OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

RREEVVIIEEWW OOFFDDYYNNCCOORRPP

IINNTTEERRNNAATTIIOONNAALL,,LLLLCC,,CCOONNTTRRAACCTT

NNUUMMBBEERRSS--LLMMAAQQMM--0044--CC--00003300,,

TTAASSKK OORRDDEERR00333388,, FFOORRTTHHEE IIRRAAQQII

PPOOLLIICCEE TTRRAAIINNIINNGG PPRROOGGRRAAMM SSUUPPPPOORRTT

SSIIGGIIRR--0066--002299

DDOOOSS--OOIIGG--AAUUDD//IIQQOO--0077--2200

JJJAAANNNUUUAAARRRYYY333000,,,222000000777
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

United States Department of State 

and the Broadcasting Board of Governors 

Inspector General 

January 30, 2007 

MEMORANDUM FOR U.S. AMBASSADOR TO IRAQ 

DIRECTOR, IRAQ RECONSTRUCTION MANAGEMENT 

OFFICE 

ASSISTANT SECRETARY, BUREAU FOR INTERNATIONAL 

NARCOTICS AND LAW ENFORCEMENT AFFAIRS, 

DEPARTMENT OF STATE 

DIRECTOR, OFFICE OF ACQUISITION MANAGEMENT, 

DEPARTMENT OF STATE 

SUBJECT: Review of DynCorp International, LLC, Contract Number 

 S-LMAQM-04-C-0030, Task Order 0338, for the Iraqi Police Training 

 Program Support (SIGIR-06-029 and DoS-OIG-AUD/IQO-07-20) 

We are providing this audit report for your information and use. We performed the audit in 

accordance with our statutory duties contained in Public Law 108-106, as amended, which 

requires that we provide for the independent and objective conduct of audits, as well as 

leadership and coordination of, and recommendations on, policies designed to promote 

economy, efficiency, and effectiveness in the administration of such programs and operations 

and to prevent and detect waste, fraud, and abuse. This report discusses the results of a joint 

Special Inspector General for Iraq Reconstruction (SIGIR) and Department of State Inspector 

General review. 

We considered comments from the Department of State Bureau for International Narcotics and 

Law Enforcement Affairs and the Bureau of Administration, Office of Acquisition 

Management on the draft of this report when preparing the final report. The comments are 

addressed in the report where applicable, and a copy of the combined agency response is 

included in the Management Comments section of this report. 

SIGIR, 400 Army Navy Drive • Arlington, Virginia 22202 

U.S. Department of State, Office of Inspector General, Washington, DC 20520-6817

Table of Contents 

Executive Summary......................................................................................... i

Introduction........................................................................................................

Background 1 

Objectives 3 

Costs Incurred Under Task Order 0338.......................................................... 4

Construction of the Camp at Adnan Palace.................................................... 6

Contracting and Contract Management........................................................ 14

Conclusion and Recommendations............................................................... 21

Appendices 

 Appendix A – Scope and Methodology ...................................................... 26

 Appendix B – Acronyms.......................................................................... 28

 Appendix C – Report Distribution ............................................................. 29

 Appendix D – Audit Team Members ......................................................... 31

Management Comments 

 Assistant Secretary, Bureau for International Narcotics and Law 

 Enforcement Affairs, Department of State 32
Review of DynCorp International, LLC, Contract Number 

S-LMAQM-04-C-0030, Task Order 0338, for the Iraqi 

Police Training Program Support 

SIGIR-06-029 

DOS-OIG 

AUD/IQO-07-20 

January 30, 2007

Executive Summary 

Introduction 

In Iraq, the Department of State (DoS) Bureau for International Narcotics and Law 

Enforcement Affairs (INL) is responsible for assisting in the development of police 

capabilities. INL, as the program execution office, used the Iraq Relief and 

Reconstruction Fund (IRRF) to provide funding for Iraqi police training and assigned a 

contracting officer representative (COR) to monitor contract activities. The DoS Office of 

Acquisition Management provided contracting officer support to INL. 

To assist in achieving its mission, the DoS awarded contract number S-LMAQM-04-C0030 to DynCorp International, LLC (DynCorp), on February 18, 2004. The contract was 

for a base year and four one-year options and had a potential value of about $1.8 billion. 

As part of this contract, DoS issued task order number 0338, with a not-to-exceed value 

of $188.7 million in June 2004, to DynCorp for an initial 3-month period to provide: 

training services for international police liaison officers; training support equipment; 

construction of a residential camp on the Adnan Palace grounds in Baghdad to house 

training personnel; and construction of five regional camps at selected locations in Iraq. 

As of October 14, 2006, INL authorized, and DoS paid DynCorp $150.8 million for work 

performed through May 2006 under Task Order 0338. There was an additional 

$1.1 million in labor cost that was invoiced by DynCorp in October 2006 for which INL 

approved provisional payment on November 8, 2006, subject to subsequent reviews, 

audits, and appropriate adjustments. The bulk of activity under this task order was 

completed by October 22, 2004, but activities related to the residential camp continued to 

at least June 2006. Subsequent activities regarding the relocation of trailers purchased 

under Task Order 0338 for the residential camp and their continued storage were 

executed under a separate task order (number 1436) with DynCorp. The actions relating 

to the establishment of the residential camp, as contained in Task Order 0338, and the 

performance of unauthorized work by DynCorp are the principal focus of this report. 

The Special Inspector General for Iraq Reconstruction (SIGIR) and the DoS Office of the 

Inspector General jointly conducted this review. 

 i 
Objectives 

The objectives of this audit were to answer the following questions: 

• What were the costs associated with the subject contract Task Order 0338, 

including amounts obligated and expended, potential liabilities, and controls over 

these costs? 

• What is the status of property purchased under Task Order 0338 including related 

internal controls, and what is the salvage value for unused assets? 

• What is the cost and program impact of the stop-work order affecting the 

construction of police training facilities at the Adnan Palace? 

• What is the status of construction of facilities to support provincial police training 

programs? 

To respond to the audit objectives we structured the report in three sections: 

• cost incurred under Task Order 0338 

• construction of the Adnan Palace residential camp and regional camps 

• contracting and contract management 

These sections in total address each of the original audit questions. We focused our work 

on supplies and services provided under Task Order 0338, as it represented the bulk of 

spending under the task order. Within supplies and services, we narrowed our focus on 

the work to be done and items to be provided for the $51.6 million residential camp and 

the $36.4 million of equipment to be procured. We did not include an assessment of the 

regional camps in this review but plan to address them in our continuing review of T.O. 

0338 and DynCorp contract S-LMAQM-04-C-0030 and other INL expenditures of IRRF. 

Results 

Poor contract administration by INL and the DoS Office of Acquisition Management 

resulted in millions of dollars put at unnecessary risk, and property that can not be 

accounted for that was acquired under Task Order 0338. Specifically, between July 2004 

and June 2006, DoS paid about $43.8 million for manufacturing and temporary storage of 

a residential camp that has never been used, including $4.2 million for unauthorized work 

associated with the residential camp. In addition, DoS may have spent another 

$36.4 million for weapons and equipment, including armored vehicles, body armor, and 

communications equipment that cannot be accounted for because invoices were vague 

and there was no backup documentation or property book specifically for items 

purchased under Task Order 0338. 

A key part of Task Order 0338 was the manufacture and installation of a residential camp 

to house 1,040 police training and advisor personnel with associated facilities including 

dining and office space. To accomplish this, DynCorp issued a subcontract valued at 

$55.1 million to Corporate Bank Financial Services (Corporate Bank), on 

 ii 
August 15, 2004, which in turn subcontracted with an Italian manufacturing firm, Cogim 

SpA, on September 1, 2004, for $47.1 million. A total of 1,048 trailers were to be 

manufactured. Because of security concerns, INL officials decided to cancel the 

residential camp project in September 2004. On or about September 23, 2004, the DoS 

contracting officer communicated to DynCorp INL’s decision not to proceed on the 

camp. DynCorp, in turn, issued a stop-work order to Corporate Bank on September 25, 

2004. 

Based on our review, we identified the following series of events concerning the 

residential camp: 

• We found contradictory information on the actual status of trailer manufacturing 

for the residential camp, as of September 2004. DynCorp issued the subcontract 

for the residential camp to Corporate Bank on August 15, 2004, and Corporate 

Bank in turn issued a subcontract to Cogim SpA on September 1, 2004. 

According to an INL internal review report, the manufacturing had actually begun 

in May 2004—more than three months before the subcontract for the residential 

camp project was issued. In addition, on July 30, 2004, DynCorp submitted an 

invoice to DoS that included $18.0 million in mobilization fees for the residential 

camp for the period of April 17, 2004, through May 16, 2004. However, it is not 

clear what costs were attributable to the mobilization or whether these costs were 

a prepayment, because DynCorp did not issue a subcontract to Corporate Bank 

until August 15, 2004. According to the DoS contracting officer, when DynCorp 

issued the stop-work order to Corporate Bank in September 2004, DoS was told 

by DynCorp that the residential camp had been completed. 

• We found no information to indicate that any INL official or the COR questioned 

why DynCorp submitted an invoice for mobilization fees for the residential camp 

before it had subcontracted for the manufacture of the trailers. Nor did INL seek 

to determine the actual status of the work when DynCorp was notified not to 

proceed, given the $18 million paid to DynCorp for mobilization fees for the 

residential camp. Rather, INL relied on DynCorp’s representations. As such, the 

true status of the manufacturing effort was unknown as of the issuance of the 

notice. 

• INL appears to be making some recent progress after about two years of 

attempting to find a resolution for the use of the residential camp trailers. In May 

2006, we communicated our concern to the COR about moving the residential 

camp components from one storage location to another before formalizing plans 

for their ultimate use. Notwithstanding our concerns, the COR authorized 

DynCorp to move the trailers to the Baghdad International Airport. On June 24, 

2006, DynCorp entered into a subcontract to obtain open and covered storage and 

security for the trailers at the Baghdad International Airport for an initial period of 

three months to two years. On September 7, 2006, INL told us that it planned to 

use the trailers to house INL’s personnel, but faced complications due to limited 

availability of land and high demand that was driving up costs in the area near the 

Baghdad airport. As of January 18, 2007, INL appears to be making progress in 

 iii 
resolving the use of the trailers in that discussions are underway for an alternative 

use of the trailers at the Baghdad Embassy. 

