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SIGIR 

Special Inspector General for IRAQ Reconstruction 

For more information, contact SIGIR Public Affairs at 

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

Summary of Report: SIGIR 10-003 

Why SIGIR Did this Study 

In April 2008, the Multi-National Force-Iraq 

(MNF-I) and the Government of Iraq (GOI) 

signed a memorandum of understanding (MOU) 

establishing the Iraq Commander’s Emergency 

Response Program (I-CERP). Since then, 

approximately $229 million of the initial 

$270 million allocated for I-CERP has been 

obligated. Under I-CERP, MNF-I executes GOI 

funds for reconstruction and other projects for 

the benefit of Iraqi citizens. 

The objectives of this report are to examine the 

extent to which MNF-I met the terms of the 

MOU with GOI and the extent to which MultiNational Corps-Iraq (MNC-I) has maintained 

I-CERP project records in accordance with 

requirements. The Special Inspector General for 

Iraq Reconstruction (SIGIR) and Iraq’s Board of 

Supreme Audit (BSA), agreed to conduct a joint 

review of I-CERP; however, in July 2009, BSA 

issued a separate I-CERP report. 

What SIGIR Recommends 

SIGIR recommends that the Commanding 

General, MNF-I, improve I-CERP program 

management by 1) requiring major subordinate 

commands to provide comprehensive 

information on all completed I-CERP projects 

with a value of at least $50,000, and 

2) determining if there is a continuing need to 

train Iraqi security forces and provincial 

government personnel to manage the I-CERP 

program, as required in the MOU. 

SIGIR also recommends that the Commanding 

General, MNC-I, improve I-CERP 

accountability and oversight by 3) clarifying the 

2010 guidance revision and specifying which 

documents must be included in I-CERP project 

files; and 4) requiring MNC-I to review I-CERP 

project files for compliance with existing 

guidance. 

Management Comments and Review 

Response 

MNF-I deferred comments to MNC-I. MNC-I 

concurred with four of the report 

recommendations but did not concur with a 

draft recommendation that it establish a system 

for tracking I-CERP project file location. 

MNC-I stated that such guidance was in its 

budget execution guidance. SIGIR dropped 

this recommendation. 

October 27, 2009 

IRAQ COMMANDER’S EMERGENCY RESPONSE PROGRAM 

GENERALLY MANAGED WELL, BUT PROJECT DOCUMENTATION AND 

OVERSIGHT CAN BE IMPROVED

What SIGIR Found 

MNF-I has generally managed the I-CERP program in accordance 

with the terms in the MOU by allocating projects to provinces as 

required and building the type of infrastructure stipulated in the MOU. 

Moreover, MNC-I data indicates that MNF-I is accounting for how 

the funds are used and disbursed. Nevertheless, MNF-I can improve 

the thoroughness of the quarterly reports it is providing GOI, 

particularly for those projects valued at $50,000 or more. In these 

cases, MNF-I provided detailed project information, called 

storyboards, on only 206 of the 347 projects and some of these lacked 

detailed project information, such as funds obligated and expended, 

project number to help identify the activity, and U.S. and GOI 

officials. Moreover, sustainment letters, which MNF-I and GOI sign 

at project initiation and document GOI support for a project, were 

missing in 13 storyboards. When sustainment letters were included, 

over 20 lacked a GOI signature and over 30 lacked a U.S. military 

signature. In addition, MNF-I has not met the MOU requirement to 

train GOI officials to manage the program and transfer I-CERP 

management to them. Officials cite the lack of additional GOI 

funding to maintain the program in the long term as a reason why this 

training has not and should not take place. 

Despite efforts to improve accountability and documentation of the 

I-CERP program, numerous MNC-I project files lack critical internal 

control documentation due to insufficient MNC-I oversight and 

unclear and incomplete guidance on document requirements. In some 

cases, project files lacked essential internal control documents such as 

receipts for cash payments and electronic funds transfers. To 

illustrate, of the 103 files we sampled, 89 lacked receipts for payments 

made in cash. Moreover, MNC-I has not provided the oversight 

necessary to ensure that U.S. military units are documenting these 

critical management actions and decisions and including them in 

project files. These inconsistencies are caused by unclear guidance. 

As a result, these projects are vulnerable to fraud, waste, and abuse. 

Iraq’s BSA also reported U.S. data to be incomplete, thereby 

hindering GOI’s oversight of U.S.-managed programs like I-CERP. 

SIGIR did not review the BSA report for accuracy. 
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

400 Army Navy Drive • Arlington, Virginia 22202 

October 27, 2009 

MEMORANDUM FOR COMMANDING GENERAL, MULTI-NATIONAL FORCE-IRAQ 

COMMANDING GENERAL, MULTI-NATIONAL CORPS-IRAQ 

SUBJECT: Iraq Commander’s Emergency Response Program Generally Managed Well, but 

Project Documentation and Oversight Can Be Improved (SIGIR 10-003) 

We are providing this report for your information and use. The report discusses our review of 

the Iraq Commander’s Emergency Response Program (I-CERP). We performed this review in 

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

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

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

operations funded with amounts appropriated or otherwise made available for the reconstruction 

of Iraq, and for recommendations on related policies designed to promote economy, efficiency 

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

SIGIR Project 9018. 

The Multi-National Force-Iraq deferred comments to the Multi-National Corps-Iraq. We 

considered comments from the Chief of Staff, Multi-National Corps-Iraq when preparing this 

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

Appendix F of this report. 

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

please contact David Warren, Assistant Inspector General for Audits, (703) 604-0982/ 

david.warren@sigir.mil, or Glenn Furbish, Principal Deputy Assistant Inspector General for 

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

Stuart W. Bowen, Jr. 

Inspector General 

cc: U.S. Secretary of State 

U.S. Ambassador to Iraq 

U.S. Secretary of Defense 

Commander, U.S. Central Command 
Table of Contents 

Introduction 1

Background 1

Responsible Organizations 3

Objectives 3

MOU Requirements Generally Met, but Documentation and Training Issues 

Remain 4

MOU Terms Are Generally Being Met 4

Quarterly Reports Provided to GOI but Could Be More Complete 9

Plans to Meet MOU Training and Transition Requirements Are Uncertain 9

Project Documentation and Oversight Need Improvement 11

Project Files Lack Documentation 11

MNC-I Has Not Provided Timely Oversight 12

Some MAAWS’ Accountability Requirements Remain Unclear 13

BSA Reports Incomplete Data Provided by United States 16

Conclusion and Recommendations 17

Conclusion 17

Recommendations 17

Management Comments and Review Response 18

Appendix A—Scope and Methodology 20

Appendix B—File Review Checklist Results 23

Appendix C—BSA Report 25

Appendix D—Acronyms 30

Appendix E—Review Team Members 31

Appendix F—Management Comments 32

Appendix G—SIGIR Mission and Contact Information 35
1 

Iraq Commander’s Emergency Response Program 

Generally Managed Well, but Project Documentation and 

Oversight Can Be Improved

SIGIR 10-003 October 27, 2009

Introduction 

In April 2008, the Multi-National Force-Iraq (MNF-I) and the Government of Iraq (GOI) signed 

a memorandum of understanding (MOU) initiating the Iraq Commander’s Emergency Response 

