OFFICE OF

LL

DDEEP

F THE SP

LLOONNGGPPAARRTT

OOFF DD

SSUUPPPP

PECIAL I

--SSTTAANN

TMMEENNTT

DDYYNNCC

PPOORRTT

TTRRAA

INSPECTO

NNDDIINNG

TT OOFF

CCOORRPP

T OOFF TT

AAIINNIINNGG

OR GENE

GG WWEE

SSTTAATT

PP CCOONN

TTHHEE IIRR

GG PPRROO

ERAL FOR

EEAAKKNN

TTEE’’SS OO

NNTTRRAACC

RRAAQQII

OOGGRRAA

R IRAQ R

NEESSSSEE

OOVVEERR

CCTT FFOO

PPOOLLII

AAMM

SSIIGGI

JJJAAANNNUUUAAARRR

RECONST

EESS IINN

RRSSIIGGHH

OORR

IICCEE

GIIRR1100--00

RRRYYY 222555,,,222000

TRUCTIO

HHTT

000088

000111000

ON
SIGIR 

Special Inspector General for IRAQ Reconstruction 

For more information, contact SIGIR Public Affairs at 

(703) 428-1100 or PublicAffairs@sigir.mil Special Inspector General for Iraq Reconstruction 

Summary of Report: SIGIR 10-008 

Why SIGIR Did this Study 

The Department of State (DoS) Bureau of 

International Narcotics and Law Enforcement 

Affairs (INL) contract with DynCorp 

International includes task orders to support the 

Department of Defense’s (DoD) Iraqi police 

training program. Under the task orders, 

DynCorp has provided police advisors and 

in-country support for those and other advisors. 

INL’s Afghanistan, Iraq, Jordan Support 

Division is primarily responsible for oversight 

of the DynCorp contract. The Special Inspector 

General for Iraq Reconstruction (SIGIR) 

examined INL’s oversight of the task orders 

because they cost over $2.5 billion and INL has 

had a history of weak oversight of the task 

orders. Specifically, SIGIR examined: (1) the 

costs, funding, and award process for the largest 

and most recent task orders; (2) DoS oversight 

of the task orders; and (3) the status of INL’s 

implementation of SIGIR’s prior 

recommendations. 

What SIGIR Recommends 

Because weak contract administration and 

oversight have been long-standing issues that 

INL has not corrected, SIGIR recommends that 

the Deputy Secretary of State for Management 

and Resources direct an immediate examination 

of the Afghanistan, Iraq, Jordan Support (AIJS) 

Division’s personnel and operations to 

determine if the Division is structured, staffed, 

and managed to effectively and efficiently 

oversee the contracts under its responsibilities. 

Until such an examination can be conducted, 

SIGIR recommends that the Assistant Secretary, 

INL, direct the Chief of AIJS to develop 

detailed guidance for ICORs, assign specific 

responsibilities to each ICOR, determine how 

many ICORs are needed in Iraq to accomplish 

assigned responsibilities, and staff the invoice 

reconciliation effort to validate historical 

invoices within the next 2 years. 

Management Comments and Audit 

Response 

INL agreed with SIGIR’s recommendations. 

It did not agree with SIGIR’s position that 

$2.5 billion in U.S. funds are vulnerable to 

waste and fraud. Because of the serious 

control weaknesses identified in this and prior 

audits, SIGIR maintains its position. 

January 25, 2010 

LONG-STANDING WEAKNESSES IN DEPARTMENT OF STATE’S 

OVERSIGHT OF DYNCORP CONTRACT FOR SUPPORT OF THE IRAQI 

POLICE TRAINING PROGRAM

What SIGIR Found 

INL continues to exhibit weak oversight of the DynCorp task orders for 

support of the Iraqi police training program. INL lacks sufficient resources 

and controls to adequately manage the task orders with DynCorp. As a 

result, over $2.5 billion in U.S. funds are vulnerable to waste and fraud. The 

In-country Contracting Officer Representatives (ICOR), who are critical to 

overseeing DynCorp’s performance and expenditures under the current task 

order, do not perform adequate reviews and tests to ensure that: (1) the costs 

submitted by DynCorp on invoices are allowable under the contract/task 

order, supported by appropriate documentation, and correct; (2) U.S. 

government property managed by DynCorp is adequately controlled; (3) 

lease agreements negotiated on behalf of the U.S. government protect the 

U.S. government’s interests; and (4) the government receives the services at 

the performance standards specified in the task order. As DoS takes 

responsibility for the police training program from DoD in 2011 and DoS 

continues to oversee contracts costing the American taxpayers hundreds of 

millions of dollars, it will be critical for DoS to have in place effective 

management and controls of those contracts to ensure that U.S. funds are 

effectively and efficiently spent. 

Inadequate resources and controls are not new problems. As early as 2005, 

INL was told that its staffing had not increased commensurate with its 

workload and that it needed to strengthen its oversight of the contracts for 

Iraq and Afghanistan. In 2007, INL was again told that its poor oversight of 

the contract for Iraq had put millions of dollars at risk. In a hearing and in 

responses to audit reports, INL officials have repeatedly stated they 

recognized the problems and had initiatives to increase staff and improve 

management and oversight of the contract for Iraq. However, INL has fallen 

far short on those initiatives. 

INL stated that it plans to increase the number of ICORs in Iraq to 11─there 

were 3 in November 2009. However, SIGIR believes the ICORs need 

additional guidance to clearly specify their responsibilities and more 

oversight to determine what they are or are not doing. Until that guidance is 

developed and implemented, INL is in no position to accurately determine 

how many additional ICORs it needs. SIGIR believes that more than 3 

ICORs are needed but does not believe INL has demonstrated it needs 11. 

Because of weak oversight of the DynCorp contract in Iraq from its start in 

2004, INL is reconciling all historical invoices. Although SIGIR was told in 

October 2007 that the reconciliation effort would take 3 to 5 years to 

complete by a full complement of 11 personnel, the reconciliations will 

likely take longer because INL has not fully staffed the effort. In addition, 

reconciliation efforts have been adversely impacted by high error rates on 

invoices and poor or missing support documentation. Moreover, the 

workload will likely increase because of the problems found with the current 

invoice review process. 
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

400 Army Navy Drive • Arlington, Virginia 22202 

January 25, 2010 

MEMORANDUM FOR U.S. SECRETARY OF STATE 

DEPUTY SECRETARY OF STATE FOR MANAGEMENT AND 

RESOURCES 

ASSISTANT SECRETARY OF STATE, BUREAU OF 

INTERNATIONAL NARCOTICS AND LAW ENFORCEMENT 

AFFAIRS 

U.S. AMBASSADOR TO IRAQ 

SUBJECT: Long-standing Weaknesses in Department of State’s Oversight of DynCorp 

Contract for Support of the Iraqi Police Training Program (SIGIR 10-008) 

We are providing this audit report for your information and use. It primarily pertains to the 

Bureau of International Narcotics and Law Enforcement Affairs’ (INL) oversight of its contract 

with DynCorp International for support of the Iraqi Police Training Program. We performed this 

audit in accordance with our statutory responsibilities contained in Public Law 108-106, as 

amended, which also incorporates the duties and responsibilities of inspectors general under the 

Inspector General Act of 1978. This law provides for independent and objective audits of 

programs and operations funded with amounts appropriated or otherwise made available for Iraq 

reconstruction and for recommendations on related policies designed to promote economy, 

efficiency, and effectiveness and to prevent and detect waste, fraud, and abuse. This audit was 

conducted as SIGIR Project 9025. 

We considered written comments from the Assistant Secretary, INL, when preparing this report. 

The comments are addressed in the report where applicable, and the letter is included in 

Appendix D. 

We appreciate the courtesies extended to the SIGIR staff. For additional information on the 

audit report, please contact David Warren, Assistant Inspector General for Audits, (703) 

604-0982/ david.warren@sigir.mil, or Glenn Furbish, Principal Deputy Assistant Inspector 

General for Audits, (703) 604-1388/ glenn.furbish@sigir.mil. 

Stuart W. Bowen, Jr. 

Inspector General 

cc: U.S. Secretary of Defense 

Commander, U.S. Central Command 

Commanding General, U.S. Forces-Iraq 
Table of Contents 

Introduction 1

Background 2

Contract Management and Oversight Organizations 5

Objectives 5

Task Order Costs, Funding, and Award Process 6

Contract Performance Period Was Extended Pending Future Awards 6

Largest Task Order Was Awarded As Exception to Fair Opportunity Provisions; 

Most Recent Task Orders Provided for Fair Opportunity 7

Oversight of Iraq Task Orders Is Weak 10

In-Country Contracting Officer Representatives Are Essential for Oversight 11

Weaknesses in Invoice Validation Process Continue 11

ICORs Exercise Limited Oversight of Property Management 16

INL’s Practices Are Questionable and Oversight of Leased Facilities Is Poor 18

INL Performs Minimal Quality Assurance Oversight 20

Police and Border Patrol Advisor Screening and Selection Process Helps Ensure 

Task Order Requirements Are Met 21

Status of Actions to Address Prior Recommendations 23

Status of INL’s Corrective Action Plan 23

Status of Prior Recommendations Pertaining to Task Order 0338 23

Conclusions, Recommendations, and Lessons Learned 26

Conclusions 26

Recommendations 27

Lessons Learned 27

Management Comments and Audit Response 27

Appendix A—Scope and Methodology 28

Appendix B—Acronyms 31
Appendix C—Audit Team Members 32

Appendix D—Department of State - INL Comments 33

Appendix E—SIGIR Mission and Contact Information 37
1 

Long-standing Weaknesses in Department of State’s 

Oversight of DynCorp Contract for Support of the Iraqi 

Police Training Program 

SIGIR 10-008 January 25, 2010

Introduction 

In 2000, the Department of State (DoS) established a program for training civilian police to 

perform international peacekeeping missions around the world. Within DoS, the Bureau of 

International Narcotics and Law Enforcement Affairs (INL) is responsible for developing 

policies and managing programs to strengthen law enforcement and other rule of law 

institutional capabilities outside the United States. INL has relied on contractors to assist in 

fulfilling its responsibilities. In early 2004, INL awarded contracts to DynCorp International, 

LLC; Pacific Architects & Engineers-Homeland Security Corporation; and Civilian Police 

International (CPI) to establish and maintain a cadre of experienced law enforcement personnel 

to serve in civilian peacekeeping missions overseas; provide pre-deployment and in-country 

support for the personnel; and perform other related functions. 

