OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

NEED TO ENHANCE OVERSIGHT OF

THEATER-WIDE INTERNAL

SECURITY SERVICES CONTRACTS

SIGIR--09--017

AAPPRRIILL2244,,22000099
Special Inspector General for Iraq

SIGIR

Reconstruction

For more information, contact SIGIR Public Affairs 

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

Summary of Report: SIGIR-09-017 

Why SIGIR Did This Study 

Private security contractors (PSCs) play an 

important role in Iraq by protecting U.S. 

personnel, facilities, and property related to 

reconstruction efforts. In September 2007, the 

Department of Defense (DoD) competitively 

awarded five Theater-Wide Internal Security 

Services (TWISS) contracts to five PSCs for 

static, or fixed site security services in Iraq. The 

contracts have a combined not-to-exceed 

maximum value of $450 million. The 

companies are among the seven largest private 

security service providers in Iraq. 

This report responds to a mandate in the 

National Defense Authorization Act for 2008, 

(Public Law 110-181) that requires audits of the 

performance of security functions to address the 

manner in which contract requirements were 

developed and contracts or task orders were 

awarded; and the manner in which DoD 

exercised control over the performance of 

contractors. 

Specifically, this report examines the cost of the 

contracts, the requirements for the static security 

forces, the government’s process for awarding 

the contracts, task orders, and modifications, 

and the oversight provided by the Contracting 

Officer Representatives (CORs). 

What SIGIR Recommends 

SIGIR recommends that to improve contract 

administration and oversight, the Commanding 

General, Multi-National Corps-Iraq; Director of 

the Defense Contract Management Agency; and 

the Commander of the Joint Contracting 

Command-Iraq/Afghanistan direct that the 

following actions be taken as they relate to their 

respective responsibilities under the contract: 

1. Provide additional training to CORs on their 

private security contractor oversight 

responsibilities with regard to the TWISS 

contracts. 

2. Assess the workload for TWISS CORs to 

identify actions that can be taken to balance 

workload demands so that sufficient time can be 

given to contract oversight responsibilities. 

Management Comments 

The Multi-National Force – Iraq and the 

Defense Contract Management Agency 

provided comments on a draft of this report. 

Both agencies generally agreed with the report. 

April 24, 2009 

NEED TO ENHANCE OVERSIGHT OF THEATER-WIDE 

INTERNAL SECURITY SERVICES CONTRACTS

What SIGIR Found 

Between February 2008 and March 2009, DoD had expended $154.6 million 

on the TWISS contracts. The contracts are funded from the Operation and 

Maintenance, Army, account. More than three quarters of the costs to date 

are for personnel costs. In most cases, life-support costs for contractor 

personnel such as food, water, and shelter are not included in contract costs 

and are paid by DoD. SIGIR estimates these costs at more than $250 million 

per year. SIGIR reviewed selected personnel pay rates and found that on 

average, competing the task orders had driven down the costs of these 

services significantly. 

The TWISS contract was created to streamline the contracting process for 

static security in anticipation of an increased need for these services in Iraq. 

The five contracts, and 47 of the 50 task orders, were competitively 

awarded. SIGIR found the requirements for the task orders were based on 

the need to replace troops performing static security with private security 

contractors (PSC) to make more troops available for combat operations. 

SIGIR identified certain vulnerabilities in the government’s oversight. 

Generally, the CORs’ experience and training was limited, and their time 

available to devote to their oversight responsibilities for these contracts was 

insufficient. This hampered their ability to perform their oversight 

responsibilities. For example, of 27 CORs responding to SIGIR questions, 

only 4 CORs said that they had previous contracting experience, 11 said that 

their training was insufficient to meet their job requirements, and 6 said that 

other duties prevented them from conducting adequate oversight. Although 

Defense Contract Management Agency Quality Assurance Representative 

inspections help provide oversight, they are periodic and not a substitute for 

the day-to-day oversight provided by CORs. 

Conclusions 

Between February 2008 and March 2009, DoD had spent $154.6 million on 

the TWISS contracts. Almost all contracts and task orders were awarded 

under full and open competition, with a well-supported decision-making 

process. Full and open competition has lowered the costs of these services. 

The experience, training, and additional duties of CORs providing oversight 

of the TWISS contracts is another example of the difficulties experienced 

when the U.S. military lacks the capacity to manage its contractors in a 

contingency environment. Selecting CORs with limited or no direct contract 

management experience, providing them training on the job or on an ad hoc 

setting, and then assigning them other principal duties, increases the 

government’s vulnerability. Moreover, in looking forward, difficulties in 

managing these contracts could easily be exacerbated as the U.S. military 

draws down its presence in Iraq and thus its available pool of experienced 

personnel to perform these functions. Furthermore, with the addition of the 

upcoming TWISS II, the TWISS contracts will grow in size to a potential 

$935 million. Such a situation would make these contracts even more 

vulnerable to fraud, waste, and abuse.
SPE CI AL I NSPE CT O R GE NE R AL FO R I R AQ RE C ONST R UCT I O N

400 Army Navy Drive • Arlington, Virginia 22202

April 24, 2009 

MEMORANDUM FOR COMMANDING GENERAL, CENTRAL COMMAND 

COMMANDING GENERAL, MULTI-NATIONAL FORCE-IRAQ 

COMMANDING GENERAL, MULTI-NATIONAL CORPS-IRAQ 

COMMANDER, JOINT CONTRACTING COMMANDIRAQ/AFGHANISTAN

DIRECTOR, DEFENSE CONTRACT MANAGEMENT AGENCY 

SUBJECT: Need To Enhance Oversight of Theater-Wide Internal Security Services Contracts 

(SIGIR-09-017) 

We are providing this report for your information and use. It pertains to the cost, requirements, 

award process, and oversight of the Department of Defense’s Theater-Wide Internal Security 

Services contracts. The audit was conducted by the Special Inspector General for Iraq 

Reconstruction (SIGIR) as project 8032 under the authority of Public Law 108-106, as amended, 

which also incorporates the duties and responsibilities of inspectors general under the Inspector 

General Act of 1978. The audit also responds to a requirement of the National Defense 

Authorization Act for 2008 (Public Law 110-181) that requires audits of the performance of 

security functions to address the manner in which contract requirements were developed and 

contracts or task orders were awarded, and the manner in which the Department of Defense 

exercised control over the performance of contractors. 