Program (I-CERP). Under the MOU, MNF-I is to complete urgent reconstruction projects to aid 

Iraqi citizens in the 15 provinces not under the Kurdish Regional Government using GOI funds 

and existing coalition spending mechanisms managed by the Multi-National Corps-Iraq 

(MNC-I). Initially, GOI indicated it would provide $300 million for I-CERP-related projects, 

but decreased that amount by 10% ($30 million)1

 at the time it signed the MOU. In May 2009, 

the Special Inspector General for Iraq Reconstruction (SIGIR) and Iraq's Board of Supreme 

Audit (BSA), agreed to conduct a joint review of I-CERP. On July 16, 2009, BSA issued a 

report titled, “Review and Audit of the Projects Executed by the U.S. [Corps] of Engineers.” See 

Appendix C for a copy of this report. 

Background 

The I-CERP MOU between MNF-I and Iraq’s Supreme Reconstruction Council of the 

Secretariat of the Council of Ministries defines the purpose of the program and the 

responsibilities of both MNF-I and GOI. It requires that MNF-I expend I-CERP funds using the 

procedures, project purchasing officers,2 paying agents,3 and accountability mechanisms already 

established for the Commander’s Emergency Response Program (CERP). In addition, the MOU 

requires that I-CERP funds be distributed among the provinces commensurate with the 

population of each province. Finally, the MOU requires that MNF-I report the I-CERP program 

status to GOI on a quarterly basis and train Iraqi security forces to enable them to manage 

I-CERP.

I-CERP projects are to be executed using the procurement, disbursement, and accountability 

mechanisms in the existing CERP program. The CERP program is guided by the policy and 

procedures manual titled Money as a Weapon System (MAAWS) issued by MNC-I for the first 

time in October 2005. In May 2008, MNC-I issued a revised version of the MAAWS that 

included standard operating procedures for I-CERP, supplementing the CERP guidance that also 

applies to I-CERP. The MAAWS was subsequently revised in January 2009 and again in 

 

1

 This amount remains subject to transfer under the supervision of the Iraq Supreme Reconstruction Council. 2

 A project purchasing officer has the authority to procure services and supplies and is responsible for managing the 

individual I-CERP projects and maintaining project files. 

3

 A paying agent receives and disburses I-CERP project funds and cannot also serve as the project purchasing 

officer. 
2 

September 2009. MNC-I officials told us that they plan another revision to the MAAWS, with 

an expected release of January 2010. The manual lists five types of projects eligible, without 

exception, for I-CERP funding. An additional four project types are eligible by exception if 

approved by the commanding general of the responsible major subordinate command (MSC), as 

shown in Table 1. No other project types are eligible for I-CERP funds. 

Table 1—Project Types Available for I-CERP Funds 

Projects Allowed Without Exception 

Water purification plants 

Schools – projects to repair or reconstruct schools 

Health clinics – projects to repair or reconstruct hospitals or clinics 

City planning facilities – ministry offices, local government offices 

Protective measures necessary to secure otherwise permissible I-CERP projects such as 

fencing, light, berms, or barriersa

Projects Allowed by Exception 

Roads 

Sewers 

Irrigation 

Nonreconstruction projects that promote small business 

Notes: 

a The protective measures category was added in January 2009, but as of September 2009, no I-CERP projects have been completed under this 

project category. 

Source: MAAWS, September 2009. 

MNC-I’s MAAWS encourages U.S. military personnel to obtain the participation of Iraqi 

Provincial Reconstruction and Development Committees and U.S. Provincial Reconstruction 

Teams (PRT) for I-CERP projects. I-CERP differs from CERP in several ways, including (1) all 

I-CERP payments are to be made in Iraqi dinars, while CERP allows for payments in U.S. 

dollars, and (2) I-CERP has fewer allowable project types available for funding. MNF-I is 

required by the MOU and an MNF-I directive, called a fragmentary order,4 to provide various 

internal and external reports. The MOU requires that MNF-I provide GOI a quarterly report on 

I-CERP projects. MNF-I quarterly reports to GOI should include a list of all I-CERP projects as 

well as a storyboard for each project valued at $50,000 or more completed during the quarter. 

Storyboards are one-slide summaries of project details, including titles, descriptions, 

photographs or maps, completion dates, funding data, and names of GOI officials associated with 

 

4

 Fragmentary Order 08-166 provides I-CERP implementation guidance and includes the MOU as an annex to the 

order. The order was modified on September 8, 2008, to provide additional detail on reporting requirements and to 

change the recipient of reports from MNF-I’s Strategic Stewardship Council to MNF-I’s Chief of Staff. 
3 

projects, required by both fragmentary and MAAWS guidance. Storyboards also include a 

sustainment letter signed by a GOI and an MNF-I official.5

 

MNF-I requires that MSCs, which manage and implement I-CERP projects, provide internal 

reports to MNC-I on their progress. These reports must contain project tracking information on 

I-CERP projects, including a unique requirement identifier, unit, project category, and funding 

data. 

Responsible Organizations 

MNF-I, headquartered in Baghdad, negotiated the terms of the MOU with GOI, coordinates with 

GOI on I-CERP issues, and provides GOI quarterly reports. MNF-I also develops guidance for 

I-CERP through orders to subordinates. 

MNC-I, also headquartered in Baghdad, coordinates and oversees projects and documentation of 

I-CERP with its four MSCs headquartered throughout Iraq: Multi-National Division – South 

(MND-S), Multi-National Division – North (MND-N), Multi-National Division – Baghdad 

(MND-B), and Multi-National Force – West (MNF-W). Each MSC is responsible for proposing 

and executing I-CERP projects in its area of responsibility, and Brigade Combat Teams, assigned 

to the MSCs, are responsible for day-to-day management of I-CERP projects. MNC-I also is 

responsible for revising MAAWS guidance. 

Objectives 

The objectives of this report are to examine the extent to which MNF-I met the terms of the 

MOU with GOI and the extent to which MNC-I has maintained I-CERP project records in 

accordance with requirements. This report also contains results of the BSA review of the 

I-CERP program. 

For a discussion of the scope and methodology, see Appendix A. For a complete list of SIGIR’s 

review of I-CERP project files, see Appendix B. For a copy of BSA’s report, see Appendix C. 

For a list of acronyms used in the report, see Appendix D, and for a list of the review team 

members, see Appendix E. For a copy of MNC-I’s comments, see Appendix F. For the SIGIR 

mission and contact information, see Appendix G. 

