IRAQ AND 

AFGHANISTAN

State and DOD Should 

Ensure Interagency 

Acquisitions Are 

Effectively Managed 

and Comply with 

Fiscal Law

Report to Congressional Committees

August 2012

GAO-12-750

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-750, a report to 

congressional committees 

August 2012 

IRAQ AND AFGHANISTAN 

State and DOD Should Ensure Interagency 

Acquisitions Are Effectively Managed and Comply 

with Fiscal Law 

Why GAO Did This Study 

State has taken on unprecedented 

responsibilities in Iraq and Afghanistan. 

In doing so, it has relied heavily on 

contractors. For some critical goods 

and services, such as fuel, security, 

and basic support like dining and 

laundry services, State turned to DOD 

to acquire the goods and services on 

its behalf through interagency 

acquisitions. Because of the risks 

associated with assisted interagency 

acquisitions, agencies need to carefully 

consider whether their use is a sound 

business decision and formally 

document roles and responsibilities in 

interagency agreements. 

To better understand how State is 

managing its responsibilities in Iraq 

and Afghanistan, GAO evaluated 

(1) the nature and extent of State’s 

reliance on DOD for the acquisition of 

critical goods and services, (2) factors 

that contributed to this reliance, and 

(3) whether State and DOD are making 

and implementing decisions regarding 

this reliance consistent with regulation 

and guidance. GAO reviewed 

documentation for 22 acquisitions, 

including State’s requests for 

assistance, comparing them to 

regulation and guidance. 

What GAO Recommends

GAO recommends that State assess 

its planning for sufficient and 

appropriate acquisition personnel and 

that State and DOD take certain steps

to bring existing and planned 

interagency acquisitions into 

compliance with regulation and 

guidance and resolve their positions on

State’s payment for DOD’s services.

Both State and DOD agreed with the 

recommendations. 

What GAO Found 

To help the Department of State (State) meet its requirements for critical goods 

and services in Iraq and Afghanistan, the Department of Defense (DOD) 

supported State on 22 acquisitions. On State’s behalf, DOD awarded and 

manages 20 acquisitions, known as assisted interagency acquisitions, under the 

authority of the Economy Act with an estimated value of almost $1 billion for 

basic support goods and services and security services. DOD also supported two 

of State’s acquisitions for medical services and unmanned aerial vehicles. Across 

the 22 acquisitions, DOD has been involved in one or more aspects of the 

acquisition cycle, including planning, award, management, and oversight. GAO 

identified at least 128 DOD personnel with contracting and subject matter 

expertise who provided support for these acquisitions. 

In justifying requests in 2010 for DOD’s acquisition assistance, State officials 

cited the urgency of ensuring requirements were met as the two departments 

prepared for U.S. military forces to withdraw from Iraq at the end of 2011. 

Underlying that sense of urgency was the insufficient capacity and expertise of 

State’s acquisition workforce. Specifically, State and DOD concluded that State 

lacked sufficient personnel, both in numbers and expertise, to conduct acquisition 

activities and that it did not have the requisite time to increase its workforce to the 

capacity required to have contracts in place following the transition to a State-led 

presence in Iraq. State has taken some steps to address the acquisition 

workforce gaps that prompted it to seek DOD’s help. However, State has not fully 

assessed whether its effort to increase its workforce is sufficient to meet 

requirements; it has the proper skill and government/contractor mix; or it has 

sufficient numbers of qualified oversight personnel to support its own acquisition

efforts in Iraq and Afghanistan in the future. 

State and DOD did not comply with requirements for use and management of 

assisted acquisitions. For 12 of the 20 assisted acquisitions GAO reviewed, State 

did not comply with Office of Management and Budget and Federal Acquisition 

Regulation requirements for determining that using DOD contracts was the best 

procurement approach. For example, State did not assess the cost-effectiveness 

of using DOD’s contracts for five of the interagency acquisitions. Further, State 

and DOD did not meet requirements for interagency acquisition agreements in 

13 cases, resulting in confusion regarding oversight responsibilities and payment 

for DOD’s assistance. Accordingly, the departments’ positions regarding State’s 

payment of DOD’s costs prior to 2012 in connection with the award and 

administration of some acquisitions remain unresolved and the departments risk 

noncompliance with fiscal law. Some lessons have been learned since State’s 

2010 requests for DOD’s acquisition assistance in Iraq. However, poor 

compliance with interagency acquisition requirements and missed opportunities 

to fully understand costs and needs for goods and services continue to limit 

State’s ability to conduct acquisition planning. Over the next 18 months, as key 

contracts for Iraq are set to expire and the U.S. presence in Afghanistan evolves, 

the departments’ opportunity is shrinking to determine whether continued 

reliance is appropriate or State should develop its own capacity. Otherwise, State 

risks again relying on assisted acquisitions with DOD by default rather than 

through sound business decisions. 

View GAO-12-750. For more information, 

contact John P. Hutton at (202) 512-4841 or 

huttonj@gao.gov. 
Page i GAO-12-750 Iraq and Afghanistan 

 

Letter 1 

Background 7

State Has Relied Heavily on DOD for the Acquisition of Critical 

Goods and Services 14

State’s Reliance on DOD to Respond to Urgent Requirements 

Stemmed from Limitations in Its Acquisition Workforce Capacity 

That Persist 18

State and DOD Did Not Comply with Requirements for Use and 

Management of Assisted Acquisitions 27

Conclusions 43

Recommendations for Executive Action 45

Agency Comments 47

Appendix I Comments from the Department of Defense 50

Appendix II Comments from the Department of State 52

Appendix III GAO Contact and Staff Acknowledgments 56

Related GAO Products 57

Tables

Table 1: State and DOD Roles in Acquisitions of Critical Goods and 

Services Currently Supporting the U.S. Missions in Iraq 

and Afghanistan 15

Table 2: Number of Personnel in AQM from 2008 to 2012 22

Table 3: Summary of Noncompliance with OMB and FAR 

Requirements for Determination of Best Procurement 

Approach for 12 Assisted Acquisitions 29

Table 4: Status of Interagency Agreements for 20 Assisted 

Acquisitions 34

Contents
Page ii GAO-12-750 Iraq and Afghanistan 

 

Figures

Figure 1: Phases of the Acquisition Process and Associated 

Activities 13

Figure 2: DOD and State Contracting and Oversight Personnel 

Involved in the Planning, Award, and Oversight of the 

LOGCAP Task Order Supporting State in Iraq 20

Abbreviations

AQM Office of Acquisitions Management

CENTCOM U.S. Central Command

COR contracting officer’s representative

DCAA Defense Contract Audit Agency

DCMA Defense Contract Management Agency

DLA Defense Logistics Agency

DOD Department of Defense

FAR Federal Acquisition Regulation

FIRST Field and Installation Readiness Support Team

LOGCAP Logistics Civil Augmentation Program

OMB Office of Management and Budget

OPE Office of the Procurement Executive

SSS-I Security Support Services-Iraq

TWISS Theater Wide Internal Security Services

UAV Unmanned Aerial Vehicle

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 3 GAO-12-750 Iraq and Afghanistan 

 

United States Government Accountability Office 

Washington, DC 20548

 

August 2, 2012

Congressional Committees

The Department of State (State) has taken on unprecedented 

responsibilities in support of U.S. government efforts in Iraq and 

Afghanistan. In December 2011, when the last U.S. military brigade left 

Iraq pursuant to the Security Agreement between the United States and 

the Government of Iraq, State and the Department of Defense (DOD) 

completed the largest military-to-civilian transition since the Marshall Plan 

at the end of World War II. In assuming responsibility from DOD for 

leading the U.S. presence, State has primary responsibility for not only 

carrying out its diplomatic mission but also providing critical goods and 

services to support all U.S. government personnel in Iraq, as well as 

some contractor personnel. These critical goods and services include 

security, medical, and basic support such as food, fuel, dining, laundry, 

and waste management. In Afghanistan, as DOD plans for a reduction in 

U.S. military forces, State plans to draw on its experiences in Iraq to 

prepare for similarly expanded responsibilities. In the future, such 

responsibilities may not be unique to Iraq and Afghanistan. In the 2010 

Quadrennial Diplomacy and Development Review, State noted that an 

expeditionary capacity to address complex conflicts and crises must 

become part of the “new normal” for the department and its personnel.1

Over the years, State has relied heavily on contractors to help accomplish 

its missions in both Iraq and Afghanistan. For example, State’s reported 

obligations on contracts to help it carry out its missions in Iraq and 

Afghanistan were a combined $2.8 billion in fiscal year 2011 alone, 

representing 30 percent of its total contract obligations worldwide. Of the 

approximately 16,000 personnel State had planned as of summer 2011 to 

constitute the U.S. mission in Iraq, about 14,000 were contractors. In 

Afghanistan, the planned U.S. diplomatic presence after the realignment 

of DOD forces in 2014 is expected to include approximately 

4,400 personnel, of which approximately 2,700 would be contractors. 

 

1

The Quadrennial Diplomacy and Development Review is an assessment by State and 

the U.S. Agency for International Development on how those two agencies can become 

more efficient, accountable, and effective in light of new threats and opportunities. It 

provides a blueprint for elevating American "civilian power" to better advance U.S. national 

interests and to be a better partner to the U.S. military. U.S. Department of State, Leading 

through Civilian Power, The First Quadrennial Diplomacy and Development Review

(Washington, D.C.: 2010).

 
Page 4 GAO-12-750 Iraq and Afghanistan 

 

Contractors are working to support the U.S. diplomatic presence in both 

countries, but not all of them are working under contracts awarded and 

administered by State. Instead, State has turned to DOD to acquire some 

critical goods and services through interagency acquisitions—also known 

as interagency contracting. 

Interagency acquisitions, such as State’s use of DOD’s acquisition 

assistance, can provide a number of benefits to agencies, including to 

help them streamline the procurement process, leverage unique expertise 

in a particular type of procurement, and achieve savings. However, such 

acquisitions also pose a variety of risks. GAO has designated the 

management of interagency contracting as a high risk area since 2005, in 

part because of the need for stronger internal controls, clear definitions of 

roles and responsibilities, and training to ensure proper use of this 

contracting method.2 To this end, federal acquisition regulation and 

guidance require, among other things, that agencies carefully consider 

whether an interagency acquisition is a sound business decision and 

formally document the terms and conditions in an interagency 

agreement.

