ARMORED 

COMMERCIAL 

VEHICLES

DOD Has 

Procurement 

Guidance, but Army 

Could Take Actions to 

Enhance Inspections 

and Oversight

Report to the Committee on Armed 

Services, House of Representatives

June 2017

GAO-17-513

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-513, a report to the 

Committee on Armed Services, House of 

Representatives

June 2017

ARMORED COMMERCIAL VEHICLES

DOD Has Procurement Guidance, but Army 

Could Take Actions to Enhance Inspections 

and Oversight

What GAO Found

The Department of Defense (DOD) and the defense components in GAO’s 

review—Army, Navy, Air Force, Marine Corps, and Defense Intelligence Agency, 

the largest buyer of armored commercial passenger-carrying vehicles (ACPV) in 

DOD—have a plethora of guidance related to ACPV procurement. This guidance 

is similar to that used by the Department of State, which also procures a large 

number of these vehicles (see figure). DOD officials GAO spoke with cited the 

Federal Acquisition Regulation as the capstone guidance for procurement 

activities. For DOD, guidance also exists department-wide and at the individual 

component levels. Guidance covers numerous aspects of ACPV acquisitions, 

including procurement methods, protection levels, inspection and acceptance, 

warranties, and oversight. 

Armored Commercial Passenger-Carrying Vehicle (left) Compared to Tactical Vehicle (right).

ACPV-related contract actions for the selected DOD components generally 

complied with guidance, policies, and procedures for ensuring the safety and 

quality of ACPVs and included contract language that met minimum armoring 

standards. However, opportunities exist for the Army to improve its processes for 

in-progress inspections—inspections that occur as the vehicle is being 

armored—as the Army instead depended primarily on the vendors’ quality 

control processes. GAO’s review of contract actions used to procure ACPVs for 

selected DOD components between 2011 and 2015 showed that in-progress 

inspections were conducted, with the exception of the Army, which conducted 

such inspections for only a single contract action. Without in-progress

inspections, the Army is accepting risk in the safety of its vehicles. Further, with 

the exception of the Army, all the DOD components have a central office and 

mechanisms for reporting ACPV information. This decentralized approach leaves 

the Army with an incomplete picture of various ACPV-related matters, including 

procurement and inspection methods. Federal standards for internal control call 

for mechanisms that allow for oversight intended to help an organization, such as 

the Army, ensure compliance with armoring and inspection standards. Without a 

designated central point of contact, the Army may face challenges for reporting 

ACPV information to DOD officials responsible for overseeing the implementation 

of armoring and inspection standards department-wide.

View GAO-17-513. For more information, 

contact Marie A. Mak at (202) 512-4841 or 

makm@gao.gov. 

Why GAO Did This Study

DOD uses armored military vehicles for 

combat and operational support, but it 

also uses armored commercial 

vehicles to transport military and 

civilian personnel in areas that pose a 

threat to their safety. These vehicles 

differ in many ways, including mission 

and appearance. 

The House Armed Services Committee 

report accompanying the National 

Defense Authorization Act for Fiscal 

Year 2017 contained a provision for

GAO to assess multiple aspects of 

DOD’s procurement practices for 

ACPVs. This report assesses (1) 

DOD’s guidance and procedures for 

acquiring ACPVs and how they 

compare with those at the Department 

of State; and (2) the extent to which 

selected DOD components adhere to 

guidance and procedures for ensuring 

the safety and quality of ACPVs.

To conduct this work, GAO analyzed 

policies, procedures, and regulations 

that govern aspects of acquiring, 

armoring, inspecting, and managing 

ACPVs; interviewed DOD and State 

Department officials; and compared 

armoring standards DOD 

components—Army, Navy, Marine 

Corps, and Defense Intelligence 

Agency—use for ACPVs against 

minimally acceptable protection 

standards. GAO reviewed contract 

actions for selected DOD components 

between 2011 and 2015.

What GAO Recommends

The Secretary of Defense should 

require the Army to conduct inprogress inspections and designate a

central point of contact for ACPV 

information. DOD concurred with the 

recommendations.
Page i GAO-17-513 Armored Commercial Vehicles

Letter 1

Background 3

The Departments of Defense and State Have Similar Guidance for 

ACPV Procurement 4

Selected DOD Components Complied with ACPV Guidance, but 

the Army Did Not Consistently Conduct In-Progress Inspections 10

Conclusions 19

Recommendations for Executive Action 19

Agency Comments 19

Appendix I Objectives, Scope, and Methodology 21

Appendix II Comments from the Department of Defense 23

Appendix III GAO Contact and Staff Acknowledgments 25

Tables

Table 1: DOD Components and Associated ACPV ComponentLevel Policy 9

Table 2: Procurement Methods Used by DOD Components in our 

Review 11

Figure

Figure 1: Typical Armored Commercial Passenger-Carrying 

Vehicle (left) Compared with Tactical Vehicle (right) 4

Contents
Page ii GAO-17-513 Armored Commercial Vehicles

Abbreviations

ACPV Armored commercial passenger-carrying vehicle

DIA Defense Intelligence Agency

DOD Department of Defense

DODI Department of Defense Instruction

FAR Federal Acquisition Regulation

GSA General Services Administration

OSD Office of the Secretary of Defense

State Department of State

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

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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Page 1 GAO-17-513 Armored Commercial Vehicles

441 G St. N.W.

Washington, DC 20548

June 9, 2017

The Honorable Mac Thornberry

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

While the Department of Defense (DOD) uses armored military vehicles 

that serve in either a combat capacity or for operational support, it also 

has a need for armored commercial vehicles to transport high-risk DOD 

military and civilian personnel into areas that pose a threat to their safety. 

