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SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

October 26, 2005 

MEMORANDUM FOR UNITED STATES AMBASSADOR TO IRAQ 

DIRECTOR, IRAQ RECONSTRUCTION MANAGEMENT OFFICE 

COMMANDING GENERAL, JOINT CONTRACTING COMMAND 

 -IRAQ/AFGHANISTAN 

COMMANDER, JOINT AREA SUPPORT GROUP-CENTRAL 

SUBJECT: Management of the Contracts, Grant, and Micro-Purchases Used To Rehabilitate 

the Karbala Library (Report No. SIGIR 05-020) 

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

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

mandates the independent and objective conduct of audits relating to the programs and 

operations funded with amounts appropriated or otherwise made available to the Iraq Relief and 

Reconstruction Fund. Public Law 108-106, as amended, requires that we provide for the 

independent and objective leadership and coordination of, and recommendations on, policies 

designed to promote economy, efficiency, and effectiveness in the administration of such 

programs and operations and to prevent and detect waste, fraud, and abuse. 

We considered management comments from the Iraq Reconstruction Management Office, the 

Joint Contracting Command-Iraq/Afghanistan, and the Joint Area Support Group-Central on a 

draft of this report when preparing the final report. Comments on the draft of this report by those 

organizations conformed to requirements and left no unresolved issues. Therefore, no additional 

comments are required. 

Because we added a recommendation to the final report, we request that the 

United States Ambassador to Iraq provide comments to the final report by November 14, 2005. 

Comments should describe actions taken or planned in response to recommendations and provide 

completion dates for the actions. 

We appreciate the courtesies extended to the staff. For additional information on this report, 

please contact Mr. Joseph T. McDermott at (703) 428-1100, or at joseph.mcdermott@sigir.mil or 

Mr. Clifton Spruill at (703) 343-8817, or at clifton.spruill@iraq.centcom.com. For the report 

distribution, see Appendix K. 

Stuart W. Bowen, Jr. 

Inspector General 

400 Army Navy Drive • Arlington, Virginia 22202 
Special Inspector General for Iraq Reconstruction 

Report No. SIGIR 05-020 October 26, 2005 

(Project No. D2004-DCPAAF-0034.3)

Management of the Contracts, Grant, and Micro-Purchases 

Used To Rehabilitate the Karbala Library 

Executive Summary 

Introduction. This audit report is one of a series of reports addressing controls over 

cash, contract management, and grant management for the Coalition Provisional 

Authority South-Central Region. This audit report discusses the deficiencies in the 

Coalition Provisional Authority South-Central Region’s process for managing 

5 contracts, 1 grant, and 33 micro-purchase contracts awarded for more than $2.1 million 

for the rehabilitation of the Karbala Library (the Library). 

Objective. The overall audit objective was to determine whether disbursing officers in 

selected locations in southern Iraq complied with applicable guidance and properly 

controlled and accounted for Development Fund for Iraq cash assets and expenditures. 

We expanded the scope of our audit to determine whether the South-Central Region 

properly managed contracts and grants at specific projects because of deficiencies 

identified in Office of the Special Inspector General for Iraq Reconstruction, Report No. 

05-006, “Control of Cash Provided to South-Central Iraq,” April 30, 2005, and at the 

request of the Deputy Secretary of Defense. We chose to review the Library because of

the multiple contracts, grant, and micro-purchase contracts that had been awarded for the 

rehabilitation of the Library. 

Specifically, for the Library, we reviewed the contract and grant award process to 

determine whether fund agents adequately controlled cash assets, fully accounted for cash 

assets and expenditures, and properly returned cash assets and whether expenditures 

complied with guidance specifying dollar thresholds and allowable uses. 

Results. South-Central Region personnel, in the management of contracts, a grant, and 

micro-purchase contracts using Rapid Regional Response Program funds to rehabilitate 

the Library: 

• circumvented guidance by splitting requirements into more than one contract to 

avoid seeking the required funding-level approval or to avoid required 

documentation 

• issued contracts for dollar amounts that exceeded the requirement documents 

• did not monitor the contracts, the grant, or micro-purchase contracts; did not make 

any site visits; did not issue performance reports; did not prepare post-award 

assessments; and did not act on the reports that the contractor was not performing 

to the standards set in the contracts 

• needlessly disbursed funds for contracts, a grant, and micro-purchase contracts for 

which work was not performed and the contracted amount was exceeded

i 
• paid-in-full, on the day the contracts, a grant, and micro-purchase contracts were 

signed, but did not require that progress payments be tied to project performance 

• did not maintain files that contained accurate or required documentation 

South-Central Region personnel needlessly disbursed more than $1.8 million on the 

project to rehabilitate the Library. South-Central Region personnel, under the direction 

of the Rapid Regional Response Program, did not comply with applicable guidance and 

did not properly manage Rapid Regional Response Program funds provided through 

5 contracts, 1 grant, and 33 micro-purchase contracts used to rehabilitate the Library. 

Specifically, South-Central Region disbursed approximately $1.6 million for which the 

work was not performed. Further, approximately $2.3 million was disbursed, although

the total value of the contracts, grant, and micro-purchase contracts awarded for the 

Library was approximately $2.1 million. 

Material Internal Control Weaknesses. The audit identified material internal control 

weaknesses. South-Central Region personnel, under the direction of the Coalition 

Provisional Authority, did not comply with applicable guidance and did not properly 

manage approximately $2.3 million of Rapid Regional Response Program funds. 

Consequently, there was no assurance that fraud, waste, and abuse did not occur in the 

management and administration of cash and property used to rehabilitate the Library. 

Indications of Potential Fraud. During this audit, we found indications of potential 

fraud and referred these matters to the Assistant Inspector General for Investigations, 

Office of the Special Inspector General for Iraq Reconstruction, for action. Related 

investigations are continuing. 

Recommendations. Since the Coalition Provisional Authority was dissolved on 

June 28, 2004, we are addressing the recommendations to three of the four 

successor organizations: the Iraq Reconstruction Management Office, the Joint 

Contracting Command-Iraq/Afghanistan, and the Joint Area Support GroupCentral. 

We added a recommendation to the United States Ambassador to Iraq because additional 

information concerning a rescinded grant, including a copy of a bank account showing 

that approximately $154,000 remaining on deposit for this particular grant, was made 

available subsequent to the issuance of the draft audit report.

1. We recommend that the United States Ambassador to Iraq recover specifically 

the $154,000 in rescinded grant funds remaining on deposit, any other funds 

related to the rescinded grant, and funds that exceeded the contracted amount 

and return the recovered funds to the Iraqi government. 

2. We recommend that the Director, Iraq Reconstruction Management Office, ensure that established policies and procedures for authorizing, awarding, and 

consolidating contracts and grants are effectively implemented and followed 

and that complete files to support transactions made for contracts and grants are 

maintained. 

3. We recommend that the Commanding General, Joint Contracting CommandIraq/Afghanistan: 

a. Ensure that established policies and procedures for awarding and 

consolidating contracts and grants are effectively implemented and followed. 

ii 
b. Ensure that established policies and procedures for monitoring contract and 

grant performance are effectively implemented and followed. 

c. Ensure that repairs were completed, purchased equipment and services were 

delivered, and work was performed. 

d. Maintain complete files to support transactions made for contracts and grants. 

4. We recommend that the Commander, Joint Area Support Group-Central, ensure 

that established policies and procedures for disbursing funds obtained through 

the Development Fund for Iraq for contracts and grants are effectively 

implemented and followed, that funds are disbursed for intended purposes, and 

that complete files to support transactions made for contracts and grants are 

maintained. 

Management Comments and Audit Response. The Director, Iraq Reconstruction 

Management Office; the Commanding General, Joint Contracting CommandIraq/Afghanistan; and the Commander, Joint Area Support Group-Central concurred with 

the finding and recommendations and the comments to all recommendations are fully 

responsive. 

iii 
Table of Contents 

Executive Summary i 

Introduction 

Background 1 

Objective 4 

Finding 

Management of the Contracts, Grant, and Micro-Purchase Contracts 

Used to Rehabilitate the Karbala Library 5 

Appendixes 

A. Scope and Methodology 22 

B. Coalition Provisional Authority Guidance Applicable 

 to Contracts and Grants 25 

C. Contracts and Grant Awarded for the Karbala Library 27 

D. Micro-Purchase Contracts Awarded for the Karbala Library 28 

E. Coalition Provisional Authority Organizational Responsibilities 

 for Contracts and Grants 29 

F. Present U.S. Government Organizational Responsibilities 

 for Contracts and Grants 30 

G. Micro-Purchases for Books for the Karbala Library 31 

H. Contractor Performance at the Karbala Library 32 

I. Internet Service at the Karbala Library 35 

J. Acronyms 37 

K. Report Distribution 38 

L. Audit Team Members 40 

Management Comments 

Commanding General, Joint Contracting Command-Iraq/Afghanistan 41

Commander, Joint Area Support Group-Central 43 

iv 
Introduction 

Background 

This audit report is one of a series of reports addressing controls over cash, contract 

management, and grant management for the Coalition Provisional Authority (CPA) 

South-Central Region. This audit report discusses the deficiencies in the CPA SouthCentral Region’s process for managing 5 contracts, 1 grant, and 33 micro-purchase 

contracts awarded for the rehabilitation of the Karbala Library (the Library). 

Coalition Provisional Authority Regulation Number 1. CPA Regulation Number 1 

was issued by the CPA Administrator on May 16, 2003. CPA Regulation Number 1 

described the powers and purposes of the CPA and stated: 

The CPA shall exercise powers of government temporarily in order to

provide for the effective administration of Iraq during the period of 

transitional administration, to restore conditions of security and

stability, to create conditions in which the Iraqi people can freely 

determine their own political future, including by advancing efforts to

restore and establish national and local institutions for representative 

governance and facilitating economic recovery and sustainable 

reconstruction and development.

