OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

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Special Inspector General for IRAQ Reconstruction

SIGIR

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 10-021 

Why SIGIR Did this Study 

SIGIR’s legislative authority states, in part, that 

it is to perform audits of the programs, 

operations, and contracts utilizing reconstruction 

funds to include the maintenance of records on 

the use of such funds to facilitate future audits 

and investigations. This report is being issued

to address that requirement. Since 2003, the 

Congress has appropriated $53.31 billion for 

Iraq relief and reconstruction activities. The 

Department of Defense (DoD), the Department 

of State (DoS), and the Administrator of the 

U.S. Agency for International Development 

(USAID) manage these activities and created 

records related to their programs. They have the 

responsibility for preserving the records for Iraq 

reconstruction activities against loss or 

premature destruction. DoD’s records exceed 

100,000 program and contract records. DoS and 

USAID have an estimated 2,650 program 

management, grant, and contract records. 

The objective for this report is to determine the 

extent to which principal U.S. agencies 

responsible for managing Iraq reconstruction 

activities have plans to preserve reconstruction 

records. 

Recommendations

SIGIR makes recommendations to officials from 

the DoD, DoS, and USAID to improve their

records preservation processes and procedures. 

Central among those recommendations is that

these organizations should coordinate the 

development of a master list of records to ensure 

record completeness; link to programs, 

associated contracts, and funding; and develop 

uniform retention policies that are consistent 

with the needs of investigative and audit 

organizations, and historical preservation. 

Lessons Learned

Planning and guidance for the transition and 

preservation of contingency operations records 

should be in effect at an operation’s start. 

Management Comments 

We received comments from some DoD 

organizations and USAID. All generally 

concurred with the report’s recommendations

and/or facts. Any additional comments received 

will be made publicly available.

July 30, 2010 

PLANS TO PRESERVE IRAQ RECONSTRUCTION PROGRAM AND 

CONTRACT RECORDS NEED TO BE IMPROVED

What SIGIR Found

DoD, DoS, and USAID have records management policies and procedures,

but have not fully implemented those procedures for preserving their Iraq 

reconstruction records. This situation leaves the U.S. government vulnerable 

to waste and theft as it may not have the necessary information to pursue 

potential cases of fraud and/or to perform audits of reconstruction activities. 

Additionally, the records have not been reviewed for historical significance, 

and important documents could be lost if action is not taken. 

SIGIR’s review showed a range of progress in preserving the records. Some 

organizations had already shipped many of their records to storage facilities, 

while others had not. Other organizations were missing records and did not 

know the status of records that had been shipped to storage. Lastly, some 

organizations did not have the appropriate-sized storage facilities, adequate 

plans for preserving records, or the ability to retrieve records in a timely 

manner. Our review also showed that, in some cases, records for joint 

reconstruction projects were dispersed among several government

organizations and storage of the records had not been coordinated to ensure 

completeness and availability. This records preservation vulnerability 

further illustrates SIGIR’s long-standing concerns about the ad hoc nature of 

the management of Iraq reconstruction. 

A recent DoD Joint Staff study identified significant problems with all 

phases of DoD’s records management in Iraq, and SIGIR’s current work 

confirmed these problems, but also found progress in resolving the issues. 

The Joint Staff study was conducted in April 2010. The study noted such 

problems as an undefined universe of records, lack of adequate guidance and 

standard operating procedures, and unclear lines of records management 

responsibility. 

SIGIR’s current work found that the U.S. Army Corps of Engineers, which

maintains a large percentage of the DoD records, is well on its way to 

preserving its records, but other DoD organizations are still focusing on 

developing plans, assembling and reviewing records for completeness, 

increasing storage facility capacity, and ensuring record retrieval 

capabilities. SIGIR is particularly concerned about the lack of progress in

preserving Iraq Security Forces Fund (ISFF) records and Commander’s 

Emergency Response Program (CERP) records. At this time, little progress 

has been made in preserving the ISFF program management records, and 

prior and ongoing SIGIR work has shown that many CERP records are 

incomplete or cannot be located. 

DoS and USAID are organizing their records but have not taken steps to 

return the records to the United States for storage. The organizations appear 

to have control over their reconstruction records, but are lacking guidance on 

how to proceed with preservation planning. 
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

400 Army Navy Drive • Arlington, Virginia 22202

July 30, 2010 

MEMORANDUM FOR U.S. SECRETARY OF STATE 

U.S. AMBASSADOR TO IRAQ

U.S. SECRETARY OF DEFENSE 

COMMANDER, U.S. CENTRAL COMMAND

COMMANDING GENERAL, U.S. FORCES-IRAQ

COMMANDING GENERAL, U.S ARMY CENTRAL COMMAND

COMMANDING GENERAL, U.S. ARMY CORPS OF ENGINEERS

ADMINISTRATOR, U.S. AGENCY FOR INTERNATIONAL 

DEVELOPMENT

MISSION DIRECTOR-IRAQ, U.S. AGENCY FOR 

INTERNATIONAL DEVELOPMENT

SUBJECT: Plans To Preserve Iraq Reconstruction Program and Contract Records Need To 

Be Improved (SIGIR 10-021) 

We are providing this report for your information and use. The report examines U.S. 

government agency efforts to preserve Iraq reconstruction program and contract records. We 

performed this audit 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 fraud, 

waste, and abuse. This audit was conducted as SIGIR Project 9030. 

We received comments from the U.S. Central Command, Army Central Command, the U.S. 

Army Corps of Engineers-Gulf Region District, and USAID. All generally concurred with the 

recommendations and/or facts presented in the report and also provided technical comments that 

SIGIR addressed as appropriate. The comments are included in Appendix G. Any additional 

comments received will be made publicly available.
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

400 Army Navy Drive • Arlington, Virginia 22202

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

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

(Washington, DC), (703) 604-1388/ glenn.furbish@sigir.mil or Nancee Needham, Deputy 

Assistant Inspector General for Audits (Baghdad), (240) 553-0581 ext. 3793/ 

nancee.needham@iraq.centcom.mil. 

Stuart W. Bowen, Jr.

Inspector General

cc: Assistant Secretary of the Army (Financial Management and Comptroller)

Chairman, Joint Chiefs of Staff
Table of Contents 

Introduction 1

Background 2

Objectives 6

Significant Gaps Exist in DoD’s Records Preservation Efforts, but Some 

Progress Has Been Made 7

JS Study Finds Significant Records Management Gaps 7

SIGIR Notes Progress and Problems in Preserving Reconstruction Records 9

DoS and USAID Need To Improve Preservation Planning 14

U.S. Embassy Records Have Not Been Preserved 14

USAID Records Remain in Iraq 14

Conclusions, Recommendations, and Lessons Learned 16

Conclusions 16

Recommendations 16

Lessons Learned 17

Management Comments and Audit Response 18

Appendix A—Scope and Methodology 19

Appendix B—FAR Subpart 4.8 Retention Schedule 21

Appendix C—Records Management Guidance 22

Appendix D—Records Management Deficiencies Identified in 

Previous SIGIR Reports 25

Appendix E—Acronyms 29

Appendix F—Audit Team Members 30

Appendix G—Management Comments 31

Appendix H—SIGIR Mission and Contact Information 37
1 

Plans To Preserve Iraq Reconstruction Program and 

Contract Records Need To Be Improved

SIGIR 10-021 July 30, 2010 

Introduction

The Congress recognized the importance of maintaining U.S. records of the reconstruction of 

Iraq and included specific requirements related to records management in SIGIR’s legislative 

authority. The statute states, in part, that SIGIR is to perform audits of the programs, operations, 

and contracts utilizing these reconstruction funds to include the maintenance of records on the 

use of such funds to facilitate future audits and investigations of the use of such funds.

1

 SIGIR 

has responded to this requirement by identifying, in numerous audits, serious deficiencies in the 

thoroughness of records on actions taken to implement contracts, programs, projects, and grants.2

Since 2003, the Congress has appropriated $53.31 billion for Iraq relief and reconstruction 

activities. U.S. agencies managing these activities created records related to their programs. The 

programs encompassed activities such as promoting democracy; water treatment, and medical 

facilities; awarding contracts to complete reconstruction tasks; and entering into grants and 

cooperative agreements with organizations to carry out activities. The agencies managing 

reconstruction activities have responsibility for preserving the reconstruction records until they 

are destroyed. The substantial volume of records that has been produced presents those agencies 

with a significant and unique management challenge. 

