

 32PACOM is currently in a steady-state environment. 

PACOM Uses Multiple 

Mechanisms to Account 

for Contractor Personnel, 

Which Has Resulted in 

Inconsistent Reporting
Page 14 GAO-17-428 Operational Contract Support

• U.S. Forces Korea officials provided a detailed accounting of 

contractor personnel, specifying the number of individuals by 

geographic area and the number of dependents, and stated that the 

detail was a result of the Invited Contractor / Technical Representative 

Program that governs U.S. Forces Korea use of U.S. or third-country 

contractors. However, the number of contractor personnel accounted 

for by the Invited Contractor Program in Korea in July 2016 (2,527 

U.S. contractor personnel) was not consistent with the number of 

contractor personnel in SPOT for the area of responsibility 

(approximately 300).

Such inconsistencies regarding contractor personnel accountability in a 

steady-state environment could present difficulties in an emergency or 

contingency operation. Joint Publication 4-10 notes that steady-state 

activities can have a significant impact on OCS in later phases of the 

operation, and, consequently, OCS planners should be aware of and pay 

close attention to steady-state activities that can provide critical 

information to support subsequent phases of an operation.33 Similarly, in 

2015, we reported that if DOD does not have timely and reliable contract 

and contractor personnel data, the department will not have complete 

visibility as to whom it may have to develop plans for, regarding such 

services as force protection, sustenance, and repatriation of injured or 

deceased contractor personnel.34

Without PACOM guidance clarifying the types of contractor personnel that 

should be accounted for in a steady-state environment, PACOM and its 

subordinate commands may continue to have limited visibility over 

contractor personnel. Similarly, without the development and 

implementation of guidance specifying a system of record, such as 

SPOT, for the collection of this information during a steady-state 

environment, PACOM may not have a comprehensive and consistent 

accounting of contractor personnel in its area of responsibility, which 

could potentially limit PACOM’s visibility over contractor personnel for 

whom it may be responsible in the event of a contingency operation or an 

emergency.

In an attempt to clarify accountability guidance, PACOM issued additional 

guidance in November 2016. Among other things, the guidance requires 

 33Joint Pub. 4-10, at I-10 (July 16, 2014).

34GAO, Contingency Contracting: Contractor Personnel Tracking System Needs Better 

Plans and Guidance, GAO-15-250 (Washington, D.C.: Feb. 18, 2015).
Page 15 GAO-17-428 Operational Contract Support

PACOM activities to report some contractor personnel by means of joint 

personnel status reporting and directs subordinate commands to 

implement SPOT as directed by PACOM headquarters. However, the 

guidance excludes foreign nationals from the contractor personnel to be 

reported via the Joint Personnel Status Report database. In addition, it 

does not specify a system of record to be used for all contractor 

personnel in steady-state environments.

DOD guidance generally discusses the benefits of vendor vetting in the 

OCS context, but does not require combatant commands to establish 

vendor vetting processes. For example, Joint Publication 4-10 discusses 

the benefit of establishing a vendor vetting cell, when circumstances 

warrant, to vet foreign vendors for possible security concerns and avoid 

awarding contracts to companies that have ties to insurgents.35 Similarly, 

in 2011, we reported on the importance of establishing vendor vetting 

processes to help mitigate the risk that malign actors could profit from 

U.S. government contracts in the context of contracting with local vendors 

during operations in Afghanistan.36

PACOM headquarters officials stated that the combatant command is 

aware of the importance of foreign-vendor vetting, but, in the absence of 

specific requirements from DOD, the command does not have a 

documented vendor vetting mechanism, such as a vendor vetting cell or 

other process by which to vet vendors. PACOM headquarters intelligence 

officials stated that they may occasionally receive requests to assist with 

vetting of a specific vendor from other headquarters directorates or 

supporting commands. Officials noted that in those cases, PACOM’s 

intelligence directorate—the joint directorate identified in Joint Publication 

4-10 as having key OCS duties related to vendor vetting—responds to the 

request by relying on the standing vendor vetting cell within U.S. 

Transportation Command to evaluate the level of operational risk posed 

by contracting with a commercial vendor. Officials noted that U.S. 

Transportation Command’s vendor vetting cell has served as a resource 

for other combatant commands in lieu of establishing their own 

corresponding cell. However, OSD officials stated that the cell at U.S. 

 35See Joint Pub. 4-10, at III-27 to III-28 (July 16, 2014).

36GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Need Improvement, 

GAO-11-135 (Washington, D.C.: June 8, 2011). 

PACOM Does Not 

Systematically Vet Foreign 

Vendors or Have a Vendor 

Vetting Process in Place
Page 16 GAO-17-428 Operational Contract Support

Transportation Command could be overwhelmed if the number of vetting 

requests from other combatant commands continues to rise.

Officials at PACOM headquarters and subordinate commands have taken 

several additional actions regarding vendor vetting, including 

incorporating vendor vetting into PACOM exercises and screening 

contractor personnel through background checks and badging processes.

Additionally, PACOM has developed antiterrorism guidance with vendor 

vetting considerations. However, while the antiterrorism guidance 

presents a checklist of questions for evaluating how contracting aligns 

with the command’s overall antiterrorism program, it does not discuss the 

operational conditions under which a foreign-vendor vetting cell would be 

established or outline a process for conducting comprehensive foreignvendor vetting through a cell at the command or leverage an existing cell 

at another command.

From a department-wide perspective, DOD has begun to take steps to 

identify foreign-vendor vetting needs. According to the OCS Action Plan 

for Fiscal Years 2017–2020—the DOD document that assigns tasks to 

various stakeholders to operationalize OCS—foreign-vendor vetting is 

becoming increasingly important. OSD officials who developed the action 

plan added that the department is trying to determine how foreign-vendor 

vetting relates to and affects OCS. To this end, DOD established a 

foreign-vendor vetting working group in January 2017 to, among other 

things, define foreign-vendor vetting as a distinct function and provide 

combatant commanders with guidance on addressing the risks 

associated with relying on commercial vendors. According to officials, this 

working group is in its infancy, and DOD decision makers are still 

exploring which entities should be key stakeholders to vendor vetting, 

including which entity should have primary responsibility for vendor 

vetting.

Furthermore, officials indicated DOD is currently inclined to examine 

solutions that can address vendor vetting issues globally rather than 

requiring geographic combatant commands to establish their own vendor 

vetting cells. Additionally, according to OSD officials, the Office of the 

Under Secretary of Defense for Acquisition, Technology and Logistics 

drafted a directive-type memorandum related to the collection of 

intelligence-based vendor threat information through a mechanism such 

as a foreign-vendor vetting entity or cell in order to mitigate operational 

risk. Officials stated, however, that this memorandum will not be finalized 
Page 17 GAO-17-428 Operational Contract Support

until after the vendor vetting working group has collected more 

information to determine the best way forward.

In lieu of comprehensive department-wide guidance on vendor vetting, 

two other combatant commands—U.S. Africa Command and U.S. Central 

Command—have developed their own foreign-vendor vetting guidance. 