We considered written comments on a draft of this report from Multi-National Force - Iraq and 

the Defense Contract Management Agency, when finalizing this report. The comments on the 

recommendations are included in Appendix D. Technical comments were also provided and are 

addressed in the report where appropriate. 

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

report, please contact Glenn Furbish, Principal Deputy Assistant Inspector General for Audits, at 

(703-428-1058/glenn.furbish@sigir.mil), or Nancee Needham, Deputy Assistant Inspector 

General for Audits (240-553-0581, ext. 3793/ nancee.needham@iraq.centcom.mil).

 

Stuart W. Bowen, Jr. 

Inspector General 
SPE CI AL I NSPE CT O R GE NE R AL FO R I R AQ RE C ONST R UCT I O N

400 Army Navy Drive • Arlington, Virginia 22202

Table of Contents 

Executive Summary i 

Introduction 1 

Background 1 

Services Provided Under TWISS Contracts 2 

Objectives 2 

Contract Costs 4 

Contracts Costs Are Substantial 4 

Personnel Rates Have Decreased 5 

Requirements Primarily Based on Need To Make Military Personnel 

Available for Combat Duties 6 

Contract and Task Orders Well Supported 7 

TWISS Contracts Were Selected Under Full and Open Competition 7 

Majority of Task Order Awards Are Competitively Awarded 8 

Vulnerabilities in Government's Oversight 10 

Contracting Officer Representatives Oversight Hampered 10 

DCMA Quality Assurance Representatives 11 

Conclusions and Recommendations 12 

Conclusions 12 

Recommendations 12 

Management Comments and Audit Response 12 

Appendices 

A. Scope and Methodology 14 

B. Acronyms 16 

C. Audit Team Members 17 

D. Management Comments 18 
i

Need To Enhance Oversight of Theater-Wide 

Internal Security Services Contracts

SIGIR-09-017 April 24, 2009

Executive Summary

This report discusses the Department of Defense’s (DoD) Theater-Wide Internal Security 

Services (TWISS) contracts for labor, weapons, equipment, and other essentials to augment 

and/or replace military security guard operations at forward operating bases and camps 

throughout Iraq. Altogether, DoD awarded TWISS contracts in September 2007, with a 

combined not-to-exceed value of $450 million, to five companies: Aegis Defence Services, 

Limited;1 EOD Technology, Inc.; Sabre International Security; Special Operations ConsultingSecurity Management Group; and Triple Canopy, Inc. The companies are among the seven 

largest private security service providers in Iraq. The five contractors participating in TWISS 

each received a $250,000 task order obligation to meet the guaranteed minimum and initiate the 

contract; the contractors then competed to provide security services at various locations in Iraq. 

Between February 2008 and March 2009, 50 task orders had been issued to the companies. 

This report responds to the mandate in the National Defense Authorization Act for 2008 (Public 

Law 110-181) that requires audits of the performance of security functions to address the manner 

in which contract requirements were developed and contracts or task orders were awarded, and 

the manner in which DoD exercised control over the performance of contractors. 

The TWISS contracts and subsequent task orders were awarded by the Joint Contracting 

Command- Iraq/Afghanistan (JCC-I/A) on behalf of Multi-National Force-Iraq (MNF-I). To 

provide oversight of the contracts, JCC-I/A delegated contract administration and oversight to 

the Defense Contract Management Agency (DCMA).2 The task orders set forth specific security 

services that are required. DCMA uses Contracting Officer Representatives (CORs) to conduct 

day-to-day oversight of the contractors’ performance and compliance with contract requirements. 

CORs are selected by the installation command and report to DCMA and the contracting officer. 

Each task order has a COR, who is a military member located where the guard services are 

provided. DCMA also uses its own Quality Assurance Representatives to periodically inspect 

the CORs’ and contractors’ performance and compliance with requirements. 

The objectives for this report are to identify: 

the costs of the contracts 

 

1

 As of the date of this report, Aegis had been awarded a task order only to initiate the contract. The contract 

minimum of $250,000 had been obligated against that task order. The obligated funds were to be used to pay for 

future tasks; however, because no additional tasks had been awarded, no funds had been paid to Aegis. 

2

 JCC-I/A is the central authority for contracting in Iraq and Afghanistan. DCMA Iraq performs administrative 

services for effects-based contingency contracts in support of the Iraq theater of operations. 
ii

the requirements for the static security forces 

the government’s process for awarding the contracts, task orders, and modifications

the oversight provided by the CORs 

SIGIR plans to review government oversight of the contractors’ bills, performance, operations, 

and processes for screening, selecting, and training its personnel in future reports. 

Results 

Between February 2008 and March 2009, DoD had expended $154.6 million on the TWISS 

contracts. The contracts are funded from the Operation and Maintenance, Army, account. More 

than three quarters of the costs to date are for personnel costs. In most cases, life-support costs 

for contractor personnel—such as food, water, and shelter—are not included in contract costs 

and are paid by DoD. SIGIR estimates these costs at more than $250 million per year. SIGIR 

reviewed selected personnel pay rates and found that on average, competing the task orders had 

driven down the costs of these services significantly. 

The TWISS contract was created to streamline the contracting process for static security in 

anticipation of an increased need for these services in Iraq. SIGIR found that the requirements 

for the task orders were based on the need to replace troops performing static security with 

private security contractors (PSC) to make more troops available for combat operations. For 

example, at Camp Bucca, a task order for 417 personnel freed up approximately 350 soldiers for 

combat operations. 