3

The risks of interagency acquisitions are compounded by the challenges 

of contracting in environments such as Iraq and Afghanistan. The 

Commission on Wartime Contracting in Iraq and Afghanistan noted in its 

final report that interagency coordination requires “clear delineation of 

roles and responsibilities ... effective interagency processes, and 

sufficient staff to perform the coordination tasks,” while also noting that 

“the volume and complexity of contract actions have overwhelmed the 

ability of government to plan for, manage, and oversee contractors.”

 

4

 

2

GAO, High-Risk Series: An Update, 

We 

have previously reported on State’s challenges with both interagency 

acquisitions and contracting in Iraq and Afghanistan. For example, we 

reported in 2008 that State had limited insights into its use of interagency 

acquisitions, including those with performance in Iraq, which hindered 

GAO-05-207 (Washington, D.C.: January 2005).

3

Federal Acquisition Regulation (FAR) §17.502 and Office of Management and Budget 

(OMB), Office of Federal Procurement Policy, Improving the Management and Use of 

Interagency Acquisitions (Washington, D.C.: June 6, 2008).

4

Commission on Wartime Contracting in Iraq and Afghanistan, Transforming Wartime 

Contracting: Controlling Costs, Reducing Risks, Final Report to Congress (Arlington, VA

Aug. 31, 2011). 
Page 5 GAO-12-750 Iraq and Afghanistan 

 

contract oversight.5 In reports issued annually since 2008, we consistently 

found that State lacked reliable sources and methods to report on its 

contracts and contractor personnel in Iraq and Afghanistan.6 Further, we 

reported in 2010 that State did not always provide enhanced oversight as 

required for certain contracts in Iraq and Afghanistan, despite the 

potential for loss of government control and accountability for missionrelated policy and program decisions.7

Because of broad congressional interest in U.S. efforts in Iraq and 

Afghanistan, we performed our work under the authority of the 

Comptroller General of the United States to conduct work on his own 

initiative. In this report, to better understand how State is managing its 

increased responsibilities for the missions in Iraq and Afghanistan with 

respect to the acquisition of critical goods and services, we evaluated 

(1) the nature and extent of State’s reliance on DOD for the acquisition of 

critical goods and services, (2) factors that contributed to this reliance, 

and (3) whether State and DOD are making and implementing decisions 

regarding this reliance consistent with regulation and guidance. 

To describe the nature and extent of State’s reliance on DOD for the 

acquisition of critical goods and services in Iraq and Afghanistan, we 

reviewed documentation, including lists of contracts supporting State’s 

presence in the two countries, agency correspondence, interagency 

acquisition agreements, memorandums of understanding and agreement, 

and other authorizations to use DOD resources. We also interviewed 

State and DOD officials in the United States, Iraq, and Afghanistan 

responsible for acquisition activities. For Iraq, our scope was limited to 

 

5

GAO, Interagency Contracting: Need for Improved Information and Policy Implementation 

at the Department of State, GAO-08-578 (Washington, D.C.: May 8, 2008).

6

See GAO, Iraq and Afghanistan: DOD, State, and USAID Cannot Fully Account for 

Contracts, Assistance Instruments, and Associated Personnel, GAO-11-886 (Washington, 

D.C.: Sept. 15, 2011); Iraq and Afghanistan: DOD, State, and USAID Face Continued 

Challenges in Tracking Contracts, Assistance Instruments, and Associated Personnel, 

GAO-11-1 (Washington, D.C.: Oct. 1, 2010); Contingency Contracting: DOD, State, and 

USAID Continue to Face Challenges in Tracking Contractor Personnel and Contracts in 

Iraq and Afghanistan, GAO-10-1 (Washington, D.C.: Oct. 1, 2009); and Contingency 

Contracting: DOD, State, and USAID Contracts and Contractor Personnel in Iraq and 

Afghanistan, GAO-09-19 (Washington, D.C.: Oct. 1, 2008). 

7

GAO, Contingency Contracting: Improvements Needed in Management of Contractors 

Supporting Contract and Grant Administration in Iraq and Afghanistan, GAO-10-357

(Washington, D.C.: Apr. 12, 2010).
Page 6 GAO-12-750 Iraq and Afghanistan 

 

those critical goods and services supporting State’s assumption of 

responsibility to lead the U.S. mission. For Afghanistan, we limited our 

scope to services for which State relied on DOD for the acquisition of 

critical services at the time of our review and reviewed the one associated 

contract and task order. We identified a subset of 22 acquisitions for 

which DOD performed one or more of the steps in the acquisition 

process. Among these, we identified 20 assisted interagency acquisitions, 

including some for Iraq that State requested of DOD beginning in April 

2010.8

To identify factors that contributed to reliance, we reviewed State and 

DOD transition planning documents for Iraq and Afghanistan and 

interviewed State and DOD officials regarding rationales for reliance on 

DOD. On the basis of the information obtained through these documents 

and interviews, we collected detailed data on the composition of State's 

acquisition workforce and processes State uses to develop its workforce. 

We compared these data and processes to acquisition activities, 

personnel, and expertise that ultimately were needed to acquire critical 

goods and services in Iraq. We also compared State’s processes for 

developing its workforce—including using a working capital fund to 

increase staff—with its own planned improvements and with practices for 

assessing performance of working capital funds.

To determine whether State is making decisions regarding its reliance on 

DOD for the acquisition of critical goods and services and both 

departments are implementing these decisions consistent with regulation 

and guidance, we reviewed documentation of coordination and decision

making since April 2010 related to Iraq. We also interviewed State and 

DOD officials in the United States, Iraq, and Afghanistan. To determine 

how State made decisions to rely on interagency acquisitions with DOD, 

we compared documentation on coordination, assessment, and approval 

of interagency acquisitions to Federal Acquisition Regulation (FAR) 

requirements and Office of Management and Budget (OMB) guidance for 

ensuring that an interagency acquisition is the best procurement 

approach and a sound business decision. To assess the departments’ 

arrangements for implementing decisions to use interagency acquisitions, 

we compared agency documentation to FAR requirements and OMB 

 

8

An assisted acquisition is a type of interagency acquisition where a servicing agency 

performs acquisition activities on a requesting agency’s behalf, such as awarding and 

administering a contract, task order, or delivery order. FAR § 2.101.
Page 7 GAO-12-750 Iraq and Afghanistan 

 

guidance for having written agreements for assisted interagency 

acquisitions, including certain features of those agreements. We also 

compared payment arrangements and activities between State and DOD 

with respect to the interagency acquisitions with the statutory requirement 

under the Economy Act for payment on the basis of actual costs.9

We conducted this performance audit from March 2011 to August 2012 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

To 

identify State’s efforts to determine whether it should continue to rely on 

DOD contracts, we reviewed available documentation on existing 

interagency acquisitions and interviewed State and DOD officials 

responsible for acquisition planning activities. We then compared these 

efforts with the FAR requirements and OMB guidance on interagency 

acquisitions and regulations on acquisition planning. 

The Security Agreement between the United States and the Government 

of Iraq directed that DOD was to complete the withdrawal of forces and 

transition the lead role for a fully diplomatic U.S. presence in Iraq to State 

by December 31, 2011.

10

 

9

31 U.S.C. § 1535; FAR § 17.502-2(d). The Economy Act provides general authority for 

federal agencies to undertake interagency acquisitions when a more specific statutory 

authority does not exist.

As we reported in September 2011, for DOD to 

focus on the final drawdown phase, DOD had set a condition that State 

become “mission capable” for its civilian-led presence in Iraq by 

10Agreement on the Withdrawal of United States Forces from Iraq and the Organization of 

Their Activities during Their Temporary Presence in Iraq, United States–Iraq, art. 24, para. 

1 (Nov. 17, 2008). 

Background

State’s Presence in Iraq 

and Afghanistan 
Page 8 GAO-12-750 Iraq and Afghanistan 

 

October 1, 2011.11

• secure and protected facilities,

State determined that to reach independent mission 

capability, each of its sites throughout the country must have: 

• secure ground and air movement, 

• quick reaction capability, 

• communications, 

• medical care and evacuation, and 

• infrastructure and life support.12

Prior to the withdrawal of U.S. forces from Iraq, DOD had provided many 

of the critical goods and services State needed to support its missions. 

Although State had responsibility for providing some services to its own 

personnel, DOD personnel and contractors had been providing basic life 

support services, medical services, and Iraq-wide security capabilities 

and infrastructure. For example, while State had a single health unit 

providing primary care at the embassy, DOD had responsibility for 

emergency care as well as medical evacuation. In addition, State had a 

contracted embassy guard force and provided for movement security of 

its own personnel using contractors but relied on DOD for general 

security across the country. Military forces provided theater security, 

operating a range of technologies such as unmanned aerial vehicles 

(UAV) for intelligence, surveillance, and reconnaissance; radars to detect 

and warn of incoming rocket and mortar attacks; and systems to help 

conduct background investigations on local national staff and contractors. 

Further, leading up to the transition of responsibility to State, a wide range 

of basic support services, including dining, laundry, and waste 

management, had been provided to U.S. government and contractor 

personnel through DOD contracts, including the Army’s Logistics Civil 

 

 

11GAO, Iraq Drawdown: Opportunities Exist to Improve Equipment Visibility, Contractor 

Demobilization, and Clarity of Post-2011 DOD Role, GAO-11-774 (Washington, D.C.: 

Sept. 16, 2011).