 

These reports, however, did not examine the final phase of records management—preservation. 

In this final phase, records are preserved to protect against loss or destruction prior to their final 

disposition. This report focuses on the planning for the preservation of the Iraq reconstruction 

records. For the purposes of this report, “preserve” means to protect against loss or destruction 

prior to required final disposition. 

Government lawyers, auditors, and other professionals will rely on the reconstruction records 

when questions are raised about the appropriateness of such things as payments made to 

contractors for goods and services. The Federal Records Act (44 USC Chapter 31) requires that 

the head of each federal agency make and preserve records containing adequate and proper 

documentation of the organization, functions, policies, decisions, procedures, and essential 

transactions of the agency. The records should be designed to furnish the information necessary 

to protect the legal and financial rights of the government and of persons directly affected by the 

agency’s activities. Additionally, the Federal Acquisition Regulation (FAR) Subpart 4.8 details

requirements for establishing, maintaining, and disposing of contract records. The FAR states 

that agency procedures for contract file disposal must include provisions that the documents may 

not be destroyed before the times indicated. The FAR also states that contract records may be 

 

1 P.L. 108-106, Sec. 3001, (f). 2 See Appendix D for a list of those reports. 
2 

retained longer if the responsible agency official determines that the records have future value to 

the government. 

These records have historical significance beyond audit and investigative needs. These records 

provide a chronological history of the reconstruction program that may be of importance to 

historians and to policymakers who look to identify lessons learned and best practices to inform 

future contingency efforts undertaken by the U.S. government. 

Background 

Iraq reconstruction activities and the related records were principally managed by the 

Department of Defense (DoD), U.S. Agency for International Development (USAID), and 

Department of State (DoS). The major appropriations associated with the reconstruction 

activities and the types of records managed by these agencies are discussed below. Because of 

their roles and responsibilities, DoD organizations managed, by far, the largest number of 

records. Table 1 shows, in general, the organizations, types of records managed, and the 

associated reconstruction funds. In most cases, the organizations that had initial responsibility 

for the records have been succeeded by other organizations. The organizations shown have 

current responsibility for records management. 
3 

Table 1—Records Management Summary for U.S. Funded Iraq Reconstruction

Reconstruction Records U.S Funds For Iraq 

Reconstruction

Department/

Organization

Program 

Management

Contract 

Management

IRRF ISFF CERP ESF

Department of 

Defense: 

     

United States 

Forces-Iraq 

Engineering 

Program 

Management 

Branch (J7)

   

United States 

Forces-Iraq 

Resource 

Management 

Branch (J8) 

   

United States 

Army Corps of 

Engineers 

     

Air Force 

Center for 

Engineering 

and the 

Environment

  

U.S. Central 

Command, 

Contracting 

Command

    

Department of 

State: 

    

U.S. Embassy, 

Iraq Strategic 

Partnership 

Office

  

United States 

Agency for 

International 

Development 

Iraq Mission

   

Source: SIGIR analysis of Iraq Reconstruction Management System data as of February 2010 and audit interviews. 
4 

Reconstruction Funds

Four major U.S. funds were used in the reconstruction of Iraq, and multiple agencies received the 

funds. The following identifies the four funds and the agencies that used them: 

• The Iraq Relief and Reconstruction Fund (IRRF) appropriations totaled about $20.86 

billion. DoD received approximately $14.04, DoS received approximately $1.61 billion, 

and USAID received approximately $4.62 billion.3

• The Iraq Security Forces Fund (ISFF) appropriations totaled $18.04 billion and were used 

to support Iraq’s Ministry of Defense and Ministry of Interior in developing the Iraqi 

Security Forces. Almost $2.5 billion in ISFF was transferred to DoS to fund contracts to 

support the Iraqi police training program. U.S. Forces-Iraq (USF-I), formerly MultiNational Force-Iraq, provides program management for the ISFF. The funds are used for

training, and equipping the Iraqi Security Forces, such as the Iraqi Police, Army, Navy, 

Air Force, and Special Operations Forces.

 The IRRF was used for activities 

such as building, repairing, and renovating Iraq’s infrastructure such as schools, office 

buildings, wastewater treatment plants, and oil terminal facilities, and developing the 

capacity of the Iraqi government. 

4

• The Commander’s Emergency Response Program (CERP) has received $3.74 billion in 

appropriations from DoD’s Operations and Maintenance account. The funds are used by

U.S. military commanders to provide targeted local relief and reconstruction projects, 

such as water and sanitation, electricity, transportation, civic cleanup, agriculture, and 

economic development activities. Only DoD received these funds. 

 This included construction of training 

centers, military bases, and police stations. 

• The Economic Support Fund (ESF) has provided $4.56 billion for Iraq reconstruction 

activities. The funds are primarily managed by DoS and USAID, although some funds 

were transferred by interagency agreements with DoD. The funds are used for programs

and grants to improve infrastructure and community security, promote democracy and 

civil society, and support capacity building and economic development. 

Reconstruction Organizations 

A number of subordinate DoD organizations have records management responsibilities. Overall, 

DoD organizational records exceed 100,000 program, project, and contract records. 

DoD Reconstruction Agencies

• CENTCOM Contracting Command commenced operations on June 11, 2010, and 

succeeded the Joint Contracting Command-Iraq/Afghanistan (JCC-I/A), which was

established in 2005 by DoD as a special command to administer and consolidate DoD’s

Iraq and Afghanistan contracting activities. CENTCOM Contracting Command is

responsible for managing contracting records for programs and projects using IRRF, 

CERP, and ISFF appropriations, and also some ESF funds transferred through interagency 

 

3 Other U.S. government organizations, such as U.S. Department of the Treasury and the U.S. Trade and 

Development Agency, also received IRRF appropriations. 

4 SIGIR will discuss the management of records for programs to train and equip the Iraqi Security Forces in 

forthcoming reports.
5 

agreements. The Command has the most significant reconstruction records management 

responsibilities for Iraq reconstruction activities. 

• U.S. Army Corps of Engineers (USACE) had several sub-organizations that were 

responsible for maintaining reconstruction records. These include the Transatlantic 

Division (formerly Gulf Region Division) and Gulf Region District (formerly Gulf 

Region Central, and Gulf Region South and Gulf Region North). By April 2010, USACE 

had reorganized and downsized its footprint in Iraq. Gulf Region District is the sole 

remaining district in Iraq.5

• Air Force Center for Engineering and the Environment (AFCEE)

 USACE provides reconstruction engineering services to DoD,

DoS, and USAID. USACE is involved in the planning, design, and management of 

military and civil-infrastructure construction projects funded, to some degree, by the 

IRRF, CERP, ISFF, and ESF funds transferred through interagency agreements. 

Consequently, USACE reconstruction records include project and contract files.

6

• USF-I Engineering Program Management Branch (J7) maintains program and project 

records as the ISFF construction program manager. Contracts to implement these 

programs are managed by AFCEE, USACE, and/or the CENTCOM Contracting 

Command. As discussed above, those organizations manage their respective records. 

administers 

programs and projects for DoD components. The projects and contracts were funded by 

IRRF and ISFF appropriations. Primarily, these programs were for facilities, schools, 

housing, police stations, and training centers. AFCEE reconstruction records include 

program and project files. 

• USF-I Resource Management Branch (J8) coordinates CERP-funded activities and

manages CERP-funded contracts under $500,000. It develops annual CERP funding 

requirements, allocates funds, and monitors commitments, obligations, and 

disbursements. J8 receives all completed CERP project files and forwards them to U.S.

Army Central Command (ARCENT) at the end of the following fiscal year. A separate 

office, J8 FWD plans, programs, budgets, and executes ISFF resources in support of 

USF-I’s train and equip mission. 