SIGIR found that most contract and task order awards were conducted under full and open 

competition, and the decision-making process was well supported. The 5 contracts and 47 of the 

50 task orders were competitively awarded. Three noncompetitively awarded task orders, worth 

$15.1 million, were appropriately justified as sole source awards. 

SIGIR identified certain vulnerabilities in the government’s oversight. Generally, the CORs’ 

experience and training was limited, and they had insufficient time available to devote to their 

oversight responsibilities. This hampered their ability to perform their oversight responsibilities. 

For example, of 27 CORs responding to SIGIR questions, only 4 CORs said that they had 

previous contracting experience, 11 said that their training was insufficient to meet their job 

requirements, and 6 said that other duties prevented them from conducting adequate oversight. 

Although DCMA Quality Assurance Representative inspections help provide oversight, they are 

periodic and not a substitute for the day-to-day oversight provided by CORs who oversee task 

orders ranging from $179.0 thousand to $22.2 million. 

Although SIGIR’s review did not identify specific problems that have resulted from these 

limitations, SIGIR has identified poor oversight as a cause of fraud and waste. Given DoD’s 

planned increase in the use of security contractors, this vulnerability could increase unless the 

problem is addressed. 
iii

Recommendations 

To improve contract administration and oversight, SIGIR recommends that the Commanding 

General, Multi-National Corps-Iraq; the Director, Defense Contract Management Agency; and 

the Commander, Joint Contracting Command-Iraq/Afghanistan, direct that the following actions 

be taken as they relate to their respective responsibilities under the contract: 

1. Provide additional training to Contracting Officer Representatives on their private 

security contractor oversight responsibilities with regard to the TWISS contracts. 

2. Assess the workload for Theater-Wide Internal Security Services Contracting Officer 

Representatives to identify actions that can be taken to balance workload demands so that 

sufficient time can be given to contract oversight responsibilities. 

Management Comments and Audit Response 

Multi-National Force-Iraq (MNF-I) and the Defense Contracting Management Agency (DCMA) 

generally agreed with the report recommendations. Specifically, both agencies agreed on the 

need for additional training and workload assessments for Contracting Officer Representatives 

(CORs) and to take actions to address SIGIR’s recommendations. 

Concerning recommendation 1, MNF-I stated that Joint Contracting Command –

Iraq/Afghanistan (JCC-I/A), in conjunction with DCMA, will reach out to CORs to provide 

targeted training in areas that CORs perceive to be their individual weaknesses. DCMA stated 

that some aspects of training are the responsibility of the COR’s unit and DCMA’s responsibility 

is training related to contract administration oversight and specific contract familiarity. DCMA 

stated that as a result of a review it performed in March 2009, DCMA plans to improve future 

COR training sessions by more directly involving the DCMA Administrative Contracting Officer 

and Quality Assurance staff in the instruction. 

With regards to recommendation 2, MNF-I stated that while the requiring activity is responsible 

for nominating CORs based on individual qualifications and abilities, JCC-I/A will work with 

the requiring activities to ensure that they understand the responsibilities demanded of CORs. 

MNF-I also stated that JCC-I/A will work with requiring activities to recommend CORs who 

have prior experience with contract oversight and/or be familiar with the function. DCMA 

concurred with the need to assess COR workload. DCMA has recognized a gap in the number of 

assigned CORs in the Iraq and Afghanistan areas of operation. It stated this gap includes CORs 

with specialized skills that are not core competencies within DCMA. It further stated that 

DCMA is working with the DoD Joint Staff to address this issue. 

MNF-I also provided technical comments, which SIGIR incorporated as appropriate. SIGIR 

believes that the actions identified by management, if properly implemented, are responsive to 

the report’s recommendations.
1

Introduction 

Private security contractors (PSCs) play an important role in Iraq by protecting U.S. personnel, 

facilities, and property related to reconstruction efforts. The Department of Defense (DoD) relies 

on PSCs to provide static, or site security in Iraq by guarding and protecting fixed locations such 

as forward operating bases.3

 In September 2007, DoD competitively awarded five Theater-Wide 

Internal Security Services (TWISS) contracts to five PSCs for static security services in Iraq. 

The contracts have a combined not-to-exceed maximum value of $450 million. The five TWISS 

contractors competitively bid on firm fixed-price task orders to provide security for specific 

operating locations. 

This report responds to the mandate in Section 842 of the National Defense Authorization Act 

for 2008, Public Law 110-181 that requires audits of the performance of security functions to 

address the manner in which contract requirements were developed and contracts or task orders 

were awarded; and the manner in which the Department of Defense exercised control over the 

performance of contractors. 

Background 

In September 2007, DoD’s Joint Contracting Command – Iraq/Afghanistan (JCC-I/A), on behalf 

of Multi-National Force – Iraq (MNF-I), awarded TWISS contracts to five PSCs: Aegis Defence 

Services, Limited4

; EOD Technology, Inc.; Sabre International Security; Special Operations 

Consulting-Security Management Group; and Triple Canopy. The companies represent five of 

the seven largest private security service providers in Iraq. The contracts provide the capability 

to replace troops, substitute PSCs for soldiers that are needed elsewhere, or streamline the 

contract award process. 

Each of the five contracts has a $250,000 minimum, and all 5 contracts combined have a 

$450,000,000 maximum value.5

 Each contract has a 1-year base period (September 28, 2007, 

through September 27, 2008) and two 1-year options (September 27, 2008, through September 

25, 2010). As of March 17, 2009, a total of 50 task orders had been awarded, $252.7 million had 

been obligated, and $154.6 million had been expended under the contracts. 

The TWISS contracts and subsequent task orders were awarded by JCC-I/A on behalf of MNF-I. 