 

 

5

 The sustainment letter is to be signed by an Iraqi official before a project commences and include a statement that 

the relevant Iraqi official acknowledges the need for the project and intends to operate and maintain the facility after 

completion. 
4 

MOU Requirements Generally Met, but 

Documentation and Training Issues Remain 

MNF-I is generally managing the I-CERP program as required in the MOU with Iraq by 

allocating projects to provinces and building the types of infrastructure projects stipulated in the 

MOU. Moreover, MNC-I data indicates that MNF-I is accounting for how the funds are used 

and disbursed. Nevertheless, MNF-I’s quarterly reports to GOI lack detailed project information 

about funds obligated and expended for specific activities and U.S. and GOI officials responsible 

for the program. Further, MNF-I has not trained GOI officials to manage the program and 

transferred I-CERP management to them as required by the MOU. Officials cite the lack of 

additional GOI funding to maintain the program in the long term as a reason why this training 

has not and should not take place. 

MOU Terms Are Generally Being Met 

MNF-I has met several key terms of the April 2008 MOU with GOI as demonstrated by 

MNC-I’s data, which indicates that it properly allocated funds, is using funds for the intended 

purposes, and is accounting for how the funds are expended. The MOU requires MNF-I to 

distribute funds according to population among the 15 provinces that do not fall under the 

Kurdish Regional Government and to focus on specific types of reconstruction projects. To 

ensure that funding would be appropriately divided, MNF-I established a percentage of I-CERP 

funding for each province, and how much money would therefore be allocated to each province. 

The distribution and allocations of I-CERP are shown in Table 2 below. 
5 

Table 2—I-CERP Project Allocations, by Province 

Province 

Agreed upon I-CERP 

Allocation

Share of $270M 

Allocation

Anbar 5.5% $14,850,000

Babylon 6% 16,200,000

Baghdad 26.5% 71,550,000

Basrah 9.2% 24,840,000

Diyala 5% 13,500,000

Kerbala 3.5% 9,450,000

Missan 3.6% 9,720,000

Muthanna 2.5% 6,750,000

Najaf 4.3% 11,610,000

Ninewa 10.7% 28,890,000

Qadissiya 4% 10,800,000

Salah al Din 4.4% 11,880,000

Tameem 4.3% 11,610,000

Thi Qar 6.5% 17,550,000

Wassit 4% 10,800,000

Total 100% $270,000,000

Source: MNF-I FRAGO 08-166, 4/16/2008, and MNC-I data, 5/20/2009. 

In addition, MNF-I focused I-CERP projects on reconstruction as required in the MOU. The 

MOU provides examples of approved project categories, including schools, health clinics, and 

roads. It also states that I-CERP projects should create small business opportunities for Iraqis. 

MNF-I’s fragmentary order for I-CERP established approved categories and listed some 

prohibited categories such as direct or indirect benefit to U.S., coalition, or other supporting 

personnel, entertainment, and weapons buyback programs.6 Table 3 provides information on 

total I-CERP funding, project type, and number of projects. 

 

6

 MNF-I’s fragmentary order established seven approved categories for I-CERP projects. MNC-I’s May 2008 

MAAWS added an additional category to include opportunities for small businesses. In January 2009, the MNC-I 

added a category for protective measures to ensure the security of ongoing I-CERP projects. 
6 

Table 3—I-CERP Funding and Projects by Category 

Project type Committed Obligated Disbursed 

Number of 

Projects

City Planning Facilities $9,850,757.24 $9,843,592.24 $4,811,783.61 63

Health Clinics 8,655,634.08 8,384,384.08 5,664,297.70 60

Irrigation 4,527,786.79 4,527,786.79 3,376,102.55 27

Protective Measures - - - -

Roads 70,882,991.07 69,920,711.07 37,738,025.01 134

Schools 86,991,108.55 82,183,312.36 55,370,618.09 373

Sewer 9,129,008.98 9,093,008.98 4,512,934.97 21

Small Business Grants 4,458,574.43 4,259,889.35 3,787,511.63 233

Water Treatment 

Facilities 42,193.462.43 40,731,582.43 24,102,853.17 199

Total $236,689,323.57 $228,944,267.30 $139,364,126.73 1,110

Source: SIGIR Analysis of MNC-I data, 9/1/2009. 

MNF-I is also accounting for I-CERP funds through a tracking spreadsheet. As of 

September 1, 2009, MNF-I had obligated approximately $229 million of the $270 million 

available for I-CERP and reports completing over 800 I-CERP projects. MNC-I’s tracking 

spreadsheet is based on monthly reports from the MSCs and includes financial tracking data, 

funding details, and project status for all I-CERP projects. MNC-I’s tracking system accounts 

for all of the approximately $229 million obligated as well as the approximately $140 million 

that has been disbursed. 

Figures 1 through 4 illustrate some of the I-CERP projects MNF-I has implemented. 

Figure 1 shows before and after photos of an I-CERP educational warehouse refurbishment 

project in Ramadi, Anbar. This project costing approximately $170,439 consisted of renovating 

the interior and exterior of a five-room warehouse measuring 10,000 square feet and four office 

spaces measuring 3,000 square feet. The warehouse is now available for the Director General of 

Education to store supplies for the school system in Ramadi. This project also included a backup 

generator as well as sanitation and potable water systems tied into the municipal system. 
7 

Figure 1—Refurbished Ramadi Educational Warehouse 

 

Source: MNF-I storyboard, September 2008. 

Figure 2 shows the refurbishment of an elementary school in Sadr City. MNF-I spent $106,460 

in I-CERP funds to refurbish the school that serves 425 boys. The project included the 

renovation of all rooms, replacement of doors and windows, and connection of the building to 

the national power grid.

Figure 2—Al Nahreen School Refurbishment 

 

Source: MNF-I storyboard, December 2008. 

As shown in Figure 3, I-CERP projects have also included improvements in infrastructure. The 

construction of the water culvert in Tameem province cost $76,500. The culvert provides a 

faster route to markets along the road above for Shia Turkomen and Sunni Arabs in the area. 

Before After 

Before After 
8 

Figure 3—Qassabat Bashaar Water Culvert 

Source: MNF-I storyboard, March 2009. 

Figure 4 illustrates the I-CERP project to purchase and install pumps, electrical equipment, and a 

water pipe as well as repair to the existing pipe. This facility in Salah al Din will provide the 

local population with potable drinking water, improve the water distribution infrastructure, aid 

against the continuing drought, and decrease the risk of infection and disease during the summer 

months. 

Figure 4—Al Fadoos Water Treatment Plant 

 

Source: MNF-I storyboard, June 2009. 

After 

After During 
9 

Quarterly Reports Provided to GOI but Could Be More Complete 

MNF-I addressed the MOU reporting requirements by establishing a progress report format in 

September 2008. Each quarter, MNF-I provides GOI with a list of all I-CERP projects. In 

October 2008, MNF-I submitted to GOI the first quarterly report, which contained a database of 

all I-CERP projects as well as some storyboards for completed projects valued at $50,000 or 

more. Since then, MNF-I has submitted three more reports, and it is required to submit a fifth 

report to GOI in October 2009. 