The Development Fund for Iraq. United Nations Security Council Resolution 1483, 

adopted May 22, 2003, noted the establishment of the Development Fund for Iraq (DFI) 

and assigned responsibility for managing the fund to the CPA. The resolution noted that 

the CPA should direct disbursement of DFI funds, in consultation with the Iraqi interim 

administration. The resolution also required the CPA to use DFI funds in a transparent 

manner to meet the humanitarian needs of the Iraqi people, for the economic 

reconstruction and repair of Iraq’s infrastructure, for the continued disarmament of Iraq, 

for the costs of Iraqi civilian administration, and for other purposes benefiting the people 

of Iraq. The DFI was the primary financial vehicle to channel revenue from ongoing 

Iraqi oil sales, unencumbered Oil-for-Food deposits, and repatriated Iraqi assets into the 

relief and reconstruction of Iraq. 

During the CPA administration of Iraq, the CPA Comptroller managed the DFI, and the 

Program Review Board (PRB) was responsible for recommending expenditures of 

resources from the DFI. For a description of CPA Regulation Number 2, which applied 

to the DFI, and CPA Regulation Number 3, which applied to the PRB, see Appendix B. 

Program Review Board Guidance. The Director of the PRB provided directives that 

applied to grant management within CPA regions. Two of these directives addressed the 

management of the Rapid Regional Response Program (R3P): 

• PRB Guidance 06, “Rapid Regional Response Program Overview,” 

September 27, 2003 

• PRB Guidance 06.2, “Rapid Regional Response Program Overview 

(amended),” December 14, 2003, and January 25, 2004 

Rapid Regional Response Program. R3P funds were derived from the DFI, and the 

CPA provided those funds to the Iraqi people for necessary repairs and upgrades to the 

infrastructure. The objectives of the R3P were to create local jobs, support local 

1 
industries, and stimulate the economy. The R3P was initially conceived as a civilian 

equivalent of the Commanders’ Emergency Response Program fund.1

 Further, it was 

designed to provide maximum flexibility to regional and governorate coordinators in 

implementing projects responsive to the needs in their areas of responsibility. The 

program incorporated and expanded the authorities of two previously funded programs: 

• the Directors’ Emergency Response Program, which provided an emergency 

response capacity

• the Construction Initiative, which provided greater funding authority for 

construction activities

The discretionary authority under which regions could execute programs without prior 

Regional Program Coordinator approval was increased to $500,000 from $200,000 

through PRB Guidance 06.2, “Rapid Regional Response Program Overview,” as 

amended on December 14, 2003, and January 25, 2004.

South-Central Region. The CPA established the South-Central Regional office in the 

spring 2003, comprising the provinces of Anbar, Babil, Karbala, Najaf, Qadisiyah, and 

Wasit, approximately half of the land mass of Iraq. South-Central Region personnel 

worked with the Iraqi people and coalition forces to establish the conditions for a free, 

sovereign, and democratically-elected representative government in Iraq. The top 

priorities of the South-Central Region were electricity, human rights, security, strategic 

communications, tribal democracy, and women’s rights. 

Karbala Library. The South-Central Region identified the Library, located in Karbala, 

Iraq, as the focal point for academic and professional learning in the area. The Library 

provided the area’s richest source of Arabic translations of the most important Western 

works of history, literature, philosophy, politics, and science. During Saddam’s regime, 

the people of the entire region were deprived of the most basic access to world literature. 

The South-Central Region determined that supporting the Library was consistent with the 

requirement that such projects benefit the people of Iraq. 

The South-Central Region awarded four contracts, in support of the Library, for the 

purchase of equipment and the following services: 

• building repairs 

• landscaping

• furniture 

• Internet service 

A fifth contract was awarded to train the Library staff. The five contracts were valued at 

$1,383,810.2

 

1

 According to Combined Joint Task Force-7, Fragmentary Order 89, June 19, 2003, DFI funds were to be

used to help fund the Commanders’ Emergency Response Program, which provides reconstruction 

assistance to the Iraqi people. 2

 Contracts DABV01-04-M-8339, in the amount of $373,400, for building repairs; DABV01-04-M-8342, 

in the amount of $197,500, for landscaping; DABV01-04-M-8343, in the amount of $224,010, for

furniture; DABV01-04-M-8345, in the amount of $498,900, for Internet service; and DABV01-04-M-8353,

in the amount of $90,000, for library staff training. 

2 
Further, the South-Central Region awarded a grant to the Library to provide for salaries 

for the Library staff. The value of the grant amounted to $210,000. Finally, the SouthCentral Region awarded 33 micro-purchase contracts to acquire books for the Library. 

The amount expended through the micro-purchases was $535,106. 

The total value of the contracts, grant, and micro-purchase contracts awarded for the 

Library was $2,128,916. For details on the contracts and the grant, see Appendix C. For 

details on the micro-purchase contracts, see Appendix D. 

Organizations Responsible for Contract and Grant Management. The CPA was the 

authority responsible for the temporary governance of Iraq through June 28, 2004. 

Thereafter, the Iraqi Interim Government assumed the authority to govern Iraq. The 

responsibility for the DFI transferred from the CPA to the Iraqi Interim Government on 

June 28, 2004. For information on the CPA’s organizational responsibilities for grants 

management, until it ceased to exist on June 28, 2004, see Appendix E. 

After the dissolution of the CPA, four U.S. government organizations assumed 

responsibilities for the management of contracts, grants, and micro-purchase contracts in 

Iraq. For information on the present organizational responsibilities for the management

of contracts and grants in Iraq, see Appendix F.

Project and Contracting Office. The Project and Contracting Office now has the 

responsibility to assess requirements for contracts and grants. National Security 

Presidential Directive 36, “United States Government Operations in Iraq,” May 11, 2004, 

established the Project and Contracting Office and directed that it provide acquisition and 

project management support for activities in Iraq, including contract and grant related 

activities. The Project and Contracting Office reports through the Deputy Assistant 

Secretary of the Army (Policy and Procurement) to the Assistant Secretary of the Army

for Acquisition, Logistics, and Technology. 

Iraq Reconstruction Management Office. The Iraq Reconstruction Management 

Office now has the responsibility to approve contracts and grants. National Security 

Presidential Directive 36, “United States Government Operations in Iraq,” May 11, 2004, 

established the Iraq Reconstruction Management Office within the Department of State 

and directed that organization to facilitate the transition in Iraq. The Iraq Reconstruction

Management Office reports to the Chief of Mission in Iraq. 

Joint Contracting Command-Iraq/Afghanistan. The Head of Contracting 

Activity, Joint Contracting Command-Iraq/Afghanistan now has the responsibility to 

administer contracts and grants.3

 The Joint Contracting Command-Iraq/Afghanistan was 

established in 2004 to consolidate contracting activities and reports through the Deputy 

Assistant Secretary of the Army (Policy and Procurement) to the Assistant Secretary of

the Army for Acquisition, Logistics, and Technology. 

Joint Area Support Group-Central Comptroller. The Joint Area Support 

Group-Central now has the financial responsibility4 for contracts and grants. The CPA 

Comptroller, as part of the CPA, ceased to exist on June 28, 2004. When the CPA was 

dissolved, the CPA Comptroller was realigned as the Joint Area Support Group-Central 

 

3

 The Joint Contracting Command-Iraq/Afghanistan used the Federal Acquisition Regulation and 

Department of Defense 3210.6-R, “DoD Grant and Agreement Regulations,” April 13, 1998, as guidance. 4

 The Joint Area Support Group-Central Comptroller provided funds to the CPA regions to disburse for

contracts and grants. Afterward, the disbursement documentation was returned to the Joint Area Support

Group-Central Comptroller’s office for review and to be cleared.

3 
Comptroller. The Joint Area Support Group-Central Comptroller continued to perform 

the same duties for that portion of the DFI still administered by the U.S. Government. 

The Joint Area Support Group-Central reports to the Commander, Multi-National 

Force-Iraq. 

Objective 

The overall audit objective was to determine whether disbursing officers in selected 

locations in southern Iraq complied with applicable guidance and properly controlled and 

accounted for DFI cash assets and expenditures. 

We expanded the scope of our audit to determine whether contracts and grants were 

properly managed by the South-Central Region at specific projects because of 

deficiencies identified in Office of the Special Inspector General for Iraq Reconstruction, 

Report No. 05-006, “Control of Cash Provided to South-Central Iraq,” April 30, 2005, 

and at the request of the Deputy Secretary of Defense. We chose to review the Library 

project for a review of the management of contracts and grants because of the multiple 

contracts, grant, and micro-purchase contracts that had been awarded for the 

rehabilitation of the Library. 

Specifically, for the Library, we reviewed the contract and grant award process to 

determine whether: 

• fund agents adequately controlled cash assets, fully accounted for cash assets and 

expenditures, and properly returned cash assets 

• expenditures complied with guidance specifying dollar thresholds and allowable 

uses 

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

Appendix A. For definitions of the acronyms used in this report, see Appendix J. For a 

list of the audit team members, see Appendix L. 