• Of the approximately $43.8 million spent on the residential camp, $4.2 million 

was for work that was not contractually authorized—the Iraqi Ministry of Interior 

directed the work but DoS, as the contracting agency, never authorized it. The 

unauthorized work included relocating the residential camp to outside of the 

Adnan Palace grounds, manufacturing an additional 20 VIP trailers, and 

construction of an Olympic size swimming pool on the palace grounds. 

Weak and sometimes non-existent contract administration was the root cause of the 

problems we identified with work performed under Task Order 0338. Our review of the 

actions taken by the DoS contracting officer and INL COR during the performance 

period of Task Order 0338 indicated that neither performed key responsibilities assigned 

by the DoS Foreign Affairs Handbook for contract administration. For example, the INL 

COR was responsible for accepting contractor work, informing the contracting officer of 

performance failure, and maintaining a COR file. However, we found no evidence that 

the COR performed or properly documented any of these activities. Further, for more 

than a decade, the INL COR assigned to Task Order 0338 has also been responsible for 

monitoring other DynCorp police contracts and task orders for INL. Many of the 

problems we identified were associated with this COR’s performance on this task order 

and had been identified and previously reported in a March 2002 DoS Office of Inspector 

General report on U.S. police support in Bosnia.1

 

The Foreign Affairs Handbook does not address the maximum length of time personnel 

should serve as a contracting officer or COR for the same contractor. In July 2006, 

correspondence on contract management2

 provided to the House and Senate Armed 

Services Committees and the Government Accountability Office noted that tenure can 

become a vulnerability if the control environment in an organization is weak. The results 

of our review of Task Order 0338 suggest that, at least for this task order, the control 

environment has been weak. However, although there have been several DoS contracting 

officers for Task Order 0338 over the past two years, the INL COR has been assigned to 

this and other DynCorp contracts/tasks orders since 1994—a 12-year period. 

In December 2005, INL issued an asset verification report documenting that DynCorp 

could not provide a complete property book and backup documentation for items it 

purchased for the U.S. government. The report concluded: 

• DynCorp invoices were frequently ambiguous and lacked the level of detail necessary 

to determine what was procured. 

• DynCorp did not maintain a complete list of items procured. 

• DynCorp did not establish policy guidance or accountability procedures. 

 

1

 Department of State, Office of Inspector General, Review of U.S. Support to the International Police Task 

Force in Bosnia, Memorandum Report AUD/PPA-02-20, March 2002. 2

 U.S. Government Accountability Office, Contract Management: DOD Vulnerabilities to Contracting 

Fraud, Waste, and Abuse, GAO-06-838R, July 7, 2006. 

 iv 
The report also concluded, “INL cannot determine if the bureau received what it paid 

for.” In our review we found that the invoices for Task Order 0338 lacked the level of 

detail to determine what was procured and that the U.S. government or DynCorp did not 

maintain a complete list of items procured under Task Order 0338. Further, we found that 

the COR, although responsible for inspecting and accepting contractor work, did not 

ensure that DynCorp maintained proper inventory control records or maintain the records 

personally for the $36.4 million of proposed equipment that was to be procured under this 

task order. 

Management Control Weaknesses 

During the audit we identified management control weaknesses in the timely issue of task 

order modifications, the process of documenting the review of contractor invoices, and 

the administration of the task order. This report includes recommendations to strengthen 

internal controls needed to improve the DoS contracting and administration of the task 

order. Further, because INL reported similar conditions in its December 2005 INL asset 

verification report, we have no reason to believe that the management internal control 

weaknesses in this task order are isolated. Therefore, SIGIR intends to continue the 

review of Task Order 0338, and will announce a full review of contract S-LMAQM-04-

C-0030 and other expenditures by INL in Iraq. 

Management Actions 

In November 2005, INL’s Principal Deputy Assistant Secretary met with the DoS 

Inspector General and subsequently with DoS Investigations to discuss concerns of 

potential fraud with Task Order 0338. Specifically, INL disclosed that DynCorp had 

billed INL for 500 trailers for the residential camp related to this task order that may not 

have been manufactured or completed at the time of billing. The preliminary 

investigation conducted by DoS investigations revealed that INL contacted DoS Office of 

Acquisition Management in October 2005 to discuss its concerns regarding the number of 

trailers actually received and billed under this task order. DoS and SIGIR worked jointly 

on this investigation, and SIGIR has taken the lead and the investigation is ongoing. 

Beginning in 2005, according to INL senior officials, INL initiated a number of steps to 

strengthen its contract and asset management across the Bureau. INL senior managers 

provided the following information: 

• A series of internal reviews were undertaken concerning property controls and an 

inventory of the residential camp trailers related to the DynCorp contract that are 

discussed in this report. 

• Between January and June 2006, INL directed DynCorp to take action on asset 

management improvements. These improvements were documented in a series of 

letters INL exchanged with DynCorp in which INL documented defects in contract 

performance and DynCorp responded by identifying corrective actions it was taking 

or planned to take. Currently, INL is in the process of following up on DynCorp 

inventory control corrective actions. 

 v 
• In June 2006, INL requested assistance from the Defense Contract Management 

Agency in reviewing DynCorp property management practices in Iraq and 

Afghanistan (which the Defense Contract Management Agency declined due to 

property administrator staffing shortages). 

• In October 2006, INL attempted to contract for Defense Contract Audit Agency 

services to close out several DynCorp task orders, including Task Order 0338. As of 

January 18, 2007, the Defense Contract Audit Agency had not responded. 

• On November 2, 2006, INL appointed an overall COR for the DynCorp contract. 

• In January 2007, INL identified an Iraq in-country COR. This person will be on duty 

once all Human Resource actions are finalized. 

• In January 2007, INL began a review to complete contract files, which consisted of 

contracts, task orders, and pertinent documents exclusive of information, such as 

contract evaluation sheets and private e-mail exchanges between a program office and 

the contracting officer. 

• Over the past several months INL has developed a process for thoroughly reviewing 

invoices. This process has already resulted in INL identifying billing errors in a 

DynCorp invoice. For example, INL rejected a January 9, 2007, invoice for $1.1 

million, which was for a different DynCorp contract3. This invoice was rejected 

because INL determined that the billed rate was outside the period of performance 

dates. 

INL also advised us that it was working to ensure internal and management controls are 

in place and adhered to at all times, and intends to reconcile all past payments made since 

the inception of INL contracts in Afghanistan, Iraq, and Jordan. 

We had initially recommended that INL consider replacing the COR for the DynCorp 

contracts and task orders who had held that position since 1994—a 12-year period. INL 

advised us on January 11, 2007: 

• The COR has been replaced. INL also provided the appointment letters for incountry CORs for all INL contracts in Afghanistan and Jordan. 

• The transition of contracting responsibilities took place in November 2006. 

• The Iraq in-country CORs, who will be personal services contractors, had been 

selected and are going through the clearance process. 

We consider INL’s actions to be responsive to the draft recommendation, and therefore 

removed it from the final report. 

 

3

 Contract SAQMPD-04C-1076 

 vi 
Recommendations 

To ensure that DoS conserves IRRF funds and other DoS funds, we recommend that the 

Assistant Secretary for the Bureau for International Narcotics and Law Enforcement 

Affairs: 

1. Present a plan to the U.S. Ambassador to Iraq for review and approval on the use of 

the residential camp to house police trainers, as originally intended, or make 

arrangements to dispose of the camp. Because of the lengthy consideration already 

given to deciding what to do with the trailers, this action should be taken within the 

next 60 days. 

To ensure that contracted work is properly invoiced, payments are proper, and the 

contract is properly managed, we also recommend that the Director, Office of Acquisition 

Management should take these actions: 

2. Seek reimbursement from DynCorp of the improperly authorized payment of 

$4.2 million that represents contractually unauthorized work directed by the Iraqi 

Ministry of Interior. This work included the relocation of the residential camp, the 

manufacture of additional VIP trailers, and the construction of an Olympic size 

swimming pool. 

3. Request the Defense Contract Audit Agency (DCAA) take these actions: 

a. Review the July 30, 2004, DynCorp invoice that included a residential camp 

mobilization fee to determine whether a prepayment of $18.0 million 

occurred. 

b. Review the October 30, 2006, DynCorp invoice for approximately 

$1.1 million pertaining to labor costs associated with Task Order 0338. 

4. On receipt of the DCAA audit report, the contracting officer should take the 

appropriate action. 

5. Enforce procedures to ensure the contracting officer and COR comply with duties and 

responsibilities as identified in the DoS Foreign Affairs Handbook. These procedures 

should address: 

a. receiving and retaining technical and financial reports 

b. examining invoice with supporting documentation before certification for 

payment 

c. processing “receiving and inspection reports” for equipment 

d. maintaining a COR file 

6. Establish and enforce tenure limitations for all contracting personnel, as part of the 

Foreign Affairs Handbook. 

 vii 
Management Comments and Audit Response 

We received written comments on a draft of this report from INL, which incorporated 

comments from DoS Office of Acquisition Management, that they agreed with 

recommendations 1 through 5. INL stated that the Office of Acquisition Management 

disagreed with recommendation 6, regarding tenure limitations, because it has a Quality 

Assurance Plan for reviewing and approving contract actions to ensure that all 

requirements of law, regulation, department policy, and sound procurement practices are 

met. We recognize the importance of a Quality Assurance Plan, but believe that the need 

for tenure limitations is underscored when the control environment in an organization is 

weak. We, therefore, retained the recommendation. 

In response to the draft of this report, INL provided us with information on its 

management actions to strengthen its contract and asset management across INL, which 

is detailed in the management actions section of this Report. INL also provided us with 

technical changes, which were incorporated in the final report as appropriate. 

 viii 
Introduction 

Background 

The Foreign Assistance Act of 1961 authorizes the Secretary of State to assist in 

promoting political and economic changes in a community of nations which respect civil 

and economic rights. Presidential Decision Directive 71, February 24, 2000, directed the 

Department of State (DoS) to strengthen criminal justice systems in support of U.S. peace 

operations and other complex contingencies. The Secretary of State designated the 

Assistant Secretary for the Bureau for International Narcotics and Law Enforcement 

Affairs (INL) as the primary focal point for DoS for all international narcotics and 

international criminal matters. The DoS role, carried out by INL, is both diplomatic and 

programmatic and includes international narcotics control, international crime control, 

and rule of law. 

