Accessible Version

OPERATIONAL

CONTRACT 

SUPPORT

Additional Actions 

Needed to Manage, 

Account for, and Vet 

Defense Contractors 

in Africa

Report to Congressional Committees

December 2015

GAO-16-105

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-105, a report to 

congressional committees 

December 2015

OPERATIONAL CONTRACT SUPPORT

Additional Actions Needed to Manage, Account for, 

and Vet Defense Contractors in Africa

Why GAO Did This Study

Since its establishment in 2008, 

AFRICOM has increased its footprint in 

Africa to support its mission—building 

African partner capabilities and 

deterring threats to regional security. In 

tandem with AFRICOM’s growing 

footprint will be a continued reliance on 

contractors to support the command’s 

operations. Accordingly, AFRICOM 

and subordinate commands must be 

able to plan for and integrate OCS 

during operations. House Report 113-

446 included a provision for GAO to 

review OCS in Africa. 

This report examines the extent to 

which AFRICOM (1) has an 

organizational structure in place to 

manage, plan for, and assess OCS; (2) 

accounts for contractor personnel; and 

(3) vets non-U.S. contractors and 

contractor employees. To conduct this 

work, GAO evaluated AFRICOM’s 

OCS organizational structures and 

conducted site visits to Djibouti, Niger, 

and Uganda to collect information on 

accountability and vetting processes. 

GAO selected these locations based 

on the types of contractor employees 

represented, among other factors.

What GAO Recommends

GAO made recommendations to DOD 

regarding types of contractor personnel 

to account for, foreign vendor vetting 

process development, and guidance 

for contractor accountability and 

employee screening, among others. 

DOD generally concurred, but did not 

concur that AFRICOM should develop 

contractor accountability guidance 

because it was in the process of doing 

so. GAO continues to believe the 

recommendations are valid, as 

discussed in this report.

What GAO Found

U.S. Africa Command (AFRICOM) has established a formal operational contract 

support (OCS) organizational structure at its headquarters to serve as the central 

coordination point to manage, plan for, and assess OCS. However, except for 

U.S. Army Africa, AFRICOM’s subordinate commands do not have OCS 

organizational structures with dedicated personnel to manage OCS. Officials 

from AFRICOM’s subordinate commands stated that applying OCS concepts 

would be helpful to avoid duplication of work and increased costs. One structure 

that the Department of Defense (DOD) has introduced is an OCS Integration 

Cell, an entity with dedicated personnel to provide staff integration and promote 

coordination on OCS issues; such a cell could help identify and address gaps at 

AFRICOM’s commands, especially in a joint environment like Combined Joint 

Task Force-Horn of Africa, where contracting officials stated that some military 

tenants have arrived without informing responsible officials about the number of 

contractors accompanying them. AFRICOM has also developed a scorecard to 

assess OCS management capabilities at the subordinate commands against 

certain standards, but these assessments have not always been accurate 

because the standards have not been clearly defined or consistently applied. 

Without clearly defined assessment standards, AFRICOM cannot accurately 

assess the OCS actions taken by subordinate commands.

AFRICOM does not have a complete picture of the number of contractor 

personnel supporting its operations in the region. AFRICOM uses two primary 

sources—daily personnel status reports and the Synchronized Predeployment 

and Operational Tracker, a DOD contractor personnel accountability database—

to collect contractor personnel accountability information, but neither source 

provides comprehensive accountability or visibility of DOD contractor personnel 

on the continent because the total number of local national contractor personnel 

are not being included in either, and the numbers of U.S. citizen and third country 

national contractor personnel vary between the two. Without clear guidance on 

how to comprehensively account for contractor personnel, it will be difficult for 

AFRICOM to ensure that it has full visibility over who is supporting its operations. 

AFRICOM conducts some limited vetting of potential non-U.S. contractors, also 

referred to as vendors, but it has not established a foreign vendor vetting process 

or cell that would preemptively identify vendors who support terrorist or other 

prohibited organizations. AFRICOM has not yet established a foreign vendor 

vetting cell because while DOD guidance discusses the benefit of a cell, it does 

not require it or specify under what conditions it would be appropriate. 

Additionally, DOD sites in Africa use background investigations to determine the 

trustworthiness of contractor employees with access to DOD facilities. However, 

not all AFRICOM sites are incorporating additional screening measures, such as 

biometric screening or counterintelligence interviews, based on the specific risks 

at each site. As a result, AFRICOM is at risk of not exercising the appropriate 

level of vendor vetting or contractor employee screening on the African continent 

View GAO-16-105. For more information, to protect DOD personnel from insider threats.

contact Cary Russell at (202) 512-5431 or 

russellc@gao.gov.
Letter 1

Background 4

AFRICOM Has Established an Organizational Structure to 

Manage, Plan for, and Assess OCS, but Some Subordinate 

Commands Have Not Done So 10

AFRICOM Cannot Comprehensively Account for DOD Contractor 

Personnel in Africa 19

AFRICOM Conducts Limited Vetting of Contractors and 

Contractor Employees and Does Not Have Guidance to Apply 

Additional Risk-Based Measures 28

Conclusions 37

Recommendations for Executive Action 38

Agency Comments and Our Evaluation 39

Appendix I: Objectives, Scope, and Methodology 44

Page i GAO-16-105 Operational Contract Support

Appendix II: Comments from the Department of Defense 48

Appendix III: GAO Contact and Staff Acknowledgments 52

GAO Contact 52

Staff Acknowledgments 52

Appendix IV: Accessible Data 53

Data Tables 53

Agency Comment Letter 53

Related GAO Products 58

Table

Table 1: U.S. Africa Command (AFRICOM) Contractor Employee 

Screening Measures Vary by Site 33

Data Table for Figure 1: Value Associated with DOD Contracts in 

U.S. Africa Command Area of Responsibility, Fiscal Years 

2009-2014 53

Contents
Figures

Page ii GAO-16-105 Operational Contract Support

Figure 1: Value Associated with DOD Contracts in U.S. Africa 

Command Area of Responsibility, Fiscal Years 2009-

2014 6

Figure 2: Operational Contract Support Functions and Associated 

Tasks 7

Figure 3: Operational Contract Support Integration Cell’s Staff 

Integration Function within a Command 8

Figure 4: Operational Contract Support Integration Cell Functions 

at Different Levels of U.S. Africa Command 13

Figure 5: U.S. Africa Command Contractor Personnel 

Accountability Processes 22

Figure 6: U.S. Africa Command’s Proposed Foreign Vendor 

Vetting Process 31

Figure 7: Camp Lemonnier, Djibouti, Contractor Employee 

Screening Process 35

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page iii GAO-16-105 Operational Contract Support

Abbreviations 

 

AFRICOM U.S. Africa Command

DOD Department of Defense 

OCS Operational Contract Support

SPOT Synchronized Predeployment and Operational 

Tracker
Page 1 GAO-16-105 Operational Contract Support

441 G St. N.W.

Washington, DC 20548

December 17, 2015

The Honorable John McCain

Chairman

The Honorable Jack Reed

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Mac Thornberry

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

As major military operations wind down in Afghanistan, the Department of 

Defense (DOD) continues to engage with partner nations in other regions 

of the world, including Africa, and increasingly relies on contractors to 

provide support for a range of activities such as security force assistance 

and training. Since 2002 DOD has spent billions of dollars on contract 

support for operations in Iraq and Afghanistan, and has taken steps to 

address challenges regarding the planning, management, and oversight 

of contractors in that region.1 However, the conditions under which DOD 

operates in Africa, such as having limited resources and extensive distances 

between DOD locations across the continent, complicated by efforts to counter 

violent extremist organizations in a noncombat zone, create additional 

challenges in contract support planning and management.

Accordingly, DOD’s U.S. Africa Command (AFRICOM) and its 

subordinate commands must be familiar with how to plan for and 

integrate operational contract support (OCS) into military operations and 

activities. OCS is the process of planning for and obtaining supplies, 

services, and construction from commercial sources in support of joint

 

1Commission on Wartime Contracting in Iraq and Afghanistan, Transforming Wartime 

Contracting: Controlling Costs, Reducing Risks (August 2011).
operations.

Page 2 GAO-16-105 Operational Contract Support

2

In our body of work on OCS,3 we have reported that DOD has 

long experienced challenges in managing OCS. For example, in our 2015 

report highlighting high risk issues in the federal government, we reported 

that DOD continues to face capacity shortfalls and lacks performance 

measures to address operational contract support issues.4In February 

2013 we reported that, with the exception of the Army, the military services had 

not issued comprehensive service-specific guidance that described roles, 

responsibilities, and requirements to help integrate OCS into their planning 

efforts for contingency operations.5 Further, in June 2010 and again in 

September 2012 we testified on the need for a cultural change in DOD that 

emphasizes an awareness of OCS throughout the department to address the 

challenges faced in contingency operations.6In recent years DOD and the 

Joint Staff have issued and updated OCS guidance, discussing matters such as 

identifying and planning for OCS requirements, OCS roles and responsibilities, 

and processes for contractor personnel accountability.7

House Report 113-446, accompanying a bill for the National Defense 

Authorization Act for Fiscal Year 2015, included a provision for GAO to 

examine matters related to OCS in Africa.8 This report evaluates the extent to 

 

2

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

2014) (hereinafter cited as Joint Pub. 4-10 (July 16, 2014)). In a DOD regulation, the 

department defines operational contract support as the ability to orchestrate and 

synchronize the provision of integrated contract support and management of contractor 

personnel providing support to the joint force within a designated operational area. 32 

C.F.R. § 158.3; Department of Defense Instruction 3020.41, Operational Contract Support 

(OCS) at 49 (Dec. 20, 2011).

3

See Related Products Page at the end of this report. 

4GAO, High-Risk Series: An Update, GAO-15-290 (Washington, D.C.: Feb. 11, 2015). Every 

2 years, in accordance with congressional elections, GAO calls attention to agencies and 

program areas that are high risk due to their vulnerabilities to fraud, waste, abuse, and

mismanagement, or are most in need of transformation. 

5GAO, Warfighter Support: DOD Needs Additional Steps to Fully Integrate Operational Contract 

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

6GAO, Warfighter Support: Cultural Change Needed to Improve How DOD Plans for and 

Manages Operational Contract Support, GAO-10-829T (Washington D.C.: June 29, 2010) 

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

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

7

See generally Department of Defense Instruction 3020.41, Operational Contract Support 

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

8

See H.R. Rep. No. 113-446, at 248-49 (2014).
which AFRICOM (1) has an organizational structure in place to manage, 

plan for, and assess operational contract support; (2) accounts for 

contractors in its area of responsibility; and (3) vets non-U.S. contractors 

and contractor employees.

To address these objectives we reviewed relevant documents, including 

DOD guidance, and interviewed officials in the Joint Staff and Office of 

the Secretary of Defense, military services, AFRICOM, and its 

subordinate commands; Special Operations Command Africa; and 

Combined Joint Task Force-Horn of Africa.

Page 3 GAO-16-105 Operational Contract Support

9 We also conducted site visits to 

three locations in Africa: (1) Navy-operated Camp Lemonnier in Djibouti; (2) 

Air Force-operated Exercise Reception Facility in Niger; and (3) multiple 

facilities operated by the Marine Corps and Special Operations forces in 

Uganda. We selected these locations based on variations in the military 

services represented, the types of contractor personnel (U.S., third 

country,10 and local national), and the types of services provided. To determine 

the extent to which AFRICOM has an organizational structure in place to 

manage, plan for, and assess OCS, we conducted interviews and 

collected documentation from AFRICOM headquarters and service 

component command officials. We also evaluated all OCS readiness 

scorecards used by AFRICOM logistics officials to measure subordinate 

commands’ OCS management capabilities. To determine the extent to 

which AFRICOM accounts for contractor personnel in its area of 

responsibility, we reviewed DOD, AFRICOM, and Joint Staff personnel 

accountability guidance and interviewed AFRICOM personnel officials, as 

well as military service officials with personnel accountability 

responsibilities at the AFRICOM sites that we visited on the continent. To 

determine the extent to which AFRICOM vets contractors and contractor 

employees, we compared DOD and AFRICOM guidance to information 

gathered from officials at AFRICOM and on the continent regarding 

vendor vetting and contractor employee screening processes. We also 

observed contractor screening and base access procedures at the sites in 

Djibouti, Niger, and Uganda. The information gathered from these three 

sites, while not generalizable to all AFRICOM sites, provides valuable 

insights about personnel accountability, contractor vetting, and contractor 

 

9AFRICOM and all of the service component command headquarters are located in Europe. 

Combined Joint Task Force-Horn of Africa is located at Camp Lemonnier, Djibouti. 

10Third country national contractors are contractors who are not from the U.S. or the country where 

the services are being provided, but rather from any other country. 
employee screening processes in the AFRICOM area of responsibility. 

Appendix I describes our objectives, scope, and methodology in greater 

detail.

We conducted this performance audit from June 2014 to December 2015 

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.

