OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

CELEBRATING THE ISSUANCE OF SIGIR AUDITS’ 200TH REPORT

SIGIR 12-006

OCTOBER 24, 2011

IRAQI POLICE DEVELOPMENT PROGRAM:

OPPORTUNITIES FOR IMPROVED

PROGRAM ACCOUNTABILITY AND 

BUDGET TRANSPARENCY
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 12-006 

Why SIGIR Did This Audit

On October 1, 2011, the Department of 

Defense (DoD) transferred responsibility for 

managing the continuing training of the Iraqi 

police to the Department of State (DoS). DoS 

is executing this effort through its new Iraqi 

Police Development Program (PDP), which 

seeks to assist the Government of Iraq (GOI) to 

strengthen police forces’ capabilities so that 

they can better maintain internal security. 

DoS’s Bureau of International Narcotics and 

Law Enforcement Affairs (INL) has the 

management lead and will provide advisors to 

mentor, advise, and train senior Iraqi police 

personnel.

In this audit, the Special Inspector General for 

Iraq Reconstruction (SIGIR) examined whether 

DoS/INL has a plan for the program possessing 

sound requirements and cost estimates, and 

whether DoS identified the funds and other 

resources that the GOI will contribute to the 

program, as required by law. We also 

examined related issues, such as security and 

overhead, that could affect program operations 

and costs. 

Recommendations

SIGIR makes three recommendations to the 

Secretary of State, highlighting the need for (1)

an adequate current assessment of the Iraqi 

police forces, (2) a more comprehensive and 

detailed program plan, and (3) a written 

agreement with the GOI ensuring its financial 

participation and agreement with the program’s

scope. 

Matters for Congressional 

Consideration 

SIGIR believes that, before additional funds 

are committed to the program, the Congress 

might consider requiring DoS to provide 

detailed data on (1) projected program costs, 

(2) existing funds available to meet FY 2012 

operational costs, and (3) expected GOI 

contributions. 

Management Comments and Audit 

Response 

The DoS agrees with SIGIR’s 

recommendations and notes that this report will 

aid in strengthening operational systems and 

controls for the PDP. Other DoS comments are 

addressed in the report as appropriate.

October 24, 2011 

IRAQI POLICE DEVELOPMENT PROGRAM: OPPORTUNITIES FOR IMPROVED 

PROGRAM ACCOUNTABILITY AND BUDGET TRANSPARENCY

What SIGIR Found

Our audit initially was impaired by DoS’s lack of cooperation, which resulted in 

limited access to key officials and documents. After an exchange of letters on 

this issue, the access problems were mitigated. Our somewhat limited 

discussions with and documents obtained from DoS officials, along with 

documents obtained from other sources, allowed us to determine that: 

• DoS does not have a current assessment of Iraqi police forces’ capabilities

upon which to base its program. Such an assessment is essential for 

effective program targeting. Further, DoS does not have a sufficiently 

comprehensive and detailed PDP plan that provides specifics on what is to 

be accomplished, including intermediate and long term milestones, 

benchmarks to assess progress and accomplishments, and transparency of 

and accountability for costs and performance outcomes. 

• DoS has reduced the size of the PDP since 2009 to offset increases in 

estimated costs and anticipated budget reductions. While it requested about 

$887 million for the program in FY 2012, current plans are to phase in a 

smaller and less costly program. Earlier this year, DoS, for the first phase of 

the program, reduced the number of planned advisors from 190 to 115 and 

eliminated the aircraft transport capability. INL officials estimate the FY 

2012 cost for Phase 1 to be about $500 million. 

• Spending plans indicate that only a relatively small portion of program 

funds—about 12%—will be used to pay for advising, mentoring, and 

developing the Iraqi police forces. The vast preponderance of money will 

fund security and life support. INL officials told us that they will seek ways 

to reduce costs of security, life support, and other overhead. 

• With the program now notably pared down, DoS plans to use remaining FY 

2010 and FY 2011 funds to pay some FY 2012 operational costs. INL data

indicates that as much as $200 million to $300 million could be available for 

this purpose. DoS did not provide SIGIR with sufficiently detailed data on 

current obligations, expenditures, and budgets, including the use of PDP 

funds to pay for Embassy operations (security, life support, and aircraft) that 

support the program. 

• DoS has not yet secured written commitments from the GOI regarding either 

its support for the PDP or its planned financial contributions, even though 

(1) DoS has written policy guidelines requiring GOI matching contributions 

and (2) congressional language appropriating funds for Iraq assistance 

specifies the use of these guidelines. 

We believe this audit raises serious concerns regarding the PDP’s long-term 

viability. The continual downsizing of the program, the planned use of unspent 

funds, and the lack of transparency regarding the use of program funds for

“Embassy platform” purposes (e.g., security, life support, and aviation) raise red 

flags about the program’s fund requirements. This report identifies opportunities 

for improved program accountability and budget transparency, which, if acted 

on, will strengthen the likelihood of program success. 
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

2530 Crystal Drive • Arlington, Virginia 22202

October 24, 2011 

MEMORANDUM FOR THE U.S. SECRETARY OF STATE

U.S. SECRETARY OF DEFENSE

SUBJECT: Iraqi Police Development Program: Opportunities for Improved Program Accountability 

and Budget Transparency (SIGIR 12-006) 

We are providing this audit report for your information and use. The report discusses the Department of 

State’s plans for the Iraqi Police Development Program, for which it became responsible on October 1, 

2011. 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 Project 

1106. 

In finalizing this report, we considered written comments dated October 14, 2011, from the Department of 

State on a draft of this report. We addressed these comments as appropriate and the comments are printed 

in their entirety in Appendix D. 

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

contact Glenn Furbish, Assistant Inspector General for Audits (Washington, D.C.), (703) 604-1388/ 

glenn.furbish@sigir.mil, or Jim Shafer, Principal Deputy Assistant Inspector General for Audits 

(Washington, DC), (703) 604-0894/ james.shafer@sigir.mil. 

Stuart W. Bowen, Jr.