DoS and USAID reconstruction programs were funded by ESF and IRRF appropriations. DoS 

also managed the ISFF-funded contract for State Department support to the Iraqi police training 

program. The Iraq Transition Assistance Office (ITAO), now the Iraq Strategic Partnership 

Office (ISPO), of the U.S. Embassy Baghdad directly managed some ESF projects. Others were 

managed by State Department bureaus in Washington, D.C. The USAID Mission in Iraq 

principally managed and contracted for its own programs, such as infrastructure restoration, 

economic development, and health care, but set up interagency agreements for some contract 

oversight services from DoD. ISPO and USAID have an estimated 2,650 program management, 

grant, and contract records. 

DoS Reconstruction Organizations

 

5 All USACE organizations involved in Iraq reconstruction will be collectively referred to as USACE for the 

purposes of this report.

6 AFCEE provides the U.S. Air Force technical and professional services in environmental and installation planning, 

construction, engineering, and military housing construction and privatization.
6 

According to a DoS official, the former U.S. Embassy offices ITAO and the Iraq Reconstruction 

Management Office provided coordination and oversight of large programs such as the 

Provincial Reconstruction Development Council, Infrastructure Security Protection, and the 

Ministerial Transitional Capacity Development Program intended to improve the capabilities of 

the Government of Iraq. The offices also coordinated with DoD components that were managing

and contracting for infrastructure projects funded by IRRF and ESF. 

Multiple Agencies Were Frequently Involved

Program and contract management responsibilities for reconstruction activities were frequently 

dispersed among DoD and DoS organizations. For example, on the contract to design and 

construct a wastewater treatment plant for Fallujah, the ITAO coordinated the overall U.S. water 

sector program, USACE managed the project, and JCC-I/A managed the contract award. Each 

of these agencies was responsible for managing and preserving its records related to the project. 

Objectives 

The objective for this report is to determine the extent to which principal U.S. agencies 

responsible for managing Iraq reconstruction activities have plans to preserve their

reconstruction records. For purposes of this report, we use the term plans in a general nature to 

include policies and procedures used to implement coordination and preservation of Iraq 

reconstruction records. 

We reviewed the results of the Joint Staff (JS) Records Management Program Assessment of

records management by DoD combatant commanders reported in November 2008 and a 

subsequent follow-on assessment of USF-I reported in April 2010. To avoid duplication of 

effort, we presented the work of the JS team in those cases where we verified that it was 

consistent with the results of our ongoing work and comments from the agencies under review. 

We also note any differences in results between the team’s study and our work. Further, we note 

that the scope of the JS work in April 2010 included all contingency records, while our work 

focused on only those records related to reconstruction activities. However, the systemic 

concerns that the team raised apply to the reconstruction records. Also, the JS study did not 

cover JCC-I/A before it was reorganized into the CENTCOM Contracting Command. 

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

Appendix A. For the FAR Contract File Retention Schedule, see Appendix B. For Records 

Management Guidance, see Appendix C. For Records Management Deficiencies Identified in 

Prior Reports, see Appendix D. For a list of acronyms used, see Appendix E. For the audit team 

members, see Appendix F. For management comments, see Appendix G. For the SIGIR

mission and contact information, see Appendix H.
7 

Significant Gaps Exist in DoD’s Records Preservation 

Efforts, but Some Progress Has Been Made

Significant gaps exist in DoD’s efforts for preserving its Iraq reconstruction records. Consistent 

with our audit work, an April 2010 JS study found significant problems with all phases of DoD’s 

records management in Iraq. The study noted such problems as an undefined universe of 

records, lack of adequate guidance and standard operating procedures, and unclear lines of 

records management responsibility. 

SIGIR identified the same concerns as the JS study. While having overall records management 

policies and procedures, SIGIR found gaps in the implementation of DoD policies and 

procedures. USACE has done well in preserving its records, but other DoD organizations are 

still focusing on assembling and reviewing records for completeness, increasing storage facility 

capacity, and ensuring record retrieval capabilities. SIGIR is particularly concerned about the 

records for projects funded by the ISFF and CERP funds.

JS Study Finds Significant Records Management Gaps 

In 2008, the JS conducted a worldwide review of U.S. Combatant Commands’ records 

management programs and found that CENTCOM's program had weaknesses but noted that the 

Command had plans or actions underway to address its problems. CENTCOM has operational 

control for U.S. forces stationed in Iraq. The study noted that it was critical for CENTCOM to 

meet the requirements for managing records to protect the interests of the Command and the U.S. 

government, to document lessons learned, and to comply with federal statute and DoD policy. 

In April 2010, a JS team reviewed the status of DoD’s operational and reconstruction records in 

Iraq for a second time. The purpose of that review was to “ensure the preservation of records 

created/maintained during armed conflict.” Overall, the JS team found improvement since its 

initial review, but nonetheless, identified major deficiencies in all phases of records management 

including the following: 

• The volume, location, size, and format of USF-I records was unknown. 

• Guidance on records requirements was not fully disseminated or implemented. 

• Directorates and staff offices lack standard operating procedures for basic records 

management requirements, including retention and migration. 

• Lines of demarcation between CENTCOM and military service records and records 

management responsibilities were unclear. 

• Large gaps existed in records collections, resulting in the failure to capture significant 

operational and historical activities. 
8 

The JS team found that CENTCOM had not provided and enforced adequate records 

management guidance to USF-I and its predecessor, the Multi-National Force-Iraq. Moreover, 

CENTCOM established a policy in October 2009 whereby records management was delegated to 

the individual military services rather than to CENTCOM and its USF-I components in Iraq. 

Based on this delegation of authority, for example, AFCEE follows Air Force records 

management policies while USACE and JCC-I/A followed Army records management policies. 

The team found that this approach was not working to meet DoD records management 

requirements. In commenting on a draft of this report, CENTCOM stated that it established a 

policy for managing records in February 2008 which was subsequently revised in October 2009. 

This revised policy directed that its components, such as ARCENT, use the records management 

policies established by their respective services to manage reconstruction records. 

The JS study’s findings are consistent with SIGIR’s findings and prior SIGIR reports detailing 

weaknesses in records management on specific reconstruction programs and contracts. For 

example, SIGIR has reported numerous instances where CERP project files were incomplete, 

IRRF contract files lacked required financial transaction documents, and CERP and IRRF files 

could not be located. In a recent example, SIGIR’s April 2010 report on CERP projects 

conducted at the Baghdad International Airport found that DoD experienced problems in 

managing files to the point that accountability for the project outcomes was not clear. These 

deficiencies were significant enough to constitute a major weakness in ensuring that CERP funds 

are not subject to fraud and waste.

7

On April 9, 2010, the JS team made a series of recommendations to address records management 

deficiencies. Of particular importance was the recommendation that USF-I lead all DoD records 

management activities for Iraq, and that CENTCOM provide guidance to that effect. 

Additionally, the JS team recommended that CENTCOM take a number of actions in Iraq and 

for other similar contingency operations, including the following tasks: 

 Reports that discuss these and other records management 

issues are included in Appendix D. 

• Identify clear lines of authority for in-theater war records. 

• Work with USF-I to establish policies and procedures for information capture, sharing, 

and retention. 

• Send qualified personnel to Iraq to assist with records management drawdown activities 

and provide training for record managers before they deploy. 

A USF-I official stated that CENTCOM and USF-I took steps to implement the 

recommendations. In May 2010, CENTCOM provided initial guidance and conducted an 

assistance visit to the USF-I Records Management office. In commenting on a draft of this 

report, however, CENTCOM stated that USF-I issued final guidance for records management on 

July 18, 2010. 

According to the USF-I official, CENTCOM began to subordinate organizations records to 

determine the amount of electronic and paper information held, and the size in cubic feet of 

 

7 Commander’s Emergency Response Program: Projects at Baghdad Airport Provided Some Benefits, but Waste 

and Management Problems Occurred, SIGIR 10-013, 4/26/2010.
9 

paper records. Nevertheless, other recommendations, such as identifying clear lines of authority 

for in-theater records have yet to be addressed. According to a JS official, as of April 2010, 

USF-I did not have personnel in country to adequately address the file management and storage 

issue. He further stated that neither CENTCOM nor USF-I had an adequate plan for managing 

the volume and location of the information it was maintaining as U.S. forces leave Iraq. 