Although MNF-I provides quarterly reports to GOI, not all of them have included the 

information that is stipulated in guidance. The MOU requires MNF-I to provide a quarterly 

I-CERP status report but does not specify what these reports must contain. In September 2008, 

MNF-I modified their fragmentary order requiring MSCs to provide storyboards along with its 

quarterly reports to GOI. Storyboards are required for projects costing at least $50,000 and 

completed in the current quarter. Moreover, a sustainment letter signed by both a GOI and U.S. 

official must accompany each storyboard. 

While MNF-I meets the requirement to provide GOI a comprehensive list and status of I-CERP 

projects, MNF-I has not provided all the storyboards for completed projects with a value of at 

least $50,000 in the time required. SIGIR found that as of July 2009, MNF-I should have 

provided a total of 347 storyboards to GOI but provided only 206, of which only 156 represented 

completed projects valued at $50,000 or more. MNC-I was able to provide SIGIR an additional 

42 storyboards that were missing from the quarterly reports but was unable to provide detail for 

the rest. MNC-I officials told us that the storyboards were missing because of high turnover in 

units and action officers, and they plan to provide the 42 previously missing storyboards to 

MNF-I to include in their next quarterly report for the quarter ending September 30, 2009. 

In addition, the storyboards submitted to GOI did not consistently provide sufficient information 

to permit necessary U.S. and GOI oversight of the projects. SIGIR’s review of the 

206 storyboards submitted to GOI shows that some required information was missing. Over 

140 storyboards did not include telephone numbers for GOI points of contact, and of those more 

than 50 did not include the name of a GOI official point of contact. Information on funds 

committed, obligated, and disbursed was missing from 28 of the storyboards. Moreover, 

15 storyboards cited incorrect project numbers, called unique requirement identifiers, which 

would allow both the United States and GOI to accurately identify the project. Sustainment 

letters were missing from 13 storyboards. Of the storyboards that included sustainment letters, 

over 20 lacked a GOI signature and over 30 lacked a U.S. military official’s signature. 

Plans to Meet MOU Training and Transition Requirements Are 

Uncertain 

MNC-I and MSC officials informed us that they have not begun to train Iraqi officials to assume 

responsibility for the management of the I-CERP program and do not know if this training will 

ever begin. One official suggested that the program may originally have been envisioned as a 

long-term joint effort with GOI to include more GOI funding. However, to date, additional GOI 

funding has not materialized, and the United States has already obligated most of the 

$270 million provided. This official suggested that it is not clear if the I-CERP program will 
10 

continue and therefore whether training GOI and transitioning management responsibilities of 

the program to GOI is necessary. In written comments on a draft of this report, MNC-I stated 

that the original agreement between the U.S. government and GOI was to encourage additional 

GOI funding beyond the $270 million provided and U.S. officials would provide training in 

executing those additional funds. According to MNC-I, no training has or should take place, 

since no new funds were provided. 

 
11 

Project Documentation and Oversight Need 

Improvement 

Despite efforts to improve accountability and documentation of the I-CERP program, project 

files are missing critical internal control documentation. In some cases project files lacked 

documents such as receipts for cash payments and electronic funds transfers. Moreover, MNC-I 

has not provided the oversight necessary to ensure that U.S. military units are documenting these 

critical management actions and decisions and including them in project files. These 

inconsistencies are caused by unclear guidance. As a result these projects are vulnerable to 

fraud, waste and abuse. 

Project Files Lack Documentation 

SIGIR judgmentally selected for review more than 10% of all completed project folders and 

more than 25% of project dollars for each MSC. Although MNC-I provided files on almost all 

projects, SIGIR found that those files provided were generally incomplete. Moreover, SIGIR 

found similar results in the files for the top three highest value ongoing I-CERP projects at each 

MSC. MNC-I’s MAAWS guidance contains a checklist and other required documentation for 

I-CERP project files. This guidance applies to all four MSCs; however, a checklist review of 

files reveals missing documentation in a variety of categories at each MSC.7 

SIGIR’s review sample included 103 of the 688 projects completed as of June 1, 2009 and 

$37 million of the $89 million obligated for those projects. Of the 103 files SIGIR reviewed, 

MNC-I was able to provide some required documentation for all but one completed project. This 

is an improvement from prior SIGIR reviews of CERP. For example, SIGIR issued a report in 

April 2007, noting that of the 173 files requested for the sample, MNC-I could provide only 122, 

or approximately 70%, of the files.8

 

From the files reviewed, SIGIR analyzed the extent to which each contained the documents 

required in the MAAWS checklist. Table 4 illustrates the documentation most frequently 

missing from the I-CERP files. 

 

7

 See Appendix A for a description of SIGIR’s scope and methodology of the project sampling and file review 

process. 

8 Management of Commander’s Emergency Response Program in Iraq for Fiscal Year 2006, SIGIR 07-006, 

4/26/2007. 
12 

Table 4—Required Information Most Often Missing from Project Files 

MND-B MND-N MND-S MNF-W 

Sample Size 34 38 17 14 

Required by Checklist 

Electronic Funds Transfer 31 36 12 13 

Cash Receiptsa 28 37b 11 13 

Contract Completion 

Statement 12 23 14 13 

MSC Comptroller Clearance 31 1 12 0 

Legal Review 0 16 7 12 

Appointment Letter 22 4 13 14 

Appointment Record 20 5 10 14 

Notes: 

a Cash receipts are forms signed by the paying agent showing his or her receipt of cash on advance and proof of vouchers for payments made and 

any unused cash on return. SIGIR has combined those two instances into one record of whether or not files had these forms because most the 

MSCs had the same number missing on advance as on return. b MND-N files had more cash receipt records signed when cash was returned than when it was provided on advance. MND-N files lacked 37 

signed cash receipt forms on advance, and just 33 signed cash receipt forms on return. 

Source: SIGIR review of I-CERP project files, as of 6/1/2009. 

The project files lacked some of the documentation for electronic funds transfer payment 

requests, cash advances, and cash receipts, which is necessary to ensure proper cash 

accountability controls over project payment. SIGIR also found that in some instances, paying 

agents had used U.S. dollars for payments contrary to MAAWS guidance requiring electronic 

transfers, bank checks, or Iraqi dinars. Also missing from files were documents that attest that 

the contract was completed (completion memorandum signed by the project purchasing officer) 

and that all fiscal requirements were met (MSC clearance memorandum signed by the MSC 

comptroller). Without such documentation, MNC-I cannot easily ensure that projects were 

complete upon transfer, files were properly closed, or nonliquidated obligations were 

deobligated. Moreover, many files lacked any indication that a legal review of the 

appropriateness of the project was completed. Lastly, appointment letters and records of 

appointment certifying that the project purchasing officers and paying agents received proper 

authorization for their positions and agreed to the responsibilities involved, including necessary 

training, were often not included. Without this documentation, commands risk having 

unauthorized personnel managing Iraqi funds and project oversight. 