4 
Management of the Contracts, Grant, and MicroPurchase Contracts Used To Rehabilitate the 

Karbala Library 

South-Central Region personnel, in the management of contracts, a grant, and micropurchase contracts using R3P funds to rehabilitate the Library: 

• circumvented guidance by splitting requirements into more than one contract to 

avoid seeking the required funding-level approval or to avoid required 

documentation 

• issued contracts for dollar amounts that exceeded the requirement documents 

• did not monitor the contracts, the grant, or micro-purchase contracts; did not make 

any site visits; did not issue performance reports; did not prepare post-award 

assessments; and did not act on the reports that the contractor was not performing 

to the standards set in the contracts 

• needlessly disbursed funds for contracts, a grant, and micro-purchase contracts for 

which work was not performed and the contracted amount was exceeded

• paid-in-full on the day the contracts, a grant, and micro-purchase contracts were 

signed, but did not require that progress payments be tied to project performance 

• did not maintain files that contained accurate or required documentation 

This occurred because South-Central Region personnel did not: 

• follow established policies and procedures for awarding and consolidating 

contracts and grants 

• use effective procedures to monitor performance and disburse funds for contracts 

and grants 

• maintain complete files to support transactions made for contracts and grants 

• ensure that repairs were completed, purchased equipment and services were 

delivered, work was performed, and that funds were disbursed for intended 

purposes 

As a result, more than $1.8 million was needlessly disbursed on the project to rehabilitate 

the Library. South-Central Region personnel, under the direction of the CPA, did not 

comply with applicable guidance and did not properly manage R3P funds provided 

through 5 contracts, 1 grant, and 33 micro-purchase contracts used to rehabilitate the 

Library. Specifically, South-Central Region disbursed approximately $1.6 million for 

which the work was not performed. Further, approximately $2.3 million was disbursed, 

although the total value of the contracts, grant, and micro-purchase contracts awarded for 

the Library was approximately $2.1 million. 

Guidance for Contracts and Grants 

In Iraq, contracts were used to purchase products or services, and grants were used to 

support or stimulate the efforts of the grant recipients to carry out a program or project. 

The contracts and grants were to directly benefit the Iraqi people or assist in the recovery 

of Iraq. The South-Central Region disbursed funds for contracts and grants by using DFI 

5 
cash issued by the CPA Comptroller (now the Joint Area Support Group-Central 

Comptroller). 

Coalition Provisional Authority Memorandum 4. CPA Memorandum Number 4, 

“Contract and Grant Procedures Applicable to Vested and Seized Iraqi Property and the 

Developmental Fund for Iraq, Implementation of Regulation Number 3, Program Review 

Board,” August 19, 2003, (CPA Memorandum Number 4) established “procedures 

applicable to the execution of contracts and grants for the benefit of the Iraqi people 

using Iraqi Funds. . . .” The memorandum directed that “the CPA will manage and spend 

Iraqi Funds, which belong to the Iraqi people, for their benefit. . . . in a transparent 

manner that fully comports with the CPA's obligations under international law, including 

Resolution 1483.” The memorandum also stated:

Consistent with their programmatic responsibility to ensure that 

contractors and grantees properly perform their duties, Contracting 

Officers shall be responsible for regularly monitoring the post-award

execution of all Contracts they approve. This monitoring process 

includes ensuring that the contractor provides the agreed upon goods, 

services or construction in accordance with the provisions, and that 

payments are made in a timely manner. Contracting Officers shall 

include in the Contract file a written report describing post-award 

performance by contractors or grantees, including a final assessment 

upon completion of the Contract. Contracting officers shall rely upon 

locally available military engineering resources in assessing all repair 

and construction projects. All documents related to the establishment 

and execution of Contracts will be maintained in a Contract file that 

includes the materials described in Appendix A to this Memorandum.

Further, the memorandum stated “the Head of Contracting Activity, CPA, shall provide 

administrative oversight as well as technical supervision” of contracting officers. Finally, 

the memorandum stated that “Large Purchase preliminary award decisions by 

Contracting Officers appointed by the Head of the Contracting Activity, CPA, will be 

coordinated with the Head of Contracting Activity, CPA, or his designee, prior to award.” 

The memorandum defined a large purchase as “A contract with a value of greater than 

US$500,000.” 

The appendices to this memorandum provided supplemental instructions on preparing 

and executing contracts and grants pursuant to the memorandum. Specifically, 

Appendices A, B, and C of the memorandum identified the contract file requirements, 

standard terms, and conditions for solicitations and contracts in excess of $5,000 and 

contract and grant procedures applicable to vested and seized Iraqi property and the DFI. 

Department of Defense 3210.6-R. Department of Defense 3210.6-R, “DoD 

[Department of Defense] Grant and Agreement Regulations,” April 13, 1998, provided 

guidance for the management of grants. For a definition of contracts and grants, see 

Appendix B. 

Multiple Contracts 

South-Central Region personnel did not follow established policies and procedures for 

consolidating contracts using R3P funds. Specifically, the South-Central Region 

personnel circumvented guidance by splitting requirements into more than one contract to 

avoid having to seek the appropriate funding-level approval or to avoid required 

6 
documentation and issued contracts for dollar amounts that exceeded the requirement 

documents. 

Coalition Provisional Authority Memorandum 4–Combining and Dividing Awards. 

CPA Memorandum 4, Section 6, “Principles Applicable to Instruments,” addressed 

combining and dividing awards, stating that to the “extent practicable, requirements for a 

project or related projects may be consolidated into one contract, in order to reduce the 

administrative burden of contracting. Requirements may not be split to avoid the 

application of these rules.” 

Program Review Board Guidance 06.2 (amended)–Discretionary Authority. 

PRB Guidance 06.2 (amended), stating that the “discretionary authority under which 

Regional Coordinators can execute projects without RPC [Regional Program

Coordinator] approval is increased to $500,000, and projects up to $100,000 can be 

executed at the Governorate Coordinators’ discretion.” 

Coalition Provisional Authority CPA Memorandum 4–Micro-Purchases. CPA 

Memorandum 4, Section 3, “Definitions,” defines a micro-purchase as “A contract with a 

value of US$5,000 or less” and a small purchase as “A contract with a value greater than 

US$5,000 and less than or equal to US$500,000.” Small purchases required documented 

solicitations, competition, communication with vendors, and invoices. Micro-purchases, 

however, simply required the provision of material contract terms and the receipts or

invoices that demonstrated the outcome. Micro-purchases were considered 

advantageous, because they were subject to less stringent contract file requirements than 

small purchases. 

Regional Program Coordinator Approval Authority. Projects over $500,000 required 

Regional Program Coordinator approval via form PRB-01, “Funding Request Form.” 

The Regional Program Coordinator was to review and approve the funding request for 

completeness of the information concerning budget and justification, appropriate 

clearances, identification of funding sources, and other pertinent factors. The following 

examples show how the guidance was circumvented by splitting requirements into more 

than one contract to avoid having to seek the appropriate funding-level approvals. 

Combining and Dividing Awards. South-Central Region personnel awarded four 

contracts between March 30 and April 2, 2004, to provide building repairs, landscaping, 

furniture, and Internet service for the Library. The four contracts, valued at almost 

$1.3 million, were awarded to the same contractor. 

The records show indications that South-Central Region personnel may have 

intentionally split the requirements because all four Funding Request Forms were 

approved on the same day, March 29, 2004, by the South-Central Region Chief of 

Operations5

. 

According to the Funding Request Forms, the purpose of the four projects was to 

“renovate the existing library in Karbala.” The single purpose underlying the 

rehabilitation of the Library required the South-Central Region to complete the project as 

a whole. However, South-Central Region personnel split the work into 4 separate 

requirements, awarded 4 separate contracts, and the single contractor was paid for all 

4 contracts. 

 

5

 This individual in this position was not authorized to approve projects. 

7 
As a result of splitting the project into separate contracts, there were duplicate 

administrative costs and questionable contracting choices. For example, on 

March 30, 2004, the South-Central Region contracted for the replacement of a 20-foot 

sliding gate, but on March 31, 2004, the South-Central Region contracted for the painting 

of the same sliding gate. The cost of the gate was $3,500 while the cost of painting that 

same gate was $4,500. The South-Central Region should have avoided these inconsistent 

charges and the accompanying duplicative administrative costs by awarding the work in a 

single project. 

Approval Authority for Contracts. South-Central Region officials avoided having to 

seek South-Central Region Regional Program Coordinator approval by splitting the 

Library project into four contracts. While none of the contracts individually exceeded the 

$500,000 discretionary approval authority of the Regional Program Coordinator, 

collectively the four contracts did exceed the approval level. The Regional Program

Coordinator discretionary approval authority was not required in those cases because

each contract was less than $500,000. In addition, South-Central Region personnel also 

circumvented coordinating the contracts with the Head of Contracting Activity, CPA, by 

avoiding the $500,000 threshold. 

Further, two of the four Funding Request Forms approved by the South-Central Region 

Chief of Operations were awarded for more than they were approved. For example, one 

Funding Request Form was approved for $131,189, but two days later, the contract was 

awarded for $197,500. Another Funding Request Form was approved for $412,000, but 

three days later, the contract was awarded for $498,900. The South-Central Region Chief 

of Operations did not have the discretionary authority to approve any funding requests. 

Micro-Purchases for Books. South-Central Region purchased books from Jordan and 

Lebanon through the use of micro-purchase contracts. Receipts available at SouthCentral Region indicate that $535,106 was spent to purchase more than 30,000 books for 

the Library. Further, in some cases, South-Central Region personnel circumvented 

guidance by splitting requirements into more than one micro-purchase contract to avoid 

the small purchase contracting requirements. Yet in other cases they awarded micropurchase contracts that exceed the micro-purchase dollar limitations but did not maintain 

the required documentation for the higher dollar amount. For the details of the micropurchases of books for the Library, see Appendix G. 

Monitoring Performance 

South-Central Region personnel did not use effective procedures to monitor performance 

for contracts and the grant using R3P funds. Specifically, South-Central Region 

personnel did not monitor any contracts, the grant, or micro-purchase contracts, did not 

make any site visits, did not issue performance reports, did not prepare post-award 

assessments, and did not act on the reports that the contractor was not performing to the 

standards set in the contracts. 