In May 2004, National Security Presidential Directive 361

 assigned the mission of organizing, 

training, and equipping Iraq’s security forces, including the police, to the U.S. Central Command 

until the Secretaries of State and Defense agreed that DoS should assume that responsibility. 

The U.S. Central Command designated the Multi-National Security Transition Command-Iraq 

(MNSTC-I), under the overall direction of the Multi-National Force-Iraq, the manager of this 

effort and created the Civilian Police Assistance Training Team2 to train and equip Iraqi police 

and other civilian security forces. The Department of Defense (DoD) components are 

responsible for setting requirements for and managing the Iraqi Police Training Program. As 

such, DoD has program office responsibility for ensuring that the program achieves its 

objectives. DoD transfers funds to DoS for contractor support and DoS, specifically INL, is 

responsible for managing the contracts that provide that support. INL and its contractors support 

the DoD program by providing police and judicial advisors and logistical support for those and 

other advisors. According to INL officials, DynCorp has been the major provider of support to 

the program in Iraq. 

The Special Inspector General for Iraq Reconstruction (SIGIR) has a separate audit underway to 

review DoD’s management of the Iraqi Police Training Program. 

 

1

 United States Government Operations in Iraq, 5/11/2004. 

2

 Now called the Iraq Training and Advisory Mission, which has been subsumed into U.S. Forces-Iraq. 
2 

Background 

The INL contract with DynCorp was awarded in February 2004 for a base year and four 1-year 

options (February 18, 2004, through February 17, 2009).3 In February 2009, the contract was 

extended for 6 months to August 17, 2009, and in August 2009, the contract was further 

extended for 1 year to August 17, 2010. 

Eight task orders have been awarded to DynCorp under that contract; seven have been concluded 

and one is ongoing. Table 1 provides details on the eight task orders, including the funds 

obligated and expended, purpose, and status. 

 

3

 Contract S-LMAQM-04-C-0030. 
3 

Table 1─Task Order Summaries (as of December 24, 2009) 

Task 

Order 

Obligations 

($ millions) 

Expenditures 

($ millions) Purpose Status 

0582 

Funds 

moved to 

Task Order 

1436 

Provide pre- and post-deployment support for 

12 U.S. judicial and criminal-justice experts in 

such areas as training, equipment, housing, 

meals, transportation, information technology, 

medical services, and security. The support 

could require the construction, repair, or 

refurbishment of facilities and buildings. 

Combined 

with Task 

Order 1436 

0765 $70.4 $70.4 

Provide all labor, materials, supervision, tools, 

equipment, services, quality assurance, and 

other necessary items and services for the 

construction of the Jordan International Police 

Training Center in Amman. 

Concluded 

 A528 55.3 55.3 

Provide operations and maintenance support 

for the Jordan International Police Training 

Center. 

Concluded 

2059 47.2 47.2 

Provide funds to reimburse DynCorp for 

equipment, construction, supplies, materials, 

services, and other functions delivered 

between July 17 and October 22, 2004. The 

contracting officer determined DynCorp should 

be reimbursed for the services because it 

continued to perform essential services during 

this period despite the expiration of the taskorder performance period. 

Concluded 

0338 152.2 152.0 

Provide training services for international 

police-liaison officers, training support 

equipment, construction of five regional 

camps, and construction of a residential 

camp—on the Adnan Palace grounds in 

Baghdad—to house training personnel. 

Concluded 

1436 1,423.9 1,391.9 

Provide police technical advisors, in-country 

support services (such as housing, food, 

security, communications, and facilities) for the 

police and other advisors provided by other 

organizations,a

 and training support for the 

Iraqi Police Training Program. 

Concluded 

7229 1.4 0.0 Renovation and expansion of villas for judicial 

advisors. Concluded 

4761 786.0 402.0 

Provide police advisorsb

 and in-country 

support for police, judicial, and corrections 

advisors. 

Ongoing 

Totals $2,536.4 $2,118.8 

Notes: 

a Judicial and corrections advisors were provided by other U.S. government agencies. b Includes border/point-of-entry advisors. 

Source: INL officials and financial and contract documents. 
4 

During the initial year of the contract, INL’s workload increased substantially without a 

commensurate increase in personnel. The result was poor contract management, which plagued 

the early years of the contract. INL’s contract management problems and its efforts to improve 

that management are well documented: 

• In July 2005, the DoS Office of Inspector General reported that INL’s responsibilities and 

programs had increased substantially between 2003 and 2005 but that its staffing had not 

increased commensurate with its workload, creating a significant management 

challenge.4

 The report stated that “INL must strengthen its mechanisms for oversight of 

procurement and contract compliance...particularly regarding the Iraq and Afghanistan 

programs.” Consequently, INL submitted a reorganization proposal—approved by 

DoS—to add 35 full-time domestic positions. According to the Inspector General’s 

report, however, the INL reorganization did not address the critical staffing requirements 

for overseas posts, including those in Iraq. 

• In a January 2007 report on Task Order 0338,5

 SIGIR and the DoS Office of Inspector 

General noted that poor contract administration by INL and the DoS Office of 

Acquisition Management, the contracting office, put millions of dollars at risk and could 

not account for property. In commenting on the report, the Assistant Secretary of State, 

INL, identified steps INL had initiated to strengthen its contract and asset management as 

well as its intent to reconcile past payments made since the inception of INL contracts in 

Iraq, Afghanistan, and Jordan. 

• On April 25, 2007, the Assistant Secretary of State, INL, in testimony on contracts for the 

Iraqi security forces,6

 recognized problems with contract management and cited related 

measures to improve INL’s management and oversight capabilities. She stated that “The 

urgency and scale of requirements in Iraq has often outstripped our staffing and oversight 

capabilities both domestically and in the field, particularly in the early stages. Security 

challenges have also impeded the ability of our staff to travel throughout Iraq.” The 

assistant secretary said that INL had recently obtained approval to increase its staff in 

Baghdad, was expanding its Washington-based Iraq program staff, and had strengthened 

such internal controls as inventory oversight and performance reporting on property 

management. 

• In October 2007, SIGIR reported on its attempt to audit the contract.7

 SIGIR stated that it 

suspended the audit because INL (1) did not have the information needed to identify what 

DynCorp provided under the contract or how funds were spent and (2) had a number of 

initiatives to improve its management and oversight of the contract and recoup funds 

inappropriately paid to DynCorp. For example, it was organizing contract files, 

increasing the number of contract management personnel in Iraq, increasing its 

 

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 ISP-I-05-14, 7/2005. 5 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, 1/30/2007. 6

Testimony by Ambassador Anne W. Patterson, Assistant Secretary of State, Bureau for International Narcotics and 

Law Enforcement Affairs, U.S. Department of State, before the House Committee on Armed Services, 

Subcommittee on Oversight and Investigation, Contracting for the Iraqi Security Forces, 4/25/2007. 7 Interim Review of DynCorp International, LLC, Spending Under Its Contract for the Iraqi Police Training 

Program, SIGIR 07-016, 10/23/2007. 
5 

headquarters staff, improving its oversight of property management, collecting for excess 

or erroneous charges, and improving its project oversight and business processes. 

• In April 2008, SIGIR reported8

 on INL’s progress on recommended improvements to its 

contract administration. SIGIR found that INL had made a concerted effort to implement 

the recommendations in prior reports on the Iraqi Police Training Program. It stated that 

while INL’s actions were in various stages of completion, taken together, they were 

improving the overall contract administration. 

Contract Management and Oversight Organizations 

Within INL, the Office of Iraq Programs coordinates requirements with MNSTC-I, provides 

foreign policy advice, manages the contract modification process, and performs other functions 

such as managing the “people” part of the contracts by reviewing resumes and approving all 

police advisor candidates. To assist in contract oversight and related functions for its biggest 

programs (Iraq and Afghanistan), INL created the Afghanistan, Iraq, Jordan Support (AIJS) 

Division. The Division Chief is also the Contracting Officer Representative (COR). AIJS is 

responsible for such oversight activities as monitoring the contractors’ performance in both Iraq 

and Afghanistan, providing technical direction to the contractors to ensure regulatory 

compliance, conducting and validating physical inventories of government-furnished equipment, 

and reconciling a large backlog of historical invoices submitted by the contractors. Assisting 

AIJS in its oversight role are In-country Contracting Officer Representatives (ICORs). The 

Office of Acquisition Management (AQM) within DoS’s Bureau of Management is the 

contracting office. 

Objectives 

Because (1) the Iraqi Police Training Program is the largest assistance program in which INL is 

involved, (2) DynCorp has been the major provider of support to the program in Iraq, and (3) 

INL has had a history of weak oversight of the Iraq task orders, SIGIR examined the largest and 

most recent task orders for the Iraqi program under the INL contract with DynCorp. 

Specifically, SIGIR examined: (1) the costs, funding, and award process for Task Orders 1436, 

4761, and 7229; (2) DoS’ oversight of DynCorp-provided services for the three task orders; and 

(3) the status of INL’s implementation of prior recommendations pertaining to Task Order 0338 

as well as overall contract management and oversight. Because of a separate review underway 

related to Task Order 1436, we focused our oversight examination on Task Orders 4761 and 

7229 but did review INL’s progress in reviewing historical invoices pertaining to 1436. 

For a discussion of the audit scope and methodology and a summary of prior coverage, see 

Appendix A. For a list of acronyms used, see Appendix B. For the audit team members, see 

Appendix C. For the management comments, see Appendix D. For the SIGIR Mission and 

Contact Information, see Appendix E. 