To oversee the contracts, JCC-I/A delegated contract administration and oversight to the Defense 

Contract Management Agency (DCMA). DCMA relies on Contracting Officer Representatives 

(COR) for the day-to-day oversight of the contractors’ performance and compliance with 

contract requirements. Each task order has a COR, who is a military member located where the 

services are provided. In addition, DCMA Quality Assurance Representatives periodically 

inspect the CORs’ performance and contractors’ performance and compliance with requirements. 

 

3

 A forward operating base is an area used to support tactical operations without establishing full support facilities. 

4

 As of the date of this report, Aegis had been awarded only a task order to initiate the contract. The contract 

minimum of $250,000 had been obligated against that task order. The obligated funds were to be used to pay for 

future tasks; however, since no additional tasks were awarded, no funds had been paid to Aegis. 

5

 The minimum contract value for all task orders issued against the contract is $250,000 
2

Services Provided Under TWISS Contracts 

The TWISS contractors are to (1) provide all labor, weapons, and equipment needed to staff 

entry control points and perimeter towers, (2) secure selected facilities, (3) provide armed escorts 

on installations for local national laborers, and (4) maintain liaison cells at selected headquarters 

sites. The number of personnel to be provided varies per task order. For example, the smallest 

task order requires only one individual to provide security consulting services, while the largest 

task order requires approximately 1,000 personnel to guard a major U.S. installation. To perform 

these services, PSCs provide individuals with varied skills and training. For example, they 

provide: 

guards who staff internal and external control points, perimeter towers, roving patrols, 

and escort teams 

explosive ordnance detection dog handlers who inspect vehicles, equipment, and supplies 

for explosives and explosive devices 

screeners and screener/interpreters who search visitors and their belongings for prohibited 

items 

supervisors and management staff, including guard team supervisors, medical and 

administrative officers, the deputy site manager, and the site manager 

Table 1 shows the estimated number of personnel under the TWISS contracts for each of these 

services as well as the management and support personnel. 

Table 1—Estimated Personnel on TWISS Contracts, by Function as of 

March 17, 2009

Function Number of Personnel

Guard 7,399

Explosive Ordnance Detection Dog Handler 37

Screener/Interpreter 179

Supervisor/Management 885

Specialized Support Personnel 80

Total 8,580

Source: SIGIR, compiled from all TWISS task orders as of March 17, 2009. 

Most of the personnel provided under TWISS are expatriates from countries such as Uganda and 

Kenya. In addition, about 200 Iraqis perform static security under the contracts. 

Objectives 

For this report, SIGIR examined (1) the cost of the contracts; (2) the requirements for the static 

security forces; (3) the government’s process for awarding the contracts, task orders, and 

modifications; (4) and the oversight provided by the CORs. SIGIR plans to review the 

government’s oversight of the contractors’ bills, performance, operations, and processes for 
3

screening, selecting, and training its personnel. These issues will be the subject of subsequent 

reviews which will be announced as separate projects at a later date. 

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

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

Appendix C. For management comments, see Appendix D. 
4

Contract Costs 

Between February 2008 and March 2009, DoD had expended $154.6 million on the TWISS 

contracts. The contracts are funded from the Operation and Maintenance, Army, account and 

more than three quarters of their costs are for personnel. In most cases, life-support costs for 

contractor personnel such as food, water, and shelter are not included in contract costs and are 

paid by DoD. SIGIR estimates these costs at more than $250 million per year. SIGIR reviewed 

selected personnel pay rates and found that on average, competing the task orders had driven 

down the costs of these services significantly. 

Contract Costs Are Substantial 

Table 2 shows the number of task orders awarded to each contractor and the total funds obligated 

and expended for those task orders. 

Table 2—Task Orders, Obligations, and Expenditures, by Contractor, 

as of March 17, 20096

Contractor

Task Orders 

Awarded Obligations Expenditures

SOC-SMG 17 $118,722,963 $77,324,207

EODT 11 $56,534,091 $30,745,416

Sabre 12 $42,349,942 $26,904,817

Triple Canopy 9 $34,859,447 $19,631,855

Aegis 1 $250,000 -

Total 50 $252,716,443 $154,606,295

Source: Joint Contracting Command – Iraq/Afghanistan and Defense Contract Management Agency. 

The task orders are firm fixed-price awards with personnel costs that account for 81% of the 

$252.7 billion obligated to date. Those costs are computed using fixed monthly rates per person 

for various positions under the task orders.7 For example, specific rates apply to expatriate 

guards, dog handlers, medics, and supervisors. The rates include overhead, travel, and training. 

The fixed prices also include mobilization fees, which include most other costs−such as 

weapons, night vision goggles, and radios. Items purchased with mobilization fees become the 

contractors’ property. As of March 17, 2009, $41.5 million or 16% of the $252.7 million 

obligated, was for mobilization fees. 

Because obligations are projected to increase quickly toward the contract maximum value of 

$450 million as requirements continue to grow; in January 2009, JCC-I/A began soliciting 

follow-on TWISS contracts, which according to the request for proposal, will have a maximum 

 

6

 The TWISS contracts are funded with Operation and Maintenance, Army funds. 

7

 We do not provide specific contractor rates since they are proprietary information. 
5

value of $485 million.8 A major change in the new contracts will be a requirement for all 

companies to have facilities clearances. A facilities clearance is an administrative determination 

that a company is eligible for access to classified information or award of a classified contract. 

According to JCC-I/A officials, MNF-I plans to add additional installations in Iraq to the new 

contracts, including Victory Base Camp, which has a requirement for approximately 2,600 

security personnel. 

In addition to the $154.6 million in contract expenditures, the government provides most lifesupport services—for example, food, water, and shelter−to contractor personnel. SIGIR 

estimates these costs at more than $250 million per year. 