Coalition Provisional Authority Memorandum 4–Monitoring Performance. CPA 

Memorandum 4, Section 8, “Monitoring Contract Performance,” addressed the 

contracting officers monitoring responsibilities. CPA Memorandum 4 states that 

Consistent with their programmatic responsibilities to ensure that 

contractors and grantees properly perform their duties, Contracting 

Officers shall be responsible for regularly monitoring the post-award

8 
execution of all Contracts they approve. This monitoring process 

includes ensuring that the contractor provides the agree[d] upon goods,

services or construction in accordance with the provisions, and that 

payments are made in a timely manner.

Monitoring Methods. CPA Memorandum 4 and R3P guidance identified performance 

monitoring as a significant duty to ensure that the recipients were properly performing. 

Monitoring required South-Central Region personnel to employ some or all of the 

following methods: 

• discussions with the contracting entity or grant recipient about project timelines

and implementation of the project 

• regular site visits 

• production of reports and/or other evidence of project activity by the 

implementing partner 

• confirmation of delivery of the goods or products and verification that the targeted 

beneficiary or recipient had received the product 

• discussions with the Iraqi beneficiary of the project to evaluate whether the 

project achieved the desired outcome 

• documentation or other evidence (pictures) of a satisfactory work product 

including a completed Certificate of Completion

Monitoring of Project Activity. The South-Central Region contracting officer was 

responsible for monitoring the Library projects, including making regular site visits, 

according to CPA Memorandum 4 and R3P guidance. The contract and grant files lack

any evidence that South-Central Region personnel visited the Library site. 

Performance Reports. The contract and grant files were required to contain 

performance verification, and the grant required at least a monthly report from the grant 

recipient documenting the expenditures incurred and any achievements. However, the 

contract and grant files did not contain any documents to verify performance. 

South-Central Region personnel did not issue any final reports for the Library contracts 

or the grant. None of the contract or grant files contained details regarding the outcome

of the contracts and the grant or the number of Iraqis directly benefiting from the use of 

DFI funds. The reports were necessary to document that the contractor provided the 

agreed upon goods, services, or construction. 

In addition, South-Central Region contracting officers did not perform a post-award 

assessment of the contractor and the grantee to detail the impact the contracts or the grant 

had upon the community or to detail the performance of the contractor or grantee. The 

post-award report was necessary to document the benefits for the Iraqi people and to 

determine whether the contractor or grant recipient could be considered for additional 

contracts or grants. 

Iraqi Forward Engineering Support Team. The South-Central Region relied 

exclusively upon the Iraqi Forward Engineering Support Team (IFEST) to monitor 

contractor performance. The IFEST was comprised of Iraqi professional engineers who 

worked for the U.S. Army Corps of Engineers. The IFEST personnel visited the Library 

four times between May 25 and September 20, 2004, to evaluate the contractor’s 

performance on the four contracts awarded for building repairs, landscaping, furniture, 

9 
and Internet service. They recorded their findings and conclusions in an inspection report 

for each contract, which was provided to the South-Central Region. 

The IFEST inspection reports for its visit on September 20, 2004, stated that the 

contractor did not perform to the standards of the contracts for building repairs, 

landscaping, and furniture, and that the contractor did not “bring any equipment for 

internet” for the Internet service contract. The IFEST inspection reports listed numerous 

items that the contractor did not provide in accordance with the contract terms. For the 

details of goods and services not provided by the contractor for building repairs, 

landscaping, and furniture, see Appendix H. For the details of goods and services not 

provided by the contractor for the Internet service, see Appendix I. 

According to CPA Memorandum 4, the South-Central Region contracting officer was 

responsible for monitoring the projects, including making regular site visits. However, 

the South-Central Region relied solely upon the IFEST to perform monitoring of the 

four contracts but apparently did not use or respond to the IFEST inspection reports 

concerning the Library. According to IFEST personnel, South-Central Region personnel 

were made aware of the contractor’s deficiencies. Regular site visits by South-Central 

Region personnel would have confirmed the fact that the contractor had not performed to 

the standards of the contracts. 

Coordinating the Monitoring Process. The South-Central Region did not effectively 

coordinate and communicate the proposed work for the Library to the library 

management. During our site visit to the Library in May 2005, the library manager stated 

that he was never aware of the contracts or the grant awarded for Library and that the 

South-Central Region did not provide the scope of work for the contracts. Further, the 

manager was not advised that over 30,000 books were to be delivered and that a contract 

and a grant were available to pay for librarians’ training and salaries. 

Additionally, the library manager stated that when the contractor provided 14 personal 

computers, he was not aware that the library was supposed to receive 68 personal 

computers. The library manager said he only became aware of the fact the Library was to 

receive 68 personal computers and Internet service when the IFEST performed its 

inspections.

Since the library manager was not advised of the contracts or provided the scope of work 

for each contract awarded for the Library, the library manager was not aware that the 

contractor was not performing to the standards of the contracts. As a result, the library 

manager did not immediately contact the South-Central Region because he was unaware 

of the lack of performance by the contractor. 

Micro-Purchases for Books. We discussed the books with the library site manager in 

May 2005, and he stated that the Library never received any books from the SouthCentral Region. Current and former South-Central Region personnel stated that they do 

not know the location of books purchased for the Library. For the details of the micropurchases of books, see Appendix G. 

Disbursing Funds 

South-Central Region personnel did not use effective procedures to disburse funds for a 

contract and the grant using R3P funds. Specifically, funds were needlessly disbursed for 

contracts, a grant, and micro-purchase contracts for which work was not performed, work 

was not contracted, equipment and services were not delivered, and the contracted 

10 
amount was exceeded. In addition, the South-Central Region paid-in-full on the day the 

contracts, a grant, and micro-purchase contracts were signed, and therefore, did not 

require that progress payments be tied to project performance. 

Coalition Provisional Authority Memorandum 4–Payment Terms. 

CPA Memorandum 4, Section 7, “Contracts,” states that “All Small Purchase contracts 

will contain payment terms including an agree[d] upon payment schedule (preferably 

with milestones tied to performance) for service contracts. . . .” 

Coalition Provisional Authority Memorandum 4–Specific Milestones. 

CPA Memorandum 4, Section 9, “Grants,” states that “Grants should be reviewed during 

implementation and where appropriate funds should be made available on a schedule tied 

to the accomplishment of specific milestones. . . .” 

Documentation Requirements. CPA Memorandum 4 and R3P Guidance required each 

contract, grant, and micro-purchase file to maintain disbursement documentation that 

recorded the date, amount, and payee for each disbursement made. 

Advance Payments. The South-Central Region did not tie any disbursements to the 

contractor to performance milestones. Instead, the contractor was paid 100 % of the 

amount awarded for each contract on the day the contract was signed. In addition, the 

contractor for the Library staff training contract and the grant recipient for the Library

staff salaries grant were both paid 100 % of the amount awarded on the day the contract 

and the grant were signed. Once the South-Central Region had disbursed the entire 

contract amount in advance to the contractors and grant recipient, it was critical that the 

South-Central Region contracting officer provide strict monitoring of the contractors and 

grant recipient to confirm that performance was done according to the contracts and the 

grant terms. 

Library Staff Training Contract. The South-Central Region awarded 

Contract DABV01-04-M-8353 on April 5, 2004, in the amount of $90,000 (even though 

the contractor’s solicitation was in the amount of $86,100), to “provide comprehensive 

training in Jordan” for a select group of young professional librarians from Karbala. 

The day after the contract was signed, the acting South-Central Region Division Level 

Agent made a disbursement of $100,000 to a CPA human rights advisor. The CPA 

human rights advisor was responsible for paying the contractor after the contract had 

been fulfilled. The contract file contained a receipt from the contractor in the amount of 

$90,000. However, the contract file did not contain documents to show what happened to 

the remaining $10,000. The $10,000 was still unaccounted for by the human rights 

advisor responsible for disbursing the money. Former South-Central Region personnel 

stated they believed that the CPA human rights advisor did not return the money. 

We discussed the contract with the library site manager (who had been the manager for 

the past 20 years) in May 2005, and he said he was unaware of this contract and stated 

that none of his staff attended this training. The contract file did not have a list of names 

of attendees for the training. Although former South-Central Region personnel 

questioned whether any training was received since there were irregularities with the 

awarding and disbursing of the funds for the contract, no action was taken. 

Library Staff Salaries Grant. The South-Central Region awarded a grant to the Library 

board on May 24, 2004, in the amount of $210,000 (although the Funding Request Form 

for the grant lacked an approving official’s signature) to provide the salaries for 

35 librarians at $500 per employee, per month for 12 months. 

11 
The grant required the establishment of a Library board before the disbursement of any 

funding and called for the South-Central Region to perform compliance reviews 

consisting of monthly reviews of expenditures of the grants funds for salaries. 

Regardless, the acting South-Central Region Division Level Agent made two 

disbursements, each in the amount of $210,000, to two different Library board members. 

One of the Library board members deposited $210,000 into a local bank account, as 

required by the grant agreement. We discussed the grant with the library site manager in 

May 2005 and he said he was unaware of any grant for librarians’ salaries. When told 

that the Library board was provided a grant to pay for 35 librarians’ salaries, the manager 

said that he only had 8 librarians on his staff and that none of them were ever paid with 

grant funds. Former South-Central Region personnel stated the grant had been rescinded 

in November 2004 when they became aware of the fact that individuals were being 

paid—even though they were not working at the Library. After the grant was formally 

rescinded, former South-Central Region personnel took control of the bank account and 

received receipt copies for all payments made by the board. Former South-Central 

Region personnel provided receipts in May 2005, in the amount of approximately 

$56,000 (disbursed as part of the $210,000 maintained in the local bank account), for 

salaries paid to individuals who did not work at the Library. They also provided a copy 

of the bank account showing that approximately $154,000 remaining on deposit. 