 

 

8 Progress on Recommended Improvements to Contract Administration for the Iraqi Police Training Program, 

SIGIR 08-014, 4/22/2008. 
6 

Task Order Costs, Funding, and Award Process 

Despite repeated requests to INL for detailed cost data on the three task orders, INL did not 

provide the data until early January 2010. Our preliminary analysis of the data raised questions 

that could not be resolved in time to include the data in this report. SIGIR will continue to 

pursue those questions with INL. According to an AIJS official, DoD provided most of the 

funds for Task Orders 1436, 7229, and 4761 from the Iraq Security Forces Fund. According to 

expenditure data provided by INL for Task Orders 1436 and 4761 as of December 24, 2009, the 

daily expenditures for the two task orders were about $1.1 million and $670,000, respectively. 

The DynCorp contract was awarded in February 2004 with options to extend through February 

2009, and those options were exercised. In addition, the contract was extended through August 

2010. We were told that DoS plans to award new contracts in 2010. In July 2011, DoS plans to 

assume responsibility for the police training program. INL officials told us they are now 

preparing to include the program in the fiscal year 2011 budget.

Task Order 1436 was awarded to DynCorp as an exception to the fair opportunity provisions 

under the Federal Acquisition Regulation (FAR). Under the provisions, INL did not have to 

open the award to the other two companies supporting INL in its law enforcement/rule of law 

activities9

 if there was an unusual and compelling urgency. However, we found no written 

explanation for the unusual and compelling urgency in the contract or task order files. The 

newest Task Orders, 4761 and 7229, were open to the other two contractors but awarded to 

DynCorp.

Contract Performance Period Was Extended Pending Future 

Awards 

As mentioned earlier, DynCorp is one of three companies under contract to INL in support of 

INL’s responsibilities to strengthen law enforcement and other rule of law institutional 

capabilities outside the United States. The DynCorp contract is a combination firm-fixed-price 

indefinite-delivery and indefinite-quantity, cost-plus-fixed fee award. It was awarded in 

February 2004 for a base year with four 1-year options (February 18, 2004, through February 17, 

2009). Each of the option years was exercised. In February 2009, the contract was extended for 

6 months to August 17, 2009, and in August 2009, the contract was further extended for 1 year to 

August 17, 2010. INL and AQM personnel noted that the other two contracts were similarly 

extended. 

In July 2011, DoS plans to assume responsibility for the police training program in Iraq. 

According to INL officials, INL is working with the U.S. military to make a smooth transition of 

the program from DoD to DoS. The officials also said that INL is working with Iraqi officials to 

develop the type of program the Iraqis want. INL officials stated that they are preparing for the 

program in the fiscal year 2011 budget. Security costs in that budget are projected to quadruple 

as the military withdraws and private security contractors are needed to fill the void. Also, INL 

 

9

 Pacific Architects & Engineers-Homeland Security Corporation and CPI. 
7 

plans to have a full and open competition for new contracts to support its law enforcement/rule 

of law mission and to award those contracts in 2010. 

The DynCorp contract was extended for 6 months (February 18, 2009, through August 17, 2009) 

under FAR provision 52.217-8, Option to Extend Services. Under that provision, the contract 

may be extended more than once, but the total extension is not to exceed 6 months. The 1-year 

extension (August 18, 2009 through August 17, 2010) to the contract without full and open 

competition was justified under 41 U.S. Code 253(c)(2) as set forth by FAR 6.302-2,10 as 

follows: 

“DynCorp International is currently performing the above services in the conflict 

or depressed areas of Iraq, Afghanistan, Sudan, Haiti, the West Bank and Liberia 

and INL continues to require the availability of the contract to respond rapidly to 

exigent requirements that may evolve before successor contracts can be 

awarded...Any delay in providing these critical services while awaiting execution 

of successor contracts would cause severe harm to diplomatic and military efforts 

to establish civil order and rule of law...The highly specialized training for both 

civilian police services and judicial services provided to these three governments, 

both in a war zone, along with the equipment necessary to perform their 

functions, precludes the possibility of a quick competition or substitution of the 

current contractor. The expected time required for the full competitive 

solicitation for the new contract is approximately 12 months. The delays in 

getting successor contracts in place result from frequent changes in program 

content as well as changes in USG [U.S. Government] policy instituted by the 

new administration.” 

Regarding the market research conducted to find alternative sources prior to the extensions, the 

contract documents state that due to the specialized nature of the services, training, locations, and 

the transition period that would be required, market research was minimal and involved using 

the U.S. General Services Administration’s Mission Oriented Business Integrated Services 

consulting services schedules. The documents further state that the schedules include companies 

that provide judicial support services and development and training services but do not provide 

those services overseas. Moreover, the labor rates for the consultants on the schedules were 

consistent with the current DynCorp contract rates. 

Largest Task Order Was Awarded As Exception to Fair 

Opportunity Provisions; Most Recent Task Orders Provided for 

Fair Opportunity 

Because three companies are under indefinite-delivery contracts to INL for the law 

enforcement/rule of law services, task order awards fall under FAR provision16.505(b)(1)(i), 

 

10 FAR 6.302-2, related to unusual and compelling urgency, states that when an agency’s need for the supplies or 

services is of such an unusual and compelling urgency that the government would be seriously injured unless the 

agency is permitted to limit the number of sources from which it solicits bids or proposals, full and open competition 

is not necessary. The statutory authority requires agencies to request offers from as many potential sources as is 

practicable under the circumstances. 
8 

“Fair Opportunity.” As such, contracting officers must provide each awardee a fair opportunity 

to be considered for each order exceeding $3,000 except as provided in FAR 16.505(b)(2). The 

exceptions include: urgency where fair opportunity would create unacceptable delays, only one 

awardee is capable of providing the supplies or services, economy and efficiency because it is a 

logical follow-on to a task order, or to satisfy a minimum guarantee. 

Task Order 1436 Was Exception to Fair Opportunity 

According to the AQM contract officer, Task Order 1436 was awarded under the provisions of 

FAR 16.505(b)(2). Although the FAR, subpart 4.8─Government Contract Files, states that the 

files should be sufficient to provide a complete background as a basis for informed decisions at 

each step in the acquisition process, we could find no written support for the exception to fair 

opportunity in the contract or task order files. According to the AIJS COR, it is not surprising 

that we could not find supporting documentation because contract decisions during the early 

years of the contract were not well documented. He indicated that his office has had similar 

problems in locating documents related to the task order. 

The initial performance period for the task order was from October 23, 2004, through January 

16, 2005. The task order performance period was extended through various modifications to 

May 31, 2008. 

Task Order 4761 Provided for Fair Opportunity 

Contractors were provided a fair opportunity for award of Task Order 4761. Requests for 

proposals were solicited from all three companies, and all three submitted proposals. A technical 

evaluation panel that comprised representatives from the Office of Iraq Programs and AIJS 

reviewed the proposals and determined that DynCorp and CPI had the highest scores. The panel 

rated the three proposals based on 46 factors distributed among 5 subtasks. The subtasks related 

to the contractors’ ability to provide: police, judicial, and correctional advisors (subtask 1); life 

and mission support for the advisors, such as lodging, subsistence, security, and communications 

(subtasks 2, 3, and 4); and common requirements, such as invoicing and transition plans (subtask 

5). Based on the proposals, the panel recommended that the award be split between DynCorp 

and CPI. Specifically, DynCorp would be responsible for providing police advisors, life and 

mission support for all advisors (police, judicial, and correctional), and DynCorp’s common 

requirements. CPI would be responsible for providing judicial and correctional advisors and its 

common requirements.11 The contracting officer accepted the panel’s recommendation. 

Upon completion of the technical evaluation, DynCorp and CPI were asked to submit revised 

proposals that reflected the contracting officer’s intent to split the award. The two companies 

submitted the revised proposals, which were evaluated based on cost and price. The independent 

government estimate for the combined price of both contractors was 54% higher than the 

contractors’ proposed prices. 

The period of performance for Task Order 4761 is from April 30, 2008, through February 28, 

2010. According to an AIJS official, the task order will likely be extended to ensure that 

services continue to be delivered until new contracts are awarded. 

 

11 According to AIJS officials, the provision to have CPI provide correction advisors was not exercised. 
9 

Task Order 7229 Provided for Fair Opportunity 

The award of Task Order 7229 for the renovation and expansion of villas for judicial advisors 

provided for fair opportunity. Requests for proposals were solicited from all three contractors, 

but only DynCorp and Pacific Architects & Engineers-Homeland Security Corporation submitted 

proposals. A technical evaluation panel that comprised representatives from the Office of Iraq 

Programs and AIJS reviewed the proposals and determined that DynCorp’s proposal was 

technically superior and price-advantageous to the government. 

The initial task order performance period was from October 1, 2008, through December 31, 

2008. In April 2009, INL requested additional work and the period of performance was 

extended to June 2, 2009. According to AIJS personnel, the work was completed in June 2009. 
10 

Oversight of Iraq Task Orders Is Weak 

The ICORs play a crucial role in overseeing DynCorp’s invoices, property management, lease 

agreements, and overall performance on the task orders. During the initial years of the 

concluded Iraq task orders, INL had only one ICOR, which was grossly inadequate to properly 

oversee the task orders. As a result, INL has no confidence in the accuracy of payments of more 

than $1 billion to DynCorp and is reconciling 100% of DynCorp’s historical invoices related to 

Iraq. However, personnel shortages, high error rates on invoices, and poor or missing support 

documentation have delayed the reconciliation process. 

Although INL increased its number of ICORs, oversight continues to be weak because both the 

number of ICORs and the guidance provided to those ICORs are insufficent. ICORs repeatedly 

said that they were understaffed. Three were in Iraq at the time we performed our audit. Our 

limited tests of controls over invoices found problems that could have been uncovered through 

proper oversight. For example, since December 2006 the government had rented two generators 

for a total of $450,000 when the requirement could have been satisfied with generators in stock. 

The lease had been renewed every 6 months, without question, until we raised the issue with the 

ICORs. 

DynCorp provides various types of equipment under the contract that must be controlled, 

preserved, protected, and maintained.12 The ICORs are responsible for ensuring that DynCorp is 

properly exercising its responsibilities pertaining to the control of equipment. This includes 

periodic checks of DynCorp’s inventory controls. The ICORs told us, however, that they do not 

have time to perform the periodic checks and rely on DynCorp to report problems. 