According to a DOD instruction, the passengers are considered high-risk 

by virtue of their rank or grade, assignment, symbolic value, relative 

isolation, or mission, which are factors that make them attractive targets 

to hostile entities. Modified commercial vehicles provide these 

passengers with transportation that is less conspicuous than traditional 

armored military vehicles while still allowing for protective armoring. Due 

to the commercial nature and critical role of these vehicles, DOD is 

subject to specific instructions and policies related to armoring and 

oversight of these vehicles.1

The Federal Acquisition Regulation (FAR) outlines the procedures to be 

used by DOD for acquiring armored commercial passenger-carrying 

vehicles (ACPVs). Procurement of these vehicles can occur through 

direct purchase from a commercial manufacturer, the General Services 

Administration (GSA) Schedules Program, and through other agencies, 

such as the Department of State (State), which procures large numbers of 

these vehicles.2 The House Armed Services Committee report 

accompanying the National Defense Authorization Act for Fiscal Year 

2017 contained a provision for us to assess multiple aspects of DOD’s 

procurement practices for ACPVs.3 This report assesses (1) DOD’s 

 1

Department of Defense Instruction C-4500.51, DOD Commercially Procured and Leased 

Armored Vehicle Policy (July 25, 2007). (Hereinafter referred to as DODI C-4500.51 (July 

25, 2007)).

2

GSA’s Schedules Program provides federal agencies with a simplified process for 

obtaining commercial supplies and services at prices associated with volume buying.

3

H.R. Rep. No. 114-537, at 136-37 (2016).

Letter
Page 2 GAO-17-513 Armored Commercial Vehicles

guidance and procedures for acquiring ACPVs and how they compare 

with those at State; and (2) the extent to which selected DOD 

components adhere to guidance, policy, and procedures for ensuring the 

safety and quality of ACPVs.

To assess the guidance and procedures that apply to DOD’s acquisition 

of ACPVs, we analyzed applicable regulations for procuring, armoring, 

inspecting, and managing ACPVs. We also reviewed DOD-specific 

guidance and procedures used across DOD components, compared them 

against those utilized within State, and identified any differences.

To assess DOD’s adherence to guidance, policy, and procedures, we 

conducted contract file reviews for contract actions that selected DOD 

components—specifically the Army, Navy, Marine Corps, and the 

Defense Intelligence Agency (DIA), the largest procurer of these vehicles 

for use overseas—used to acquire ACPVs between 2011 and 2015. We 

selected this time frame to cover from when DOD stopped reporting 

information on ACPVs to Congress to the most recently available 

information at the time of our review. We collected contract file 

information for selected contract actions identified by DOD for procuring 

armored commercial sedans, trucks, and sport utility vehicles during that 

time frame. For our contract file reviews, we obtained and analyzed presolicitation materials, statements of work, contracts, inspection reports, 

and other documents contained in the files. We excluded some details 

regarding certain contract actions from this report because they are 

classified. In addition, we searched the federal procurement database in 

order to identify any instances where separate contracts were executed to 

correct any deficiencies that were discovered after vehicles were fielded. 

We interviewed DOD and State officials to discuss acquisition and 

inspection procedures and how they ensure compliance with their 

established regulations and policies. We also evaluated alternative 

armoring standards referenced in many of the contracting files against the 

minimum armoring specifications for ACPVs outlined in the Department of 

Defense Instruction (DODI) C-4500.51, dated July 2007, the relevant 

instruction for the timeframe we assessed. Details regarding DOD’s 

minimum ballistic and blast specifications are classified. Appendix I 

contains more detail on our objectives, scope, and methodology.

We conducted this performance audit from May 2016 to June 2017 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 
Page 3 GAO-17-513 Armored Commercial Vehicles

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

ACPVs are non-tactical vehicles, or vehicles not used in combat

operations, that can be lightly or heavily armored. The level of armoring 

depends on the expected threat. Both light and heavy armored vehicles 

provide 360 degree protection of the passenger compartment against 

ballistic threats, with commercial light armored vehicles providing slightly 

less protection than commercial heavy armored vehicles. Both variants 

are intended to transport American citizens and service members, as well 

as other passengers, in and around dangerous areas. ACPVs are 

extensively modified from commercially available sedans, trucks, or sport 

utility vehicles as they are intended to be inconspicuous and blend in with 

local traffic.

ACPVs differ from traditional DOD military armored vehicles in various 

ways. First of all, traditional military armored vehicles are designed with 

military applications in mind, and typically the armor is integral to the 

design and construction. That is not the case with ACPVs, which are 

initially built for commercial markets and later disassembled, armored, 

and reassembled. Secondly, military armored vehicles are acquired 

through major defense acquisition programs while ACPVs are not. The 

guidance and regulation associated with major defense acquisition 

programs is generally not applicable to ACPVs. Moreover, an ACPV is 

considered a modified commercial item in that it is an item customarily 

used by the general public, except for modifications (armoring) made to 

meet the government’s requirements.4 Therefore, ACPVs are not subject 

to the developmental and operational testing required of major defense 

acquisition programs, although material and acceptance testing for 

functionality, armor certification, and roadworthiness is to occur.

Figure 1 presents a comparative illustration between a typical ACPV and 

a typical military armored vehicle.

 4

Federal Acquisition Regulation (FAR) § 2.101.

Background
Page 4 GAO-17-513 Armored Commercial Vehicles

Figure 1: Typical Armored Commercial Passenger-Carrying Vehicle (left) Compared with Tactical Vehicle (right)

To meet its need for ACPVs, DOD components can procure vehicles 

through a variety of means. According to officials from the DOD 

components in our review —the Army, Air Force, Navy, Marine Corps, 

and the DIA—DOD components procured more than 410 ACPVs from 

2011 through 2015. Due to corroborating documentation being 

unavailable in a few cases, we were unable to adequately verify the exact 

total number of vehicles. Appendix I provides additional details on this 

limitation. Due to classification concerns, we do not identify procurement 

quantities at the individual component level.

DOD and its components—Army, Navy, Air Force, Marine Corps, and 

Defense Intelligence Agency, the largest buyer of ACPVs in DOD—are 

subject to a plethora of guidance related to the procurement of ACPVs, 

much of which is similar—and, in most cases, identical—to that used by 

State. For DOD, that guidance exists at the overall federal level, the 

department level, and the individual component level. State follows 

guidance that exists at both the federal level and the department level. 

For both agencies, the guidance covers key aspects of ACPV 

acquisitions, including procurement methods, protection levels, vendor 

clearances, inspection and acceptance, warranties, and fleet oversight.