Bureau for International Narcotics and Law Enforcement Affairs 

In Iraq, INL is responsible for assisting in the development of police capabilities. INL, as 

the program execution office, used the Iraq Relief and Reconstruction Fund (IRRF) for 

training Iraqi police. INL provided trainers and advisors to assist the Coalition 

Provisional Authority to address public security issues, structures, and organizations; 

developed a curriculum to train new and existing Iraqi police and corrections personnel; 

and re-established a police academy in Baghdad. 

INL’s workload increased substantially between 2003 and 2005, which includes the 

period during which activities discussed in this report occurred. In July 2005 the DoS and 

the Broadcasting Board of Governors Office of Inspector General issued an inspection 

report on INL.4

 The inspection took place between February and April 2005 and covered 

executive direction, policy and program implementation, resource management, and 

management controls in INL’s Washington operations and activities. The report stated 

that in the past two years (2003-2005) INL responsibilities and programs have burgeoned 

because of pressing demands in the high priority police training/rule of law programs in 

Iraq and Afghanistan and new counter narcotics challenges in Afghanistan. It also stated 

that INL’s staffing has not increased commensurately with its workload and is a 

significant management challenge facing INL. Consequently, INL submitted a 

reorganization proposal that was approved by DoS in November 2004, adding 34 fulltime domestic positions. It was also reported that the INL reorganization did not address 

the critical staffing requirements for any overseas posts, including Iraq. 

In 2006 INL obtained a commitment from Embassy management in Baghdad for 20 

positions to manage the civilian police and rule of law programs that totaled over $600 

million per year; however, as of January 16, 2007, only 7 are in place. 

 

4

 United States Department of State and the Broadcasting Board of Governors Office of Inspector General, 

Report on Inspection Bureau of International Narcotics and Law Enforcement Affairs, Report Number ISPI-05-14, July 2005. 

 1 
DynCorp International, LLC Contract Number S-LMAQM-04-C-0030 

To assist INL in achieving its mission, the DoS Office of Acquisition Management, 

which provides contracting officer support, awarded contract number S-LMAQM-04-C0030 to DynCorp International, LLC (DynCorp), on February 18, 2004.5

 The contract 

was for a base year and four one-year options and had a potential value of about 

$1.8 billion. The contract is a combination firm-fixed-price, indefinitedelivery/indefinite-quantity, and cost-plus-fixed-fee type contract dependent upon 

whether services, equipment, or construction efforts were being acquired. The contract, 

among other things, required DynCorp to provide housing, training support systems, and 

personnel to support the civilian police training program. 

As part of this contract, DoS issued Task Order 0338 (T.O. 0338) in June 2004 to 

DynCorp for an initial 3-month period to provide and support police trainers and 

construct several camps. The task order, which had a not to exceed value of 

$188.7 million, incorporated DynCorp’s detailed cost proposal. Based on our analysis of 

the cost proposal we identified the value of specific work to be done and items to be 

provided, including DynCorp’s overhead, general and administrative costs, and profit, as 

follows: 

• $51.6 million for the residential camp at the Adnan Palace 

• $38.1 million for the cost of providing training to the Iraqi police 

• $36.4 million for weapons and equipment, including armored vehicles, body 

armor, and communications equipment 

• $25.0 million for miscellaneous supplies and services 

• $17.9 million for constructing regional camps 

• $17.6 million for operations and maintenance for camps 

• $2.1 million for security service for civil police 

We focused our work on supplies and services provided under T.O. 0338, as it 

represented the bulk of spending under the task order. Within supplies and services, we 

narrowed our focus on the work to be done and items to be provided for the $51.6 million 

residential camp and the $36.4 million of equipment to be procured. 

 

5

 AQM awarded two other large contracts in early 2004 for civilian police support in other parts of the 

world. One contract was awarded to Civilian Police International on February 26, 2004, with a value of 

$1.6 billion. Another contract was awarded on March 25, 2004, to a joint venture partnership between PAE 

Government Services and HomeLand Security Corporation with a value of $1.8 billion. 

 2 
Objectives 

The objectives of this audit were to answer the following questions: 

• What were the costs associated with the subject contract T.O. 0338, including 

amounts obligated and expended, potential liabilities, and controls over these 

costs? 

• What is the status of property purchased under T.O. 0338 including related 

internal controls, and what is the salvage value for unused assets? 

• What is the cost and program impact of the stop-work order affecting the 

construction of police training facilities at the Adnan Palace? 

• What is the status of construction of facilities to support provincial police training 

programs? 

To respond to the audit objective we structured the report in three sections, which in total 

address each of the original audit questions: 

• cost incurred under T.O. 0338 

• construction of the Adnan Palace residential camp and regional camps 

• contracting and contract management 

The Adnan Palace camp was to be composed of a series of trailers providing living 

quarters, dining facilities, offices, and training classrooms. The trailers were to be 

manufactured in Italy and shipped to Iraq. Various documents, including DynCorp and its 

subcontractor’s correspondence and DoS email messages, at times refer to the trailers as: 

trailers, containers, and components. For purposes of this report, we use the term trailers 

throughout the report. We also use the term residential camp when referring to the Adnan 

Palace camp. We did not include an assessment of the regional camps in this review but 

plan to address them in our continuing review of T.O. 0338 and DynCorp contract 

S-LMAQM-04-C-0030 and other INL expenditures of IRRF. 

For a discussion of the audit scope, methodology, and prior coverage, see Appendix A. 

For acronyms used in this report, see Appendix B. For distribution of the draft report and 

planned distribution of the final report, see Appendix C. For a list of the audit team 

members, see Appendix D. 

 3 
Costs Incurred Under Task Order 0338 

On June 24, 2004, T.O. 0338 was issued with a not-to-exceed value of $188.7 million, 

and initially was intended to cover the period April 17, 2004, through July 16, 2004. As 

of October 14, 2006, $150.8 million had been paid to DynCorp for work performed 

through May 31, 2006. There was an additional $1.1 million in labor cost that was 

invoiced by DynCorp in October 2006. 

Statement of Work 

The statement of work6 for the task order required DynCorp to among other things: 

• Recruit, select, train, equip and support in the field, 500 International Police Liaison 

Officers (IPLO) personnel, who will be under the operational control of the Civilian 

Police Advisory Training Team that is charged with the mission to establish an Iraqi 

Police Service organization responsible for law enforcement functions throughout 

Iraq; and be prepared to increase from 500 to 750 the number of International Police 

Advisors, if necessary. 

• Purchase additional armored vehicles to meet changing security conditions. 

• Provide a self-contained residential camp to be located within the Adnan Palace 

grounds, Baghdad, Iraq, for 1,040 people with space for all trainers and advisors to 

relocate from local hotels. 

• Install and/or construct, outside Baghdad, additional regional container camps to 

house and support IPLO personnel, including a 64-person camp in Tikrit, and up to 

4 such camps in locations to be identified. DynCorp shall be prepared to provide 

operation and maintenance services. 

Period of Performance 

T.O. 0338 was initially intended to cover the period April 17, 2004, through July 16, 

2004. According to T.O. 0338, DynCorp was given a verbal notice to proceed by the DoS 

contracting officer; however, no date was specified. Following the expiration of the 

original period of performance, there was no new scope of work initiated, and the work 

being performed under T.O. 0338 was not contractually extended. According to 

DynCorp’s ratification proposal, DynCorp stated that because of the importance of this 

program to INL, it continued to perform essential work, as described in the task order, 

during the period July 16, 2004, through October 22, 2004, notwithstanding the fact that 

the task order had expired. As a result, on February 3, 2005, DoS’s Office of Acquisition 

Management senior procurement officials and INL senior officials retroactively approved 

that work, an action which is discussed in detail later in this report.

 

6

 Task Order 0338 incorporated the DynCorp cost proposal dated June 3, 2004 for the execution of the 

Statement of Work. 

 4 
One element of the task order statement of work was the construction of a residential 

camp composed of trailers that would be manufactured outside of Iraq and shipped to the 

Adnan Palace grounds in Baghdad, Iraq. The trailers were manufactured, but put into 

storage. Billing of storage and related costs continued through May 2006. On June 25, 

2006, further activity relating to storing and moving the trailers was shifted to another 

task order on the DynCorp contract, number 1436. Task Order 1436 is a broad task order 

directing the continuation of support to the civilian police training program. Activities 

concerning the trailers are discussed in detail later in this report. 

Funds Available and Amounts Paid 

T.O. 0338 was issued on June 24, 2004, with a not-to-exceed value of $188.7 million. 

The INL contracting officer representative (COR) approved the payment of 

$150.8 million for work performed through May 31, 2006, under the task order. As 

shown in Table 1, DoS deobligated a total of $36.6 million. This consisted of 

$34.3 million deobligated on December 13, 2005, and an additional $2.3 million 

deobligated on June 28, 2006. The June 2006 deobligation was based on a DoS 

evaluation of invoices paid to date and a DynCorp estimate of further storage and security 

costs. 

Table 1 – Funds Available Under Task Order 0338 

Event Amount

Original Task Order Authorization $188,734,225.85

Funds Deobligated 36,582,795.65

Net Available Task Order Funds 152,151,430.20

Costs paid for work performed through May 

31, 2006 150,812,220.81

Remaining Balance $1,339,209.39

Source: Developed by SIGIR from DoS data as of September25, 2006. 

Subsequently, on October 30 2006, DynCorp submitted an invoice for about $1.1 million 

for labor costs associated with this task order for the performance period April 17, 2004, 

to July 16, 2004. INL approved provisional payment of the invoice on November 8, 

2006, subject to subsequent reviews, audits, and appropriate adjustments. 

 5 
Construction of the Camp at Adnan Palace 

T.O. 0338 required the construction of a residential camp to house the civilian police 

trainers at the Adnan Palace in Baghdad and 5 regional camps elsewhere in Iraq. Due to 

security concerns the residential camp was not completed, but over time all the trailers 

that were to comprise the camp were manufactured and placed in storage. Although DoS 

has paid about $43.8 million for work associated with the trailers, according to INL 

officials, they have been yet to implement their plan for the use of the trailers but are 

making progress in doing so. T.O 0338 also required the installation/construction of 

regional camps. While $17.9 million was reported as paid for these regional camps, these 

camps were not included in the scope of this review. We plan to address during a future 

review of INL and its use of IRRF funds. 