INL has paid for leased facilities in Iraq to house advisors provided by DynCorp and other 

organizations as well as to store equipment. During our work in Iraq, we found that some lease 

arrangements raise serious questions about the role of the ICORs in lease negotiations and INL’s 

oversight of the lease agreements. For example, we found that an ICOR was involved in a lease 

negotiation and also prepared the independent cost estimate. 

Quality assurance inspections are an integral part of oversight. Although INL has a detailed 

quality assurance surveillance plan in its statement of work for Task Order 4761, it has had no 

resources in Iraq since October 2008 to implement that plan. 

Task Order 4761 specifies qualifications for the various police and border patrol advisor 

positions DynCorp is required to fill. We found that DynCorp’s process for screening and 

selecting advisors and INL oversight of the process help ensure that task order requirements are 

met. 

 

12 Includes weapons, vehicles, and medical, food services, and personal protection equipment. 
11 

In-country Contracting Officer Representatives Are Essential for 

Oversight 

As mentioned earlier, INL staff shortages, especially in overseas positions, led to serious 

oversight problems, which were described in the July 2005 DoS Office of Inspector General’s 

report, the January 2007 joint audit report by SIGIR and DoS’ Office of Inspector General on 

Task Order 0338, and the April 2007 testimony by the Assistant Secretary of State, INL. In 

responding to the January 2007 joint report, INL stated that it had selected ICORs for Iraq, they 

were undergoing the clearance process, and their duties and responsibilities were detailed in their 

appointment letters. The appointment letters state that the ICORs’ responsibilities include: 

defining project requirements and developing statements of work or specifications; assisting in 

the preparation of purchase requests used to formulate contract modifications and/or task orders; 

monitoring contractors’ technical progress and the expenditure of resources relating to the 

contracts; performing government inspections and reviews; reporting costs being incurred that 

are not appropriately chargeable to the contracts; and validating contractors’ invoices, to include 

associated receipts for goods or services submitted by the contractor for payment. 

Prior to early 2007, INL had only one ICOR overseeing the Iraq task orders. Since March/April 

2007, INL has had a maximum of four permanently-assigned ICORs at any one time in Iraq. 

Three ICORs have been assigned since March/April 2007. The fourth ICOR arrived in January 

2008 and was replaced in August/September 2008 by another ICOR who left about a year later 

for Afghanistan. According to AIJS officials, efforts are underway to increase the number of 

ICORs in Iraq to 11. 

Weaknesses in Invoice Validation Process Continue 

DynCorp invoices are complex because of the billing structure and sheer volume of line items. 

During the initial years of the concluded Iraq task orders, the sole ICOR did little to no validation 

of invoices. Because INL had no confidence that it received what it paid for and that what it 

received was in accordance with the task order and contract, INL is performing a 100% 

reconciliation of those invoices. However, staff shortages, errors on invoices, and poor 

documentation are delaying the reconciliation process. Although INL has increased the number 

of ICORs over the years, the invoice review process continues to have serious weaknesses. 

Complex Contract Billing Structure Make Invoice Validation Necessary to Detect Erroneous 

and Excess Charges 

The DynCorp contract provides for a complex billing structure based on the services provided. 

For example, labor costs for police advisors and some support personnel, such as interpreters, 

program management, and medics, are to be billed based on firm-fixed labor rates. Those rates 

vary by type of specialty, and they have been adjusted over time as option years and contract 

extensions have been approved. The rates are to include wages, overhead, fringe benefits, 

general and administrative expenses, and profit/fee. Travel, training, and housing are to be billed 

on a reimbursable basis and require DynCorp to provide proof of costs. Some services and 

supplies, such as materials, subcontracts, minor construction, and morale/welfare/recreational 

activities, are to be billed on a cost-plus fixed-fee basis. Fees include a fixed-fee, material 

handling fee, overhead rate, and general and administrative expense rate. The overhead and 
12 

general and administrative expense rates have also been adjusted over time as option years and 

contract extensions have been approved.

The billing structure is further complicated in that DynCorp can charge for housing, food, 

protection, and other in-country services for police advisors as well as other advisors provided by 

CPI and U.S. government agencies. These services would have to be provided if the military 

cannot provide them when advisors are collocated with military forces. Moreover, advisors are 

in multiple locations in Iraq, and those locations as well as the number of advisors at those 

locations have changed and continue to change over time.

The invoice validation process is further complicated by the sheer volume of line items on the 

invoices. We reviewed a few invoices that had thousands of line items, including salaries for 

individuals, purchased items and supplies, leases, travel costs such as airline fares, and housing. 

Staff Shortages, Errors, and Poor Documentation Delay Reconciliation of Historical Invoices 

According to an AIJS official, during most of the period DynCorp was billing for Task Orders 

1436, 0338, and other task orders awarded earlier in the contract, the sole ICOR was approving 

all DynCorp invoices without questioning their accuracy. As a result, INL has no confidence in 

the accuracy of over $1 billion in charges and is now performing a 100% reconciliation of all 

INL-funded, Iraq-related invoices prior to October 2006.13 In April 2007 testimony, the 

Assistant Secretary of State, INL, stated that the reconciliation process would take 3 years. In 

October 2007, SIGIR was told that although the reconciliation effort began in April 2006, 

progress had been slow because a limited number of personnel were devoted to the effort and 

that the reconciliation process would take 3 to 5 years for 11 personnel to review and validate 

invoices that were paid prior to October 2006. In October 2007, INL officials stated that INL 

was working to obtain 10 detailees from the Defense Finance and Accounting Service and other 

agencies to assist INL staff with invoice reconciliations. According to the officials, seven 

detailees had been accepted, and INL was in the process of selecting the three remaining 

applicants. AIJS officials said in August 2009 that seven individuals were working on invoice 

reconciliations for the various task orders—two on Iraq, two on Afghanistan, two on Jordan, and 

one on reconciling payments to the DoS financial systems—and plans to bring on more 

individuals to reconcile invoices had been hampered by funding constraints. However, another 

AIJS official noted that funding had been approved to increase staffing to 10 personnel. We 

learned in December 2009 that only five individuals remained on the reconciliation team to 

complete the task.

The reconciliation is adversely affected not only by a shortage of personnel to examine invoices 

but also by high error rates on invoices and poor or missing support documentation. AIJS 

personnel said that the plan was to review 100% of the invoiced items except for labor charges. 

However, because tests of labor charges proved to show a high error rate, AIJS decided to review 

100% of the charges. Regarding poor documentation for charges, we were told that a review of 

some 3,000 timesheets for Task Order 0338 found that 93% had not been signed by a supervisor 

and 50% to 60% had not been signed by the employees. According to an AIJS official, INL will 

request reimbursement for the unsupported labor charges. DynCorp employees are working with 

AIJS personnel to find missing support documents.

 

13 INL stated that it began addressing contract management and oversight in Iraq beginning in October 2006. 
13 

To assist in the reconciliation effort, INL requested that the Defense Contract Audit Agency 

(DCAA) review direct labor and cost reimbursable elements for Task Order 1436. Regarding 

direct labor charges, the audit is to determine whether the hours charged match the hours on 

timecards and the rates charged agree with the contract rates. For reimbursable items, the audit 

is to determine whether the charges are allowable under the contract/task order and supportable. 

Finally, for the cost reimbursable items, DCAA auditors are to compare the billed costs to the 

audited and/or provisional indirect rates to ensure these have not been overbilled. The audit was 

underway at the time we completed our work in December 2009. 

DynCorp Invoice Preparation and Review Process 

DynCorp compiles invoices from various sources. For example, DynCorp records time worked 

by advisors in its Time and Labor System, which is used to compute labor charges. Labor 

charges for all police and border patrol advisors, who do not have security clearances, are 

received from its partially-owned subsidiary in Dubai, the DynCorp International Free Zone,14

and procurement costs are accumulated by various DynCorp systems depending on the type and 

location of purchases. 

According to DynCorp representatives, DynCorp has a number of internal controls to ensure that 

its invoices are accurate. For example, employees’ supervisors must approve time charges 

before they can be submitted; travel costs must be accompanied by authorized leave request 

forms, travel orders completed by the travel department, and airline tickets; housing costs under 

lease agreements require approved purchase requests, purchase orders, and vendor invoices; all 

costs are reviewed against proposals and statements of work; and all materials and services 

purchased through subcontractors require approved purchase requests, delivery receipts, and 

invoices. DCAA reviewed DynCorp’s billing, labor accounting, and information technology 

control systems and reported significant internal control deficiencies.15 According to DCAA 

officials, DynCorp submitted corrective action plans and asserts that the actions have been taken. 

DCAA reviewed the action plans and determined that DynCorp’s proposed actions had the 

potential to address the identified conditions if implemented and monitored properly. However, 

DCAA considers the controls to be inadequate until corrective actions have been completed and 

an audit verifies that actions have been effectively implemented. DCAA plans to review the 

systems and corrective actions in fiscal year 2010. According to DCAA officials, DynCorp’s 

senior management has taken significant interest in fixing the problems. 

INL’s Validation Process for Current Invoices Continues to Have Serious Weaknesses 

As mentioned earlier, the sole ICOR approved DynCorp invoices for Task Orders 1436, 0338, 

and others awarded earlier in the contract without questioning their accuracy. As a result, INL 

has no confidence that the invoices are accurate and has undertaken an effort to reconcile them. 

 

14 According to DynCorp representatives, the advisors are employed by the Dubai subsidiary, which charges 

DynCorp for their services. Also, according to the representatives, U.S. employees with security clearances must be 

employed by a U.S.-based company. 

15 Report on Audit of Billing System, Audit Report No. 03181-2009D11010001, 4/23/2009. Report of Labor 

Accounting System and Internal Controls, Audit Report No. 03181-2007D13010001, 3/18/2009. Report on Audit of 

Contractor Information Technology (IT) General Internal Controls, Audit Report No. 3311-2006Q11510001, 

4/17/2007. 
14 

Although three ICORs were in Iraq at the time of our audit, only one was responsible for 

validating invoices for Task Order 4761, which had obligations of almost $800 million. The 

only guidance we found pertaining to invoice validation was an invoice review checklist that the 

ICOR is to submit to AIJS with the invoice. The checklist has 18 questions to which the ICOR 

must answer yes, no, or not applicable. Examples of questions are: Were the correct labor rates 

used and calculated correctly?; Were travel costs calculated correctly and are they properly 

documented?; and, Are all costs submitted on the invoice included in the awarded task order? If 

the answer to any question is no, the invoice is to be rejected. 