AFRICOM is DOD’s newest geographic combatant command and was 

designated fully operational in September 2008. The command’s area of 

responsibility comprises all the countries on the African continent except 

Egypt. According to AFRICOM officials, Camp Lemonnier, Djibouti, is the 

only DOD site in Africa with a long-term use agreement, but AFRICOM 

has established temporary facilities across the continent to house the 

personnel and equipment used for security assistance, training, and other 

operations in the region. AFRICOM is supported by its subordinate 

commands: U.S. Army Africa, U.S. Naval Forces Africa,

Page 4 GAO-16-105 Operational Contract Support

11 U.S. Marine 

Corps Forces Africa, U.S. Air Force Africa, and Special Operations 

Command Africa. AFRICOM also has a subordinate joint force command, 

Combined Joint Task Force-Horn of Africa, which conducts operations in 

East Africa to enhance partner nation capacity, promote regional stability, 

dissuade conflict, and protect U.S. and coalition interests.12 U.S. Army 

Africa has a dedicated military contracting element, the 414th Contracting 

Support Brigade, which provides OCS planning assistance to U.S. Army 

Africa and synchronizes and executes contracting solutions across the 

continent. AFRICOM’s subordinate commands are located in Europe and 

do not have assigned forces, except for the joint task force, which is 

located at Camp Lemonnier in Djibouti.

 

11In addition to U.S. Naval Forces Africa, three other Navy component commands engage 

in contracting in the AFRICOM area of responsibility: the Navy Supply Systems Command 

Fleet Logistics Center Sigonella; the Navy Expeditionary Combat Command, and the 

Navy Facilities Engineering Command.

12A subordinate joint force command is a joint force command—either a subordinate unified 

command or joint task force command—that is subordinate to a combatant command and exercises 

command authority or operational control over a joint force.

Background
Since its establishment AFRICOM has increased its footprint on the 

continent to support the command’s missions of building African partner 

defense capabilities, responding to crises, and deterring transnational 

threats in order to promote regional security. In tandem with AFRICOM’s 

growing footprint there has been a continued reliance on contractors to 

provide, among other things, logistical, transportation, and intelligence 

support to the command’s missions. This reliance on contractors was 

highlighted in September 2014 when AFRICOM supported the U.S. 

Agency for International Development and Liberia under Operation United 

Assistance in responding to the largest Ebola epidemic in history. 

AFRICOM reported having approximately 5,600 personnel

Page 5 GAO-16-105 Operational Contract Support

13 on the African 

continent in October 2014, of whom 569—approximately 10 percent—were 

U.S. citizen contractor personnel. Moreover, the dollar value associated 

with DOD contracts in AFRICOM’s area of responsibility more than 

doubled, from $147 million in fiscal year 2009 to $463 million in fiscal year 

2014.14 While the dollar value associated with these contracts decreased 

in most regions from fiscal year 2013 to fiscal year 2014 (see figure 1), 

AFRICOM officials expect the need for contract support to increase as 

regional instability and responsibilities for protecting U.S. personnel and 

facilities continue.

 

13These reported personnel were military, civilian, and U.S. contractor employees. 

14The dollar values represent the obligations associated with contracts awarded by the Department 

of Defense in the Africa Command area of responsibility, according to a DOD report using data 

from the Federal Procurement Data System and supplemented with data from the Army 

Contracting Business Intelligence System in some cases.
Figure 1: Value Associated with DOD Contracts in U.S. Africa Command Area of Responsibility, Fiscal Years 2009-2014

Page 6 GAO-16-105 Operational Contract Support

Notes: The dollar values in the figure above represent the obligations associated with contracts 

awarded by the Department of Defense (DOD) in the Africa Command (AFRICOM) area of 

responsibility, according to a DOD report using data from Federal Procurement Data System and 

supplemented with data from the Army Contracting Business Intelligence System in some cases.

aContract values from fiscal years 2012 to 2014 reflect approximately $600 million in military 

construction projects at Camp Lemonnier, Djibouti, that according to DOD officials are scheduled to 

be completed in fiscal years 2016-2017.

b

The data provided by DOD reflect a negative contract action obligation value in the Southern Africa 

region in fiscal year 2010. According to AFRICOM, this was due to a canceled contract that resulted 

in the funds being returned to DOD.
OCS is the process of planning for and obtaining supplies, services, and 

construction from commercial sources in support of joint operations. OCS 

encompasses three functions: contract support integration, contracting 

support, and contractor management.

Page 7 GAO-16-105 Operational Contract Support

15 These functions and their 

associated tasks are described in figure 2.

Figure 2: Operational Contract Support Functions and Associated Tasks

Determining OCS requirements, as well as conducting the initial planning 

for and coordination of these tasks, is primarily an operational, not a 

contracting, function. As a result, all of the directorates within a command 

have OCS roles or responsibilities, but the directorates may not fully 

understand how to properly define requirements for and manage OCS. In 

the 2014 update to Joint Publication 4-10 the Joint Staff introduced the 

concept of an OCS Integration Cell as a central coordination point that 

can, among other things, provide staff integration by assisting and 

advising the directorates on these issues. Figure 3, based on information 

from the Joint Staff, demonstrates the integrating role of an OCS 

Integration Cell.

 

15In the context of OCS, “contractor management” refers to the oversight and integration of 

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

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

OCS Functions
Figure 3: Operational Contract Support Integration Cell’s Staff Integration Function within a Command

Page 8 GAO-16-105 Operational Contract Support

Engi

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

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

vary.

Personnel accountability is generally the process by which the geographic 

combatant command identifies, captures, and records information—

usually through the use of a database—about the number and type of 

personnel, including contractor personnel, in its area of operations. 

DOD’s Synchronized Predeployment and Operational Tracker (SPOT) 

Contractor Personnel 

Accountability
was developed to assist the combatant commander in ensuring that 

accountability, visibility, force protection, medical support, personnel 

recovery, and other related support can be accurately forecasted and 

provided for the contractor personnel in the command’s area of 

responsibility. SPOT contains personnel accountability data only for 

contractor personnel (U.S. citizen, third country, and local national), not 

military or civilian personnel. When specified by contract, vendors are 

responsible for inputting and maintaining their employees’ personnel data 

in SPOT throughout the employees’ periods of performance. SPOT and 

service-specific accountability systems typically feed information into 

DOD’s accountability system to produce joint personnel status reports.

DOD contracting officers are required to check prospective contractors’ 

names against a list of prohibited, restricted, or otherwise ineligible 

entities in a U.S. government contracting database called the System for 

Award Management.

Page 9 GAO-16-105 Operational Contract Support

16 The prohibited entities list in the System for Award 

Management contains sanctioned and other prohibited entities identified by the 

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

agencies. A foreign vendor vetting cell can also be established to vet 

selected local national and third county national companies so as to 

prevent DOD from awarding contracts to companies having ties to violent 

extremist organizations or other inappropriate entities. The vetting 

consists of researching the principal owners and connections of the 

company using information provided by owners, and then cross-checking 

this information against various intelligence sources.

Subordinate and individual base commanders are responsible for the 

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

responsibility. A contractor employee screening process mitigates the 

potential security risk that third country and local national contractor 

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

there is no standard DOD methodology for contractor employee 

screenings overseas, a background investigation or similar process to 

 

16See Class Deviation 2014-O0020, Prohibition on Contracting with the Enemy (Sept. 17, 2014); 

48 C.F.R. (FAR) § 9.405(d). After a draft of this report was sent to DOD for comment, 

DOD issued Class Deviation 2015-O0016 in September 2015, which superseded Class 

Deviation 2014-O0020. The new guidance retained the requirement for contracting 

officers to check the prospective contractors’ names against the list. See Class Deviation 

2015-O0016, Prohibition on Providing Funds to the Enemy and Authorization of Additional 

Access to Records, attachment 3 (Sept. 15, 2015). 

Vendor Vetting and 

Contractor Employee 

Screening
confirm the trustworthiness of contractor personnel should be conducted 

to the greatest extent possible.

Page 10 GAO-16-105 Operational Contract Support

17

AFRICOM established a formal OCS structure with dedicated 

personnel—including an OCS Integration Cell—at the headquarters level 

to serve as the central coordination point to integrate OCS in all 

directorates, and to manage, plan for, and assess OCS. However, only 

one of AFRICOM’s subordinate commands has an organizational 

structure in place with dedicated personnel to manage and plan for OCS. 

Furthermore, AFRICOM has developed a scorecard to assess OCS 

capabilities at the subordinate command level, but portions of each 

assessment of the six subordinate commands have been inaccurate 

because it is unclear how the performance measures in scorecards 

should be applied.

AFRICOM headquarters’ establishment of a formal OCS organizational 

structure began in 2011 with three dedicated DOD civilian personnel to 

oversee OCS activities in Africa. Since that time, several notable OCS 

milestones have been achieved, such as the establishment of an OCS 

Integration Cell for the command’s headquarters in early 2014. According 

to Joint Publication 4-10, an OCS Integration Cell should be established 

as a permanent cell at the geographic combatant command level. The 

primary function of the cell is to conduct general OCS planning, provide 

advice, promote coordination, and maintain a common OCS operating 

picture.18 In 2015 AFRICOM headquarters expanded its OCS Integration Cell 

from three dedicated civilian personnel to five who work alongside two 

preexisting OCS planners from the Defense Logistics Agency’s Joint 

Contingency Acquisition Support Office, according to AFRICOM officials. 

AFRICOM directorates also participate in facilitating OCS. For example, 

AFRICOM’s personnel directorate is tasked with maintaining personnel 

accountability throughout the area of responsibility. AFRICOM also has 

boards and working groups dedicated to coordinating OCS activities, 

including a board that synchronizes and optimizes OCS during all phases 

 

17See Department of Defense Instruction 2000.16, DOD Antiterrorism (AT) Standards, encl. 

3, para. E3.18.2 (Oct. 2, 2006) (incorporating change Dec. 8, 2006).

18See Joint Pub. 4-10, at III-3 to III-4 (July 16, 2014).

AFRICOM Has 

Established an 

Organizational 

Structure to Manage, 

Plan for, and Assess 

OCS, but Some 

Subordinate 

Commands Have Not 

Done So

AFRICOM Has 

Established an 

Organizational Structure to 

Manage and Plan for OCS
of operation. Participants in these boards and working groups include 

members of the OCS Integration Cell, such as the Joint Contingency 

Acquisition Support Office planners assigned to the combatant command, 

as well as staff from the combatant command, service component 

commands, and other combat support agencies.

AFRICOM’s OCS Integration Cell has also taken steps to manage OCS 

at its subordinate commands by conducting staff assistance visits to 

enhance OCS capabilities. Specifically, since March 2014, AFRICOM 

OCS Integration Cell officials have conducted staff assistance visits to all 

of AFRICOM’s service component commands as well as to Special 

Operations Command Africa and Combined Joint Task Force-Horn of 

Africa. The purpose of these visits is to assist and partner with 

subordinate commands to ensure that current AFRICOM processes, 

policies, tools, and procedures for OCS align with DOD policy and joint 

doctrine, and to enhance mission execution. Additionally, staff assistance 

visits help AFRICOM officials to gain a better understanding of OCS 

procedures and challenges at the subordinate commands. Common 

observations that have been made during such visits include noting a lack 

of standardized OCS organization at the subordinate command levels, 

noting constrained subordinate command resources for managing OCS,

and noting a lack of OCS training. AFRICOM officials stated that they 

intend to work with the subordinate commands to address these issues. 

However, these officials did not provide details or a plan for how they 

were to work with the subordinate components.

AFRICOM’s OCS Integration Cell also plays a key role in planning for 

OCS by working with operational planners to incorporate OCS concepts 

into planning documents. For example, according to officials, the OCS 

Integration Cell assisted AFRICOM’s planning directorate officials in 

developing OCS annexes for several concept plans, as well as the 

theater and regional campaign plans. These OCS annexes generally 

contained key considerations discussed in Joint Staff and other DOD 

guidance related to OCS, such as force protection, host nation 

agreements, and contractor oversight.

AFRICOM OCS Integration Cell officials also developed a template for 

subordinate commands to use as they begin to develop their own OCS 

planning documents, including OCS annexes to plans and orders when 

needed. The OCS planning template is meant to guide AFRICOM 

subordinate commands in OCS planning for operations, exercises, 

security cooperation activities, and other initiatives. It contains 20 steps, 

including identifying mission length and requirements, leveraging 

Page 11 GAO-16-105 Operational Contract Support
historical contracts, developing acquisition and cross-servicing 

agreements, researching vendors, and identifying other factors that may 

impact OCS.

With the exception of U.S. Army Africa, AFRICOM’s subordinate 

commands, including service component and joint force commands, 

generally lack formal organizational structures with personnel dedicated 

to OCS. Joint Publication 4-10 notes that OCS Integration Cells can be 

established at the service component and subordinate joint force 

command levels. Specifically, Joint Publication 4-10 indicates that each 

service component command determines, based on specific operational 

requirements, whether it should establish an OCS Integration Cell. For 

details about the functions of OCS Integration Cells at the combatant 

command, component command, and joint force command levels, see 

figure 4. 

Page 12 GAO-16-105 Operational Contract Support

Most AFRICOM 

Subordinate Commands 

Have Not Established an 

OCS Organizational 

Structure
Figure 4: Operational Contract Support Integration Cell Functions at Different 

Page 13 GAO-16-105 Operational Contract Support

Levels of U.S. Africa Command

Note: Operation United Assistance refers to DOD’s counter-Ebola effort in West Africa in fall 2014. As 

part of this operation, AFRICOM set up a Joint Force Command headquartered in Monrovia, Liberia, 

to provide regional support to U.S. military activities and facilitate coordination with U.S. government 

and international relief efforts.