Inspector General

cc: U.S. Ambassador to Iraq

Commander, U.S. Central Command

Commanding General, U.S. Forces–Iraq
Table of Contents

Introduction 1

Background 1

Objective 3

INL’s Program Not Based on an Adequate Assessment of Iraqi Police 

Capabilities and Not Guided by a Comprehensive Plan 5

Assessments Do Not Provide Basis for Program Priorities and Activities 5

INL Has Not Developed a Comprehensive and Detailed Plan 6

Cost Increases and Funding Uncertainties Result in Downsized Program 

and Unused Funds 9

Reduction in Number of Planned Advisors and Program Operations 9

Budget Requests for Larger Program Has Resulted in Unused Funds 10

Concerns About the Use of PDP Funds for Embassy Operations 12

Request for FY 2012 Funds for PDP Operations Not Based on Current Program 13

DoS Lacks Written Agreement with GOI on the Program 15

Conclusions, Recommendations, and Matters for Congressional 

Consideration 17

Conclusions 17

Recommendations 17

Matters for Congressional Consideration 18

Management Comments and Audit Response 19

Appendix A—Scope and Methodology 20

Appendix B—Letters by DoS and SIGIR Officials on Audit Impairment 22

Appendix C—Acronyms 42

Appendix D—DoS Management Comments 43

Appendix E—Audit Team Members 47

Appendix F—SIGIR Mission and Contact Information 48
1 

Iraq Police Development Program: 

Opportunities for Improved Program Accountability 

and Budget Transparency 

SIGIR 12-006 October 24, 2011 

Introduction

On October 1, 2011, the Department of Defense (DoD) transferred to the Department of State (DoS) 

responsibility for managing the Police Development Program (PDP) to assist the Government of Iraq 

(GOI) develop police forces capable of maintaining internal security. DoS’s Bureau of International 

Narcotics and Law Enforcement Affairs (INL) manages the program. DoD and DoS have been planning 

the transfer for about two years, and INL has already received about $745 million to support the PDP. 

Specifically, INL received $450 million in FY 2010 to support the program’s start-up requirements, and 

about $295 million for program operational costs in the 4th quarter of FY 2011. DoS has requested about 

$887 million for FY 2012 to maintain program operations for the program’s first year. 

INL anticipates at least a five-year program but states that, beginning in the fourth year, the program will 

require fewer resources as it will have built sufficient GOI capacity. The GOI’s Ministry of Interior 

(MOI) oversees the Iraqi police forces in 15 of Iraq’s 18 provinces, with the Kurdistan Regional 

Government responsible for the remaining 3 provinces. 

Background 

Since 2003, the United States has spent about $8 billion to train, staff, and equip Iraqi police forces to

maintain domestic order and deny terrorists a safe haven within Iraq. Within DoS, INL is responsible for 

developing policies and managing programs that strengthen law enforcement and other rule of law 

institutional capabilities outside the United States.1

In 2003, INL was assigned initial responsibility for the Iraqi police training program and funded it. The 

Department of Justice’s International Criminal Investigation Training and Assistance Program was also 

involved. However, program responsibility was transferred to DoD in 2004 due to the Iraq security 

situation, the scale of the task, and the need to ensure unity of command and effort. Specifically, on May 

11, 2004, National Security Presidential Directive 36

 

2

The DoD Program Built a Sizeable Force That Iraq Ministry of Interior Now Oversees 

assigned the mission of organizing, training, and 

equipping Iraq’s security forces, including the police, to the U.S. Central Command, until the Secretaries 

of State and Defense agreed that DoS should take on that responsibility. 

The DoD-run Iraqi police training program built a sizeable force. According to a May 2003 assessment 

conducted for the Coalition Provisional Authority, the Iraqi police force under Saddam Hussein numbered 

 

1 Presidential Decision Directive 71, February 24, 2000, directed DoS to strengthen criminal justice systems in 

support of U.S. peace operations and other complex contingencies. The Secretary of State designated INL as the 

primary focal point for rule of law matters. 2 United States Government Operations in Iraq, 5/11/2004.
2 

about 58,000. By 2010, DoD reported that there were 412,000 police in the force.3

 The Special Inspector 

General for Iraq Reconstruction (SIGIR) previously reported on problems in obtaining the true number of 

assigned and trained police.4

The Iraqi MOI oversees the nation’s police forces in 15 of Iraq’s 18 provinces

 SIGIR has also reported on the lack of performance metrics to assess the

DoD program. 

5

• The Iraqi Police Service, which comprises patrol and station police, as well as specialists such as 

forensic experts, assigned throughout 15 of Iraq’s provinces. Its mission is to enforce the law, 

safeguard the public, and provide internal security at the local level.

 including: 

• The Federal Police, which is a bridging force between the Iraqi Police Service and the Iraqi Army, 

allowing MOI to project police capabilities across provinces. It could be used to counter largescale civil disobedience and to attend to national emergencies. 

• The Border Police, which staff border forts and ports of entry to protect Iraq’s borders from 

unlawful entry. 6

• The Oil Police, which provide security for Iraq’s oil infrastructure.

• The Facilities Protection Services, which protect Iraqi government buildings. 

Although coalition forces initially managed and conducted police training, the MOI assumed the 

management of all police training centers, colleges, and stations in 2006. The MOI funds, staffs, and 

manages training centers, colleges, and police stations in 15 of 18 provinces in Iraq. Iraqi police 

instructors lead classroom instruction, and Iraqi officials manage all programs. The MOI operates 3 

police colleges and 28 training centers, while the Kurdistan MOI operates 2 police colleges and 6 training 

centers.

DoS Transition Planning Began in 2009 

The Strategic Framework Agreement between the United States and Iraq, signed in November 2008, 

provided a basis for continuing bilateral law enforcement and judicial training. One provision directed 

cooperation on enhancing law enforcement. The PDP grew out of this agreement. 

In 2009, DoS identified three options for assuming responsibility for the PDP. The options resulted from 

an interagency study of the DoD-led program. The option selected was endorsed as the approved concept 

of operations by the National Security Council’s Deputies Committee7

 

3 Measuring Stability and Security in Iraq, Department of Defense Report to Congress in accordance with the 

Department of Defense Supplemental Appropriations Act 2008, 6/2010.

 in August 2009. At that time, the 

4 Interim Analysis of Iraqi Security Force Information Provided by the Department of Defense Report, Measuring 

Stability and Security in Iraq, SIGIR 08-015, 4/25/2008; and Challenges in Obtaining Reliable and Useful Data on 

Iraqi Security Forces Continue, SIGIR 09-002, 10/21/2008. 5 The Iraq MOI does not oversee the police forces in the Kurdistan region. Those forces are overseen by the 

Kurdistan MOI. Future references to the MOI will be limited to the Iraqi MOI, unless noted. 6 Officially known as the Directorate of Border Enforcement and the Ports of Entry Directorate. 7 The National Security Council’s Deputies Committee is a senior sub-Cabinet interagency committee dealing with 

national security issues. The organization and function are detailed in the February 2009 Presidential Policy 

Directive-1.
3 

transition from DoD to DoS was planned for the summer of 2011—the date was later changed to October 

1, 2011. 

The DoS options paper identified the following guiding principles for an effective and credible PDP:

• The U.S. government has provided sufficient entry-level police training.

• The Iraqis are ready to assume greater responsibility for developing their internal security, desire 

a less intrusive mentoring and advisory program, and require ready access to qualified U.S. 

advisors. 