SIGIR Notes Progress and Problems in Preserving Reconstruction 

Records 

SIGIR’s review found that the various DoD organizations in Iraq are proceeding with steps to 

assemble and permanently store their reconstruction records, but progress among the 

organizations varies significantly. USACE, one of the largest records holders, has made good 

progress, and has a detailed, written records management and archiving plan to guide records 

preservation efforts. However, the other DoD organizations had made less progress. For 

example, we noted that some organizations were missing records or did not know the status of 

records shipped to storage. Others lacked appropriate-sized facilities to store records or had not 

developed processes for organizing and retrieving those records in a timely manner.

USACE Has Transfer Plan but Lacks Data on Records Shipped to Storage 

At the time of our review, USACE had detailed plans for preserving its program, project, and 

contract records and had a process to transfer these records to a permanent storage facility. 

USACE has identified records for 8,470 projects valued at $16.15 billion in various 

reconstruction funds that it plans to store in Winchester, Virginia. According to the JS study of

USACE records, the records are well-kept and in good order. 

USACE’s records management plan follows Army Regulation 25-1, Army Knowledge 

Information Management and Information Technology, dated December 4, 2008. The plan

assigns responsibilities, identifies the records that should be preserved (such as signed contracts 

or task orders, statements of work, statements of requirements and quality assurance reports), and 

defines the process and procedures for archiving. The plan also states that well-marked and 

well-packaged hard copy and/or electronic documents from all offices (division, district, area, 

and resident offices) are required to be sent to the USACE records holding area in Winchester, 

Virginia. Overall responsibility for records management resides with USACE. 

One shortcoming in USACE’s process, however, is that it lacks comprehensive information on 

its progress in shipping completed records. Each regional office in Iraq handled the preparation 

and shipping of its project and contract records independently. According to a USACE official, 

there was no single collection point in Iraq for records from district offices around Iraq. The 

district offices did not send their official records transmittal and receipt forms capturing the 

status of their contract records to USACE when the districts were disbanded. 

However, USACE officials stated that it is in the process of gathering the forms generated from 

each former USACE district. Also, in commenting on a draft of this report, USACE stated that it 

established a records management section in November 2009 to ensure better oversight of the 

archiving of records. Using this information, USACE will identify the numbers of project and 
10 

contract records sent to Virginia. The division estimates that this task will be completed by 

October 2010. 

CENTCOM Contracting Command Made Progress in Permanently Archiving Contract 

Records but Needs Better Tracking of Records

The CENTCOM Contracting Command, which succeeded JCC-I/A, has undertaken a number of 

efforts to plan for the preservation of its reconstruction contract records. Many JCC-I/A records 

were shipped to a storage location in San Antonio, Texas, where they have been scanned into 

databases. However, a former JCC-I/A official noted that more needs to be done before the 

records are ready for final storage. In some cases, records are incomplete and prior audits have 

shown that other records could not be located. It is now the responsibility of CENTCOM

Contracting Command to address these issues. 

The Command established a Contract Closeout Task Force Office in November 2008, before 

JCC-I/A was disbanded. According to the Task Force Director, the JCC-I/A Commander 

directed that all contract records with a completion or award date in or prior to fiscal year 2009 

be shipped to the permanent storage facility by September 2009. Also, according to JCC-I/A 

contracting officials, JCC-I/A conducted an inventory of contracting records in Iraq and 

Afghanistan in 2009. That inventory identified 90,000 contracting records through fiscal year 

2008, which would fall under this requirement. JCC-I/A officials further informed us that of 

these records, 85,000 contracts were shipped to storage. The remaining 5,000 records were 

shipped to the Defense Contract Management Agency in southern Europe for contract closeout. 

As with USACE, JCC-I/A also lacks documentation to support the records it has shipped. A 

JCC-I/A official said that it shipped 90,000 contract records, but could not locate shipment 

record transmittal and receipts, and the person responsible was no longer in Iraq. According to 

the Task Force Director, they have developed a database to register the contract records received

from the JCC-I/A regional contracting offices in Iraq and Afghanistan. However, as of January

2010, the database was not fully operational. 

An additional problem impacting the storage and ease of document retrieval is the small size of 

the storage facility in San Antonio. In November 2009, the then-JCC-I/A Director of Operations 

informed us that the facility had the capacity to store only 25,000 records. This is about 25% of 

JCC-I/A’s record storage needs. In January 2010, JCC-I/A officials told us that the Task Force 

hired additional personnel to process the records and rented additional space to house those 

personnel. However, the issue of the space needed for the documents has not been resolved. 

J7 Engineering Program Management Branch Beginning Work on Assembling ISFF 

Program and Project Records

According to J7 Engineering Program Management Branch officials, the branch does not have 

procedures for shipping records to a final storage facility and is not familiar with the regulations 

for storage and disposition of project files. The officials noted that over the past five years of 

building facilities for the Iraqi Security Forces, project files were maintained by individuals with 

varying degrees of program management experience. As a result, the quality and completeness 

of the records they currently have vary from project to project. 
11 

The ISFF construction project records should include requirements statements, operational and 

training manuals, and asset transfer documents. In January 2010, officials from J7 informed us 

they were taking steps to preserve their ISFF files by purging, renaming, and organizing the files. 

In March 2010, the officials stated they had identified 2,134 projects closed as of January 31, 

2010, and planned to continue to work on assembling the files through the end of September 

2011. A J7 branch official noted it had not received any guidance from CENTCOM or 

ARCENT regarding where and to what office the records should be shipped. In commenting on 

a draft of this report however, CENTCOM stated its policies for records management were in 

effect at the time the J7 official made these statements. 

J8 Resource Management Branch’s CERP Project Records in Disarray

The J8 Resource Management Branch is responsible for managing the records for the $3.74 

billion CERP program. J8 officials told us that there are specific file content requirements for 

CERP projects, and that it has ensured that the project records have been maintained. They also 

said that they have been routinely sending records to ARCENT, which stores them in a facility at 

Fort Gillem, Georgia. 

Nevertheless, in this and other SIGIR audits, we have found serious problems in the 

completeness of CERP files and in the ability to locate CERP project records. For example, our 

review of J8 tracking information and work on other reviews and inspections found that DoD

does not have accurate information on its CERP records. During this audit, SIGIR attempted, 

but could not verify, the number of files shipped to ARCENT for fiscal years 2007 through 2009. 

We obtained a listing that J8 maintained of all the file numbers of records that were shipped and 

compared them to the CERP Project Tracking spreadsheet. The spreadsheet provides the project 

number and the status of the project. 

We found, however, that the file numbers used by the Multi-National Divisions to identify their 

records did not always match the numbers listed on the Project Tracking spreadsheet. During 

the course of the review, J8 officials stated that they would take steps to rectify this problem. In 

March 2010, a J8 official stated that the branch began creating an improved tracking system. 

The system is supposed to identify records shipped in the Project Tracking spreadsheet. 

Officials also stated they were in the process of formalizing the steps that needed to be taken to 

develop and preserve their records. Lastly, they noted they are formalizing the records 

management process which will include records training. 

SIGIR has experienced problems in retrieving records once they have been sent to the ARCENT 

storage facility. According to J8 officials, once the records are received at Fort McPherson, 

Georgia, they are shipped to a final storage facility co-located at Fort Gillem, Georgia. An 

ARCENT representative told us that the records often do not contain an inventory that would 

allow them to be catalogued and stored in a manner that permits easy identification and retrieval. 

ARCENT personnel also told us that the records are placed in cages and separated by fiscal year, 

location, and funding source. However, finding an individual record remains difficult since the 

boxes have been shipped from Iraq unlabeled and without an inventory of contents. 