U.S. Army Africa has established an organizational structure with 

dedicated full-time OCS personnel employed within the logistics 

directorate.19 This OCS Cell works with planners to incorporate OCS 

 

19While U.S. Army Africa does not consider these personnel to constitute an OCS Integration 

Cell, the division provides the same OCS-coordinating function as an OCS Integration 

Cell.
concepts into planning documents. U.S. Army Africa’s OCS Cell has also 

issued OCS guidance, which outlines OCS roles and responsibilities, 

including those related to development of contract requirements; OCS 

programs and procedures; and intra-theater cooperation with other 

component commands. Additionally, U.S. Army Africa’s dedicated military 

contracting element—414th Contracting Support Brigade—provides OCS 

planning assistance to U.S. Army Africa. While U.S. Naval Forces Africa, 

U.S. Air Force Africa, and U.S. Marine Corps Forces Africa do not have 

formalized OCS organizational structures, all of the service component 

commands participate in AFRICOM’s OCS-related working groups. In 

addition, Marine Corps Forces Africa has designated one official in its 

logistics directorate to serve as the component command’s OCS chief, 

but according to Marine Corps officials, this official is also responsible for 

OCS policy and coordination in the European Command area of 

responsibility. U.S. Air Force Africa and U.S. Naval Forces Africa

Page 14 GAO-16-105 Operational Contract Support

20 have 

not established OCS organizational structures or dedicated OCS personnel.

While joint staff guidance does not require the establishment of an OCS 

Integration Cell or dedicated OCS personnel at the service component 

command level, joint staff has emphasized the benefits of using an OCS 

Integration Cell to synchronize requirements and coordinate contracting 

actions. Moreover, Navy contracting officials stated that contract 

requirements are not always clear, and if they do not have the statements 

of work from the requiring activity at an early stage, they may not know 

what is needed before the forces arrive on the ground. As a result, 

operations might be delayed or might be carried out without sufficient 

equipment or support services. An OCS Integration Cell or similar 

structure with dedicated OCS personnel at the other service component 

commands could help identify contract support issues early in the 

requirements development process, thereby enabling the commands to 

avoid delays. For example, U.S Army Africa’s dedicated OCS personnel 

and the 414th Contracting Support Brigade have corrected potential 

issues regarding poor coordination of contracts. U.S. Army Africa officials 

stated that an Army unit may fail to inform contracting officials about what 

equipment they are bringing along on deployment, or may disregard 

training on how to properly draft a performance work statement. The 

 

20In addition to the U.S. Naval Forces Africa, three other Navy component commands engage in 

contracting in the AFRICOM area of responsibility: the Navy Supply Systems Command Fleet 

Logistics Center Sigonella, the Navy Expeditionary Combat Command, and the Navy 

Facilities Engineering Command. 
414th Contracting Support Brigade will incorporate these missing details 

into the contracts based on previous experience with units requiring 

similar services or goods.

U.S. Naval Forces Africa, U.S. Marine Corps Forces Africa, and U.S. Air 

Force Africa logistics officials stated that one of their challenges is the 

limited number of personnel who are available to be dedicated to OCS. In 

our February 2015 report on high risk issues, we reported that DOD 

continues to face capacity shortfalls for addressing OCS issues.

Page 15 GAO-16-105 Operational Contract Support

21 Funding 

and staffing constraints may prevent the establishment of an OCS 

Integration Cell at the service component command level. Joint 

Publication 4-10 recognizes that the establishment of an OCS Integration 

Cell or similar structure at the service component command level will vary 

based on specific operational requirements. Joint guidance also indicates 

that there is no set structure or size for an OCS Integration Cell at any 

command level; size and configuration are mission-dependent, and a cell 

could be as small as two individuals or could be significantly larger, 

depending on the operation. Air Force Africa and Navy Africa officials also 

cited a lack of service guidance as an impediment to establishing an OCS 

organizational structure.

An OCS Integration Cell was established at AFRICOM’s subordinate joint 

force command supporting Operation United Assistance in 2014, but not 

at the Combined Joint Task Force-Horn of Africa at Camp Lemonnier, 

Djibouti, or Special Operations Command Africa.22 Joint Publication 4-10 

indicates that an OCS Integration Cell is normally established at the 

subordinate joint force command level, where it leads general OCS 

planning, provides advice, promotes coordination of OCS matters, and 

maintains an OCS common operating picture, among other tasks.23 As of 

January 2015, according to officials, Combined Joint Task Force-Horn of Africa 

had two officials in the contingency contracting office and one logistics 

official who received OCS training. Officials further stated that Combined 

Joint Task Force-Horn of Africa plans to dissolve its contingency 

contracting office entirely by the end of fiscal year 2016, as it transitions 

 

21GAO-15-290

22Joint Publication 1 indicates that a joint task force is a type of joint force command. See 

generally Joint Chiefs of Staff, Joint Pub. 1, Doctrine for the Armed Forces of the United 

States, ch. IV (Mar. 23, 2013).

23Joint Pub. 4-10, at III-7, D-4 to D-7 (July 16, 2014).
to a more enduring presence at Camp Lemonnier, Djibouti. DOD officials 

stated that there are plans to create two dedicated OCS positions within 

the Combined Joint Task Force-Horn of Africa’s logistics directorate. As 

dedicated personnel, these officials could carry out some OCS 

coordinating tasks and could frequently communicate with logistics, 

operations, and planning officials about OCS issues. However, an OCS 

Integration Cell would provide a permanent centralized coordination point 

within the joint environment at Camp Lemonnier. Furthermore, this type of 

coordination will be increasingly important in the future, as DOD develops 

a more enduring joint presence at Camp Lemonnier.

At the subordinate joint force command level, joint guidance provides that 

an OCS Integration Cell should normally exist, depending on mission 

conditions, but the guidance does not specify those conditions. As a 

result, there is no clear guidance directing Combined Joint Task ForceHorn of Africa or Special Operations Command Africa to establish an 

OCS Integration Cell. An OCS Integration Cell or similar structure would 

be particularly useful in a joint environment due to the number of military 

service contracting elements operating at one location with potentially 

limited resources. According to Combined Joint Task Force-Horn of Africa 

contracting officials, applying OCS concepts such as establishing an OCS 

Integration Cell at Camp Lemonnier would be helpful to avoid duplication 

of work and increased costs. For example, there are multiple car rental 

contracts for different service components located at Camp Lemonnier, 

Djibouti. Combined Joint Task Force-Horn of Africa contracting officials 

stated that if they had all contracted with one vendor they would have 

gotten a better price. As another example, officials at Camp Lemonnier 

stated that some military service tenants have arrived without previously 

informing the Navy as the Lead Service for Contracting at Camp 

Lemonnier about the number of contractor personnel accompanying 

them. Without prior coordination, Navy officials do not know how much 

housing, food, and fuel they require at the base. Special Operations

Command Africa officials stated that the contract requirements 

development process can be haphazard, and that logistical planners are 

often brought into the process later than necessary. An OCS 

organizational structure or dedicated OCS personnel could ensure that 

OCS requirements are considered and clarified well before operations 

have begun.

Page 16 GAO-16-105 Operational Contract Support
In May 2013 AFRICOM developed and began utilizing OCS Readiness 

Scorecards to systematically assess its subordinate commands’ progress 

in managing OCS. The scorecards document how well OCS is being 

incorporated into the subordinate commands’ planning documents, 

organizational structures such as boards and working groups, training 

exercises, and accountability processes. To that end, the scorecards 

comprise 32 OCS tasks divided among four broad categories: (1) 

compliance (planning, administration, and training); (2) boards and 

working groups; (3) exercises; and (4) common operating picture/SPOT. 

The command’s OCS Integration Cell rated each subordinate command 

as being either compliant, partially compliant, or non-compliant for each 

component task, based on OCS Integration Cell officials’ determination 

about the subordinate command’s progress toward completing that task. 

For example, according to U.S. Army Africa’s May 2014 OCS readiness 

scorecard, personnel had received training for contracting officer’s 

representatives prior to their deployment, so it was rated as compliant for 

this task. According to AFRICOM officials, the scorecards provide an 

overall picture of subordinate commands’ OCS capabilities, promote 

collaboration on OCS issues, and identify timely OCS training 

requirements and activities.

However, we found that AFRICOM’s assessments do not fully reflect the 

extent to which subordinate commands have completed or not completed 

OCS tasks. Specifically, in three of AFRICOM’s scorecard assessments it 

listed the subordinate command as complying with a task, when the 

subordinate command had not accomplished that task. For example, one 

component task is to incorporate OCS-specific tasks into exercises. 

AFRICOM assessed Air Force Africa as compliant on this task. However, 

Air Force Africa officials stated that they did not participate in any 

exercises during the assessment time period, so they did not incorporate 

OCS tasks into exercises. In another example, Special Operations 

Command Africa officials stated that they had processes for awarding 

contracts, but they lacked standard processes for incorporating OCS into 

planning and requirements determinations. However, AFRICOM listed 

Special Operations Command Africa as possessing standardized 

processes for support units and activities because the scorecard does not 

specify that these processes should specifically involve the incorporation 

of OCS into planning and requirements development.

Furthermore, AFRICOM applied different standards of compliance to 

different subordinate commands. For example, one component task 

focuses on contractor accountability through the utilization of SPOT, a 

contractor personnel accountability database. AFRICOM assessed 

Page 17 GAO-16-105 Operational Contract Support

AFRICOM Developed a 

Tool to Assess 

Subordinate Commands’ 

OCS Capabilities, but 

Assessments Do Not Fully 

Reflect Subordinate 

Command Performance
Marine Forces Africa as partially compliant with its contractor 

accountability guidance, and all other components as fully compliant. 

However, AFRICOM officials stated that no subordinate command had 

processes in place to ensure that contractor personnel were being 

included in SPOT—a contractor accountability database—at the time of 

the assessment, and that AFRICOM contractor personnel accountability 

guidance was unclear about when the commands were required to 

account for contractor personnel, and what types of contractor personnel 

to include. While AFRICOM did not penalize the subordinate commands 

for non-compliance when the guidance they need to comply with is 

unclear, the scorecards did not clarify how to assess subordinate 

commands under these conditions. As a result, the assessment officials 

inconsistently applied the assessment standards.

According to GAO’s performance measure evaluation guidance, 

performance measures should be objective and performance data should 

be accurate and consistent. According to AFRICOM’s OCS Instruction, 

AFRICOM logistics officials are tasked with conducting periodic reviews 

or inspections of AFRICOM staff and component commands to ensure 

compliance with required OCS tasks.

Page 18 GAO-16-105 Operational Contract Support

24 In addition, Standards for Internal 

Control in the Federal Government state that control activities need to be 

established to monitor performance measures and indicators, and that these 

activities should be effective and efficient in accomplishing objectives.25

Moreover, according to GAO best practices in performance measurement, 

agency officials need to ensure that performance data are complete, accurate, 

and consistent enough to document performance and support decisionmaking at various organizational levels.26 Further, to the greatest extent 

possible, performance goals and measures should not require subjective 

considerations or judgments to dominate the measurement.27

 

24U.S. Africa Command Instruction 4800.01A, Operational Contract Support (OCS), para. 

6.a(19) (May 1, 2012). 

25GAO, Standards for Internal Control in the Federal Government (Washington, D.C.: November 

1999).

26GAO/GGD-96-118 Executive Guide: Effectively Implementing the Government 

Performance and Results Act (Washington, D.C.: June 1996). 

27GAO/GGD-10.1.20, Results Act: An Evaluator’s Guide to Assessing Agency Annual 

Performance Plans (Washington, D.C.: April 1998). 
AFRICOM’s assessments do not accurately reflect subordinate command 

OCS capabilities in that its assessment standards are unclear. In 

explaining the errors contained within the scorecards, AFRICOM officials 

who conducted the scorecard evaluations stated that they gave the 

subordinate commands the benefit of the doubt for certain tasks, 

particularly those for which guidance was unclear. AFRICOM officials 

further stated that the scorecard process is maturing, that there are 

several component tasks in the scorecards that they realize need 

improvement or clarification, and that the future Theater Campaign Plan 

will provide clearer explanations of the component tasks in terms of 

compliance and OCS planning. However, AFRICOM officials stated that 

they are in the process of updating the Theater Campaign Plan and did 

not give a timeframe for completion.

Without clearly defined assessment standards for the scorecard, 

AFRICOM cannot accurately assess the OCS actions taken by 

subordinate commands. The lack of accurate assessments threatens the 

integrity of those measures and undermines their value in promoting 

progress in OCS management. Furthermore, AFRICOM officials stated 

that they plan to incorporate OCS scorecards into the Defense Readiness 

Reporting System, the system used to gauge readiness across DOD. 

Without improvements, either full or partial incorporation of the scorecard 

assessments into DOD’s readiness reporting system could compromise 

the integrity of that system by capturing an inaccurate picture of OCS 

readiness.

Contractors in Africa provide a variety of services in support of U.S. 

military operations, such as transportation, construction, and food

services, and officials expect the number of contractor personnel on the 

continent to increase. However, AFRICOM does not have a complete 

picture of the number of contractor personnel supporting its operations in 

the region. AFRICOM uses two primary sources—daily personnel status 

reports

Page 19 GAO-16-105 Operational Contract Support

28 and SPOT, a DOD contractor personnel accountability database—to 

collect contractor personnel accountability information, but neither source 

provides comprehensive accountability or visibility of DOD contractor 

personnel on the continent because the total number of local national 

 

28We refer to the personnel reports that each subordinate command compiles to send to AFRICOM 

as personnel status reports. The reports AFRICOM then compiles from the subordinate commands 

to send to the Joint Staff are referred to as joint personnel status reports. 