• The MOI needs effective assistance to build managerial and administrative skills at Baghdad and 

provincial headquarters.

• Higher-order training is required to build specialized criminal investigative skills.

• Assistance in curriculum development, instructor development, and training academy 

management is required at the three police colleges and 17 provincial police academies.

• Enhanced border integrity is an essential element for future Iraqi security.

In preparing for the transfer, DoD drew down its much more extensive program to sync with INL’s 

planned program levels. In doing so, it reduced the number of civilian police advisors from over 600 and 

redeployed police advisors from 12 camps around the country. The INL program will operate mainly out 

of three locations—Baghdad, Basrah, and Erbil. INL officials said that, as they begin operating the 

program from these locations, they recognize that the program will have to be conducted under the 

difficult and dangerous security environment that exists in Iraq. 

Other Organizations Have Supported Iraqi Police Development 

DoD and DoS have provided most of the U.S. support for the program to help train, staff, and equip Iraqi 

police forces. However, other U.S. organizations also have supported the program, in some cases with 

funding from INL. For example, the Federal Bureau of Investigations, Department of Homeland 

Security, and the Bureau of Alcohol, Tobacco, Firearms, and Explosives each provide specialized training 

as needed or requested. Also, the MOI requested that the Federal Bureau of Investigation assist in 

developing a federal investigation academy. Since 2005, the Department of Homeland Security has 

trained Iraqi personnel on a variety of skills, including: physical security; port operations; threat 

assessments; document analysis and search techniques; and developing border, customs, and immigration 

courses. The Bureau of Alcohol, Tobacco, Firearms, and Explosives has had a continuous presence in 

Iraq since 2003, providing support to the DoD police training program in an advisory capacity at crime 

scenes, in training development/delivery, and as subject matter experts in firearms, explosives, and other 

areas as requested.

Objective 

Our objective for this report is to address whether DoS/INL has a program plan with sound requirements 

and cost estimates, and whether DoS identified the funds and other resources that the GOI will contribute 

to the program. We also examined related issues that could affect program management and costs. 

The DoS did not fully cooperate with SIGIR during this audit. There were delays in gaining access to key 

officials and in obtaining documents. Moreover, the documents provided were incomplete and, 

particularly in the area of funding and budgets, the data was so incomplete that SIGIR could not clearly 

link DoS’s current program resources to budget requests. It is unclear whether DoS did not provide the 
4 

requested documents because they did not exist or for other reasons. This lack of cooperation is described 

further in Appendix A to this report, and Appendix B provides the letters exchanged between SIGIR and 

DOS officials addressing audit impairment. Because of the impairment, SIGIR’s audit is not as complete 

and detailed as envisioned. Nevertheless, because of significant concerns about program management 

and costs, as well as identified opportunities for improved program accountability and budget 

transparency, we are reporting on the audit work that we could complete. 

For a list of acronyms, see Appendix C. For management comments, see Appendix D. For the audit team 

members, see Appendix E. For the SIGIR mission and contact information, see Appendix F. 
5 

INL’s Program Not Based on an Adequate Assessment 

of Iraqi Police Capabilities and Not Guided by a 

Comprehensive Plan

INL has not currently assessed Iraqi police capabilities to the extent necessary to provide a sufficient basis 

for developing detailed program tasks and an effective system for measuring program results. Over twoand-a-half years ago, a Joint Transition Planning Team made a three-week visit to Iraq to gain a baseline 

understanding of Iraq police forces’ capabilities, but noted that a number of follow-on steps would be 

required for program design. However, the follow-on steps for program design were not accomplished

and a planned 2011 baseline assessment was not completed.

The only clearly stated program tasks are those that call for INL advisory teams to advise and mentor 

Iraqi police; these tasks do not provide a basis for measuring results against specific objectives. Further, 

INL does not have a comprehensive and detailed PDP plan that provides specifics on what is to be 

accomplished, intermediate and longer term milestones, measures to assess progress and 

accomplishments, and transparency and accountability for program costs and performance. 

Assessments Do Not Provide Basis for Program Priorities and 

Activities 

In March 2009, a Joint Transition Planning Team made a three-week visit to Iraq to gain a baseline 

understanding of Iraq police capabilities; however, this effort was not intended to and did not provide a 

basis for identifying program priorities and activities. According to the report, the intent of the Planning 

Team was not to conduct a comprehensive assessment of the status of the Iraqi police forces, but rather to 

provide a baseline understanding of current capabilities as well as future requirements and priorities. The 

Planning Team concluded that there was no longer a need for continuous local-level training for the 

police, but that limited technical assistance and mentoring and advising at the senior level was required. 

However, the Planning Team did not define specific areas of mentoring and advising. In fact it noted that 

a number of follow-on steps would be required in a program design phase. These steps included drafting 

comprehensive program work plans that described goals, strategies, staffing, timelines/staging, roles and 

responsibilities, and required resources. 

In October 2010, SIGIR raised concerns that DoS would be assuming responsibility for a program to 

advise and assist Iraqi police forces when the capabilities of those forces had not been assessed in any 

comprehensive way. We reported8

INL officials, recognizing the need for a further assessment, awarded a grant in April 2011 that included 

$1 million to conduct a base-line assessment of the Iraqi police. However, the assessment was not 

that neither DoD nor DoS has fully assessed the capabilities of the 

Iraqi police. DoD carried out some assessments, but they have limited usefulness in evaluating the 

current capabilities of the Iraqi police services. SIGIR recommended that the Commanding General, U.S. 

Forces-Iraq, in consultation with the Assistant Secretary, INL, work with the MOI to help assess the 

capabilities of the Iraqi police and provide that assessment to INL. Although U.S. Forces–Iraq agreed 

with the report recommendation, the assessment was not completed. 

 

8 Iraqi Security Forces: Police Training Program Developed Sizeable Force, but Capabilities Are Unknown, SIGIR-11-

003, 10/25/2010.
6 

completed. Still recognizing the need for such an assessment, INL officials said advisors would complete 

assessments as part of their initial program efforts by November 1, 2011. Given that INL has had two 

years to plan for this transition and that program activities are due to begin October 1, 2011, we are 

concerned about the lack of a current baseline for the program. Without a current assessment and a 

derivative plan to address the needs identified by the assessment, it is not possible to determine the 

resources needed to carry out the program and the related cost of those resources. 

INL Has Not Developed a Comprehensive and Detailed Plan

INL has not developed a comprehensive and detailed PDP plan. Similarly, DoD operated its Iraqi police 

development program for years without a comprehensive plan. In the previously cited October 2010 

report, SIGIR noted that DoD’s program lacked clearly articulated goals; a timeframe for accomplishing 

its goals; an estimated program cost; a list of required resources; and metrics to measure progress. 