Specifically, we reported in 2015 that U.S. Africa Command had not 

established a foreign-vendor vetting process or vendor vetting cell that 

would preemptively identify vendors who support terrorist or other 

prohibited organizations. In response, U.S. Africa Command issued an 

instruction establishing a vendor vetting program, naming a service as the 

lead in establishing the capability and a joint staff intelligence directorate 

subdivision to provide support. Under the instruction, the vendor vetting 

cell would likely operate in contingency operation environments as well as 

in some steady-state environments. Similarly, U.S. Central Command 

established a vendor vetting cell to vet non-U.S. vendors in Afghanistan 

to minimize the risk of insurgents or criminal groups using contracts to 

fund their operations. PACOM headquarters officials, however, stated the 

command does not plan to issue vendor vetting guidance in the absence 

of overarching DOD guidance on how vendor vetting should be 

addressed at a combatant command.

While the establishment of a foreign-vendor vetting cell may not be 

appropriate for all operations or circumstances, published DOD guidance 

specifying under what circumstances and how a vetting cell should be 

established would better position PACOM and other combatant 

commands to avoid contracting with the enemy in high-threat areas. 

Furthermore, as the recently established working group identifies DOD 

entities to be key stakeholders in vendor vetting, including which entity 

should have primary responsibility for vendor vetting, PACOM could 

consider developing its own vendor vetting guidance as other combatant 

commands have done, to prepare for the event that it becomes actively 

engaged in hostilities.
Page 18 GAO-17-428 Operational Contract Support

In June 2014, PACOM established an interim organizational structure to 

oversee and manage OCS in its area of responsibility. DOD introduced 

the concept of an OCS Integration Cell in a 2014 update to Joint 

Publication 4-10 as a permanent, full-time cell at the combatant-command 

level that can, among other things, provide staff integration by assisting 

and advising the directorates of a combatant command on determining 

OCS requirements as well as conducting the initial planning for and 

coordination of OCS tasks.37 In PACOM, the role of the OCS Integration 

Cell is performed by the OCS Mission Integrator Demonstration—a 3-year 

pilot program that began in June 2014 and is scheduled to end in June 

2017. The pilot program is designed to establish OCS as an enduring, 

warfighting capability that supports implementation of Joint Force 2020.38

The intent of the OCS Mission Integrator Demonstration is to establish 

OCS as an enduring capability to provide the combatant command, 

subordinate unified commands, and service components a central entity 

to integrate OCS across joint functions—in effect, to operationalize OCS 

within PACOM—in steady-state and contingency environments. 

Specifically, the PACOM OCS Mission Integrator Demonstration has 

three primary purposes:

• establish a capability to address current PACOM gaps regarding the 

ability to plan and integrate OCS into operations and training;

• contribute to the department’s mandate to improve acquisition 

processes through training and continuous improvement in the 

qualifications and experience both of the acquisition workforce and of 

nonacquisition personnel; and

• inform OCS force development across DOD.

PACOM officials provided examples of how the OCS Mission Integrator 

Demonstration has enhanced OCS capabilities at PACOM through 

training in Joint Operational Contract Support Planning and Execution 

 37See, e.g., Joint Pub. 4-10, app. D (July 16, 2014). According to Joint Publication 4-10, 

the OCS Integration Cell is a permanent, full-time cell at the combatant-command level 

and is normally stood up as a full-time cell at the subordinate joint-force-command level 

for the duration of the command’s existence. Id. at III-7. 

38Joint Force 2020 is the vision outlined in defense strategic guidance for the joint force by 

the year 2020. See Department of Defense, Sustaining U.S. Global Leadership: Priorities 

for 21st Century Defense (January 2012).

PACOM Established 

an Interim 

Organizational 

Structure to Manage 

and Oversee OCS, 

but the Future 

Organizational 

Structure Is Focused 

in the Logistics 

Directorate
Page 19 GAO-17-428 Operational Contract Support

Courses at PACOM, and the integration of key OCS features or practices 

into four major exercises, including the OCS Joint Exercise 2015, 

Talisman Sabre, Pacific Sentry, and Keen Edge. See appendix II for 

additional details on the integration of OCS into these exercises.

The OCS Mission Integrator Demonstration team comprises military 

personnel assigned to PACOM, two Joint Contingency Acquisition 

Support Office (JCASO) civilian planners, and six contractor personnel. 

These personnel are all located in PACOM’s J4 logistics directorate and 

the logistics directorates in three of PACOM’s service component 

commands, although the distribution has varied during the 3 years of the 

experiment. Officials stated that this horizontal and vertical integration—

horizontally across the PACOM logistics directorate and vertically down to 

the logistics directorates within the service components—will remain in 

place through 2017, and acknowledged it has both advantages and 

disadvantages. For example, PACOM officials stated that maintaining a 

separate OCS branch within the logistics directorate simplifies 

assignment tasking, but makes it more difficult to embrace OCS outside 

of the designated OCS billets.

DOD, Joint Staff, and PACOM guidance indicate the important role 

directorates beyond logistics should play as stakeholders in OCS. As 

described by Joint Publication 4-10, an OCS Integration Cell leads the 

OCS planning and integration efforts across multiple staff sections, 

helping to ensure OCS is fully embedded and integrated throughout the 

command structure, as depicted in figure 2 below.39

 39See, e.g., Joint Pub. 4-10, at III-7, D-1 to D-7 (July 16, 2014).
Page 20 GAO-17-428 Operational Contract Support

Figure 2: Operational Contract Support Integration Cell’s Staff Integration Function 

within a Command

Note: DOD’s combatant commands are typically organized into directorates (designated as Js in the 

figure). This figure is a general depiction of a combatant command’s structure; individual structures 

may vary.
Page 21 GAO-17-428 Operational Contract Support

In October 2016, DOD issued Command and Staff Guide to Operational 

Contract Support, which identifies key OCS questions a commander 

should ensure staff across multiple directorates can answer.40 For 

example:

• J1 personnel directorate: How many DOD contractors are in the 

operational area? What is the breakdown of contractor personnel with 

respect to U.S. citizens, third-country nationals, and local nationals?

• J2 intelligence directorate: How are vendors being vetted? How are 

the vetting results communicated within DOD and among U.S. 

government agencies?

• J3 operations directorate: How is the command measuring the 

operational impacts of contracts? What is our process for determining 

base access?

Further, joint doctrine identifies a key OCS principle that states that 

contracted support is not restricted to logistics support, but may include 

significant nonlogistic support as well. Joint doctrine also notes that close 

coordination between all primary and special staff members is required to 

ensure OCS planning balances effectiveness with efficiency and risk 

while seeking to attain the commander’s strategic end state.41 The Joint 

Staff is in the process of developing an OCS planning manual that, 

according to officials, would encourage OCS integration with all staff 

directorates at a combatant command. Specifically, officials stated the 

manual will discuss ways in which a command can ensure OCS equities 

are being considered from all directorates, including hosting OCS 

Integration Cell meetings open to all command staff. However, as of 

February 2017, this manual had not been issued.

PACOM guidance also recognizes the important role directorates beyond 

logistics should play as stakeholders in OCS. Specifically, PACOM’s OCS 

guidance identifies recommended planning considerations for command 

directorates, including nonlogistics directorates, with respect to OCS 

within the command’s area of responsibility in preparation for a 

contingency operation.42 For example:

 40 See DOD, Command and Staff Guide to Operational Contract Support, at 16 (Oct. 25, 

2016).