AFRICOM Cannot 

Comprehensively 

Account for DOD 

Contractor Personnel 

in Africa
contractor personnel are not being included in either, and because the 

numbers of U.S. citizen and third country national contractor personnel 

vary between the two.

According to SPOT data, which account for some but not all contractor 

personnel, the number of contractor personnel in Africa is more than 

1,130—a nine-fold increase since April 2011. DOD contractor personnel 

perform a variety of functions and services to support mission needs, 

including transportation, linguistics, engineering, construction, cleaning, 

and food services. For example, in November 2014 AFRICOM reported 

approximately 300 U.S. contractor personnel included in SPOT as 

supporting Operation United Assistance in Senegal and Liberia. The 

contractor services primarily consisted of construction and engineering of 

training and medical units, and basic life support for troops, such as food 

and janitorial services. AFRICOM also reported approximately 350 U.S. 

contractor personnel at Camp Lemonnier, Djibouti, in October 2014 

through its daily personnel status reports. These contractor personnel 

performed a number of functions, including transportation, engineering, 

and construction.

AFRICOM officials expect the number of contractor personnel on the 

continent to continue to increase. Plans for expansion at Camp 

Lemonnier in 2015 include numerous projects to increase capacity such 

as expansion of emergency troop housing, taxiway extension, living and 

working quarters, aircraft loading areas, and upgrades to existing power 

plant capabilities. Although AFRICOM officials stated that they expect the 

number of contractors at Camp Lemonnier to decrease over time as 

construction is completed, they also stated that they expect the total 

number of contractor personnel on the African continent to continue to 

increase and shift from location to location as missions evolve, 

particularly with regard to special operations. For example, officials from 

Special Operations Command Africa stated that they are experiencing a 

significant increase in contracting actions for Combined Joint Task ForceHorn of Africa and that plans are in place to add 10 contingency 

contracting officers to Special Operations Command Africa for fiscal year 

2016. Officials stated that it is extremely important to integrate OCS into 

planning for the base’s expansion. Due to the austere environment, 

officials stated that they intend to rely on contracted solutions because 

they are more cost-effective than using military personnel.

Page 20 GAO-16-105 Operational Contract Support

Contractors Provide a 

Variety of Services to 

Support U.S. Military 

Operations in Africa and 

AFRICOM Expects to 

Increase Its Reliance on 

Them
AFRICOM generally accounts for U.S. citizen contractor personnel, but it 

accounts for third country and local national contractor personnel 

inconsistently. AFRICOM uses two sources to capture accountability 

information on contractor personnel supporting DOD operations—daily 

personnel status reports from the services, and SPOT. According to 

AFRICOM guidance, military service components, joint task forces, subunified commands, and forward operating sites in the AFRICOM area of 

responsibility are responsible for accounting for all military, DOD civilian, 

and DOD contractor personnel assigned, attached to, or under their 

operational control, and they must submit a daily personnel status report 

to AFRICOM personnel officials via email.

Page 21 GAO-16-105 Operational Contract Support

29 This information is also to be 

inputted into military service personnel accountability systems. DOD’s 

personnel accountability system—Joint Personnel Accountability 

Reconciliation and Reporting (JPARR)—receives information from 

various sources, including service-specific accountability databases and 

SPOT, and generates Joint Personnel Status Reports. AFRICOM 

personnel officials stated that they have not yet implemented JPARR and 

are instead using daily personnel status reports from the services via 

email and SPOT to manually develop Joint Personnel Status Reports and 

account for contractor personnel. For a depiction of both AFRICOM’s 

daily personnel status report and SPOT accountability processes, see 

figure 5.

 

29See U.S. Africa Command Instruction 1700.05A Personnel Management, (Apr. 4, 2012).

AFRICOM Generally 

Accounts for U.S. Citizen 

Contractor Personnel but 

Does Not Consistently 

Account for Third Country 

and Local National 

Contractor Personnel
Figure 5: U.S. Africa Command Contractor Personnel Accountability Processes

Page 22 GAO-16-105 Operational Contract Support

Note: The requirement to register contractor personnel in SPOT is incorporated into the company’s 

contract depending on the conditions of the support being provided.
AFRICOM’s daily personnel status reports generally account for U.S. 

citizen contractor personnel, but they account for third country and local 

national contractor personnel inconsistently. AFRICOM officials generally 

rely on daily personnel status reports from service components via email 

to provide visibility on the number of personnel on the continent, including 

the number of contractor personnel. These reports generally account for 

U.S. contractor personnel, but they do not consistently include local or 

third country national contractor personnel, or certain U.S. citizen 

contractor personnel not directly assigned to a U.S. installation. For 

example, the 414th Contracting Support Brigade in Uganda accounts for 

local and third country national contractor personnel in its daily personnel 

status report, but daily personnel status reports from the Air Force in 

Niger do not. In addition, AFRICOM’s daily personnel status reports do 

not include some U.S. contractor personnel who are not directly working 

on U.S. installations in a given country. For example, personnel recovery 

contractor personnel in Niger are not being accounted for in daily 

personnel status reports because, according to officials, they do not live 

on the installation.

DOD guidance indicates that combatant commands are to establish 

policies and procedures to account for contractor personnel. Joint 

Publication 4-10 indicates that a key to success in contractor 

management is for geographic combatant commands and subordinate 

joint force commands to establish clear, enforceable, and well-understood 

contractor personnel accountability policies and procedures early in the 

planning stages. The guidance notes that the supported commands must 

work closely with service components to ensure that proper contract and 

contractor management oversight is in place.

Page 23 GAO-16-105 Operational Contract Support

30 The guidance further states 

that contractor personnel visibility and accountability are essential to determine 

and provide the needed resources for government support requirements such as 

life support, force protection, and personnel recovery in uncertain or 

austere operational environments. Moreover, Chairman of the Joint 

Chiefs of Staff policy and guidance on personnel accountability31 states that 

the joint personnel status reports developed by combatant commanders are 

meant to satisfy the commander’s information needs and to authenticate 

the total number of personnel, including military, DOD civilian, and DOD 

 

30See Joint Pub. 4-10, at V-3 (July 16, 2014).

31Chairman of the Joint Chiefs of Staff Manual 3150.13C, Joint Reporting Structure—

Personnel Manual (Mar. 10, 2010) (current as of Nov. 6, 2012). 

Daily Personnel Status Reports 

Account for Third Country and 

Local National Contractor 

Personnel Inconsistently
contractors, who are physically present in a geographic combatant 

commander’s area of responsibility. Under the policy and guidance, the 

geographic combatant commander is responsible for reporting the total 

number of personnel, including DOD contractors, via joint personnel 

status report to the Joint Staff personnel directorate daily via secure 

website.

However, this guidance is unclear as to what types of contractors should 

be accounted for in the joint personnel status report. The Chairman of the 

Joint Chiefs of Staff guidance identifies SPOT as the designated webbased contractor database and lists the types of contractor personnel 

included in SPOT—including U.S., local national, host nation, and third 

country national—but it does not clearly specify the types of contractor 

personnel to report in the daily personnel status report.

Page 24 GAO-16-105 Operational Contract Support

32 AFRICOM 

officials stated that they interpreted this guidance as directing them to 

account only for U.S. citizen contractor personnel in the daily personnel 

status reports. Conversely, service component officials at some forward 

operating sites included both third country and local national, as well as 

U.S. citizen, contractor personnel in their personnel status reports sent to 

AFRICOM. AFRICOM guidance indicates that personnel status reports 

should include all military, civilian, and contractor personnel assigned, 

attached, or under the operational control of the service component, subunified command, joint task force, or forward operating site commander.33

However, AFRICOM guidance does not specify whether these contractor 

personnel include third country or local national contractor personnel such as 

linguists, or U.S. citizen contractor personnel who are under the 

operational control of the local commander but do not live on the 

installation. In addition, AFRICOM officials stated that while they receive 

daily personnel status reports from all of the services, they do not have 

complete information on how each of the services is collecting this 

information. Without consistently recording the number of contractor 

personnel in personnel status reports, AFRICOM cannot comprehensively 

 

32See id., encl. A, para. 2.a(10); encl. E, para. 13. See generally id., encl. A. The guidance also 

identifies SPOT as the source of DOD-funded contractor “JPERSTAT-type” information for a 

geographical combatant command (using the acronym for the joint personnel status 

report). See id., para. 6.b(3). However, even assuming that a combatant commander uses 

SPOT to account for each type of contractor personnel (including host nationals), the 

guidance is not explicit as to whether each type must be reported in the joint personnel 

status report itself.

33See U.S. Africa Command Instruction 1700.05A Personnel Management (Apr. 4, 2012). 
account for contractor personnel on the continent. Thus, revising the 

Chairman of the Joint Chiefs of Staff and AFRICOM policy and guidance 

on personnel accountability to clearly specify the types of personnel to be 

accounted for in the joint personnel status report would provide 

AFRICOM with better assurance that its staff consistently provides it with 

comprehensive information.

We found that not all contractors consistently accounted for their 

employees in SPOT. Specifically, contractors at two of the three sites we 

visited are not reporting third country national and local national 

employees in SPOT. For example, the contractor that manages the 

primary logistics contract in Uganda reported U.S. citizen, third country, 

and local national contractor personnel in SPOT in January 2015, but 

another contractor that manages the primary base services contract at 

Camp Lemonnier, Djibouti, accounted for U.S. citizen, third country, and 

local national contractor personnel only in its company systems and not in 

SPOT. DOD contracting officials subsequently modified the primary base 

services contract for Camp Lemonnier to include a SPOT accountability 

requirement specific to Djibouti. Officials from the primary base services 

company at Camp Lemonnier stated that they have plans to report U.S. 

citizen and third country national employees in SPOT, but they did not 

provide a timeframe for doing so. In addition, according to Camp 

Lemonnier officials, construction contractors building facilities at the site 

do not account for their U.S. citizen, third country, and local national 

contractor personnel in SPOT and do not have plans for doing so.

Various provisions in guidance cover the use of SPOT to account for 

contractor personnel.

Page 25 GAO-16-105 Operational Contract Support

34 In December 2014 AFRICOM issued an interim policy 

for the use of SPOT to account for and maintain visibility of contractor personnel 

in the AFRICOM area of responsibility.35 The guidance states that AFRICOM 

requires the use of SPOT, or its successor, to account for contractor 

 

34See, e.g., Department of Defense Instruction 3020.41, Operational Contract Support (OCS), 

encl. 2, para. 3.c (Dec. 20, 2011); 32 C.F.R. § 158.6(c)(3); 48 C.F.R. (DFARS) § 252.225-

7040(g). See also Chairman of the Joint Chiefs of Staff Manual 3150.13C, Joint Reporting 

Structure—Personnel Manual, encl. E, para. 13 (Mar. 10, 2010) (current as of Nov. 6, 

2012) (identifying SPOT as the central repository for data on all DOD funded contractor 

personnel—United States, local national, host nation, and third country national).

35U.S. Africa Command Notice 4800.01, Cancellation of ACI 4800.02A, Use of 

Synchronized Pre-deployment and Operational Tracker (SPOT) in the U.S. Africa 

Command Area of Responsibility (AOR) (Dec. 12, 2014).

Contractors Are Not 

Consistently Accounting for 

Their Employees in SPOT
personnel in all phases of operations. It states that SPOT is to be used for 

all U.S. citizens and third country nationals deploying to the area of 

responsibility, regardless of contract dollar amount. SPOT is also to be 

used to report an aggregate count of all local nationals on a monthly basis 

for contracts employing these personnel with periods of performance 

longer than 30 days.

Page 26 GAO-16-105 Operational Contract Support

36 AFRICOM’s OCS annex to the theater campaign plan 

indicates that SPOT should be utilized to account for contractor personnel 

deploying to the area of responsibility and that contracting agencies will 

direct contractors to input required information, although it does not 

specify what type of contractor personnel should be registered in SPOT in 

these provisions.37 In addition, guidance issued by DOD directs the use of 

clauses that would require contractors to use SPOT to account for certain 

contractor personnel supporting DOD operations in Djibouti and in Operation 

United Assistance.38 However, we found that many of the contracts 

identified by DOD as involving performance in Djibouti or in support of 

Operation United Assistance did not contain the clauses.39 Although DOD 

guidance directs the inclusion of the clauses for new contracts providing supplies 

or services in Djibouti and for Operation United Assistance, and 

modification of existing contracts to the extent feasible, in some cases 

there may be a good reason for omitting the clause. For example, if the 

contract is for hotel lodging, it may not make sense to have hotel 

employees registered in SPOT. In other contracts where the personnel 

will be directly supporting operations at DOD facilities, such as those for 

construction or base support, requiring the contractor to register its 

personnel in SPOT would help AFRICOM to identify who is supporting its 

operations and for whom it may be responsible in the event of an 

emergency.

 

36SPOT is also to be used for all private security contracts. See id.

37The guidance specifies use of SPOT to account for contractors authorized to 

accompany the force in several provisions, but not in others.

38See Class Deviation 2014-O0005, Requirements for Contractor Personnel Performing in Djibouti 

(Jan. 13, 2014); Class Deviation 2015-O0003, Contractor Personnel Performing in Support 

of Operation United Assistance in the United States Africa Command Theater of 

Operations (Dec. 16, 2014). 