Instead, elements of plans and programs existed but changed from one year to the next without 

explanation. 

DoS, with assistance from DoD, has been planning for more than two years for the transfer of the police 

training assistance program to INL. As stated earlier, the program evolved from three options identified 

in 2009. The selected option involved developing a hub-and-spoke concept of operations. Police 

advisors located at the three locations (hubs) travel to provinces, Iraqi training academies, and other key 

police facilities (spoke sites). They mentor and advise police officials and can provide higher-order 

training in subjects such as forensics, investigative skills, use of information technology in policing, and 

program management. The hub-and-spoke concept is designed to allow INL to adjust the size of the 

program depending on available funds and Iraqi needs. INL officials did not provide information on the 

two options not selected. However, in response to our question, they said that neither of the other 

program options would have involved a greater portion of program funds being used for program 

activities, as opposed to support activities such as security, life support, and transportation. They added 

that, as the program is being implemented, they will continue to seek ways to reduce security, life 

support, and other support costs.

The goal of DoS’s planned program is to set the stage for the gradual transfer of full responsibility for 

police development and law enforcement to the MOI. DoS reported that within a five-year program time 

frame (by 2016) Iraq could achieve the capacity to sustain program gains. Accordingly, the strategy is to 

devote substantial resources and efforts for a two to three-year period, followed by annual programs with 

diminished resources and assistance.

While DoS has further defined the program since the option was adopted, it has not developed specific 

goals on what is to be accomplished, intermediate and longer-term milestones, metrics to assess progress 

and accomplishments, and or means to ensure transparency and accountability for program costs and 

performance. In response to our request for a program plan, INL initially provided a four-page document 

dated January 20, 2011, and a five-page document dated March 10, 2011. These plans provide a general 

description of the program and its goal—assisting in the development of a professional MOI and its 

police services. They emphasize that the focus of the police development effort will be to mentor and 

advise Iraqi police officials, but note that the program will also involve structured classroom training for 

large audiences, particularly in advanced or specialized technical skills, as well as international training 

for a small number of officials. 

In a July 2011 meeting, INL officials asserted that its PDP plan entailed a collection of various 

documents, DoS cables, emails, and PowerPoint slides. On August 22, 2011, INL officials provided 

SIGIR a 22-page PowerPoint briefing slide presentation, prepared that month, and stated that this was 
7 

their current PDP plan. The August briefing slides contained additional program details, but did not 

present the basic elements required in a comprehensive plan. 

A few days later on August 26, 2011, INL provided a paper that outlined its draft goals, objectives, and 

performance measures for the PDP but noted that this important set of metrics would be fine-tuned to 

develop quantifiable indicators and measures of performance. Based on our review of this paper, INL has 

identified goals and objectives for MOI performance, but not how the PDP advisors will accomplish these 

goals and objectives. None of the nine identified goals (with multiple objectives and milestones) address 

the program’s objectives. The goals and objectives identified are for the MOI—not for the PDP—and the 

plan does not identify how the program advisors will be used to reach these goals and objectives.

In September 2011, INL provided SIGIR revised goals, objectives, and performance measures for the 

PDP. These revisions added additional details on metrics and evaluation indicators, but did not address 

how the PDP advisors will contribute to accomplishing the goals and objectives that INL established for 

the MOI. Further, INL provided no evidence that the MOI agrees with or will accept the goals, objective, 

and performance measures that INL determined the MOI should achieve. 

On September 22, after SIGIR briefed INL officials on its audit findings, INL provided a binder of 

documents it referred to as the “PDP Plan.” The INL transmittal note stated that the binder included 

many documents previously provided but organized as a more comprehensive plan. Specifically, the plan 

includes its August briefing slide presentation; the September revision of the list of goals, objectives, and 

performance measures; updated FY 2010 budget information; advisor position descriptions and 

deployment and staffing projections; descriptions of preliminary training plans; and a summary of its 

monitoring and evaluation advisor plans. 

In general, the plans provided by INL have progressed from the earlier four- and five-page documents to

longer PowerPoint presentations, to the binder of documents provided on September 22, 2011. However, 

a comprehensive and detailed plan, based on a current police force capability assessment and with INLfocused metrics, is still lacking. 

In assessing the adequacy of PDP plans, SIGIR uses the Government Performance and Results Act9

 and 

its update, the Government Performance and Results Modernization Act of 201010

• establish performance goals to define the level of performance to be achieved by a program activity

 to identify key plan 

elements. While the performance plans required by the Acts are agency-wide plans, the key elements are 

applicable for program plans. The Acts provide that performance plans should, among other things, 

• express such goals in an objective, quantifiable, and measureable form

• provide a description of how the performance goals are to be achieved, including clearly described 

milestones

• establish performance indicators to be used in measuring or assessing the relevant outputs, service 

levels, and outcomes of each program activity

• provide a basis for comparing actual program results with the established performance goals

 

9 Public Law 103-62, August 3, 1993. 10 Public Law 111-352, January 4, 2011.
8 

For the PDP, SIGIR believes that the above statements clearly indicate the need to define Iraqi police 

requirements and needs and how these requirements and needs will be met through a program of 

mentoring, advising, and training. 

INL documents indicate that the planned training and advising is largely unstructured and undefined, 

other than a program to mentor and advise, with some specialized training yet to be identified. Program 

documents note that advising and mentoring is highly individualized and dependent on the needs of the 

Iraqi police personnel, but that the advisory teams will have the necessary skills and expertise to advise, 

mentor, and train in a wide range of ministerial functions. The documents give examples of the types of 

assistance that will be provided, but also note that other assistance is being considered, and additional 

topics/areas of specialized assistance can be added as appropriate. Further, the documents note that a 

program team leader, working with Iraqi counterparts, will identify the functions or specific issues to be 

addressed and will assign experts to advise, mentor, and conduct training as needed. INL officials stated 

that flexibility is built into the PDP to respond to issues identified as the advisors interact with Iraqi 

officials. 

INL’s plan lacks details on specifically what the program and its advisors are to accomplish other than 

assisting and supporting the GOI in developing the management and leadership function of the Iraqi 

police forces. Further it lacks descriptions on how the advisors are to achieve performance goals. While 

earlier program documents mention a three- to five-year program, the planning documents we reviewed 

did not identify intermediate or longer-term milestones or measures for assessing progress and 

accomplishments, and none provide essential transparency and accountability for future years’ program 

costs and performance. Also, none of the planning documents present details on transferring program 

responsibility to the MOI. 