41Joint Pub. 4-10, at I-9, III-3 (July 16, 2014).

42See PACOM Instruction 0601.7, Operational Contract Support, para. 10 (Aug. 21, 2012).
Page 22 GAO-17-428 Operational Contract Support

• J1 Manpower and Personnel Directorate is to provide status reports 

(through SPOT) to DOD on contractors authorized to accompany the 

force and to develop contractor reception policies and procedures in 

coordination with the J3 Operations Directorate.

• J2 Intelligence Directorate is to conduct intelligence-specific activities 

associated with data reported in SPOT, as required.

• J3 Operations Directorate is to integrate SPOT data into AntiTerrorism Force Protection networks.

• J5 Strategic Planning and Policy Directorate is to provide awareness 

on joint planning tools in regard to generating OCS requirements and 

identifying capability gaps.

While each of these directorates has OCS responsibilities as outlined 

above, they did not have representation in the OCS Mission Integrator 

Demonstration. PACOM officials acknowledged that maintaining its OCS 

Integration Cell within the logistics directorate complicates assignment 

tasking outside of that directorate and reinforces the view of OCS as a 

separate function, making it difficult to integrate OCS efforts in other 

directorates. In addition, PACOM service component officials told us that 

the OCS Mission Integrator Demonstration might have been more 

effective if it integrated individuals from all joint staff functions, including 

other directorates beyond logistics. Officials from one component told us 

they thought a key purpose of the OCS Mission Integrator Demonstration 

was to engage all staff directorates in OCS issues and integrate OCS 

across all joint functions to best optimize total force capability, which may 

not have been optimally met by placing the pilot program within the 

logistics directorate.

PACOM has not determined the size and organizational structure of an 

entity managing OCS following the conclusion of the pilot in June 2017. 

PACOM officials told us the future OCS capability, at a minimum, will 

consist of one military officer and the two civilian embedded planners 

from JCASO and will remain within the logistics directorate.

We have previously reported that because DOD doctrine recognizes that 

OCS is more than just logistical support, it is important that a significant 

culture change occur, one that emphasizes OCS throughout all aspects of 

the department, including planning, training, and personnel requirements. 

Moreover, as we reported in 2013, DOD has faced challenges integrating 
Page 23 GAO-17-428 Operational Contract Support

OCS in functional areas beyond logistics.43 For example, we determined 

that combatant commands and their components were not planning for 

the potential use of contractors in areas where they may be needed 

beyond logistics such as communications. Additionally, we reported that 

OCS planners embedded in a combatant command do not typically focus 

on OCS matters in areas beyond logistics, leaving DOD at risk of being 

unprepared to plan and manage deployed contractor personnel across 

functional areas and provide the necessary oversight during future 

operations. By considering ways to integrate individuals from all joint staff 

functions beyond the logistics area into its enduring OCS organizational 

structure, PACOM may be better positioned to build upon the progress 

made during the OCS Mission Integrator Demonstration and more 

effectively integrate OCS across the command.

PACOM has integrated OCS into 6 of its 11 operational, concept, and 

campaign plans for potential contingencies by developing OCS 

annexes—known as Annex Ws— that are required by DOD guidance for 

certain plans, but the annexes lack details on contractor management 

and support estimates in required appendixes.44 PACOM planners from 

the OCS Mission Integrator Demonstration as well as the plans 

directorate worked with logistics directorate officials at PACOM 

headquarters, the service component commands, and subordinate unified 

commands to develop the annexes. PACOM officials noted that although 

the 5 remaining plans do not require the annex, they will update them with 

Annex Ws as planning cycles dictate and resources allow, and noted that 

personnel will have to prioritize planning efforts when the OCS Mission 

Integrator Demonstration pilot program ends in June 2017, as previously 

discussed.

According to joint doctrine, an Annex W is the primary means used by 

combatant command staff, subordinate staff, service components, and 

other organizations to document OCS in operation plans.45 DOD 

 43GAO-13-212.

44During a visit to PACOM in July 2016, we reviewed and analyzed five operational or 

concept plans and concluded that OCS was integrated into the plans. In January 2017, 

PACOM officials told us that they had completed a sixth Annex W. We were unable to 

review this particular plan, but are reporting that PACOM has completed annexes for six 

plans based on the officials’ statements. 

45Joint Pub. 4-10, at III-14 (July 16, 2014).

PACOM Has 

Integrated OCS 

Annexes into

Operational and 

Concept Plans, but 

the Information Lacks 

Details on Contractor 

Management and 

Support Estimates
Page 24 GAO-17-428 Operational Contract Support

Instruction 3020.41 directs combatant commanders to include an Annex 

W in operation plans and in concept plans with time-phased force and 

deployment data.46 Additionally, Chairman of the Joint Chiefs of Staff 

Manual 3130.03 identifies the key components of an Annex W, including 

a description of key OCS-related planning assumptions and limiting 

factors, key tasks for subordinate units, and commercial sourcing for 

nonlogistics support such as intelligence and communications, as well as 

logistics support such as commodities, base life support, and common 

equipment maintenance.47 PACOM’s annexes generally include these 

elements, such as assumptions about the number and types of services 

that may require contract support (e.g., bottled water, base life support, 

construction, and maintenance).

However, we determined that PACOM Annex Ws lacked detailed 

information in appendixes required by guidance. Specifically, Chairman of 

the Joint Chiefs of Staff Manual 3130.03 identifies the key components of 

an Annex W, including three appendixes.48 For example, these 

appendixes should include a

• Summary of Contracting Capabilities and Capacities Support 

Estimate, which identifies the estimated numbers of support personnel 

for each assigned unit, designated locations, and key contracting 

organizations;

• Contractor Management Plan, which focuses on contractor personnel 

and equipment tasks, to include contractor personnel accountability, 

as well as government-furnished support and equipment; and

• Summary of Contractor Support Estimate, which includes estimates of 

the number of contractors authorized to accompany the force by 

operational phase and capability area.

We found PACOM’s Annex Ws do not have precise information in their 

Summary of Contracting Capabilities and Capacities Support Estimate, 

 46See DODI 3020.41, encl. 2, para. 2.a (Dec. 20, 2011); see also 32 C.F.R. § 158.6(b)(1). 

Although DOD Instruction 3020.41 does not specifically require an Annex W as part of the 

Theater Campaign Plan, PACOM officials identified this plan as a plan for which the 

command required an Annex W.

47See generally Chairman of the Joint Chiefs of Staff Manual 3130.03, Adaptive Planning 

and Execution (APEX) Planning Formats and Guidance, encl. E, app. W (Annex W) (Oct. 

18, 2012).

48See id.
Page 25 GAO-17-428 Operational Contract Support

Contractor Management Plans, and Summary of Contractor Support 

Estimate appendixes. While the details of these annexes are classified, in 

general the appendixes did not always include the estimated number of 

support personnel or key contracting organizations. Additionally, some of 

the appendixes did not include the number of contractors authorized to 

accompany the force by operational phase and capability area.