We found serious weaknesses with the ICOR’s validation process. For example: 

• The ICOR said that his validation of payroll charges consists of comparing the names of 

employees listed on two documents provided by DynCorp headquarters: the employee 

roster and the invoice. He also said that he had not tested the accuracy of the employee 

roster by verifying that the employees shown on the roster for a location were actually 

there. During our visits to sites where employees are located, we visually tried to verify 

that the individuals listed on the headquarters roster were there or could be accounted for 

through other means such as documented authorized time off. Through this check, we 

found that the roster provided by DynCorp headquarters was not current in that some 

advisors listed on the roster had been transferred. When we informed DynCorp 

representatives of our findings, they agreed that the headquarters roster was not up to date 

and that the roster maintained at the installation was correct. They agreed to make 

changes to ensure the headquarters roster is corrected. The ICOR was unaware of the 

inaccuracies in the headquarters roster and had been comparing an incorrect roster to 

invoices without discovering the discrepancy. We tested the accuracy of the rosters 

maintained at the installations and found that the individuals listed were either there or 

could be accounted for through other means. 

• The ICOR had not performed other checks to determine payroll accuracy. For example, 

he had not verified that the individuals were entitled to pay for days claimed.16 Our 

comparison of timecards with authorized time off documents showed that some 

individuals had been overpaid while others had been underpaid. When we informed 

DynCorp officials, they agreed with our findings, have undertaken a 100% review of 

timecards submitted since July 2008 (the start of Task Order 4761), and have instituted 

other processes and training to help prevent this problem from occurring in the future. As 

of November 2009, DynCorp’s review of timecards had just started and had found a 30% 

error rate at a few locations and that 75% of the errors were overpayments to individuals. 

• The ICOR said that he does not compare, even on a test basis, individuals’ pay rates to 

the rates specified in the task order but relies on DynCorp to get it right. Nevertheless, on 

some of the invoice review checklists, he had answered yes to the question—Are the 

correct labor rates being used and calculated correctly? When questioned about his 

answer, he stated that he considers his reviews to be preliminary and that others in AIJS 

or AQM verify the rates and calculations. We did not determine whether the pay rates 

 

16 While in Iraq, an individual is entitled to his/her daily salary. When an individual leaves Iraq for authorized time 

off, he/she is entitled to their pay for the day of departure and the day of return. The individual is not entitled to 

their pay for the other authorized days off. 
15 

DynCorp had charged were correct and believe this process would be involved because, 

as mentioned earlier, the rates vary by type of specialty; have been adjusted over time as 

option years and contract extensions have been approved; and include overhead, fringe 

benefits, and other items. 

• Because timesheets submitted under earlier task orders often were not signed by the 

employee and/or supervisor, we asked DynCorp if it had corrected the problem for Task 

Order 4761. DynCorp representatives said that timesheets for Task Order 4761 are 

entered into DynCorp’s Time and Labor System which automatically records an 

employee’s signature when the employee submits the timesheet to the supervisor and 

automatically records the supervisor’s signature when that individual submits the 

timesheet. We validated the DynCorp employees’ statements. We found problems with 

the controls in the Time and Labor System in that supervisors can elect to approve all 

timesheets at once rather than individually. When we informed DynCorp representatives 

of this situation, they said that they would emphasize to supervisors in training that they 

should approve each timecard individually. We informed the ICOR of this weakness in 

controls and emphasized to him that individual approval would require the supervisor to 

at least consider the time charges being approved. 

• INL has been leasing two generators for villas at a camp in Erbil since December 2006 at 

a total cost of $450,000 even though generators were in inventory. The lease, which has 

been renewed every 6 months, is scheduled to end in February 2010. The cost of the 

lease for the first 6 months was $66,000, and the total cost of the lease from December 

2006 through February 2010 is $450,000. According to the landlord’s business 

representative, the landlord initially offered to lease the generators at $11,000 per month 

or to sell the generators for $39,000 each, or $78,000 total, but INL chose to lease the 

equipment.17 The ICOR stated that he was unaware of the lease arrangement for the 

generators even though DynCorp submitted invoices for the leases. Another ICOR stated 

that the requirement for the generators could have been satisfied from generators in stock, 

negating the need for their lease or purchase. We later learned that the ICORs had 

instructed that two in-stock generators be moved to the camp in Erbil. 

• INL was paying for two security teams in the Kurdish region at a camp in Sulaymaniah to 

protect six corrections advisors. One team, comprising 16 DynCorp personnel, was 

assigned in June 2009 at the request of an ICOR. DynCorp representatives in the area 

indicated that the security team was unneeded since the region is very safe, but an ICOR 

had instructed that the security team be transferred to the area. The DynCorp 

representatives stated that police advisors travel with no protection. According to an 

AIJS official, a generic DynCorp security team consisting of 13 personnel (which is 

smaller than the team assigned to Sulaymaniah) costs about $4.54 million per year, which 

includes lodging and other support costs. After we raised the issue with an ICOR, he said 

that he had recommended that INL relocate the DynCorp security team from 

Sulaymaniah since INL was also paying for a security team provided by Janusian 

Security Risk Management, LTD, under a subcontract with DynCorp to protect the same 

corrections advisors. An AIJS official told us that the Janusian security team at that camp 

costs about $546,000 annually. 

 

17 In 2007, the cost to lease the two generators increased to $12,000 per month. 
16 

The ICOR said that he simply did not have the time to validate the invoices and relies on 

individuals within AIJS to perform the validation. In late November 2009, we learned that he 

was reviewing and processing about 100 invoices before going on leave in mid-December. The 

one individual in AIJS who is assigned responsibility for reviewing and processing current 

invoices said he relies on the ICOR to validate the invoices. AIJS includes the group that is 

responsible for reviewing all historical invoices. However, as mentioned previously, that group 

is already behind schedule in reviewing invoices that are several years old. 

ICORs Exercise Limited Oversight of Property Management 

Under its contract, DynCorp provides various types of equipment that must be controlled, 

preserved, protected, and maintained. The ICORs are responsible for ensuring that DynCorp is 

properly exercising its responsibilities. Those responsibilities include periodic checks of 

DynCorp’s inventory controls. The ICORs noted that they do not have time to perform the 

periodic checks and rely on DynCorp to report problems. However, the ICORs have participated 

in yearly inventory reviews. In our tests of inventories for high-value and sensitive items such as 

weapons, generators, and vehicles, we either located all items or DynCorp representatives 

satisfactorily explained why the items were unavailable for us to see. We brought to the ICORs’ 

attention other issues related to property management, such as a large backlog of property to be 

disposed of or destroyed. 

Contract and Task Order Requirements 

The contract specifies that DynCorp may be required to provide various types of equipment,18

supplies, and facilities to support the program in Iraq. The government equipment, which is 

either provided by the government or purchased for the government, is to be managed according 

to the requirements of FAR 52.245. The regulation requires the contractor to control, preserve, 

protect, repair, and maintain U.S. government property in its possession. FAR 45.105(a) states 

that the agency responsible for contract administration shall conduct an analysis of the 

contractor’s property management policies, procedures, practices, and systems. The DoS 

Foreign Affairs Handbook requires DoS property managers to conduct annual inventory audits. 

The statement of work for Task Order 4761 requires DynCorp to establish an automated 

inventory management system to track accountable government-furnished property and 

contractor-purchased equipment and supplies. The statement also requires DynCorp to provide 

monthly inventory reports of all accountable property to the ICORs and COR. According to 

INL, an ICOR must approve all purchases of equipment before DynCorp makes the purchase.

As part of quality assurance/quality control, DynCorp and the ICORs are required to conduct 

random unannounced inventories of selected line items, and the contractor is to conduct 

additional inventory reviews at the direction of the ICORs. DynCorp property managers must 

also review 10% of the non-sensitive inventory items and 100% of the sensitive items (e.g., 

weapons, ballistic vests) every month. The contractor is required to immediately report to the 

ICORs and COR any loss, suspected loss, or damage to accountable property. Under the COR’s 

direction, the contractor is to investigate the circumstances of the loss or damage and recommend 

disciplinary action and procedures to prevent recurrence.

 

18 Such as weapons, vehicles, and medical, food services, and personal protection equipment. 
17 

DynCorp Property Management System Found to be Satisfactory by Defense Contract 

Management Agency 

According to DynCorp representatives, its automated property management system, DynMRO, 

is a fully-integrated property management system. As such, it can account for equipment and 

supplies from purchase order to destruction/disposal. The system has been operational since 

2007 and has been reviewed by the Defense Contract Management Agency. In September 2009, 

the Agency found the system acceptable to protect government property. The agency found no 

major discrepancies, and required no corrective actions.

ICORs Provide Limited Oversight of Property Management 

We confirmed that an ICOR is required to approve all purchase orders, including those for 

low-cost bench stock items. During November 2009, we learned that the ICOR who had been 

approving purchase orders had a backlog of over 700 purchase orders to review and approve. 

The ICORs said that they perform a 100% annual review of the inventory and were conducting 

that review as we were completing our audit. During the last review, the ICORs found that 

DynCorp had made significant progress in accounting for government-held property since the 

2008 review. The total net value of the government property managed by DynCorp was about 

$145.2 million, and the review found shortages of about $68,500, or .05%. The 2009 review 

found property management at several locations in Iraq was excellent and that staff was well 

trained in DynMRO applications and property accountability. However, the ICORs also found 

careless property record-keeping, failure to implement DynMRO, and a lack of adequate 

DynMRO training for logistics staff at some locations. It further found that some of the 

problems stemmed from DynCorp’s failure to perform the required 10% monthly physical 

inventory reviews. The report recommended improvements. According to DynCorp 

representatives, DynCorp has corrected some of the problems and is working to correct others. 