Disbursements. As a result, South-Central Region personnel needlessly disbursed 

$520,000 for the contract and grant. It appears that $300,000 was disbursed for work not 

performed ($90,000 for the contract and $210,000 for the grant) and $220,000 was 

disbursed that exceeded the awarded amount of the contract and the grant ($10,000 for 

the contract and $210,000 for the grant). 

Further, South-Central Region personnel did not tie the disbursements to any specific 

performance. Instead, the South-Central Region disbursed the entire amounts for the 

contract and grant at one time apparently before any work commenced. Finally, the lack 

of a monthly review of the Library grant allowed funds to be disbursed for expenses that 

were not intended by the grant’s objective. 

Library Site Evaluation 

We visited the Library in May 2005, to evaluate contractor performance under the 

four contracts awarded to provide building repairs, landscaping, furniture, and Internet 

service for the Library and to determine whether the IFEST inspection reports adequately 

documented the quality and completeness of the contractor’s work. For the details of

goods and services not provided by the contractor, see Appendix H. 

Building Repairs. We agreed with the conclusion in the IFEST inspection report that

the contractor failed to perform according to the scope of work. The contractor did not 

provide numerous items; such as ceiling fans, glass panels, and seals around the 

windows. In addition, the contractor did not provide quality repairs to the building. For 

an illustration of the poor workmanship of some of the repairs, see Photo 1 and Photo 2. 

For the details of goods and services not provided by the contractor for building repairs, 

see Appendix H. 

12 
Photo 1. Incomplete door hinge repair

Photo 2. Improperly sized glass door panel 

Landscaping. We agreed with the conclusion in the IFEST inspection report that the 

contractor failed to perform according to the scope of work. The solicitation called for 

the construction of a paved parking area of 42 m x 75 m. Instead, the contractor provided 

a paved parking area of 30 m x 35 m and decreased the parking area require by 

12 m x 40 m. In addition, the contractor did not provide a fountain with an operable 

13 
pump, did not provide any hedge plants, and did not provide the correct number of 

landscaping lights. For an illustration of the fountain, hedge plants, and landscaping 

lights, see Photo 3. Further, the contractor did not remove the three trees in the front, left, 

and right of the steps and replant them. For an illustration of the trees, see Photo 4. For 

the details of goods and services not provided by the contractor for landscaping, see 

Appendix H. 

Photo 3. Inoperable fountain, missing hedge plants, and partial landscaping lights 

14 
Photo 4. Trees flanking and in front of entrance that were not removed and 

replanted, as required in the contract 

Furniture. We agreed with the conclusion in the IFEST inspection report that the 

contractor failed to acquire the agreed upon goods. The items the contractor provided 

were not up to the standards in the scope of work, were used, or were not in good 

condition. For example, the contractor provided plastic chairs instead of the required 

upholstered metal chairs. For an illustration of the plastic chairs, see Photo 5. In 

addition, the contractor supplied three very poor quality wood and glass frame cases 

instead of the required new glass and wood frame cases. For an illustration of the poor 

quality wood and glass frame cases, see Photo 6. Further, the 138 2-meter double face 

bookshelves were made of pressed wood, not the “solid wood” the contract specifically 

required. For an illustration of the pressed wood, see Photo 7. For the details of goods 

and services not provided by the contractor for furniture, see Appendix H.

15 
Photo 5. Plastic rather than upholstered metal chairs 

Photo 6. Used wood and glass frame cases 

16 
Photo 7. Pressed rather than solid wood bookshelves 

Internet Service. We agreed with the conclusion of the IFEST inspection report that the 

contractor failed to deliver and install the Internet service. The contractor did not provide 

54 of the required 68 personal computers and failed to provide the hardware and software 

for the installation of the Internet service. We viewed the Library’s computer room and 

found that the personal computers provided by the contractor were working as standalone computers with no server connection, as required by the contract. There was no 

evidence that any hard-wiring had been installed or that any connections had been 

installed from the computers to a server. For an illustration of the stand-alone personal

computers, see Photo 8. For the details of goods and services not provided by the 

contractor for Internet service, see Appendix I. 

17 
Photo 8. Stand-alone personal computers 

Conclusion 

More than $1.8 million was needlessly disbursed on the project to rehabilitate the 

Library. South-Central Region personnel, under the direction of the CPA, did not comply 

with applicable guidance and did not properly manage R3P funds provided through 

5 contracts, 1 grant, and 33 micro-purchase contracts used to rehabilitate the Library. 

Specifically, South-Central Region disbursed approximately $1.6 million for which the 

work was not performed. Further, approximately $2.3 million was disbursed although 

the total value of the contracts, grant, and micro-purchase contracts awarded for the 

Library was approximately $2.1 million. 

We reviewed the IFEST inspection reports, the contracts’ solicitations, and the results of 

our site visit to quantify the amount of work performed and not performed by the 

contractor. Of the more than $2.3 million disbursed, we determined that the amount of 

work performed to be more than $.5 million, the amount of work not performed to be 

more than $1.6 million, and the amount that exceeded the awarded value for one contract 

and the grant to be more than $.2 million. For details on the amounts of cash disbursed, 

see the following table. 

18 
Amount of Cash Disbursed for Contracts, a Grant, and Micro-Purchase Contracts 

and for 

Work Performed, Work Not Performed, and that 

Exceeded the Contracted Amount 

Contracts,

Grant, and 

MicroPurchase 

Actions 

a. 

Value of

Contract 

b. 

Amount

Disbursed 

for Work 

Performed

c. 

Amount

Disbursed 

for Work 

Not 

Performed

d. 

Amount

Disbursed 

that

Exceeded 

the 

Contracted

Amount

e. 

Total 

Amount

Disbursed 

Needlessly 

(Column c. 

plus 

Column d.) 

Total 

Amount

Disbursed 

(Column b.

plus 

Column e.)

Contract 

DABV01-

04-M-8339

$373,400 $310,606 $62,794 $0 $62,794 $373,400

Contract 

DABV01-

04-M-8343

$224,010 $94,920 $129,090 $0 $129,090 $224,010

Contract 

DABV01-

04-M-8342

$197,500 $85,770 $111,730 $0 $111,730 $197,500

Contract 

DABV01-

04-M-8345

$498,900 $30,090 $468,810 $0 $468,810 $498,900

Contract 

DABV01-

04-M-8353

 $90,000 $0 $90,000 $10,000 $100,000 $100,000

Grant $210,000 $0 $210,000 $210,000 $420,000 $420,000

33 MicroPurchases $535,106 $0 $535,106 $0 $535,106 $535,106

 

Total $2,128,916 $521,386 $1,607,530 $220,000 $1,827,530 $2,348,916

South-Central Region personnel circumvented guidance by splitting requirements into 

more than one contract to avoid having to seek the appropriate funding-level approval or 

to avoid required documentation and issued contracts for dollar amounts that exceeded 

the requirement documents. 

Further, they did not monitor the contracts, the grant, or micro-purchase contracts; did not 

make any site visits; did not issue performance reports; did not prepare post-award 

assessments; and did not act on the reports that the contractor was not performing to the 

standards set in the contracts. 

Finally, South-Central Region paid-in-full on the day the contracts, a grant, and micropurchase contracts were signed but did not require that progress payments be tied to 

project performance. 

19 
Material Internal Control Weaknesses. The audit identified material internal control 

weaknesses. South-Central Region personnel, under the direction of the CPA, did not 

comply with applicable guidance and did not properly manage approximately 

$2.3 million of R3P funds. Consequently, there was no assurance that fraud, waste, and 

abuse did not occur in the management and administration of cash and property used to 

rehabilitate the Library. 

Indications of Potential Fraud. During this audit, we found indications of potential 

fraud and referred these matters to the Assistant Inspector General for Investigations, 

Office of the Special Inspector General for Iraq Reconstruction, for action. Related 

investigations are continuing. 

Recommendations, Management Comments, and Audit 

Response 

Redirected and Added Recommendations. Since the Coalition Provisional 

Authority was dissolved on June 28, 2004, we are addressing the recommendations 

to three of the four successor organizations: the Iraq Reconstruction Management 

Office, the Joint Contracting Command-Iraq/Afghanistan, and the Joint Area 

Support Group-Central. 

We added a recommendation to the United States Ambassador to Iraq because additional 

information concerning the rescinded grant, including a copy of a bank account showing 

that approximately $154,000 remaining on deposit for this particular grant, was made 

available subsequent to the issuance of the draft audit report.

1. We recommend that the United States Ambassador to Iraq recover specifically 

the $154,000 in rescinded grant funds remaining on deposit, any other funds 

related to the rescinded grant, and funds that exceeded the contracted amount 

and return the recovered funds to the Iraqi government. 

2. We recommend that the Director, Iraq Reconstruction Management Office, ensure that established policies and procedures for authorizing, awarding, and 

consolidating contracts and grants are effectively implemented and followed 

and that complete files to support transactions made for contracts and grants are 

maintained. 

Management Comments. The Director, Iraq Reconstruction Management Office 

did not provide written comments to the report but verbally concurred with the 

finding and recommendations through a telephone conversation with the Inspector 

General. 

3. We recommend that the Commanding General, Joint Contracting CommandIraq/Afghanistan: 

a. Ensure that established policies and procedures for awarding and 

consolidating contracts and grants are effectively implemented and followed. 

b. Ensure that established policies and procedures for monitoring contract and 

grant performance are effectively implemented and followed. 

c. Ensure that repairs were completed, purchased equipment and services were 

delivered, and work was performed. 

20 
d. Maintain complete files to support transactions made for contracts and grants. 

Management Comments. The Commanding General, Joint Contracting 

Command-Iraq/Afghanistan concurred with the finding and recommendations. 

4. We recommend that the Commander, Joint Area Support Group-Central, ensure 

that established policies and procedures for disbursing funds obtained through 

the Development Fund for Iraq for contracts and grants are effectively 

implemented and followed, that funds are disbursed for intended purposes, and 

that complete files to support transactions made for contracts and grants are 

maintained. 