PACOM officials stated that they face several challenges with regard to 

including this detail in appendixes. For example, PACOM headquarters 

and service component officials identified challenges related to planning 

cycles and the tendency of operational planners to review only the 

annexes that pertain to their own issue areas. Additionally, officials stated 

that other challenges hinder requirements development, which is a 

necessary step to developing the needed details for Annex W 

appendixes. For example, requirements development can be hindered by 

limited access to the operational environment in order to conduct site 

surveys, as well as dependence on host nations to support site surveys. 

Officials also stated that lack of visibility into details regarding the 

capabilities that will be available during a contingency makes it difficult to 

develop detailed requirements.

Despite these limitations, progress has been made by selected PACOM 

subordinate commands regarding requirements development. For 

example, officials from III Marine Expeditionary Force stated that they are 

working to address this concern through the development of a Marine 

Requirements and Resourcing Review Board. According to officials, this 

board will focus not just on requirements, but also on the resources that 

will be needed to obtain them. The board reviews all contracts for III 

Marine Expeditionary Force, validates the resourcing for those contracts, 

prioritizes the current and future requirements in relation to the resources, 

and makes recommendations to the Deputy Commanding General. 

Because the board validates not just the requirement but also the 

resources available to fulfill that requirement, officials stated that it should 

help to obtain information that could be useful in Annex Ws and their 

accompanying appendixes.

PACOM officials acknowledged the need to address these challenges 

and conducted a series of five OCS planning working groups from 

November 2016 to January 2017 to discuss the development of OCS 

requirements in support of planning efforts. Additionally, OCS working 

groups housed within the logistics directorate have been integrated into 

PACOM’s daily planning activities in order to ensure that OCS equities 

are considered within the command’s activities. The establishment of 
Page 26 GAO-17-428 Operational Contract Support

working groups and incorporation of OCS equities into the command’s 

regular planning activities demonstrate progress in improving the 

development of OCS requirements. However, a lack of clarity continues 

to exist with respect to the roles and responsibilities associated with 

headquarters and service component officials and the level of detail 

needed in the development of Annex Ws and their appendixes. 

Specifically, PACOM officials stated that this information is not included in 

the completed Annex W appendixes that PACOM expects the 

requirements generators within the service components to provide. 

However, service component and subordinate unified command officials 

stated that they need additional guidance from PACOM or their service 

headquarters to determine the level of detail that is needed.

Combatant commanders have discretion regarding the amount of detail 

needed in the relevant annexes and their appendixes both at the 

combatant command and subordinate levels. However, service 

component officials stated that additional direction or an established 

mechanism for communication from PACOM headquarters or their 

service headquarters could help to clarify the level of detail needed to 

enhance the usefulness of the Annex Ws and their accompanying 

appendixes. Also, Standards for Internal Control in the Federal 

Government states that management should assign responsibility and 

delegate authority to achieve the entity’s objectives, including determining 

the level of authority that should be delegated to key roles. Without 

guidance that clarifies roles and responsibilities as well as the process for 

requirements development to inform the development of Annex Ws and 

their appendixes, the annexes will continue to lack important details that 

are needed to determine OCS requirements and adequately plan for 

future operations.

While PACOM has taken steps to manage and oversee OCS, challenges 

remain in areas such as accounting for the total number of contractor 

personnel, vendor vetting, the enduring OCS organizational structure, and 

OCS requirements-development planning for incorporation into 

operational plans. PACOM’s November 2016 personnel accountability 

guidance demonstrates progress toward addressing the collection of 

contractor personnel data, but it does not specifically account for thirdcountry nationals and local nationals or specify a system of record to be 

used for all contractor personnel in steady-state environments. 

Additionally, DOD accountability guidance on the types of contractor 

personnel to account for in steady-state environments remains unclear. 

PACOM also has not established a foreign-vendor vetting process to 

Conclusions
Page 27 GAO-17-428 Operational Contract Support

preemptively identify vendors that support criminal, terrorist, or other 

sanctioned organizations due in part to a lack of DOD guidance 

specifying under what conditions a vendor vetting process or cell should 

be established. Additionally, without updated guidance that integrates 

individuals from directorates beyond logistics into the OCS Integration 

Cell, PACOM may lose some of the ground gained during the OCS 

Mission Integrator Demonstration. Finally, PACOM has made progress in 

developing OCS annexes to plans, but those annexes do not include 

precise and important details on contractor management. OCS is a critical 

force multiplier that supports U.S. military forces in the region when they 

respond rapidly to crises, such as threats including North Korea. 

PACOM’s readiness is evaluated against its ability to execute operational 

and contingency plans, which place a premium on forward-stationed, 

ready forces that can exercise, train, and operate with our partner nations’

militaries, and on follow-on forces, including contractor support, to be able 

to respond to operational contingencies.

We recommend that the Secretary of Defense take the following six 

actions:

To enable the department to enhance its visibility over contractor 

personnel for whom it may become responsible in the event of 

contingency and other applicable operations, we recommend that the 

Secretary of Defense, in coordination with the Chairman of the Joint 

Chiefs of Staff, update accountability guidance clarifying the types of 

contractor personnel that are to be accounted for in a steady-state 

environment.

To enable PACOM to consistently account for contractor personnel in its 

area of responsibility, we recommend that the Secretary of Defense direct 

the PACOM Commander to clarify contractor personnel accountability 

guidance for the collection of all contractor personnel data in a steadystate environment and specify a system of record, such as SPOT, for the 

collection of this information.

To ensure that combatant commands are not contracting with entities that 

may be connected to or supporting prohibited organizations, we 

recommend that the Secretary of Defense, in coordination with the 

Chairman of the Joint Chiefs of Staff, develop and issue guidance that 

clarifies the foreign-vendor vetting steps or process that should be 

established at each combatant command, including the operational 

Recommendations for 

Executive Action
Page 28 GAO-17-428 Operational Contract Support

conditions under which a foreign-vendor vetting cell should be 

established.

To ensure that PACOM is not contracting with entities that may be 

connected to or supporting prohibited organizations, we recommend that, 

while awaiting DOD guidance on vendor vetting, the Secretary of Defense 

direct the PACOM commander to consider developing vendor vetting 

guidance as other combatant commands have done, to prepare for the 

event that PACOM becomes actively engaged in hostilities.

To enable OCS to be fully embedded in the command structure at the 

command and continue to build upon the progress of integrating OCS into 

the command, we recommend that as PACOM updates OCS guidance, 

the Secretary of Defense direct the PACOM Commander to consider 

ways to ensure all joint staff functions beyond the logistics area are fully 

integrated into its OCS organizational structure and OCS Integration Cell.

To enable PACOM to better identify OCS requirements and incorporate 

those requirements into Annex Ws and their appendixes, we recommend 

that the Secretary of Defense direct the PACOM Commander to develop 

guidance that clarifies roles and responsibilities and the process that 

should be followed for OCS requirements development.

In written comments on a draft of this report, DOD and PACOM concurred 

with two recommendations and partially concurred with four 

recommendations. Comments from DOD and PACOM are summarized 

below and reprinted in appendix III. DOD and PACOM also provided 

technical comments, which we incorporated as appropriate.