To illustrate, in an ongoing review of a CERP-funded program, in May 2010 SIGIR requested 

116 CERP records from fiscal years 2007 through 2010. The J8 Project Tracking spreadsheet 

indicated that 66 had been sent to ARCENT. As of July 27, 2010, ARCENT was able to locate 
12 

31 of the records. However, an ARCENT official stated that it had taken approximately 150 

man-hours to locate the records. In a July 2010 visit to ARCENT, we confirmed the difficult 

problem facing ARCENT in inventorying and archiving these records. For example, we saw 

large pallets of unorganized records that had arrived from Iraq that ARCENT will have to 

catalogue for storage. ARCENT officials are fully aware of the problem and are taking steps to 

address the issues. These include issuing an instruction requiring better organization and 

cataloging of records shipped from Iraq and hiring additional personnel. In commenting on a 

draft of this report, ARCENT stated that it expects to issue final instructions for record storage 

and retrieval by September 1, 2010. If properly implemented, these steps should improve the 

record retrieval process. Figures 1-2 show ARCENT’s records storage facility. 

Figure 1: Pallet Boxes Containing Smaller Boxes of Files Sent From the Field 

Including Iraq and Afghanistan CERP Files. 

Source: SIGIR photograph taken during site visit July 27, 2010
13 

Figure 2: Contents of a Pallet Boxes Which Contain Boxes of FY08 CERP Files 

Sent Directly From the Field. 

Source: SIGIR photograph taken during site visit July 27, 2010.

AFCEE Records Are Not Ready for Final Storage 

AFCEE officials stated that none of its contract records are eligible to be sent to final storage. 

However, the officials stated that they are following the records requirements prescribed in Air 

Force Manual 33-363, Communication and Information, Records Disposition–Procedures and 

Responsibilities, dated March 1, 2008. 

AFCEE officials stated that contract files are eligible for final storage when the contract has been 

formally closed out for a least one year. According to AFCEE documents, as of March 2010, of 

the 291 contracts, 52 had been closed out. As such, AFCEE is maintaining all of the hard copies 

of contract records in its contracting office at Brooks Air Force Base, Texas. AFCEE staff in 

Iraq use electronic versions for their day-to-day management. AFCEE officials informed us that 

the contract records will be maintained and available for review as necessary at Brooks Air Force 

Base. 
14 

DoS and USAID Need To Improve Preservation 

Planning 

Although the U.S. Embassy-Baghdad organization responsible for overseeing reconstruction 

programs and the USAID Mission in Iraq have established policies and procedures for records 

management, they have not started implementing the procedures to archive the records to the 

United States. While these records represent a smaller volume of information than DoD records, 

they remain an important part of the reconstruction records. The Embassy’s Iraq Strategic 

Partnership Office (ISPO) has taken some steps to ready its files for transfer. The USAID 

Mission has made some progress, but its records remain in Iraq. 

U.S. Embassy Records Have Not Been Preserved

In September 2009, the former Iraq Transition Assistance Office (ITAO) created a new policy 

regarding archiving and preserving its records. It began taking steps to inventory existing

records and determine what records to archive and which records to destroy. Former ITAO 

officials informed us that in October 2009 they contacted the DoS Records Officer seeking 

guidance on preserving the ITAO records. DoS assigned a records manager to work with ITAO 

to help it determine what information should be preserved. The manager provided guidance on 

how and where to transfer records. 

ISPO officials informed SIGIR that they were taking actions to prepare their records for transfer

to storage. However, ISPO plans to continue to maintain all records in Iraq until it is no longer 

operational. ISPO maintains records of 35 projects for the nearly $40.5 million Ministerial and 

Management Capacity Development Program. The office also has 25 other reconstruction 

project and grant records. The records for any contract associated with these projects and grants

are the responsibility of the CENTCOM Contracting Command. ISPO records management

policies and procedures are governed by the DoS Foreign Affairs Manual and Handbook. That 

document contains policies and procedures for the creation, maintenance, use, and disposition of 

DoS records. The DoS records manager is located in Washington, D.C. and provides shipping 

and handling procedures for sending files to the Records Center in Newington, Virginia. ISPO

officials also informed us that they are confident that their records will be complete and ready for 

final storage when this information is no longer needed in Iraq. 

USAID Records Remain in Iraq

USAID Mission officials informed SIGIR that in January 2009 they began to implement agencywide records management and preservation requirements. The Mission stated that on February 

28, 2010, it had records for 107 contracts, grants, and cooperative agreements associated with its

$7.1 billion in reconstruction program activities, but all of its records remain in Iraq. 

The USAID Administrative Directive Systems Chapter 502, Records Management Program, 

dated September 2, 2008, contains the policies and procedures for creating, maintaining, storing, 

and disposing of USAID records. It requires that USAID’s Missions annually provide the 

Information and Records Division an inventory of all their records. USAID’s Missions are to 
15 

also provide a plan that addresses storage, transfer, and destruction of records. In response, in 

March 2010, the USAID Mission in Iraq completed a Records Inventory and Disposition plan 

that listed the 45 active and 26 closed awards and their location. Moreover, USAID established a 

guide that outlines the procedures for maintaining and updating electronic documents in the 

contracting office. The guidelines prescribe a filing format for contracts and task orders. It also 

tasks the contracting officer with verifying that appropriate documents are filed in accordance 

with the electronic filing procedures. 

However, the Mission has not met directive requirements that state that missions in “troubled 

areas where threat of emergency exists” can keep records covering no more than one fiscal year. 

Files older than one year must be shipped to the USAID Records Depository in Washington, 

D.C., to then be archived in the Washington National Records Center in Suitland, Maryland. 

Recognizing that the records cannot be permanently stored until all the financial and other 

administrative requirements have been completed, USAID agreed that 16 completed contract, 

grant, and program records totaling $257 million had gone through this process. Nevertheless, to 

date, USAID has not identified a permanent record storage area in the United States, and no 

records have been shipped. Moreover, as of June 2010, USAID Iraq could not tell SIGIR when 

it plans to begin shipping eligible records back to the United States. In addition, USAID had 

only partially updated its plan and was unable to explain why it needed to retain the files in Iraq. 

According to USAID officials, they plan to request that USAID Headquarters provide them 

guidance on what to do with their records. 

In commenting on a draft of this report, USAID stated that it had implemented an Agency-wide 

Vital Records Program for those records that are essential to the continuity of USAID activities 

under national emergency conditions. This includes scanning contract files and other records 

and storing these documents offline and offsite to facilitate easier access and recovery. In 

addition, based on the audit recommendation, files covering no more than one fiscal year will be 

packed in official retirement boxes and shipped to the depository in Washington, D.C., for 

retention. The depository serves as a staging area before USAID ships it records to the 

Washington National Records Center. 
16 

Conclusions, Recommendations, and Lessons Learned 

Conclusions 

DoD, DoS, and USAID, while having overall records management policies and procedures, 

nevertheless have gaps in implementing those policies and procedures. Some organizations have 

already shipped a substantial number of records to storage facilities, while others have not. 

Others were missing records and did not know the status of records that had been shipped to 

storage. Further, some organizations did not have the appropriate-sized storage facilities, 

adequate plans for preserving recordings, or the ability to retrieve those records in a timely 

manner. Lastly, in some cases, records management for joint reconstruction projects were 

dispersed among several DoD, DoS, and USAID organizations and not coordinated to ensure 

completeness and availability of project files. These conditions leave the U.S. government 

vulnerable to not having the necessary information to pursue potential cases of fraud and/or to 

perform audits of contracts, and losing records with historical value. It also illustrates SIGIR’s 

longstanding concerns about the ad hoc nature of the Iraq reconstruction management process 

that has led to a lack of accountability across the spectrum of reconstruction management issues.

DoD is responsible for the vast majority of Iraq reconstruction records. As such, it faces a 

significant management challenge. To this point, efforts have been mixed, and much remains to 

be completed. USACE’s efforts, and the JS study’s recommendations to enhance records 

management in Iraq, are steps in the right direction. Nevertheless, significant gaps exist in 

implementing the preservation process. This is particularly the case for CERP and ISFF records 

and, to a lesser extent, for CENTCOM Contracting Command’s records. The management 

challenge and associated risks are complicated because the preservation responsibilities are 

dispersed among at least five different DoD components, with differing regulations for 

accomplishing the task. Lacking central guidance, each component has moved forward to 

accomplish the task, achieving varying degrees of success. Nonetheless, actions must be taken 

within the existing framework to ensure these records are preserved. 