Without specific goals, objectives, and performance measures, the PDP could become a “bottomless pit” 

for U.S. dollars intended for mentoring, advising, and training the Iraqi police forces. Meetings held with 

Iraqi police officials and training courses provided could simply become “accomplishments,” without any 

indicators of changes in the management and functioning of the Iraqi police forces that can be attributed 

to this costly program.
9 

Cost Increases and Funding Uncertainties Result in 

Downsized Program and Unused Funds 

Since DoS began PDP planning in FY 2009, the program has been significantly downsized. The number 

of planned advisers was initially reduced from 350 to 190, and, because of budget concerns, that number 

for Phase 1 of the program has been reduced to 115 advisors, one-third of the original number. 

Furthermore, the use of aviation to transport advisors to various Iraqi sites has been put on hold along 

with the need for some related facilities. Only about 53 senior police advisors are expected to be on board 

as of October 1, 2011. Nevertheless, INL continues to plan for a program of 190 advisors and the use of 

Embassy aircraft, if full funding is appropriated. 

With the reduced Phase 1, the number of security, life support personnel, and other support staff required 

for the advisors would also decrease. As a result, FY 2010 and 2011 funds appropriated for a program 

with either 350 or 190 advisors will not be used as planned. INL plans to use these funds to pay 

operational costs in FY 2012. INL data indicates that about $200 million to $300 million could be 

available from these funds to pay FY 2012 program expenses. 

Reduction in Number of Planned Advisors and Program Operations 

INL estimated in 2009 that the yearly operational cost for a 350-advisor program was $721 million, or 

approximately $2.1 million per advisor per year. The 350 advisors (52 U.S. government employees and 

298 contractors) and 1,067 support and security personnel would be based out of Baghdad, Erbil, and 

Basrah, and would use both air and ground assets to support administrative and technical advice and 

mentoring to the MOI, the Provincial Headquarters, Police Colleges and Provincial/Regional Academies, 

the Federal Police, and the Department of Border Enforcement. 

A December 2010 briefing document shows that INL downsized the program to 190 advisors based out of 

the same three hubs. Figure 1 shows that the PDP was to have 28 sites, with 21 reached by land and 7 by 

air, in 10 of 18 provinces. INL planned for nine light-lift UH-1N helicopters in Erbil and three mediumlift S-61 helicopters in Baghdad. No helicopters were planned for Basrah. INL officials note that this is 

the program on which its FY 2012 budget request is based. 
10

Figure 1—PDP Site List as of December 2010

Source: INL briefing slide. 

For the downsized 190-advisor program, the estimated operational costs for the last quarter of FY 2011 

were about $294.5 million. This is the equivalent of $1.18 billion for a full year or approximately $6.2 

million per advisor per year—almost triple the initial estimated cost per advisor. Furthermore, current 

INL plans call for the vast majority of program funds to be spent on security, life support, and 

transportation, not directly to advise, mentor, and develop the Iraqi police.

By July 2011, INL officials decided to implement the program in two phases because they were not 

optimistic that the amount of funds requested for FY 2012 would be appropriated. They stated that Phase

1 of the program will be limited to 115 advisors distributed among the three hub locations—a reduction of 

235 advisors from the original plan of 350 advisors—and that air operations will be eliminated. 

Accordingly, the total number of sites to be served has been reduced from 28 to 21. Also, because some 

operational and security costs are fixed, the reduction to 115 advisors will likely result in a further 

increase in the annual operating cost per advisor. INL officials noted that the program could be ramped 

up to 190 advisors and 28 sites if requested FY 2012 funding is provided. 

Budget Requests for Larger Program Has Resulted in Unused 

Funds 

DoD and INL identified resource requirements for the transition of the police program and INL submitted 

budgets requests of $517.4 million for startup costs and $294.6 million for FY 2011 4th quarter operations. 
11

The startup funds were for the base camp and aviation facility upgrades, security infrastructure, the 

procurement of aircraft to transport advisors between program hubs and field locations, and initial 

funding to recruit and train key personnel, including security, contract management, and oversight 

personnel. 

In August 2010, INL received $450 million for startup costs, or $67.4 million less than requested, and 

$200 million for FY 2011 4th quarter operating costs, or $94 million less than requested. According to an 

INL official, the reduced and delayed startup funding resulted in INL suspending its plans to operate 

dedicated INL aircraft for the PDP. Table 1 shows the Department’s FY 2010 Supplemental 

Appropriations Spending Plan for the startup costs as of October 2010. In September 2011, INL provided 

updated expenditures data that shows how spending compares with the plan. 

Table 1—Spending Plan for Startup Costs Funded by FY 2010 Supplemental and Spending as of 

September 2011($ in millions)

Category of Cost

Planned 

Spending 

October 2010

Spending 

September 

2011

Upgrade hub and aviation facilities $343.7 $334.6

Purchase rotary wing aircraft 49.0 0.0

Recruit and train advisors, security, and aircraft maintenance personnel 32.3 33.0

Transfer of funds to Embassy operations 25.0 0.0

Total $450.0 $367.6

Source: DoS’s FY 2010 Spending Plan dated October 20, 2010 and INL-provided spending data as of September 2011. 

INL’s Spending Plan also identified initial operating expenses during the 4th Quarter of FY 2011 as shown 

in Table 2. As of September 2011, the only significant expenditures have been for security. INL officials 

noted that FY 2011 appropriated funds were not received until August 16, 2011. They stated that 

congressional committees have been briefed on plans to use FY 2011 4th quarter funds for FY 2012 

program operating costs. 
12

Table 2—Spending Plan for 4th Quarter FY 2011 Operating Costs Funded by FY 2010 

Supplemental and Spending as of September 2011 ($ in millions)

Category of Cost

Planned 

Spending 

October 2010

Spending 

September 

2011

Hire, train, and deploy 190 advisors and other experts $23.4 $0.0

Provide life and mission support 58.0 0.2

Provide movement and static security 85.0 75.3

Operate and maintain helicopter air wing 33.6 0.0

Total $200.0 $75.5

Source: DoS’s FY 2010 Spending Plan dated October 20, 2010 and INL-provided spending data as of September 2011. 

DoS’s plan to spend the $200 million shows that only about 12% of the funds are targeted to hire, train, 

and deploy police advisors and managers. The remaining 88% are for (1) life and mission support for the 

advisors and staff, (2) security for sites and transportation, and (3) operation and maintenance of the 

helicopter air wing. Based on INL’s September 2011 data, $75.3 million—virtually all of the $75.5 

million in expenditures—has been for security costs. 

For both FYs 2010 and 2011 funds, INL did not have information on expenditures by DoS’s Bureaus of 

Diplomatic Security and Overseas Building Operations, which are using PDP funds to upgrade program 

security and facilities. Accordingly, INL is reporting funds as expended after the funds are obligated. It

recognizes that some of these funds might not be expended and could be returned and used for other PDP 

costs. 