DOD concurred with the first recommendation that the Secretary of 

Defense, in coordination with the Chairman of the Joint Chiefs of Staff, 

update accountability guidance clarifying the types of contractor 

personnel that are to be accounted for in a steady state environment. In 

its response, DOD stated that DOD Instruction 3020.41, Operational 

Contract Support, is being updated, and will include guidance on the 

types of contractor personnel that are to be accounted for in Phase 0 

operations, when directed by the combatant commander or joint task 

force commander, using SPOT. The department will also update 

Chairman of the Joint Chiefs of Staff Manual 3150.13C, Joint Personnel 

Reporting Structure—Personnel Manual, to clarify the types of contractor 

personnel that are to the accounted for, based on the updates to DOD 

Instruction 3020.41. We agree that these guidance updates, when 

Agency Comments 

and Our Evaluation
Page 29 GAO-17-428 Operational Contract Support

completed and issued as stated, would meet the intent of the 

recommendation.

DOD partially concurred with the second recommendation that the 

PACOM Commander clarify contractor personnel accountability guidance 

for the collection of all contractor personnel data during a steady state 

environment and specify a system of record, such as SPOT, for the 

collection of this information. In its response, PACOM stated that the 

accountability instruction issued in November 2016, referenced earlier in 

this report, prescribes guidance for the reporting of DOD-affiliated 

personnel, to include contractors, in crisis, contingency, and steady state 

operations using the Joint Personnel Status Report as the system of 

record. Additionally, PACOM noted that it is conducting a feasibility 

assessment of implementing SPOT in Phase 0 operations in three 

countries where the majority of contractors currently work, and will 

conduct a review of its accountability instruction to further clarify 

contractor accountability and visibility guidance. We agree that the review 

of accountability guidance and the feasibility assessment would be 

beneficial in further clarifying contractor accountability and visibility 

guidance. As we discuss in the report, in the absence of clear 

accountability guidance from DOD, PACOM has used multiple 

mechanisms for contractor personnel accountability, which has resulted in 

inconsistent reporting. Additionally, PACOM’s accountability guidance 

issued in November 2016 is limited in that it excludes foreign-national 

contractor personnel. This recommendation was intended to provide 

PACOM with the flexibility to identify a system of record in its 

accountability guidance for the collection of contractor personnel 

accountability information in a steady-state or Phase 0 environment so 

that PACOM could utilize a single mechanism for contractor personnel 

accountability. Without updated guidance to clarify what types of 

contractor personnel are to be accounted for in Phase 0 operations, as 

well as the identification of a system of record for contractor personnel 

accountability information, PACOM may not have a comprehensive and 

consistent accounting of contractor personnel in its area of responsibility, 

which could potentially limit PACOM’s visibility over contractor personnel 

for whom it may be responsible in the event of a contingency operation or 

an emergency.

DOD partially concurred with the third recommendation that the Secretary 

of Defense, in coordination with the Chairman of the Joint Chiefs of Staff, 

develop and issue guidance that clarifies the foreign vendor vetting steps 

or process that should be established at each combatant command, 

including the operational conditions under which a foreign vendor vetting 
Page 30 GAO-17-428 Operational Contract Support

cell should be established. DOD agreed that it needs to develop and 

issue overarching guidance. As a result, DOD noted that, in October 

2016, OSD and Joint Staff established a quarterly working group to 

develop a framework for intelligence-based vendor threat mitigation—

vendor vetting—objectives across DOD. The working group identified 

three major objectives for DOD, including providing an overarching 

framework, identifying a DOD lead for program policy and oversight, and 

improving information sharing across DOD and other federal agencies. 

DOD indicated that an office within OSD, as part of the working group, 

has incorporated inputs through a draft directive type memorandum that 

will provide guidelines to meet the objectives while ensuring combatant 

commands retain the flexibility needed to tailor vetting programs to meet 

their specific theater and mission needs. However, DOD noted that under 

section 164 of Title 10, U.S. Code, combatant commanders have the 

authority to organize commands and forces as necessary to carry out 

missions. We agree with DOD’s assessment, and as we discuss in the 

report, the establishment of a foreign-vendor vetting cell may not be 

appropriate for all operations or circumstances. However, publishing 

guidance for the combatant commanders to consider in their decision and 

approach to establishing a foreign vendor cell would provide important 

information to guide their efforts. Therefore, we continue to believe that 

publishing DOD guidance identifying relevant operational conditions and 

how a vetting cell should be established would better position PACOM 

and other combatant commands to avoid contracting with the enemy in 

high-threat areas.

DOD concurred with the fourth recommendation that while awaiting DOD 

guidance on vendor vetting, the PACOM commander consider developing 

vendor vetting guidance as other combatant commands have done in the 

event that they become actively engaged in hostilities. In its response, 

PACOM stated that they have begun gathering facts and best practices 

regarding vendor vetting, and in the absence of DOD guidance, both the 

process and echelon at which vetting should occur deserves additional 

study and refinement. PACOM also stated that implementation of vendor 

vetting will be dependent on resource availability and priority, and ability 

to leverage the capabilities and accesses of a broader community of 

concern. We agree that PACOM’s further study and refinement of vendor 

vetting processes in its geographic area of responsibility would be 

beneficial in the absence of DOD vendor vetting guidance, and would 

meet the intent of the recommendation.

DOD partially concurred with the fifth recommendation for the PACOM 

Commander to consider ways to ensure all joint staff functions beyond 
Page 31 GAO-17-428 Operational Contract Support

the logistics area are fully integrated into its OCS organizational structure 

and OCS Integration Cell. In its response, PACOM stated that it will 

continue the ongoing process of publishing an updated OCS instruction, 

as we discussed in the report, including specific primary and special staff 

responsibilities related to OCS. However, PACOM stated that it integrates 

staff with the OCS Integration Cell through its established process for 

daily activities, including an OCS working group, but does not plan to 

physically integrate other staff members into the OCS Integration Cell. 

PACOM noted that it routinely integrates OCS with the greater staff by 

inviting representatives to the established OCS working group, based on 

agenda items, attending routine activities hosted by other staff 

directorates, and hosting an internal OCS working group with 

headquarters staff. We noted a number of these actions in the report and 

agree that they are beneficial to the integration of OCS throughout the 

staff directorates. Additionally, we recognize that Joint Publication 4-10 

does not specifically call for representation from all staff within the OCS 

Integration Cell itself, and notes only that the OCSIC should be made up 

of a mixture of specially trained personnel with operational-level logistics 

and contingency contracting experience, as DOD states in its comments. 

However, as also noted in our report, PACOM officials stated that 

maintaining its OCS Integration Cell within the logistics directorate 

complicates assignment tasking outside of that directorate and reinforces 

the view of OCS as a separate function, making it difficult to integrate 

OCS efforts in other directorates. In addition, PACOM service component 

officials told us that the OCS Mission Integrator Demonstration might 

have been more effective if it integrated individuals from all joint staff 

functions, including other directorates beyond logistics. Accordingly, we 

continue to believe that PACOM should consider additional ways to 

ensure all joint staff functions beyond the logistics area are fully 

integrated into its OCS organizational structure and OCS Integration Cell.