The Departments of 

Defense and State 

Have Similar 

Guidance for ACPV 

Procurement
Page 5 GAO-17-513 Armored Commercial Vehicles

Agency officials at State and DOD components cited the FAR as the 

capstone guidance for their procurement activities. At the DOD level, in 

2007, the Undersecretary of Defense for Policy, issued DOD Instruction 

C-4500.51, DOD Commercially Procured and Leased Armored Vehicle 

Policy.5 The department delegates much of the responsibilities for ACPV 

procurement to the components. In addition to the FAR, State follows its 

own guidance, which includes the Foreign Affairs Manual and Foreign 

Affairs Handbook on ACPV procurement, inspection, and fleet 

management.

Multiple methods exist for the procurement of ACPVs, including 

standalone contracts negotiated directly with a vendor, purchases from 

the GSA Multiple Award Schedule Program, interagency acquisitions, and 

no-cost transfers from other agencies with excess property. The four 

methods used for procurement are described in more detail below.

• Direct Contracts with Vendors: Since ACPVs are modified commercial 

items, agencies can utilize streamlined procedures for solicitation and 

evaluation, provided under the FAR.6 With this approach, the agency 

issues a request for proposals. Vendors respond with their pricing, 

armor certifications, delivery schedules, warranty information, and any 

other information required. The agency then evaluates the offerors’

proposals and makes an award.

• Use of General Services Administration Schedules Program: ACPVs 

can be procured from GSA’s Multiple Award Schedule program.7 This 

program provides federal agencies with a simplified process for 

obtaining commercial supplies and services at prices associated with 

volume buying. In these cases, the GSA has prequalified and 

awarded indefinite delivery/indefinite quantity contracts—contracts 

that provide for an indefinite quantity, within stated limits, for a fixed 

time—to a number of vendors, and agencies can place orders against 

those contracts to meet their needs.

 5

In May 2017, while our draft report was with DOD for review, DOD cancelled this 

instruction; however, it was applicable during the timeframe we examined for this report—

2011 to 2015.

6

FAR Subpart 12.6.

7

FAR Subpart 8.4.

Acquisition Regulations 

Allow Multiple Methods for 

DOD and State 

Procurement of ACPVs
Page 6 GAO-17-513 Armored Commercial Vehicles

• Interagency Acquisitions: An interagency acquisition takes place when 

an agency that needs supplies or services obtains them from another 

agency. The Economy Act of 1932, as implemented in the FAR, 

provides general authority for federal agencies to undertake 

interagency acquisitions when a more specific statutory authority does 

not exist.8 Interagency acquisitions under the Economy Act can save 

the government duplicative effort and costs when appropriately used 

and leverage the government’s buying power. In doing so, the 

acquiring agency can convey responsibility for several aspects of the 

procurement to a separate agency that is better poised to execute the 

acquisition.

• Excess Personal Property Transfers: In some cases, an agency may 

have excess inventory and can transfer ACPVs at no cost to the 

acquiring agency, thus avoiding the procurement process altogether 

and, in a sense, resulting in savings by the acquiring entity. The FAR 

states that agencies whose property is transferred to other agencies 

shall not be reimbursed for the property in any manner.

DOD has outlined minimum blast and ballistic armoring requirements for 

protection against explosives and firearms, respectively, for ACPVs in 

DODI C-4500.51, but the detailed armoring specifications outlined in the 

instruction are classified.9 Generally, the specifications detail the 

minimum ballistic and blast protection standards that must be satisfied by 

all DOD ACPVs, whether they are light or heavy armored vehicles. State 

also has a classified policy that outlines armoring specifications for the 

ACPVs it procures for use in locations around the world.

The FAR contains provisions for safeguarding classified information that 

apply to all federal agencies procuring goods and services, including 

DOD and State. While neither DOD nor State policies for ACPVs directly 

address vendor clearances, both agencies must comply with the FAR.

Depending on the armoring specifications cited in the contract, a vendor 

supplying ACPVs to the government may require access to classified 

information. To accommodate such cases, Executive Order 12829 

created the National Industrial Security Program, for which the Secretary 

 8

31 U.S.C. § 1535; FAR § 17.502-2.

9

DOD-I C-4500.51 (July 25, 2007).

DOD and State Each 

Have Armoring Standards

Both DOD and State Are 

Subject to FAR Provisions 

for Vendor Clearances
Page 7 GAO-17-513 Armored Commercial Vehicles

of Defense is the executive agent, to safeguard classified information 

released to contractors. To implement the order, DOD issued the National 

Industrial Security Program Operating Manual to prescribe requirements, 

restrictions, and other safeguards necessary to prevent unauthorized 

disclosure of classified information and to control authorized disclosure of 

classified information released by executive branch departments and 

agencies to their contractors.10

The FAR requires a security requirements clause when the contract may 

require access to classified information.11 The clause requires the 

contractor to comply with the requirements identified in the National 

Industrial Security Program Operating Manual. In addition, as part of the 

process of obtaining a facility clearance, a contractor must sign a DOD 

Security Agreement, which documents the security responsibilities of both 

the contractor and the government in accordance with the requirements 

of the manual.

As a part of this program, Defense Security Services within DOD 

administers and implements the defense portion of the National Industrial 

Security Program. Defense Security Services serves as the interface 

between the government and “cleared industry” and maintains a database 

of contractors that have valid, current facility clearances that allow for the 

safeguarding of classified material.12

While the July 2007 DODI C-4500.51 does not contain any specific 

instructions requiring ACPV inspection and acceptance procedures, it 

does state that DOD component heads shall ensure that the vehicles 

comply with armoring standards and existing acquisition regulations and 

specifically mentions the FAR. State’s ACPV policy is similar to the DODI 

with respect to inspections, but State is also required to comply with FAR.

The FAR provides that agencies shall ensure that contracts include 

inspection and other quality requirements that are determined necessary 

 10Department of Defense Manual 5220.22-M, National Industrial Security Program 

Operating Manual (Feb. 28, 2006, incorp. ch. 2, May 18, 2016). 

11FAR §§ 4.404, 52.204-2.

12Department of Defense Instruction 5220.22, National Industrial Security Program Encl. 

2, para. 2 (Mar. 18, 2011).