In its FY 2011 Foreign Operations budget justification, DoS requested an additional $314.6 million to pay 

for virtually the same requirements it had requested in its FY 2010 supplemental: “start-up requirements 

such as facilities upgrades, security infrastructure, and procurement of aircraft, as well as costs associated 

with recruiting; hiring; training; deploying; and supporting key program, support, and security personnel.” 

INL did not specify why these additional funds were needed nor did it provide SIGIR with its FY 2011 

Spending Plan. According to INL officials, the PDP received $94.56 million in FY 2011 funding. This 

amount, in addition to the $200 million provided in the FY 2010 supplemental, brought the FY 2011 4th

quarter funding back to the original amount INL requested. According to an INL document in August 

2011, none of the $94.56 million FY 2011 funds had been obligated. Based on this INL data, SIGIR 

estimates that about $200 million to $300 million could be available from FYs 2010 and 2011 funds to 

pay FY 2012 program expenses. 

Concerns About the Use of PDP Funds for Embassy Operations

SIGIR’s concerns about the lack of transparency and accountability in using PDP funds for police 

advising and mentoring and to support Embassy operations for the program such as security, life support, 

and aviation support is illustrated by the aviation situation. INL requested and obligated $49 million to 

purchase rotary aircraft. However, these aircraft will become part of one fleet operated in Iraq as 

“Embassy Air.” An INL document states that all aircraft will be operated as “one fleet” regardless of 

funding source and that the priority for rotary-wing aircraft will be as follows:

• Medical evacuation

• Quick Reaction Force
13

• Ambassador/VIP/Congressional Delegation

• Chief of Mission General Support

While we agree with the one fleet concept, we question why PDP funds would be used to purchase 

aircraft for the “Embassy Air” fleet when supporting the PDP is not a fleet priority. We believe that the 

justification for, and procurement of, needed aircraft should come from the fleet manager based on known 

and estimated requirements of all users. Further complicating the use of program funds to purchase 

aircraft is that, according to INL officials, air transport is no longer part of Phase 1 operations. INL 

officials said that the funds obligated for aircraft had been deobligated, but would remain committed for 

aircraft purchase so that the purchase could be made if full program funding becomes available. SIGIR

remains concerned about using PDP funds to purchase aircraft for the now non-program-related Embassy 

Air fleet. 

In addition to plans to use PDP funds to purchase aircraft, program funds are being used to upgrade 

aviation facilities and to recruit, hire, and train aircraft maintenance personnel. Again, SIGIR questions 

why program funds are being used for such “Embassy platform” expenditures. Similar questions exist 

about how program funds are being used to support Embassy security and life support activities.

While the PDP will depend on Embassy-provided security and life support, DoS/INL did not provide any 

detailed data on the basis for calculating these costs. In response to SIGIR’s request for detailed data on 

obligations and expenditures, INL reported that security costs are based on data provided by the Bureau 

of Diplomatic Security, using either a government cost estimate or a “rough order of magnitude” estimate. 

INL stated that to calculate life support costs, a rough order of magnitude estimate was developed based 

on data provided by Embassy Baghdad and the Bureau for Near Eastern Affairs. DoS believes that SIGIR 

does not have the jurisdiction to audit security and life support programs and thus did not provide us 

details about these two major PDP-fund expenditures. In commenting on security, life support, and 

aviation costs, INL noted that (1) the Department is at the crux of a transition effort at this time; (2) some 

cost estimates will have to be worked through over the next few months; and (3) costs will be modified to 

reflect on-the-ground experience and final costs. 

Request for FY 2012 Funds for PDP Operations Not Based on 

Current Program 

For FY 2012, INL’s budget justification includes $1 billion for Overseas Contingency Operations for Iraq 

and notes that the vast majority of these funds—about $887 million including $860 million for the 

program and $27 million for program development and support—are needed to support a full year of 

operation of the PDP. At the time of the justification, INL stated that the program would include about 

190 advisors based in three hub cities with planned travel to about 30 MOI critical spoke sites in an 

estimated 10 provinces. The justification is not specific on why the funds requested are needed or how 

they will be used; it states that $25 million is to be transferred to support other capacity-building work in 

the justice sector.

INL’s Phase 1 of the program is a much smaller PDP program than the one on which the FY 2012 budget 

request was based. As noted, the Phase 1 plan provides for 115 advisors versus 190 and does not include 

using air transportation (despite program expenditures for it). INL officials estimate the FY 2012 cost for 

the currently planned program at $500 million. However, even this downsized program will not be fully 

operational as planned on October 1, 2011. 

According to INL officials, staffing is behind schedule and facilities upgrades are delayed. In September

2011, INL officials reported that only 53 senior police advisors would be on board on October 1, 2011. 
14

Although INL is reporting that a total of 90 personnel were on board on October 1, this includes 27 

holdovers from the DoD program who will be replaced later, and 10 Department of Homeland Security 

Border Advisors. Some facilities upgrades at program sites will not be completed until mid-2012. 

Accordingly, FY 2012 operating costs for the program should be significantly less than requested in 

INL’s FY 2012 budget request and less than the $500 million estimated cost for a 115-advisor program. 

Program reductions and delays have resulted in much of the FYs 2010 and 2011 appropriations for the 

PDP not being obligated and expended. These unused funds would need to be considered in determining 

FY 2012 program funding requirements. Because of the program reductions and the availability of prioryear funds, a significant reduction in the FY 2012 budget request should be considered. SIGIR cannot 

recommend a specific reduction in requested FY 2012 funds that should be considered because DoS has 

not provided us with detailed data on obligations, expenditures, or detailed requirements and budget 

data—especially data detailing how program funds were used to support Embassy operations (security, 

life support, and aircraft fleet). 
15

DoS Lacks Written Agreement with GOI on the 

Program

The U.S. government has long recognized that host-country agreement with and commitment to 

assistance programs is important for program success. Furthermore, the Congress has required by law 

that the GOI assume greater responsibility for programs and pay a share of all reconstruction efforts. In 

April 2009, DoS established policy guidelines for GOI contributions to U.S. reconstruction efforts. 

Congressional language appropriating funds for Iraq assistance specified that U.S. funds be made 

available in accordance with these guidelines. However, the Department has not applied the guidelines to 

the PDP. 

DoS has yet to obtain a signed agreement with the GOI for the PDP, although hundreds of millions of 

U.S. dollars have already been spent on providing program support. It has also not prepared the 

documents required by the guidelines, which would describe the program cost and the GOI financial 

participation. SIGIR has reported that working closely with the GOI is essential to long-term program 

success and to avoid waste of U.S. funds. In prior work, SIGIR recommended that U.S. efforts be based 

on assurances that the GOI supports the U.S. approach, and that there are measurable indicators of 

progress. Absent such assurances, the programs are vulnerable to waste.11

In 2009, DoS and USAID drafted an Iraq-specific cost-sharing policy statement in response to 

congressional concerns on cost sharing and to provide guidance to U.S. government civilian agencies 

implementing assistance programs. These guidelines were submitted to the Congress with the FY 2009 

supplemental budget request. Pursuant to that plan, DoS has attempted to obtain a GOI cost-sharing 

agreement for the PDP. A July 2010 cable states that the Embassy “has introduced to the GOI a Letter of 

Agreement to act as a technical framework for engagement and continues to push for its signing.” 