DOD partially concurred with the sixth recommendation for the PACOM 

Commander to develop guidance that clarifies roles and responsibilities 

and the process that should be followed for OCS requirements 

development. In its response, PACOM stated that its requirements 

determination in support of planning requires improvement, but that its 

guidance is clear. Specifically, PACOM stated that existing published 

guidance from the Joint Staff logistics directorate and PACOM logistics 

directorate is clear and concise, and identifies the roles and 

responsibilities of the command and subordinate units regarding planning 

and the process of determining requirements. PACOM agreed that a 

need exists to emphasize existing guidance to subordinate commands in 

order to assist them in developing and documenting requirements. 
Page 32 GAO-17-428 Operational Contract Support

Emphasizing existing guidance is a good first step in improving the 

requirements development and documentation process. However, as 

discussed in the report, PACOM officials also stated that some key details 

are not included in the completed Annex W appendixes, which the 

command expects requirements generators within the service 

components to provide. Service component officials stated that additional 

direction or an established mechanism for communication from PACOM 

headquarters or their service headquarters could help to clarify the level 

of detail needed to enhance the usefulness of the Annex Ws and their 

accompanying appendixes. We continue to believe that until PACOM 

addresses this issue, annexes could continue to lack important details 

that are needed to determine OCS requirements and adequately plan for 

future operations.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense, Chairman of the Joint Chiefs of 

Staff, and the PACOM Commander. The report will also be available at 

no charge on GAO’s website at http://www.gao.gov.

If you or your staff have questions about this report, please contact me at 

(202) 512-5431 or russellc@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of the final report. GAO staff who made key contributions to this report are 

listed in appendix IV.

Cary B. Russell

Director

Defense Capabilities and Management
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-17-428 Operational Contract Support

The objectives of our review were to determine the extent to which U.S. 

Pacific Command (PACOM) has: (1) accounted for contractor personnel 

and has a process to vet foreign vendors in its area of responsibility; (2) 

an organizational structure to manage and oversee operational contract 

support (OCS); and (3) integrated OCS into key planning documents. The 

focus of this review was on PACOM and its subordinate service 

components and subordinate unified commands, including U.S. Army 

Pacific; U.S. Pacific Air Forces; U.S. Marine Forces, Pacific (inclusive of 

III Marine Expeditionary Force on the Japanese island of Okinawa); the 

U.S. Pacific Fleet; U.S. Forces Japan; and, U.S. Forces Korea. Further, in 

terms of our review of PACOM contractor personnel accountability and 

contractor vetting, our scope included only contract support in the 

PACOM area of responsibility, excluding contract support located at 

PACOM headquarters.

To determine the extent to which PACOM accounts for contractor 

personnel, we reviewed the Department of Defense (DOD), PACOM, and 

Joint Staff personnel accountability guidance and interviewed PACOM, 

service component, and subordinate unified command J1 personneldirectorate officials. We additionally requested, received, and reviewed 

Synchronized Predeployment and Operational Tracker (SPOT) data as of 

September 30, 2016, from the SPOT Program Management Office to 

determine the number of contractor personnel captured in SPOT for the 

PACOM area of responsibility. We conducted a data-reliability analysis of 

this information, including the transmittal of a data-accuracy and -

completeness questionnaire to the SPOT Program Management Office. 

On the basis of the SPOT Program Management Office’s responses to 

the team’s data-reliability questionnaire and our prior reporting on SPOT, 

we determined the data are reliable for the purposes of identifying a 

“rough order of magnitude” in regard to the number of contractor 

personnel in the U.S. Pacific Command area of responsibility as of 

September 30, 2016. We compared these data to DOD and PACOM 

guidance regarding personnel accountability processes and reporting, 

including for contractor personnel.

To determine the extent to which PACOM has a process to vet 

contractors and contractor employees, we reviewed DOD, Joint Staff, and 

combatant command guidance on OCS and compared them to data 

collected in interviews with PACOM, service component, and subordinate 

unified command intelligence-directorate officials and other staff 

stakeholders. We additionally reviewed DOD OCS and acquisition 

guidance, DOD OCS action plans, U.S. Africa Command guidance, and a 

draft Office of the Secretary of Defense (OSD) memorandum.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-17-428 Operational Contract Support

To determine the extent to which PACOM has an organizational structure 

in place to manage and oversee OCS, we gathered information from and 

conducted interviews with officials at PACOM, service components, and 

subunified command headquarters, and compared it to DOD, PACOM, 

Joint Staff, and multiservice OCS guidance we reviewed that identifies 

roles and responsibilities for multiple directorates outside the logistics 

area with OCS equities. Additionally, we reviewed OCS Mission Integrator 

Demonstration documentation, including annual progress reports, 

combatant command briefing documents, combatant command afteraction reports for theater exercises; and Joint Operational Planning and 

Execution Course documentation.

To determine the extent to which PACOM has integrated OCS into key 

planning documents, we gathered information from and conducted 

interviews with officials at PACOM, service components, and subunified 

command headquarters. We reviewed and analyzed the OCS annexes—

Annex Ws—to PACOM’s theater campaign plan and operation plans to 

determine the extent to which they included key OCS concepts outlined in 

DOD and Chairman of the Joint Chiefs of Staff guidance, including 

whether they contained key details in annex appendixes related to 

contractor management plans, summaries of contractor support 

estimates, and summaries of contracting capabilities and capacities 

support estimates. To complete this review, we first identified and created 

a checklist of Annex W elements as specified in Chairman of the Joint 

Chiefs of Staff guidance regarding operation plan formats.1 Then each of 

the three team members reviewed each Annex W and recorded whether 

the annex featured the specified information. We additionally analyzed 

the level of detail provided in the annex for each element. We then 

aggregated the observations completed for each annex, and the team 

members collectively identified generalizable trends regarding the extent 

to which the reviewed Annex Ws featured OCS concepts. The details of 

this analysis are classified.

 1

Chairman of the Joint Chiefs of Staff Manual 3130.03, Adaptive Planning and Execution 

(APEX) Planning Formats and Guidance (Oct. 18, 2012).
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-17-428 Operational Contract Support

We interviewed officials from the following DOD organizations during our 

review:

Department of Defense (DOD)

• Office of the Under Secretary of Defense for Acquisition, 

Technology and Logistics

• Defense Procurement and Acquisition Policy Directorate

• Office of the Under Secretary of Defense for Intelligence

• Joint Staff J4 (Logistics) Directorate

• Defense Logistics Agency

U.S. Pacific Command (PACOM)

• PACOM Headquarters, Honolulu, Hawaii

• PACOM J1 (Personnel) Directorate, Honolulu, Hawaii

• PACOM J2 (Intelligence) Directorate, Honolulu, Hawaii

• PACOM J3 (Operations) Directorate, Honolulu, Hawaii

• PACOM J4 (Logistics) Directorate, Honolulu, Hawaii

• PACOM OCS Mission Integrator Demonstration, Honolulu, Hawaii

• U.S. Forces Japan Headquarters, Yokota Air Base, Japan

• U.S. Army Garrison, Camp Zama, Japan

• U.S. Forces Korea Headquarters, Seoul, South Korea

• 411th Contract Support Brigade, Seoul, South Korea

Department of the Air Force

• Department of the Air Force, Arlington, Virginia

• U.S. Pacific Air Forces, Honolulu, Hawaii

• U.S. Air Force A1 (Personnel), Honolulu, Hawaii

• U.S. Air Force A2 (Intelligence), Honolulu, Hawaii

• U.S. Air Force A3 (Operations), Honolulu, Hawaii

• U.S. Air Force A4 (Logistics), Honolulu, Hawaii

• 374th Contracting Squadron U.S. Air Force Japan, Yokota Air 

Base, Japan
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-17-428 Operational Contract Support