Both DOD and State Are 

Subject to FAR Provisions 

for Inspection and 

Acceptance
Page 8 GAO-17-513 Armored Commercial Vehicles

to protect the government’s interest.13 The regulation goes on to state that 

commercial item contracts shall rely on a contractor’s existing quality 

assurance system as a substitute for compliance with government 

inspection and testing before items are provided for acceptance, unless 

customary market practices for the commercial item being acquired 

permit in-progress inspection. The FAR contains additional language that 

provides the contracting officer with discretion in determining the type and 

extent of contract quality requirements, which could include additional 

inspections. In particular, the FAR states that the government shall not 

rely on inspection by the contractor if the contracting officer determines 

that the government has a need to test the supplies prior to acceptance, 

and, in making that determination, the FAR directs the contracting officer 

to consider, among other things, the nature of the supplies and services 

being acquired, their intended uses, and the potential losses in the event 

of defects.

Similar to the areas outlined above, the DODI C-4500.51does not contain 

any specific language requiring warranties for ACPV procurements, but it 

states the vehicles shall be procured in accordance with the FAR. 

Likewise, State’s armored vehicle policy does not include specific 

references to warranties. However, State is bound by the FAR.

The FAR states that the use of warranties is not mandatory.14 However, 

the FAR sets forth criteria that contracting officers shall consider when 

deciding whether a warranty is appropriate. These factors include, but are 

not limited to, complexity and function, the item’s end use, difficulty of 

detecting defects before acceptance, and potential harm to the 

government if the item is defective. The FAR also offers suggested terms 

and conditions that contracting officers may incorporate into contracts. 

For example, in the event defects are discovered, the government may 

obtain an equitable adjustment of the contract or direct the contractor to 

repair or replace the defective item at the contractor’s expense.

 13FAR § 46.102(a).

14FAR § 46.703. We note that FAR § 12.404(b) provides, in a commercial item 

procurement, that the contracting officer, to the maximum extent practicable, require 

vendors to offer the government at least the same warranty terms offered to the general 

public in customary commercial practice. 

FAR Provisions for 

Warranties Govern Both 

DOD and State
Page 9 GAO-17-513 Armored Commercial Vehicles

The DODI C-4500.51 outlines a number of responsibilities for different 

DOD officials that relate to ACPV fleet management and, ultimately, 

oversight. In particular, the instruction establishes that an assistant 

secretary within the Under Secretary of Defense, Policy, shall be the 

principal individual responsible for collecting and reporting information 

specific to DOD’s ACPV fleet. Part of that reporting includes providing 

ACPV-related information to Congress. State policy includes similar 

provisions for ACPV management and oversight.

While DOD and the components have developed policies and procedures 

for managing their non-tactical vehicle fleets, the language contained in 

those instructions often defers to DODI C-4500.51 for specific ACPV 

guidance. Table 1 identifies the different component-level policies that 

exist for ACPVs, a brief description, and whether there is a particular 

office within the component for ACPV-related matters.

Table 1: DOD Components and Associated ACPV Component-Level Policy

Component Component-level policy Policy description Designated office for 

ACPVs?

Army U.S. Army, Army Regulation 58-1. Motor 

Transportation—General: Management, 

Acquisition, and Use of Motor Vehicles (June 

12, 2014)

This regulation for managing motor 

vehicles includes comprehensive 

instructions for management, acquisition, 

and use of non-tactical vehicles. In the 

case of ACPVs, it defers to policy, 

procedures, and reporting requirements 

of DODI C-4500.51.

Yes, although Army 

officials stated that 

oversight of procurement 

is limited

Navy Department of the Navy, Navy Antiterrorism 

(AT) Program, OPNAV Instruction 3300.53B 

(Washington, D.C.: Nov. 28, 2007)

This instruction outlines non-tactical 

armored vehicle policies and procedures, 

references DODI C-4500.51, and 

includes similar language for reporting to 

DOD.

Yes

Air Force U.S. Air Force, Office of Special Investigations, 

Armored Vehicle Program, AFOSI Manual 71-

115 (July 18, 2014)

This manual implements DODI C4500.51 and presents Air Force-specific 

guidance for commercial armored 

vehicles. It provides the roles and 

responsibilities of various offices having 

input to the development of 

requirements, budgeting, and fielding of 

ACPVs.

Yes

DIA Defense Intelligence Agency, Standard 

Operating Procedure: Acquisition and 

Deployment of Non-Armored and Armored 

Vehicles, SOP Number LOG/16-13, 007 (Feb 5, 

2016)

This document outlines responsibilities 

and procedures for multiple aspects of 

armored vehicle procurement and 

includes a reference to DODI C-4500.51.

Yes

DOD Policy Identifies 

Roles for ACPV Fleet 

Oversight
Page 10 GAO-17-513 Armored Commercial Vehicles

Component Component-level policy Policy description Designated office for 

ACPVs?

Marine Corps Memorandum of Agreement Between the U.S. 

Department of State and the United States 

Marine Corps (June 28, 2013).

This memorandum of agreement is for 

the operation and administration of the 

Marine Security Guard Program and 

outlines procedures for ACPV 

replacement.

Yes

Source: DOD and State Department (data), GAO (analysis and presentation). | GAO-17-513

Similar to the instructions and manuals used by the DOD components, 

State’s Foreign Affairs Manual outlines roles and responsibilities for its 

armored vehicle program.15 Other policies and procedures are 

incorporated by reference in these manuals for items such as armoring 

standards, vehicle procurement, assignments (i.e., locations), 

maintenance, and disposal. This guidance also assigns a single State 

entity—the Bureau of Diplomatic Security—as having overarching 

responsibility for the armored vehicle program.

Selected DOD components in our review complied with guidance for the 

procurement and inspection of ACPVs for the contracts we reviewed. 

Further, we found evidence of in-progress inspections of DOD’s ACPVs, 

although the Army conducted such inspections for only a single contract 

action. DOD utilized the four procurement methods described above for 

acquiring the vehicles, all of which are allowable under the FAR. The 

blast and ballistic armoring standards referenced in the contract actions 

we reviewed satisfy the levels of protection required under DODI C4500.51. For classified contract actions, vendor security clearances were 

requested and verified. All the contract actions reviewed had similar 

warranty provisions and generally reflected what is stated in the FAR. We 

found no evidence of contracts for correcting armoring deficiencies after 

delivery. The contracts we reviewed generally included FAR-based 

language for inspections and acceptance and in-progress inspections. 