Management Comments. The Commander, Joint Area Support Group-Central 

concurred with the finding and recommendations. 

Audit Response. The Director, Iraq Reconstruction Management Office; the 

Commanding General, Joint Contracting Command-Iraq/Afghanistan; and the 

Commander, Joint Area Support Group-Central comments’ to all recommendations are 

fully responsive. 

21 
Appendix A. Scope and Methodology 

In September 2004, we initiated an audit of cash controls over disbursing officers in 

southern Iraq as a result of concerns brought to our attention by staff of the Coalition 

Provisional Authority (CPA) Comptroller. 

We reviewed the following documents issued by the CPA: 

• CPA Regulation Number 2, “Developmental Fund for Iraq,” June 10, 2003 

• CPA Regulation Number 3, “Program Review Board,” June 18, 2003 

• CPA Memorandum Number 4, “Contract and Grant Procedures Applicable 

to Vested and Seized Iraqi Property and the Developmental Fund for Iraq, 

Implementation of Regulation Number 3, Program Review Board,” 

August 19, 2003 

• Combined Joint Task Force-7, Fragmentary Order 89, June 19, 2003 

• Combined Joint Task Force-7, Fragmentary Order 1268, December 22, 2003 

• Director, Program Review Board, Program Review Board Guidance 01, 

“Coalition Provisional Authority Allocation Process,” June 9, 2003, updated 

October 4, 2003 

• Director, Program Review Board, Program Review Board Guidance 02, 

“Program Management Model for the Regions,” July 30, 2003 

• Director, Program Review Board, Program Review Board Guidance 03, 

“Program Management Assessment,” July 9, 2003 

• Director, Program Review Board, Program Review Board Guidance 04, 

“Maintaining Project Files,” September 30, 2003 

• Director, Program Review Board, Program Review Board Guidance 05, 

“Project Monitoring and Evaluation,” September 30, 2003 

• Director, Program Review Board, Program Review Board Guidance 06, 

“Rapid Regional Response Program Overview,” September 27, 2003 

• Director, Program Review Board, Program Review Board Guidance 06.2, 

“Rapid Regional Response Program Overview (amended),” December 14, 

2003 and January 25, 2004 

We expanded the scope of our audit to determine whether contracts and grants were 

properly managed by the South-Central Region at specific projects because of 

deficiencies identified in Office of the Special Inspector General for Iraq Reconstruction, 

Report No. 05-006, “Control of Cash Provided to South-Central Iraq,” April 30, 2005, 

and at the request of the Deputy Secretary of Defense. We selected the Karbala Library 

(the Library) project for a review of the management of contracts and grants because of

the multiple contracts, grants, and micro-purchase contracts that had been awarded for the 

rehabilitation of the Library. 

The CPA South-Central Region used Rapid Regional Response Program funds to 

rehabilitate the Library, and it awarded 5 contracts in the amount of $1,383,810, 

1 grant in the amount of $210,000, and 33 micro-purchase contracts in the amount 

of $535,106 for a total of $2,128,916 for this purpose. We reviewed all the 

contracts, grants, and micro-purchases for the rehabilitation of the Library that were 

awarded from February through June 2004. 

22 
We reviewed all the contract, grant, and micro-purchase files. Specifically, we reviewed 

the contracts, grant, and micro-purchase files for the following documentation: funding 

approval, signed agreements, disbursements, and certificates of completion. We

reviewed the Program Review Board minutes to determine whether the South-Central 

Region contracts and grant in excess of $500,000 were approved by the Program Review 

Board. During the course of our audit, we observed deficiencies in the contract and grant 

award documentation and expanded our scope to include the total process of awarding 

and monitoring the contracts, grant, and micro-purchases and the disbursement of funds.

We spoke with the contracting officials available at the time of our audit regarding 

the status of the projects and examined documentation maintained in the contract, 

grant, and micro-purchase files. Those contracting officers primarily were located 

at the South-Central Region, now known as the U.S. Regional Embassy Office, 

located in Al Hillah, Iraq; but one contracting officer who had previously worked 

for the South-Central Region was working for the Joint Contracting CommandIraq/Afghanistan. 

We performed audit work at two locations to review applicable documentation and 

management procedures. At the Joint Area Support Group-Central Comptroller’s Office, 

located in the U.S. Embassy, Baghdad, Iraq; we reviewed receipts submitted by SouthCentral Region pay agents to confirm disbursements made for the contracts, grant, and 

micro-purchases. At the U.S. Regional Embassy Office, we reviewed all other aspects of 

the contracts, grant, and micro-purchases. We reviewed the inspection reports completed 

by the Iraqi Forward Engineering Support Team and interviewed the lead engineer 

regarding his findings. 

We visited the Library to determine whether the Iraqi Forward Engineering Support 

Team inspection reports accurately documented contractor deficiencies and noted any 

deficiencies not captured in the inspection reports. We then calculated the costs of work 

not performed by the contractor by identifying the costs within the independent 

government estimate or the contractor’s bid proposal to determine the amount of work 

and services provided by the contractor. We also interviewed the Library manager to 

determine whether the manager or his staff had received any operations training or had 

any salaries paid via contracts or grant awarded by the South-Central Region. In 

addition, we spoke to the Library manager regarding the receipt of any books from the 

South-Central Region. 

Finally, we spoke with officials at the Joint Contracting Command-Iraq/Afghanistan 

regarding their intentions for further action towards the contractor and the Library. 

We conducted this performance audit from September 2004 through September 2005, in 

accordance with generally accepted government auditing standards. 

Use of Computer-Processed Data. We did not use computer-processed data to perform

this audit. 

Prior Coverage. The Special Inspector General for Iraq Reconstruction (SIGIR), 

which was formerly the Office of the Inspector General, Coalition Provisional 

Authority (CPA-IG), issued eight reports related to controls over cash and the 

management of contracts. The U.S. Army Audit Agency also issued a report 

related to controls over cash. The reports are listed below and are available at the 

indicated website addresses. 

23 
Special Inspector General for Iraq Reconstruction Reports. Reports can be accessed 

on its website at http://www.sigir.mil. 

SIGIR Report No. 05-016, “Management of the Contracts and Grants Used To 

Construct and Operate the Babylon Police Academy,” October 26, 2005 

SIGIR Report No. 05-015, “Management of Rapid Regional Response Program

Grants in South-Central Iraq,” October 25, 2005 

SIGIR Report No. 05-019, “Attestation Engagement Concerning the Award of NonCompetitive Contract DACA63-03-D005 to Kellogg, Brown, and Root Services, 

Inc.,” September 30, 2005 

SIGIR Report No. 05-006, “Control of Cash Provided to South-Central Iraq,” 

April 30, 2005 

SIGIR Report No. 05-008, “Administration of Contracts Funded by the 

Development Fund of Iraq,” April 30, 2005 

CPA-IG Report No. 04-009, “Coalition Provisional Authority Comptroller Cash 

Management Controls Over the Development Fund for Iraq,” July 28, 2004 

CPA-IG Report No. 04-013, “Coalition Provisional Authority’s Contracting 

Processes Leading Up to and Including Contract Award,” July 27, 2004 

CPA-IG Report No. 04-007, “Oil for Food Cash Controls for the Office of Project 

Coordination in Erbil, Iraq,” July 26, 2004 

U.S. Army Audit Agency. Reports can be accessed on its website at 

https://www.aaa.army.mil/reports.htm. 

U.S. Army Audit Agency Audit Report: A-2005-0095-FFG, “Vested and Seized 

Assets, Operation Iraqi Freedom,” February 16, 2005 

24 
Appendix B. Coalition Provisional Authority 

Guidance Applicable to Contracts and Grants 

Coalition Provisional Authority (CPA) guidance for the Development Fund of Iraq 

(DFI) and for the Program Review Board’s (PRB) operations that are relevant to 

contracts and grants is: 

Coalition Provisional Authority Regulation Number 2. CPA Regulation 

Number 2, “Development Fund for Iraq,” June 10, 2003, described the 

responsibilities for the administration, use, accounting, and auditing of the DFI. 

This regulation was intended to ensure that the DFI was managed in a transparent 

manner for and on behalf of the Iraqi people, consistent with United Nations 

Security Council Resolution 1483, and that all DFI disbursements would be for 

purposes benefiting the people of Iraq. 

Coalition Provisional Authority Regulation Number 3. CPA Regulation 

Number 3 “Program Review Board,” June 18, 2003, established the procedures 

applicable to the PRB operations. The PRB was responsible for recommending 

expenditures of resources from the DFI in a manner that meets the interests of the 

people of Iraq, furthers CPA policy objectives, and comports fully with CPA 

stewardship and financial management duties under the applicable laws and 

regulations, including United Nations Security Council Resolution 1483. The PRB 

was not responsible for overseeing the manner in which approved spending 

requirements were executed. 

Coalition Provisional Authority Memorandum 4. CPA Memorandum 

Number 4, “Contract and Grant Procedures Applicable to Vested and Seized Iraqi 

Property and the Developmental Fund for Iraq, Implementation of Regulation 

Number 3, Program Review Board,” August 19, 2003, defined contracts and grants. 

A contract was defined as “A written agreement whereby the CPA or Coalition 

Forces acquire goods, services or construction from a person or entity under 

prescribed terms and conditions, for the purpose of assisting the Iraqi people or 

assisting in the recovery of Iraq.” 

A grant was defined as “A written instrument that transfers Iraqi Funds from the 

CPA or Coalition Forces to a recipient grantee, in order to carry out a program or 

project that directly benefits the Iraqi people or assisting in the recovery of Iraq.” 