Department of the Army

• Department of the Army, Arlington, Virginia

• U.S. Army Pacific, Honolulu, Hawaii

• U.S. Army Pacific G1 (Personnel), Honolulu, Hawaii

• U.S. Army Pacific G2 (Intelligence), Honolulu, Hawaii

• U.S. Army Pacific G3 (Operations), Honolulu, Hawaii

• U.S. Army Pacific G4 (Logistics), Honolulu, Hawaii

• 413th Contracting Support Brigade, Honolulu, Hawaii

Department of the Navy

• Department of the Navy, Arlington, Virginia

• U.S. Commander, Pacific Fleet, Honolulu, Hawaii

• U.S. Commander, Pacific Fleet N1 (Personnel), Honolulu, Hawaii

• U.S. Commander, Pacific Fleet N2 (Intelligence), Honolulu, Hawaii

• U.S. Commander, Pacific Fleet N3 (Operations), Honolulu, Hawaii

• U.S. Commander, Pacific Fleet N4 (Logistics), Honolulu, Hawaii

• Naval Facilities Command Pacific, Honolulu, Hawaii

• Headquarters, U.S. Marine Corps, Arlington, Virginia

• U.S. Marine Corps Pacific Forces, Honolulu, Hawaii

• U.S. Marine Corps Pacific Forces G-1 (Personnel) Directorate, 

Honolulu, Hawaii

• U.S. Marine Corps Pacific Forces G-2 (Intelligence) Directorate, 

Honolulu, Hawaii

• U.S. Marine Corps Pacific Forces G-3 (Operations) Directorate, 

Honolulu, Hawaii

• U.S. Marine Corps Pacific Forces G-4 (Logistics) Directorate, 

Honolulu, Hawaii

• III Marine Expeditionary Force, Okinawa, Japan

• III Marine Expeditionary Force G-1 (Personnel) Directorate, 

Okinawa, Japan

• III Marine Expeditionary Force G-2 (Intelligence) Directorate, 

Okinawa, Japan
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-17-428 Operational Contract Support

• III Marine Expeditionary Force G-3 (Operations) Directorate, 

Okinawa, Japan

• III Marine Expeditionary Force G-4 (Logistics) Directorate, 

Okinawa, Japan

We conducted this performance audit from December 2015 to June 2017 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Operational Contract Support 

Features and Practices Included in U.S. Pacific

Command Exercises

Page 38 GAO-17-428 Operational Contract Support

Operational Contract Support (OCS) Mission Integrator Demonstration 

personnel developed numerous OCS-related features or practices that 

were incorporated into at least one of the four major exercises at various 

U.S. Pacific Command (PACOM) command levels. Table 1 below 

provides additional details on the integration of OCS into these exercises.

Table 1: Operational Contract Support Features and Practices Included in U.S. Pacific Command Exercises 2015–2016

Master scenario event 

list feature or practicea Command level Exercise and date Outcome

Assess steady state 

contracting coordination 

to determine need for 

transition to Lead Service 

for Contracting or Joint 

Theater Support 

Contracting Command

U.S. Pacific 

Command 

Headquarters

Pacific Sentry

August 2015

U.S. Pacific Command (PACOM) planners, in coordination 

with subunified, functional, and service component 

planners, examined the issue in the Operational Contract 

Support (OCS) Working Group and recommended the 

optimal contracting organization construct upon transition 

from steady state to Phase One. The OCS Working Group 

briefed recommendations to the Joint Contracting Support 

Board and presented recommendations to the Joint Staff 

logistics directorate. This effort is intended to inform 

development of the Annex W for an operational plan.

OCS Joint Exercise

April 2015

Efforts in the OCS joint exercise facilitated the 

assessment detailed above for Pacific Sentry.

Keen Edge 16

January 2016

Staff developed and briefed a draft decision support matrix 

to facilitate a decision to transition from Lead Service for 

Contracting Coordination to Lead Service for Contracting.

Intent to establish 

functional / service 

component OCS 

Integration Cell 

U.S. Army Pacific

Pacific Fleet

Pacific Air Forces

OCS Joint Exercise

April 2015

After this exercise, Pacific Air Forces directed 

establishment of an OCS Integration Cell in a Pacific Air 

Forces Supplement to Air Force Instruction 13-103 and is 

working an OCS Integration Cell charter. Due to lack of 

resources and a desire for continuity with PACOM, Pacific 

Air Forces implemented an OCS Working Group in June 

2016. 

Pacific Sentry

August 2015

After Pacific Sentry, U.S. Army Pacific established an 

external OCS Working Group, which started meeting 

monthly in September 2015 and is working to establish an 

internal OCS Working Group with U.S. Army Pacific staff. 

PACOM officials told us that Pacific Fleet briefed its intent 

to establish an OCS Working Group, but has not formally 

established it. According to officials, components have a 

task in the Theater Campaign Plan and Theater Campaign 

Order to establish OCS Integration Cells as required to 

support OCS planning and execution.

Keen Edge

January 2016

During Keen Edge, PACOM deployed two contractor 

personnel to help establish an OCS Integration Cell at 

U.S. Forces Japan with a three-member Joint 

Contingency Acquisition Support Office (JCASO) mission 

support team to support U.S. Forces Japan in 

implementing OCS training objectives for the exercise.

Appendix II: Operational Contract Support 

Features and Practices Included in U.S. 

Pacific Command Exercises
Appendix II: Operational Contract Support 

Features and Practices Included in U.S. Pacific 

Command Exercises

Page 39 GAO-17-428 Operational Contract Support

Master scenario event 

list feature or practicea Command level Exercise and date Outcome

Contractor vetting and 

medical screening 

guidance

7th Fleet

U.S. Army Pacific

OCS Joint Exercise

April 2015

OCS planners conducted cross-functional coordination 

with the PACOM headquarters, 7th Fleet, and U.S. Army 

Pacific personnel within the intelligence directorate and 

surgeon staffs.

Talisman Sabre

July 2015

Combined Task Force J34 facilitated two meetings that 

included intelligence-directorate personnel and provided 

vetting considerations. According to PACOM officials, 

Combined Task Force Surgeon developed medical 

guidance for contractors.

Pacific Sentry

August 2015

U.S. Army Pacific Surgeon committed to participate in an 

OCS Working Group during Phase 0.

Risk assessment for 

reliance on contractor 

performance 

PACOM 

Headquarters

Pacific Sentry

August 2015

OCS planners conducted vertical coordination through the 

OCS Working Group to solicit component and subunified 

input, and briefed the consolidated input at the Joint 

Contracting Support Board. After the exercise, PACOM 

formally solicited input from subunified commands and 

service components. This action facilitates further 

horizontal and vertical coordination at the subunified 

command level.

