OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

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SIGIR 

Special Inspector General for IRAQ Reconstruction 

For more information, contact SIGIR Public Affairs at 

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

Summary of Report: SIGIR 11-018 

Why SIGIR Did This Study 

Private security contractors play an important 

role in Iraq by protecting U.S. personnel, 

facilities, and property. In August 2009, the 

Department of Defense (DoD) awarded five 

Theater-wide Internal Security Services 

(TWISS) contracts for site security in Iraq. The 

five contracts have a combined not-to-exceed 

value of $485 million. 

Base commanders, under U.S. Forces–Iraq, 

nominate contracting officer’s representatives 

(CORs), who are responsible for verifying the 

U.S. government receives what it pays for. The 

Defense Contract Management Agency 

(DCMA) appoints and trains CORs and 

manages their activities. DCMA uses Quality 

Assurance Representatives (QARs) to monitor 

the CORs’ and contractors’ performance. 

SIGIR is reporting on the U.S. government’s (1) 

oversight of the TWISS contracts, and (2) 

process for adjusting those contracts as U.S. 

forces withdraw. 

What SIGIR Recommends 

SIGIR recommends the Director, DCMA, direct 

actions to (1) provide regular feedback on 

CORs’ performance, (2) train and appoint 

alternate CORs, (3) verify that all COR and 

QAR reviews are conducted, and (4) provide 

COR nominating officials information about 

CORs’ time and duty requirements. 

SIGIR also recommends the Commander, U.S. 

Forces–Iraq, direct actions to (1) assess and 

rebalance the workload of TWISS CORs, and 

(2) enforce existing policy that rating officials 

evaluate COR performance during assessments. 

Lessons Learned 

The issues SIGIR identifies in this report and 

the recommendations SIGIR makes could be 

applicable to a broad array of U.S. government 

contracts utilizing CORs, although they appear 

most applicable to contracts in contingency 

environments. 

Management Comments and Audit 

Response 

DCMA concurred with two recommendations 

and non-concurred with two. USF-I concurred 

with SIGIR’s recommendations. 

July 28, 2011 

CONTROL WEAKNESSES REMAIN IN OVERSIGHT OF THEATER-WIDE 

INTERNAL SECURITY SERVICES CONTRACTS

What SIGIR Found 

Although COR duties are critical to the U.S. government’s oversight of the 

TWISS contracts, SIGIR found issues that could adversely impact their 

ability to perform those duties, leaving the U.S. government at risk of 

contractor fraud, waste, and abuse. Specifically, almost 40% of the CORs 

we surveyed said the training they received did not prepare them for their 

duties and 25% said they lack sufficient time to conduct effective oversight. 

SIGIR found similar issues the last time it looked at the TWISS contracts in 

2009. After that report, DCMA increased training requirements but 

recognized in an April 2011 internal review that not all training was being 

conducted and documented. Regarding the lack of time, DCMA said only 

the CORs’ commanders can rebalance workloads and that during the process 

to nominate CORs, nominating officials are affirming CORs have the time 

and resources to perform their duties. While this may be true, SIGIR 

believes DCMA should better inform the CORs’ nominating officials of the 

time required to perform their duties. USF-I, for its part, needs to assess the 

CORs’ workloads and identify actions to rebalance those workloads. 

SIGIR also found that CORs are not completing, or DCMA is not 

maintaining, all monthly review checklists, which DCMA developed to help 

CORs review contractor compliance with task order requirements. Even 

when completed, SIGIR noted most reviews appeared to be of questionable 

value or provided little assurance that CORs’ oversight was adequate, a fact 

DCMA officials acknowledge. These reviews are important to DCMA’s 

ability to perform its contract administration and oversight responsibilities. 

Despite DCMA’s concerns about the performance of some CORs, it did not 

provide the CORs or their rating officials with regular feedback on 

performance. At the same time, the CORs’ rating officials did not request 

COR performance information from DCMA. SIGIR believes regular, 

written feedback would (1) alert the CORs to areas where they need 

improvement, (2) alert rating officials to the CORs’ weaknesses and the 

possible need for additional training or relief from other duties, and (3) 

provide rating officials with the information they need to comply with the 

Deputy Secretary of Defense’s policy memorandum requiring that raters 

evaluate CORs’ performance during assessments. 

SIGIR also notes that many locations lacked trained backup CORs when the 

primary COR was unavailable. CORs may not always be available to 

perform their oversight duties because of vacations, sickness, emergencies, 

and duty rotations. Trained backups would ensure continuity in contractor 

oversight during these times. 

Finally, the process to terminate TWISS task orders as U.S. troops withdraw 

and the U.S. military closes or transfers bases to the Iraqis appears to be 

working well. 
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

400 Army Navy Drive • Arlington, Virginia 22202 

July 28, 2011 

MEMORANDUM FOR COMMANDING GENERAL, U.S. FORCES–IRAQ 

DIRECTOR, DEFENSE CONTRACT MANAGEMENT AGENCY 

SUBJECT: Control Weaknesses Remain in Oversight of Theater-wide Internal Security 

Services Contracts (SIGIR 11-018) 

We are providing this audit report for your information and use. The report discusses control 

weaknesses associated with oversight of the Theater-wide Internal Security Services contracts. 

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 1008. 

We considered comments from U.S. Forces-Iraq, U.S. Central Command Joint Theater Support 

Contracting Command, and the Defense Contract Management Agency when preparing this final 

report. The comments are addressed in the report, as appropriate. 

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

report, please contact Glenn D. Furbish, Assistant Inspector General for Audits (Washington, 

DC), (703) 604-1388/ glenn.furbish@sigir.mil or Jason Venner, Principal Deputy Assistant 

Inspector General for Audits (Washington, DC), (703) 607-1346/ jason.venner@sigir.mil. 

Stuart W. Bowen, Jr. 

Inspector General 

cc: U.S. Secretary of State 

U.S. Ambassador to Iraq 

U.S. Secretary of Defense 

Commander, U.S. Central Command 

S i l I t G l f I R t ti
Table of Contents 

Introduction 1

Background 1

Objectives 3

Control Weaknesses Remain with COR Oversight of the TWISS Contracts 5

CORs and QARs Perform Key Roles in TWISS Oversight 5

Some TWISS CORs Lack Sufficient Training and Time To Conduct Effective Oversight 6

DCMA Does Not Have Documentation of All Monthly Reviews 8

DCMA Has Not Provided Performance Feedback on Poorly Performing CORs 9

Contracting Office Has A Process To Close TWISS Task Orders as Troops 

Withdraw 11

Conclusions, Recommendations, and Lessons Learned 12

Conclusions 12

Recommendations 13

Lessons Learned 13

Management Comments and Audit Response 14

Appendix A—Scope and Methodology 16

Appendix B—Acronyms 19

Appendix C—Audit Team Members 20

Appendix D—CENTCOM Joint Theater Support Contracting Command 

Comments 21

Appendix E—USF-I Inspector General Comments 22

Appendix F—DCMA Comments 23

Appendix G—SIGIR COR Survey Questions 30

Appendix H—SIGIR Mission and Contact Information 35
1 

Control Weaknesses Remain in Oversight of Theater-wide 

Internal Security Services Contracts 

SIGIR 11-018 July 28, 2011

Introduction 

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

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

relies on PSCs to provide static, or site, security throughout Iraq by guarding and protecting 

fixed locations, such as forward operating bases.1 In September 2007, DoD awarded five 

Theater-wide Internal Security Services (TWISS) contracts to PSCs for static security at various 

bases in Iraq.2

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

reported on the cost, requirements, and oversight of these contracts, noting that contracting 

officer’s representatives (CORs) sometimes had insufficient experience, training, and time to 

perform their oversight roles.3 In August 2009, DoD awarded another five TWISS contracts. 