Department of Defense 3210.6-R. According to Department of Defense 3210.6-R, 

“DoD [Department of Defense] Grant and Agreement Regulations,” April 13, 1998, a 

grant is: 

A legal instrument which, consistent with 31 U.S.C. 6304, is 

used to enter into a relationship:

(a) The principal purpose of which is to transfer a thing of

value to the recipient to carry out a public purpose of support or

stimulation authorized by a law of the United States, rather than to 

acquired property or services for the Department of Defense’s direct

benefit or use.

25 
(b) In which substantial involvement is not expected between 

the Department of Defense and the recipient when carrying out the 

activity contemplated by the grant. 

26 
Appendix C. Contracts and Grant Awarded 

for the Karbala Library 

For the Karbala Library (the Library), the South Central Region awarded five contracts 

for building repairs, landscaping, furniture, Internet service, and training for the Library 

staff; and one grant to provide salaries for the Library staff. The value of the five 

contracts and one grant amounted to $1,593,810. For details of the five contracts 

awarded for the Library, see Table 1. For details of the grant awarded for the Library, see 

Table 2. 

Table 1. Contracts Awarded for the Karbala Library 

Contract Number 

Date the Contract was 

Signed Contract

Amount Scope of Work

DABV01-04-M-8339 March 30, 2004 $373,400 Building Repairs. 

DABV01-04-M-8342 April 1, 2004 $197,500 Landscaping.

DABV01-04-M-8343 April 1, 2004 $224,010 Furniture.

DABV01-04-M-8345 April 3, 2004 $498,900 Computers and Internet 

Service. 

DABV01-04-M-8353 April 5, 2004 $90,000 Training for the Library 

Staff. 

Total Contracts Amount $1,383,810

Table 2. The Grant Awarded for the Karbala Library 

Grant Number

Date the Grant was

Signed Grant 

Amount Scope of Work

DABV01-04-M-8020 June 2, 2004 $210,000 Salaries for the Library Staff

Total Grant Amount $210,000

27 
Appendix D. Micro-Purchase Contracts 

Awarded for the Karbala Library 

For the Karbala Library, the South Central Region used 33 micro-purchase contracts to 

acquire and ship books. The value of the 33 micro-purchases amounted to $535,106. For 

details of the micro-purchase contracts awarded for the Library, see the following table. 

Micro-Purchase Contracts Awarded for the Karbala Library 

Purchase Amount Purchase Description 

$150,000 Books

$50,000 Library Books

$50,000 Karbala Library Books

$50,000 Library Books

$16,000 Karbala Library Books

$14,995 Arabic Books/Children’s Books 

$14,940 Books and Encyclopedias 

$14,592 Classics and Encyclopedias in Arabic 

$12,584 Arabic Encyclopedias

$12,480 Arabic Encyclopedias

$12,340 English Books

$12,048 Scientific Books

$11,970 Arabic/Islamic Books

$9,970 Arabic/International Books

$9,930 Books

$9,620 Books and Encyclopedias 

$9,592 International Law Books

$8,600 Books and Encyclopedias 

$7,030 Books

$5,300 Books

$4,917 Books

$4,900 Books

$4,860 Books

$4,590 Books

$4,480 Books

$4,455 Books

$4,330 Books

$4,000 Arabic Books

$3,940 Books

$3,560 Books

$3,065 Books

$3,063 Books

$2,955 Books

28 
Appendix E. Coalition Provisional Authority 

Organizational Responsibilities for Contracts 

and Grants 

The diagram shown below identifies organizational entities within the Coalition 

Provisional Authority (this is not a complete organizational diagram of the Coalition

Provisional Authority) that had oversight and administrative responsibilities for contracts 

and grants until it ceased to exist on June 28, 2004. 

Administrator

Comptroller

Rapid Regional

Response Program

Coordinator

Head Contracting

Activity

Program

Management

Office

Field 

Disbursing Agents

Field

Contracting Agents

29 
Appendix F. Present U.S. Government 

Organizational Responsibilities for Contracts 

and Grants 

The diagram shown below identifies the present U.S. government organizational 

entities that had oversight and administrative responsibilities for contracts and 

grants. 

Director, 

Iraq Reconstruction 

Management Office 

Approval 

Project and Joint Contracting Joint Area Support 

Contracting Office CommandIraq/Afghanistan Group-Central 

Requirements Disburse 

Award/Monitor 

30 
Appendix G. Micro-Purchases for Books for 

the Karbala Library 

The South-Central Region awarded 33 micro-purchase contracts, in the amount of 

$535,106, to provide books to the Library. However, South-Central Region personnel 

did not follow established policies and procedures for micro-purchases using R3P funds. 

Specifically, in some cases the South-Central Region personnel circumvented guidance 

by splitting requirements into more than one micro-purchase contract to avoid the small 

purchase contracting requirements yet in other cases awarded micro-purchase contracts 

that exceed the micro-purchase dollar limitations but did not maintain the required 

documentation for the higher dollar amount. 

Coalition Provisional Authority CPA Memorandum 4–Micro-Purchases. CPA 

Memorandum 4, Section 3, “Definitions,” defines a micro-purchase as “A contract with a 

value of US$5,000 or less” and a small purchase as “A contract with a value greater than 

US$5,000 and less than or equal to US$500,000.” 

Coalition Provisional Authority CPA Memorandum 4–Combining and Dividing 

Awards. CPA Memorandum 4, Section 6, “Principles Applicable to Instruments,” 

addressed combining and dividing awards, and states that to the “extent practicable, 

requirements for a project or related projects may be consolidated into one contract, in 

order to reduce the administrative burden of contracting. Requirements may not be split 

to avoid the application of these rules.” 

A South-Central Region project officer made a series of nine book purchases from the 

same contractor for the following amounts: $4,917, $4,900, $4,860, $4,590, $4,480, 

$4,455, $4,330, $3,940, and $3,560. It appears that the purchases were split into two or 

more disbursements of $5,000 or less to avoid the more stringent contracting 

requirements for a small purchase contract. In addition, these actions circumvented the 

requirements of CPA Memorandum 4. 

Coalition Provisional Authority CPA Memorandum 4–Contract File Requirements. 

CPA Memorandum 4, Appendix A, “Contract File Requirements,” listed the contract file 

requirements for micro-purchases and small purchases. Micro-purchase files were 

required to include (after the award) material contract terms and information that 

demonstrated the outcome such as receipts, delivery notices, or contracting officer notes 

on contractor performance for services. Small purchases files were required to include 

(after the award) a written contract with required terms (when exceeding $10,000) or a 

summary of material terms (when less than $10,000), invoices, and verification of 

performance. Micro-purchases were considered advantageous because those contracts 

were subject to less stringent file requirements than small purchases. 

The South-Central Region made 20 book purchases that were in excess of $5,000 each 

(totaling $481,991). It appears that purchases exceeded the micro-purchase dollar 

limitations but did not maintain the required documentation for the higher dollar amount. 

In addition, the files on these 20 separate micro-purchase contracts did not have required 

documentation such as solicitation, competition, and correspondence with multiple 

vendors’ records. The only documentation was a vendor receipt for books purchased. 

31 
Appendix H. Contractor Performance at the 

Karbala Library 

The South-Central Region awarded four contracts, in support of the Library for the 

purchase of equipment and the following services: 

• building repairs 

• landscaping

• furniture 

• Internet service 

Iraqi Forward Engineering Support Team. The South-Central Region relied on the 

Iraqi Forward Engineering Support Team (IFEST) to monitor contractor performance. 

The IFEST was comprised of professional Iraqi engineers who worked for the U.S. Army

Corps of Engineers. The IFEST visited Iraqi reconstruction projects sites, such as police 

stations, schools, and water plants, because it was easier for them to move about a site 

and communicate with Iraqi workers.

IFEST daily reports included such details as quality assessments, the number of people 

working at a site, the type of construction taking place, and any safety or security issues 

that needed to be addressed. 

IFEST personnel visited the Library four times between May 25 and September 20, 2004, 

to evaluate the contractor’s performance on the four Library contracts. They recorded 

their findings and conclusions in an inspection report, which was provided to the SouthCentral Region. 

Building Repairs. The justification for Contract DABV01-04-M-8339 was that the 

library buildings were in a “general state of disrepair from lack of upkeep and 

maintenance.” This contract was awarded on March 30, 2004, in the amount of 

$373,400, to repair or replace the following: 

• plumbing fixtures 

• electrical equipment 

• wiring conduits 

• window frames and glass 

• interior and exterior doors 

• ceiling tiles and fixtures 

The IFEST visited the Library on September 20, 2004, and its inspection report stated 

that the contractor did not perform to the standards of the contract. The IFEST inspection 

report stated that the contractor did not provide the following: 

• seal around the windows 

• Jordanian wooden frames (double) for wooden doors 

• 411 square meters of carpet 

• 10 ceiling fans 

• glass panels 

32 
• slate board 

• D-section end trim

• shelf with support 24”x6” 

• shelf with support 24”x10” 

• looped slat hook and chrome

Landscaping. The justification for Contract DABV01-04-M-8342 was that the “library 

grounds look like a garbage dump.” This contract was awarded on March 31, 2004, in 

the amount of $197,500, to perform the following: 

• remove trash, cars, and debris from site 

• pave parking area and sidewalk 

• fence repairs 

• remove and plant trees 

• plant hedges 

• two fountains 

• park benches 

• landscaping lights 

The IFEST visited the Library on September 20, 2004, and its inspection report stated 

that the contractor did not perform to the standards of the contract. The IFEST inspection 

report cites these deficiencies: 

• The solicitation called for the construction of a paved parking area of 

42 m x 75 m. Instead, the contractor provided a paved parking area of 

30 m x 35 m. The contractor decreased the parking area by 12 m x 40 m;

however, the contractor did not refund a percentage of the funds received. 

• The contractor did not provide any hedge plants. 

• One fountain was not functional because the pump was inoperable. 

• The contractor only provided 22 of the 42 landscaping lights. 