39In some instances, the contracts may have contained related clauses requiring the use of SPOT 

for certain contractor personnel, such as DFARS § 252.225-7040. Although these clauses 

include information related to SPOT accountability for certain contractor personnel, it may 

not always be clear which contractor personnel they cover or whether they apply in 

circumstances such as performance in Djibouti or during Operation United Assistance. 
AFRICOM personnel accountability guidance is unclear. As stated earlier, 

Chairman of the Joint Chiefs of Staff guidance does not specify what 

types of contractor personnel, such as U.S. citizen, third country national, 

or local national, should be included in joint personnel status reports. In 

addition, there are multiple provisions in guidance issued by different 

sources, requiring the registration of different types of employees in 

SPOT in various circumstances. Furthermore, AFRICOM’s interim 

guidance generally requiring all contractor personnel in its area of 

responsibility to be accounted for in SPOT expires in December 2015. 

AFRICOM officials stated that they intend to request that this interim 

guidance be included in an updated version of the Defense Federal 

Acquisition Regulation Supplement. According to DOD officials, as of 

October 2015, AFRICOM was in the final stages of drafting proposed 

language to this effect. However, as of November 2015, there have been 

no changes.

In March 2014, the AFRICOM commander stated that the command is 

responsible for helping to protect U.S. personnel in Africa.

Page 27 GAO-16-105 Operational Contract Support

40 Without clear 

accountability guidance, AFRICOM cannot consistently or 

comprehensively determine how many contractor personnel support DOD 

operations in the region. Without clarification and deconfliction of 

guidance, AFRICOM and its subordinate commands will not know what 

types of contractor personnel to include in personnel status reports and in 

SPOT, and they could continue to account for these personnel 

inconsistently. As a result, commanders are at risk of not having 

comprehensive visibility over who is supporting DOD operations in the 

area of responsibility. In addition, the AFRICOM area of responsibility lies 

in an increasingly high threat environment. The Department of State has 

identified 15 high threat posts on the continent. Without comprehensive 

and consistent contractor personnel accountability, commanders may be 

unaware of whom they are responsible for in the event of an emergency.

 

40Statement of AFRICOM Commander General David M. Rodriguez, submitted to the Senate 

Armed Services Committee, Mar. 6, 2014. 
AFRICOM conducts some limited vetting of potential contractors, also 

referred to as vendors, but it has not established a foreign vendor vetting 

process or cell that would preemptively identify vendors who support 

criminal, terrorist, or other sanctioned organizations. Additionally, in 

efforts to conduct individual contractor employee screening, AFRICOM 

sites we visited used different types of background investigations to 

determine the trustworthiness of contractor employees with access to 

DOD facilities. However, these AFRICOM forward operating sites were 

not incorporating additional screening measures, such as biometric 

screening or counterintelligence interviews, according to the specific risks 

at each site. As a result, AFRICOM is at risk of not exercising the 

appropriate level of vendor vetting or contractor employee screening on 

the African continent.

AFRICOM conducts some limited vendor vetting, but it has not 

established a foreign vendor vetting process. The Federal Acquisition 

Regulation and DOD guidance require contracting officers to ensure that 

they are not contracting with any prohibited entities by vetting potential 

vendors’ names against a list of prohibited, restricted, or otherwise 

ineligible persons or entities in the System for Award Management.

Page 28 GAO-16-105 Operational Contract Support

41 The 

System for Award Management is a database used during the procurement 

process that, among other things, provides information on parties that are 

prohibited or restricted from receiving federal contracts. In addition to 

information added by DOD, the database includes entities identified by 

the Department of Treasury’s Office of Foreign Assets Control, 

Department of State, and other U.S. agencies. All of the AFRICOM 

service components with whom we conducted interviews stated that their 

contracting officials do check the prohibited entities list in the System for 

Award Management. However, as noted by Joint Publication 4-10 in a 

related discussion, checking certain lists alone may be insufficient. 

Specifically with respect to two lists maintained by the U.S. Department of 

 

41See FAR § 9.405(d); Class Deviation 2014-O0020, Prohibition on Contracting with the 

Enemy (Sept. 17, 2014). After a draft of this report was sent to DOD for comment, DOD 

issued an updated Class Deviation in September 2015. Although the update may be more 

limited in scope, generally covering contracts in support of contingency operations in 

which members of the Armed Forces are actively engaged in hostilities, the requirement 

for contracting officers to check the exclusions list does not explicitly include this limitation, 

applying instead to contracts awarded on or before December 31, 2019, to be performed 

outside the United States and its outlying areas. See Class Deviation 2015-O0016, 

Prohibition on Providing Funds to the Enemy and Authorization of Additional Access to 

Records, attachment 3 (Sept. 15, 2015).

AFRICOM Conducts 

Limited Vetting of 

Contractors and 

Contractor 

Employees and Does 

Not Have Guidance 

to Apply Additional 

Risk-Based Measures

AFRICOM Conducts 

Limited Vetting but 

Does Not Have a 

Foreign Vendor 

Vetting Process to 

Prevent Contracting 

with Prohibited 

Entities
Treasury, Joint Publication 4-10 indicates that the department has 

traditionally designated only umbrella organizations.

Page 29 GAO-16-105 Operational Contract Support

42 In addition, officials 

from all of AFRICOM’s service components stated that in their contracting 

process they use a list of vendors vetted by the local U.S. embassy. 

However, U.S. Embassy and Department of State headquarters officials 

stated that vendors on these lists are not vetted for security risks or to 

determine whether they are connected to or supporting any prohibited 

organizations; rather, they are vetted only for their ability to provide the 

required services. As a result, AFRICOM’s current vetting process is 

limited in its ability to ensure that DOD is not funding prohibited 

organizations in high risk areas.

Current DOD guidance is not clear on what vendor vetting steps or 

process should be established at each combatant command to mitigate 

the risk of contracting with terrorist or other prohibited organizations. Joint 

Publication 4-10 discusses the benefit of establishing a cell, when 

circumstances warrant, to vet foreign vendors for possible security 

concerns and avoid awarding contracts to companies that have ties to 

insurgents.43 However, the guidance does not require the establishment of a 

vendor vetting cell or specify under what conditions it would be 

appropriate. Two combatant commands—U.S. Transportation Command 

and U.S. Central Command—have established foreign vendor vetting 

cells for this purpose. Although AFRICOM does not have its own foreign 

vendor vetting cell, during AFRICOM’s most recent contingency 

operation—Operation United Assistance—AFRICOM requested 

assistance from U.S. Transportation Command’s foreign vendor vetting 

cell to provide threat assessments on all of the vendors that had been 

awarded AFRICOM contracts. Although U.S. Transportation Command 

was able to take on this additional workload, AFRICOM does not have a 

written agreement to use that command’s vetting capability, and it may 

not be able to leverage U.S. Transportation Command’s capabilities for 

future contingencies.

In addition, AFRICOM may not be fully prepared to avoid contracting with 

vendors who may also be supporting the enemy should it become actively 

engaged in hostilities. In response to recent statutory provisions regarding 

contracting with the enemy, DOD has issued guidance for geographic 

 

42See Joint Pub. 4-10, at III-22 (July 16, 2014).

43See id. at III-27 to III-28.
combatant commands (with the exception of U.S. Northern Command) to 

identify persons or entities who directly or indirectly provide funds, 

including goods and services, received under covered contracts to person 

or entities that are actively opposing U.S. or Coalition forces in a 

contingency operation in which the armed forces are actively engaged in 

hostilities.

Page 30 GAO-16-105 Operational Contract Support

44 According to DOD officials, the list of identified persons and 

entities is integrated into the System for Award Management. As noted 

above, the guidance also requires contracting officers to check this 

database to ensure that contracts are not awarded to prohibited or 

restricted persons or entities. According to officials, U.S. Central 

Command is the only combatant command that is currently required to 

proactively identify these vendors, organizations, and people and add 

them to the prohibited entities list because it is the only combatant 

command currently engaged in hostilities in a contingency environment. 

Although AFRICOM does not currently have any declared contingency 

operations involving active hostilities, it operates in a high threat 

environment in which hostilities could quickly arise. Without having a 

foreign vendor vetting process in place, it will be difficult for AFRICOM to 

recognize and thereby avoid instances of contracting with the enemy.

AFRICOM officials agree that a foreign vendor vetting process would 

reduce the risk that they would contract with prohibited entities, and they 

have drafted guidance on establishing a foreign vendor vetting cell. 

However, AFRICOM officials stated that they would need specific 

guidance from the Office of the Secretary of Defense or Joint Chiefs of 

Staff specifying the conditions under which combatant commands should 

establish a vendor vetting cell to effectively implement this process. For a 

description of AFRICOM’s current vendor vetting process and how it 

would be supplemented by the establishment of the foreign vendor vetting 

cell described in its draft guidance see figure 6.

 

44See Class Deviation 2015-O0016, Prohibition on Providing Funds to the Enemy and 

Authorization of Additional Access to Records, attachment 3 (Sept. 15, 2015). The guidance 

implements section 841 of the Carl Levin and Howard P. “Buck” McKeon National 

Defense Authorization Act for Fiscal Year 2015, Pub. L. No. 113-291 (2014) (10 U.S.C. § 

2302 note). It superseded earlier guidance implementing provisions from the National 

Defense Authorization Act for Fiscal Year 2014. See Class Deviation 2014-O0020, 

Prohibition on Contracting with the Enemy (Sept. 17, 2014).
Figure 6: U.S. Africa Command’s Proposed Foreign Vendor Vetting Process

Page 31 GAO-16-105 Operational Contract Support

Note: AFRICOM’s proposed vendor vetting process would apply to solicitations or contract awards 

with an estimated value in excess of $50,000 that would be performed using foreign vendors.

AFRICOM officials also cited resource limitations, specifically a shortfall in 

intelligence analyst positions required for the proposed foreign vendor 

vetting cell, as one of the challenges it faces to establishing a foreign 

vendor vetting process. We have previously concluded that a risk-based 

approach can help agencies strategically allocate limited resources to 
achieve desired outcomes.

Page 32 GAO-16-105 Operational Contract Support

45 In 2011 we recommended that U.S. Central 

Command consider a risk-based approach in identifying and vetting the 

highest-risk foreign vendors.46 In response to our recommendation, U.S. 

Central Command established a formalized risk-based vetting program. 

Its vetting process is designed to ensure that DOD funds are not used for 

illicit purposes and to provide a risk management tool to identify foreign 

vendors that have ties to the insurgency or that are involved in nefarious 

activities. While the establishment of a foreign vendor vetting cell may not 

be appropriate for all operations, published DOD guidance specifying 

under what circumstances and how a vetting cell should be established 

would better position AFRICOM and other commands to avoid contracting 

with the enemy in high threat areas or in the event that they become

actively engaged in hostilities.

AFRICOM generally operates in a high threat area of responsibility, and 

the screening of non-U.S. personnel entering AFRICOM facilities protects 

DOD personnel, equipment, and installations from acts of espionage, 

sabotage, or other intelligence activities. According to agency officials and 

our observation of contractor personnel screening at the sites we visited, 

all of the sites conduct some type of background investigation to screen 

non-U.S. contractors, but Camp Lemonnier, Djibouti—the largest and 

most enduring site in the AFRICOM area of operations—has the most 

comprehensive screening process (see table 1 below). The other sites 

that we visited have incorporated additional screening measures to 

varying degrees.

 

45For example, see GAO-11-144, Federal Lands: Adopting a Formal, Risk-Based Approach 

Could Help Land Management Agencies Better Manage Their Law Enforcement 

Resources, (Washington, D.C.: Dec. 17, 2010) and GAO-09-85, Commercial Vehicle 

Security: Risk-Based Approach Needed to Secure the Commercial Vehicle Sector, 

(Washington, D.C.: Feb. 27, 2009).

46GAO-11-355, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Need Improvement. 

(Washington, D.C.: June 8, 2011).

AFRICOM Sites That GAO 

Visited Use Background 

Investigations to Screen 

Contractor Employees but 

Lack Risk-Based 

Guidance for Incorporating 

Additional Screening 

Measures
Table 1: U.S. Africa Command (AFRICOM) Contractor Employee Screening Measures Vary by Site

Page 33 GAO-16-105 Operational Contract Support

Site

Type of site, 

threat level

Background 

investigationa

Counterintelligence 

interviewb

Biometric 

screeningc

Document and 

media 

exploitationd

Process generally 

documented in 

local guidance

Djibouti Enduring, high 

threat 

Yes, conducted by 

Department of 

Defense (DOD)

Limited Yes YeseYes

Niger Semi-enduring, 

high threat 

Yes, conducted by 

DOD and U.S. 

embassy 

Limited Nof No Nog

Uganda Semi-enduring, 

high threat

Yes, conducted by 

U.S. embassy or 

vendor

Limited Limited to local 

national drivers

No No

Source: GAO analysis of DOD and State Department information | GAO-16-105

Notes: 

a

A background investigation is the screening of contractors’ biographical information against local 

criminal records and/or US terrorist watch lists and other intelligence databases.

b

A counterintelligence interview is an interview conducted to confirm the trustworthiness of the 

contractor employee and the information provided for the background investigation.

c

Biometric screening is the screening of an individual’s physical characteristics, such as fingerprints or 

irises, against a biometrically enabled watch list or other biometric intelligence database.

dDocument and media exploitation is the collection, analysis, and exploitation of captured equipment, 

personal documents, and media to generate actionable intelligence.

e

In August 2014, Camp Lemonnier, Djibouti reinitiated contractor employee screening document and 

media exploitation related operations after an 8 month gap.

f

Air Force officials at the Niger site received three biometric collection kits in Fall 2014, but two of 

three kits broke soon after their arrival and the officials have since suspended biometric collection as 

part of its contractor screening process.

g

The Air Force’s Niger site has local security guidance, but it does not describe the contractor 

screening process currently in place.