The combined not-to-exceed value of the five current contracts is $485 million, about $258 

million of which has been disbursed as of June 9, 2011. 

This report focuses on the five current TWISS contracts and responds to the mandate in Section 

842 of the National Defense Authorization Act for 2008, Public Law 110-181, that requires 

audits of the performance of security functions to address the manner in which DoD exercised 

control over the contractors’ performance. 

Background 

In August 2009, the U.S. Central Command’s (CENTCOM) Joint Theater Support Contracting 

Command4

 awarded five TWISS contracts on behalf of United States Forces–Iraq5 (USF-I) to 

EOD Technology, Inc.; Torres Advanced Enterprise Solutions, LLC; Special Operations 

Consulting-Security Management Group; Triple Canopy, Inc.; and Protection Strategies Inc. 

The TWISS contracts were created to streamline the contracting process for static security in 

anticipation of an increased need for these services in Iraq. Requirements for the contracts were 

based on the need to replace U.S. troops performing static security with private security 

contractors, leaving more troops available for combat operations. 

 

1

 A forward operating base is an area used to support tactical operations without establishing full support facilities. 2

 The five PSCs were: Aegis Defense Services, Limited; EOD Technology, Inc.; Sabre International Security; 

Special Operations Consulting-Security Management Group; and Triple Canopy, Inc. 

3 Need To Enhance Oversight of the Theater-wide Internal Security Services Contracts, SIGIR 09-017, 4/24/2009. 4

 At the time these contracts were awarded, CENTCOM Joint Theater Support Contracting Command’s portfolio 

was handled by the Joint Contracting Command–Iraq/Afghanistan. In April 2010, this command transitioned into 

CENTCOM Contracting Command, which later changed its name to CENTCOM Joint Theater Support Contracting 

Command. 

5

 At the time these contracts were awarded, the requesting organization was called Multi-National Force–Iraq, which 

was replaced by the United States Forces–Iraq on January 1, 2010. 
2 

The five contractors can bid on task orders for the protection of installations in Iraq. Each 

installation is covered by a task order and each task order has a twelve-month period of 

performance and two option periods not to exceed six months each. Each current contract has a 

$25 thousand minimum value, and all five contracts have a combined not-to-exceed value of 

$485 million. As of June 9, 2011, about $258 million had been disbursed under the contracts. 

CENTCOM Joint Theater Support Contracting Command has awarded a total of 53 TWISS task 

orders under the current contracts, 29 of which are still active. USF-I plans to close the 29 

remaining bases in 2011 as follows: nine in September, twelve in October, two in November, 

and the remaining six in December. See Table 1 for task orders and disbursements by contractor. 

Table 1—Task Orders and Disbursements by Contractor ($ in millions) 

Contractor 

Awarded

Task Orders 

Active

Task Orders Disbursements

Special Operations Consulting-Security 

Management Group 16 13 $153.6

Torres Advanced Enterprise Solutions, LLC 14 6 46.8

Triple Canopy, Inc. 11 7 44.6

EOD Technology, Inc. 10 3 10.1

Protection Strategies Inc. 2 0 2.6

Total 53 29 $257.8

Notes: 

Disbursements do not add due to rounding. 

Source: Disbursements from the Defense Finance and Accounting Services as of June 9, 2011; Task Orders from CENTCOM 

Joint Theater Support Contracting Command, as of July 1, 2011. 

CENTCOM Joint Theater Support Contracting Command is the contracting office on the TWISS 

contracts. It delegated contract administration and oversight to the Defense Contract 

Management Agency (DCMA). DCMA appoints and relies on CORs for day-to-day oversight of 

the contractors’ performance and compliance with contract requirements. All 29 active task 

orders have at least one COR, all of whom are U.S. military members. Some task orders also 

have one or more alternate CORs. As a result, there are currently 43 total CORs on the TWISS 

contracts—32 primary and 11 alternate. Alternate CORs perform their duties when the primary 

CORs cannot. All TWISS CORs are located on site where the TWISS contractors provide their 

services. DCMA also employs Quality Assurance Representatives (QARs) to periodically 

instruct and inspect the CORs’ performance and inspect the contractors’ performance and 

compliance with requirements. This includes providing the CORs’ on-site orientation and 

baseline performance reviews, reviewing the CORs’ records, mentoring the CORs, and 

conducting their own monthly contractor reviews. DCMA assigns a QAR to each TWISS task 

order. 

SIGIR’s April 2009 report identified certain vulnerabilities in the government’s oversight. 

Generally, the TWISS CORs had limited experience and training, and insufficient time to devote 

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

example, of the 27 CORs that responded to SIGIR’s questions in April 2009, only 4 CORs said 
3 

they had previous COR experience, 11 said their training was insufficient to meet their job 

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

result, SIGIR recommended DCMA, USF-I, and Joint Contracting Command–Iraq/Afghanistan, 

 Provide additional training to CORs on their TWISS contract oversight responsibilities, 

and 

 Assess the CORs’ workload to identify actions that can be taken to balance workload and 

provide the CORs with sufficient time to perform their contract oversight responsibilities. 

We considered the findings and recommendations in SIGIR’s prior report in developing our 

methodology for this audit, leading us to focus on the CORs’ activities and oversight. 

Objectives 

SIGIR is reporting on the U.S. government’s oversight of services provided and charges billed 

under TWISS contracts, as well as the U.S. government’s process for adjusting those contract 

requirements as the U.S. military withdraws from Iraq. With regards to our oversight objective, 

SIGIR focused primarily on the roles and responsibilities of the CORs since these individuals are 

critical to the government’s oversight. 

To accomplish our objectives, SIGIR attempted to survey all 43 TWISS CORs to obtain 

information about their prior experience, training received, and responsibilities, among other 

things. While SIGIR requested responses from all 43 CORs, we received only 28 responses. 