Residential Camp Construction 

One of the key tasks assigned to DynCorp under T.O. 0338 was the manufacture and 

installation of a residential camp for 1,040 police training and advisor personnel with 

associated facilities including dining and office space. At the request of INL program 

officials, DynCorp prepared a fixed price cost proposal, June 3, 2004, for the camp, 

which estimated the cost—including manufacturing and installing the trailers—would be 

$51.6 million including DynCorp’s overhead, general and administrative costs, and 

profit. On August 15, 2004, DynCorp issued a subcontract to Corporate Bank Financial 

Services (Corporate Bank), in the amount of $55.1 million to plan for and provide the 

residential camp; including $47.1 million for the camp, $5.2 million for general and 

administrative expenses, and $2.8 million for profit.7 On September 1, 2004, Corporate 

Bank in turn issued a subcontract to Cogim SpA, located in Italy, in the amount of $47.1 

million, to plan for and provide the residential camp. A total of 1,048 trailers were to be 

manufactured by Cogim SpA. 

On or about September 23, 2004, the DoS contracting officer communicated to DynCorp 

INL’s decision not to proceed with the manufacture and installation of the camp. This 

decision was based on a late September 2004 site visit by senior INL program officials, 

during which INL concluded that the residential camp at the Adnan Palace posed a 

security risk to personnel working and living at the camp. Upon receipt of this 

instruction, on September 25, 2004, DynCorp issued a written “stop-work” order to its 

subcontractor, Corporate Bank, to stop all work associated with construction of the camp. 

According to DynCorp, Corporate Bank then sent a stop-work order to its subcontractor, 

Cogim SpA, to cease work and the project was put on hold. 

 

7

 DynCorp’s $51.6 million cost proposal for the camp was incorporated into Task Order 0338 by DoS’s 

Office of Acquisition Management. Neither the cost proposal nor DynCorp’s subcontract with Corporate 

Bank explains why DynCorp subcontracted the trailer manufacture for more than its fixed price cost 

proposal. DynCorp was ultimately paid $43.2 million for the trailers’ manufacture as documented in its 

invoices and liquidation proposal and subsequently paid an additional $565,798 for storage costs under TO 

0338. 

 6 
We found contradictory information on the actual status of trailer manufacturing for the 

residential camp, as of September 2004. DynCorp issued the subcontract for the 

residential camp to Corporate Bank on August 15, 2004, and Corporate Bank in turn 

issued a subcontract to Cogim SpA on September 1, 2004. According to an INL internal 

review report, the manufacturing had actually begun in May 2004—more than three 

months before the subcontract for the residential camp project was issued. In addition, on 

July 30, 2004, DynCorp submitted an invoice to DoS that included $18.0 million in 

mobilization fees for the residential camp for the period of April 17, 2004, through May 

16, 2004. However, it is not clear what costs were attributable to the mobilization or 

whether these costs were a prepayment, because DynCorp did not issue a subcontract to 

Corporate Bank until August 15, 2004. According to the DoS contracting officer, when 

DynCorp issued the stop-work order to Corporate Bank in September 2004, DoS was told 

by DynCorp that the residential camp had been completed. 

However, DynCorp subsequently reported that it was not complete. On September 21, 

2005, more than one year after the issuance of the stop-work order, DynCorp provided 

INL program officials with a status report on the trailers, stating that the materials were in 

various stages of completion. On September 27, 2005, DynCorp advised INL program 

officials that 500 units (i.e. trailers) had not yet been manufactured. Since the camp was 

to consist of about 1,048 trailers, we calculated that just over half had been manufactured 

as of September 27, 2005. 

We reviewed records from DoS, INL, and the contractors, we were able to put together a 

timeline of events based on available information and interviews, as shown in Table 2. 

 7 
Table 2 – Chronological Events of Task Order 0338 - Trailers 

Date Event 

2/18/04 Indefinite Delivery/Indefinite Quantity contract S-LMAQM-04-C-0030 awarded to DynCorp. 

This was a base year and 4 one-year options to provide a cadre of experienced law 

enforcement personnel to provide police training to Iraqis and to provide logistics and 

administrative support to the law enforcement personnel. 

5/04 According to a May-June 2006 INL internal review report on the residential camp, “in May 

2004, INL and DynCorp began a project to establish a camp on the grounds of the Adnan 

Palace to provide life support for all of police. For numerous reasons, the Civilian Police 

Advisory Training Team (CPATT) decided to scrub the project. According to records, that left 

INL and DynCorp holding the camp that was located in Italy, northern Iraq, and Baghdad.” 

This internal review report also stated that the manufacturer, Cogim SpA, began delivery of 

parts to storage in Zakho, Iraq, in May 2004. 

6/24/04 T.O. 0338 awarded with a performance period 4/17/04 – 7/16/04. Verbal authorization (date 

was not specified in DoS contract files) to proceed was provided before the task order was 

formally awarded. 

7/30/04 DynCorp invoices DoS for camp mobilization (4/17/04 – 5/16/04) for $18.0 million. 

8/15/04 DynCorp awards $55.1 million subcontract to Corporate Bank for trailers. Specifies that 

contractor is to plan and provide for a self contained residential camp. 

9/01/04 Corporate Bank subcontracts with Cogim SpA, Italy for trailer manufacturing (actually signed 

by both parties on 9/6/04). This contract was valued at $47.1 million. 

9/04 According to a May-June 2006 INL internal review report, there were 222 erected units in 

Zakho, Iraq. 

9/23/04 DoS contracting officer tells DynCorp “not to proceed” with the manufacture and installation 

of the camp. In a June 27, 2006, discussion, the DoS contracting officer told SIGIR that a “not 

to proceed” was issued orally as opposed to “stop work” because he was told by DynCorp that 

manufacturing of the trailers had not begun. However, in an October 18, 2005, communication 

within the Office of Acquisition Management the same contracting officer stated that DynCorp 

told DoS that the camp was completed. This illustrates the confusion over the status of the 

residential camp. 

9/25/04 According to a May 5, 2005, memorandum from the President of Corporate Bank to DynCorp: 

DynCorp official issued a “stop-work” order to Corporate Bank. Corporate Bank further stated 

that Corporate Bank “immediately makes (sic) all reasonable steps to cease and minimize the 

incurrence of costs allocable to the work order”. 

The “stop-work” order was for 90 days; extended for additional 30 day periods on December 

15, 2004, January 21, 2005, and again on February 19, 2005. According to several interviews, 

there was a belief that the order would be eventually made but this never happened. 

10/22/04 DoS states that the bulk of activity under this task order was completed by October 22, 2004. 

However, activities related to the residential camp continued to at least June 2006. 

2/3/2005 INL and DoS contracting officer accepts DynCorp ratification proposal that it continued to 

perform work after the task order period of performance expired. 

 8 
Date Event 

5/05/05 In a May 5, 2005, Corporate Bank memorandum to DynCorp addressing the residential camp, 

Corporate Bank states that by September 2004, the trailers were almost complete with a few 

components needing assembly. 

9/07/05 DynCorp invoices DoS for $25.2 million for Corporate Bank’s materials, sunk costs, storage 

cost (Italy and Iraq), and personnel (Italy and Iraq). 

9/21/05 DynCorp reports to INL “that materials were in various stages of completion.” 

9/27/05 DynCorp advises INL that 500 trailers had not been manufactured. 

10/12/05 In an email to a senior DoS contracting official, DynCorp states that “the majority of the set is 

complete and ready to move to storage. The factory is finalizing assembly on the last 500 

containers that were in production when the stop-work order was issued.” 

10/17/05 DynCorp asks DoS contracting officer, “when can we expect the go ahead to complete the 

assembly and move camp into a storage facility under DynCorp control?” 

10/18/05 DoS contracting officer emails DynCorp stating that, “you are hereby authorized to move the 

containers into storage.” SIGIR found no record where there was any authorization to 

complete the assembly. 

12/13/05 DoS deobligates $34.2 million from task order. 

5/25/06 COR advises SIGIR that the trailers may be moved to the Baghdad International Airport 

(BIAP). SIGIR recommended to the COR that the trailers should not be moved until there is a 

plan defining the use of the trailers. COR responds that a plan is being developed and should 

be completed before any decision to move the trailers is made. 

6/06 In an August 2006 meeting with INL officials, SIGIR was told that sometime around June the 

COR advised the DoS contracting officer of a requirement to move trailers to BIAP. 

6/23/06 DynCorp invoices for storage costs from 11/1/05 – 5/31/06 for $565,798. 

6/24/06 DynCorp subcontracts security and trailer storage at BIAP for 3 months. 

6/25/06 DoS issues modification to Task Order 1436 to DynCorp for variety of efforts including the 

movement of trailers to BIAP. 

6/28/06 DoS deobligates an additional $2.3 million from task order. 

9/07/06 SIGIR is told by INL’s Controller/Executive Director that INL had been unable to implement 

its plan for the use of the trailers. 

10/14/06 DynCorp advises DoS that the trailers arrived at Baghdad International Airport. 

10/30/06 DynCorp submits an invoice for about $1.1 million for labor costs for the performance period 

ending July 16, 2004.

 9 
Based on this series of events, that at the time of the September 2004 stop-work order, it 

is unclear to us as to whether a large number of the trailers had been manufactured prior 

to authorization. We found no information to indicate that any INL official or the COR 

questioned why DynCorp submitted an invoice for mobilization fees for the residential 

camp before it had subcontracted for the manufacture of the trailers. Nor did INL seek to 

determine the actual status of the work when DynCorp was notified not to proceed, given 

the $18 million paid to DynCorp for mobilization fees for the residential camp. Rather 

INL relied on DynCorp’s representations. As such, the true status of the manufacturing 

effort was unknown as of the issuance of the notice. We believe that had the COR 

pursued the matter, DoS might have been able to take steps to ensure that the government 

did not make any improper payments for any trailers manufactured after the work was 

contracted and before the stop-work order was issued. Instead, through June 2006, DoS 

has paid about $43.8 million for the trailers’ manufacture and for their storage and 

security between September 2004 and May 2006. 

When we discussed the results of our work with senior INL officials on August 30, 2006, 

the INL officials voiced concern that INL was invoiced for work not yet completed. We 

analyzed the DynCorp invoices and identified three invoices that relate to the residential 

camp for a total of about $43.8 million. 