AFRICOM officials stated that all DOD sites in the AFRICOM area of 

responsibility conduct background investigations for non-U.S. contractors 

who require base access. All three sites that we visited use background 

investigations to determine the trustworthiness of third country and local 

national contractor employees who have access to DOD facilities. 

Background investigations at the sites we visited generally consist of 

gathering the contractor employee’s biographical information and 

crosschecking it with U.S. government intelligence sources and against 

local criminal records. However, the utility of these types of background 

investigations is limited by the quality of (1) the biographic information 

provided by the contractors, and (2) local government records, upon 

which the investigations are based. For example, according to base 

Background Investigations
access officials, Djiboutian local national contractors are often able to 

provide the year, but not the specific day and month, in which they were 

born. In addition, at the sites we visited, DOD and Department of State 

officials stated that local government criminal records in Africa may not be 

easily searchable or well-maintained. As a result, additional contractor 

employee screening measures may be warranted.

In light of the limitations of background investigations, additional 

contractor employee screening measures, such as counterintelligence 

interviews, biometric screening, and document and media exploitation, 

are incorporated to varying degrees at the three sites we visited (see 

table 1). For example, counterintelligence interviews with potential 

contractor personnel can be used to confirm the trustworthiness of the 

contractor employee and the information provided for the background 

investigation. While all of the sites we visited conduct counterintelligence 

interviews to varying degrees, according to DOD officials, none of them 

conducts interviews with all of its non-U.S. contractor personnel.

Biometric screening is another measure that can be incorporated into the 

contractor employee screening process. The collection of biometric 

information, such as fingerprints or irises, unequivocally links the 

individual’s identity by attaching it to measurable physical characteristics. 

Officials can then screen this biometric information against a biometrically 

enabled watch list or other intelligence database. In August 2009 

AFRICOM issued a Biometrics Concept of Operations stating that, to the 

maximum extent allowable under policy and law, persons requiring 

access to DOD installations in the AFRICOM area of responsibility will be 

enrolled into a biometrics database.

Page 34 GAO-16-105 Operational Contract Support

47 However, Camp Lemonnier, Djibouti, 

is the only site we visited that has fully incorporated biometrics screening 

into its contractor employee screening process. From April to midDecember 2014 Camp Lemonnier, Djibouti, denied access to six 

contractor personnel after finding derogatory information on them through 

its biometric screening process.

Security officials at Camp Lemonnier, Djibouti, also use biometric and 

document and media exploitation systems to upload contractor 

employees’ biometrics and personal documentation to the larger DOD 

intelligence enterprise (see figure 7). Uploading of personal 

 

47AFRICOM Biometric Concept of Operations, Aug. 2009.

Additional Screening Measures
documentation into U.S. intelligence databases refers to document and 

media exploitation, which consists of the collection, analysis, and 

exploitation of equipment, personal documents, and media to generate 

actionable intelligence. This information can then be accessed by 

intelligence officials if the contractor employee attempts to access another 

DOD site. For example, from April to mid-December 2014 security 

officials at Camp Lemonnier, Djibouti, placed 30 contractor employees on 

a watch list based on their negative activity.

Figure 7: Camp Lemonnier, Djibouti, Contractor Employee Screening Process

Page 35 GAO-16-105 Operational Contract Support

Moreover, with the exception of Camp Lemonnier, Djibouti, contractor 

employee screening processes are not well-documented in local base 

security guidance. Joint Publication 4-10 states that commanders must 

ensure that local screening and badging policies and procedures are in 
place for all contractor personnel requiring access to U.S. facilities.

Page 36 GAO-16-105 Operational Contract Support

48 We

found that Camp Lemonnier, Djibouti, was the only site of the three we 

visited that had clearly outlined contractor employee screening processes 

in local base security guidance. The Air Force’s site in Niamey, Niger, has 

base security guidance, but it does not describe its contractor employee 

screening process.

One reason cited by officials for not developing local contractor employee 

screening procedures and policies was that AFRICOM has not yet 

specified what measures should be incorporated into the sites’ contractor 

employee screening processes. DOD Instruction 2000.12, providing 

guidance for the DOD Antiterrorism Program, states that combatant 

commands shall establish antiterrorism policies and programs for the 

protection of all DOD elements and personnel in their areas of 

responsibility.49 One of the minimum elements of an antiterrorism program is 

risk management. Antiterrorism risk management includes the 

determination of how best to employ given resources and force protection 

measures to deter, mitigate, or prepare for a terrorist incident.50 Those 

measures could include contractor employee screening measures. 

AFRICOM drafted contractor employee screening guidance in November 

2014, which it subsequently updated. As of June 2015, AFRICOM 

officials stated that the guidance was under review, but they did not 

provide a timeframe for its issuance. This draft guidance would provide 

that screening measures, including biometric screening, should be in 

place when non-U.S. personnel have access to AFRICOM-controlled 

facilities. The draft guidance contains a detailed appendix that describes 

under what conditions biometric screening should be conducted, and it 

discusses document and media exploitation. However, it lacks additional 

information regarding when other screening measures should be 

implemented. Officials at the sites we visited stated that access to 

biometric collection equipment and counterintelligence agents constituted 

a challenge due to limited resources. As a result, although AFRICOM’s 

draft guidance would direct sites to perform additional screening 

measures whenever a non-U.S. contractor employee requires access to 

 

48Joint Pub. 4-10, at V-25 (July 16, 2014).

49Department of Defense Instruction 2000.12, DOD Antiterrorism (AT) Program, encl. 2, para. 

20.b (Mar. 1, 2012) (incorporating change Sept. 9, 2013).

50See id. at 29; see also Department of Defense Instruction 2000.16, DoD Antiterrorism (AT) 

Standards, encl. 3, para. E3.3 (Oct. 2, 2006) (incorporating change, Dec. 8, 2006).
them, the sites may not have the resources to implement the guidance, 

when issued.

Furthermore, risk varies from site to site, depending on a number of 

factors, such as the location’s threat profile, operations, and numbers and 

types of personnel. Risk-based guidance that indicates the specific 

measures to be incorporated into contractor employee screening 

processes could better position AFRICOM components to conduct the 

appropriate level of screening and effectively allocate screening 

resources to protect DOD personnel and facilities from insider threats.

DOD has spent billions of dollars on contract support since 2002, and as 

its footprint in Africa increases it is more frequently relying on contractor 

support for a range of operations to provide logistical, transportation, and 

intelligence support to AFRICOM’s missions. The enhanced capabilities 

offered by OCS can be a significant force multiplier in every phase of joint 

and coalition operations in Africa. Conversely, the inability to effectively 

manage and plan for OCS could yield unintended consequences such as 

higher costs and inadvertent contracting with vendors that have ties to 

violent extremist organizations that could complicate or even undermine 

operational objectives. While AFRICOM has taken steps to manage and 

plan for OCS, challenges remain in areas such as development of OCS 

structures, assessments of subordinate command capabilities, accounting 

of the total number of contractor personnel, and contractor vetting. 

Several of AFRICOM’s subordinate commands—service component and 

joint force commands—lack organizational structures, such as OCS 

Integration Cells, with dedicated personnel to manage and plan for OCS. 

A structure such as an OCS Integration Cell would be particularly useful 

in a joint environment, such as Combined Joint Task Force-Horn of 

Africa, due to the number of military service contracting elements 

operating at the same location, with potentially limited resources. 

Additionally, clearly defined assessment standards could help AFRICOM 

to more accurately assess the OCS actions taken by subordinate 

commands. Furthermore, AFRICOM cannot comprehensively account for 

DOD contractors on the continent because AFRICOM and joint staff 

guidance is unclear regarding the types of contractors who should be 

accounted for and by which personnel accountability process. Clear 

guidance could help AFRICOM to determine how many contractors 

support DOD operations in the region, providing commanders with 

greater visibility over who is supporting DOD operations in the area of 

responsibility. Also, AFRICOM has not established a foreign vendor 

vetting process to preemptively identify vendors that support criminal, 

Page 37 GAO-16-105 Operational Contract Support

Conclusions
terrorist, or other sanctioned organizations, because there is no DOD 

guidance specifying conditions under which combatant commands should 

have a vendor vetting process or cell in place to determine whether 

potential vendors actively support any terrorist, criminal, or other 

sanctioned organizations. Moreover, there is no guidance clarifying when 

combatant commands should develop procedures for transmitting names 

of vendors identified through such a vendor vetting process for inclusion 

in prohibited entities lists. Finally, not all of the AFRICOM forward 

operating sites we visited are incorporating additional screening 

measures according to the specific risks at each site. The development of 

a foreign vendor vetting process and risk-based employee screening 

measures could help AFRICOM to determine appropriate levels for 

vendor vetting and contractor employee screening on the African 

continent.

We recommend the following seven actions.

To enable AFRICOM’s component commands to better plan, advise, and 

coordinate for OCS, we recommend that the AFRICOM Commander, as 

part of AFRICOM’s ongoing efforts to update related guidance and 

emphasize the importance of OCS integration at the subordinate 

command level, take the following actions:

· Direct the service components to designate elements within their 

respective staffs to be responsible for coordinating OCS, and consider 

the establishment of an OCS Integration Cell or similar structure with 

these dedicated OCS personnel, as needed.

· Clarify under what conditions a subordinate joint force command, 

such as Combined Joint Task Force-Horn of Africa, should establish 

an OCS Integration Cell.

To enable AFRICOM to better identify, address, and mitigate OCS 

readiness gaps at its component commands before inaccurate 

information is incorporated into formal defense readiness reporting 

systems, we recommend that the AFRICOM Commander take the 

following action:

· Clarify the scorecard process, including assessment standards, for 

OCS Readiness Scorecards to ensure that evaluators can accurately 

assess subordinate commands’ OCS capabilities.

To enable AFRICOM to comprehensively and consistently account for 

contractor personnel in Africa, we recommend that: 

Page 38 GAO-16-105 Operational Contract Support

Recommendations for 

Executive Action
· The Secretary of Defense, in coordination with the Chairman of the 

Joint Chiefs of Staff, direct Joint Staff to clarify what types of 

contractor personnel should be accounted for in its guidance on 

personnel status reports.

· The AFRICOM Commander develop area of responsibility-wide 

contractor personnel accountability guidance on or before December 

2015, when the current guidance expires, that clarifies which types of 

contractor personnel should be accounted for using SPOT, and when 

SPOT accountability requirements should be incorporated into 

contracts.

To ensure that combatant commands are not contracting with entities that 

may be connected to or supporting prohibited organizations, we 

recommend that the Secretary of Defense, in coordination with the 

Chairman of the Joint Chiefs of Staff, take the following action:

· Develop guidance that clarifies the conditions under which combatant 

commands should have a foreign vendor vetting process or cell in 

place to determine whether potential vendors actively support any 

terrorist, criminal, or other sanctioned organizations, including 

clarifying when combatant commands should develop procedures for 

transmitting the names of any vendors identified through this process 

for inclusion in prohibited entities lists in the appropriate federal 

contracting databases, such as the System for Award Management.

To ensure that AFRICOM applies a risk-based approach to contractor 

employee screening in Africa, we recommend that the Secretary of 

Defense take the following action:

· Direct AFRICOM to complete and issue guidance that specifies the 

standard of contractor employee screening for forward operating sites, 

based on factors such as the number of DOD personnel on base, type 

of operations, and local security threat.

In written comments on a draft of this report, DOD concurred with four of 

our recommendations, partially concurred with two, and did not concur 

with our recommendation related to AFRICOM contractor personnel 

accountability guidance. DOD’s comments are summarized below and 

reprinted in appendix II. DOD also provided technical comments, which 

we incorporated where appropriate. 

DOD partially concurred with our first recommendation, that AFRICOM 

direct its service components to designate elements within their 

respective staffs to be responsible for coordinating OCS, and consider the 

Page 39 GAO-16-105 Operational Contract Support

Agency Comments 

and Our Evaluation
establishment of an OCS Integration Cell or similar structure with 

dedicated OCS personnel. DOD stated that AFRICOM is assessing its 

subordinate commands’ OCS structures to determine the best way 

forward, and acknowledges that there are clear advantages and benefits 

to establishing an OCS Integration Cell at the service-component level 

even though there is no doctrinal requirement to do so. As we discuss in 

the report, while joint staff guidance does not require the establishment of 

an OCS Integration Cell or dedicated OCS personnel at the service 

component command level, joint staff has emphasized the benefits of 

using an OCS Integration Cell to synchronize requirements and 

coordinate contracting actions. This recommendation was intended to 

provide service component commands with the flexibility to develop OCS 

Integration Cells or similar structures with dedicated OCS personnel who 

can address these concerns. Moreover, an OCS Integration Cell or 

similar structure could help identify contract support issues early in the 

requirements development process, thereby enabling the service 

component commands to avoid delays in receiving needed equipment or 

services. Further, this designation would better ensure AFRICOM’s 

component commands effectively plan, advise, and coordinate OCS 

activities and meet the intent of the recommendation. 