Further, due to implementation of Office of the Secretary of Defense 

(OSD) efficiency initiatives, DOD components no longer report ACPV 

information to the OSD, as required by DODI C-4500.51. Moreover, the 

Army has no central office with complete oversight of contracting and fleet 

management activities or that maintains all relevant ACPV-specific 

information.

 15Department of State, Foreign Affairs Manual: Armored Vehicle Program, 12 FAM 380 

(July 18, 2012). 

Selected DOD 

Components 

Complied with ACPV 

Guidance, but the 

Army Did Not 

Consistently Conduct 

In-Progress 

Inspections
Page 11 GAO-17-513 Armored Commercial Vehicles

In accordance with allowable FAR provisions, DOD components in our 

review utilized four procurement methods to acquire ACPVs between 

2011 and 2015. Specifically, the components used direct contracts with

vendors, GSA multiple award schedules, interagency acquisitions, and 

excess personal property transfers to acquire the vehicles. According to 

DOD officials, DOD components consider multiple factors in deciding how 

to procure ACPVs and meet armoring requirements, including the 

quantity of ACPVs needed, the components’ expertise in procuring the 

vehicles, the components’ technical specifications, and the urgency of the 

requirement. Table 2 presents the DOD components included in our 

review and the four methods they used to procure ACPVs.

Table 2: Procurement Methods Used by DOD Components in our Review

Direct contracts 

with vendors

GSA Multiple 

Award Schedule 

Program

Interagency 

acquisitions

Excess 

personal 

property 

transfer

Army Yes Yes No No

Navy No No Yes No

Marine Corpsa No No Yes No

Defense 

Intelligence 

Agency

Yes Yes No Yes

Source: DOD (data), GAO (analysis and presentation). | GAO-17-513

a

State officials stated the Marine Corps may have also received ACPVs as excess personal property 

transfers but were unable to provide corroborating documentation.

• The Army and DIA awarded contracts directly to vendors, as well as 

placing orders under GSA’s Multiple Award Schedule Program. 

According to DOD officials, one DOD component contracted with a 

vendor who subcontracted the armoring work; in this type of 

arrangement, the subcontractor is generally referred to as a thirdparty armorer.

• The Navy and Marine Corps used interagency acquisitions pursuant 

to the Economy Act whereby State ordered ACPVs on their behalf 

using State contract vehicles. Marine Corps and Navy officials stated 

that, by doing so, they abdicated all procurement responsibilities to 

State. This approach also allowed these components to leverage 

State’s volume purchasing power, which, according to a Navy official, 

resulted in cost savings for ACPVs.

All Four Methods Were 

Utilized for Procurement of 

ACPVs
Page 12 GAO-17-513 Armored Commercial Vehicles

• DIA received some ACPVs as transfers from State’s and another 

agency’s excess property. State officials stated that Marine Corps 

may also have received some ACPVs as excess property from State’s 

inventory but were unable to provide corresponding documentation. 

We saw no evidence of fund transfers as the ACPVs were transferred 

free of charge to DIA, in compliance with the FAR.16

While the contract actions we reviewed generally did not explicitly 

reference the DODI C-4500.51 armoring specifications, they did reference 

other standards that were similar in most respects to those specifications, 

which allowed them to avoid creating a classified contract. These 

included standards from State, the North Atlantic Treaty Organization 

Standardization Agency, and the European Committee for 

Standardization. These standards are similar to the DODI armoring 

specifications in many respects, but the North Atlantic Treaty 

Organization standards and the European Standards are unclassified.

The three armoring specifications that were most frequently referenced in 

the contract actions we reviewed included State standards, North Atlantic 

Treaty Organization standards, and European standards.17 In cases 

where the contract documentation referred to standards that did not 

satisfy the minimum armoring specifications outlined in the DODI C4500.51, there was supplemental language in the contract that 

compensated for the differences. The North Atlantic Treaty Organization 

standards contained ballistic and blast specifications similar to the DODI 

C-4500.51, while the European standards cover only ballistic armoring 

specifications. Any additional details regarding the differences between 

the standards are classified.

DOD is currently updating its criteria with regards to armoring standards 

pursuant to findings and proposed steps contained in an August 2015 

DOD report on ACPVs.18 The DOD report stated that the department

should regularly review and update armoring specifications. The 

 16FAR § 45.602-4.

17While we did notice slight differences in the ballistic specifications, a DIA official 

characterized the differences as immaterial.

18Department of Defense, Office of the Under Secretary of Defense for Acquisition, 

Technology, and Logistics, Report and Briefing to Congress on Procurement and 

Inspection of Armored Commercial Passenger-Carrying Vehicles to Transport Civilian 

Employees of the Department of Defense (Washington, D.C.: Aug 2015).

Selected DOD 

Components’

Procurements Met 

Required Protection 

Levels
Page 13 GAO-17-513 Armored Commercial Vehicles

department cancelled DOD Instruction C-4500.51 in May 2017 because, 

according to an OSD official, the Undersecretary of Defense for 

Acquisition, Technology and Logistics did not want the responsibility for 

determining the new armoring requirements.

Anticipating the cancellation of DODI C-4500.51, the department issued a 

separate instruction. This instruction, DODI O-2000.16 Volume 1, dated 

November 2016, gave DIA responsibility for developing minimum 

standard inspection criteria for ACPVs.19 DIA is also responsible for 

disseminating specifications for the acquisition or modification of ACPVs 

and overseeing their incorporation into contracts awarded by DOD 

components. DIA officials said the criteria have been developed, but the 

agency is still determining how they will be distributed to the components. 

Also, DIA has not yet established a process for ensuring components 

incorporate those criteria in their contracts. According to DIA officials, 

implementing a process for oversight may be challenging for their agency. 

As of April 2017, DIA had not yet determined how long it would take to 

complete these actions.

The majority of DOD components’ contract actions we reviewed were 

unclassified, and, in those cases, no security clearance information was 

required or requested. For the unclassified contract actions, the 

contractors never required access to any classified information and the 

components did not require security clearances. This included the 

contract actions with the third party armorers—neither the prime nor 

subcontractors required any classified information, so there was neither a 

need nor a request for security clearances.