This response rate was at least partly the result of the time it took using the process USF-I 

required us to use to obtain this data. Specifically, we obtained the CORs’ names, locations, and 

contact information from DCMA, for whom the CORs perform their oversight. Because the 

CORs are directly assigned to USF-I commanders, the USF-I Inspector General would not allow 

us to contact the CORs directly but required the USF-I Inspector General to send our 

questionnaire out as a formal order, addressed to the CORs’ commanders. The USF-I Inspector 

General also required that all responses be returned to the Inspector General, who forwarded 

them to SIGIR. To expedite the process, a representative from the USF-I Inspector General’s 

office spent many hours identifying the CORs’ commanders. However, between the time we 

gave the list of CORs to the Inspector General and when we received the CORs’ responses, a 

total of 30 days had elapsed, and 10 CORs had left Iraq.6

 Since that process took so long and we 

would have had to use the same process to contact the replacement CORs, we were unable to 

follow up with the replacement CORs and still meet our reporting timelines. Had SIGIR been 

able to contact the CORs directly, we believe two to three weeks would have been eliminated 

from the process, thus allowing time to contact the replacement CORs and follow up on nonresponses. SIGIR considers the restrictions imposed on contacting CORs directly to be an 

external impairment to our independence that interferes with our ability to form independent and 

objective opinions, findings, and conclusions. For a further discussion of this impairment, see 

Appendix A. SIGIR is working with USF-I to address this problem. 

 

6

 Of the other five non-responses, one was on emergency leave, one had his base closed, and three did not respond to 

our request. 
4 

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

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

Appendix C. For comments from CENTCOM Joint Theater Support Contracting Command, see 

Appendix D. For comments from the USF-I Inspector General, see Appendix E. For comments 

from the Defense Contract Management Agency, see Appendix F. For a copy of SIGIR’s COR 

survey, see Appendix G. For the SIGIR mission and contact information, see Appendix H. 
5 

Control Weaknesses Remain with COR Oversight of 

the TWISS Contracts

Although CORs are responsible for verifying the U.S. government receives what it pays for, 

SIGIR found control weaknesses associated with their oversight of the TWISS contracts that 

leave the government at risk of contractor fraud, waste, and abuse. Specifically, 11 of 28 CORs 

from whom we received completed surveys stated the training they received did not prepare 

them for their COR duties, and 7 stated they lack sufficient time to conduct effective oversight 

on the task orders for which they are responsible. These are similar issues to those uncovered 

during our prior TWISS report in April 2009. We also found that DCMA did not have copies of 

all monthly reviews required of the CORs and could not determine whether they were not 

prepared or not in the files. Of the monthly reviews we sampled, many indicate weak 

oversight—a fact that DCMA officials acknowledged. Moreover, despite DCMA’s concerns 

that some CORs may not be performing their oversight functions effectively, we found that 

DCMA—and QARs in particular—were not providing the CORs or their rating officials with 

feedback on the CORs’ performance. While DCMA’s policy guidance does not require that 

CORs or their rating officials be provided regular performance feedback, SIGIR believes this 

does not relieve DCMA of the responsibility to correct these identified problems. 

CORs and QARs Perform Key Roles in TWISS Oversight 

CORs and QARs perform key oversight roles on the TWISS contracts. CORs are to verify that 

the U.S. government receives all services for which it pays and that the contractors’ charges are 

allowable. QARs are to help train and mentor CORs and perform their own reviews of the 

contractors’ performance. 

Roles and Responsibilities of CORs 

CORs are the primary oversight personnel on the TWISS contracts. They are nominated by their 

base commanders or “Requiring Activity Commanders,” and fall under the USF-I chain of 

command. The CORs’ performance evaluations are to be provided by an individual in the USF-I 

chain of command, although the CORs are appointed and trained for their contract 

responsibilities by DCMA, to which they provide reports. Eighteen of 28 CORs surveyed stated 

they have non-COR duties assigned by their base commander or others in their chain of 

command. On the TWISS contracts, COR responsibilities include verifying the contractor 

performs all contract and task order requirements; performing necessary inspections; accepting 

government services performed under the contract and rejecting those that do not meet the 

contract’s requirements; monitoring the contractor’s performance; and notifying the contractor, 

QAR, and contracting officer of deficiencies observed during surveillance. 

CORs are also responsible for reviewing and verifying the contractor’s invoices for payment. 

Since CORs are the only government oversight officials located on-site with the contractors’ 

personnel, their invoice reviews are critical for verifying that TWISS contractor invoices 

accurately reflect the services provided. This is particularly important for the TWISS contracts 

since, on average, 42 of 45 contract requirements relate to personnel. In order for CORs to 
6 

verify the contractors’ invoices, they—or someone under their direction—must physically 

observe that the contractor provided the number and type of personnel required. 

To aid CORs in conducting oversight, DCMA’s QARs developed checklists based on the task 

orders. These checklists are intended to help CORs review the contractors’ compliance with 

various aspects of the task order, including the Performance Work Statement, fuel consumption, 

human trafficking,7 and arming requirements. CORs are required to use these checklists to 

conduct monthly contractor reviews. According to DCMA officials, COR checklists are a tool 

used to record and report to DCMA incidents of faulty or non-conforming work, delays, or other 

problems. They also help DCMA ensure the contractors comply with directions to remedy nonconforming work. Thus, DCMA’s ability to appropriately perform its contract administration 

and oversight responsibility is contingent on the CORs performing their oversight 

responsibilities and completing the checklists. 

Roles and Responsibilities of QARs 

QARs also play an important role in overseeing the TWISS contracts. They are appointed by 

DCMA and are responsible for providing the CORs’ on-site orientation, performing a baseline 

review of the CORs’ performance, reviewing the CORs’ records, and mentoring the CORs. 

QAR’s should perform an initial evaluation and baseline review of each COR within the first 30 

days of the COR’s appointment. This evaluation and review includes instruction on the monthly 

reviews each COR will be required to perform. It is intended to ensure the COR is fully capable 

of performing contractor surveillance and also has the requisite technical skills. During this 

initial visit, DCMA requires the QAR to complete and document an assessment of how well the 

COR performed during their meeting. The QAR is also responsible for reviewing COR audits 

each month and documenting if the audit is not received. The QAR is also required to perform a 

final COR evaluation at the completion of the COR’s assignment. 

In addition to evaluating and mentoring CORs, QARs are required to visit each base every month 

to conduct their contractor reviews. When conducting these reviews, QARs are to use the same 

checklists the CORs use for their monthly reviews. According to DCMA officials, if a QAR 

cannot travel to a given base one month because of travel restrictions, the QAR can receive 

permission from the Commander to conduct an “alternative surveillance strategy,” which could 

include verifying contract surveillance information from the COR or auditing documentation 

provided by the contractor. While the QARs’ reviews help provide contractor oversight, they 

cannot substitute for the CORs’ day-to-day quality assurance oversight, since QARs are often not 

located on the bases where the contract work is performed. 

Some TWISS CORs Lack Sufficient Training and Time To Conduct 

Effective Oversight 

DCMA has augmented its COR training since SIGIR last reported on the TWISS contracts; 

however, 11 of 28 CORs we surveyed stated their training did not prepare them to perform COR 

 

7

 All contractors (both prime and sub-contractors) are required to comply with the prohibition contained in Title 18, 

U.S. Code, Section 1592, against destroying, confiscating, or possessing any actual purported passport, or 

immigration document to prevent or restrict, without lawful authority, a person’s liberty or travel, in order to 

maintain the labor or services of that person. 
7 

duties on the TWISS contracts. In addition, 7 of 28 TWISS CORs stated they do not have 

enough time to perform the oversight they believe is necessary given their other assigned duties. 