DoS and USAID have a much smaller volume of records to preserve than DoD. DoS has taken 

actions to organize its records but does not have a specific records preservation plan. USAID 

has a records preservation plan, but its records remain in Iraq. Further, both organizations appear 

to have control over their reconstruction records but are lacking guidance on how to proceed 

with preservation planning. 

Recommendations 

1. SIGIR recommends that the U.S. Secretaries of Defense and State and the Administrator of 

USAID assign an office the responsibility for ensuring the preservation of the Iraq

reconstruction records to provide transparency and accountability at the Department level. 

At a minimum, these offices should coordinate the development of a master list of records to 

(1) ensure record completeness; (2) link to program, associated contracts, and funding; and 

(3) develop uniform retention policies that are consistent with the needs of investigative and 

audit organizations. The office should also consult with agency historians to determine 

which records may require permanent archiving. 
17 

2. SIGIR recommends that the Commander, U.S. Central Command, in implementing the JS 

recommendations, include in the new guidance specific direction related to the transfer and 

preservation of reconstruction records that incorporates methods for tracking records, 

identification of program and associated funding, and final storage location. 

3. SIGIR recommends that the Commander, U.S. Central Command, direct the CENTCOM 

Contracting Command to review the efforts by the former JCC-I/A to identify remaining 

issues that need to be addressed in the preservation planning process, such as completeness 

of contracting records, missing records, tracking records, and the adequacy of storage 

facilities. 

4. SIGIR recommends the Commanding General, USF-I, direct that plans be developed for 

preserving the ISFF and CERP records. These plans could take the form of standard 

operating procedures to help ensure that existing records are complete and missing records 

have been identified. 

5. SIGIR recommends that the Commanding General, ARCENT, review the processes being 

used to store and locate CERP records. 

6. SIGIR also recommends that the Secretary of State provide U.S. Embassy Baghdad with 

detailed guidance to be used for the final storage of reconstruction records; and U.S. 

Embassy Baghdad develop plans for the preservation of reconstruction records in accordance 

with this guidance. 

7. SIGIR recommends that the Administrator, USAID, provide guidance to its Iraq Mission on 

the preservation of reconstruction records; and the Mission Director, USAID Iraq, develop 

plans for the preservation of reconstruction records in accordance with this guidance. 

Lessons Learned

Planning and guidance for the transition and preservation of records created during a 

contingency operation should be in effect at the beginning of the contingency operation, not left 

to chance at the end. Overall policies with clear lines of authority need to be developed and 

disseminated by JS for all combatant commands. In contingency reconstruction actions, it is 

critical that all agencies plan for the end of the operation by establishing comprehensive record 

keeping procedures from the start. This lesson learned should be implemented immediately for 

all other ongoing contingency operations, such as Afghanistan.
18 

Management Comments and Audit Response

CENTCOM, ARCENT, the USACE-Gulf Region District, and USAID provided comments on a 

draft of this report. CENTCOM and ARCENT concurred with the report’s recommendations 

and/or facts presented in the report and provided technical comments that SIGIR addressed as 

appropriate. USAID statements generally concurred with report’s recommendations and/or did 

not otherwise raise objections. We will follow-up with USAID to determine the specific actions 

it plans to take on our recommendations. Further, USAID also provided technical comments 

that SIGIR addressed as appropriate. USACE also provided technical comments that SIGIR 

addressed as appropriate. 

Any additional comments received will be made publicly available. 
19 

Appendix A—Scope and Methodology 

Scope and Methodology 

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

Project 9030 to examine agency plans for transitioning Iraq reconstruction program, project, and 

contract records to permanent storage facilities. The objective for this report is to determine the 

extent to which principal U.S. agencies responsible for managing Iraq reconstruction activities 

have plans to preserve reconstruction records. For purposes of this report, we use the term 

“plans” in a general nature to include policies and procedures used to implement records 

management requirements. SIGIR performed the audit 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. SIGIR conducted its work during November 2009 

through July 2010 in Baghdad, Iraq and the United States . 

To accomplish our objective we held discussions with officials and reviewed records 

management processes and procedures from the United States Army Corp of Engineers

(USACE); Air Force Center for Engineering and Environment (AFCEE); Joint Contracting 

Command-Iraq/Afghanistan (JCC-I/A); United States Forces-Iraq (USF-I) Engineering, 

Program, Management Branch (J7); USF-I Resource Management Branch (J8); Department of 

State’s Iraq Transition Assistance Office (ITAO) and Iraq Strategic Partnership Office (ISPO); 

and the U.S. Agency for International Development (USAID). We also visited the U.S. Army 

Central Command and reviewed their process for storing and retrieving records. 

Additionally, we reviewed the results of the Joint Staff Records Management Program 

Assessment of records management by combatant commanders. A follow-on assessment was 

conducted for USF-I during the course of our audit in April 2010. The Joint Staff assessment 

reviewed the records management programs for all of the USF-I directorates, except JCC-I/A,

whereas SIGIR only reviewed the records management programs of two USF-I directorates 

involved in reconstruction program management activities. To avoid duplication of effort we 

presented the work of the Joint Staff team once we verified it was consistent with the results of 

our ongoing work. 

We reviewed the Department of Defense and Department of State agencies policies and 

procedures that implement the Federal Records Act tenets and the National Archives and 

Records Association code of federal regulations for preservation and disposition of records. In 

addition, see Appendix C for a list of all regulations, polices, and guidance reviewed. We 

provided officials questions and reviewed the rules and regulations identified above to ascertain 

the scope of the records to be retained and whether the organization was in compliance with the 

rules and regulations for preserving program, project, and contract records. Our effort was 

extended to JCC-I/A, USACE, USF-I, AFCEE, U.S. Central Command (CENTCOM), ITAO, 

ISPO and USAID in order to include those agencies or organizations that generated program, 

project, and contract records in support of Operation Iraqi Freedom. We reviewed the 

procedures for transferring records which are not in compliance with federal rules and 

regulations. 
20 

The audit 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 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 computer-processed data contained in the MAXIMO database maintained by 

USACE and the Crystal Viewer systems database maintained by USAID for background and 

information purposes. The data was insignificant to the audit results and was not verified but 

considered sufficiently reliable for purposes of the audit objective.

Internal Controls 

In conducting the audit, we assessed certain internal controls pertinent to the audit objective with 

respect to agencies’ preservation of program, project, and contract records. Specifically, we 

identified and assessed internal or management controls, including processes for: 

• creation, maintenance, and disposition of Iraq reconstruction records

• recordkeeping activities for preserving program, project, and contracting efforts in Iraq 

Prior Coverage 

The SIGIR reports that were reviewed for this report are listed in Appendix D. 
21 

Appendix B—FAR Subpart 4.8 Retention Schedule

Source: Federal Acquisition Regulation, effective June 16, 2010.

Document Retention Period 

(1) Records pertaining to Contract Disputes Act actions. 6 years and 3 months after final action or decision for 

records created prior to October 1, 1979. 1 year after final 

action or decision for records created on or after 

October 1, 1979. 

(2) Contracts (and related records or documents, including successful proposals) 

exceeding the simplified acquisition threshold for other than construction. 

6 years and 3 months after final payment. 

(3) Contracts (and related records or documents, including successful proposals) at 

or below the simplified acquisition threshold for other than construction. 

3 years after final payment. 

(4) Construction contracts: 

(i) Above $2,000. 6 years and 3 months after final payment. 

(ii) $2,000 or less. 3 years after final payment. 

(iii) Related records or documents, including successful proposals, except for 

contractor's payrolls (see (b)(4)(iv)). 

Same as contract file. 

(iv) Contractor's payrolls submitted in accordance with Department of Labor 

regulations, with related certifications, anti-kickback affidavits, and other related 

papers. 

3 years after contract completion unless contract 

performance is the subject of an enforcement action on that 

date. 

(5) Solicited and unsolicited unsuccessful offers, quotations, bids, and proposals: . 