SIGIR’s project file review included a list of 35 categories for verification, including those 

required by the I-CERP project file checklist, the MAAWS, and the MOU. See Appendix B for 

the results of our review of all 35 categories. 

MNC-I Has Not Provided Timely Oversight 

MNC-I has not provided the oversight necessary to ensure that files are completed as required 

and that accurate project data is maintained in the Iraq Reconstruction Management System as 

required by the MAAWS. MNC-I and the MSCs did not meet the January 2009 MAAWS 
13 

guidance to send all closed project files from the MSCs to MNC-I on a quarterly basis. None of 

the MSCs submitted closed I-CERP files to MNC-I, and MNC-I did not request that they do so. 

As a result, MNC-I was unable to review closed project files to determine whether the necessary 

information was included and provide timely feedback to the MSCs to make the necessary 

corrections. Moreover, the MAAWS requires that MSC officials input accurate project 

information in the Iraq Reconstruction Management System, but MSC officials told SIGIR that 

the system has not been kept up to date. SIGIR has documented the inaccuracy of the data in the 

Iraq Reconstruction Management System in a number of previous SIGIR audit reports.9

While an MNC-I official stated project files are now to be maintained at the MSCs for one year 

and then sent directly to storage, the most recent version of the MAAWS, released in 

September 2009, did not reflect such a change in guidance and still requires files to be sent to 

MNC-I on a quarterly basis upon completion. The latest guidance did reflect a revision stating 

MNC-I will review closed project files by making quarterly trips to each of the MSCs to review 

their files. According to an MNC-I official, MNC-I has already completed one such trip to 

MND-S. 

Some MAAWS’ Accountability Requirements Remain Unclear 

Compounding the documentation difficulty, MNC-I’s MAAWS is unclear about what 

documentation is necessary to meet required I-CERP processes and internal control 

requirements. MNC-I revised the MAAWS in May 2008 to include guidance on managing the 

I-CERP program, and in January and September 2009 made some additional clarifications. 

MNC-I plans further modifications in January 2010. Nevertheless, the guidance remains unclear 

in critical areas related to criteria, such as the level of authority required to approve a project on 

an exception basis, who should sign GOI sustainment letters, file accountability, and checklist 

completeness. 

Approval Process for Exception Categories 

The MAAWS empowers MSC Commanders to approve some types of I-CERP projects included 

in the exception categories. However, the MAAWS does not provide criteria for approving 

projects, nor does it address delegation of authority to approve these exceptions. As discussed 

earlier, the MOU stipulates that I-CERP is to focus primarily on projects relating to water, 

schools, health, city planning, and protective measures. MSC Commanding Generals have the 

authority to approve a second tier of projects discussed in the MOU, which includes roads, 

sewers, irrigation, and small business (micro-grants) on an exception basis. However, the 

MAAWS does not discuss the criteria for determining whether to fund one of these projects, so 

the distinction between project categories allowed without exception and those allowed only by 

exception is limited. Additionally, while the MAAWS authorizes the delegation of project 

approval for those projects valued below $500,000, it does not specifically state if the exceptions 

approval previously discussed delegates automatically as well. 

 

9 Comprehensive Plan Needed to Guide the Future of the Iraq Reconstruction Management System, SIGIR 08-021, 

7/26/2008 and Management of Iraq Relief and Reconstruction Fund Program: The Evolution of the Iraq 

Reconstruction Management System, SIGIR 06-001, 4/24/2006.
14 

Project Sustainment Letters 

The MAAWS requires that prior to project approval, units must obtain letters signed by GOI 

officials in which GOI agrees to accept the project and commits to maintain it. However, the 

MAAWS guidance does not specify the format of these letters or the level at which they should 

be signed. As a result of this lack of specificity, letters could be signed by an official lacking the 

authority to budget GOI funds for project sustainment upon completion. Moreover, during a 

review of individual project sustainment letters, SIGIR found letters missing signatures 

altogether, written entirely in Arabic, lacking accurate project titles, and containing various other 

inconsistencies. Such sustainment letter weaknesses limit the U.S. government’s ability to 

support the claim that proper officials agreed to the responsibility of project sustainment prior to 

project approval. 

Project File Accountability 

Although MNC-I was able to locate and provide files for all but one project requested by SIGIR, 

MNC-I currently does not have a system to track files as they are sent from MSCs to MNC-I and 

then to U.S. Army Central Command. The MAAWS does not outline a system or emphasize the 

need to be accountable for the location of files. Best practices suggest that record accountability 

is critical to reduce the risk of errors, fraud, misuse, or unauthorized alteration and to provide 

information necessary for future audits.10 In written comments on a draft of this report, MNC-I 

stated they are following fiscal year 2009 budget execution guidance from U.S. Army Central 

Command. According to MNC-I, this guidance requires the MSCs to keep their closed files until 

November 1, 2009 before shipping them to U.S. Army Central Command. MNC-I 

acknowledged that this guidance was not incorporated into the MAAWS but stated it would be 

included in the next revision to the guidance. 

Project File Checklist 

Though the MAAWS guidance requires units to obtain specific documents, it does not require 

that those documents be included in the project file. The project file checklist, which units use as 

a guide to populate the files, does not require that key documentation such as coordination with 

PRTs and GOI project receipts be included in project files. The MAAWS requires that projects 

valued over $50,000 be coordinated with PRTs and that this coordination be shown in project 

documentation. Additionally, both the MAAWS and the MOU require documentation of the 

date, time, and value of a project at the time it is transferred to GOI. Without such 

documentation, MNC-I cannot easily ensure project transfer completion. 

Table 5 shows the extent to which these required documents were missing from the 103 project 

files SIGIR reviewed. As illustrated, all the MSC files, with the exception of MND-N, failed to 

meet these key documentation requirements over 85% of the time. MSC officials explained they 

did not include these documents in the files because the checklist did not stipulate that they do 

so. 

 

10 Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1, 11/1999. 
15 

Table 5—Key MAAWS Required Documents Missing from Project Files 

Required by MAAWS: MND-B MND-N MND-S MNF-W 

PRT Coordination 97% 24% 88% 100% 

Project Transfer Receipt 

(Date, Time, and Value) 100% 0% 94% 100% 

Source: SIGIR review of I-CERP project files, as of 6/1/2009. 

Although MNC-I’s September 2009 MAAWS revision included a clarification of the checklist to 

align file requirements by project amount, the PRT coordination and project receipt 

documentation were not among the added documents. 
16 

BSA Reports Incomplete Data Provided by United 

States 

SIGIR and BSA agreed to jointly review the management of the I-CERP program. The 

preceding sections of this report present SIGIR’s findings with regard to the I-CERP program. 

The results of the independent work conducted by BSA are presented in a separate letter and 

contained in Appendix C. The contents of that letter are summarized below. 