DCMA Has Augmented Its COR Training, but Some CORs Still Not Adequately Prepared 

In April 2009, SIGIR reported that 11 of 27 CORs surveyed stated their COR training did not 

fully prepare them to oversee the TWISS contractors. At that time, SIGIR recommended CORs 

receive additional instructions on their oversight responsibilities. Since that report, DCMA has 

instituted additional in-person COR training requirements. Current requirements now include 

general and contract-specific COR training. 

 DCMA’s general COR training includes two online courses on common COR duties, one 

online course on ethics, and one online course on human trafficking. DCMA’s 

Administrative Contracting Officer should then provide each COR in-person training on 

general COR duties. Upon completion of these requirements, DCMA awards the COR a 

certificate and an official appointment letter for the TWISS contracts. 

 DCMA’s contract-specific COR training should include two additional sessions of inperson instruction. The first is with the Administrative Contracting Officer regarding the 

specific task order each COR will oversee. The second occurs once they reach their base, 

when a QAR instructs each COR how to conduct their monthly checklist reviews of the 

contractor, and provides the COR with feedback on their performance. 

Despite this augmented training requirement, 11 of 28 current CORs responded to SIGIR’s June 

2011 survey by stating their training did not adequately prepare them to perform COR duties on 

the TWISS contracts.8

 On a separate survey question, 17 of 28 CORs stated they did not receive 

their in-person training with the Administrative Contracting Officer on the task order for which 

they were responsible.9 DCMA officials stated they are aware of this deficiency and are taking 

steps to ensure that new TWISS CORs receive all required training. 

In addition, SIGIR’s review of DCMA’s files showed DCMA lacked documentation that 39 of 

43 CORs received their in-person QAR instruction on how to conduct monthly checklist reviews. 

DCMA was also missing 10 of 43 general COR training certificates and appointment letters. 

During our audit, SIGIR learned that a DCMA internal review in April 2011 identified similar 

deficiencies.10 As a result of that review, DCMA began taking steps to conduct in-person QAR 

training for all CORs and to track training and appointment documentation. However, as of July 

10, 2011, DCMA was able to provide documentation that they had conducted in-person QAR 

training for only 16 of 43 CORs. 

Without adequate training, CORs may not be conducting sufficient oversight of the TWISS 

contractors’ services and invoice payments. This training is particularly important since 24 of 28 

CORs we surveyed stated they had no previous COR experience. Some common suggestions 

CORs made to improve training included adding more instruction on the specific contract they 

 

8

 Of those CORs who provided supplementary comments in response to this question, only one noted a lack of 

training regarding oversight of a security contract. All others noted a lack of training in general contracting duties. 

9

 Of the 17 who did not receive in-person training, 8 did not think their training prepared them to perform COR 

duties on the TWISS contracts. 

10 In April 2011, DCMA conducted a Management Internal Control Review. 
8 

would oversee, as well as more on-the-job training. Most suggestions highlighted the 

importance of DCMA’s in-person, contract-specific training as well as additional QAR feedback 

to the CORs. 

Some TWISS CORs Lack Sufficient Time To Conduct Effective Oversight 

Some TWISS CORs lack sufficient time to effectively oversee their task order. In April 2009, 

SIGIR reported that 6 of 27 TWISS CORs had other duties that prevented them from conducting 

adequate oversight. At that time, SIGIR recommended USF-I and DCMA assess and rebalance 

the workload for TWISS CORs. Both agencies agreed with this recommendation. However, in 

SIGIR’s June 2011 COR survey, 7 of 28 TWISS CORs stated they do not have enough time to 

perform the oversight they believe is necessary given their other assigned duties. One COR, for 

example, stated “this should be a job for someone with no other assigned duties.” 

Current DCMA officials agreed that some CORs do not have enough time to perform all 

assigned duties. However, these officials stated that DCMA cannot rebalance the CORs’ 

workload because CORs do not fall under their chain of command. Instead, only the CORs’ 

USF-I commanders can rebalance the CORs workload, and, by nominating a COR, these 

officials affirm the COR has all necessary time and resources to perform their duties. While this 

may be true, SIGIR believes DCMA better understands what roles, responsibilities, and time 

commitments CORs will be required to assume. Nominating officials, on the other hand, do not. 

SIGIR asked DCMA what information it provides nominating officials prior to a COR’s 

nomination about CORs’ duties and time requirements. DCMA did not respond to this question. 

Absent this information, SIGIR has no evidence the CORs’ chains of command receive sufficient 

information to nominate the appropriate individuals. Because nominating officials may not have 

a clear understanding of the roles, responsibilities, and time commitments CORs will assume, it 

is difficult, if not impossible, for them to nominate the appropriate individuals for the job and 

balance their workloads. Moreover, without CORs having sufficient time to oversee all aspects 

of contractor operations, the U.S. government risks contractors billing for more services than 

they provided or not fulfilling all contract requirements. 

DCMA Does Not Have Documentation of All Monthly Reviews 

SIGIR’s review of DCMA’s files showed DCMA does not have documentation of all monthly 

reviews required of the CORs and QARs. As discussed above, DCMA requires CORs and 

QARs to conduct TWISS contractor reviews every month based on QAR-developed checklists. 

According to DCMA officials, the Performance Work Statement checklists are particularly 

important because they mirror contract requirements. These checklists are intended to help 

CORs and QARs verify the contractor is providing all contracted services, like whether the 

contractor is providing all required guards at each post. SIGIR requested DCMA provide three 

months of COR and QAR Performance Work Statement reviews from February through April 

2011 for all open task orders. The COR and QAR reviews should have totaled 114 each.11 

DCMA, however, could provide only 81 (71%) of the COR reviews and 98 (86%) of the QAR 

reviews requested. DCMA did not know if the other reviews were ever prepared or they simply 

 

11 Victory Base falls under one task order even though it contains seven separate sub-bases, each of which requires 

its own checklist. Thus, while there are 29 open task orders, there are actually 35 separate TWISS bases and subbases that require monthly reviews. 
9 

did not have them in the files. Because of this lack of documentation, SIGIR could not 

determine if CORs and QARs conducted all required oversight on the TWISS contracts. 

According to DCMA officials, some COR reviews could be missing because CORs were not 

available to complete them. For example, some bases do not have alternate CORs to conduct the 

reviews and perform other COR responsibilities if the primary COR leaves for vacation, transfers 

out, or is absent for other purposes. In addition, DCMA officials stated that when the primary 

COR leaves and there is no alternate COR or an immediate replacement, gaps may occur. 

DCMA officials added that oversight is improved when an alternate COR is assigned on a task 

order in addition to the primary COR. DCMA, however, only assigns an alternate COR when 

the primary COR requests one, according to a DCMA official. With respect to QAR audits, 

DCMA officials stated that personnel turnover, combined with multiple storage media, have 

contributed to reviews not being conducted or being misplaced. Without a trained TWISS COR 

on site at all times, and without QARs conducting and carefully maintaining all required reviews, 

there can be gaps in critical oversight, which could leave the U.S. government vulnerable to 

contractor fraud, waste, and abuse. In particular, the U.S. government risks contractors billing 

for more services than provided, or not fulfilling all contract requirements. 