According to the cable, an Iraqi interagency working group—the MOI, the Ministry of Justice, higher 

Judicial Council and Health Ministry—was formed to consider the Letter of Agreement. Embassy 

officials reported that they will continue to press the GOI to sign the Agreement.

According to INL officials, they do not yet have a written cost-sharing agreement with the GOI on the 

PDP. However, an INL official said that obtaining a written agreement is neither required nor critical, 

noting that INL already has advisors working with the MOI, that they are being “well received,” and that 

the work and action of the advisors “speaks loudly” to the support they are getting from the MOI. The 

official added that obtaining an agreement was not important because such agreements are simply paper 

and that paper can be torn up or ignored when a new MOI official is put in charge of the program. In 

meetings with MOI officials in August 2011, the Assistant Chief of Mission for Law Enforcement and 

Rule of Law Assistance suggested establishing a joint committee to discuss the PDP and areas where the 

U.S. could be of most assistance to the MOI. While no documentation was provided, an INL official said 

that the MOI leadership had agreed to create an advisory body for the PDP. 

The DoS cost-sharing guidelines specify that, to assess compliance with the guidelines, the Department 

must compile a written document describing the types of GOI financial participation to the program 

before the obligation of funds. In addition, the document is to include a plan for transitioning the program 

responsibility to the GOI or other Iraqi counterpart. INL did not provide SIGIR these documents in 

response to our requests. They provided one document showing that in October 2010, MOI had agreed to 

provide the U.S. with access and use of Joint Security Station Shield, a PDP site, at no cost.

 

11 Key Recurring Management Issues Identified in Audits of Iraq Reconstruction Efforts, SIGIR 08-020, 7/27/2008.
16

The guidelines also state that the required document setting forth the GOI financial participation must 

require the GOI counterpart to report at least semi-annually on their participation. The guidelines further 

note that, since the process will be subject to U.S. government audits, the programs should be set up to 

track and report on the GOI financial participation. None of the documents provided by INL for the PDP 

address these requirements. A Determination and Memorandum of Justification was submitted to 

congressional committees in January 2011 and reports that the GOI supports, and is cooperating with, the 

program. It further adds that substantial discussions have occurred about GOI contributions to the 

program and notes some contributions, but it also states that no final agreement has been made.

The DoS guidelines for GOI contributions state that the U.S. government will seek maximum GOI 

financial participation in U.S.-funded civilian foreign assistance programs and projects. It states that for 

programs that directly benefit or involve the Iraqi central government, or that are in its direct interest, the 

required contribution will be 50% of total program costs. The guidelines note that a significant portion of 

U.S. government program funding covers security and other special costs of operating in Iraq, such as 

extraordinary “life support” and force protection costs—in the case of the PDP it could be more than 80% 

of program costs, depending on what is included in special costs. The guidelines state that such costs 

shall be excluded from the basis for calculating the counterpart requirement because “it is not reasonable 

in these circumstances to expect the Iraqis to contribute to these costs.” SIGIR believes that the Congress 

could consider whether, and to what extent, these special costs of operating in Iraq might be considered as 

PDP costs that require a matching Iraqi contribution. 
17

Conclusions, Recommendations, and Matters for 

Congressional Consideration

Conclusions 

SIGIR believes that the following issues raise serious concerns about the PDP’s viability: (1) the lack of 

a current and accurate assessment of Iraqi police forces’ capabilities; (2) the absence of a comprehensive 

and detailed PDP plan; (3) the use of the vast majority of program funds for security, life support, and 

transportation; and (4) the lack of written GOI commitments to financially and otherwise support the 

program. The program’s continual downsizing, combined with the planned use of unspent funds and the 

lack of transparency regarding program funds and Embassy funds for security, life support, and aviation 

raises concerns about whether PDP appropriations are being used to support only program requirements. 

Based on the documentation provided, SIGIR could not determine how DoS developed its current $887 

million budget request for the program. Further, without additional detailed support for its FY 2012 (and 

beyond) program objectives, requirements, and costs, SIGIR questions whether the benefits derived from 

the limited resources devoted directly for Iraqi police development justifies the significant total costs. 

SIGIR believes that DoS could avoid wasting funds, and use appropriated monies more efficiently and 

effectively, if the following recommendations are implemented. 

Recommendations 

SIGIR recommends that the Secretary of State: 

1. Direct INL to work with the MOI to complete quickly an adequate current assessment of the Iraqi 

police forces that will provide a basis for the mentoring, advising, and training to be provided. 

2. Direct INL to finish quickly a comprehensive and detailed PDP plan that includes specifics on what is 

to be accomplished—including intermediate and longer term milestones, and metrics to assess 

progress and accomplishments—in order to provide greater transparency of and more accountability 

for program costs and performance. To the extent feasible, ensure that the PDP plan maximizes funds 

for direct program use as opposed to support activities. 

3. Complete a written agreement with the GOI on Iraqi roles and duties in the PDP—including 

agreement on the joint accountability for the PDP and the types and amount of Iraq’s financial 

participation. If such an agreement cannot be obtained, determine how the PDP should be modified. 
18

Matters for Congressional Consideration

SIGIR believes that the Congress could consider requiring DoS to provide data on and analysis of PDP 

plans, requirements, and costs before additional U.S. funds are committed to a program that is currently 

without budget transparency and measurable goals, and has the potential for significant waste. The 

Congress could also consider requiring DoS to provide details on how previously provided funds can be 

used to meet PDP costs in FY 2012, and documentation required by DoS guidance that describes the GOI 

financial contribution to the program. Further, the Congress could consider whether the GOI’s 50% 

contribution to PDP costs should be calculated by including or excluding security, life support, and other 

special costs of operating in Iraq.
19

Management Comments and Audit Response

On October 14, 2011, the DoS provided written comments on a draft of this report. DoS agreed with the 

SIGIR recommendations and noted that it is already implementing the three recommendations. The 

comments noted that the timely report will aid ongoing INL efforts to refine and strengthen the 

operational systems and controls necessary to support the PDP. We are encouraged by DoS’s agreement 

with the recommendations and with initial steps that have been taken. However, much remains to be 

done to adequately implement the recommendations.