12As of June 2012, this exclusively diplomatic presence consisted of 14 sites: 8 

maintained by State for diplomatic purposes and 6 additional sites maintained by DOD (5 

for the Office of Security Cooperation-Iraq, and 1 for the Office of Security CooperationIraq and State’s consulate in Kirkuk), which is managing security assistance and 

cooperation with the Government of Iraq. For additional information on the status of

establishing support at these sites, see GAO, Mission Iraq: State and DOD Face 

Challenges in Finalizing Support and Security Capabilities, GAO-12-856T (Washington, 

D.C.: June 28, 2012).
Page 9 GAO-12-750 Iraq and Afghanistan 

 

Augmentation Program (LOGCAP) contract. Several LOGCAP task 

orders supported State’s needs at the embassy.13

With the withdrawal of U.S. military forces from Iraq in December 2011, 

State would become solely responsible in January 2012 for supporting its 

presence throughout the country. To ensure goods and services were in 

place for the transition of responsibility to State, acquisition activities—

such as planning, defining requirements, developing cost estimates, and

preparing solicitations—needed to occur for each of the critical goods and 

services in advance. In 2010, as the departments’ planning for DOD’s 

withdrawal and transition to a State-led presence in Iraq got underway, 

and throughout the following year, security conditions were such that 

State’s traditional means of ensuring basic services in posts around the 

world—relying on the local economy—were not available, and State’s 

security capabilities were insufficient to support the planned presence. 

Senior DOD and State officials have acknowledged that coordination 

occurred late in the process and the delays made the transition more 

challenging.

 

14

In Afghanistan, State and DOD currently share responsibility for the U.S. 

presence. State’s presence includes the U.S. embassy in Kabul and 

regional consulates, as well as civilian personnel assigned to locations 

Adding to the challenge was uncertainty as to whether 

DOD would reach agreement with the Government of Iraq for a follow-on 

presence of U.S. military forces, which would also have required support 

services if agreed to. To help State identify critical requirements for which 

it had previously relied on DOD and address other issues associated with 

the transition, the two departments established an Executive Steering 

Group cochaired by the Deputy Assistant Secretaries for Program 

Support (DOD) and Logistics Management (State) in September 2010. 

The group proposed solutions to fulfill State’s requirements, including 

acquisition of needed capabilities through a combination of State 

acquisitions and interagency acquisitions with DOD under the authority of 

the Economy Act, as well as equipment transfers from DOD. The group 

received guidance from the Principal Deputy Under Secretary of Defense 

for Acquisition, Technology, and Logistics and the Under Secretary of 

State for Management. 

 

13A task order is an order for services placed against an established contract or with 

government sources. FAR § 2.101.

14GAO-11-774. 
Page 10 GAO-12-750 Iraq and Afghanistan 

 

throughout Afghanistan. State currently provides security for its own 

facilities and personnel, although DOD continues to provide for 

countrywide security. Current U.S. strategy calls for provinces and 

districts to transition to greater Afghan government control as local 

capacity improves and conditions allow.15 Further, the United States, 

along with its North Atlantic Treaty Organization partners, has committed 

to fully transferring lead security responsibility to the Afghan government 

by the end of 2014. In May 2012, a United States-Afghanistan Strategic 

Partnership Agreement was signed that provides for the possibility of U.S. 

forces in Afghanistan after 2014, to be determined in a follow-on bilateral 

security agreement.16 As the United States plans for a reduction in U.S. 

forces, State is making plans for realignment of its diplomatic enduring 

presence to meet policy objectives.

An interagency acquisition takes place when an agency needing supplies 

or services (the requesting agency) obtains them from another agency 

(the servicing agency). The term includes interagency acquisitions under 

the Economy Act and non-Economy Act acquisitions completed under 

other statutory authority.17 Statutory authority, such as the Economy Act, 

is required for federal agencies to conduct interagency acquisitions to 

avoid running afoul of federal fiscal law.18

 

15The U.S. strategy for Afghanistan refers to the strategy announced in a March 2009 

speech by the President, which was reiterated in a December 2010 strategic review. 

The Economy Act provides 

general authority for federal agencies to undertake interagency 

acquisitions when a more specific statutory authority does not exist. 

Interagency acquisitions authorized by the Economy Act can save the 

government duplicative effort and costs when appropriately used. 

Circumstances under which an Economy Act interagency acquisition may 

be appropriately used include when one agency already has a contract 

16Enduring Strategic Partnership Agreement, United States–Afghanistan, § III, para. 6,

(May 2, 2012). 

17Economy Act of 1932, 31 U.S.C. § 1535; FAR § 17.502-2.

18Fiscal law provides that an agency generally must use its appropriated funds for the 

purposes for which the appropriations were made. 31 U.S.C. § 1301(a). In addition, an 

agency receiving goods or services funded by another agency’s appropriations must 

reimburse the servicing agency to avoid improperly augmenting the requesting agency’s 

appropriations. Furthermore, payments received by the servicing agency for goods or 

services provided, without other statutory authority, must be deposited into the Treasury 

as miscellaneous receipts. 31 U.S.C. § 3302(b). 

Interagency Acquisitions
Page 11 GAO-12-750 Iraq and Afghanistan 

 

for goods or services similar to those needed by another agency or when 

an agency has unique capabilities or expertise that qualify it to enter into 

a contract.

State has its own policy for making and implementing decisions regarding 

the use of interagency acquisitions. In 2002, before the risks associated 

with interagency acquisition were widely reported, State implemented the 

State First policy for acquisition that directs State’s domestic bureaus and 

offices to use State contracting offices, as opposed to paying another 

agency to conduct an acquisition, unless the appropriate State acquisition 

and procurement policy officials grant a waiver. In April 2008, State 

updated its State First policy noting that GAO, State’s Inspector General, 

and OMB had all identified the interagency acquisition process as an area 

of high risk requiring active management. In doing so, State implemented 

GAO recommendations to strengthen and clarify the policy by updating it 

to cover a wider range of interagency acquisitions and to require that 

when requesting a waiver, a bureau identify a contracting officer’s

representative (COR) who would provide technical oversight of the 

interagency acquisition. 

As part of the Duncan Hunter National Defense Authorization Act for 

Fiscal Year 2009, Congress enacted section 865 on preventing abuse of 

interagency acquisitions, which resulted in OMB’s issuance of 

comprehensive guidance in June 2008 and revisions to the FAR in 

2010.19 OMB’s guidance recognized the risks of interagency acquisitions, 

noting that “[l]ack of clear lines of responsibility between agencies with 

requirements (requesting agencies) and the agencies which provide 

acquisition support and award contracts on their behalf (servicing 

agencies) has contributed to inadequate planning, inconsistent use of 

competition, weak contract management, and concerns regarding 

financial controls.”20

• ensure the use of an interagency acquisition is a sound business 

decision by requiring consideration of certain factors and 

The guidance directed agencies to

• strengthen the management of assisted interagency acquisitions by 

requiring formal agreements between requesting and servicing 

 

19Pub. L. No. 110-417, § 865 (2008).

20OMB, Office of Federal Procurement Policy, Improving the Management and Use of 

Interagency Acquisitions (Washington, D.C.: June 6, 2008).
Page 12 GAO-12-750 Iraq and Afghanistan 

 

agencies that contain certain elements, such as roles and 

responsibilities for acquisition activities.

The FAR’s requirements for interagency acquisitions were amended in 

2010, as directed by Congress, and reflect the 2008 OMB guidance. 

Under the FAR, agencies are to determine an interagency acquisition is 

the best procurement approach among alternative procurement 

approaches through a determination that an interagency acquisition 

• satisfies the requesting agency’s schedule, performance, and delivery 

requirements (taking into account the servicing agency’s authority, 

experience, and expertise as well as customer satisfaction with the 

servicing agency’s past performance), 

• is cost-effective (taking into account reasonableness of the servicing 

agency’s fees), and 

• will result in the use of funds in accordance with appropriation 

limitations and compliance with the requesting agency’s laws and 

policies.21

In addition, for assisted interagency acquisitions, the FAR requires that 

the servicing agency and requesting agency sign a written interagency 

agreement, which establishes the general terms and conditions governing 

the relationship, and that they refer to the OMB guidance in preparing 

these agreements.22

Support provided by one agency to another can span across the 

acquisition cycle, including acquisition planning, contract award, contract 

management, and contract oversight (see figure 1). 

 

21FAR §17.502-1(a)(1). 

22FAR §17.502-1(b). 
Page 13 GAO-12-750 Iraq and Afghanistan 

 

Figure 1: Phases of the Acquisition Process and Associated Activities 

Responsibility for acquisition policy and management at State is shared 

by two offices within the Bureau of Administration—the Office of the 

Procurement Executive (OPE) and the Office of Acquisitions 

Management (AQM). For example, OPE is responsible for establishing 

acquisition policy, such as the State First policy that AQM is to implement 

with OPE’s concurrence through waivers or exceptions to that policy.

Other OPE responsibilities include prescribing and implementing 

acquisition policies, regulations, and procedures; managing State’s 

procurement reporting system; appointing contracting officers; 

establishing a system for measuring the performance of State contracting 

offices; and managing the acquisition career program to improve the 

competence of the department’s acquisition workforce. AQM is 

responsible for providing a full range of contracting services to support 

activities across State, including acquisition planning, contract 

negotiations, cost and price analysis, and contract administration. AQM is 

responsible for over 98 percent of State’s acquisitions. State’s Under 

Secretary for Management has overall responsibility for AQM, OPE, and 

Acquisition Management 

Structure and Challenges 

at State
Page 14 GAO-12-750 Iraq and Afghanistan 

 

the functional bureaus that have requirements for contracted services in 

Iraq and Afghanistan. These functional bureaus include Diplomatic 

Security, which is State’s security and law enforcement arm, and the 

Office of Medical Services, which provides health care at embassies 

worldwide. The Under Secretary for Political Affairs has responsibility for 

identifying the needs for goods and services to support the presences in 

Iraq and Afghanistan through the Bureaus of Near Eastern Affairs and 

South and Central Asian Affairs, respectively.

State acknowledged in its 2010 Quadrennial Diplomacy and Development 

Review that it needed to change the way it awards, manages, and 

monitors contracts to ensure that contracts serve its strategic interests 

and deliver results for the American taxpayer. Similarly, we and others 

have reported on long-standing acquisition management challenges at 

State. For example, State’s Inspector General has identified contracting 

and procurement as one of the most serious management and 

performance challenges facing the department, noting with particular 

concern that AQM continues to experience an increase in the number of 

procurement transactions processed and considerable growth in the 

dollar value of procurement actions issued without a corresponding 

increase in contracting personnel to handle the workload. The Inspector 

General found that frequent turnover of contract support staff, especially 

overseas, has resulted in waste, a lack of adequate coordination, and a 

loss of institutional memory and that his office has identified several 

instances in which contract administration and oversight were not 

adequate, including in Iraq and Afghanistan.