DynCorp provided documents to support most of its corrective actions. 

As we traveled to various camps, we performed limited tests to determine whether high-value 

and sensitive items included in DynMRO were on hand or accounted for. We tested the 

inventories for weapons, vehicles, generators, containerized housing units, and computers. We 

either located items in our tests or DynCorp representatives were able to satisfactorily explain 

why the items were unavailable for us to see. For example, some items had been moved with 

personnel moves and DynMRO had not been adjusted. We brought the following issues related 

to inventories to the ICORs’ attention:

• At Camp Shield in the Baghdad area, DynMRO contained a large number of items 

assigned to a DynCorp employee. The items had been purchased with DoD funds by 

another contractor and were supposed to be transferred to the Government of Iraq. 

However, previous DynCorp personnel had discovered the items and recorded them in 

DynMRO as INL property. Although the installation was included in the prior year 

100% inventory review, the ICORs were unaware of the problem. The DynCorp logistics 

manager said that DynCorp would correct the problem. 
18 

• At Camp Klecker in the Baghdad area, where items awaiting destruction or disposal are 

stored, we found a large backlog of such items valued at about $2 million.19 DynCorp 

representatives said that the proper documentation had been prepared and submitted to 

INL for destruction or disposal of the items, but no action had been taken for months. 

They were concerned that the ICORs would raise issues with this property as they had in 

the prior annual audit. We discussed the large backlog with the COR and contracting 

officer and asked them why no actions had been taken. They said they were unaware of 

the backlog and would look into it. 

The ICORs said that they do not have time to conduct random unannounced inventory reviews of 

selected line items at the various locations and rely on DynCorp to perform day-to-day checks of 

the inventories and surface any problem in monthly reports. We learned that the ICOR 

responsible for reviewing the DynCorp property book had not logged into DynMRO since 

January 2009.

INL’s Practices Are Questionable and Oversight of Leased Facilities 

Is Poor 

INL has paid for leased facilities in Iraq to house advisors provided by DynCorp and other 

organizations and to store equipment. An ICOR said that INL had a total of six active leases in 

November 2009. We also learned of other leases that had been terminated. During our 

in-country work, we learned of some lease arrangements that raise serious questions about the 

ICORs’ role in lease negotiations and INL’s oversight of the lease agreements. 

The following are examples of lease arrangements that raise questions about INL’s oversight 

responsibilities: 

• INL was reimbursing DynCorp for the lease of villas that were renovated and expanded 

under Task Order 7229. The villas, which are located in the international zone, were 

rented for $35,000 a month. In addition, DynCorp is authorized to charge about 11% of 

the rental price for fees, overhead, and general and administrative expenses. The initial 

lease was signed in September 2008, and the current lease extends to February 2010. An 

ICOR said that he helped negotiate the cost of the lease with the property manager. 

DynCorp prepared the lease agreement. Although the villas have been substantially 

improved at a cost to the U.S. government of about $1.4 million, we found no evidence 

that the price negotiations factored in the cost of the improvements to the property. 

• INL reimbursed DynCorp $747,041 for the lease of a parcel of land in the international 

zone to be used to establish a camp. The lease was for 15 months from December 2008 

through February 2010 but was terminated after only 4 months in March 2009. The 

monthly rental was $90,000 to which DynCorp added its 11% for fees, overhead, and 

general and administrative expenses. According to an ICOR, the lease agreement 

required that 50% of the total lease cost be paid in advance. He also said that INL had 

anticipated a need for the land for a number of containerized housing units for individuals 

that would need to relocate from other installations but that it subsequently determined 

 

19 Includes such items as furniture, vehicles, and equipment. 
19 

that the land was not needed. The landlord’s business representative said that an ICOR 

helped to negotiate the cost of the lease with the property manager. According to a 

document in the contract/task order file, the same ICOR prepared the government’s 

independent cost estimate, which simply stated that the cost estimate was $150,000 per 

month; no explanation was given as to how that estimate was derived. DynCorp prepared 

the lease agreement. A contracting officer in the U.S. Embassy’s General Services Office 

who specializes in leases in the international zone told us that the price negotiated for the 

land appeared excessive and that the ICOR had not consulted with his office concerning 

the lease arrangement. He further stated that the Embassy had negotiated the lease of a 

parcel of land in the international zone that is 807,283 square feet at a cost of $3.75 

million per year, or $4.65 per square foot. The INL lease, which was for 34,510 square 

feet of land, would have cost $1.08 million per year, or $31.30 per square foot. Thus, the 

lease of the INL parcel would have cost almost seven times as much per square foot as 

the lease of the Embassy parcel. 

• INL was reimbursing DynCorp for the rental of three homes in the international zone. 

The homes, which varied in size, were used to house advisors. At the time we completed 

our audit in country in November 2009, INL had 6-month leases for the homes: two for 

$15,000 a month and one for $20,000 a month. Two of the leases were scheduled to end 

in February 2010 and one was scheduled to end in January 2010. All three leases 

increased in cost over time. Two of the increases appeared to be excessive. Specifically, 

the lease for house #6 began in January 2006 at a monthly cost of $12,000, but in January 

2008, the monthly rent increased 67% to $20,000. The lease for house #22 began in 

August 2006 at a monthly cost of $10,000, but in January 2009, the monthly rent 

increased 50% to $15,000. We saw no indication that the lease agreements included 

price escalation clauses that would have limited the increases. 

• DynCorp subleased land at Camp Victory in Baghdad for INL to temporarily store 

containerized housing units until they could be moved. The lease was with the Defense 

Logistics Support Services Corporation, which had been authorized by the landlord, the 

Multi-National Corps-Iraq,20 to sublease the property. The authorization stipulated that 

the Defense Logistics Support Services Corporation could charge for services (utilities 

and security) but not for use of the land. INL was charged $53,400 a month from March 

2007 through May 2009 for the services. The services were terminated in May when the 

containerized housing units were moved to Camp Butler. We were told that the only 

security for the area in which the housing units were stored was provided by 

third-country nationals and that the cost of that security would be minimal since the area 

is within the confines of other secure areas. When we questioned an ICOR as to why he 

did not review the cost of the lease, he stated that the lease was in effect before he arrived 

in Iraq. When asked as to why he had not questioned the costs, he had no response. 

Furthermore, DynCorp did not respond to our requests for details concerning the $53,400 

monthly costs. The COR stated that he was aware of the lease but was unaware of the 

reasons for the costs and would have an AIJS employee look into the matter. 

 

20 This command was subsumed into U.S. Forces-Iraq on January 1, 2010. 
20 

INL Performs Minimal Quality Assurance Oversight 

Quality assurance inspections are an integral part of oversight. They can help ensure that the 

government is receiving the services specified in the task order and that the services meet the 

specified performance standards. DynCorp has implemented a quality control program as 

required by Task Order 4761. Although INL has a detailed quality assurance surveillance plan in 

its statement of work for Task Order 4761, it did not have the resources in Iraq to implement that 

plan. 

DynCorp Quality Control Requirements and Activities 

The statement of work for Task Order 4761 requires DynCorp to develop and implement 

effective quality control and continuous improvement processes to meet or exceed the 

performance standards established in the statement of work. DynCorp is required to report 

monthly on its quality control efforts, including a brief description of projects, current quality 

control activities, major quality control activities accomplished during the period, planned 

activities for the next period, observed and identified risk areas within the project, and the trend 

of that risk (improving, worsening, no change) as well as impacts of the risks and risk mitigation 

recommendations. 

DynCorp had a quality control program and had a quality control team of four individuals in Iraq 

that visited installations and produced monthly quality control reports. The reports for July 

through September 2009 appeared to conform to requirements in the statement of work. 

DynCorp representatives noted that DynCorp would be adding three additional personnel to the 

team.21 

ICORs Perform Minimal Quality Assurance Oversight 

The statement of work for Task Order 4761, appendix 3, states that INL’s Quality Assurance 

Surveillance Plan is to be used to “assure that systematic quality assurance methods are used in 

administration of the performance-based requirements.” The plan details how and when the 

government will survey, observe, test, sample, evaluate, and document the contractor’s 

performance in accordance with the statement of work. The stated purpose of the plan is to 

ensure that INL is receiving the services specified in the task order and that the services meet the 

performance standards specified in the task order. The plan further states that by employing a 

fully developed plan, INL and the contractor will “achieve an understanding of performance 

expectations and how performance will be measured against those expectations.” Moreover, a 

complete and robust plan ensures that all aspects of the task order are measured and receive fair 

and proper weight in the overall evaluation. Further, the results of the plan evaluation are a 

direct and significant input on the performance of this task order. The government is to perform 

scheduled, random, and customer feedback inspections to determine the contractor’s compliance 

with the task order and to assess performance acceptance in conjunction with the plan. The 

COR/ICOR and their representatives are responsible for inspection and acceptance of services as 

outlined in the plan. 

According to an ICOR, no quality assurance inspections had been performed since October 2008 

when INL’s quality assurance manager left Iraq. The ICOR also said that he does not have the 

 

21 In mid-November 2009, two individuals were added to the team. 
21 

staff to conduct formal quality assurance inspections as specified in the quality assurance 

surveillance plan. Instead, the ICORs said they review DynCorp’s monthly quality control 

reports and perform some quality assurance checks when visiting various sites, but those checks 

are minimal. 

Police and Border Patrol Advisor Screening and Selection Process 

Helps Ensure Task Order Requirements Are Met 

Task Order 4761 specifies qualifications for the various police and border patrol advisor 

positions DynCorp is required to fill. DynCorp has an established process to screen and select 

individuals that meet those qualifications and verify details about the individuals. In addition, all 

applicants must attend a training and evaluation program during which candidates are subjected 

to physical and psychological assessments, fire arms testing, and interviews. According to 

DynCorp representatives and INL officials, INL personnel participate in the training and 

evaluation program and have an opportunity to evaluate the candidates during the program. In 

addition, INL officials noted that INL personnel review each candidate’s resume and must 

approve the candidate for admission to the program.