In its comments, DoS states that “SIGIR’s speculation that the program would not be fully operational on 

October 1” is inaccurate. However, the comments acknowledge that by October 1, 2011, they will have 

deployed no more than 90 of the 115 planned advisors and that the full complement of advisors will not 

be in place until the end of 2011. Further, as stated in this report, some facility upgrades at program sites 

will not be completed until mid-2012. Throughout the audit, INL officials have stated and provided 

documentation showing that staffing for the PDP was behind schedule and that facilities were unfinished. 

SIGIR’s position that the program was not fully operational on October 1, 2011, is not based on 

speculation, but on the number of advisors available and the status of facilities.

DoS also states that SIGIR inaccurately suggests that “INL may be improperly applying FY 2010 and FY 

2011 funding to support operations into FY 2010.” DoS states that the intention to use prior year funds to 

support “initial operations” was stated in their FY 2010 and FY 2011 budget requests and spending plans. 

However, in its FY 2011 Congressional Budget Justification, DoS stated that such funding would be used 

to enable it to assume “full responsibility” for the PDP at the beginning of FY 2012. DoS’s FY 2010 

Supplemental Appropriations Spending Plan shows that it received $425 million for “one-time start up 

costs” and $200 million for the PDP during the “transition period,” with the transition period identified as 

the last three months in FY 2011. While the FY 2010 Supplemental Appropriations Act (P.L. 111-212) 

allowed these funds to remain available through FY 2012, these funds were justified and requested to pay 

only for PDP start-up and operational costs during FY 2011. SIGIR did not “suggest” that the use of 

these funds to support FY 2012 operations is improper. SIGIR’s discussion of these prior-year funds is to 

help ensure that the Congress considers this unused and available amount of about $200 million to $300 

million when determining the amount of FY 2012 funds needed for the program.
20

Appendix A—Scope and Methodology

In April 2011, the Special Inspector General for Iraq Reconstruction (SIGIR) announced Project 1106 to

audit the Department of State’s (DoS) Police Development Program (PDP), focusing on the goals, 

timeframes, and costs for the Program, planned to begin on October 1, 2011. SIGIR performed this 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 

from June 2011 through September 2011from its headquarters in Arlington, Virginia and in Baghdad, 

Iraq. 

SIGIR could not accomplish as complete and detailed audit as was planned because of a lack of DoS/INL 

cooperation. We did have discussions with INL officials and analyzed the few documents provided by 

the officials. We also analyzed other available public documents related to the PDP. However, the lack 

of cooperation impaired our ability to carry out the envisioned audit. The documentation that was 

provided was limited and was not provided in a timely manner. For example, our audit announcement 

was dated April 27, 2011, but DoS did not schedule an opening meeting until June 8, 2011, a delay of 

about six weeks. An early meeting scheduled for May 19, 2011 with INL officials was canceled about 

one hour before the scheduled time because of the officials’ “need for additional Department guidance” 

on responding to the audit. 

At the meeting on June 8, we requested documentation related to 10 different items, with the first item 

being “All plans related to the transition of responsibility for the PDP from the U.S. military to DoS/INL 

on October 1, 2011.” Among other documents requested were “Documents reporting on the coordination 

of program plans with the GOI (and other countries) including data on the GOI (and other countries) 

planned financial and other support for the program.” We also requested detailed information on DoS 

budget requirements, obligations, costs, expenditures, and spending plans for the PDP, along with their 

assessments of the Iraqi police capabilities. SIGIR did not begin receiving substantive documents on the 

program until more than two months after the request—we received some irrelevant and nonresponsive 

documents on July 19, 2011. Finally, in August, the Department sent a few documents related to the 

above requested items, and stated on August 12 that the documents provided “fully fulfills SIGIR’s 

current request for information.” SIGIR disagrees with this assertion. The provided documents were 

incomplete and did not fully fulfill our request. Furthermore, along with our request for documents, we 

requested contact information be provided for officials so that we could conduct follow-up discussions. 

We were not provided names of officials and therefore were not given access to them. Officials in the 

Bureau of Diplomatic Security did not respond to our requests for information and meetings. 

On June 29, 2011, the DoS Under Secretary for Management wrote to SIGIR expressing concerns about 

this audit and stating that DoS would limit SIGIR access to documents. Because of this letter and the lack 

of cooperation and delays in obtaining documents, SIGIR responded to the Under Secretary on July 1, 

2011, expressing concerns about DoS’s lack of cooperation. On August 3, SIGIR notified the Secretary 

of State and Congress of DoS’s continued obstructions to the execution of SIGIR’s statutory authority to 

conduct oversight. On August 4, 2011, the DoS Legal Adviser responded to that letter, and the next day 

the SIGIR General Counsel responded to the Legal Adviser. On August 12, 2011, the DoS Legal Adviser 

responded to SIGIR’s letters to the Secretary and to the Legal Adviser. Appendix B includes all of the 

letters exchanged between SIGIR and DOS officials addressing audit impairment. 

We conducted the audit 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 
21

evidence obtained provides a reasonable basis for our findings and conclusions based on our audit 

objectives.

Use of Computer-processed Data

Any computer-processed data used in this report was not critical to our findings, conclusions, or 

recommendations. Therefore, we did not test the accuracy of the data because it was used for background 

purposes only. 

Internal Controls 

In conducting this audit, we reviewed internal management controls within the context of specific plans, 

policies, and procedures for implementing and managing the PDP. For example, we addressed whether 

DoS has developed a comprehensive plan for the program describing (1) what the program is intended to 

accomplish, (2) milestones for program accomplishments, (3) means for monitoring and evaluation 

activities, and (4) how progress and accomplishments will be measured. We presented the results of our 

review on internal controls in the body of this report as appropriate. 
22 

Appendix B—Letters by DoS and SIGIR Officials on 

Audit Impairment
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42

Appendix C—Acronyms

ACRONYM DESCRIPTION

DoD Department of Defense

DoS Department of State

GOI Government of Iraq

INL Bureau of International Narcotics and Law Enforcement Affairs

MOI Ministry of Interior

PDP Police Development Program

SIGIR Special Inspector General for Iraq Reconstruction
43

Appendix D—DoS Management Comments 
44
45
46
47

Appendix E—Audit Team Members

This report was prepared and the audit conducted under the direction of Glenn Furbish, 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: 

David Childress

George Salvatierra

William Shimp
48

Appendix F—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 

 2530 Crystal Drive

 Arlington, VA 22202-3940 

Phone: 703-604-0368 

Email: hillel.weinberg@sigir.mil

Public Affairs Deborah Horan

Director of Public Affairs

Mail: Office of the Special Inspector General 

for Iraq Reconstruction 

 2530 Crystal Drive

 Arlington, VA 22202-3940 

Phone: 703-428-1217 

Fax: 703-428-0817 

Email: PublicAffairs@sigir.mil