DCMA Has Not Provided Performance Feedback on Poorly 

Performing CORs 

Some CORs provide weak oversight, and while DCMA cannot compel CORs to improve, it has 

not provided TWISS CORs or their rating officials with regular feedback to otherwise improve 

COR performance. At the same time, CORs’ rating officials have not requested information on 

the TWISS CORs’ performance from DCMA. Although DCMA’s policy guidance does not 

require it to provide regular feedback to CORs or their rating officials, SIGIR believes this does 

not relieve DCMA of the responsibility of providing feedback when warranted. In fact, a 2008 

memorandum from the Deputy Secretary of Defense requires rating officials evaluate the 

performance of COR duties as part of their performance assessments throughout the contract. 

This same memo encourages COR supervisors to solicit input on COR performance from the 

contracting officer. Regular feedback would allow rating officials to comply with the 

memorandum’s requirements. 

According to DCMA officials, some TWISS CORs provide excellent oversight and others 

provide weak oversight. To verify this statement, SIGIR examined the 81 COR Performance 

Work Statement reviews available from February through April 2011. SIGIR’s examination 

noted that five appeared comprehensive in nature, 21 appeared adequate, and the remaining 55 

appeared of questionable value.12 In the auditors’ judgment, reviews of “questionable value” 

provided no reasonable assurance the COR’s oversight was sufficient to guarantee the U.S. 

government received all services for which it paid. Common problems included reviews with 

few written comments, or ones that repeated all comments exactly from the previous month. On 

the other hand, comprehensive reviews contained many informative, specific comments, all of 

which changed from month to month. In discussions, DCMA officials agreed that some CORs’ 

monthly reviews appeared to have been completed very quickly and with little effort. 

 

12 By comparison, SIGIR judged only one of 95 QAR reviews to be of questionable value. 
10 

Despite some CORs providing weak oversight, DCMA has taken few steps to improve COR 

performance. DCMA officials stated they cannot compel CORs to improve because CORs are 

under USF-I’s chain of command, and not under DCMA’s. While true, DCMA has not provided 

CORs with regular performance feedback, which would alert them to areas for improvement. 

DCMA’s QARs are required to evaluate CORs during their initial and final meetings together, 

and although feedback during the initial meeting could prove helpful, any information CORs 

receive in their final meeting comes too late to help on the TWISS contracts. Thus, CORs 

currently receive no feedback on how to correct persistent, weak oversight. In addition, while 

DCMA policy guidance identifies only two specific instances where QARs should provide CORs 

feedback, SIGIR considers this a minimum requirement, and does not believe it relieves DCMA 

of the responsibility to seek corrective actions for ongoing problems. DCMA officials noted that 

they have terminated two TWISS CORs for unsatisfactory performance. However, without a 

requirement for DCMA to provide TWISS CORs with regular performance feedback, weak 

oversight could go uncorrected, as indicated by the condition of COR reviews noted above. 

In addition, DCMA has not provided, and COR rating officials have not requested, information 

on the CORs’ performance. DCMA guidance states that the Administrative Contracting Officer 

should provide feedback to the CORs’ chains of command “as necessary.” Yet, a 2008 policy 

memorandum from the Deputy Secretary of Defense states that, “Raters will evaluate the 

performance of COR duties as part of their performance assessments throughout the period of 

the contract.”13 [Emphasis added.] The memorandum also states “COR supervisors are 

encouraged to solicit input on performance of COR duties from the contracting officer.” SIGIR 

requested DCMA provide documentation of regular feedback to the TWISS CORs’ chains of 

command or rating officials, but DCMA officials stated they have not provided any. DCMA 

officials also stated they have no record of COR supervisors soliciting input on the performance 

of their CORs. This form of feedback is crucial since DCMA has visibility over elements of 

COR performance that the CORs’ chains of command do not—for example the monthly 

contractor reviews and invoice reviews. 

Currently, five of the CORs we surveyed stated that their COR performance is not included in 

their evaluations, and 14 did not know if it was included. Without CORs’ chains of command or 

rating officials receiving performance feedback from DCMA and utilizing this in the CORs’ 

performance evaluations, poorly performing CORs have little incentive or opportunity to 

improve. Alternatively, excellent CORs may not be properly rewarded for their efforts. In 

addition, without this feedback, the CORs’ chains of command may not be aware if a COR has 

insufficient training or time to perform their COR duties in conjunction with other assigned 

tasks. These circumstances fail to optimize U.S. oversight assets and leave the U.S. government 

at greater risk than would be the case otherwise. 

 

13 August 22, 2008, “Subject: Monitoring Contract Performance in Contracts for Services.” 
11 

Contracting Office Has A Process To Close TWISS 

Task Orders as Troops Withdraw 

CENTCOM Joint Theater Support Contracting Command (CJTSCC) and DCMA have a process 

to terminate TWISS task orders as U.S. troops withdraw and the U.S. military closes or transfers 

bases to the Government of Iraq. As the contracting office, CJTSCC is responsible for managing 

the termination of TWISS task orders. USF-I tracks base closures and informs CJTSCC and 

DCMA when a base is scheduled for closure or transfer to the Iraqis. To confirm these 

schedules, CJTSCC and DCMA coordinate with the CORs who communicate with their base 

commanders. With this information, CJTSCC adjusts the end date of each task order to align 

with the scheduled base closure or transfer date. 

To allow for timely base closures or transfers, the TWISS task orders each have two six-month 

option periods. These option periods can be exercised in full, or in smaller increments of time, to 

align with the exact base closure or transfer date. For example, according to CJTSCC and 

DCMA officials, the contracting office could exercise a three-month extension on a task order. 

Later, if circumstances required, the contracting officer could exercise another three-month 

extension to total the allowable six months. Alternately, the TWISS contracts allow CJTSCC to 

terminate a task order for the U.S. government’s convenience, at any time. This occurred in 

April 2011 with the termination of two TWISS task orders. A CJTSCC official stated the 

termination clause in the TWISS contracts provide necessary flexibility to manage base closures 

and transfers in an uncertain environment. 

DCMA handles each base closure or transfer on a case-by-case basis. According to a contracting 

office official, DCMA gives contractors a base closure notice 180 days prior to the scheduled 

base closure date. The TWISS task orders then require the contractor to submit a demobilization 

plan to DCMA no less than 60 days before the end of the task order’s performance period or 

when requested by the contracting officer. To keep the contractor on schedule, the 

demobilization plans should include, among other things, an exit plan from Iraq, an accounting 

of prime and subcontractor personnel and procedures for transferring contractor-controlled 

facilities and government-furnished equipment. CJTSCC and DCMA officials stated that 

planned timeframes are sometimes difficult to manage given the environment. However, the 

government reserves the right to withhold payment from a contractor who is not in compliance 

with the demobilization plan. In addition, QARs support base closure activities by providing 

increased surveillance when requested. Demobilization planning is applicable to all active task 

orders issued on the TWISS contracts. 

CJTSCC and DCMA officials are not aware of any instances where contracting officials had to 

reduce or increase the requirements on a TWISS task order. Instead, TWISS task orders are 

either extended or terminated in full. 