Personnel Rates Have Decreased 

According to JCC-I/A officials, the use of competition has helped drive down the costs of 

security services. We analyzed the two personnel rates most frequently used (Expatriate Guards 

and Expatriate Supervisors) to determine if the rates have been reduced over time and found that 

average costs have been significantly reduced over the course of the contracts, especially when 

compared to the rates agreed upon at contract award. For example, as shown in Table 3 the 

average rate for an expatriate security guard decreased 26% between the time the contract was 

awarded and the award of the first task order. In the most recent task order, the rate decreased an 

additional 29% for a total decrease of 55%. 

Table 3—Average Percentage Changes in Personnel Rates between Base 

Contract, First Task Order, and Most Recent Task Order Rates from 

February 2008 to February 2009

Service

Base Contract and 

First Order

Base Contract and 

Most Recent Order

Expatriate Guard -26.43% -54.89%

Expatriate Supervisor -28.41% -55.58%

Source: SIGIR Analysis of TWISS Task Orders 

 

8

 According to JCC-I/A, due to the security agreement signed by the United States and Iraq, some of the planned 

option years will not be exercised or task orders could be terminated for convenience depending on installation 

closures. 
6

Requirements Primarily Based on Need to Make 

Military Personnel Available for Combat Duties

In April 2007, MNF-I issued a request for proposals for static security services. The contract 

was to standardize static security services, streamline the contracting for these services, augment 

existing static security, and/or replace troops who were providing security with contractorprovided personnel. At the time, security was performed by a mix of coalition forces and 

contract personnel. MNF-I anticipated a dramatic increase in the need for static security services 

at multiple locations and realized that by using a multiple award indefinite delivery and 

indefinite quantity contract, it could satisfy those requirements by issuing task orders instead of 

individual contracts. 

In our review of task orders, we found that 40 were justified on the need to replace troops, that is, 

to substitute PSCs for soldiers that were needed elsewhere, or incorporate an existing PSC 

contract into TWISS. In 19 of the 40, PSCs replaced soldiers performing static security at an 

installation. For example: 

At Camp Taji, DoD issued a task order for over 900 personnel to replace 400 soldiers and 

to address deficiencies in existing site security 

At Camp Bucca, DoD issued a task order for 417 personnel to free up approximately 350 

soldiers for combat operations 

At forward operating base Hammer, DoD issued a task order for 124 personnel to free up 

102 soldiers for combat operations 

The other 21 task orders involved using contractor personnel in lieu of soldiers to meet (1) 

increased security requirements or (2) to incorporate an existing PSC contract into TWISS. For 

example: 

At forward operating base Hussaniyah, additional static security personnel were required 

when the installation size quadrupled. Without PSCs to fill this additional requirement, 

the base would have had to provide military personnel, jeopardizing its mission of 

training and developing the Iraqi Army 

At contingency operations base Shocker, the unexpected redeployment of Republic of 

Georgia soldiers created a requirement for security personnel to maintain a secure 

compound. 
7

Contract and Task Order Awards Well Supported 

The contract and task orders were mostly awarded under full and open competition, and the 

decision-making process was well-supported. The 5 contracts and 47 of the 50 task orders were 

competitively awarded. The three noncompetitively awarded task orders, worth $15.1 million, 

were appropriately justified as sole source awards. 

TWISS Contractors Were Selected Under Full and Open 

Competition 

Contractors performing under the TWISS contracts were selected under full and open 

competition. The government’s evaluation of the proposals appears to be thorough and well 

documented. As part of the award process, a Source Selection Evaluation Board reviewed all 

proposals and rated each on technical capability, past performance, past experience, Iraqi 

participation, and price. The five contractors that were awarded contracts were the top bidders 

based on JCC-I/A’s criteria. Although the awards were protested to the Government 

Accountability Office by one unsuccessful bidder, the protest was denied. 

On April 30, 2007, JCC-I/A initially issued the Request for Proposal, which stated that there 

would be multiple awards of indefinite delivery and indefinite quantity contracts with firm fixedprice task orders for a 1-year base period, with up to two 1-year options, to the companies whose 

solicitations would be most advantageous to the government. Proposals were submitted and 

rated based on the following five factors: 

Technical Capability: Describes how the company plans to meet the requirements 

included in the performance work statement. For example, the companies were required 

to address how they would provide high-quality force protection with up to 500 qualified 

guards. In addition, the government requested vetting, deployment, training, transition, 

and program management plans. 

Past Performance: Measures how well a company in the past 3 years has satisfied its 

customers and efficiently and effectively managed its contracts on projects of similar 

scope and magnitude. The companies were required to submit five relevant projects or 

contracts that addressed their abilities to perform in accordance with the statement of 

work. 

Past Experience: Assesses the capability of the company to perform based on the 

capabilities that the company currently possesses and will rely on to complete work under 

the contract, including training, familiarity in skill areas, and access resources to perform 

the job. In addition, the government requested information on a company’s years of 

experience, locations of work, logistics, experience in high security areas, and ability to 

deal with government restrictions in the United States and Iraq. 

Iraqi Participation: Demonstrates a company’s ability to meet the intent of the MultiNational Force – Iraq headquarter’s ―Iraqi-First‖ policy. Companies were required to 

submit a plan for how they would use, train, and transfer knowledge, skills, and abilities 

to an Iraqi workforce. 
8

Price: Provides cost analysis for performing the tasks under the statement of work, 

including component costs, ordering period costs, factors and assumptions in the cost, 

and verification of license. 

According to the Request for Proposal, past performance and past experience were 

approximately equal in weight and significantly more important than technical capability and 

Iraqi participation, which were equal in weight. The four factors combined were significantly 

more important than price. 