(i) Relating to contracts above the simplified acquisition threshold. If filed separately from contract file, until contract is 

completed. Otherwise, the same as related contract file. 

(ii) Relating to contracts at or below the simplified acquisition threshold. 1 year after date of award or until final payment, whichever 

is later. 

(6) Records for canceled solicitations. 5 years after cancellation. 

(7) Other copies of procurement file records used by component elements of a 

contracting office for administrative purposes. 

Upon termination or completion. 

(8) Documents pertaining generally to the contractor as described at 4.801(c)(3). Until superseded or obsolete. 

(9) Data submitted to the Federal Procurement Data System (FPDS). Electronic data 

file maintained by fiscal year, containing unclassified records of all procurements 

other than simplified acquisitions, and information required under 4.603. 

5 years after submittal to FPDS. 

(10) Investigations, cases pending or in litigation (including protests), or similar 

matters. 

Until final clearance or settlement, or, if related to a 

document identified in (b)(1) - (9), for the retention period 

specified for the related document, whichever is later. 
22 

Appendix C—Records Management Guidance

The Federal Records Act, as amended 

The Federal Records Act, as amended and codified at 44 U.S.C. Chapter 31, requires the head of 

each Federal agency to make and preserve records, maintain a continuing program for the 

economic and efficient management of the records, and provide for transfer of records to a 

records center if such transfer may affect the substantial economies and increased operating 

efficiency. The records management program overseen by Federal agency heads must provide 

for effective controls over the creation, maintenance, and use of records in the conduct of 

business, and for cooperation with the Administrator of the General Services Administration and 

the Archivist in applying standards, procedures, and techniques to improve records management. 

National Archives and Records Administration Code of Federal Regulations, 36 CFR 1220, 

Federal Records 

The National Archives and Records Administration Code of Federal Regulations Title 36, 

Chapter XII, Subchapter B prescribes policies for Federal agencies' records management 

programs to comply with the Federal Records Act, as amended. The regulations in this 

subchapter require adequate controls over the creation, maintenance, and use of records; 

provisions to ensure that records no longer of current use to an agency are promptly disposed of 

or retired; and an assigned responsibility for the development of the records management 

program. 

Federal Acquisition Regulation (FAR), Subpart 4.8 - Government Contract Files

The Federal Acquisition Regulation, Subpart 4.8, Government Contract Records, prescribes 

requirements for establishing, maintaining, and disposing of contract files. It requires the head 

of each office performing contracting, contract administration, or paying functions to establish 

records containing the records of all contractual actions. 

Defense Federal Acquisition Regulation Supplement, Section 204.805 – Disposal of Contract 

Files

The Defense Federal Acquisition Regulation Supplement, Section 204.805, Disposal of Contract 

Files Subsection 3, requires the holding of contract records in the office responsible for 

maintaining them for a period of 12 months after completion. After the initial 12 months, the 

records must be sent to the local records holding or staging area until they are eligible for 

destruction. If no space is available locally, the files must be transferred to the General Services 

Administration Federal Records Center. 

Department of State, 5 Foreign Affairs Manual 400, Records Management, and 5 Foreign 

Affairs Handbook - 4 H-100 through 5 FAH-4 H-400, Records Management 

Volume 5 of the Department of State’s Foreign Affairs Manual and Foreign Affairs Handbook 

establishes the policies and procedures for the Department of State Records Management 

Program and all of its components in the United States and abroad, as required by federal statutes 

and regulations. 
23 

United States Agency for International Development Administrative Directive Systems, 

Chapter 502, the USAID Records Management Program 

The USAID Records Management Program, found in USAID Administrative Directive Systems 

(ADS), Chapter 502, contains the policies and procedures for creating, maintaining, preserving, 

and disposing of USAID records. ADS Chapter 502 was revised on September 2, 2008.

Department of Defense Directive 5015.2, DoD Records Management Program 

DoDD 5015.2, dated March 6, 2000, updates DoD policy and responsibility for the DoD Records 

Management Program and updates policy and responsibilities for life-cycle management 

(creation, maintenance and use, and disposition) of information as records in all media, including 

electronic.

Chairman of the Joint Chiefs of Staff Instruction5760.01A, Records Management Policy for 

the Joint Staff and Combatant Commands, and Chairman of the Joint Chiefs of Staff Manual 

(CJCSM) 5760.01, Joint Staff and Combatant Command Records Management Manual: 

Volumes I and II 

Chairman of the Joint Chiefs of Staff Instruction 5760.01A, dated April 30, 2007, provides 

policy and guidance to the Joint Staff and the combatant commanders in the conduct of the Joint 

Staff and Combatant Command Records Management Program. Volume I of the Chairman of 

the Joint Chiefs of Staff Manual 5760.01, dated February 7, 2008, sets forth records management 

administrative instructions and procedural guidance for the Joint Staff and combatant commands. 

Volume II of the same manual, dated March 10, 2003, comprises the Joint Staff and combatant 

command records disposition schedule. 

CENTCOM Regulation 25-50, Records Management Policy 

CENTCOM R 25-50, dated October 12, 2009, prescribes policies and procedures for 

management of the Command Records Management Program, directed by Chairman of the Joint 

Chiefs of Staff Manual 5760.01A. 

Army Regulation 25-1, Information Management, Army Knowledge Management and 

Information Technology 

Army Regulation 25-1, Information Management, Army Knowledge Management and 

Information Technology, dated December 4, 2008, and effective January 5, 2009, updates and 

adds to Army records management responsibilities and assigns the records management senior 

Army role to the Administrative Assistant to the Secretary of the Army in accordance with 

public laws and regulatory guidance. 

Army Regulation 25-400-2, Information Management, the Army Records Information 

Management System

Army Regulation 25-400-2, Information Management, the Army Records Information 

Management System, dated October 2, 2007, implements Army Regulation 25-1, Chapter 8, 

Records Management Policy, governs the maintenance and disposition of Army information, and 

implements new policy on recordkeeping requirements for certain Army regulations. 
24 

Department of the Army Pamphlet 430-2, Guide to Record Keeping in the Army 

This pamphlet, dated August 11, 2008, provides operational procedures and guidelines for 

recordkeeping in the Army. It is to be used with Army Regulation 25-400-2. It provides 

guidelines for records cutoffs and transfers to a records holding area. 

Air Force Policy Directive 33-3, Communications and Information, Information Management 

Air Force Policy Directive 33-3, Communications and Information, Information Management, 

dated March 28, 2006, establishes the framework for how the Air Force creates, uses, and 

preserves information and data to achieve its strategic priorities, fulfill its missions, support its 

programs, deliver its capabilities, and meet its accountability obligations prescribed by statute. 

Air Force Instruction 33-322, Communications and Information, Records Management 

Program 

Air Force Instruction 33-322, Communications and Information, Records Management Program, 

dated October 7, 2003, implements Air Force Policy Directive 33-3, Information Management. 

It establishes policy and assigns responsibilities for life-cycle management (i.e., creation, 

maintenance and use, and disposition) of information as records in all media through the Air 

Force Records Management Program. 

Air Force Manual 33-363, Communications and Information, Management of Records 

Air Force Manual 33-363, dated March 1, 2008, implements Department of Defense Directive 

5015.2, DoD Records Management Program, and Air Force Policy Directive 33-3, Information 

Management. It establishes the requirement to use the Air Force Records Information 

Management System; establishes guidelines for managing all records (regardless of media); and 

defines methods and the format for record storage, file procedures, converting paper records to 

other media or vice versa; and defines the minimum to comply with records management legal 

and policy requirements. 

Air Force Instruction 33-364, Communications and Information, Records Disposition –

Procedures and Responsibilities 

Air Force Instruction 33-364, Communications and Information, Records Disposition –

Procedures and Responsibilities, dated December 22, 2006, implements Air Force Policy 

Directive 33-3, Information Management, by listing program objectives and responsibilities, 

guiding personnel in disposing of special types of records, retiring or transferring records using 

staging areas, and retrieving information from inactive records. 
25 

Appendix D—Records Management Deficiencies 

Identified in Previous SIGIR Reports 

Audit Reports

6/25/2004, 04-001 - Coalition Provisional Authority Coordination of Donated Funds 

Important information about planned reconstruction projects and donations was not being 

captured. 