To help State meet its requirements for critical goods and services in Iraq 

and Afghanistan, DOD supported State on 22 acquisitions, as shown in 

table 1. 

State Has Relied

Heavily on DOD for

the Acquisition of 

Critical Goods and 

Services 
Page 15 GAO-12-750 Iraq and Afghanistan 

 

Table 1: State and DOD Roles in Acquisitions of Critical Goods and Services Currently Supporting the U.S. Missions in Iraq 

and Afghanistan

Critical service

Acquisitions 

(number)

Contract value 

(dollars in 

millions)a

Roles in acquisition activities

Planning

Administration

Award Management Oversight

Iraq

Basic services/goods Logistics Civil 

Augmentation 

Program (1) 

$506.5    

Food and Fuel (7) 273.0b    

Security Security Support 

Services-Iraq (2)

73.0    

Theater Wide Internal 

Security Services (5)

20.1    

Sense and Warn (2) 74.1    

Field and Installation 

Readiness Support 

Team Maintenance 

(1)

37.4    

Vetting Services (1) 7.0    

Unmanned Aerial 

Vehicles (1)

28.0    

Medical Medical Support 

Services-Iraq (1)

467.5    

Afghanistan

Basic services Logistics Civil 

Augmentation 

Program (1)

6.9    

Legend:  DOD lead 

  State lead 

  Shared responsibility 

Source: GAO analysis of State and DOD contract documentation, data, and discussion with officials.

a

Contract value, for the purpose of this table, is the estimated value at award plus priced options and 

modifications as of April 30, 2012. 

b

These DOD supply contracts serve multiple agencies, so we report State’s total estimated cost per 

fiscal year, including direct costs and overhead, not value as of April 30, 2012. 

DOD awarded and managed 20 interagency acquisitions on State’s 

behalf under the authority of the Economy Act with an estimated value of 

$1 billion for basic support services and goods as well as security 
Page 16 GAO-12-750 Iraq and Afghanistan 

 

services.23

Of the 22 acquisitions, 20 were assisted acquisitions in which DOD 

executed one or more contract actions on State’s behalf and had the lead 

in managing the contract. 

DOD also provided support on two State acquisitions for 

medical services and UAV operations. Across the 22 acquisitions, DOD 

has been involved in one or more aspects of the acquisition cycle, 

including planning, award, management, and oversight. Based on our 

review of documents and interviews with officials, we identified at least

128 DOD personnel with contracting and subject matter expertise who 

provided support for these acquisitions—46 in the United States and 82 in 

Iraq. 

• Basic Services—Logistics Civil Augmentation Program (LOGCAP): 

DOD’s LOGCAP program office and Rock Island Contracting Center 

led planning, award, and management of a task order for basic 

services at multiple locations across Iraq. LOGCAP provides for a 

wide range of utilities and maintenance services including dining, 

laundry, and waste management. State participated in planning and 

leads contract oversight, with quality assurance support from the 

Defense Contract Management Agency (DCMA).24

• Basic Goods—Supplies of Food and Fuel: The Defense Logistics 

Agency (DLA) awarded seven contracts for food and fuel that the 

LOGCAP contractors use to provide their services in Iraq. DLA is 

In Kabul, 

Afghanistan, DOD is performing all acquisition activities on State’s 

behalf supporting its requirement for three dining facilities.

 

23The 20 assisted interagency acquisitions include DOD contracts under which State is a 

customer, task orders awarded by DOD under DOD indefinite delivery / indefinite quantity 

contracts on behalf of State, and modifications to DOD contracts and task orders made on 

behalf of State. When the same DOD task order was modified multiple times on State’s 

behalf, we counted the task order that was modified on State’s behalf as one interagency 

acquisition and did not count each individual modification as a separate interagency 

acquisition.

24DCMA provides contract administration services such as quality assurance oversight, 

when delegated that authority by the contracting officer. DCMA has an organization 

dedicated to supporting contingency contracts. DCMA is responsible for ensuring the 

integrity of contractual processes and providing a broad range of contract management 

and administration services. We reported in November 2011 that, amid DCMA’s ongoing 

efforts to rebuild its capacity, several factors presented challenges, including that officials 

believe contingency missions have a constraining effect on DCMA’s domestic mission. 

GAO, Defense Contract Management Agency: Amid Ongoing Efforts to Rebuild Capacity, 

Several Factors Present Challenges in Meeting Its Missions, GAO-12-83 (Washington, 

D.C.: Nov. 3, 2011). 
Page 17 GAO-12-750 Iraq and Afghanistan 

 

responsible for awarding the contracts, with DLA and State sharing 

planning and oversight responsibilities. 

• Security—Security Support Services-Iraq (SSS-I), Theater Wide 

Internal Security Services (TWISS), and Sense and Warn: Multiple 

DOD contracting offices have taken actions to provide State with 

security capabilities in Iraq. The Rock Island Contracting Center led 

planning and award of two SSS-I task orders. The U.S. Central 

Command’s (CENTCOM) Joint Theater Support Contracting 

Command modified five existing TWISS task orders for guard and 

movement security services.25

• Security—Field and Installation Readiness Support Team (FIRST) 

Maintenance: The Rock Island Contracting Center modified an 

existing task order to provide for maintenance of the Sense and Warn 

capability and biometrics equipment, as well as other DOD-loaned 

equipment. State participated in planning to meet its requirements, but 

DOD leads contract management and oversight. 

DOD’s Redstone Contracting Center 

and the Defense Information Technology Contracting Organization 

modified two existing Sense and Warn task orders for the installation 

and operation of a capability to detect incoming rocket, artillery, and 

mortar attacks. A DOD program office conducted a survey of State 

facilities in Iraq to determine Sense and Warn requirements. DOD and 

State share oversight responsibilities. 

• Security—Vetting Services: The Rock Island Contracting Center 

awarded a task order for additional screeners and counterintelligence 

specialists to support State’s vetting of Iraqi nationals working under 

the LOGCAP contract. According to State officials, both State and 

DOD contributed to acquisition planning and oversight. DCMA 

manages the task order on State’s behalf, while a State regional 

security officer serves as a COR to provide oversight.

Across all of these assisted acquisitions, in addition to DCMA’s contract 

management support, the Defense Contract Audit Agency (DCAA) 

provides audit support.26

 

25State independently planned and awarded four task orders under its Worldwide 

Protective Services contracts to provide security for its facilities and personnel in Iraq, and 

its personnel are responsible for contract management and oversight. However, when 

mobilization of State’s Worldwide Protective Services contractors was delayed, State 

requested that DOD extend performance under its TWISS task orders at five locations 

throughout Iraq to ensure continuation of critical security services.

26DCAA provides accounting and financial advisory services for DOD in connection with 

the negotiation, administration, and settlement of contracts and subcontracts. DCAA also 

provides contract audit services to other federal government agencies as appropriate. 
Page 18 GAO-12-750 Iraq and Afghanistan 

 

State independently awarded and administers two of the acquisitions we 

reviewed, with DOD providing acquisition planning support in both cases: 

• Unmanned Aerial Vehicles: State’s decision to operate UAVs in Iraq 

led it to independently award, manage, and oversee its first contract 

for UAV operations and maintenance after DOD assisted in market 

research and requirements definition. 

• Medical Support Services-Iraq: Contracting for medical services on 

such a large scale was a new and unfamiliar task to State. However, it 

independently awarded and manages its own contract for primary and 

emergency medical care to State personnel and some contractors. 

DOD’s medical command officials assisted with requirements 

development, and DOD personnel participated as nonvoting members 

on the technical panel evaluating contractor proposals.

In justifying its 2010 requests for support from DOD in acquiring critical 

goods and services, State cited the urgency of ensuring requirements 

were met as the U.S. military withdrew from Iraq. Underlying that sense of 

urgency was the insufficient capacity and expertise of State’s acquisition 

workforce. Specifically, State and DOD concluded that State lacked 

sufficient personnel, both in numbers and expertise, to conduct 

acquisition activities and that it did not have the requisite time to increase 

workforce capacity required to have contracts in place following the 

transition. State has taken some steps to address the acquisition 

workforce challenges that prompted it to seek DOD’s assistance by 

increasing the number of acquisition professionals. However, State has 

not fully assessed whether (1) the effort to increase its acquisition 

workforce is sufficient to meet surge requirements, (2) its acquisition 

workforce has the proper skill and government/contractor mix, and (3) it 

has sufficient numbers of qualified oversight personnel to support its own 

contracting efforts in Iraq and Afghanistan in the future. For example, 

State’s workforce planning through 2014 does not address specific needs 

for contract oversight personnel to support complex acquisitions in 

environments like Iraq or Afghanistan, even though DOD expects State to 

assume additional oversight responsibilities at the start of 2014. 

State lacked sufficient personnel, both in terms of numbers and expertise,

to conduct acquisition activities. State was not able to increase its

capacity in time to support the transition to a State-led civilian presence. 

In the justification accompanying the Under Secretary of State for 

Management’s April 2010 request for the continued use of LOGCAP, 

State’s Reliance on 

DOD to Respond to 

Urgent Requirements 

Stemmed from 

Limitations in Its 

Acquisition Workforce 

Capacity That Persist

Requirements to Acquire 

Goods and Services for 

Iraq Exceeded Capacity 

and Expertise of State’s 

Acquisition Workforce 
Page 19 GAO-12-750 Iraq and Afghanistan 

 

State noted that (1) if it was not able to rely on LOGCAP, it would be 

forced to redirect its resources to develop, implement, and oversee a new 

basic support infrastructure throughout the country and (2) doing so 

would place the civilian presence at risk given the magnitude, 

uncertainties, and complexities involved. State had explored awarding its 

own contract for its post-2011 support services as an alternative, but 

discontinued the effort in June 2010, in part because it could not develop 

its contract management and oversight capabilities quickly enough. In 

August 2010, after an assessment of the critical support needs in Iraq, 

DOD concluded that State's organizational shortfalls in contracting placed 

the transition at a potential for significant risk if State had to assume 

responsibility for independently contracting for basic support services. 