 
12 

Conclusions, Recommendations, and Lessons Learned 

Conclusions 

Although COR duties are critical to the U.S. government’s oversight of the TWISS contracts, 

SIGIR found issues that could adversely impact their ability to perform those duties, leaving the 

U.S. government at risk of contractor fraud, waste, and abuse. Specifically, almost 40% of the 

CORs we surveyed said the training they received did not prepare them for their duties and 25% 

said they lack sufficient time to conduct effective oversight. SIGIR found similar issues the last 

time it looked at the TWISS contracts in 2009. After that report, DCMA increased training 

requirements, but recognized in an April 2011 internal review that not all training was being 

conducted and documented. Regarding the lack of sufficient time, DCMA said only the CORs’ 

commanders can rebalance workloads, and that during the process to nominate CORs, 

nominating officials are affirming CORs have the time and resources to perform their duties. 

While this may be true, SIGIR believes DCMA should better inform the CORs’ nominating 

officials of the time required by CORs to perform their duties. USF-I, for its part, needs to assess 

the CORs’ workloads and identify actions to rebalance those workloads. 

SIGIR also found that CORs are not completing, or DCMA is not maintaining, all monthly 

review checklists, which DCMA developed to help CORs review contractor compliance with 

task order requirements. Even when completed, SIGIR found most reviews appeared to be of 

questionable value or provided little assurance that CORs’ oversight was adequate, a fact DCMA 

officials acknowledge. These reviews are important to DCMA’s ability to perform its contract 

administration and oversight responsibilities. 

Despite DCMA’s concerns about the performance of some CORs, it had not provided the CORs 

or their rating officials with regular feedback on performance. At the same time, the CORs’ 

rating officials had not requested COR performance information from DCMA. SIGIR believes 

regular, written feedback would (1) alert the CORs to areas where they need improvement, (2) 

alert rating officials to the CORs’ weaknesses and the possible need for additional training or 

relief from other duties, and (3) provide rating officials with the information they need to comply 

with the Deputy Secretary of Defense’s policy memorandum requiring raters evaluate CORs’ 

performance during assessments. 

SIGIR also notes that many locations lacked trained back-up CORs when the primary COR was 

unavailable. CORs may not always be available to perform their oversight duties because of 

vacations, sickness, emergencies, and duty rotations. Trained backups would ensure continuity 

in contractor oversight during these times. 

Finally, the process to terminate TWISS task orders as U.S. troops withdraw and the U.S. 

military closes or transfers bases to the Iraqis appears to be working well. 
13 

Recommendations 

SIGIR recommends the Director, Defense Contract Management Agency direct the following 

actions be taken as they relate to DCMA’s responsibilities under the TWISS contracts: 

1. Change DCMA policy guidance to require regular, documented feedback on CORs’ 

performance to the CORs and their chains of command. 

2. Train and appoint alternate CORs for every TWISS task order that does not have one. 

Concentrate efforts on the installations that are scheduled to close last. 

3. Verify that all CORs and QARs are conducting monthly reviews. 

4. Prior to nomination, verify CORs’ nominating officials have sufficient information about 

CORs’ time and duty requirements upon which to make nomination decisions. 

SIGIR also recommends that the Commanding General, U.S. Forces–Iraq, direct the following 

actions be taken: 

5. Assess the workload of TWISS CORs to identify actions that can be taken to balance 

workloads so sufficient time can be given to contract oversight responsibilities. 

6. Enforce the Deputy Secretary of Defense’s August 2008 policy memorandum directing 

rating officials to evaluate the performance of CORs’ duties as part of their performance 

assessments throughout the period of the contract. 

Lessons Learned 

The issues identified in this report and the recommendations SIGIR makes could be applicable to 

a broad array of U.S. government contracts utilizing CORs, although they appear most applicable 

to contracts in contingency environments. 

 
14 

Management Comments and Audit Response 

SIGIR received management comments from CENTCOM Joint Theater Support Contracting 

Command, USF-I, and DCMA. CENTCOM Joint Theater Support Contracting Command and 

USF-I concurred with the recommendations. The Contracting Command provided technical 

comments that we have addressed, as appropriate. The USF-I Inspector General provided a 

response for SIGIR’s consideration. The Inspector General stated: 

USF-I enjoys a strong and mutually supportive relationship with SIGIR. A 

significant amount of time and effort is dedicated to ensure SIGIR’s requests are 

supported expeditiously. Auditors working with the Command have access to all 

personnel assigned, including those at the subordinate level. 

USF-I staff work within the Command and its subordinate units through the RFI [Request 

for Information] and FRAGO [Fragmentary Order] systems which enable proper staffing 

and follow through on all requests. The RFI and FRAGO processes ensure consistency in 

staffing, timeliness, and accuracy of all requests. Thus all audit agencies receive timely 

and precise information as a result of this process. 

SIGIR agrees that it enjoys a strong and mutually supportive relationship with USF-I and that 

USF-I personnel spend significant time and effort to support SIGIR’s requests for information. 

SIGIR is very appreciative of USF-I’s support. Despite that support, SIGIR has not consistently 

had direct access to USF-I personnel who are responsible for the programs and issues SIGIR is 

auditing. Moreover, although the intent of the RFI and FRAGO systems may be to ensure that 

audit agencies receive timely and precise information, SIGIR believes the systems did not work 

as intended on this audit. It is for these reasons that SIGIR will work with USF-I to try to 

resolve issues that adversely impact and impair SIGIR’s independence and cause unnecessary 

delays to SIGIR’s audits. 

DCMA concurred with our recommendations that it (1) train and appoint alternate CORs for 

every TWISS task order that does not have one and (2) verify all CORs and QARs are 

conducting monthly reviews. It did not concur with our recommendations that it (1) change its 

policy guidance to require regular, documented feedback on CORs’ performance to the CORs 

and their chains of command and (2) verify CORs’ nominating officials have sufficient 

information about CORs’ time and duty requirements upon which to make nomination decisions. 

With regards to documented feedback on CORs’ performance, DCMA stated it does not exercise 

administrative, operational or tactical control of the CORs, and therefore does not routinely 

provide performance feedback to the nominating officials. DCMA added that it provides 

feedback to the CORs’ chains of command “as necessary,” for example, if a COR has 

overstepped their authority. SIGIR disagrees with DCMA’s position. As stated in the report, 

SIGIR believes DCMA’s regular feedback to the CORs’ chains of command is crucial since 

DCMA has visibility over elements of COR performance that the CORs’ chains of command do 

not—for example the monthly contractor reviews and invoice reviews. In addition, although 

DCMA’s policy guidance does not require it to provide regular feedback to CORs or their rating 

officials, SIGIR does not believe it relieves DCMA of the responsibility to seek corrective 
15 

actions for ongoing problems, as evidenced by 55 of 81 COR reviews that appear to be of 

questionable value. In addition, without regular, documented feedback to CORs’ rating officials, 

poorly performing CORs have little incentive to improve, and excellent CORs may not be 

properly rewarded. DCMA was silent on its rationale for not providing feedback to the CORs 

themselves; however, SIGIR continues to believe that without poorly performing CORs 

receiving feedback on their performance they have no opportunity to improve. 