7/30/2004, 04-008 - Coalition Provisional Authority Control Over Seized and Vested Assets 

Disbursement and approval documentation for the seized and vested assets was not readily 

available. 

4/30/2005, 05-007 - Administration of Iraq Relief and Reconstruction Fund Contract Files 

Contract files were incomplete and did not contain signed copies of the award or the required 

justification and approval records. 

4/30/2005, 05-008 - Administration of Contracts Funded by the Development Fund of Iraq

Files were missing contract awards, evidence that goods and services were received, invoices, 

and evidence of payment. 

7/8/2005, 05-009 - Reconciliation of Reporting Differences of the Source of Funds Used on 

Contracts after June 28, 2004

Development Fund for Iraq contract awards files were missing. 

07/26/2005, 05-010 - Interim Briefing to the Project and Contracting Office - Iraq and the 

Joint Contracting Command–Iraq on the Audit of the Award-Fee Process

Contract files were missing appointment letters for the award fee evaluation personnel. 

10/26/2005, 05-016 - Management of the Contracts and Grants Used To Construct and 

Operate the Babylon Police Academy

Contract and grant files did not contain the required documentation or the proper approval 

authority. 

10/26/2005, 05-020 - Management of the Contracts, Grant, and Micro-Purchases Used To 

Rehabilitate the Karbala Library

Contract and grant files did not contain accurate or required records on site visits, performance 

reports, and post award assessments. 

1/23/2006, 05-025 - Management of the Commander's Emergency Response Program for 

Fiscal Year 2005 

Commander’s Emergency Response Program project files were missing required documentation 

including appointment letters for purchasing officers, contract awards, and invoices from 

vendors. 
26 

4/28/2006, 06-008 - Development Fund for Iraq–Cash Accountability Review: Joint Area 

Support Group–Central 

There was no file system to store and readily retrieve the pay agent’s documents. 

4/28/2006 06-009 - Review of Task Force Shield Programs

There were limited records documenting program cost, how the money was used, or the location 

of the millions of dollars of equipment purchased with Task Force Shield funds. 

4/28/2006, 06-010 - Review of the Multi-National Security Transition Command–Iraq 

Reconciliation of the Iraqi Armed Forces Seized Assets Fund

Numerous contracts, modifications, invoices, receipts, and receiving reports needed to support or 

justify making payments were missing from the files. 

4/29/2006, 06-011 -Management of the Primary Healthcare Centers Construction Projects

Contract file does not have a record of who directed an estimated $39 million in undefinitized 

constructive changes to the award. 

4/28/2006, 06-015 - Iraq Armed Forces Seized Assets Fund: Review of Contracts and 

Financial Documents 

Contract files were incomplete and missing contract awards, amendments/modifications, 

deobligation confirmations, and closure checklists/forms. 

1/30/2007, 06-029 - Review of DynCorp International, LLC Contract Number S LMAQM04-C-0030, Task Order 0338, for the Iraqi Police Training Program Support

The contract file was missing key records on monitoring of the contractors’ performance and 

acceptance of the contractors’ work. 

4/26/2007, 07-006 - Management of the Commander’s Emergency Response Program in 

Iraq for Fiscal Year 2006 

CERP project files were missing, and the existing project files did not contain the required 

information to include appointment letters for purchasing and pay agents, copies of contract 

award, and invoices from vendors. 

10/29/2007, 08-003 - Review of the Use of Contracts in Managing Iraq Relief and 

Reconstruction Projects 

Contract files contained limited documentation on the award fee results, contractors’ 

performance, and disclosure restriction statements. 

1/25/2008, 08-006 - Commander's Emergency Response Program in Iraq Funds Many 

Large-Scale Projects

Management weaknesses related to incomplete project files continue to persist. 

4/29/2008, 08-011 - Review of Outcome, Cost, and Oversight of Electricity-Sector 

Reconstruction Contract with Perini Corporation

Quality-assurance reports were initially unavailable and dispersed throughout multiple locations 

in Iraq and the United States. 
27 

1/14/2009, 09-010 - Oversight of Aegis' Performance on Security Services Contracts in Iraq 

with the Department of Defense

There was no central depository for the contract-related electronic records that provide a history 

on the contractor’s performance. 

1/29/2009, 09-011 - Opportunities To Improve Management of the Quick Response Fund

The project files did not contain the all required closeout documentation identifying results of the 

project.

4/26/2009, 09-016 - Asset-transfer Process for Iraq Reconstruction Projects Lacked Unity 

and Accountability

There is no accurate and comprehensive project management information system on project 

construction, transfer, and operational status. 

7/26/2009, 09-026 - Commander’s Emergency Response Program: Hotel Construction 

Completed, but Project Management Issues Remain

Quality-assurance documentation was largely missing from the contract files. 

7/28/2009, 09-023 - Investigation and Remediation Records Concerning Incidents of 

Weapons Discharges by Private Security Contractors Can Be Improved

Files lacked records concerning reviews, investigations undertaken, and remedial actions for 

many of the weapons discharge incidents. 

10/26/2009, 10-002 - Data Provided to the Government of Iraq on U.S. Reconstruction 

Projects Lacked Clarity

The Iraq Reconstruction Management System project data provided to the Government of Iraq 

was unclear and gave the appearance of duplicate projects and payments. 

10/27/2009, 10-003 - Iraq Commander's Emergency Response Program Generally 

Managed Well, but Project Documentation and Oversight Can Be Improved

I-CERP project files were missing critical internal control documentation, such as receipts for 

cash payments and electronic funds transfers. 

1/28/2010, 10-007 - Wamar International Successfully Completed Contracts, but 

Unanticipated Problems Affected Costs and Schedule 

The official 2006 and 2007 Wamar contract award files were missing. 

4/26/2010, 10-013 Commander’s Emergency Response Program: Projects at Baghdad 

Airport Provided Some Benefits, but Waste and Management Problems Occurred

The CERP files lacked key records related to the transfer of projects to the Government of Iraq. 

4/29/2010, 10-015 - Health Center Sustainment Contract Resulted in Some Repairs, but 

Iraqi Maintenance Capability Was Not Achieved

The acquisition justification and other award-related records were not readily available at the 

time of the audit. 
28 

4/26/10, 10-013 - Commander’s Emergency Response Program: Projects at Baghdad 

Airport Provided Some Benefits, but Waste and Management Problems Occurred 

Project files were not well-maintained, and project tracking data were incomplete.

Inspection Reports

1/14/2010, PA-09-168 - Renovation of the Tomb of the Unknown Soldier, Baghdad Iraq 

Project file was not readily available and lacked payment documentation and quality assurance

reports.

4/21/2010, PA-09-189 - Basrah Modern Slaughterhouse, Basrah, Iraq 

Project file lacked legal analysis or written justification for the decision to approve the 

contractor‘s submittals. 
29 

Appendix E—Acronyms

Acronym Description

AFCEE Air Force Center for Engineering and the Environment

ARCENT U.S. Army Central Command

CERP Commanders Emergency Response Program

CENTCOM U.S. Central Command

DoD Department of Defense

DoS Department of State

ESF Economic Support Fund

FAR Federal Acquisition Regulation

IRRF Iraq Relief and Reconstruction Fund

ISFF Iraq Security Forces Fund

ITAO Iraq Transition Assistance Office

ISPO Iraq Strategic Partnership Office

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

SIGIR Special Inspector General for Iraq Reconstruction

USACE United States Army Corps of Engineers

USAID United States Agency for International Development

USF-I United States Forces-Iraq 
30 

Appendix F—Audit Team Members 

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

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

Reconstruction. 

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

Nancee Needham

W. Dan Haigler

Robin McCoy 

Arthur Granger

Walter Franzen 
31 

Appendix G—Management Comments
32 
33 
34 
35 
36 
37 

Appendix H—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 703-428-1059 

Email hillel.weinberg@sigir.mil

Public Affairs Deborah Horan

Director of 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: 703-428-0817 

Email: PublicAffairs@sigir.mil