The following month DOD agreed to provide the requested support to 

prevent mission degradation. 

For most of the 22 acquisitions we reviewed, State did not have the 

contracting or subject matter expertise necessary to plan, manage, or 

oversee the contracts, so the department sought DOD personnel’s 

expertise. For example, when State requested DOD’s assistance for the 

continuation of DOD’s LOGCAP and associated food and fuel contracts to 

support establishing an exclusively diplomatic presence, State recognized 

that it did not have the sufficient experience and expertise to perform the

necessary contract oversight. LOGCAP provides for dining and laundry 

service as well as light construction, comprehensive utilities services 

(power, water, sewage, fuel, and waste management), airfield operations 

(including air traffic control), ground transportation and vehicle 

maintenance, and shipping and receiving. A senior State official explained 

to us that DCMA assistance was needed to help oversee this wide range 

of services, in part because State personnel are not accustomed to 

overseeing, for example, dining facilities or power plants. A comparison of 

DOD and State contracting and oversight personnel supporting the

award, administration, and oversight of State’s LOGCAP task order in 

Iraq illustrates the extent of State’s personnel shortfalls. As shown in 

figure 2, DOD provided 71 contracting and oversight personnel over the 

acquisition cycle to support this task order, while State provided fewer 

than 20 oversight personnel. 
Page 20 GAO-12-750 Iraq and Afghanistan 

 

Figure 2: DOD and State Contracting and Oversight Personnel Involved in the Planning, Award, and Oversight of the LOGCAP 

Task Order Supporting State in Iraq
Page 21 GAO-12-750 Iraq and Afghanistan 

 

In addition, when developing its own contract for medical support 

services, State relied on DOD medical planning experts in Iraq in part 

because of DOD’s expertise operating in a conflict environment. State’s 

medical officials tasked with developing the requirements informed us that 

they were not prepared to write requirements for the medical services 

contract on their own because they had little to no experience related to 

contracting. Further, they stated that no one within AQM could assist 

them because State did not have contracting personnel with expertise 

related to medical services. 

State has taken some steps to address its long-standing shortage of 

acquisition professionals by using a dedicated source of funding for its

acquisition workforce. Until 2008, AQM’s operations were funded by 

annual appropriations, which State acquisition officials believed did not 

provide a basis to obtain sufficient government or contractor personnel. In 

2008, AQM began using a working capital fund—a shared services model 

that provides procurement services on a fee-for-service basis to both 

domestic and overseas customers.27

State’s expectation that the working capital fund would allow AQM to be 

more responsive to increased demands on its acquisition workforce has 

been partially met. Between February 2008, when AQM began using the 

working capital fund, and April 2010, when State requested DOD’s 

support for acquisitions in Iraq, AQM added 21 full-time government 

personnel and 60 support contractors. By February 2012, shortly after 

 A one percent fee is charged to 

State’s internal customers, which is then used to finance all of AQM’s 

operations, including salaries and travel. According to State AQM 

officials, State began using the fund because it needed to be able to 

quickly respond to acquisition workload increases—including those 

specifically associated with operations in Iraq—and the fund would

generate a volume of resources directly proportional to AQM’s workload. 

 

2722 U.S.C. § 2684. 

State Has Not Fully 

Addressed Factors That 

Contributed to Reliance on 

DOD Acquisition Support

State Has Not Assessed 

Whether the Effort to Increase

Its Acquisition Workforce Is 

Sufficient
Page 22 GAO-12-750 Iraq and Afghanistan 

 

State took lead responsibility in Iraq, AQM added 25 more staff. This 

represents a 59 percent increase in AQM’s workforce overall since the 

implementation of the fund in 2008 (see table 2).

Table 2: Number of Personnel in AQM from 2008 to 2012

February 2008 April 2010 February 2012

Number of government personnel 141 162 200

Number of contract support staff 39 99 86

Total 180 261 286

Source: State data.

Even with these increases, State’s Inspector General reported in 

November 2010 and 2011 that the department lacked sufficient 

contracting personnel to handle the increase in the number of 

procurement transactions processed and the rise in the dollar value of 

procurement actions issued over the past decade. The Inspector General 

also identified associated challenges in acquisition planning, 

administration, and oversight in places like Iraq. Further, the relationship 

at State between procurement obligations and the number of government 

contracting professionals—a ratio that State has used to track its 

progress towards the goal of eliminating its long-standing shortage of 

acquisition professionals—worsened from 2008 to 2010. Over the two 

years, this ratio rose from about $47 million per government contracting 

professional in 2008 to about $57 million in 2010.28

State has not assessed how well the working capital fund has met 

expectations to surge the workforce for situations like Iraq and 

Afghanistan. State established the fund’s one percent fee after assessing

AQM’s expenses in 2007, and according to officials, anticipated demands 

for an increase in contract services for Iraq. While State’s Under 

In 2010, the 

department assessed its 2008 ratio as unfavorable compared with that of 

other federal agencies, but it has not established the target ratio it hopes 

to achieve. 

 

28State calculates a procurement ratio by dividing procurement obligations by the number 

of government employees classified in the General Schedule Contracting series (GS1102). The GS-1102 series is important for federal agencies because these personnel 

develop the knowledge of the legislation, regulations, and methods of federal contracting 

and skills to conduct central acquisition responsibilities such as to manage, supervise, 

perform, or develop policies and procedures for procurement.
Page 23 GAO-12-750 Iraq and Afghanistan 

 

Secretary for Management has repeatedly testified that the fund is 

helping State to “surge” its resources to respond to contingency 

requirements, State has not assessed the extent to which the fund has 

helped AQM’s workforce surge to meet requirements for Iraq and 

Afghanistan. In an April 2012 assessment of the fund, State identified 

some improvements as a result of its use of the fund, such as hiring 

additional staff that allowed for overall faster processing of contract 

actions, but did not address whether the fund has enabled AQM to surge 

its acquisition workforce capacity. This lack of an assessment of the 

fund’s ability to help AQM respond to contingency requirements is 

inconsistent with our prior conclusions that agencies should establish 

performance measures for working capital funds that align with strategic

goals.

29

Although State has acknowledged a shortage of contracting and subjectmatter expertise in its requests for DOD’s support in acquiring critical 

goods and services, the department has not assessed the expertise 

needed to support future contracting operations in Iraq and Afghanistan 

as part of its acquisition workforce planning efforts. We have previously 

reported that understanding where workforce gaps exist in the 

competencies and skills required to meet programmatic goals is key to 

helping agencies develop effective workforce strategies.

 

30

State also has not fully leveraged DOD’s expertise to further build its own 

capacity for managing complex acquisitions in environments like Iraq. For 

example, according to DOD and State officials, prior to the award of the 

LOGCAP task order, a State official from the embassy in Baghdad was 

working with contracting personnel at the Rock Island Contracting Center 

State’s 

acquisition workforce human capital plan for fiscal years 2010 through 

2014 does not address the need for additional skills or expertise for 

contracting personnel or subject-matter experts to support contracts in 

complex acquisition environments such as Iraq or Afghanistan. 

 

29GAO, Department of Justice: Working Capital Fund Adheres to Some Key Operating 

Principles but Could Better Measure Performance and Communicate with Customers, 

GAO-12-289 (Washington, D.C.: Jan. 20, 2012); and Intergovernmental Revolving Funds: 

Commerce Departmental and Census Working Capital Funds Should Better Reflect Key 

Operating Principles, GAO-12-56 (Washington, D.C.: Nov. 18, 2011).

30GAO, Department of Homeland Security: A Strategic Approach Is Needed to Better 

Ensure the Acquisition Workforce Can Meet Mission Needs, GAO-09-30 (Washington, 

D.C.: Nov. 19, 2008). 

State Has Not Assessed the 

Skills and Workforce Mix 

Needed to Meet Future 

Requirements
Page 24 GAO-12-750 Iraq and Afghanistan 

 

to facilitate the refinement of requirements and source selection process. 

However, according to Rock Island Contracting Center officials 

responsible for planning and awarding the task order, State’s AQM 

officials had minimal involvement in these activities, which limited their 

opportunities to gain insight and expertise. While State AQM officials are 

working with personnel at the embassy in Baghdad to identify continuing 

requirements beyond LOGCAP, DOD officials told us and State officials 

confirmed as of April 2012, AQM personnel were not working directly with 

their DOD counterparts at the Rock Island Contracting Center to build 

expertise even though State anticipates taking over the contracting 

function for these services within the next few years. State officials 

explained that there are no unique functions or processes for contracting

in contingency environments such as Iraq and Afghanistan and, therefore, 

State does not need to develop a separate workforce expertise or 

capability for its efforts in those countries. 

Approximately half of the personnel added to AQM’s workforce since

2008 are support contractors. While we did not assess the specific roles 

being performed by these contractors, some of them may be performing 

contract administration functions. However, State has not assessed the

extent to which it is appropriate for contractors to perform contract 

administration functions, which we recommended in April 2010 the 

department do.31

 

31

 As of February 2012, these support contractors 

accounted for approximately one-third of AQM’s staff. State’s Office of 

Inspector General attributed the increased reliance on contractors in part 

to delays and other difficulties associated with the hiring process for 

government employees, citing lead times of up to 18 months to hire 

government personnel. While contractors provide valuable support, they 

do not have the authority to perform certain types of acquisition activities 

such as awarding contracts or approving contractual documents. 

Moreover, State’s Deputy Inspector General testified in April 2012 that the 

use of contractors to supplement staffing in support of acquisition 

management has increased risk related to potential conflict of interest. 

Without determining the extent to which support contractors should 

perform contract administration functions, State is limited in its ability to 

ensure that it has sufficient government contracting personnel to meet 

future needs in Iraq and Afghanistan. 