• The contractor provided 30 park benches; however, the park benches were 

broken. 

Furniture. The justification for Contract DABV01-04-M-8343 was that the “library has 

very little furniture or fixtures.” The contract also stated that “most of the furniture was

looted near the end of the war and what was left is in a state of disrepair.” The contract 

scope of work specified that the materials not be “previously used, recycled, or repaired,” 

and shall be the “best quality of material available.” In addition, the bookshelves, desks, 

and tables shall be “made of solid wood and one piece construction. Pressed wood and 

plywood construction are unacceptable.” The contractor was to provide upholstered 

metal frame chairs and glass and wooden frame cases. This contract was awarded on 

March 31, 2004, in the amount of $224,010, to furnish and install the following: 

• bookshelves 

• tables 

• computer desks 

33 
• charging desk with laminate top 

• card catalog

• slate board 

• rolling ladders 

• chairs and desks 

The IFEST visited the Library on September 20, 2004, and its inspection report stated 

that the contractor did not perform to the standards of the contract. The IFEST inspection 

report stated the following discrepancies: 

• 138 2M-high, double-face bookshelves, instead of 180 

• Zero 4M-high, single-face bookshelves, instead of 30 

• Zero rolling ladders instead of 4 

• 63 reading tables instead of 110 

• 575 PLASTIC chairs instead of 182 upholstered chairs on metal frames 

• Zero charging desks instead of 9 

• Zero glass and wooden frame library cases instead of 24 

• Zero computer tables instead of 8 

• 21 previously used swivel chairs instead of 68 

• No card catalogs with 60 trays instead of 4 

• 14 desks for the computer lab instead of 60 

• No desk for the teacher instead of 1 

Internet Service. For the details of goods and services not provided by the contractor for 

Internet service, see Appendix I.

34 
Appendix I. Internet Service at the Karbala 

Library 

The justification for Contract DABV01-04-M-8345 was that the “library has no existing 

internet or computer systems.” The South-Central Region wanted to provide the Library 

with Internet service that would be modeled after libraries in the United States. The 

contract was awarded on April 2, 2004, in the amount of $498,900, to provide the Library 

with the following: 

• 68 personal computers 

• 68 workstations 

• 2 servers - one primary and a backup 

• all necessary hardware and software 

• installation 

The Iraqi Forward Engineering Support Team (IFEST) visited the Library on 

September 20, 2004, and its inspection report stated that the contractor did not perform to 

the standards of the contract and had not produced the agreed upon goods and services. 

The IFEST inspection report stated that the contractor did not “bring any equipment for 

internet.” 

The South-Central Region did not act until almost two months after the IFEST inspection 

report documented that the contractor failed to perform on the Internet service contract. 

On November 19, 2004, the South-Central Region issued a Cure Notice to the contractor 

for failing to perform the Internet service contract. The Cure Notice provided the 

contractor 25 days to cure the conditions noted in the notice. The contractor did not 

respond to the notice. 

The Joint Contracting Command-Iraq/Afghanistan (JCC-I/A) issued a Show-Cause 

Notice to the contractor on February 27, 2005. This notice required the contractor to 

respond within 10 days. The contractor responded that he “did not fail to perform under 

this contract.” The contractor continued that he “did install internet equipment in Karbala 

Library.” The contractor conceded that the “internet subscription was not enabled, but 

through no fault” of the contractor. The contractor stated that the service provider 

“required a Beneficiary of the contract,” and since the contractor was not the “beneficiary 

they could not sign the contract. As the library caretaker did not prove ownership, such a 

contract couldn’t be signed.” 

The contractor provided a signed affidavit by the contractor’s project manager for the 

Internet service. The project manager stated he “personally supervised the installation of

all materials and equipment. Everything, including the electronic systems, were properly 

placed and approved by me and the CPA.” The project manager continued that the 

“internet service was not provided since I did not receive further instructions from

anyone at CPA or the caretaker of the library.” During the course of our site visit to the 

Library, we carefully looked at the computer rooms to determine if any “electronic 

systems” had been installed. We did not identify any Internet systems that appeared to be 

newly installed. The contract also called for satellite hardware, which was not observed 

during our site visit. 

35 
JCC-I/A personnel stated that there would be no further action with regard to Internet 

service. A JCC-I/A legal opinion was that it appeared “we still don’t have good 

supporting documentation or evidence to show” that the contractor “did not fully perform

the contract (other than in regard to the Internet connection, which” the contractor 

“admits it failed to do but essentially claims ‘impossibility’ due to local requirements).” 

JCC-I/A personnel did not believe enough evidence existed to show that the contractor 

had failed to perform the contract, even though the contractor admitted, in writing, that 

the Internet service was not provided. 

For example, the contract required the contractor to provide Internet service provider fees 

for 12 months, for which the contractor charged $4,500 per month. Because there was no 

Internet service, the contractor was paid $54,000 for services not performed. In another 

example, the JCC-I/A did not require the contractor to provide the Internet service and

the contractor was paid at least $145,000 for the installation, software, software tests, and 

satellite hardware for services not performed. In a further example, the contractor was

paid for 68 personal computers when he only provided 14. As a result, the contractor was 

paid $58,320 for computers not provided. 

The contractor’s response stated that the Internet service was not provided because he did 

not receive instructions from the CPA or the caretaker of the Library. The JCC-I/A did 

not respond to the contactor and did not require that the contractor install the Internet 

service. 

JCC-I/A personnel stated that they did not plan to pursue completion of the contract or 

seek funds reimbursement. The JCC-I/A also stated that “if we can’t obtain or create 

some documentation or other evidence to support our position, we may have to move on 

without” the contractor to “complete the library project.” This would require the JCC-I/A 

to use appropriated funds and solicit another contract for the remaining 54 personal 

computers and Internet installation. 

As a result of this inaction, the contractor was paid the contracted amount of $498,900, 

but only performed work valued at $30,090. The value of the services not performed and 

equipment not delivered was $468,810. 

36 
Appendix J. Acronyms 

CPA Coalition Provisional Authority 

CPA-IG Coalition Provisional Authority Office of the Inspector General 

DFI Development Fund for Iraq 

DLA Division Level Agent 

IFEST Iraqi Forward Engineering Support Team 

JCC-I/A Joint Contracting Command-Iraq/Afghanistan 

PRB Program Review Board 

R3P Rapid Regional Response Program

RPC Regional Program Coordinator 

SIGIR Special Inspector General for Iraq Reconstruction 

37 
Appendix K. Report Distribution 

Department of State 

Secretary of State 

Senior Advisor to the Secretary and Coordinator for Iraq 

U.S. Ambassador to Iraq 

Director, Iraq Reconstruction Management Office

Inspector General, Department of State 

Department of Defense 

Secretary of Defense 

Deputy Secretary of Defense 

Director, Defense Reconstruction Support Office 

Under Secretary of Defense (Comptroller)/Chief Financial Officer 

Deputy Chief Financial Officer 

Deputy Comptroller (Program/Budget) 

Inspector General, Department of Defense 

Department of the Army 

Assistant Secretary of the Army for Acquisition, Logistics, and Technology 

Principal Deputy to the Assistant Secretary of the Army for Acquisition, 

Logistics, and Technology 

Deputy Assistant Secretary of the Army (Policy and Procurement) 

Director, Project and Contracting Office 

Commanding General, Joint Contracting Command-Iraq/Afghanistan 

Assistant Secretary of the Army for Financial Management and Comptroller 

Chief of Engineers and Commander, U.S. Army Corps of Engineers 

Commander, Gulf Region Division 

Auditor General of the Army

U.S. Central Command

Commanding General, Multi-National Force-Iraq 

Commanding General, Multi-National Security Transition Command-Iraq 

Commander, Joint Area Support Group-Central 

Other Defense Organizations

Director, Defense Contract Audit Agency 

38 
Other Federal Government Organizations 

Director, Office of Management and Budget 

Comptroller General of the United States 

Inspector General, Department of the Treasury 

Inspector General, Department of Commerce 

Inspector General, Department of Health and Human Services 

Inspector General, U.S. Agency for International Development 

Mission Director-Iraq, U.S. Agency for International Development 

Congressional Committees and Subcommittees, Chairman and 

Ranking Minority Member 

U.S. Senate 

Senate Committee on Appropriations 

Subcommittee on Defense 

Subcommittee on State, Foreign Operations and Related Programs

Senate Committee on Armed Services 

Senate Committee on Foreign Relations 

Subcommittee on International Operations and Terrorism

Subcommittee on Near Eastern and South Asian Affairs 

Senate Committee on Homeland Security and Governmental Affairs 

Subcommittee on Federal Financial Management, Government Information and 

International Security 

Subcommittee on Oversight of Government Management, the Federal 

Workforce, and the District of Columbia 

U.S. House of Representatives 

House Committee on Appropriations 

Subcommittee on Defense 

Subcommittee on Foreign Operations, Export Financing and Related Programs

Subcommittee on Science, State, Justice and Commerce and Related Agencies 

House Committee on Armed Services 

House Committee on Government Reform

Subcommittee on Management, Finance and Accountability 

Subcommittee on National Security, Emerging Threats and International 

Relations

House Committee on International Relations 

Subcommittee on Middle East and Central Asia 

39 
Appendix L. Audit Team Members 

The Office of the Assistant Inspector General for Auditing, Office of the Special 

Inspector General for Iraq Reconstruction, prepared this audit report. The Office of 

the Special Inspector General for Iraq Reconstruction staff members who 

contributed to the report include: 

Angelina Johnston 

Robert Murrell 

Kevin O’Connor 

William Shimp 

William Whitehead 

40 
Management Comments 

Commanding General, Joint Contracting CommandIraq/Afghanistan 

41 
42 
Management Comments 

Commander, Joint Area Support Group Central 

43