Iraq’s BSA finds U.S. data to be incomplete, which hinders GOI oversight of U.S.-managed 

programs like I-CERP. BSA issued a report on July 16, 2009, reviewing I-CERP projects 

conducted under an agreement signed between the Iraqi Higher Reconstruction Council and 

MNF-I. The review was conducted by the BSA offices in Baghdad and the provinces (except 

Kurdistan region). Detailed spending information was requested by BSA and reports were 

received from multiple U.S. government sources. The report covered $270 million in funds 

transferred from the Government of Iraq to MNF-I. The funds are managed by MNF-I per the 

signed agreement. BSA conducted a review of the information in the conflicting reports. 

In regards to the project management, BSA found that project documentation did not always 

include all GOI requirements for oversight of the projects. BSA identified the following 

inconsistencies in regards to project documentation provided by the U.S. government: 

• Lack of complete information to verify project spending and/or location; 

• Contract names and description did not match project information; 

• Details describing the project did not agree with project category; and 

• Project category did not agree with the actual work performed. 

BSA provided support for each of the conditions above, identifying specific projects and 

descriptive information to support their findings. BSA stated the inconsistencies identified 

above led to confusion during their audit in identifying projects. 

SIGIR made a cursory review of the BSA report but did not evaluate the validity of BSA's 

conclusions or findings discussed in the report. SIGIR is appending BSA’s report for the use of 

MNF-I and MNC-I officials (Appendix C). 

 
17 

Conclusion and Recommendations 

Conclusion 

Overall, MNF-I has met critical GOI requirements for I-CERP by initiating the type of projects 

GOI wants and in the areas GOI wants them. Moreover, MNF-I developed guidance on 

managing and reporting on these projects and has met the MOU requirement that it keep GOI 

informed of its activities on a quarterly basis. Nevertheless, MNF-I could improve its reporting 

and oversight of project activities. Such improvements could provide greater assurances to GOI 

that the United States is a good steward of its funds and has established the internal controls 

necessary to avoid fraud, waste and abuse. Unless MNF-I adheres to existing requirements and 

clearly communicates those requirements to subordinate units, MNF-I will continue to provide 

GOI with incomplete reports. In addition, without a clear process in place to transition the 

I-CERP program to GOI, MNF-I cannot ensure that U.S. efforts to date will be sustained over 

the long term. 

Without clear defined guidance that is consistently adhered to, MNC-I will be unable to ensure 

the accuracy of project documentation and maintain visibility over the I-CERP program. This 

will be increasingly important as remaining I-CERP funds are obligated. Further, without 

detailing specific documentation requirements, the MSCs will continue to apply requirements 

inconsistently, resulting in incomplete project files. Moreover, without consistent adherence to 

guidance, MNC-I cannot review project files for accuracy. Thus, unless MNC-I takes action to 

clarify I-CERP documentation requirements, the MSCs will continue to interpret requirements 

inconsistently, files will continue to be incomplete, and MNC-I will continue to lack visibility 

over the I-CERP program. 

Recommendations 

SIGIR recommends that the Commanding General, MNF-I take the following actions to improve 

I-CERP program management: 

1. requiring MSCs to provide comprehensive information on all completed I-CERP projects 

with a value of at least $50,000, in accordance with current guidance; and 

2. determining if there is a continuing need to train Iraqi security forces and provincial 

government personnel to manage the I-CERP program, as required in the MOU. 

SIGIR also recommends that the Commanding General, MNC-I take the following actions to 

improve I-CERP accountability and oversight: 

3. clarifying and specifying in the 2010 MAAWS revision which documents must be included 

in I-CERP project files; and 

4. requiring MNC-I to review I-CERP project files in accordance with existing guidance. 
18 

Management Comments and Review Response 

In written comments on a draft of this report, MNC-I concurred with four and did not concur 

with one of the recommended actions. MNC-I’s comments are reprinted in their entirety in 

Appendix F. MNC-I also provided technical comments, which we have incorporated as 

appropriate. 

MNF-I deferred comments in response to a draft of this report to MNC-I who concurred with 

both recommendations directed to MNF-I. MNC-I concurred with our recommendation that 

MNF-I require MSCs to provide comprehensive information on all completed I-CERP projects 

with a value of at least $50,000, in accordance with current guidance. MNC-I stated the 

MAAWS already includes such guidance. While MNC-I agreed with this recommendation, its 

response did not state if the guidance would be changed to ensure this guidance is adhered to by 

the MSCs. SIGIR’s review found that not all project information has been communicated to 

GOI, in accordance with guidance. Therefore we encourage MNF-I and MNC-I to ensure that 

existing guidance is adhered to so that information on completed I-CERP projects is 

communicated to GOI. 

MNC-I also concurred with our recommendation that MNF-I determine if there is a continuing 

need to train Iraqi security forces and provincial government personnel to manage the I-CERP 

program, as required by the MOU. In its comments, MNC-I stated the original agreement 

between the U.S. government and GOI was to encourage GOI to add additional funds beyond the 

original $270 million and U.S. officials would train Iraqi officials in executing these additional 

funds. Since no additional funds were added, training has not and should not occur, according to 

MNC-I. 

MNC-I concurred with two recommendations addressed to MNC-I, but did not concur with one 

recommendation to improve I-CERP accountability and oversight. First, MNC-I concurred with 

our recommendation that it clarify and specify in the 2010 MAAWS revision the documents that 

must be included in I-CERP project files. In its comments, MNC-I stated that the MAAWS will 

be updated to include an I-CERP checklist that includes all required documents. Although 

MNC-I agreed with this recommendation, its response did not indicate whether the revised 

checklist will include clarification related to criteria, such as the level of authority required to 

approve a project on an exception basis, who should sign GOI sustainment letters, and which 

documents not currently required by the checklist, but required by the MAAWS, will be 

included. Since guidance is necessary to ensure complete project file documentation and 

sufficient oversight, we encourage MNC-I to include clarification on these requirements in 

revising the checklist. 

Second, MNC-I concurred with our recommendation requiring MNC-I to review I-CERP project 

files in accordance with existing guidance. MNC-I stated they conduct random audits with 

respect to project selection, payment, and execution. MNC-I also stated they conduct quarterly 

visits to each MSC, and the MSCs are required to conduct quarterly visits to each Brigade 

Combat Team. The MSCs randomly select projects to review for adherence to the January 2009 

version of the MAAWS. As stated in our report, however, MNC-I and the MSCs did not meet 

the January 2009 MAAWS guidance, which requires that MSCs send all closed project files to 
19 

MNC-I on a quarterly basis for review. While the September 2009 MAAWS revision states 

MNC-I will review project files at each MSC, it still includes a requirement that the MSCs 

submit files to MNC-I quarterly. Without specific guidance on how project files will be 

reviewed, MNC-I cannot ensure the files include the necessary information and provide timely 

feedback to the MSCs to make the necessary corrections. 