GAO-10-357. 
Page 25 GAO-12-750 Iraq and Afghanistan 

 

State has not conducted the planning necessary to ensure it has sufficient 

contract oversight capacity for Iraq and Afghanistan in the future, even 

though it has acknowledged a lack of personnel with requisite experience 

and expertise to meet its current oversight needs. Contract oversight was 

in State’s scope of planned activities in Iraq, but the extent of planning for 

oversight functions was inconsistent among contracted services we 

reviewed. To carry out contract oversight, State generally relies on CORs 

appointed from programs within the department’s regional and functional 

bureaus to help ensure that the contractor accomplishes the required 

work. These CORs are funded through programmatic and bureau 

budgets, as opposed to AQM’s working capital fund. State typically 

assigns COR duties to staff whose primary duties are program 

management, so these staff perform COR duties part-time. The practice 

of having personnel perform their COR duties on a part-time basis is also 

used at other agencies, including DOD for its oversight of contracts in Iraq 

and Afghanistan. According to State contracting and regional bureau 

officials, State conducts general planning for CORs as part of the 

department’s human capital planning process to meet its overall mission 

and generally determines the number of CORs necessary to oversee a 

specific contract during early acquisition planning meetings. 

Because State officials had limited involvement in the acquisition 

planning, they did not have sufficient insight into the oversight required for 

basic support services in Iraq. According to DOD officials directly involved 

in the planning and award of the LOGCAP task order, State’s limited 

involvement in acquisition planning led to State’s difficulty in

understanding the full extent of contract oversight needed. This included 

identifying the minimum number of CORs needed and their training. 

State’s limited acquisition planning for the extent of oversight needed is 

reflected in State’s fiscal year 2012 congressional budget justification, as 

well as State’s fiscal year 2013 Mission and Strategic Resource Plan for 

the U.S. Mission to Iraq. In neither case did State identify funding or the 

number of personnel expected to perform contract oversight supporting 

the LOGCAP task order. It was only after extensive negotiation between 

State and DOD officials and the award of the LOGCAP task order that 

State agreed to assign the number of oversight personnel DOD 

considered sufficient. Providing the agreed upon level of oversight for the 

LOGCAP task order and other DOD awarded and managed contracts 

resulted in an unplanned allocation of staff for State. As a result of the 

negotiations with DCMA, State dedicated four of its personnel in Baghdad 

as full-time CORs rather than having them perform COR duties in addition 

to other responsibilities. Finally, even with new understanding of the level 

of contract oversight required for the LOGCAP task order, State’s fiscal 

State Has Not Sufficiently 

Planned for Contract Oversight 

in Iraq and Afghanistan 
Page 26 GAO-12-750 Iraq and Afghanistan 

 

year 2013 congressional budget justification for Iraq does not request 

funding for additional positions to conduct oversight. As a result, State 

may need to again redirect personnel from other duties to perform as 

CORs for State’s LOGCAP task order until its expiration at the end of 

2013. 

In contrast, State has improved its planning for contract oversight of 

private security contractors. We previously reported on improvements 

State made to its oversight of private security contractors in Iraq by 

increasing the number of diplomatic security personnel stationed in Iraq to 

oversee contractor activities and requesting and receiving funding to hire 

and train 100 additional agents.32

DOD documentation indicates an expectation that oversight and other 

acquisition support roles for basic support and other critical goods and 

services in Iraq should transition from DOD to State no later than the start 

of 2014. However, State has not determined its future requirements for 

oversight personnel and the funding needed to fulfill those needs. For 

example, State has not conducted an overall assessment of the number 

of personnel needed to replace DOD personnel conducting contract 

oversight on State’s behalf in Iraq. Similarly, there has not been an 

assessment of the skills, expertise, and training such oversight personnel 

would need; whether other employees can be redirected to fulfill the 

oversight role; or requests for funding to ensure sufficient contract 

oversight capability for these contracts as they transition from DOD to 

State oversight. For example, State’s Acquisition Workforce Human 

Capital Plan for Fiscal Years 2010 through 2014 does not address any 

specific needs for contract oversight personnel to support complex 

To ensure it could sustain this progress, 

State conducted extensive planning to oversee its Worldwide Protective 

Services contract for guard and movement security services, which 

informed decisions to increase resources and personnel. For example, in 

2010, State requested funding to add 15 full-time positions specifically for

oversight of its worldwide personal protective services contracts. 

Similarly, for fiscal year 2011, State’s Bureau of Diplomatic Security 

requested additional funding for costs associated with oversight 

personnel for contracts that provide protective security services 

throughout Iraq. 

 

32GAO, Rebuilding Iraq: DOD and State Department Have Improved Oversight and 

Coordination of Private Security Contractors in Iraq, but Further Actions Are Needed to 

Sustain Improvements, GAO-08-966 (Washington, D.C.: July 31, 2008). 
Page 27 GAO-12-750 Iraq and Afghanistan 

 

acquisition environments such as Iraq or Afghanistan. Without conducting 

planning for contract oversight, State is not well positioned to determine 

whether it has sufficient time to hire or otherwise develop its capacity to 

meet future oversight needs or whether it again must rely on DOD to 

supplement its acquisition workforce. A decision to proceed with acquiring 

needed services without sufficient oversight personnel in place puts the 

agency at risk of being unable to identify and correct poor contractor 

performance in a timely manner and ensure consistent delivery of goods 

and services critical to maintaining State’s presence in Iraq.

In deciding to rely on DOD for 20 assisted acquisitions, State did not 

always comply with requirements for determining whether an assisted 

acquisition was the best procurement approach. For 12 of the assisted 

acquisitions, we found that determinations were not consistent with FAR 

and OMB requirements in terms of the extent to which certain factors 

were considered. For example, in deciding to use DOD’s LOGCAP 

contract in Iraq, State did not assess cost-effectiveness. We also found 

that State and DOD did not prepare and sign interagency agreements for 

13 of the 20 assisted acquisitions that contained certain factors designed 

to ensure strong management. For example, State and DOD did not 

identify roles and responsibilities as part of an interagency acquisition 

agreement prior to solicitation of the LOGCAP task order in January 

2011. The State First policy for making and implementing decisions 

regarding interagency acquisitions has not been updated since 2008 to 

reflect current OMB guidance and FAR requirements for determinations 

of best procurement approach or interagency acquisition agreements.

Furthermore, the Economy Act—which the departments cited as their 

authority for interagency acquisitions—requires that State reimburse DOD 

based on the actual costs of awarding and managing interagency 

acquisitions. In April 2012, the Army’s Rock Island Contracting Center 

began tracking the staff-hours dedicated to assisted acquisitions 

supporting State in Iraq and Afghanistan and expects to submit the 

associated costs to State for payment. However, the departments have 

unresolved positions over whether State should reimburse DOD for the 

costs DOD incurred prior to January 2012. These positions could have 

been resolved if the departments had prepared and signed the required 

interagency acquisition agreements. The lack of compliance with 

guidance and regulation has implications for State’s ability to make sound 

acquisition decisions. Specifically, State lacks the insight needed to 

assess alternative acquisition approaches and has not provided evidence 

of taking key acquisition planning steps. The expiration of key contracts 

supporting its presence in Iraq and changes to the U.S. presence in 

State and DOD Did 

Not Comply with 

Requirements for Use 

and Management of 

Assisted Acquisitions 
Page 28 GAO-12-750 Iraq and Afghanistan 

 

Afghanistan over the next 18 months compresses the time available for 

State to gain insights, plan, and make sound decisions about whether to 

continue to rely on interagency acquisitions or independently acquire 

critical goods and services.

The OMB guidance issued in 2008 and the FAR provisions regarding 

interagency acquisitions require agencies to make a determination that 

the use of an interagency acquisition represents the best procurement 

approach. In making this determination, the requesting agency—in this 

case, State—is to consider certain factors prior to requesting that a 

servicing agency—in this case, DOD—conduct an acquisition on its 

behalf. State officials told us they regard the justifications contained in the 

approved “waiver packets” prepared under the State First policy to be 

sufficient to meet FAR and OMB requirements.33 However, the State First 

policy has not been updated since the issuance of OMB’s 2008 guidance 

on improving the use of interagency acquisitions or the 2010 amendment 

to the FAR requiring a determination of best procurement approach.34

 

33In response to GAO requests for documentation of compliance with FAR and OMB 

requirements for a determination of best procurement approach for the assisted 

acquisitions within the scope of our review, State provided “waiver packets” prepared 

under its State First policy. Waiver packets provided included one or more of the following: 

waiver, internal memo, Economy Act determination and findings, Military 

Interdepartmental Purchase Request(s), and /or State standard form 1921 for award or 

modification of an interagency acquisition agreement. For our analysis of compliance with 

the requirement for a determination of best procurement approach, we reviewed waivers 

and internal memos because the other documents included in the waiver packets go to 

requirements other than the determination of best procurement approach. Under the State 

First policy, the waiver must contain certain information such as a description of the 

requirement, duration of the requirement, estimated value, and reason that using another 

agency for the acquisition is in the best interest of State. 

 

These differences have implications for assisted interagency acquisitions, 

such as those we reviewed. OMB’s guidance is intended to help agencies 

make sound business decisions to support the use of interagency 

acquisitions, and the purpose of the amendment to the FAR provisions on 

interagency acquisitions is to prevent abuse of interagency contracts by 

requiring a best procurement approach determination. The State First 

policy is silent with respect to how requesting bureaus wanting to enter 

into an interagency acquisition should make and document a 

determination of best procurement approach, putting the agency at risk 

34An interim rule was issued on December 13, 2010 and the final rule was issued on 

January 3, 2012. 75 Fed. Reg. 77,733, 77, 735; 77 Fed. Reg. 183. 

State Did Not Comply with 

Requirements for 

Determining Best 

Procurement Approach 
Page 29 GAO-12-750 Iraq and Afghanistan 

 

for moving forward with an interagency acquisition that is not a sound 

business decision. 