Some of the contract actions we reviewed were classified because they 

required armoring in accordance with State standards, which are 

classified, while other contract actions cited to alternative standards and,

therefore, were unclassified. Specifically, when the Army required a 

security clearance, the vendor provided evidence of its facility clearance 

with its proposal. For the Navy and Marine Corps, their ACPVs were 

procured via interagency acquisition using State contracts, which were all 

classified, as they required armoring to the classified State standards. In 

these cases, State officials told us that their Industrial Security Division 

 19Department of Defense Instruction O-2000.16, Vol. 1, DOD Antiterrorism (AT) Program 

Implementation: DOD AT Standards (Nov. 17, 2016). 

Steps Taken to Verify 

Required Vendor Security 

Clearances
Page 14 GAO-17-513 Armored Commercial Vehicles

performs an initial check of whether prospective vendors possess the 

required security clearance and provides results to the contracting office.

According to officials, at contract award the Industrial Security Division 

issues a final, signed classification specification form to document that the 

selected vendor’s clearance is in accordance with the requirements of the 

contract. In these cases, we found evidence that State took steps to 

ensure vendors were properly vetted and cleared, including obtaining 

signed classification specification forms.

State and all selected DOD components, with the exception of the Army, 

provided evidence of in-progress inspections for each contract action 

used to procure ACPVs between 2011 and 2015. All contract actions 

reviewed included provisions for inspections and acceptance, including 

in-progress inspections.

According to DIA officials, conducting in-progress inspections of their 

ACPVs is a best practice and a key step to ensuring vehicle quality and 

safety. We reviewed documentation for each DIA contract action and 

found evidence of in-progress inspections for all of them. Such evidence 

included detailed trip summary reports that documented multiple aspects 

of in-progress inspections at vendor armoring facilities. The in-progress 

inspection trip reports identified problems early that could be corrected 

before another in-progress inspection or the final inspection; deficiencies 

were dealt with before delivery and acceptance of the ACPVs. The trip 

reports contained detailed narratives listing the inspection dates, 

manufacturing facilities, inspection attendees, pictures of the vehicles, 

and any problems and corrections. The reports contained thorough trip 

narratives detailing the ACPVs’ performance and road tests, any 

problems with the ACPVs, how problems were corrected from an earlier 

in-progress inspection, and any action items or follow-up for the 

contractor.

We received evidence of State conducting in-progress inspections on 

ACPVs procured on behalf of the Navy through interagency acquisitions. 

As with DIA, State considers in-progress inspections to be a best practice 

when procuring ACPVs. Those inspections were similar to DIA’s. 

Specifically, the contract files contained checklists for in-progress 

inspections of opaque armor, transparent armor, and roadworthiness, as 

well as vehicle components such as the engine, exterior, interior, 

operation/control, and special equipment/options. The files also contained 

evidence of final inspection armoring checklists completed by State 

personnel. State personnel inspected the vehicle’s chassis, glass, 

The Army Did Not 

Consistently Conduct InProgress Inspections
Page 15 GAO-17-513 Armored Commercial Vehicles

serviceability, appearance, and roadworthiness. Based on our review of 

in-progress inspections conducted by State, there were issues with 

vehicles ranging from problems with adhesive or fenders to a need to 

reseal transparent armor. Lastly, there was evidence of final acceptance, 

indicating that any issues discovered in inspections were addressed, with 

both State officials and Navy officials accepting the ACPVs under these 

interagency acquisitions.

According to a Marine Corps official, they deferred to State to conduct inprogress inspections of Marine Corps’ ACPVs procured through 

interagency acquisitions. Marine Corps identified the State contracts that 

were utilized to procure their ACPVs and State provided evidence of final 

and in-progress inspections and acceptance for vehicles procured under 

those contracts. However, GAO could not confirm that those inspection 

records correlated to the Marine Corps’ ACPVs in every case. The 

inspection records referenced vehicle identification numbers that linked to 

State’s contracts and task orders, but neither State nor the Marine Corps 

were able to provide all the task orders required to corroborate these 

purchases. While this demonstrated that inspections were conducted for 

vehicles procured under these contracts, it did not allow verification that 

all the Marine Corps’ ACPV orders were placed under those contracts.

Army contract actions contained language and clauses for in-progress 

inspections as well as final inspections and acceptance, and Army 

officials provided evidence of final inspections and acceptance of ACPVs 

procured between 2011 and 2015. However, Army officials conducted inprogress inspections for a single procurement in 2011. Although the 

remaining Army contract actions included clauses that allowed such 

inspections, the Army instead depended on the vendors’ certified quality 

control and inspection processes to ensure the vehicles were 

manufactured to specifications. Army officials acknowledged they did not 

conduct in-progress inspections for any other ACPVs procured between 

2011 and 2015, but maintained that they had visited all the armoring 

facilities in the past under other contracts prior to the period of our review. 

However, the Army’s lack of in-progress inspections results in the service 

relying on the vendor’s quality control processes and therefore a 

presumption of quality for those vehicles produced without componentlevel, firsthand verification of armoring processes and safety. As we noted 

earlier, both State and DIA found problems during their in-progress 

inspections that may not have been discovered otherwise. As a result, 

there is the risk that Army ACPVs may be placed into service with 

undetected defects.
Page 16 GAO-17-513 Armored Commercial Vehicles

As mentioned above, DOD is updating its ACPV criteria. These updated 

criteria are expected to include minimum specifications for inspections 

pursuant to findings and proposed steps contained in DOD’s August 2015 

report on ACPVs to the House Armed Services Committee.20 According 

to the report, the minimum inspection criteria will include various stages of 

inspections, including in-progress inspection. Although this is a positive 

step, these changes have not yet been approved, promulgated to the 

components, and implemented, nor is there a mechanism in place to 

ensure the criteria are being consistently applied and executed across the 

components. Until these criteria are approved and implemented, the risk 

of vehicles deploying with defects remains.