Task Order Requirements for Police and Border Patrol Positions 

The statement of work for Task Order 4761 specifies minimum and preferred qualifications for 

the various police and border patrol positions DynCorp is required to fill. For example, police 

advisors are to: have a minimum of 5 years of work experience as a state or local law 

enforcement officer with principal responsibilities for providing police protection and criminal 

investigation services, including experience as a field training officer; have extensive knowledge 

of and experience in certain subject areas, such as criminal investigations and patrol operations; 

have the ability to effectively communicate, advise, and train others; and be free of physical 

defect(s), disease, or psychological conditions that would render the individual unable to perform 

critical tasks. Preferably, police advisors would have 2 or more years as a first-line supervisor in 

a law enforcement organization; specialized training in areas such as firearms and instructor 

development; and a bachelor’s degree from an accredited educational institution in a law 

enforcement-related field. Border patrol advisors, for example, are required to have 4 or more 

years of work experience as a U.S. Border Patrol Officer or as an officer within the Bureau of 

Immigration and Customs Enforcement (or its predecessor agencies); service as a field training 

officer; and professional knowledge and expertise in modern techniques, operations and related 

functions of points of entry and border enforcement, and a background in customs and 

immigration practices. Police advisors are required to be U.S. citizens, whereas border patrol 

advisors can be from countries that have credentialed border police. These include the United 

Kingdom, Australia, and Canada. 

INL Actively Participated in Advisor Screening and Selection Process 

According to DynCorp representatives, DynCorp has a detailed screening and selection process 

for police and border patrol advisors. DynCorp representatives stated that applications are 

screened electronically to ensure that each applicant meets the minimum experience required for 

the position; applicants are interviewed by a recruiter to verify details about background and 

experience and to surface disciplinary/criminal issues; information is collected from the 
22 

applicant’s employer concerning any Internal Affairs investigations and to confirm employment, 

licensing, and certification; statements concerning education, work history, and criminal/credit 

history are validated by a third party company; all background information is reviewed by a 

committee of recruiting supervisors chaired by a retired chief of police; and applicants must 

attend Police Assessment, Selection, and Training, a 2-week training and evaluation program 

during which candidates are subjected to physical and psychological assessments, fire arms 

testing, and interviews. 

According to DynCorp representatives and INL officials within the Office of Iraq Programs, INL 

officials participate in each 2-week training session to inform the candidates of their duties and 

responsibilities and the conditions they will be subjected to and to assess the candidates. In 

addition, INL must approve all police and border patrol candidates. According to Office of Iraq 

Programs officials, that office reviews each candidate’s resume to see if the documents raise 

questions concerning experience. The officials further stated that INL must approve the 

candidates for admission to the program. 
23 

Status of Actions to Address Prior Recommendations 

We could not determine the status of INL’s corrective action plan because INL did not provide 

us with that information. Most of the actions related to recommendations pertaining to Task 

Order 0338 were on hold at the direction of the Department of Justice. One recommendation 

pertaining to Task Order 0338 and related to duties and responsibilities of the COR and 

contracting officer remains open because INL had not taken all of the corrective actions it had 

previously claimed. 

Status of INL’s Corrective Action Plan 

SIGIR’s October 2007 report recommended that INL prepare a coordinated, comprehensive 

corrective-action plan that would include the various contract-management improvement 

initiatives within AIJS. SIGIR’s April 2008 report stated that INL had prepared a plan using 

Microsoft Project and that the plan included start and finish dates for the initiatives. The report 

also stated that, according to INL, the project manager and executive director had approved the 

AIJS priority tasks, time frames, and resources needed for accomplishing the comprehensive 

plan and that the items were due for formal approval by INL’s principal deputy assistant 

secretary and assistant secretary. 

Despite repeated requests for information concerning the status of INL’s corrective action plan, 

INL did not provide the information. 

Status of Prior Recommendations Pertaining to Task Order 0338 

SIGIR’s April 2008 report found that corrective actions on the recommendations were in 

process. The following paragraphs present updated information on INL’s implementation of 

those recommendations:

Recommendation on 1,040-person residential camp: Present to the U.S. Ambassador to Iraq a 

plan for review and approval of the use of the residential camp to house police trainers, as 

originally intended, or of the disposal of the facility. 

Prior Status: Corrective actions were in process. INL had conducted an inventory of all 

1,181 trailers associated with the camp, had transferred 495 residential trailers to 

the Bureau of Overseas Building Operations for use at the U.S. Embassy in 

Baghdad, and was in the process of transferring the remaining trailers for use for a 

500-person residential camp at the Baghdad International Airport. Construction 

on that camp, scheduled for use by police trainers and support personnel, was 

scheduled to begin in April 2008. 

Current Status: During October 2008, DoS Office of Inspector General personnel 

visually inspected the residential trailers and associated support facilities at the 

U.S. Embassy Baghdad. In addition, we visually inspected and accounted for 

trailers at the Embassy and camps we visited. 
24 

Recommendation on disputed payments: Seek reimbursement from DynCorp for the 

improperly-authorized $4.2 million payment for contractually unauthorized work directed by the 

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

manufacture of additional trailers for very-important-persons, and the construction of an 

Olympic-size swimming pool. 

Prior Status: Corrective actions were in process. In response to a June 2007 demand 

letter issued by the Office of Acquisition Management to DynCorp for 

$4,060,959, DynCorp disagreed and contested the office’s position that the work 

was unauthorized and improper. The company stated that the previous 

contracting officer and the COR had authorized the work. INL was reviewing 

documents that DynCorp provided to support its position. 

Current Status: In April 2008, INL disputed the DynCorp reply. Subsequently, INL 

was notified by the Department of Justice to temporarily suspend any collection 

effort due to a related case. 

Recommendation on invoice reviews: Request that DCAA review two DynCorp invoices: one 

dated July 30, 2004, which included a residential-camp mobilization fee, to determine whether a 

prepayment of $18.0 million occurred, and a second one dated October 30, 2006, for 

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

receipt of the DCAA audit report, the contracting officer should take the appropriate action.

Prior Status: Corrective actions were in process. INL was reviewing the DCAA reports 

on the two invoices and DynCorp’s response to those reports. 

Current Status: Regarding DCAA’s review of the labor costs, DCAA questioned 

$162,869 because DynCorp billed for labor hours for which it did not pay its 

workers. This questioned cost is based on a sample of 21 out of 413 employees 

who charged hours to a particular contract line item. As with the previous 

recommendation, INL was notified by the Department of Justice to temporarily 

suspend actions due to a related case. 

Recommendation on duties and responsibilities: Enforce procedures to ensure that the 

contracting officer and COR comply with duties and responsibilities as identified in the DoS 

Foreign Affairs Handbook. These procedures should address the following matters: receiving 

and retaining technical and financial reports; examining invoices and supporting documentation 

before certification for payment; processing “receiving and inspection reports” for equipment; 

and maintaining a COR file. 

Prior Status: Corrective actions were in process. According to INL: 

a) The COR was retaining financial and technical reports. 

b) AIJS was rejecting all invoices not properly supported or not in agreement with all 

terms and conditions in the contracts. It reported that it had rejected invoices 

amounting to more than $260 million from contractors in Iraq and Afghanistan. It 
25 

further reported that rejected invoices are often corrected and resubmitted for lesser 

amounts, resulting in savings of $5.6 million to date.22

c) It had completed a 100% weapons-accountability check. In addition, it routinely 

requires monthly accountability reports from contractors for weapons and other 

equipment and makes spot checks to verify the reports. Moreover, the contract files 

were fully compiled and organized by country, contract, and invoice number. 

Current Status: INL had not taken all of the corrective actions it previously claimed. 

As discussed earlier in this report, it was not performing a thorough enough review of 

current invoices to identify and reject invoices not properly supported or not in agreement 

with the terms and conditions of the contract. Regarding equipment, the ICORs were not 

spot-checking DynCorp monthly accountability reports. Moreover, the contract files 

were incomplete. Therefore, we consider this recommendation open. 

 

22 According to INL, the savings applied to both Iraq and Afghanistan. 
26 

Conclusions, Recommendations, and Lessons Learned 

Conclusions 

INL continues to exhibit weak oversight of the DynCorp task orders for support of the Iraqi 

police training program. INL lacks sufficient resources and controls to adequately manage the 

task orders with DynCorp. As a result, over $2.5 billion in U.S. funds are vulnerable to waste 

and fraud. The ICORs, who are critical to overseeing DynCorp’s performance and expenditures 

under the current task order, do not perform adequate reviews and tests to ensure that (1) the 

costs submitted by DynCorp on invoices are allowable under the contract/task order, supported 

by appropriate documentation, and correct; (2) U.S. government property managed by DynCorp 

is adequately controlled; (3) lease agreements negotiated on behalf of the U.S. government 

protect the government’s interests; and (4) the U.S. government receives the services at the 

performance standards specified in the task order. As DoS takes responsibility for the police 

training program from DoD in 2011 and DoS continues to oversee contracts costing the 

American taxpayers hundreds of millions of dollars, it will be critical for DoS to have in place 

effective management and controls of those contracts to ensure that U.S. funds are effectively 

and efficiently spent. 

Inadequate resources and controls is not a new problem. As early as 2005, INL was told that its 

staffing had not increased commensurate with its workload and that it needed to strengthen its 

oversight of the contracts for Iraq and Afghanistan. In 2007, INL was again told that its poor 

oversight of the contract for Iraq had put millions of dollars at risk. In a hearing and in responses 

to audit reports, INL officials have repeatedly stated they recognized the problems and had 

initiatives to increase staff and improve management and oversight of the contract for Iraq. 

However, INL has fallen far short on those initiatives. 

INL stated that it plans to increase the number of ICORs in Iraq to 11─there were 3 in November 

2009. However, the ICORs need additional guidance to clearly specify their responsibilities and 

more oversight to determine what they are or are not doing. Until that guidance is developed and 

implemented, INL is in no position to accurately determine how many additional ICORs it needs. 

SIGIR believes that more than 3 ICORs are needed but does not believe INL has demonstrated it 

needs 11. 