We found that for 12 of the 20 assisted acquisitions we reviewed, 

determinations of best procurement approach—documented through the 

State First waiver packets—were not made in accordance with the FAR 

and OMB requirements. In one case, a determination of best procurement 

approach was not made at all. In September 2010, State’s mission in 

Afghanistan requested to receive dining facility services through DOD’s 

LOGCAP contract. State’s AQM and OPE did not approve a State First 

waiver or make any other determination of best procurement approach for 

this interagency acquisition. In the case of LOGCAP Iraq, the Near 

Eastern Affairs bureau’s requirements for services under LOGCAP were 

not approved through a State First waiver before DOD proceeded with 

that interagency acquisition and State transferred funds to DOD.35

Table 3: Summary of Noncompliance with OMB and FAR Requirements for 

Determination of Best Procurement Approach for 12 Assisted Acquisitions

Further, as shown in table 3, State did not always consider, as required, 

its full scope of requirements or cost-effectiveness when making a 

determination of best procurement approach.

Contract, task order, or 

modification

Considered full scope of 

requirements?

Considered costeffectiveness?

LOGCAP (Afghanistan)a  

LOGCAP (Iraq)  

Sense and Warn Installation  

Sense and Warn Operations  

FIRST Maintenance  

Food  

Fuel (6 contracts)  

Legend:  Yes

  No

Source: GAO analysis of State and DOD documents.

a

No determination of best procurement approach was made. 

 

35State prepared two waivers in support of its task order under LOGCAP Iraq. One waiver 

was for the Bureau of Diplomatic Security’s requirements, which was approved in July 

2011. The second waiver was for the Bureau of Near Eastern Affairs’ requirements, which 

has not been approved and, according to AQM and Near Eastern Affairs officials, remains 

in draft form.
Page 30 GAO-12-750 Iraq and Afghanistan 

 

In the April and September 2010 letters from State to DOD requesting 

that DOD acquire goods and services on State’s behalf and in the 

subsequent coordination activities between the departments, there was 

extensive discussion of some of the factors agencies are to consider 

when making a best procurement approach determination under the FAR 

requirements and OMB guidance. For example, State’s request letters 

documented an urgent need that could be filled using DOD’s contracts, 

and State indicated it had been satisfied with DOD’s acquisition of the 

services as an existing customer. While these are among the factors

agencies are to consider when making their determinations, subsequent 

events revealed that State did not have a full understanding of other 

factors, such as how its requirements would be met, when it decided to 

pursue interagency acquisitions with DOD. 

This lack of full understanding can be illustrated by State’s experience 

working with DOD to acquire basic support goods and services to support 

its mission in Iraq. In State’s April 2010 letter to DOD requesting 

continued use of LOGCAP for basic services and use of associated food 

and fuel supply contracts, State highlighted how those contracts would 

meet its requirements. However, it appears that State did not have a full 

understanding of the scope of services and limitations of the contracts 

when it made its request. For example, under the terms of DLA’s food 

contract, consistent with regulations regarding supply, certain goods 

cannot be acquired from the local economy.36

 

36Under the Javits-Wagner-O’Day Act, the Committee for Purchase from People Who Are 

Blind or Severely Disabled, that implements the AbilityOne program, maintains a 

procurement list of all supplies and services required to be purchased from AbilityOne 

participating nonprofit organizations. Supply distribution facilities in DLA are required to

obtain supplies on the procurement list from the central nonprofit organization identified or 

its designated AbilityOne participating nonprofit organization. 41 U.S.C. § 8503-04; FAR § 

8.705-1.

According to State and 

DOD officials, State subsequently became aware of this limitation when it 

sought to have DOD modify the contract so that it could procure goods 

locally. In addition, by requesting to use the LOGCAP contract, State 

unknowingly took on additional security requirements because the 

contract requires that contractor personnel travel with a security escort. 

DOD had previously arranged for this security, but with DOD’s withdrawal 

from Iraq, State had to make other security arrangements. According to 

State and DOD officials, including those in Iraq, after unsuccessful efforts 

to modify or eliminate security requirements from the contract, State 

requested that DOD award a task order under its existing SSS-I contract. 
Page 31 GAO-12-750 Iraq and Afghanistan 

 

Furthermore, State officials did not believe it was necessary to provide 

security for convoys of food and fuel. However, State ultimately decided 

to do so based on discussions with DOD and coordination with supplier 

companies. In requesting and justifying its use of LOGCAP and DLA 

supply contracts, State did not acknowledge these additional 

requirements or their implications as part of its decision to rely on DOD.

Similarly, we found that State First waiver packets and other 

documentation did not fully implement the FAR’s requirement that costeffectiveness be considered in making the determination of best 

procurement approach. For example, neither the State First waiver 

prepared for use of DOD’s contract for sustainment of equipment nor the 

waiver prepared for use of DOD’s Sense and Warn capability assessed 

cost-effectiveness. Further, there is evidence that State’s decision to rely 

on DOD’s LOGCAP contract in Iraq did not consider cost-effectiveness. In 

State’s April 2010 request to use LOGCAP, the justification does not refer 

to cost-effectiveness. A subsequent September 2010 DOD memorandum 

authorizing DOD components’ implementation of that request concluded, 

“DOD cannot provide the [requested] support at a lower cost or more 

quickly than could State contracting independently.” DOD’s assessment 

of the costs also noted that “the amounts requested by State are likely to 

be significantly less than the actual cost of the support,” which were

estimated at the time to be at least $63 million annually. Indeed, over the 

15 months following State’s initial request to use LOGCAP, requirements 

for services changed and associated costs rose to an estimated 

$219 million for 2012 at the time DOD awarded State’s LOGCAP task 

order. However, the State First waiver submitted by the Bureau of 

Diplomatic Security in July 2011 stated, in the cost-benefit analysis 

section, that market research or other comparison methods were not 

used because of the urgency of the requirement. Although State’s 

decision to request LOGCAP to sustain critical goods and services to 

avoid mission failure may have been reasonable under the 

circumstances, the absence of any subsequent effort to assess costeffectiveness is not only contrary to acquisition regulation but also limits 

the department’s understanding of expected resource needs, ability to 

plan and budget for future costs, and evaluate other options in the future 

for meeting this requirement. 
Page 32 GAO-12-750 Iraq and Afghanistan 

 

Although State and DOD coordinated to identify State’s acquisition needs

for Iraq and made a series of decisions on what DOD would provide, how

the departments documented and implemented these decisions was in 

some cases inconsistent with the FAR and OMB guidance intended to 

ensure effective management of interagency acquisitions. Specifically, 

the regulation and guidance require agencies to enter into written 

agreements to govern assisted interagency acquisitions. For 13 of the 

20 assisted acquisitions we reviewed, State and DOD either did not 

prepare an agreement, did not both sign the agreement, or the agreement 

did not contain required elements designed to ensure effective 

management. 

Formal interagency acquisition agreements establishing roles and 

responsibilities help ensure strong management. We previously reported 

that a lack of clear definitions of roles and responsibilities is a significant 

risk with interagency acquisitions.

37 To help mitigate that risk, the FAR 

and OMB’s 2008 guidance on strengthening the management of 

interagency acquisitions direct agencies to have in place prior to 

solicitation of a contract or task order a written interagency acquisition 

agreement that, among other things:

38

• defines roles and responsibilities for contract management, 

• describes goods or services covered in order to demonstrate a bona 

fide need, 

• includes funding information from both the requesting and servicing 

agency to ensure the proper transfer and obligation of funds, and

• identifies unique terms and conditions that apply for the requesting 

agency.

Under the State First policy, once AQM and OPE approve a bureau’s 

State First waiver, AQM is required to work with the bureau to prepare an 

interagency acquisition agreement with the servicing agency. The 

agreement may be prepared on a State standard form and must contain 

(1) a description of the supplies or services required, (2) delivery 

requirements, (3) a funds citation, (4) a payment provision, and 

 

37GAO, High-Risk Series: An Update, GAO 11-278 (Washington, D.C.: February 2011). 

38FAR § 17.502-1(b)(1) and OMB, Office of the Federal Procurement Policy, Improving 

the Management and Use of Interagency Acquisitions (Washington, D.C.: June 6, 2008). 

The OMB guidance provides that part A of an interagency agreement, which sets out the 

general terms and conditions, may cover multiple assisted acquisitions. 

State and DOD Did Not 

Fully Meet Requirements 

for Assisted Interagency 

Acquisition Agreements 
Page 33 GAO-12-750 Iraq and Afghanistan 

 

(5) acquisition authority as may be appropriate. The State First policy 

generally aligns with the FAR provisions regarding interagency 

acquisitions under the Economy Act in effect prior to the 2010 

amendment to FAR. However, the State First policy has not been 

updated since the issuance of OMB’s 2008 guidance on improving the 

management of interagency acquisitions by ensuring interagency 

agreements for assisted acquisitions contain certain elements or the FAR 

amendment requiring a written agreement on responsibility for 

management and administration for assisted acquisitions. Under State’s 

policy, an interagency agreement may be documented on a standard 

one-page form. Completion of this form does not meet the requirements 

for a written interagency agreement delineated in the FAR and OMB 

guidance because the form does not require details such as roles and 

responsibilities for contract administration and management. Among other 

things, identifying roles and responsibilities is critical to ensuring effective 

management of an interagency acquisition. 

DOD policy also mandates the use of interagency acquisition 

agreements. The Director, Defense Procurement and Acquisition Policy, 

issued a memorandum in October 2008 to implement OMB’s 2008 

guidance, and we found it to be consistent with that guidance and current 

FAR provisions. In addition, for all interagency acquisitions over 

$500,000—which includes all of the interagency acquisitions we 

reviewed—DOD’s memorandum directs that interagency acquisition 

agreements contain the elements or follow the model in the interagency 

acquisition agreement template provided in OMB’s guidance.