Synchronized 

Predeployment and 

Operational Tracker 

(SPOT) Implementation 

Plan

PACOM 

Headquarters

Pacific Sentry

August 2015

OCS planners conducted cross-functional coordination 

with the personnel directorate and addressed this issue in 

the Personnel Working Group. The working group 

conducted vertical coordination through the OCS Working 

Group. Additionally, U.S. Forces Korea conducted a 

SPOT proof of principle and is working to codify guidance 

for potential implementation. According to PACOM 

officials, U.S. Forces Korea and U.S. Forces Japan have a 

task in the Theater Campaign Plan to assess feasibility of 

implementing Synchronized Predeployment and 

Operational Tracker (SPOT) in steady-state operations.

Guidance on private 

security contractors and 

arming of contractors for 

personal protection

PACOM 

Headquarters

OCS Joint Exercise

April 2015

Cross-functional coordination with the intelligence 

directorate and operations exercise participants 

highlighted the lack of PACOM guidance in these areas. A 

real-world request for an arming delegation in summer 

2015 provided an opportunity to reengage on this policy 

gap. This real-world issue amplified the observation from 

OCS Joint Exercise 2015 about the need for guidance in 

this area. In December 2015, PACOM J34 staffed a draft 

PACOM Instruction on arming of contractor personnel. 

The instruction was published in March 2016. 

Counter threat finance 

guidance

Pacific Fleet Pacific Sentry

August 2015

OCS planners conducted cross functional coordination 

with the Pacific Fleet staff and vertical coordination with 

the operations directorate Counter Threat Finance cell.
Appendix II: Operational Contract Support 

Features and Practices Included in U.S. Pacific 

Command Exercises

Page 40 GAO-17-428 Operational Contract Support

Master scenario event 

list feature or practicea Command level Exercise and date Outcome

Conduct Joint 

Requirements Review 

Board meeting

PACOM 

Headquarters

7th Fleet

U.S. Forces Japan

OCS Joint Exercise

April 2015

Talisman Sabre

July 2015

OCS Joint Exercise 2015 and Talisman Sabre provided an 

opportunity to familiarize cross functional staff participants 

with the Joint Requirements Review Board. During OCS 

Joint Exercise 2015, participants from PACOM’s 

operations and logistics directorates provided valuable 

insight on the validation and prioritization of the 

requirements and concerns related to anti-terrorism and 

force protection.

Pacific Sentry

August 2015

This exercise enabled cross functional coordination 

between U.S. Forces Japan’s operations, logistics, and 

planning directorates concerning pursuit of contracted 

solutions rather than host nation support and the potential 

effects.

Keen Edge

January 2016

During Keen Edge, U.S. Forces Japan conducted a Joint 

Requirements Review Board, followed by a Joint 

Contracting Support Board meeting to address validated 

requirements.

Request Joint 

Contingency Acquisition 

Support Office (JCASO) 

mission support team 

augmentation

PACOM 

Headquarters

OCS Joint Exercise

April 2015

PACOM coordinated with the Combined Task Force on 

the development of a request for support from the JCASO 

mission support team and developed a request for forces 

to support the requirement.

Pacific Sentry

August 2015

U.S. Forces Japan assessed the requirement for a 

JCASO mission support team and released a formal 

request for support through the U.S. Forces Japan 

operations directorate to PACOM, exercising the request 

process for mission support teams.

Keen Edge

January 2016

PACOM developed a draft decision support matrix to 

facilitate the decision process to request a mission support 

team.

Source: GAO. | GAO-17-428

a

According to Chairman of the Joint Chiefs of Staff Manual 3500.03E, Joint Training Manual for the 

Armed Forces of the United States (Apr. 20, 2015), a joint master scenario event list includes a 

collection of prescripted events intended to guide an exercise toward specific outcomes.Appendix III: 

Comments from the Department of Defense
Appendix III: Comments from the Department 

of Defense

Page 41 GAO-17-428 Operational Contract Support

Appendix III: Comments from the 

Department of Defense
Appendix III: Comments from the Department 

of Defense

Page 42 GAO-17-428 Operational Contract Support
Appendix III: Comments from the Department 

of Defense

Page 43 GAO-17-428 Operational Contract Support
Appendix III: Comments from the Department 

of Defense

Page 44 GAO-17-428 Operational Contract Support
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 45 GAO-17-428 Operational Contract Support

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

In addition to the contact named above, James A. Reynolds, Assistant 

Director; Courtney Reid-Bond, Analyst in Charge; Vijay Barnabas; 

Ricardo Marquez; Richard Powelson; Michael Shaughnessy; Mike Silver; 

Amie Lesser; and Cheryl Weissman made contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 46 GAO-17-428 Operational Contract Support

Operational Contract Support: Additional Actions Needed to Manage, 

Account for, and Vet Defense Contractors in Africa. GAO-16-105. 

Washington, D.C.: December 17, 2015.

Operational Contract Support: Actions Needed to Enhance the Collection, 

Integration, and Sharing of Lessons Learned. GAO-15-243. Washington, 

D.C.: March 16, 2015.

Contingency Contracting: Contractor Personnel Tracking System Needs 

Better Plans and Guidance. GAO-15-250. Washington, D.C.: February 

18, 2015.

High Risk Series: An Update. GAO-15-290. Washington, D.C.: February 

11, 2015.

Defense Acquisitions: Update on DOD’s Efforts to Implement a Common 

Contractor Manpower Data System. GAO-14-491R. Washington, D.C.: 

May 19, 2014.

Warfighter Support: DOD Needs Additional Steps to Fully Integrate 

Operational Contract Support into Contingency Planning. GAO-13-212. 

Washington, D.C.: February 8, 2013.

Operational Contract Support: Management and Oversight Improvements 

Needed in Afghanistan. GAO-12-290. Washington, D.C.: March 29, 2012.

Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Need Improvement. 

GAO-11-355. Washington, D.C.: June 8, 2011.

Warfighter Support: Cultural Change Needed to Improve How DOD Plans 

for and Manages Operational Contract Support. GAO-10-829T. 

Washington, D.C.: June 29, 2010.

Warfighter Support: DOD Needs to Improve Its Planning for Using 

Contractors to Support Future Military Operations. GAO-10-472. 

Washington, D.C.: March 30, 2010.

Contingency Contract Management: DOD Needs to Develop and Finalize 

Background Screening and Other Standards for Private Security 

Contractors. GAO-09-351. Washington, D.C.: July 31, 2009.

Related GAO Products
Related GAO Products

Page 47 GAO-17-428 Operational Contract Support

Military Operations: DOD Needs to Address Contract Oversight and 

Quality Assurance Issues for Contracts Used to Support Contingency 

Operations. GAO-08-1087. Washington, D.C.: September 26, 2008.

Military Operations: High-Level DOD Action Needed to Address Longstanding Problems with Management and Oversight of Contractors 

Supporting Deployed Forces. GAO-07-145. Washington, D.C.: December 

18, 2006.

Military Operations: Background Screenings of Contractor Employees 

Supporting Deployed Forces May Lack Critical Information, but U.S. 

Forces Take Steps to Mitigate the Risk Contractors May Pose.

GAO-06-999R. Washington, D.C.: September 22, 2006.

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