DOD concurred with our second recommendation, that AFRICOM clarify 

under what conditions a subordinate joint force command, such as 

Combined Joint Task Force-Horn of Africa, should establish an OCS 

Integration Cell. In its comments, AFRICOM stated that all subordinate 

joint force commands should establish an OCS Integration Cell. 

AFRICOM further stated that it had scheduled a staff assistance visit to 

Combined Joint Task Force-Horn of Africa to assess and develop a plan 

for establishing an OCS Integration Cell. We acknowledge that 

AFRICOM’s statement in its comments clarifies that an OCS Integration 

Cell should be established at a subordinate joint force command, and 

believe that the scheduling of a staff assistance visit to Combined Joint 

Task Force-Horn of Africa is a positive first step toward establishing a cell 

there. However, we also believe that providing that clarification in 

AFRICOM guidance would better ensure the establishment of such a cell 

at various types of subordinate joint force commands. As we noted in the 

report, an OCS Integration Cell was established at AFRICOM’s 

subordinate joint force command supporting Operation United Assistance 

in 2014, but not at the Combined Joint Task Force-Horn of Africa in 

Djibouti, or Special Operations Command Africa. Furthermore, AFRICOM 

officials stated they conducted a staff assistance visit to Combined Joint 

Task Force-Horn of Africa in August 2015 to assess and develop a plan 

to establish an appropriate OCS structure there. Guidance clarifying 

Page 40 GAO-16-105 Operational Contract Support
under what conditions a subordinate joint force command should 

establish an OCS Cell, if fully implemented, would meet the intent of our 

recommendation. 

DOD partially concurred with the third recommendation, that AFRICOM 

clarify the scorecard process, including assessment standards, for OCS 

Readiness Scorecards to ensure that evaluators can accurately assess 

subordinate commands’ OCS capabilities. DOD stated that the scorecard 

is a command initiative designed to drive discussion about OCS issues 

with subordinate commands, but is not a replacement for the Defense 

Readiness Reporting System to report OCS. We agree that the scorecard 

is not such a replacement. However, as noted in the report, AFRICOM 

officials stated that they plan to incorporate OCS scorecards into the 

Defense Readiness Reporting System, the system used to gauge 

readiness across DOD. This recommendation was intended to ensure 

that OCS scorecard assessment standards are clearly defined so that 

AFRICOM can accurately assess OCS actions taken by subordinate 

commands. Without improvements, either full or partial incorporation of 

the scorecard assessments into DOD’s readiness reporting system could 

compromise the integrity of that system by capturing an inaccurate picture 

of OCS readiness. 

DOD concurred with our fourth recommendation, that the Secretary of 

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

direct Joint Staff to clarify what types of contractor personnel should be 

accounted for in its guidance on personnel status reports. In its 

comments, DOD stated that Chairman of the Joint Chiefs of Staff Manual 

3150.13C, Joint Personnel Reporting Structure-Personnel Manual 

provides policy and guidance on what types of contractor personnel to 

account for in personnel status reports, but that additional training and 

amplifying local procedures issued by AFRICOM’s personnel directorate 

may be needed to fully implement its provisions and ensure consistent 

interpretation of the guidance. As we noted in the report, the Chairman of 

the Joint Chiefs of Staff guidance identifies SPOT as the designated webbased contractor database and lists the types of contractor personnel 

included in SPOT—including U.S., local national, host nation, and third 

country national—but it does not clearly specify the types of contractor 

personnel to report in the daily personnel status report, and as a result, 

service component officials at some forward operating sites inconsistently 

included various types of contractors in personnel status reports. While 

we believe that additional guidance provided by AFRICOM’s personnel 

directorate would provide further clarification on this issue, we continue to 

believe that clarifying Joint Staff guidance to clearly specify the types of 

Page 41 GAO-16-105 Operational Contract Support
contractor personnel to be accounted for in joint personnel status reports 

would provide AFRICOM better assurance that its staff consistently

provides it with comprehensive information.

DOD did not concur with the fifth recommendation, that the Secretary of 

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

direct AFRICOM to develop area of responsibility-wide contractor 

personnel accountability guidance on or before December 2015, when 

the current guidance expires, that clarifies which types of contractor 

personnel should be accounted for using SPOT and when SPOT 

accountability requirements should be incorporated into contracts. DOD 

stated that there is not a requirement for the Secretary of Defense to 

direct AFRICOM to develop this guidance. We agree that it may not be 

necessary for the Secretary of Defense to direct this action and 

accordingly adjusted the language of the recommendation directly to 

AFRICOM. Additionally, DOD stated it is coordinating a draft class 

deviation to the Defense Federal Acquisition Regulation Supplement on 

accountability requirements for contractor personnel performing in the 

AFRICOM area of responsibility, which it expects to be approved and 

published by December 2015. We acknowledge that this class deviation, 

when completed, may provide further clarity on the types of contractor 

personnel to include in SPOT. However, we continue to believe that 

AFRICOM could benefit from developing and issuing contractor personnel 

accountability guidance for its area of responsibility. Specifically, as we 

noted in the report, there have been no changes to the Defense Federal 

Acquisition Regulation Supplement to date on this topic, DOD has not 

issued a Class Deviation, and AFRICOM’s existing interim guidance 

expires in December 2015. Thus, we continue to believe that clear 

accountability guidance would enable AFRICOM to more consistently and 

comprehensively determine how many contractor personnel support DOD 

operations in the region.

DOD concurred with our sixth recommendation, that the Secretary of 

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

develop guidance that clarifies the conditions under which combatant 

commands should have a foreign vendor vetting process or cell in place 

to determine whether potential vendors actively support any terrorist, 

criminal or other sanctioned organizations, including clarifying when 

combatant commands should develop procedures for transmitting the

names of any vendors identified through this process for inclusion in 

prohibited entities list in the appropriate federal contracting databases, 

such as the System for Award Management. In its comments, DOD 

stated that OSD has established a joint working group to identify key 

Page 42 GAO-16-105 Operational Contract Support
stakeholders and develop DOD policy requiring combatant commands to 

develop foreign vendor vetting processes. When fully implemented, we 

believe these actions would meet the intent of our recommendation. 

DOD concurred with our seventh recommendation, that AFRICOM 

continue to complete and issue guidance that specifics the standard of 

contractor employee screening for forward operating sites, based on 

factors such as the number of DOD personnel on base, type of 

operations, and local security threat. In its comments, DOD stated that 

AFRICOM has completed the staffing of a draft instruction that will 

provide guidance and specify the standards for contractor employee 

screening for forward operating sites, including a risk-based approach to 

contractor employee screening based on applicable mitigating factors that 

include the type of contractor, operations and local security threat. While 

we have not seen an updated version of this draft guidance that includes 

a risk-based approach to screening, if it is fully implemented as described 

above, it would meet the intent of our recommendation. 

We are providing copies of this report to the appropriate congressional 

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

Staff and the AFRICOM Commander. In addition, this report is available 

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

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

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

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

page of this report. GAO staff who made key contributions to this report 

are listed in appendix III. 

Cary B. Russell

Director, Defense Capabilities and Management

Page 43 GAO-16-105 Operational Contract Support
Appendix I: Objectives, Scope, and 

Methodology

The objectives of our review were to determine the extent to which 

AFRICOM: (1) has an organizational structure in place to manage, plan 

for, and assess operational contract support; (2) accounts for contractor 

personnel in its area of responsibility; and (3) vets non-U.S. contractors 

and contractor employees. The focus of this review was on AFRICOM 

and its subordinate commands, including the service component 

commands, as well as Special Operations Command Africa in Europe, 

and the Combined Joint Task Force-Horn of Africa at Camp Lemonnier in 

Djibouti. Further, in terms of our review of AFRICOM contractor personnel 

accountability and contractor vetting, our scope included only contract 

support on the African continent, excluding contract support located at 

AFRICOM headquarters.

To determine the extent to which AFRICOM has an organizational 

structure in place to manage, plan for, and assess operational contract 

support, we gathered information from and conducted interviews with 

officials at AFRICOM headquarters, as well as the AFRICOM service 

component command headquarters in Europe. To determine the extent to 

which AFRICOM assesses OCS capabilities, we evaluated the OCS 

readiness scorecards created by AFRICOM J4 (Logistics Directorate) to 

measure its service components’ OCS capabilities in 2014. In its 

assessment of the component commands, AFRICOM J4 rated each 

service component as compliant, partially compliant, or non-compliant 

with OCS tasks for four performance measure categories: planning, 

policy, operations/exercises/security cooperation, and administration. We 

evaluated the ratings that J4 applied to the service components in these 

categories to determine whether they were accurate. Specifically, to 

evaluate the accuracy of the scorecard ratings, we validated the ratings 

using evidence gathered from the service components and compared 

ratings of the service components with similar conditions against one 

another to determine whether they received the same ratings. To 

evaluate the extent to which AFRICOM plans for OCS, we reviewed OCS 

annexes—Annex W’s—to AFRICOM’s theater campaign plan and its 

regional campaign plans to determine the extent to which they included 

key OCS concepts outlined in DOD and joint staff guidance.

To determine the extent to which AFRICOM accounts for contractor 

personnel, we reviewed DOD, AFRICOM, and Joint Staff personnel 

accountability guidance and interviewed AFRICOM J1 officials, as well as 

military service officials with personnel accountability responsibilities at 

the AFRICOM forward operating sites we visited. In addition, we reviewed 

contracts with place of performance in Djibouti from March 2013 to 

February 2014, as well as Operation United Assistance (OUA) contracts 

Page 44 GAO-16-105 Operational Contract Support

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

from December 2014 to February 2015 listed in the All Government 

Contract Spend data, to determine whether they included clauses to 

register employees supporting the contracts in the Synchronized 

Predeployment and Operational Tracker (SPOT). The different 

timeframes used for the selection of those contracts were based, in part, 

on the timing of various DOD requirements to use clauses that included 

SPOT-related provisions. Finally, we reviewed monthly SPOT data from 

2011 to 2015 provided by AFRICOM personnel officials to determine 

whether the numbers of contractor personnel had increased or decreased 

within the past 5 years. We conducted a data reliability analysis of this 

information, including corroborating the data with agency officials to 

ensure that it is accurate, up-to-date and reasonable. We determined the 

data to be sufficient and reliable for the purposes of this report.

To determine the extent to which AFRICOM vets contractors and 

contractor employees we reviewed DOD and military department 

contracting, anti-terrorism, and physical security guidance and compared 

it to information gathered from AFRICOM J2X (counterintelligence) and 

three forward operating sites concerning their vendor vetting and 

contractor employee screening processes. In addition, we observed 

contractor screening and base access procedures at the forward 

operating sites in Djibouti, Niger, and Uganda. We selected these 

locations based on variations in the military services represented, the 

types of contractors (U.S., third country, and local national), and the types 

of contract services provided. The information gathered from these three 

sites, while not generalizable to all AFRICOM sites, provides valuable 

insights about personnel accountability, contractor vetting, and contractor 

employee screening processes in the AFRICOM area of responsibility.

We visited or contacted officials from the following DOD organizations 

during our review:

· Office of the Under Secretary of Defense for Acquisition, Technology 

and Logistics

· Defense Procurement and Acquisition Policy Directorate

· Office of the Under Secretary of Defense for Personnel and 

Readiness

· Office of the Under Secretary of Defense for Intelligence

· Chairman of the Joint Chiefs of Staff

· Joint Staff J-4 (Logistics) Directorate

· AFRICOM Headquarters, Stuttgart, Germany

· AFRICOM J-1 (Personnel) Directorate, Stuttgart, Germany

Page 45 GAO-16-105 Operational Contract Support

Department of Defense
Appendix I: Objectives, Scope, and 

Methodology

· AFRICOM J-2 (Intelligence) Directorate, Stuttgart, Germany

· AFRICOM J-3 (Operations) Directorate, Stuttgart, Germany

· AFRICOM J-4 (Logistics) Directorate, Stuttgart, Germany

· Special Operations Command Africa, Stuttgart, Germany

· Special Operations Forward – Eastern Area, Uganda

· Special Operations Forward – Central Area, Uganda

· Combined Joint Task Force-Horn of Africa

· J-1 (Personnel) Directorate, Camp Lemonnier, Djibouti

· J-2 (Intelligence) Directorate, Camp Lemonnier, Djibouti

· J-3 (Operations) Directorate, Camp Lemonnier, Djibouti

· J-4 (Logistics) Directorate, Camp Lemonnier, Djibouti

· J-5 (Plans) Directorate, Camp Lemonnier, Djibouti

· Contingency Contracting Office, Camp Lemonnier, Djibouti

· U.S. Air Forces in Europe–Air Forces Africa, Ramstein, Germany

· U.S. Air Force 449th Air Expeditionary Group, Camp Lemonnier, 

Djibouti

· 768th Air Expeditionary Squadron at Niamey, Niger

· Contracting Office, Niamey, Niger

· Security Forces and Office of Special Investigations, Niamey, Niger

· Air Force A-1 (Personnel), Niamey, Niger

· Office of the Deputy Chief of Staff, G-4 (Logistics), Washington, D.C.