MNC-I did not concur with SIGIR’s recommendation to establish a system for tracking I-CERP 

project file location. MNC-I stated all closed I-CERP files were stored at the MSCs in 

accordance with fiscal year 2009 budget execution guidance from U.S. Army Central Command. 

According to MNC-I, this guidance requires the MSCs to keep their closed files until 

November 1, 2009 before shipping them to U.S. Army Central Command. MNC-I 

acknowledged that this guidance was not incorporated into the MAAWS but stated it would be 

included in the next revision to the guidance. We agree that MNC-I guidance should reflect 

MNC-I’s practices. Therefore, SIGIR removed this as a recommendation. 
20 

Appendix A—Scope and Methodology

In May 2009, the Special Inspector General for Iraq Reconstruction (SIGIR) initiated 

Project 9018 to examine U.S. government spending of Iraqi funds provided under the Iraq 

Commander’s Emergency Response Program (I-CERP). SIGIR’s objectives for this report were 

to examine the extent to which Multi-National Force-Iraq (MNF-I) met the terms of the 

Memorandum of Understanding (MOU) with the Government of Iraq (GOI) and the extent to 

which Multi-National Corps-Iraq (MNC-I) has maintained I-CERP project records in accordance 

with requirements. This review was performed by SIGIR under the authority of Public Law 

108-106, as amended, which incorporates the duties and responsibilities of inspectors general 

under the Inspector General Act of 1978. SIGIR conducted its work during May through 

October 2009 in Baghdad, Iraq. 

To review the extent to which MNF-I met the terms of the MOU with GOI, we: 

• Met with officials from MNF-I. 

• Examined criteria in the MOU between GOI and MNF-I, MNF-I Fragmentary Order 

08-166 regarding guidance on the administration of I-CERP projects and funds, and 

relevant Commander’s Emergency Response Program (CERP) guidance. 

• Evaluated MNC-I’s data to determine I-CERP funds committed, obligated, and 

disbursed, by approved project category and by province. 

• Reviewed 206 storyboards from MNF-I’s quarterly reports to GOI for compliance with 

I-CERP reporting criteria in the MOU. 

• Compared the quarterly report storyboards to MNC-I’s internal project records database 

for accuracy and completeness. 

To review the extent to which MNC-I has maintained I-CERP project records in accordance with 

requirements, we: 

• Met with officials from MNC-I, all four Major Subordinate Commands (MSC), and the 

four related Provincial Reconstruction Teams (PRT). The four MSCs are headquartered 

throughout Iraq: Multi-National Division – South (MND-S), Multi-National Division – 

North (MND-N), Multi-National Division – Baghdad (MND-B), and Multi-National 

Force – West (MNF-W). 

• Examined criteria in MNC-I’s Money as a Weapons System (MAAWS). 

• Requested and reviewed a sample of completed (or closed) project files from each of the 

four MSCs to determine completeness in meeting 35 requirements established in the 

I-CERP project file checklist and the MAAWS. 

• Requested and reviewed a sample of the top three dollar value open project files from 

each of the four MSCs to determine completeness, as applicable, in meeting 

35 requirements established in the I-CERP project file checklist and the MAAWS. 
21 

• Conducted a file review where we sampled more than 10% of all completed project 

folders for each MSC and more than 25% of all completed project dollars obligated at 

each MSC. In all, the sample included 103 of 688 completed projects and approximately 

$37 million of the approximately $89 million completed project dollars. 

Table 6—Completed and Sampled I-CERP, by Project 

 MND-B MND-N MND-S MNF-W Total 

Total Completed 255 297 83 53 688 

Total Sample 34 38 17 14 103 

Sample Percentage of Total 13% 13% 20% 26% 15% 

Source: SIGIR analysis of MNC-I data, as of 6/1/2009. 

Table 7—Completed and Sampled I-CERP, by Dollar 

 MND-B MND-N MND-S MNF-W Total

Total Completed $53,338,293 $12,003,648 $10,289,187 $13,315,704 $88,946,832

Total Sample $22,570,153 $3,009,463 $4,577,083 $6,801,861 $36,958,560

Sample 

Percentage of 

Total 

42% 25% 44% 51% 42%

Source: SIGIR analysis of MNC-I data, as of 6/1/2009. 

• Reviewed MNC-I’s comprehensive spreadsheet comprising MSC monthly project reports 

to ensure accountability of all I-CERP funds disbursed. 

• Compared MNC-I’s checklist for I-CERP projects with the four MSC’s project files to 

determine completeness and compliance with established guidance. 

In July 2009, Iraq’s Board of Supreme Audit (BSA) issued a report reviewing I-CERP projects. 

BSA's report was completed independent of SIGIR's evaluation of I-CERP and does not fall 

under generally accepted government auditing standards. SIGIR did not provide input to BSA’s 

independent report and has not evaluated any conclusions therein. The BSA summary and 

appendix included in this review are merely informational and do not represent SIGIR’s views or 

conclusions. 

This review was conducted in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the review to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and conclusions based on our 

objectives. We believe that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our objectives. 
22 

Use of Computer-processed Data 

To achieve the assignment’s objectives, we extensively relied on computer-processed data 

contained in MNC-I’s I-CERP project tracker. We assessed the reliability of this data, including 

relevant general controls, and found it to be adequate. We also conducted sufficient tests of the 

data. Based on these assessments and tests, we conclude that the data were sufficiently reliable 

to be used in meeting the assignment’s objectives. 

We also relied on computer-processed data contained in the Iraq Reconstruction Management 

System. Previous SIGIR reviews of the system controls and results of data tests indicate 

limitations in the data’s completeness or accuracy; however, the data are the best available for 

purposes of our review. 

Internal Controls 

In conducting the review, we assessed certain internal controls to administer and oversee I-CERP 

projects and funds. Specifically, we examined the internal and management control procedures 

and documents that MNF-I and MNC-I require and use to manage I-CERP. 

Related Reports by SIGIR 

SIGIR has issued six reports on the management controls and accountability of the CERP. 

SIGIR has also issued several reports that include analysis of the Iraq Reconstruction 

Management System. This report is SIGIR’s first review of I-CERP funds. 

• Commander’s Emergency Response Program: Muhallah 312 Electrical Distribution 

Project Largely Successful, SIGIR 09-025, 7/23/2009. 

• Commander’s Emergency Response Program: Hotel Construction Completed, But 

Project Management Issues Remain Unresolved, SIGIR 09-026, 7/23/2009. 

• Asset-transfer Process for Iraq Reconstruction Projects Lacks Unity and Accountability, 

SIGIR 09-016, 4/26/2009.

• Comprehensive Plan Needed to Guide the Future of the Iraq Reconstruction 

Management System, SIGIR 08-021, 7/26/2008. 

• Commander’s Emergency Response Program in Iraq Funds Many Large-scale Projects, 

SIGIR 08-006, 1/25/2008. 