Offers were submitted by 15 companies. After a Source Selection Evaluation Board evaluated 

each company using the evaluation and rating assessment criteria in the solicitation, a 

competitive range was set and two companies were excluded from further proposals. Following 

the Board’s review, four of the five contractors that eventually won the contract were ranked in 

the top five. JCC-I/A then initiated discussions with the 13 remaining companies to identify 

deficiencies in their proposals and received revised proposals from each. The contracting officer 

reviewed the final proposals and determined that the proposals submitted by Aegis Defence 

Services, Limited; EOD Technology, Inc.; Sabre International Security; Special Operations 

Consulting-Security Management Group; and Triple Canopy, Inc., represented the best value for 

the government. In October 2007, one of the unsuccessful companies protested the bid to the 

Government Accountability Office, which denied the protest. According to JCC-I/A, while the 

protest delayed awarding TWISS task orders, installations still had immediate static security 

needs. As a result, JCC-I/A issued short-term Blanket Purchase Agreements until the task orders 

could be issued. The first TWISS task order was awarded in February 2008. 

Majority of Task Order Awards Are Competitively Awarded 

When awarding task orders, JCC-I/A requests proposals from all five TWISS contractors in 

accordance with Federal Acquisition Regulation 16.505 (b) (1) (i) ―Fair Opportunity.‖

9

 

Contractors then have the opportunity to submit proposals. Those proposals are evaluated by the 

contracting officer, who determines the awardee based on various factors, including price and 

past performance. 

Of the 50 task orders we reviewed, 47 were awarded under fair opportunity, and 3 task orders 

worth $15.1 million were sole source awards.10 All task orders had the necessary 

documentation—such as memorandums documenting the award, contractor proposals, and 

justification and approval documentation—to justify the award decisions. For one of the sole 

source awards, the task order was awarded to the contractor that was performing the work before 

TWISS was awarded. According to the justification, awarding the task order to a new contractor 

would cause unacceptable delays and increase operational risk while units were in rotation at the 

installation. Two task orders were protested on the basis that the winning contractor did not 

 

9

 FAR 16.505 (b) (1) (i) states that the contracting officer must provide each awardee a fair opportunity to be 

considered for each order exceeding $3,000 issued under multiple delivery-order contracts or multiple task-order 

contracts, except as provided in FAR 16.505 (b) (2). Exceptions include: urgency where fair opportunity would 

create unacceptable delays, only one awardee is capable of providing the supplies or services, economy and 

efficiency because it is a logical follow-on contract, or to satisfy a minimum guarantee. 

10 Of these task orders, five were initially awarded as part of the contract award minimum of $250,000. Four of the 

five initial task orders were modified to reflect competed task orders. 
9

possess a facilities clearance and was therefore ineligible for award. In both cases, the 

Government Accountability Office denied the protests. 
10

Vulnerabilities in Government’s Oversight

Weaknesses in the government’s oversight processes create vulnerabilities that could contribute 

to waste, fraud, or abuse. Generally, the CORs’ experience and training was limited, and their 

time available to devote to their oversight responsibilities insufficient. As a result, their abilities 

to perform their oversight responsibilities were hampered. For example, of 27 CORs responding 

to SIGIR questions, only 4 CORs said they had previous contracting experience, 11 said that 

their training was insufficient to meet their job requirements, and 6 said that additional duties 

prevented them from conducting adequate oversight. Although DCMA Quality Assurance 

Representatives’ inspections help provide oversight, they are periodic and not a substitute for the 

day-to-day oversight provided by CORs who oversee task orders ranging from $179.0 thousand 

to $22.2 million. 

Contracting Officer Representatives Oversight Hampered 

The installation command assigns a COR for each task order to be the eyes and ears of the 

installation commander and the contracting officer. Overall, the COR is to monitor the 

contractor’s performance and compliance with contractual requirements, including compliance 

with all applicable laws, regulations, orders, and directives. Furthermore, the COR is responsible 

for validating invoices for payment submitted by the contractor. In addition to the above COR 

duties, TWISS CORs are also responsible for ensuring that PSCs adhere to arming requirements, 

personnel reporting systems, serious incident reporting systems, badging, and compliance with 

MNF-I fragmentary orders. According to DCMA, most CORs spend at least 6 months on these 

duties before they are reassigned to other jobs. SIGIR provided questions to all 50 TWISS 

CORs and received responses from 27. Based on the 27 responses: 

Prior Experience: Four had previous contracting experience. Twenty seven CORs 

received their training on COR duties after they arrived in Iraq. 

Training: Eleven stated that the training provided did not fully prepare them for their 

responsibilities in overseeing PSCs. CORs receive initial training in Trafficking in 

Persons, a 40-hour online course by the Defense Acquisition University, and in some 

cases an additional class provided by JCC-I/A. Furthermore, eight CORs stated that 

training specific to private security contractors would be helpful. Fifteen CORs stated 

that they learned their duties from on the job training from their predecessor when 

available, the DCMA Quality Assurance Representative, or even the contractor that they 

are overseeing. 

Additional Duties: Six CORs assigned to oversee the task orders have additional duties 

and contracts that prevent them from conducting adequate oversight of the TWISS 

contractors. While MNF-I requires that CORs have contract oversight as their primary 

function, this is not necessarily the case. For example, one COR noted that his primary 

duty is that of a platoon leader. In addition, he is responsible for overseeing other 

contracts. As a result, he is able to devote about 40% of his time to overseeing the 

TWISS task order. Another COR, who is in charge of one of the largest TWISS task 

orders, stated that he spends about 50% of his time on TWISS and six other services’
11

contracts. In both cases, the CORs felt that their additional duties prevented them from 

dedicating the necessary time to oversee the PSCs. 

Six CORs were able to balance their duties when they were also involved with 

installation security. For example, one COR whose duties involve installation security 

said that he was able to adequately meet his COR responsibilities despite his other duties 

because they were interrelated. 

Three of the TWISS contractors we spoke with stated that CORs are often ill-prepared for 

their tasks. For example, one contractor stated that in the majority of cases, CORs’ 

knowledge of contracting and responsibilities has been limited. In addition, 2 

contractors noted that CORs are often late in signing the invoices or filled them out 

incorrectly, leading to up to 3 month delays in payment to the contractor. 