· U.S. Army Africa, Vicenza, Italy

· G-1 (Personnel) Directorate, Vicenza, Italy

· G-2 (Intelligence) Directorate, Vicenza, Italy

· G-4 (Logistics) Directorate, Vicenza, Italy

· 414th Contract Support Brigade, Vicenza, Italy

· Air Force Office of Special Investigations, Niamey, Niger

· Deputy Assistant Secretary of the Navy – Acquisition and 

Procurement, Washington, D.C.

· U.S. Naval Forces Europe–Africa, Naples, Italy

· Naval Forces Africa N-4 (Logistics) Directorate, Naples, Italy

· Naval Forces Africa N-1 (Personnel) Directorate, Naples, Italy

· Naval Facilities Command Europe, Africa, Southwest Asia, Naples, 

Italy

· Naval Supply Systems Command, Fleet Logistics Center Sigonella, 

Naples, Italy

· U.S. Marine Corps Forces Europe and Africa, Stuttgart, Germany

· Special Purpose Marine Air Ground-Task Force, Uganda

· U.S Naval Camp Lemonnier, Djibouti

Page 46 GAO-16-105 Operational Contract Support

Department of the Air 

Force

Department of the Army

Department of the Navy
Appendix I: Objectives, Scope, and 

Methodology

· N-1 (Personnel), Camp Lemonnier, Djibouti

· Public Works Office/Contracting Office, Camp Lemonnier, Djibouti

· Base Access Control Office, Camp Lemonnier, Djibouti

· Naval Criminal Investigative Services, Camp Lemonnier, Djibouti

· Office of Acquisitions Management, Washington, D.C.

· Office of Logistics Management, Washington, D.C.

· Bureau of African Affairs, Washington, D.C.

· Bureau of Diplomatic Security, Washington, D.C.

· U.S. Embassy, Djibouti, Djibouti

· U.S. Embassy, Niamey, Niger

· U.S. Embassy, Kampala, Uganda

We conducted this performance audit from June 2014 to December 2015 

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.

Page 47 GAO-16-105 Operational Contract Support

Department of State
Appendix II: Comments from the Department 

of Defense

Page 48 GAO-16-105 Operational Contract Support

 

Appendix II: Comments from the Department 

of Defense

GAO sent a draft of this 

report to DOD for 

comment on July 2, 

2015, identified as 

GAO-15-679. GAO 

received DOD’s 

comments on 

November 20, 2015. 

The report number was 

changed to GAO-16-

105 to reflect the 

appropriate fiscal year 

of issuance. 
Appendix II: Comments from the Department 

of Defense

Page 49 GAO-16-105 Operational Contract Support

 
Appendix II: Comments from the Department 

of Defense

Page 50 GAO-16-105 Operational Contract Support

 
Appendix II: Comments from the Department 

of Defense

Page 51 GAO-16-105 Operational Contract Support

 
Appendix III: GAO Contact and Staff 

Acknowledgments

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

In addition to the contact named above, Carole Coffey and James A. 

Reynolds, Assistant Directors; Gregory Hellman; Courtney Reid; Michael 

Shaughnessy; Michael Silver; Amie Steele; Cheryl Weissman; and 

Amanda Weldon made key contributions to this report.

Page 52 GAO-16-105 Operational Contract Support

 

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Appendix IV: Accessible Data

Data Table for Figure 1: Value Associated with DOD Contracts in U.S. Africa 

Page 53 GAO-16-105 Operational Contract Support

 

Command Area of Responsibility, Fiscal Years 2009-2014

2009 2010 2011 2012 2013 2014

North Africa 1.468 31.484 76.63 28.238 57.906 12.626

Central Africa 14.248 17.489 21.435 73.691 63.651 32.787

East Africa 101.81 83.568 398.578 408.018 503.739 332.835

West Africa 14 27.955 46.342 24.284 23.147 71.73

Southern Africa 15.265 0 51.145 47.98 14.708 12.528

HEADQUARTERS

UNITED STATES AFRICA COMMAND

Unit 29951

APO AE 09751

J1/8

MEMORANDUM FOR Defense Capabilities Management (Attn: Cary 

Russell, Director), U.S. Government Accountability Office, 441 G Street 

NW, Washington DC 20548

SUBJECT: Department of Defense (DoD) response to the Government 

Accountability Office (GAO) Draft Report, GA0-15-179

1. This is the DoD response to the GAO Draft Report, GA0-15-179, 

'OPERATIONAL CONTRACT SUPPORT: Additional Actions Needed 

To Manage, Account For, and Vet Defense Contractors in Africa," 

dated July 2, 2015 (GAO Code 351933)." Detailed comments on the 

rep011 recommendations are enclosed.

Appendix IV: Accessible Data

Data Tables

Agency Comment 

Letter

Text of Appendix II: 

Comments from the 

Department of Defense

Page 1
Appendix IV: Accessible Data

2. The U.S. Africa Command (USAFRICOM) concurs or partially concurs 

with GAO recommendations one, two, three, and seven. 

USAFRICOM non-concurs with recommendation five since the 

Command is already addressing the issue identified in the GAO 

recommendation: AOR-wide contractor pers01mel accountability. This 

DoD response reflects the Director, Joint Staff's concurrence to 

recommendations four and six.

3. Should you have any questions or require clarification, please contact 

MAJ Shaalim David at Shaalim.h.david.mil@mail.mil or telephone at 

+49-711-729-2826

ROBERT M. MAXWELL, SES

Director of Resources (J1/8)

Enclosure:

DoD response to GAO Draft Report

GAO DRAFT IU PORT DATED, JULY 2, 2015 GA0-15-679 (GAO CODE 

351933)

''OPERATIONAL CONTRACT SUPPORT: ADDITIONAL ACTIONS 

NEEDED TO MANAGE, ACCOUNT FOR, AND VET DEFENSE 

CONTRACTORS IN AFRICA"

DEPARTMENT OF DEFENSE COMMENTS TO THE GAO 

RECOMMENDATION

RECOMMENDATION 1: The GAO recommends that AFR I COM direct 

its service components to designate elements within their respective 

staffs to be responsible for coordinating OCS, and consider the 

establishment of an OCS Integration Cell or similar structure with these 

dedicated OCS personnel, as needed.

USAFRICOM RESPONSE: Partially concur.

COMMENTS: Establishment of an OCS Integration Cell (OCSIC) at the 

Geographic Combatant Command and, when formed, at the subordinate 

joint force command level (JFC) is not only appropriate, but also 

necessary to ensure OCS-related matters arc synchronized and 

optimized to support the mission. Although there are clear advantages 

and benefits to establishing an OCSIC al service-component level, there 

Page 54 GAO-16-105 Operational Contract Support

 

Page 2
Appendix IV: Accessible Data

exists no doctrinal requirements for service components to do so. 

However, USAFRICOM is currently assessing its Subordinate Commands 

OCS structures to determine the best way forward, including its inherent 

authority to direct Subordinate Commands to establish their respective 

OCSIC. Absent an established OCSIC or dedicated OCS personnel, OCS 

planning and coordination would defer to assigned logistics planners.

RECOMMENDATION 2: The GAO recommends that AFRICOM clarity 

under what conditions a subordinate joint force command, such as 

Combined Joint Task Force-Horn of Africa, should establish an OCS 

Integration Cell.

USAFIUCOM RESPONSE: Concur.

COMMENTS: All USAFRICOM subordinate joint force commands should 

establish an OCSIC. A USAFRICOM staff assistance visit of CJTP-HOA 

is scheduled for the third quarter of FY 2015 to assess and develop plan 

for establishment of an OCSIC.

RECOMMENDATION 3: The GAO recommends that the AFR ICOM 

clarity the scorecard process, including assessment standards, for OCS 

Readiness Scorecards to ensure that evaluators can accurately assess 

subordinate commands' OCS capabilities.

USAFRICOM RESPONSE: Partially concur.

COMMENTS: OCS Readiness Scorecard assessment standards have 

been sent to the subordinate commands for feedback/comments. The 

OCS readiness scorecard, however, is not designed to replace the 

Defense Readiness Reporting System (DRRS) to report on OCS. The 

OCS scorecard was a Command initiative, subject to continuous 

improvement, to drive 

discussion, tell USAFRICOM story, and highlight areas requiring focused 

efforts. In fact, when this initiative was brought to the attention of the 

GAO auditors, the preliminary feedback from the latter was that the OCS 

readiness scorecard may be considered a "benchmark" or a "best 

practice" in OCS execution.

RECOMMENDATION 4: The GAO recommends that the Secretary of 

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

direct Joint Staff to clarify what types of contractor personnel to account 

Page 55 GAO-16-105 Operational Contract Support

 

for in its guidance on personnel status reports.

Page 3
Appendix IV: Accessible Data

USAFRICOM RESPONSE: Concur.

COMMENTS: The CJCSM 3150. I JC, Joint Personnel Reporting 

Structure-Personnel Manual, provides policy and guidance on what types 

of contractor personnel to account for in personnel status reports. 

However, additional training and amplifying local procedures issued by 

the USAFRICOM J-1 may be necessary to Cully implement its provisions 

and ensure consistent interpretation. While USAFRICOM J-1 issuance of 

a coordinated directive on local policies, procedures and standards would 

mitigate many of the interpretation issues, lessons from USAFRICOM's 

implementation of the policy will be incorporated into the next update of 

the CJCSM 3150.13C.

RECOMMENDATION 5: The GAO recommends that the Secretary of 

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

direct AFRICOM to develop area of responsibility-wide contractor 

personnel accountability guidance on or before December 2015, when 

the current guidance expires, that clarifies which types or contractor 

personnel should be accounted for using SPOT and when SPOT 

accountability requirements should be incorporated into contracts.

USAFRICOM RESPONSE: Non-concur.

COMMENTS: There is no requirement for the Secretary of Defense to 

direct AFRICOM to develop area of responsibility-wide contractor 

personnel accountability guidance on or before December 2015. A draft 

Synchronized Pre-deployment and Operational Tracker (SPOT) Defense 

Federal Acquisition Regulation Supplement (DFARS) deviation clause for 

USAFRlCOM area of responsibility-wide contractor personnel 

accountability is already being coordinated with the respective 

USAFRICOM staff and subordinate commands via the Task Management 

Tool (TMT) System. After USAFRICOM/subordinate staff coordination, 

the draft SPOT DFARS deviation clause will be submitted lo 

OSD/Defense Procurement and Acquisition Policy (DPAP) for review and 

approval. USAFRICOM expects the SPOT DFARS deviation clause to be 

approved and published before Dec 2015.

RECOMMENDATION 6: The GAO recommends that the Secretary of 

Defense, in coordination with the Chairman of the Joint Chiefs or Stan 

develop guidance that clarifies the conditions under which combatant 

commands should have a foreign vendor vetting process or cell in place 

to determine whether potential vendors actively support any terrorist, 

criminal, or other sanctioned organizations, including clarifying when 

Page 56 GAO-16-105 Operational Contract Support

 
Appendix IV: Accessible Data

combatant commands should develop procedures for transmitting the 

names of any vendors identified through this process

for inclusion in prohibited entities lists in the appropriate federal 

contracting databases, such as the System for Award Management.

USAFRICOM RESPONSE: Concur.

COMMENTS: The OSD has established a joint working group to identity 

key stakeholders and develop DoD policy requiring CCMDs to develop 

foreign vendor vetting processes.

RECOMMENDATION 7: The GAO recommends that AFRICOM continue 

to complete and issue guidance that specifics the standard of contractor 

employee screening for forward operating sites, based on factors such as

the number of DOD personnel on base, type of operations, and local 

security threat.

USAFRICOM RESPONSE: Concur.

COMMENTS: AFRICOM has completed the staffing of their existing 

"DRAFT" Instruction which is currently with the Chief of Staff awaiting 

signature. This Instruction will provide guidance and specify the standards 

for Contractor employee screening for forward operating sites in the AOR. 

The guidance includes a risk-based approach to Contractor employee 

screening based on applicable mitigating factors that include type of

contractor (US or non-US), type of operations, and local security threat.

Page 57 GAO-16-105 Operational Contract Support

 

Page 4
Page 58 GAO-16-105 Operational Contract Support

Operational Contract Support: Actions Needed to Enhance the Collection, 

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

D.C.: March 16, 2015.

Contingency Contracting: Contractor Personnel Tracking System Needs 

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

18, 2015.

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

11, 2015.

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

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

May 19, 2014.

Warfighter Support: DOD Needs Additional Steps to Fully Integrate 

Operational Contract Support into Contingency Planning. 

GAO-13-212.Washington, D.C.: February 8, 2013.

Operational Contract Support: Management and Oversight Improvements 

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

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

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

Warfighter Support: Cultural Change Needed to Improve How DOD Plans 

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

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

Warfighter Support: DOD Needs to Improve Its Planning for Using 

Contractors to Support Future Military Operations. 

GAO-10-472.Washington, D.C.: March 30, 2010.

Contingency Contract Management: DOD Needs to Develop and Finalize 

Background Screening and Other Standards for Private Security 

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

Military Operations: DOD Needs to Address Contract Oversight and 

Quality Assurance Issues for Contracts Used to Support Contingency 

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

Military Operations: Background Screenings of Contractor Employees 

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

Related GAO Products
Page 59 GAO-16-105 Operational Contract Support

Forces Take Steps to Mitigate the Risk Contractors May Pose.

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

(351933)
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