• Management of the Commander’s Emergency Response Program in Iraq for Fiscal 

Year 2006, SIGIR 07-006, 4/26/2007. 

• Management of Iraq Relief and Reconstruction Fund Program: The Evolution of the Iraq 

Reconstruction Management System, SIGIR 06-001, 4/24/2006. 

• Management of the Commander’s Emergency Response Program for Fiscal Year 2005, 

SIGIR 05-025, 1/23/2006. 

• Management of the Commanders’ Emergency Response Program for Fiscal Year 2004, 

SIGIR 05-014, 10/13/2005. 
23 

Appendix B—File Review Checklist Results 

Table 8—I-CERP Documentation Missing from Project Files 

MND-B MND-N MND-S MNF-W Total

Sample Size 34 38 17 14 103

Required by MAAWS Checklist 

Electronic Funds Transfer Payment 

Request 31 36 12 13 92

Cash Receipt on Advance 28 37 11 13 89

Cash Receipt on Return 28 33 11 13 85

Project Performance Metrics 4 34 16 12 66a

Contract Completion Statement 12 23 14 13 62

Paying Agent Appointment Letter 22 4 13 14 53

Paying Agent Appointment Record 20 5 10 14 49

MSC Comptroller Clearance Memo 31 1 12 0 44

Legal Review 0 16 7 12 35

Sustainment Letter 6 5 10 9 30

MSC Endorsement 1 7 10 9 27

Project Purchasing Officer Appointment 

Letter 

b

 2 14 2 18

Commander's Clearance Memo 5 0 8 4 17

Standard Letter of Justification 0 3 8 4 15

Modifications 0 10 5 0 15

Project Proposal or Statement of Work 0 4 6 3 13

Project Purchasing Officer Appointment 

Record 

c

 1 10 2 13

Inspection and Receiving Report 4 1 2 5 12

Signed Memorandum of Agreement 0 6 2 3 11

Completed Contract 6 1 3 0 10

Funds Increase Memo 0 0 3 3 6

Vouchers 4 0 2 0 6

Purchase Request and Commitment 1 0 1 3 5

Memorandum of MSC concurrence 0 0 0 1 1

No Classified Documents 0 0 0 0 0
24 

MND-B MND-N MND-S MNF-W Total

SIGIR Added Checklist Categories 

Document Site Visits 31 36 16 14 97

PRT Coordination 33 9 15 14 71

Project Transfer Receipt (Date, Time, 

Value) 34 0 16 14 64

Iraqi Recipient (Name and Title) 34 0 15 14 63

Provincial Reconstruction and 

Development Council Coordination 7 26 14 14 61

Bidding Process 16 3 11 13 43

Project Purchasing Officer and Paying 

Agent differ 21 0 0 2 23

Paid in Dinar d 9 6 1 16

MSC Commanding General Approval for 

"Exception" Projects 0 0 2 7 9

Iraqi Firm 0 1 1 0 2

Notes: 

a SIGIR’s review did not initially include checking that Project Performance Metrics were implemented. After reviewing MND-B files, SIGIR 

changed its methodology to review files for Project Performance Metrics as well as some evidence or statement that metrics were achieved. 

SIGIR did not reexamine MND-B files to determine if they met this requirement. The methodology change led to inconsistent results among 

the MSCs, so SIGIR has included its findings in this appendix, but removed references to missing Project Performance Metrics in the body of 

this report. b SIGIR’s review did not initially differentiate between Project Purchasing Officer and Paying Agent appointment letters because the MAAWS 

checklist included them as one requirement for the file. After reviewing MND-B files, SIGIR changed its methodology because SIGIR found 

that this is a requirement for two different documents. SIGIR did not reexamine MND-B files for compliance and instead summarized only 

letters present in files as Paying Agent appointment letters and left blank the entry for Project Purchasing Officer appointment letters. c

 SIGIR’s review did not initially differentiate between appointment record for Project Purchasing Officer and those for Paying Agent because 

the MAAWS checklist included them as one requirement for the file. After reviewing MND-B files, SIGIR changed its methodology because 

SIGIR found that this is a requirement for two different documents. SIGIR did not reexamine MND-B files for compliance and instead 

summarized only forms present in files as Paying Agent appointment record and left blank the entry for Project Purchasing Officer appointment 

record. d SIGIR’s review did not initially gather information on whether contracts were paid in Iraqi dinar. After reviewing MND-B files, SIGIR began 

gathering this information for the other MSCs, but did not reexamine MND-B files. 

Source: SIGIR analysis of I-CERP Project Files, as of 6/1/2009. 
25 

Appendix C—BSA Report 
26 
27 
28 
29 
30 

Appendix D—Acronyms 

Acronym Description 

BSA Board of Supreme Audit 

CERP Commander’s Emergency Response Program 

GOI Government of Iraq 

I-CERP Iraq Commander’s Emergency Response Program 

MAAWS Money as a Weapon System 

MNC-I Multi-National Corps-Iraq 

MND-B Multi-National Division-Baghdad 

MND-N Multi-National Division-North 

MND-S Multi-National Division-South 

MNF-I Multi-National Force-Iraq 

MNF-W Multi-National Force-West 

MOU Memorandum of Understanding 

MSC Major Subordinate Command 

PRT Provincial Reconstruction Team 

SIGIR Special Inspector General for Iraq Reconstruction 
31 

Appendix E—Review Team Members 

This report was prepared and the review 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 review and contributed to the report include: 

Meredith P. Baumeister 

W. Dan Haigler 

J.J. Marzullo 

Whitney H. Miller 

P. Hayden Morel 

Nancee K. Needham 

 
32 

Appendix F—Management Comments 
33 
34 
35 

Appendix G—SIGIR Mission and Contact Information 

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

operations in Iraq, the Special Inspector General for Iraq 

Reconstruction provides independent and objective: 

• oversight and review through comprehensive audits, 

inspections, and investigations 

• advice and recommendations on policies to promote 

economy, efficiency, and effectiveness 

• deterrence of malfeasance through the prevention and 

detection of fraud, waste, and abuse 

• information and analysis to the Secretary of State, the 

Secretary of Defense, the Congress, and the American 

people through Quarterly Reports 

Obtaining Copies of SIGIR 

Reports and Testimonies 

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

SIGIR’s Web site (www.sigir.mil). 

To Report Fraud, Waste, and 

Abuse in Iraq Relief and 

Reconstruction Programs 

Help prevent fraud, waste, and abuse by reporting 

suspicious or illegal activities to the SIGIR Hotline: 

• Web: www.sigir.mil/submit_fraud.html 

• Phone: 703-602-4063 

• Toll Free: 866-301-2003 

Congressional Affairs Hillel Weinberg 

Assistant Inspector General for Congressional 

Affairs 

Mail: Office of the Special Inspector General 

for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-604-0368 

Email: hillel.weinberg@sigir.mil 

Public Affairs Daniel Kopp 

Assistant Inspector General 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