Because of weak oversight of the DynCorp contract in Iraq from its start in 2004, INL is 

reconciling all historical invoices. Although SIGIR was told in October 2007 that the 

reconciliation effort would take 3 to 5 years to complete by a full complement of 11 personnel, 

the reconciliations will likely take longer because INL has not fully staffed the effort. In 

addition, reconciliation efforts have been adversely impacted by high error rates on invoices and 

poor or missing support documentation. Moreover, the workload will likely increase because of 

the problems found with the current invoice review process. 
27 

Recommendations 

Because weak contract administration and oversight have been long-standing issues that INL has 

not corrected, SIGIR recommends that the Deputy Secretary of State for Management and 

Resources, take the following actions: 

1. Direct an immediate examination of the Afghanistan, Iraq, Jordan Support Division’s 

personnel and operations to determine if the Division is structured, staffed, and managed to 

effectively and efficiently oversee the contracts under its responsibility. The results of this 

examination should be provided to the authorization and appropriations committees of the 

Congress. 

Until such an examination can be conducted and to improve contract administration and 

oversight, SIGIR further recommends that the Assistant Secretary, Bureau of International 

Narcotics and Law Enforcement Affairs, direct the Chief of the Afghanistan, Iraq, Jordan 

Support Division take the following actions: 

2. Develop detailed guidance for the ICORs that specify their responsibilities and ways they can 

fulfill those responsibilities. 

3. Assign specific responsibilities to each ICOR, and have each provide reports on actions taken 

to fulfill assigned responsibilities. 

4. Determine how many ICORs are needed to accomplish assigned responsibilities, and request 

positions to fill those needs. 

5. Determine how many additional personnel are needed to review and validate historical 

invoices within the next 2 years and request positions to fill those needs. 

Lessons Learned 

Because INL relies on contractors for assistance in implementing police training programs in 

other countries, such as Afghanistan, it needs to consider the adequacy of its oversight 

mechanisms in those countries. Recommendations 2, 3, and 4 could be applicable to ICORs in 

those countries. 

Management Comments and Audit Response 

INL agreed with SIGIR’s recommendations. It did not agree with SIGIR’s position that $2.5 

billion in U.S. funds are vulnerable to waste and fraud. Because of the serious control 

weaknesses identified in this and prior audits, SIGIR maintains its position.
28 

Appendix A—Scope and Methodology 

Scope and Methodology 

In June 2009, the Special Inspector General for Iraq Reconstruction (SIGIR) initiated Project 

9025 to audit the Department of State’s (DoS) oversight of the DynCorp International task orders 

that support the Iraq Police Training Program managed by the Multi-National Security Transition 

Command-Iraq.23 SIGIR’s objectives for this report were to examine: (1) the cost, funding, and 

award process for Task Orders 1436, 4761, and 7229; (2) DoS oversight of DynCorp-provided 

services for the three task orders; and (3) the status of INL’s implementation of prior 

recommendations pertaining to Task Order 0338 as well as overall contract management and 

oversight. SIGIR performed this audit under the authority of Public Law 108-106, as amended, 

which also incorporates the duties and responsibilities of inspectors general under the Inspector 

General Act of 1978. SIGIR conducted its work during July through December 2009 in 

Baghdad, Erbil, and Sulaymaniah, Iraq; the Washington, D.C. area; and Fort Worth, Texas. 

To determine the cost and funding for the three task orders, SIGIR requested the detailed cost 

data and funding source from the Bureau of International Narcotics and Law Enforcement 

Affairs (INL). We initially requested the detailed cost data during our entrance meeting in early 

July 2009 and made repeated requests during subsequent months. INL did not provide the data 

until early January 2010. Our preliminary analysis of the data raised questions which could not 

be resolved in time for inclusion of the data in this report. SIGIR will continue to pursue those 

questions with INL. 

To evaluate the award process, SIGIR examined available documents pertaining to (1) the 

government’s evaluations of the contractors’ proposals, (2) the contractors’ proposals, and (3) 

DoS’ justifications for the task order awards. 

To determine DoS’ oversight of the task orders, SIGIR reviewed the contract and task order 

provisions. We gained an understanding of DynCorp’s internal controls by reviewing pertinent 

documents and conducting discussions with DynCorp and Defense Contract Audit Agency 

(DCAA) personnel in Fort Worth, Texas. In Iraq, we discussed with the In-country Contracting 

Officer Representatives (ICOR) their oversight procedures and practices related to invoices, 

property management, lease agreements, and DynCorp’s overall performance. As we traveled to 

various camps, we performed tests to determine whether personnel listed on rosters for a location 

were actually there and whether equipment listed on the property book could be accounted for. 

At some camps, we verified 100% of the personnel and high dollar value or sensitive equipment 

items, such as vehicles, weapons, generators, and containerized housing units. At other camps, 

due to time constraints and/or the camp size, we verified a judgmental sample of personnel and 

equipment. We discussed the results of our tests with DynCorp representatives and the ICORs. 

To evaluate payroll accuracy, we compared a sample of timecards for individuals who requested 

time off to the authorized time off documents. We found discrepancies between the number of 

 

23 This command was subsumed into U.S. Forces-Iraq on January 1, 2010. 
29 

days individuals were paid and the number of days they were entitled to be paid. We discussed 

these discrepancies with DynCorp representatives and the ICORs. 

To evaluate INL’s quality assurance program, we reviewed INL’s quality assurance plan in the 

statement of work for Task Order 4761. We discussed the implementation of the plan with the 

ICORs and reviewed several ICOR trip reports to determine the extent of their quality assurance 

efforts. We discussed DynCorp’s quality control program with DynCorp representatives and 

reviewed DynCorp quality assurance reports. 

To evaluate INL’s oversight of leases, we obtained copies of active leases from DynCorp 

representatives. We discussed the leases with DynCorp representatives and the ICORs. In 

addition, we discussed some of the leases with the landlords’ representatives. Moreover, we 

discussed one lease with a contracting officer in the U.S. Embassy’s General Services Office 

who specializes in leases in the international zone. 

To determine the current status of INL’s implementation of prior recommendations, SIGIR used 

information obtained from the DoS Office of Inspector General and INL and performed some 

tests in Iraq. 

We are aware of the Government Accountability Office’s (GAO) recent findings regarding 

DCAA’s audit quality including the compromise of auditors’ independence, insufficient audit 

testing, and inadequate planning and supersision. We are reporting on the factual information 

contained in DCAA reports that relate to our audit work; however, due to the nature of GAO’s 

findings we are not relying on solely DCAA’s findings or lack thereof.24

SIGIR’s audit was conducted in accordance with generally accepted government auditing 

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

appropriate evidence to provide a reasonable basis for our findings and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. 

Use of Computer-processed Data 

We obtained time and attendance, roster, and inventory data from DynCorp. We performed 

limited tests to determine if the data were correct. When we found discrepencies, we informed 

DynCorp officials and the ICORs. 

Internal Controls 

We reviewed the specific controls that INL used to manage the Iraq task orders under its contract 

with DynCorp. These included controls of DynCorp’s invoices, government property, lease 

agreements, and DynCorp’s overall performance under the task orders. The report focuses on 

weaknesses in those controls and provides recommendations for improving them. 

 

24 Defense Management: Widespread DCAA Audit Problems Leave Billions of Taxpayer Dollars Vulnerable to 

Fraud, Waste, Abuse, and Mismanagement, GAO-10-163T, 10/15/2009. DCAA which include DCAA Audits: 

Widespread Problems with Audit Quality Require Significant Reform, GAO-09-468, 9/23/2009. 
30 

Prior Coverage 

We reviewed the following applicable reports issued by SIGIR, the Department of State and 

Broadcasting Board of Governors’ Office of Inspector General, and the Defense Contract Audit 

Agency. 

Special Inspector General for Iraq Reconstruction 

Progress on Recommended Improvements to Contract Administration for the Iraqi Police 

Training Program, SIGIR 08-014, 4/22/2008. 

Interim Review of DynCorp International, LLC, Spending Under Its Contract for the Iraqi Police 

Training Program, SIGIR 07-016, 10/23/2007. 

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/IQO07-20, 1/30/2007. 

U.S. Department of State and the Broadcasting Board of Governors, Office of Inspector 

General 

Report of Inspection, Bureau of International Narcotics and Law Enforcement Affairs, 

ISP-I-05-14, 7/2005. 

Defense Contract Audit Agency 

Report on Audit of DynCorp International LLC (DI) Control Environment and Overall 

Accounting System Internal Control Activities, Audit Report No. 3181-2007D11070001, 

10/15/2009. 

Report on Audit of Billing System, Audit Report No. 03181-2009D11010001, 4/23/2009. 

Report of Labor Accounting System and Internal Controls, Audit Report No. 

03181-2007D13010001, 3/18/2009. 

Report on Audit of Contractor Information Technology (IT) General Internal Controls, Audit 

Report No. 3311-2006Q11510001, 4/17/2007. 
31 

Appendix B—Acronyms 

Acronym Definition 

AIJS Afghanistan, Iraq, Jordan Support Division 

AQM Office of Acquisition Management 

COR Contracting Officer Representative 

CPI Civilian Police International 

DCAA Defense Contract Audit Agency 

DoD Department of Defense 

DoS Department of State 

FAR Federal Acquisition Regulation 

GAO Government Accountability Office 

ICOR In-country Contracting Officer Representative 

INL Bureau of International Narcotics and Law Enforcement Affairs 

MNSTC-I Multi-National Security Transition Command-Iraq 

SIGIR Special Inspector General for Iraq Reconstruction 

 
32 

Appendix C—Audit Team Members 

This report was prepared and the review was conducted under the direction of David R. Warren, 

Assistant Inspector General for Audit, Office of the Special Inspector General for Iraq 

Reconstruction. 

The staff members who conducted the audit and contributed to the report include: 

Michael A. Bianco 

Patricia H. Morel 

Robert L. Pelletier 

Nadia Shamari 

Michael Welsh 

 
33 

Appendix D—Department of State - INL Comments 
34 
35 
36 

 
37 

Appendix E—SIGIR Mission and Contact Information 

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 Hillel Weinberg 

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: 703-428-1059 

Email: hillel.weinberg@sigir.mil 

Public Affairs Daniel Kopp 

Director 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