• The first invoice, dated July 30, 2004, included a “mobilization fee” for the 

residential camp ($18.0 million). However, it is not clear what costs were 

attributable to the mobilization or whether these costs were a prepayment, as 

DynCorp did not issue a subcontract to Corporate Bank until August 15, 2004, for 

the residential camp. 

• The second invoice, submitted on September 7, 2005, concerned settlement cost 

associated with the residential camp cancellation and was for an additional 

$25.2 million. 

• A third invoice was subsequently submitted on June 23, 2006, by DynCorp, for 

$565,798 for additional storage costs for the residential camp for the period 

November 1, 2005, through May 31, 2006. 

Since DynCorp subsequently advised INL that almost half of the trailers had not been 

manufactured as of September 21, 2005, INL’s concerns seem to be valid. We are 

making a recommendation to address this matter. In addition, SIGIR is continuing to 

review invoices concerning the ordering, manufacturing, delivery, and storage of the 

camp components including the trailers. 

In addition to paying for trailers that were no longer needed for their original purpose of 

housing police trainers, for the past two years, senior INL officials have been trying to 

develop a plan for the use or disposition of the trailers and, in January 2007, may have 

found a partial solution. At various times in 2005, INL officials considered donating the 

trailers for various uses, including earthquake relief in Pakistan and hurricane relief in the 

United States following Hurricane Katrina. Actions that followed included: 

 10 
• In October 2005, DoS requested DynCorp to provide information on the 

residential camp’s disposal. 

• In early November 2005, DynCorp provided a liquidation proposal that addressed 

the elements that DoS requested and provided a spreadsheet that included 

proposed storage costs for the trailers. 

• On May 25, 2006, the INL COR, who is also the Iraq Program Manager for INL, 

told us he was planning to move all the trailers from their current storage 

locations in Italy and northern Iraq to the Baghdad International Airport, place 

them in storage there. 

• On May 25, 2006, we communicated our concern to the COR about moving the 

residential camp components from one storage location to another before 

formalizing plans for their ultimate use. 

• Notwithstanding our concerns, the COR authorized DynCorp to move the trailers 

to the Baghdad International Airport. Senior INL officials told us that key factors 

in the decision to move the trailers were security issues associated with housing 

INL personnel in insecure areas in Iraq and the cost of maintaining personnel in 

hotels there, estimated at $28 million annually. 

• On June 24, 2006—one day before the task order to move the trailers was 

issued—DynCorp entered into a subcontract to obtain open and covered storage 

and security for the trailers at the Baghdad International Airport for an initial 

period of three months (at an initial cost of $275,000), and for as long as two 

years. 

• On June 25, 2006, DoS issued a fixed priced task order, number 1436, to 

DynCorp for $4.6 million to move the trailers to the Baghdad International 

Airport. 

• On September 7, 2006, however, INL told us that it had not been able to 

implement its plan to use the trailers to house its personnel at the Baghdad airport 

because of complications due to limited availability of land and high demand that 

was driving up costs in the area near the Baghdad airport. The plan to use the 

trailers to house its personnel is INL’s preferred option. Should it prove 

impossible to locate the camp at the airport, another option being considered by 

INL is to use the trailers to house Iraqi judges and witnesses. According to INL, 

as the security situation has deteriorated, security for judges and witnesses has 

become a high U.S. government priority. INL did not say where it would put the 

trailers if it implemented this option. Finally, INL said that it could donate the 

trailers to the Ministry of the Interior. 

• As of January 18, 2007, INL appears to be making progress in resolving the use 

of the trailers in that discussions are underway for an alternative use of the trailers 

at the Baghdad Embassy. 

 11 
Performance of Unauthorized Work 

The statement of work provided DynCorp by DoS directed that the residential containers 

be placed within the Adnan Palace grounds. On June 14, 2004, during the initial 

construction of the camp, the Chief of Staff of the Coalition Provisional AuthorityMinistry of the Interior approved an Iraqi Ministry of Interior statement of requirements 

for the Adnan Palace site. The statement called for relocating the camp outside the Adnan 

Palace grounds on an adjacent 21-acre plot. The Ministry of Interior also established a 

requirement for the manufacture and installation of 20 additional camp trailers for VIP 

quarters and construction of an Olympic size swimming pool on the Adnan Palace 

grounds. Documentation indicated the Ministry of Interior directed that the VIP trailers 

and the swimming pool be constructed within the Adnan Palace grounds and “be 

completed without delay.” 

We could find no documentation in the DoS contract file showing that the residential 

camp relocation, the construction of VIP quarters, or the swimming pool were authorized 

modifications to the task order statement of work. According to the Federal Acquisition 

Regulation 43.102, “only contracting officers acting within the scope of their authority 

are empowered to execute contract modifications on behalf of the Government.” In 

discussing this work with DynCorp officials they recognized the importance of only 

doing contractually authorized work and said they believed they had been contractually 

authorized to perform the work but had no supporting documentation. In the absence of 

DoS and DynCorp documentation showing that the work was authorized by the 

contracting officer it appears that the changes directed by the Coalition Provisional 

Authority on behalf of the Ministry of Interior, and consequently, the actions by 

DynCorp, were not contractually authorized, and that any costs associated with those 

changes were improper charges to the task order. 

The September 7, 2005, invoice submitted by DynCorp for $25.2 million in settlement 

costs, included $4.2 million for costs associated with a decision to relocate part of the 

camp outside the Adnan Palace grounds and design changes related to this decision. It 

also included costs associated with manufacturing the VIP trailers and constructing the 

swimming pool. During our exit conference with senior INL officials, they stated to us 

that they stopped the unauthorized work at the end of September 2004 when the changes 

came to their attention during a trip to Iraq. These costs were incurred prior to receipt of 

the late September 2004 DoS contracting officer’s instruction to “stop work.” However, 

INL’s COR approved the invoice for payment notwithstanding the lack of documentation 

contractually authorizing the work. 

Regional Camps 

T.O. 0338 also required that DynCorp construct five regional camps at selected locations 

in Iraq. The regional camps were to house and provide facilities to support IPLO 

personnel while providing police mentoring to Iraqi police officers. The task order set a 

firm fixed-price for the regional camps of $17.9 million including overhead, general and 

administrative costs, and profit. DynCorp built the camps, located at Tikrit, Mosul, 

Ramadi, Sulaymniayah, and Diwaniyah. Figure 2 indicates the location of the regional 

 12 
camps. Although DynCorp billed, the COR authorized, and DoS paid $17.9 million, the 

INL COR told us that he never visited the sites due to security concerns and had relied on 

reports from others regarding the status of the camps. SIGIR plans to visit these camps as 

we continue to review T.O. 0338 and Contract S-LMAQM-04-C-0030. 

Figure 2 – Regional Camps Constructed in Iraq Under Task Order 0338 

Regional Camps 

Source: Developed by SIGIR from information provided by DynCorp as of July 2006. 

 13 
Contracting and Contract Management 

The contracting officer and the COR are essential acquisition personnel for ensuring an 

efficient acquisition process. According to DoS’ Foreign Affairs Handbook, the 

contracting officer and COR are the most directly involved in the placement and 

administration of a contract by the U.S. government. DoS contracting officials 

responsible for T.O. 0338 did not perform many of the key responsibilities set out in the 

Foreign Affairs Handbook for contracting officers and CORs. As a result, our review 

showed that DynCorp was not provided sufficient direction and that DoS both incurred 

unnecessary costs and retroactively approved work performed by DynCorp that was not 

initially contractually authorized. 

Foreign Affairs Handbook Requirement 

The Foreign Affairs Handbook identifies the roles and responsibilities of both the 

contracting officer and the COR. According to the handbook, responsibilities of the 

contracting officer include: 

• establishing contract terms, conditions and general provisions, including the 

methods of pricing, paying, and financing 

• administering the contract, including the execution of contract modifications and 

other changes 

• closing out or terminating contracts 

• signing the contract 

• appointing the contracting officer’s representative, who will have limited 

authority to act for the contracting officer 

A COR, who is appointed by the contracting officer, assists in the administration of the 

contract. The COR is responsible for: 

• defining project requirements 

• monitoring the contractor’s technical progress and expenditures 

• performing inspection and acceptance of work on behalf of the U.S. government 

• reporting to the contracting officer any issues which cannot be resolved without 

additional cost or time 

• informing the contracting officer in writing of any needed changes in the 

statement of work 

• reviewing and approving contractor invoices 

• maintaining a COR file 

 14 
The Foreign Affairs Handbook also states that in certifying invoices, the COR is 

responsible for verifying the accuracy and propriety of all documents and that the 

certified payment is legal, correct, and proper. The Handbook further states that the COR 

executes acceptance by processing a “receiving and inspection report,” or by approving 

the contractor’s invoice. 

Contracting Officer and COR Did Not Perform a Number of 

Their Responsibilities 

Our review of the responsibilities of the contracting officer and COR during the 

performance period of T.O. 0338 indicated that the contracting officer did not perform 

key responsibilities assigned by the Foreign Affairs Handbook and that the COR 

performed few, if any, of a COR’s responsibilities or if they were performed failed to 

document them.

As shown in Table 3, the contracting officer performed some of his responsibilities and 

did not administer the contract to include modifications and changes. Our review of T.O. 

0338 showed that a number of contracting actions were not performed. Specifically, the 

contracting officer: 

• Allowed the original period of performance to expire and DynCorp to continue to 

work for three months beyond the original period of performance, which resulted in 

the issuance of a ratification action to retroactively approve the contractor’s continued 

performance. 

• Never officially issued a notice not to proceed after the decision was made to not 

build the residential camp. 

• Did not issue a task order modification directing the storage of the residential camp. 

Table 3 – Contracting Officer Responsibilities and Analysis of Performance for 

T.O. 0338 

Responsibilities per DoS Foreign 

Affairs Handbook Fully Performed 

Not Performed or 

Not Fully Performed 

No Evidence That 

Performed 

Establish contract terms, pricing, 

paying and financing 3

Appoint the COR with limited 

authority 3

Sign the contract and appropriate 

modifications 3

Administer contract to include 

modifications and changes 3

Source: Developed by SIGIR from the Foreign Affairs Handbook and DoS records as of July 2006. 