With regards to providing CORs’ nominating officials with sufficient information about CORs’ 

time and duty requirements, DCMA stated it is not in a position to judge the capabilities of each 

individual COR or the time requirements necessary to do their jobs. SIGIR is not recommending 

DCMA assess the capabilities of individual CORs prior to nomination. Rather, SIGIR is 

recommending DCMA provide nominating officials with sufficient information about COR duty 

requirements, so that the nominating officials themselves can make informed decisions about 

who to nominate. As noted in the report, DCMA appoints, trains, reviews, coordinates and 

mentors the CORs. In this capacity DCMA understands what roles, responsibilities, and time 

commitments CORs will be required to assume. Nominating officials, on the other hand, do not. 

Absent this information, nominating officials cannot make informed decisions about who to 

nominate. 

SIGIR addressed DCMA’s technical comments in the report, as appropriate. In the comments, 

DCMA stated it believes SIGIR’s inability to interview CORs directly undermined the 

effectiveness and accuracy of this audit. As discussed earlier, this process was imposed on 

SIGIR by USF-I. While we agree that our findings would have been enhanced through direct 

communication with the CORs, we believe that our review of DCMA files and the results of our 

formal survey of available CORs, adequately support our conclusions. A copy of SIGIR’s 

survey instrument is included as Appendix G. 
16 

Appendix A—Scope and Methodology 

Scope and Methodology 

In March 2010, the Special Inspector General for Iraq Reconstruction (SIGIR) initiated Project 

1008 to examine the Department of Defense’s (DoD) oversight of Theater-wide Internal Security 

Services (TWISS) contractors. Work was begun in earnest in March 2011. SIGIR’s objectives 

for this report were to examine the U.S. government’s oversight of services provided and charges 

billed under TWISS contracts, as well as the U.S. government’s process for adjusting those 

contract requirements as the U.S. military withdraws from Iraq. With regards to our oversight 

objective, SIGIR focused primarily on the roles and responsibilities of the contracting officer’s 

representatives (CORs) since these individuals are critical to the government’s oversight 

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

as amended, which also incorporates the duties and responsibilities of inspectors general under 

the Inspector General Act of 1978. The audit was also conducted in response to the mandate in 

Section 842 of the National Defense Authorization Act for 2008, Public Law 110-181, that 

requires audits of the performance of security functions to address the manner in which DoD 

exercised control over the contractors’ performance. SIGIR conducted its work from March 

2011 to July 2011 in Baghdad, Iraq and Arlington, Virginia. 

We conducted this audit in accordance with Government Auditing Standards14, except for 

General Standard 3.10, External Impairments. Generally accepted government auditing 

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. 

Certain inappropriate external impairments to our independence limited the scope of our audit, as 

discussed in more detail below. 

Section 3.10 of Government Auditing Standards requires that audit organizations must be free 

from external impairments to independence. The section states that, under certain conditions, 

auditors may not have complete freedom to make an independent and objective judgment, 

thereby adversely affecting the audit. The section specifically cites the following conditions 

under subsections (a), (b), and (d): (a) external interference or influence that could improperly 

limit or modify the scope of an audit or threaten to do so, (b) external interference with the 

selection or application of audit procedures or in the selection of transactions to be examined, 

and (d) externally imposed restrictions on access to records, government officials, or other 

individuals needed to conduct the audit. 

SIGIR believes that the constraints imposed by U.S. Forces–Iraq (USF-I) impaired our 

independence and limited our scope, methodology, and ability to fully accomplish our audit 

objectives. SIGIR is required by law to inform the Secretary of Defense and SIGIR’s oversight 

committees in the Congress, whenever requested information or assistance is unreasonably 

refused or not provided. See Public Law 108-106, Section 3001(h), as amended. However, 

SIGIR will not be reporting this impairment at this time to the Secretary and to SIGIR’s 

oversight committees in Congress because USF-I has agreed to work with SIGIR to resolve these 

 

14 Government Auditing Standards, U.S. Government Accountability Office, July 2007 Revision. 
17 

issues. The following paragraphs describe our scope and methodology and the constraints and 

delays encountered. 

To accomplish our objectives, SIGIR attempted to survey all 43 TWISS CORs to obtain 

information about their prior experience, training received, and responsibilities, among other 

things. While SIGIR requested responses from all 43 CORs, we received only 28 responses. 

This response rate was at least partly the result of the time it took using the process USF-I 

required us to use to obtain this data. Specifically, we obtained the CORs’ names, locations, and 

contact information from the Defense Contract Management Agency (DCMA), for which the 

CORs perform their oversight. However, because the CORs are directly assigned to USF-I 

commanders, the USF-I Inspector General would not allow us to contact the CORs directly but 

required us to use the USF-I Inspector General to send our questionnaire out as a formal order, 

addressed to the CORs’ commanders. The USF-I Inspector General also required that all 

responses be returned to the Inspector General, who forwarded them to SIGIR. To expedite the 

process, a representative from the USF-I Inspector General’s office spent many hours identifying 

the CORs’ commanders. However, between the time we gave the list of CORs to the Inspector 

General and when we received the CORs’ responses, a total of 30 days had elapsed, and 10 

CORs had left Iraq. Since that process took so long, and we would have had to use the same 

process to contact the replacement CORs, we were unable to follow up with the replacement 

CORs and meet our reporting timelines. Had SIGIR been able to contact the CORs directly, we 

believe two to three weeks would have been eliminated from the process, thus allowing time to 

contact the replacement CORs and follow up on non-responses. SIGIR also considers the 

restrictions imposed on contacting CORs directly to be an external impairment to our 

independence that interferes with our ability to form independent and objective opinions, 

findings, and conclusions. As stated above, SIGIR is working with USF-I to address this 

problem. 

To examine the U.S. government’s oversight of services provided and charges billed under 

TWISS contracts, we interviewed knowledgeable officials at the DCMA, U.S. Central Command 

(CENTCOM) Joint Theater Support Contracting Command (formerly CENTCOM Contracting 

Command), and CORs under U.S. Forces–Iraq. We visited the DCMA offices, Central Iraq, in 

May 2011. We also requested and reviewed the contract files, COR and Quality Assurance 

Representatives’ reports, training documentation, policy guidance and other relevant oversight 

documents. To examine the U.S. government’s process for adjusting those contract requirements 

as the U.S. military withdraws from Iraq, we interviewed knowledgeable officials at the DCMA 

and CENTCOM Joint Theater Support Contracting Command. We also requested and reviewed 

relevant contract and scheduling documents. 

Use of Computer-processed Data 

We did not use computer-processed data in this report. 

Internal Controls 

We reviewed the specific controls used in managing COR and QAR appointments, training and 

oversight. 
18 

Prior Coverage 

We reviewed the following SIGIR reports: 

Need To Enhance Oversight of Theater-wide Internal Security Services Contracts, SIGIR 09-

017, 4/24/09. 