While the FAR provides that contracts for commercial items shall 

generally rely on the contractor’s existing quality assurance system as a 

substitute for government inspection, the regulation also provides the

contracting officer with discretion to conduct in-progress inspections when 

deemed appropriate. Specifically, the FAR directs the contracting officer 

to consider the nature of the supplies and services being acquired and 

the potential losses in the event of defects. Both DIA and State 

determined that in-progress inspections of ACPVs are warranted, as the 

intended use of these vehicles is to transport American citizens and 

service members through dangerous areas, and failures stemming from 

armoring deficiencies could endanger passengers. In addition, officials 

from both DIA and State consider in-progress inspections imperative and 

a best practice towards ensuring their ACPVs are armored in a manner 

that improves the likelihood that vehicles meet contractual specifications. 

DIA in-progress inspections discovered vehicle deficiencies that required 

corrective actions. These inspections are above and beyond the quality 

control procedures provided by the vendors. They serve as safeguards 

and provide greater confidence that ACPVs are being built in a manner 

that satisfies minimum armoring specifications and that the ACPVs are 

protecting the lives of the people who rely on them in potentially 

dangerous situations.

The nature of the armoring process itself suggests in-progress 

inspections are important. The armoring process involves disassembling 

the commercial vehicles, integrating the armor, and then rebuilding the 

 20Department of Defense, Office of the Under Secretary of Defense for Acquisition, 

Technology, and Logistics, Report and Briefing to Congress on Procurement and 

Inspection of Armored Commercial Passenger-Carrying Vehicles to Transport Civilian 

Employees of the Department of Defense (Washington, D.C.: Aug 2015).
Page 17 GAO-17-513 Armored Commercial Vehicles

vehicles, which essentially conceals evidence of the armoring techniques. 

As a result, any defects that are not discovered during the armoring 

process may not be noticeable during the government’s final inspection 

and acceptance event. Given the intended use of these vehicles to 

transport American citizens and service members as well as other 

passengers that are considered high-value targets through dangerous 

areas, further inspection of ACPVs is an important step in the quality 

assurance system.

All contract actions we reviewed had some form of warranty provision. 

Most contract actions we reviewed had a 1- to 3-year warranty range for 

opaque armor (i.e., steel). All contract actions had a 2-year warranty for 

transparent armor (i.e., glass) and coverage at the ACPV fielded location 

with no cost to government. All DIA contract actions also had 2-year 

warranties for workmanship. The FAR has no mandatory policy requiring 

warranties, but it does direct contracting officers to consider several 

factors when determining whether a warranty is appropriate for an 

acquisition.

DOD officials stated that any problems with the ACPVs were minor, such 

as window noise. These problems were documented and corrected in the 

inspection phase before final acceptance by the government. Officials 

from the components stated that their ACPVs did not have any 

catastrophic failures during testing or in the field. Further, we found no 

evidence of contract actions for correcting armoring deficiencies after 

delivery.

DOD components no longer report ACPV inventory information to the 

Assistant Secretary of Defense for Special Operations and Low Intensity 

Conflict and Interdependent Capabilities in OSD, as required by the DODI 

C-4500.51. OSD officials eliminated the ACPV reporting requirement 

pursuant to an efficiency initiative memo promulgated by former Secretary 

of Defense Gates on March 31, 2011. It stated:

Office of Secretary of Defense Principal Staff Assistants and DoD Component Heads, in 

coordination with the Director, Administration and Management and General Counsel of 

the Defense Department, will eliminate all non-essential, internally generated reports, 

including any and all reports generated with a commissioning date prior to 2006. The 

Director, Administration and Management shall publish guidance regarding use of, cost 

benefit analysis of, and establishing sunset provisions for, report requirements.

Selected DOD 

Components Used Similar 

Warranty Provisions

DOD Components Do Not 

Report ACPV Information 

to the Office of the 

Secretary of Defense
Page 18 GAO-17-513 Armored Commercial Vehicles

While OSD eliminated this reporting, as mentioned above, there is a 

requirement in DODI O-2000.16 Volume 1 for DIA to oversee 

incorporation of armoring and inspection criteria in all components’

contracts. DOD officials stated this requirement will require some 

coordination among the components. DIA officials said the agency does 

not currently have a mechanism for such oversight and that establishing 

such a mechanism could be challenging. This situation puts a premium 

on coordination between DIA and the services and increases the 

importance of services being able to provide procurement and inspection 

information to DIA.

With the exception of the Army, all the DOD components we reviewed 

have a central point of contact and mechanisms for managing and 

organizing their ACPV information. According to an Army official, while 

the Army’s program office for non-tactical vehicles can track Army-wide 

vehicle condition for replacement decisions, that office does not maintain 

more comprehensive ACPV information, such as information for contract 

execution and vehicle inspections, across the entire Army. This 

decentralized approach for ACPV management leaves the Army with an 

incomplete picture of various ACPV-related matters, including 

consistency of procurement and inspection methods. For example, since 

the Army does not have ACPV information in a centralized manner, it may 

be difficult for the Army to provide information on the types of contracts 

used for procuring these vehicles and whether in-progress inspections 

are being conducted, to DIA for oversight. It could also present 

challenges to the Army for consistent application of best practices and 

lessons learned between the purchasing entities, as well as difficulty 

leveraging contracting mechanisms to obtain the best value for the 

government.

Federal standards for internal control call for mechanisms that allow for 

oversight intended to help an organization, such as the Army, meet 

objectives and manage risks for activities such as ACPV procurement.21

The internal control standards advocate for an oversight structure to fulfill 

responsibilities set forth in laws and regulations and for control activities 

at various levels to help meet objectives and manage risks. Such control 

activities would include management reviews to compare actual 

performance to planned or expected results throughout the organization. 

 21GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sep. 2014). 

Army Utilizes a Decentralized 

Approach for ACPV 

Management
Page 19 GAO-17-513 Armored Commercial Vehicles

Further, internal controls advocate for reports for use by the organization 

to ensure compliance with internal objectives, evaluate compliance with 

laws and regulations, and inform outside stakeholders.

While selected DOD components in our review are complying with 

guidance, policies, and procedures for ensuring the safety and quality of 

ACPVs, opportunities exist for the Army to provide greater assurances 

that vehicles meet armoring and quality specifications. DOD’s use of 

ACPVs to transport personnel through areas that are understood to have 

potential for attack increases the importance of in-progress inspections 

and oversight. Such inspections provide greater assurances that vendors 

are adhering to established quality assurance procedures and delivering 

vehicles that satisfy the armoring standards for protecting passengers. By 

DIA’s own admission, overseeing the implementation of revised armoring 

and inspection standards in DOD contracts will be a challenge. A focal 

point within each of the DOD components that can collect and report 

ACPV-related contracting information to DIA could help ease that burden. 