 15 
Furthermore, while the contracting officer did appoint a COR, he did not identify the 

COR’s responsibilities. However, according to the DoS Acquisition Regulation 642.270, 

all personnel assisting the contracting officer should have a clear delegation of 

responsibilities. 

Although the COR for T.O. 0338 has been responsible for monitoring civilian police 

contracts for more than a decade, including INL’s current contract with DynCorp, for 

T.O. 0338, the COR performed few, if any, of a COR’s responsibilities adequately, or if 

they were performed, failed to document them, as shown in Table 4. The COR was also, 

at the same time, the INL Director of the Civilian Police and Rule of Law programs. The 

DoS contract files show that the Director has been the COR, monitoring DynCorp police 

contracts, since 1994. Although the Director never completed COR training, the 

contracting officer determined that the training was not required due to his years of 

experience. However, according to the DoS Acquisition Regulation 642.270, all 

personnel assisting the contracting officer should have appropriate training. Further, as 

discussed later, the same COR was cited in 2002 by the DoS Office of Inspector General 

for not receiving required training. 

Table 4 – Contracting Officer’s Representative Responsibilities and Analysis of 

Performance for T.O. 0338 

Responsibilities per DoS Foreign 

Affairs Handbook Fully Performed 

Not Performed or 

Not Fully Performed

No Evidence 

That Performed 

Monitor contractor progress and 

expenditures 3

Inspect and accept contractor work 3

Inform contracting officer, in writing, of 

any performance or schedule failure 3

Review and approve contractor 

vouchers or invoices 3

Maintain a COR file 3

Source: Developed by SIGIR from the Foreign Affairs Handbook and DoS records as of July 2006. 

 16 
Our review of T.O. 0338 identified a number of shortcomings in the COR’s performance 

of stated responsibilities, such as: 

• Monitor contractor progress. There were a number of instances where the COR 

did not monitor performance. 

o As discussed earlier, in June 2004, DynCorp performed work directed by 

the Iraqi Ministry of Interior that was not contractually authorized by DoS. 

INL documentation shows that it was not until late-September 2004 that 

INL officials became aware of the changes the Ministry of Interior 

directed in June 2004. Closer monitoring of the DynCorp effort by the 

COR could have stopped the work directed by the Ministry of Interior 

before it was performed. 

o Also as discussed, at the time of the stop-work order on the residential 

camp, a substantial amount of manufacturing had not been completed—a 

fact that became known to DoS a year later. More aggressive oversight by 

the COR in seeking to determine the status of the work when DynCorp 

was notified not to proceed, rather than relying on DynCorp’s 

representations could have allowed the COR to learn the true status of the 

work. Given the $18 million paid to DynCorp for mobilization fees for 

the residential camp, DoS might have been able to take steps to ensure that 

the government did not make any improper payments for any trailers 

manufactured after the work was contracted and before the stop-work 

order was issued. Instead, the COR approved a July 30, 2004, invoice 

submitted by DynCorp that included mobilization fees for the residential 

camp, although DynCorp had not yet subcontracted for the manufacture of 

the camp. 

• Accept contractor work. The COR is required to ensure that contractor acquired 

equipment is properly obtained and safeguarded. Under the basic contract 

DynCorp was required to provide inventory control of acquired equipment and 

supplies. 

o Under T.O. 0338 DynCorp, on behalf of INL, was to purchase a wide 

array of equipment to support police training including armored vehicles, 

weapons, night vision goggles, body armor, and communications 

equipment. It was the COR’s responsibility to ensure that the contractorpurchased items for the U.S. government meet contract requirements and 

were under proper contractor control. Our review found that the COR did 

not maintain records to substantiate the review and acceptance of the 

armored vehicles, weapons, goggles, body armor, or any communications 

support equipment. According to the DynCorp proposal this was valued at 

$36.4 million. 

o Regarding the trailers manufactured for the residential camp and 

subsequently stored in Iraq and Italy, although they are U.S. government 

property acquired by the contractor, as of July 2006, DoS had not formally 

taken possession of them by obtaining proper documentation. In addition, 

 17 
there was limited documentation to support the inventory related to the 

trailers. An INL inventory, conducted in May-June 2006 at the residential 

camp components storage sites in Italy and northern Iraq, found that no 

single DynCorp document existed that provided a comprehensive list, with 

descriptions, to be able to conduct the inventory. Therefore, our review 

could not definitively identify whether the inventory included all the 

components, although INL staff were able to account for the bulk of the 

components.

o A December 2005 report on an INL asset verification that was conducted 

in July-August 2005, reviewed DynCorp’s inventory control procedures in 

Iraq, Jordan, and Afghanistan. The scope of the review was to determine 

whether adequate asset records were maintained, appropriate controls 

were in place for asset safeguarding, and contract requirements for 

contractor procured assets were satisfied. The study reported that DynCorp 

could not provide a complete property book and backup documentation for 

items purchased by DynCorp for the U.S. government. The report 

concluded that DynCorp invoices were frequently ambiguous, unclear, and 

lacked the level of detail to determine what was procured; that DynCorp 

did not maintain a complete list of items procured; and DynCorp did not 

establish policy guidance or accountability procedures. The report 

concluded “INL cannot determine if the bureau received what it paid for.” 

Other task orders to DynCorp required the acquisition of equipment, but 

without established controls, such as providing detailed identification of 

items procured (i.e. record of serial numbers), it is impossible to determine 

what task order acquired the item and whether DynCorp had previously 

been compensated for the item. Since the COR was the INL representative 

for civilian police contracts and it is the COR’s responsibility to inspect 

and accept contractor work, the COR should have ensured DynCorp 

maintained proper inventory control records.

• Inform contracting officer, in writing, of any performance or schedule failure.

According to the contracting officer, although the COR was his “eyes and ears on 

the ground” in Iraq, the COR repeatedly did not provide him with information on 

work being performed under T.O. 0338 or respond to his requests for information 

about the task order. Consequently, the contracting officer had little knowledge of 

the work that was being performed. 

• Review and approve contractor vouchers or invoices. It is also unclear as to the 

degree of invoice examination the COR performed prior to certifying invoices for 

payment. For example, the COR certified payment of the invoice that included 

$4.2 million of costs associated with the unauthorized Ministry of Interior 

directed work as well as the residential camp mobilization fee invoice prior to 

DynCorp contracting for its construction. In our opinion, contractually the 

unauthorized costs should not have been paid by the DoS. 

• Maintain a COR file. In response to our request for a copy of the COR files for 

T.O. 0338, INL told us that the COR did not maintain a file. As a result of the 

failure to maintain a COR file, key documents are not available. For example, the 

 18 
basic contract that T.O. 0338 was issued under required DynCorp to submit 

monthly technical and financial reports. Our review disclosed that the COR did 

not have the reports. The Foreign Affairs Handbook states that technical and 

financial status reports can be an effective control tool in monitoring performance 

and requires that the COR maintain a file to assist in administrating the contract. 

The only official file we have been able to identify regarding this task order is the 

contract file, which is limited to key contractual documents, including the original 

notice to proceed and formal contract modifications. We have found no 

documentation relating to other actions such as verbal notices to proceed and 

stop-work orders. 

The DoS Office of Inspector General previously reported on problems with this same 

COR—similar to those we identified that were associated with this COR’s performance 

on this task order—in a March 2002 report on U.S. support to the International Police 

Task Force in Bosnia.8

 In that report the DoS Office of Inspector General found among 

other things that: 

• the official government contract files were not complete 

• there was no COR letter of delegation and evidence of required training 

• procurement officials did not adequately monitor contract provisions for the 

inspection and acceptance of contract services 

• the COR did not document oversight 

The DoS Office of Inspector General made recommendations to strengthen contract 

administration and oversight and to require that all personnel assisting the contracting 

officer have a clear delegation of responsibilities and appropriate training. INL and the 

DoS Office of Acquisition Management agreed with the report recommendations and 

agreed to take corrective action. However, as discussed above, many of these problems 

continue to exist. 

In an apparent recognition that program oversight needed improvement, in July 2006, 

INL officials stated that they are in the process of assigning a Government Technical 

Monitor. The Foreign Affairs Handbook states that the contracting officer may appoint a 

Government Technical Monitor to assist the COR in monitoring contractor’s 

performance. The Government Technical Monitor operates under the COR’s supervision, 

but the final acceptance of contractor’s work and approval of invoices remains with the 

COR. 

The Foreign Affairs Handbook does not address the maximum length of time personnel 

should serve as a contracting officer or COR for the same contractor. In July 2006, 

correspondence on contract management provided to the House and Senate Armed 

Services Committees and the Government Accountability Office noted that tenure can 

 

8

 Department of State, Office of Inspector General, Review of U.S. Support to the International Police Task 

Force in Bosnia, Memorandum Report AUD/PPA-02-20, March 2002 

 19 
become a vulnerability if the control environment in an organization is weak.9

 We 

believe that the results of this review suggest that, at least for this task order, the control 

environment has been weak. However, although there have been several DoS contracting 

officers for Task Order 0338 over the past two years, the INL COR has been assigned to 

this and other DynCorp contracts/task orders since 1994—a 12-year period. 

Impact of the Failure to Perform Contracting Responsibilities 

DoS had to take action to rectify weak contract administration and incurred unnecessary 

costs. The lack of proper contract and administration controls required DoS officials to 

execute a ratification for DynCorp’s continued performance beyond the contracted period 

identified in Task Order 0038. Contract ratification is a process of retroactively 

approving an action that was not contractually authorized. T.O. 0338 had a performance 

period of April 17, 2004, through July 16, 2004. The DoS ratification documentation 

stated that DynCorp continued to perform services from July 17, 2004, to October 22, 

2004, at a cost of $35 million and acquired equipment, supplies, material, and personnel 

services critical to the police training program. The ratification was necessary to allow 

DoS to pay DynCorp for its work during that period. 

As discussed, we believe that DoS has incurred potentially unnecessary expenses as a 

result of weak contract administration. This included the payment of $4.2 million in 

contractually unauthorized work directed by the Iraqi Ministry of Interior and to ascertain 

the true status of the residential camp at the time DoS issued a verbal “not to proceed 

order” in late September 2004. As a result of the failure to ascertain the true status of the 

residential camp at the time of the stop-work order DoS ultimately paid about 

$43.8 million for the manufacturing of camp components following the order and the cost 

of storing and securing the camp components for almost two years. DoS will pay 

$4.6 million more for the cost of transporting the camp components to Baghdad which 

was directed in July 2006, $275,000 storage cost for the initial three month period at the 

Baghdad airport, and the potential cost of installing the camp at a location to be 

determined if it is decided to install the trailers. 