Gulf Region District Is Adjusting Its Aegis Security Contract Requirements for Changes in 

Reconstruction Activities in Iraq, SIGIR 11-015, 4/27/11. 
19 

Appendix B—Acronyms 

Acronym Description 

CENTCOM U.S. Central Command 

CJTSCC CENTCOM Joint Theater Support Contracting Command 

COR Contracting Officer Representative 

DCMA Defense Contract Management Agency 

DoD Department of Defense 

QAR Quality Assurance Representative 

SIGIR Special Inspector General for Iraq Reconstruction 

TWISS Theater-wide Internal Security Services 

USF-I United States Forces–Iraq 

 
20 

Appendix C—Audit Team Members 

This report was prepared and the audit conducted under the direction of Glenn D. 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: 

Arthur Granger 

Randy Gentry 

Wilson D. Haigler 

J.J. Marzullo 

Robert L. Pelletier 
21 

Appendix D—CENTCOM Joint Theater Support 

Contracting Command Comments 
22 

Appendix E—USF-I Inspector General Comments 
23 

Appendix F—DCMA Comments 
24 
25 
26 
27 
28 
29 

 
30 

Appendix G—SIGIR COR Survey Questions 

Background 

1. If you are involved with the TWISS contract, please list the contract ________________________,

task order __________________, and base ___________________ for which you are responsible.  

Are you the Primary_____ or Alternate______COR for the TWISS contract?

2. Please list the date you were assigned TWISS COR duties _______________ and the date you are

scheduled to end those duties _________________.   

3. Do you have prior experience as a COR?  Yes_____ No_____   If so, from__________________ to

___________________?  Where was that experience (location___________________________)?

COR Guidance and Assistance 

4. Were you provided with a copy of the current TWISS task order for which you are the COR?   

Yes______ No ______.   Date _______________________ of that task order.

5. Are you familiar with the requirements of the contractor in that task order?  Yes_____ No_____   

If not, please provide a brief explanation.  

6. Do you have a COR appointment letter for that task order? Yes _____ No ______  

7. Are you familiar with your responsibilities in that letter? Yes _____   No______  
31 

8. Please indicate the COR training you received, the approximate dates of that training and your

opinion of its usefulness in preparing you for your COR duties.  

Course Name Approximate 

Dates 

Opinion on Level of Usefulness for TWISS 

COR Duties 

Extremely 

Useful 

Somewhat 

Useful 

Limited 

Usefulness 

Not 

Useful at 

all 

Did not 

have this 

training 

CLC 206 “Contracting 

Officer's Representatives 

in a Contingency 

Environment” 

(online from DAU) 

 

CLC 106 “Contracting 

Officer's Representative 

with a Mission Focus” 

(online from DAU) 

 

Ethics (online from DAU) 

Trafficking in Persons 

(online from DAU) 

 

Initial COR overview 

training with the ACO or 

Contract Assistant 

In-person, contractspecific training with the 

TWISS ACO 

 

In-person, contractspecific training with the 

TWISS Quality Assurance 

Rep (QAR) 

 

Other 

(If other, please identify) 

 

9. In general, did the COR training you received adequately prepare you to perform your COR duties

on the TWISS contract? Yes ______ No_______

10. Could the COR training be improved to better prepare you and others?  If so, we would

appreciate your thoughts.

 
32 

Duties and Responsibilities 

11. Do you have other duties besides COR responsibilities under the TWISS contract? Yes______

No_______    Briefly describe those other duties.

12. What percent of your time is devoted to your COR responsibilities on the TWISS contract?  

_________%

13. If you have other duties, do you have enough time to effectively check whether:

 The required numbers of contractor security personnel are on duty, when and where

they should be?  Yes ______ No______ N/A______

 The required types of contractor security personnel (Expats, TCN, etc.) are on duty when

and where they should be?  Yes ______ No ______ N/A______

 The contractor’s invoices are correct for the number and types of security personnel

actually provided?  Yes______ No______ N/A______

 The contractor’s invoices are correct for the rates charged per security person (i.e.,

contractor is charging the rates listed in the contract)? Yes_____ No_____ N/A______

14. If you do not have enough time to perform the oversight you believe is necessary on the TWISS

contract, approximately what percent of your time (__________ %) do you believe should be

spent on that oversight?

15. If you do not have enough time to perform oversight on the TWISS contract, have you informed

any of the following?

a. Your chain of command? Yes______ No_______

b. The TWISS QAR? Yes______ No_______

c. The TWISS ACO? Yes______ No_______

d. The TWISS Contracting Officer? Yes______ No______

16. If you informed someone that you do not have enough time to perform oversight on the TWISS

contract, what actions were taken to rectify the problem?
33 

17. Are there impediments to you performing effective oversight on the TWISS contract? Yes_____

No_____ If yes, what are they?

18. Is the quality of your performance as a TWISS COR reflected in your annual evaluation report?

Yes_____ No_____ Not sure_____

19. How do you verify the information on the PWS checklist? (Check all that apply)

 Physical inspection

 Documents provided by the contractor

 Descriptions provided by contractor

 Other (Please elaborate)

 I cannot fully verify all information on the PWS checklist (Please elaborate.)

20. How often do you physically verify the contractor is manning all TWISS duty stations with the

required number and type of personnel? Daily_______, Weekly_______, Monthly_______,

Other_______. If other, please describe.

21. How do you record/keep track of whether the contractor is manning all TWISS duty stations with

the appropriate number and type of personnel?  Please describe.

22. How often does the TWISS contractor provide you with their manning reports?

Daily_______, Weekly________, Monthly________, Other_______. If other, please describe.

23. Other than when you received your training and appointment letter, have you ever

communicated with the following individuals?

a. The TWISS QAR? Yes______ No______

b. The TWISS ACO? Yes______ No______

c. The TWISS Contracting Officer? Yes______ No______
34 

24. Since your appointment as a COR on the TWISS contract:

a. How many times has the QAR visited you?   (________ times.)

b. How many times has the ACO visited you?   (________ times.)

Invoice Reviews 

25. Do you receive the contractor’s invoices for review prior to payment?  Yes_____ No_____

26. Do you review the invoices for accuracy?   Yes______ No______   If so, what

documents/information do you use to check accuracy?  Please describe.

27. If someone else validates the invoices, do you provide that person with the results of your

inspections so your findings can be compared to the contractor's charges______ Yes ______ No?

28. Have you ever done any of the following on the TWISS contract?  

 Requested the contractor reconsider questionable costs on an invoice? Yes_____

No_____

 Requested the contractor provide additional support for an invoice? Yes_____ No_____

 Requested the contractor change an invoice? Yes_____ No_____

 Recommended to the ACO or Contracting Officer that payment be denied for a TWISS

invoice? Yes_____ No_____

29. If you answered “Yes” to any of the questions in 28, have these occurred Frequently_______

Occasionally_______ Almost never_______?  If frequently or occasionally, briefly describe the

more prevalent problem(s).

30. Is there anything else significant about the performance of your TWISS contractor, or the U.S.

government’s oversight on the TWISS contract which was not discussed in the questionnaire, but

would be helpful for us to know?  If so, please describe.
35 

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 

 2530 Crystal Drive 

 Arlington, VA 22202-3940 

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 

 2530 Crystal Drive 

 Arlington, VA 22202-3940 

Phone: 703-428-1217 

Fax: 703-428-0817 

Email: PublicAffairs@sigir.mil