DCMA Quality Assurance Representatives 

As noted earlier, DCMA uses Quality Assurance Representatives to perform periodic inspections 

of the PSCs’ performance and compliance with requirements. Most task orders are assigned a 

Quality Assurance Representative, who is required to (1) develop inspection checklists, (2) 

perform independent assessments, (3) provide training to the COR, (4) conduct COR validation 

audits, and if necessary (5) submit corrective action requests to document a contractor’s 

noncompliance. 

According to DCMA officials, these inspections are usually performed once a month or with 

greater frequency based on the level of risk. Between November and December 2008, we 

accompanied Quality Assurance Representatives on three quality assurance reviews. We 

observed that these visits were beneficial to the oversight process. Specifically, on one of our 

visits, we observed that the Quality Assurance Representative identified an instance where the 

contractor failed to perform in accordance with the contract’s requirements. Further, we noted 

the COR had not been aware that the number of personnel in the contractor’s operations center 

was not in accordance with the statement of work. 
12

Conclusions and Recommendations 

Conclusions 

Between February 2008 and March 2009, DoD had spent $154.6 million on the TWISS 

contracts. Almost all contracts and task orders were awarded under full and open competition, 

with a well-supported decision-making process. Full and open competition has lowered the costs 

of these services. 

The experience, training, and additional duties of CORs providing oversight of the TWISS 

contracts is another example of the difficulties experienced when the U.S. military lacks the 

capacity to manage its contractors in a contingency environment. Selecting CORs with limited or 

no direct contract management experience, providing them training on the job or on an ad hoc 

basis, and then assigning them other principal duties, increases the government’s vulnerability. 

Moreover, in looking forward, difficulties in managing these contracts could easily be 

exacerbated as the U.S. military draws down its presence in Iraq and thus its available pool of 

experienced personnel to perform these functions. Furthermore, with the addition of the 

upcoming TWISS II, the TWISS contracts will grow in size to a potential $935 million. Such a 

situation would make these contracts even more vulnerable to fraud, waste, and abuse. 

Recommendations 

SIGIR recommends that to improve contract administration and oversight, the Commanding 

General, Multi-National Corps-Iraq; Director of the Defense Contract Management Agency; and 

the Commander of the Joint Contracting Command-Iraq/Afghanistan direct that the following 

actions be taken as they relate to their respective responsibilities under the contract: 

1. Provide additional training to Contracting Officer Representatives on their private 

security contractor oversight responsibilities with regard to the TWISS contracts. 

2. Assess the workload for Theater-Wide Internal Security Services Contracting Officer 

Representatives to identify actions that can be taken to balance workload demands so that 

sufficient time can be given to contract oversight responsibilities. 

Management Comments and Audit Response 

Multi-National Force-Iraq (MNF-I) and the Defense Contracting Management Agency (DCMA) 

generally agreed with the report recommendations. Specifically, both agencies agreed on the 

need for additional training and workload assessments for Contracting Officer Representatives 

(CORs) and to take actions to address SIGIR’s recommendations. 

Concerning recommendation 1, MNF-I stated that Joint Contracting Command –

Iraq/Afghanistan (JCC-I/A), in conjunction with DCMA, will reach out to CORs to provide 

targeted training in areas that CORs perceive to be their individual weaknesses. DCMA stated 

that some aspects of training are the responsibility of the COR’s unit and DCMA’s responsibility 

is training related to contract administration oversight and specific contract familiarity. DCMA 
13

stated that as a result of a review it performed in March 2009, DCMA plans to improve future 

COR training sessions by more directly involving the DCMA Administrative Contracting Officer 

and Quality Assurance staff in the instruction. 

With regards to recommendation 2, MNF-I stated that while the requiring activity is responsible 

for nominating CORs based on individual qualifications and abilities, JCC-I/A will work with 

the requiring activities to ensure that they understand the responsibilities demanded of CORs. 

MNF-I also stated that JCC-I/A will work with requiring activities to recommend CORs who 

have prior experience with contract oversight and/or be familiar with the function. DCMA 

concurred with the need to assess COR workload. DCMA has recognized a gap in the number of 

assigned CORs in the Iraq and Afghanistan areas of operation. It stated this gap includes CORs 

with specialized skills that are not core competencies within DCMA. It further stated that 

DCMA is working with the DoD Joint Staff to address this issue. 

MNF-I also provided technical comments, which SIGIR incorporated as appropriate. SIGIR 

believes that the actions identified by management, if properly implemented, are responsive to 

the report’s recommendations.
14

Appendix A—Scope and Methodology 

In August 2008, the Special Inspector General for Iraq Reconstruction (SIGIR) initiated Project 

8032 to examine the Department of Defense’s (DoD) Theater-Wide Internal Security Services 

(TWISS) contracts with Aegis Defence Services, Limited; EOD Technology, Inc.; Sabre 

International Security; Special Operations Consulting-Security Management Group; and Triple 

Canopy, Inc. The reporting objectives for this report are to identify (1) the costs of the contracts; 

(2) the requirements for the static security forces; (3) the government’s process for awarding the 

contracts, task orders, and modifications; and (4) the oversight provided by the CORs. SIGIR 

plans to review the government’s oversight of the contractors’ bills, performance, operations, 

and processes for screening, selecting, and training its personnel. These issues will be the 

subject of subsequent reviews that will be announced as separate projects at a later date. 

To identify the costs of the contract, we examined the contracts and task orders issued under 

TWISS. We identified costs in the contract by the line item listed in each task order and 

modification. To obtain expenditure information, we relied on information from the Defense 

Contract Management Agency (DCMA). To estimate the cost of government provided lifesupport, we obtained a daily/per person rate charged to the government under the Logistics Civil 

Augmentation Program contract. We used that rate and the number of TWISS personnel 

estimated to be on the contract to compute a daily rate. We then projected that to an estimated 

yearly rate based on the need for such services 365 days a year. 