While many components have a single, centralized office that is 

responsible for all aspects of ACPV that would be capable of reporting 

this information, the Army’s non-tactical vehicle office does not maintain 

similar information. In that regard, the Army could benefit from a 

centralized point of contact that can collect and, ultimately, report to DIA 

information pertaining to all aspects of the component’s ACPV safety, 

procurements, and fleet status.

To help ensure that ACPV armoring and quality standards are met, that 

evolving department and component policies are consistent, and that they 

are consistently applied, we recommend that the Secretary of Defense:

• Until the department approves and implements the updated armoring 

and inspection standards, direct the Secretary of the Army to conduct 

in-progress inspections at the armoring vendor’s facility for each 

procurement; and

• Direct the Secretary of the Army to designate a central point of 

contact for collecting and reporting ACPV information to facilitate 

DIA’s oversight of armoring and inspection standards in these 

contracts.

We provided drafts of this product to the Department of Defense (DOD) 

and the State Department for comment. In its comments, reproduced in 

Conclusions

Recommendations for 

Executive Action

Agency Comments
Page 20 GAO-17-513 Armored Commercial Vehicles

appendix II, DOD concurred with our recommendations. DOD also 

provided a technical comment, which we incorporated as appropriate. As 

we made no recommendations to the State Department, it did not provide 

comments.

We are sending copies of this report to the appropriate congressional 

committees; the Secretary of Defense; the Secretaries of the Army, Navy, 

and Air Force; the Director of the Defense Intelligence Agency; and the 

Secretary of State. In addition, the report is available at no charge on the 

GAO Web site at http://www.gao.gov.

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

me at (202) 512-4841 or makm@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.

Marie A. Mak

Director, Acquisition and Sourcing Management
Appendix I: Objectives, Scope, and 

Methodology

Page 21 GAO-17-513 Armored Commercial Vehicles

This report addresses DOD components procurement of Armored 

Commercial Passenger-Carrying Vehicles (ACPVs). The objectives are to 

determine (1) DOD’s guidance and procedures for acquiring ACPVs and 

how they compare with those at State; and (2) the extent to which 

selected DOD components adhere to guidance, policy, and procedures 

for ensuring the safety and quality of ACPVs.

To assess DOD’s guidance and procedures for acquiring ACPVs and how 

they compare with those at State, we reviewed the DOD instruction for 

specific guidance pertaining to ACPV acquisitions and the departmentlevel policies for procuring modified commercial vehicles. We also 

reviewed the associated federal acquisition regulations that pertain to the 

various aspects of our review, namely those for procurement 

mechanisms, warranties, security clearances, inspection, and 

acceptance. We identified service-specific guidance that could also apply 

to the acquisition and inspection of ACPVs and interviewed DOD service 

and agency officials to verify their applicability to ACPV procurement. We 

researched the State Foreign Affairs Manual and Foreign Affairs 

Handbook for specific sections dealing with various aspects of ACPV 

procurement and inspection and verified their applicability during 

meetings with State officials. We summarized the contents of DOD and 

State policies for comparative purposes. We also analyzed armoring 

standards that were referenced in contract file documents—which 

included State standards, North Atlantic Treaty Organization standards, 

and European standards—and compared them with the minimum 

armoring standards outlined in DOD Instruction C-4500.51, the relevant 

instruction for the timeframe we assessed. The specific armoring 

standards contained in the DOD Instruction and State policy are 

classified, which preclude us from presenting a detailed assessment of 

those standards in this report.

To determine the extent to which selected DOD components—namely the 

Army, Navy, Marine Corps, and DIA, the largest procurer of these 

vehicles for use overseas—adhered to guidance, policy, and procedures 

for ensuring the safety and quality of armored commercial passengercarrying vehicles, we worked with DOD and State officials to identify 

contract actions that were used to acquire ACPVs that DOD components 

received between 2011 and 2015. We selected this time frame to cover 

from when DOD stopped reporting this information to Congress to the 

most recently available information at the time of our review. For each 

contract action, we reviewed numerous documents, including base 

contracts, task orders, work statements, vendor proposals, invoices, and 

inspection reports, in order to identify evidence of contracting 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 22 GAO-17-513 Armored Commercial Vehicles

mechanisms, armoring specifications, vendor clearances, inspection and 

acceptance, and fleet management. We also created data collection 

instruments, populated them with the information obtained during the 

course of our review, verified the information with agency officials through 

multiple interviews, and created summary analyses that allowed us to 

succinctly present the information in our report. We searched the federal 

procurement database in order to identify any instances where separate 

contracts were executed to correct any deficiencies that were discovered 

after vehicles were fielded. We were unable to identify any such 

contracts.

In order to determine the total quantities of ACPVs that selected DOD 

components purchased between 2011 and 2015, we sent questionnaires 

to agency officials asking specifically about procurement quantities. We 

also reviewed contract file documentation that pertained to quantities 

obtained over that time frame and summarized the results. Although we 

calculated a quantity for ACPVs that DOD components procured from 

2011 to 2015, the State information for vehicles it provided to DOD was 

inconsistent with information provided by all the services. As a result, we 

were unable to verify the exact total number of vehicles DOD components 

acquired over this time frame. For example, State and Marine Corps 

officials both reported vehicle quantities and contract numbers, but they 

were unable to provide task orders to validate those quantities.

We conducted this performance audit from May 2016 to June 2017 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Department 

of Defense

Page 23 GAO-17-513 Armored Commercial Vehicles

Appendix II: Comments from the Department 

of Defense
Appendix II: Comments from the Department 

of Defense

Page 24 GAO-17-513 Armored Commercial Vehicles
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 25 GAO-17-513 Armored Commercial Vehicles

Marie A. Mak, (202) 512-4841, makm@gao.gov.

In addition to the contact named above, J. Kristopher Keener, Assistant 

Director; Emily Bond; Thomas M. Costa; Andrea C. Evans; Marcus C. 

Ferguson; Kristine R. Hassinger; and Hai V. Tran made key contributions 

to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100885)
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