 

9

 U.S. Government Accountability Office, Contract Management: DOD Vulnerabilities to Contracting 

Fraud, Waste, and Abuse, GAO-06-838R, July 7, 2006. 

 20 
Conclusion and Recommendations 

Conclusion 

Poor contract administration by INL and the DoS Office of Acquisition Management 

resulted in millions of dollars put at unnecessary risk and property that can not be 

accounted for that was acquired under Task Order 0338. Specifically, between July 2004 

and June 2006, DoS paid about $43.8 million for manufacturing and temporary storage of 

a residential camp that has never been used, including $4.2 million for unauthorized work 

associated with the residential camp. In addition, DoS may have spent another $36.4 

million for weapons and equipment, including armored vehicles, body armor, and 

communications equipment that cannot be accounted for because invoices were vague 

and there was no backup documentation or property book specifically for items 

purchased under Task Order 0338. 

As we reported there is much confusion over the manufacturing of the trailers. However, 

we believe had INL, particularly the COR, been more aggressive in questioning why 

DynCorp submitted an invoice before it had subcontracted for the manufacture of the 

trailers and sought to determine the status of the work at the time INL notified DynCorp 

not to proceed, given the $18 million paid to DynCorp for mobilization fees for the 

residential camp, rather than relying on DynCorp’s representations, he might have been 

able to learn the true status of the manufacturing effort and could have taken steps to 

assure that no improper payments were made. 

Further, the DoS contracting officer recently authorized, at the request of the COR, 

movement of all camp components to Baghdad where they are in storage. As of January 

18, 2007, INL appears to be making progress in resolving the use of the trailers in that 

discussions are underway for an alternative use of the trailers at the Baghdad Embassy. 

DoS contracting personnel, specifically the contracting officer and particularly the COR 

did not perform many of the responsibilities detailed for their positions in the Foreign 

Affairs Handbook. Many of the problems we identified are a direct result of not 

providing adequate contract oversight. In addition, no comprehensive record exists of 

DoS actions involving the task order. 

In December 2005, INL issued its own report that identified that DynCorp could not 

provide a complete property book and backup documentation for items it purchased for 

the U.S. government. The report concluded that DynCorp invoices were frequently 

ambiguous, unclear, and lacked the level of detail to determine what was procured; that 

DynCorp did not maintain a complete list of items procured; and DynCorp did not 

establish policy guidance or accountability procedures. The report concluded, “INL 

cannot determine if the bureau received what it paid for.” Other task orders to DynCorp 

required the acquisition of equipment, but without established controls, such as providing 

detailed identification of items procured (i.e. record of serial numbers), it is impossible to 

determine what task order acquired the item and whether DynCorp had previously been 

compensated for the item. We found the same conditions for DynCorp invoices under 

 21 
Task Order 0338. We also concluded that since the COR was the INL representative for 

civilian police contracts and it is the COR’s responsibility to inspect and accept 

contractor work, the COR should have ensured DynCorp maintained proper inventory 

control records and provided accountable invoicing. 

Management Control Weaknesses 

During the audit we identified management control weaknesses in the timely issue of task 

order modifications, the process of documenting the review of contractor invoices, and 

the administration of the task order. This report includes recommendations to strengthen 

internal controls needed to improve the DoS contracting and administration of the task 

order. Further, because INL reported similar conditions in its December 2005 INL asset 

verification report, we have no reason to believe that the management internal control 

weaknesses in this task order are isolated. Therefore, SIGIR intends to continue the 

review of Task Order 0338, and will announce a full review of contract S-LMAQM-04-

C-0030 and other expenditures by INL in Iraq. 

Management Actions 

In November 2005, INL’s Principal Deputy Assistant Secretary met with the DoS 

Inspector General and subsequently with DoS Investigations to discuss concerns of 

potential fraud with Task Order 0338. Specifically, INL disclosed that DynCorp had 

billed INL for 500 trailers for the residential camp related to this task order that may not 

have been manufactured or completed at the time of billing. The preliminary 

investigation conducted by DoS investigations revealed that INL contacted DoS Office of 

Acquisition Management in October 2005 to discuss its concerns regarding the number of 

trailers actually received and billed under this task order. DoS and SIGIR worked jointly 

on this investigation, and SIGIR has taken the lead and the investigation is ongoing. 

Beginning in 2005, according to INL senior officials, INL initiated a number of steps to 

strengthen its contract and asset management across the Bureau. INL senior managers 

provided the following information: 

• A series of internal reviews were undertaken concerning property controls and an 

inventory of the residential camp trailers related to the DynCorp contract that are 

discussed in this report. 

• Between January and June 2006, INL directed DynCorp to ensure asset management 

improvements. These improvements were documented in a series of letters INL 

exchanged with DynCorp in which INL documented defects in contract performance 

and DynCorp responded by identifying corrective actions it was taking or planned to 

take. Currently, INL is in the process of following up on DynCorp inventory control 

corrective actions. 

 22 
• In June 2006, INL requested assistance from the Defense Contract Management 

Agency in reviewing DynCorp property management practices in Iraq and 

Afghanistan (which the Defense Contract Management Agency declined due to 

property administrator staffing shortages). 

• In October 2006, INL attempted to contract for Defense Contract Audit Agency 

services to close out several DynCorp task orders, including Task Order 0338. As of 

January 18, 2007, the Defense Contract Audit Agency had not responded. 

• On November 2, 2006, INL appointed an overall COR for the DynCorp contract. 

• In January 2007, INL identified an Iraq in-country COR. This person will be on duty 

once all Human Resource actions are finalized. 

• In January 2007, INL began a review to complete contract files, which consisted of 

contracts, task orders, and pertinent documents exclusive of information, such as 

contract evaluation sheets and private e-mail exchanges between a program office and 

the contracting officer. 

• Over the past several months INL has developed a process for thoroughly reviewing 

invoices. This process has already resulted in INL identifying billing errors in a 

DynCorp invoice. For example, INL rejected a January 9, 2007, invoice for $1.1 

million which was for a different DynCorp contract10. This invoice was rejected 

because INL determined that the billed rate was outside the period of performance 

dates. 

INL also advised us that it was working to ensure internal and management controls are 

in place and adhered to at all times, and intends to reconcile all past payments made since 

the inception of INL contracts in Afghanistan, Iraq, and Jordan. 

We had initially recommended that INL consider replacing the COR for the DynCorp 

contracts and task orders who had held that position since 1994—a 12-year period. INL 

advised us on January 11, 2007: 

• The COR had been replaced. INL also provided appointment letters for in-country 

CORs for all INL contracts in Afghanistan and Jordan. 

• The transition of contracting responsibilities took place in November 2006. 

• The Iraq in-country CORs, who will be personal services contractors, had been 

selected and are going through the clearance process. 

We consider INL’s actions to be responsive to the draft recommendation and, therefore, 

removed it from the final report. 

 

10 Contract SAQMPD-04C-1076 

 23 
Recommendations 

To ensure that DoS conserves IRRF funds and other DoS funds, we recommend that the 

Assistant Secretary for the Bureau for International Narcotics and Law Enforcement 

Affairs: 

1. Present a plan to the U.S. Ambassador to Iraq for review and approval on the use of 

the residential camp to house police trainers, as originally intended, or make 

arrangements to dispose of the camp. Because of the lengthy consideration already 

given to deciding what to do with the trailers, this action should be taken within the 

next 60 days. 

To ensure that contracted work is properly invoiced, payments are proper, and the 

contract is properly managed, we also recommend that the Director, Office of Acquisition 

Management should take these actions: 

2. Seek reimbursement of the improperly authorized payment of $4.2 million that 

represents contractually unauthorized work directed by the Iraqi Ministry of Interior, 

which directed the relocation of the residential camp, the manufacture of additional 

VIP trailers, and the construction of an Olympic size swimming pool. 

3. Request the Defense Contract Audit Agency (DCAA) take these actions: 

a. Review the July 30, 2004, DynCorp invoice submitted that included a 

residential camp mobilization fee to determine whether a prepayment of 

$18.0 million occurred. 

b. Review the October 30, 2006, invoice submitted by DynCorp for about 

$1.1 million pertaining to labor costs associated with Task Order 0338. 

4. On receipt of the DCAA audit report, the contracting officer should take the 

appropriate action. 

5. Enforce procedures to ensure the contracting officer and COR comply with duties and 

responsibilities as identified in the DoS Foreign Affairs Handbook. These procedures 

should address: 

a. receiving and retaining technical and financial reports 

b. examining invoice with supporting documentation prior to certification for 

payment 

c. processing “receiving and inspection reports” for equipment 

d. maintaining a COR file 

6. Establish and enforce tenure limitations for all contracting personnel as part of the 

Foreign Affairs Handbook. 

 24 
Management Comments and Audit Response 

We received written comments on a draft of this report from INL, which incorporated 

comments from DoS Office of Acquisition Management, that they agreed with 

recommendations 1 through 5. INL stated that the Office of Acquisition Management 

disagreed with recommendation 6, regarding tenure limitations, because it has a Quality 

Assurance Plan for reviewing and approving contract actions to ensure that all 

requirements of law, regulation, department policy, and sound procurement practices are 

met. We recognize the importance of a Quality Assurance Plan, but believe that the need 

for tenure limitations is underscored when the control environment in an organization is 

weak. We, therefore, retained the recommendation. 

In response to the draft of this report, INL provided us with information on its 

management actions to strengthen its contract and asset management across INL, which 

is detailed in the management actions section of this Report. INL also provided us with 

technical changes, which were incorporated in the final report as appropriate. 

 25 
Appendix A – Scope and Methodology 

The Special Inspector General for Iraq Reconstruction (SIGIR) and the DoS Office of the 

Inspector General jointly conducted this review (Project 6017). 

The objectives of this audit were to answer the following questions: 

• What were the costs associated with the subject contract Task Order 0338, 

including amounts obligated and expended, potential liabilities, and controls over 

these costs? 

• What is the status of property purchased under Task Order 0338 including related 

internal controls, and what is the salvage value for unused assets? 