To review the government’s requirements for contracted static security forces, we reviewed 

requirements documentation submitted by the installations requesting the services. In addition, 

we sent questions to all contracting officer representatives (CORs) and received responses 

from 27. 

To evaluate the contracting process, we examined available documents pertaining to (1) 

government evaluations of contractor proposals, (2) bid protests, and (3) contractor proposals. 

To review whether or not fair opportunity was granted for each task order, we reviewed contract 

documentation. When fair opportunity provisions for task orders were not used, we reviewed the 

contract documentation to ensure that Federal Acquisition Regulations were followed. In 

addition, we spoke with Joint Contracting Command – Iraq/Afghanistan (JCC-I/A) contracting 

officers, DCMA, and TWISS contractors. 

To review the level of oversight performed by the government; we reviewed MNF-I, DCMA, 

and JCC-I/A regulations and guidance regarding COR responsibilities. We reviewed COR 

training materials by JCC-I/A and DCMA. We sent questions to all TWISS CORs and received 

responses from 27. In addition, we attended three DCMA quality assurance reviews in the 

International Zone. 

This audit was performed by SIGIR under the authority of Public Law 108-106, as amended, 

which also incorporates the duties and responsibilities of inspectors general under the Inspector 

General Act of 1978. It was conducted in accordance with generally accepted government 

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

sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 
15

based on our audit objectives. We believe that the evidence obtained provides a reasonable basis 

for our findings and conclusions based on our audit objectives. 

Use of Computer-Processed Data 

We obtained obligation data from the Joint Contracting Command – Iraq/Afghanistan. In order 

to validate the information provided by JCC-I/A, we compared their data with information 

compiled from the task orders themselves. In addition, we relied on DCMA invoice data for 

expenditures. We relied on that system as the official source because it is the most complete 

source for such data. We selected a judgmental sample of data and tested it against payment 

information from the Defense Finance and Accounting Service and found it to be accurate. 

Internal Controls 

We conducted a limited review of the specific controls used in managing and administering the 

TWISS contracts. We focused on the contract oversight controls related to COR and DCMA 

oversight. We also reviewed controls related to contract award and oversight. 

Prior Coverage 

We reviewed the following applicable reports issued by SIGIR, the Government Accountability 

Office (GAO), and the Congressional Research Service:

Special Inspector General for Iraq Reconstruction 

Oversight of Aegis' Performance on Security Services Contracts in Iraq with the Department of 

Defense, SIGIR-09-010, 1/14/2009. 

Agencies Need Improved Financial Data Reporting for Private Security Contractors, SIGIR-09-

005, 10/30/2008. 

U.S. Government Accountability Office 

Rebuilding Iraq: DOD and State Department Have Improved Oversight and Coordination of 

Private Security Contractors in Iraq, but Further Actions Are Needed to Sustain Improvements, 

GAO-08-966, 7/ 31/ 2008.

Rebuilding Iraq: Actions Still Needed to Improve the Use of Private Security Providers, GAO06-865T, 6/13/2006.

Rebuilding Iraq: Actions Needed to Improve Use of Private Security Providers, GAO-05-737, 

7/28/2005.

Congressional Research Service 

Private Security Contractors in Iraq: Background, Legal Status, and Other Issues, 8/25/2008.

Private Security Contractors in Iraq: Background, Legal Status, and Other Issues, 7/11/2007.
16

Appendix B—Acronyms 

Acronym Definition

COR Contracting Officer Representative

DCMA Defense Contract Management Agency

DoD Department of Defense

JCC-I/A Joint Contracting Command-Iraq/Afghanistan

MNF-I Multi-National Force - Iraq

PSC Private Security Contractor

SIGIR Special Inspector General for Iraq Reconstruction

TWISS Theater-Wide Internal Security Services
17

Appendix C—Audit Team Members 

This report was prepared and the review was conducted under the direction of David R. Warren, 

Assistant Inspector General for Audit, Office of the Special Inspector General for Iraq 

Reconstruction. 

The staff members who conducted the audit and contributed to the report include: 

Daniel Chen 

Robert L. Pelletier 

Lovell Walls 
18

Appendix D—Management Comments 

Multi-National Force – Iraq 
19
20
21

Management Comments 

Defense Contract Management Agency 
22
23

SIGIR’s Mission Regarding the U.S. reconstruction plans, programs, and 

operations in Iraq, the Special Inspector General for Iraq 

Reconstruction provides independent and objective:

oversight and review through comprehensive audits, 

inspections, and investigations

advice and recommendations on policies to promote 

economy, efficiency, and effectiveness

deterrence of malfeasance through the prevention and 

detection of fraud, waste, and abuse

information and analysis to the Secretary of State, the 

Secretary of Defense, the Congress, and the 

American people through Quarterly Reports

Obtaining Copies of SIGIR 

Reports and Testimonies

To obtain copies of SIGIR documents at no cost, go to 

SIGIR’s Web site (www.sigir.mil).

To Report Fraud, Waste, and 

Abuse in Iraq Relief and 

Reconstruction Programs

Help prevent fraud, waste, and abuse by reporting 

suspicious or illegal activities to the SIGIR Hotline:

Web: www.sigir.mil/submit_fraud.html

Phone: 703-602-4063

Toll Free: 866-301-2003

Congressional Affairs Hillel Weinberg

Assistant Inspector General for Congressional

 Affairs

Mail: Office of the Special Inspector General

 for Iraq Reconstruction

 400 Army Navy Drive

 Arlington, VA 22202-4704

Phone: 703-428-1059

Email: hillel.weinberg@sigir.mil

Public Affairs Daniel Kopp

Director for Public Affairs

Mail: Office of the Special Inspector General

 for Iraq Reconstruction

 400 Army Navy Drive

 Arlington, VA 22202-4704

Phone: 703-428-1217

Fax: 703-428-0818

Email: PublicAffairs@sigir.mil