• What is the cost and program impact of the stop-work order affecting the 

construction of police training facilities at the Adnan Palace? 

• What is the status of construction of facilities to support provincial police training 

programs? 

To respond to the audit objective we structured the report into three sections: 

• cost incurred under T.O. 0338 

• construction of the Adnan Palace residential camp and the regional camps 

• contracting and contract management 

The audit was performed between May 2006 and January 2007, in accordance with 

generally accepted government auditing standards. The audit was conducted with U.S. 

government officials in Baghdad, Iraq; Dubai, United Arab Emirates; and offices in 

Washington, D.C.; and with DynCorp officials in Baghdad, Dubai, and Irving, Texas. We 

interviewed current and former DoS and INL contract administration and management 

officials responsible for issuing and administering T.O. 0338. We also interviewed 

contracting and contract administration officials for DynCorp. 

Cost Incurred Under Task Order 0338 

To determine costs incurred, we reviewed DynCorp invoices submitted to DoS for 

approval and payment between July 30, 2004, and September 25, 2006, and created an 

Excel spreadsheet to list task order obligated funding by CLIN and statement of work. 

We also discussed the invoicing process with DoS officials responsible for processing the 

invoices. 

Construction of the Adnan Palace Residential Camp 

We visited Adnan Palace to observe the camp construction and Palace renovation project, 

reviewed official contract files containing the task order statement of work and 

subsequent task order modifications, camp construction specifications, inspection reports 

and inventory report on the trailers. We interviewed Baghdad officials from DoS-INL, 

 26 
Civilian Police Advisory Training Team, Multi-National Security Transition CommandIraq, as well as DoS contracting and program management officials in Washington, D.C.; 

and Dubai, United Arab Emirates. We also contacted DynCorp officials in Baghdad, Iraq, 

Dubai, and in Irving, Texas, and observed DynCorp operations at the Baghdad Hotel. 

Contracting and Contract Management 

We collected and reviewed correspondence between DoS and DynCorp officials; 

interviewed representatives from INL Baghdad, DynCorp International, and Civilian 

Police Advisory Training Team responsible for support to the Iraq civilian police training 

program; and examined the DoS Foreign Affairs Handbook to identify responsibilities of 

various functional contracting positions and compared those responsibilities to actual 

performance. 

Limitations 

We focused our work on CLIN 0043 within T.O. 0338 as it represented the bulk of 

spending under the task order—88%—and within CLIN 43 on both the residential camp 

as it was the remaining outstanding item under the task order and involved the largest 

item in the CLIN with a proposed cost of about $51.6 million and the $36.4 million for 

equipment to be procured. We did not include an assessment of the regional camps in 

this review, but plan to address them in our continuing review of T.O. 0338, DynCorp 

contract S-LMAQM-04-C-0030, and other INL expenditures of IRRF. 

Internal Controls 

During the audit, internal control weaknesses were identified in the timely issue of task 

order modifications, the approving contractor invoices, and the administration of the task 

order. This report includes recommendations to strengthen internal controls needed to 

improve the DoS contracting and administration of the task order. 

Use of Computer-Processed Data 

Computer processed data was not used during this review. 

Prior Coverage 

There were no prior reviews of the DynCorp contract S-LMAQM-04-C-0030, T.O. 0338; 

however, there were two related reports on contracting and contract administration. One 

report by the Government Accountability Office and one by the DoS Office of Inspector 

General: 

• U.S. Government Accountability Office, Contract Management: DOD 

Vulnerabilities to Contracting Fraud, Waste, and Abuse, GAO-06-838R, July 7, 

2006. 

• DoS and the Broadcasting Board of Governors Office of Inspector General, 

Report on Inspection Bureau of International Narcotics and Law Enforcement 

Affairs, Report Number ISP-I-05-14, July 2005. 

• DoS, Office of Inspector General, Review of U.S. Support to the International 

Police Task Force in Bosnia, Memorandum Report AUD/PPA-02-20, March 

2002. 

 27 
Appendix B – Acronyms 

Acronym Definition 

BIAP Baghdad International Airport 

COR Contracting Officer’s Representative 

CLIN Contract Line Item Number 

DoS Department of State 

INL Bureau for International Narcotics and Law Enforcement Affairs 

IPLO International Police Liaison Officers 

IRRF Iraq Relief and Reconstruction Fund 

SIGIR Special Inspector General for Iraq Reconstruction 

T.O. 0338 Task Order 0338 

VIP Very Important People 

 28 
Appendix C – Report Distribution 

Department of State 

Secretary of State 

Senior Advisor to the Secretary and Coordinator for Iraq 

Director of U.S. Foreign Assistance/Administrator, U.S. Agency for 

International Development 

 Director, Office of Iraq Reconstruction 

 Assistant Secretary, Bureau for International Narcotics and Law Enforcement 

 Affairs* 

 Assistant Secretary, Bureau of Administration 

 Director of Acquisition Management* 

 Assistant Secretary for Resource Management/Chief Financial Officer, 

 Bureau of Resource Management 

 U.S. Ambassador to Iraq 

Director, Iraq Reconstruction Management Office 

Mission Director-Iraq, U.S. Agency for International Development 

Inspector General, Department of State 

Department of Defense 

Secretary of Defense 

Deputy Secretary of Defense 

Under Secretary of Defense (Comptroller)/Chief Financial Officer 

 Deputy Chief Financial Officer 

 Deputy Comptroller (Program/Budget) 

Deputy Assistant Secretary of Defense-Middle East, Office of Policy/International 

Security Affairs 

Inspector General, Department of Defense 

Director, Defense Contract Audit Agency 

Director, Defense Finance and Accounting Service 

Director, Defense Contract Management Agency 

Department of the Army 

Assistant Secretary of the Army for Acquisition, Logistics, and Technology 

Principal Deputy to the Assistant Secretary of the Army for Acquisition, 

Logistics, and Technology 

Deputy Assistant Secretary of the Army (Policy and Procurement) 

Director, Project and Contracting Office 

Commanding General, Joint Contracting Command-Iraq/Afghanistan 

Assistant Secretary of the Army for Financial Management and Comptroller 

Chief of Engineers and Commander, U.S. Army Corps of Engineers 

 Commanding General, Gulf Region Division 

Chief Financial Officer, U.S. Army Corps of Engineers 

Auditor General of the Army 

 29 
U.S. Central Command

Commanding General, Multi-National Force-Iraq 

Commanding General, Multi-National Corps-Iraq 

Commanding General, Multi-National Security Transition Command-Iraq 

Commander, Joint Area Support Group-Central 

Other Federal Government Organizations 

Director, Office of Management and Budget 

Comptroller General of the United States 

Inspector General, Department of the Treasury 

Inspector General, Department of Commerce 

Inspector General, Department of Health and Human Services 

Inspector General, U.S. Agency for International Development 

President, Overseas Private Investment Corporation 

President, U.S. Institute for Peace 

Congressional Committees and Subcommittees, Chairman and 

Ranking Minority Member 

U.S. Senate 

Senate Committee on Appropriations 

Subcommittee on Defense 

Subcommittee on State, Foreign Operations and Related Programs 

Senate Committee on Armed Services 

Senate Committee on Foreign Relations 

Subcommittee on International Operations and Terrorism 

Subcommittee on Near Eastern and South Asian Affairs 

Senate Committee on Homeland Security and Governmental Affairs 

Subcommittee on Federal Financial Management, Government Information and 

International Security 

Subcommittee on Oversight of Government Management, the Federal 

Workforce, and the District of Columbia 

U.S. House of Representatives 

House Committee on Appropriations 

Subcommittee on Defense 

Subcommittee on Foreign Operations, Export Financing and Related Programs 

Subcommittee on Science, State, Justice and Commerce and Related Agencies 

House Committee on Armed Services 

House Committee on Government Reform 

Subcommittee on Management, Finance and Accountability 

Subcommittee on National Security, Emerging Threats and International 

Relations 

House Committee on International Relations 

Subcommittee on Middle East and Central Asia 

* Recipient of the draft audit report. 

 30 
Appendix D – Audit Team Members 

This report was prepared under the direction of Mr. Joseph T. McDermott, Assistant 

Inspector General for Audit, Office of the Special Inspector General for Iraq 

Reconstruction (SIGIR). 

This joint audit was conducted under the direction of Mr. Joseph T. McDermott, 

Assistant Inspector General for Audit, Office of the Special Inspector General for Iraq 

Reconstruction, and was performed in consultation with Mr. Mark Duda, Assistant 

Inspector General for Audits, Department of State, Office of Inspector General (DoS 

OIG). The staff members who contributed to the report include: 

Richard Astor, DoS OIG 

Karen Bell, SIGIR 

Roger Florence, SIGIR 

Michael Herbaugh, SIGIR 

Steven Sternlieb, SIGIR 

David Wilcox, DoS OIG 

 31 
Management Comments 

Assistant Secretary, Bureau for International 

Narcotics and Law Enforcement Affairs, 

Department of State 

 32 
 33 
 34 
SIGIR’s Mission Regarding the U.S. reconstruction plans, programs, 

and operations in Iraq, the Special Inspector General 

for Iraq Reconstruction provides independent and 

objective: 

• oversight and review through comprehensive 

audits, inspections, and investigations 

• advice and recommendations on policies to 

promote economy, efficiency, and effectiveness 

• deterrence of malfeasance through the prevention 

and detection of fraud, waste, and abuse 

• information and analysis to the Secretary of 

State, the Secretary of Defense, the Congress, 

and the American people through Quarterly 

Reports 

Obtaining Copies of SIGIR 

Reports and Testimonies 

To obtain copies of SIGIR documents at no cost, go 

to SIGIR’s Web site (www.sigir.mil). 

To Report Fraud, Waste, 

and Abuse in Iraq Relief 

and Reconstruction 

Programs 

Help prevent fraud, waste, and abuse by reporting 

suspicious or illegal activities to the SIGIR Hotline: 

• Web: www.sigir.mil/submit_fraud.html 

• Phone: 703-602-4063 

• Toll Free: 866-301-2003 

Congressional Affairs Marthena Cowart 

Assistant Inspector General for Congressional 

 Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-604-0368 

Email: marthena.cowart@sigir.mil 

Public Affairs Denise Burgess 

Assistant Inspector General for Public Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1217 

Fax: 703-428-0818 

Email: PublicAffairs@sigir.mil 

 35