Although written interagency acquisition agreements were required for all

20 of the assisted acquisitions we reviewed, State and DOD did not 

consistently prepare them in accordance with acquisition regulation and 

guidance, as shown in table 4. 
Page 34 GAO-12-750 Iraq and Afghanistan 

 

Table 4: Status of Interagency Agreements for 20 Assisted Acquisitions

Contract, task order, or modification

Agreement 

prepared

Signed by both 

departments

Food  

Fuel (6 contracts)  

LOGCAP (Iraq)  

SSS-I (for LOGCAP)  

SSS-I (for food and fuel)  

LOGCAP (Afghanistan)  

TWISS (5 task orders)  

Sense and Warn Installation  

Sense and Warn Operations  

FIRST Maintenance  

Vetting  

Legend:  Yes

  No 

  Did not meet one or more requirements

Source: GAO analysis of State and DOD documents

Seven of the 20 acquisitions were covered by an interagency acquisition 

agreement between State and DLA that contained the required elements, 

such as roles and responsibilities, designed to ensure effective 

management of the acquisition. Of the remaining 13, interagency 

acquisition agreements were prepared for 3, but these agreements were 

not signed by both departments prior to solicitation and did not contain 

roles and responsibilities or other elements. For example, State officials 

prepared standard one-page Department of State forms for the LOGCAP 

task order and two SSS-I task orders, but DOD officials did not sign the 

forms. Further, these forms did not specify State’s requirements for the 

acquisition or the respective roles and responsibilities for State and DOD. 

The other 10 assisted acquisitions were not covered by any interagency 
Page 35 GAO-12-750 Iraq and Afghanistan 

 

acquisition agreement, which contributed to confusion and limited 

effective management of the acquisitions.39

According to State and DOD officials, in lieu of formal interagency 

acquisition agreements, DOD’s acquisition assistance was implemented 

at the lowest possible organizational level. State and DOD officials 

identified the Executive Steering Group, which was established in 

September 2010, as well as the associated Embassy Support and 

Enduring Base Transition Board, as the primary mechanisms of 

coordinating and implementing DOD’s acquisition support. The Executive 

Steering Group meets on at least a bi-weekly basis. According to 

Executive Steering Group leadership, it does not have any decisionmaking authority but rather helps identify issues and relevant officials or 

organizations that might address them and tracks the progress of the 

issues to resolution. The departments’ Principal Under Secretary of 

Defense for Acquisition, Technology, and Logistics and Under Secretary 

of State for Management provide guidance and make decisions pertaining 

to issues raised in the group on an as-needed basis. Though a draft 

charter for the group was prepared, officials noted a determination was 

made not to finalize it, as they believed the goodwill between the 

departments was sufficient to resolve any disagreements. 

While the Executive Steering Group facilitated discussion and identified 

acquisition issues, the group’s activities did not replace the departments’ 

responsibilities under the FAR and OMB guidance for formalizing written 

interagency acquisition agreements. Executive Steering Group members 

from both departments informed us that they did not consider State’s 

reliance on DOD to acquire critical goods and services in these instances 

as constituting assisted acquisitions that required interagency 

agreements, even though group membership included State acquisition 

officials and DOD acquisition and financial management officials. For 

example, senior State and DOD officials told us that the departments did 

not enter into written interagency acquisition agreements for LOGCAP or 

SSS-I because of their understanding that the Military Interdepartmental 

 

39With respect to State’s use of LOGCAP in Afghanistan, the U.S. Forces-Afghanistan and 

the U.S. mission in Afghanistan entered into a memorandum of agreement in August 2009 

for the support of personnel acting under the authority of the chief of mission to implement 

the U.S. strategy in Afghanistan. The agreement is an umbrella agreement intended to 

provide a baseline direction for support responsibilities, rather than an interagency 

acquisition agreement for a specific interagency acquisition.
Page 36 GAO-12-750 Iraq and Afghanistan 

 

Purchase Requests submitted by State were sufficient to facilitate 

agreement and associated reimbursement.40

By not having formalized agreements in place prior to solicitation, State 

and DOD experienced significant expectation gaps about roles and 

responsibilities. These gaps delayed establishment of contract oversight 

responsibility and contractor performance standards. Although the 

departments eventually reached mutual understanding through 

discussions at the Executive Steering Group, the process was inefficient 

and the delays were avoidable. For example: 

 However, Diplomatic 

Security officials responsible for preparing waivers and processing 

payment for the assisted acquisitions acknowledged that interagency 

acquisition agreements were required. They stated that AQM did not 

pursue agreements due to the urgency of the needs and the limited time 

for DOD to execute contract actions on State’s behalf. Standard one-page 

interagency agreement forms were prepared for both LOGCAP and SSSI, indicating recognition at some level within AQM that these acquisitions 

were interagency acquisitions. These one-page forms, however, did not 

meet FAR requirements and OMB guidance, such as specifying the 

departments’ respective roles and responsibilities. 

• A one-page interagency agreement form for the use of LOGCAP in 

Iraq was prepared by State in January 2011 but never signed by 

DOD. The form did not define the roles and responsibilities for 

acquisition activities between State and DOD, including contract 

oversight. Resulting disagreements between DOD and State 

regarding which department would provide CORs persisted for 

several months, leading to DCMA not entering into an agreement to 

support State without State first identifying its CORs and agreeing to 

train them to DOD standards. State eventually agreed to provide 

18 full- and part-time oversight personnel, and DCMA provided

26 quality assurance representatives with specific subject matter 

expertise for overseeing the contractor, in support of the State 

personnel. Although that agreement was reached in February 2012, it 

was delayed over a year beyond solicitation of the LOGCAP task 

order as State and DCMA officials resolved issues related to the 

 

40Although OMB’s guidance identifies Military Interdepartmental Purchase Requests as 

one of the forms that can facilitate interagency transfers, it also directs that these requests

incorporate by reference or attachment the terms and conditions of an overarching 

interagency acquisition agreement, which State did not do for these acquisitions.
Page 37 GAO-12-750 Iraq and Afghanistan 

 

oversight roles and responsibilities, as well as the associated payment 

for DCMA’s services.

• State prepared a one-page interagency agreement form covering two

SSS-I task orders DOD awarded on State’s behalf, which DOD did not 

sign. The form did not identify unique terms and conditions that 

applied to State, as required by the FAR and OMB guidance, which in 

this case pertained to security contracts. Given the transition in 

responsibility from DOD to State for the mission in Iraq, DOD 

contracting officials raised concerns throughout the summer of 2011 

over the continued use of DOD security contractor performance 

standards, such as rules of engagement. State ultimately decided to 

use its own performance standards, but the delay in reaching 

agreement regarding security standards delayed task order award by 

2 months.

In contrast, DCAA and DCMA entered into agreements with State, 

covering their specific roles in administration, oversight, and audits across 

the 20 assisted acquisitions. DCAA and DCMA provide support across 

multiple organizations both within and outside DOD and regularly use 

agreements to formalize that support. Since 1983, State has received 

DCAA’s contract audit services under an agreement generally renewed 

annually. In addition, since 2003, DCAA’s Iraq Branch Office has been 

supporting both DOD’s and State’s acquisitions in Iraq; the agreement 

was modified in December 2011 to support State’s requirements following 

DOD’s departure. In February 2012, State entered into a memorandum of 

agreement with DCMA for contract administration support for the 

contracts awarded on behalf of State with performance in Iraq, including 

LOGCAP. The agreements with DCAA and DCMA pertain to only those 

agencies’ specific activities with respect to the covered acquisitions. As 

such, these agreements do not fulfill OMB and FAR requirements for 

interagency acquisition agreements as they do not cover other activities 

and responsible parties, such as performing contract award and 

administration on State’s behalf.

The actual costs to a servicing agency in an Economy Act assisted 

interagency acquisition generally include both the costs of the contracted 

goods or services, as well as the costs associated with the servicing 

agency’s commitment of personnel and other resources to plan and 

execute the contract action on the requesting agency’s behalf. For 

example, beginning with State’s requests in 2010 for DOD’s assistance 

under the Economy Act, DOD committed personnel and other resources 

to plan and execute the contract actions on State’s behalf. State provided 

Payment for Certain Costs 

Associated with Assisted 

Interagency Acquisitions 

Remain Unresolved
Page 38 GAO-12-750 Iraq and Afghanistan 

 

payments to DOD for the costs of the contracted goods and services for 

the 20 assisted interagency acquisitions in our review. For some of these 

acquisitions, however, State has not yet paid DOD for other direct or 

indirect costs of providing goods and services. After we raised questions 

regarding State’s payment for actual costs, DOD legal officials have taken 

the position that State should pay DOD for these costs and are now in the 

process of determining the amount State should pay going back to 2010. 

In contrast, State legal officials have taken the position that State is 

prohibited from paying DOD for the costs associated with awarding and 

supporting the interagency acquisitions prior to 2012. These positions are 

unresolved. Had the departments formalized interagency acquisition 

agreements in accordance with the FAR and OMB guidance, these 

issues could have been resolved prior to moving forward with these 

acquisitions. Furthermore, unresolved positions on the terms and extent 

of State’s payment to DOD place the departments at risk of noncompliance with fiscal law.41

The Economy Act was the authority used for the interagency acquisitions 

in our review. For interagency acquisitions under the authority of the 

Economy Act, the requesting agency is required to pay the servicing 

agency on the basis of the actual cost of entering into and administering 

the contract on the requesting agency’s behalf.42

 

41Fiscal law provides that an agency generally must use its appropriated funds for the 

purposes for which the appropriations were made. 31 U.S.C. § 1301(a). In addition, an 

agency receiving goods or services funded by another agency’s appropriations must 

reimburse the servicing agency to avoid improperly augmenting the requesting agency’s 

appropriations. Furthermore, payments received by the servicing agency for goods or 

services provided, without other statutory authority, must be deposited into the Treasury 

as miscellaneous receipts. 31 U.S.C. § 3302(b).

 In determining actual 

costs, agencies must avoid the unauthorized augmentation of their 

appropriations, as charging too much would augment the servicing 

agency’s appropriations, while charging too little would augment the 

requesting agency’s appropriations. The Economy Act requires that the 

actual costs include all direct costs attributable to the performance of a 

service or furnishing of materials, regardless of whether the servicing 

4231 U.S.C. § 1535(b); FAR § 17.502-2(d)(4). Although precise calculations of actual costs 

are not required, the amount to be paid should result from a bona fide attempt to 

determine actual cost and should reasonably approximate actual cost. For a discussion of 

payment requirements under the Economy Act, see GAO, Principles of Federal 

Appropriations Law, 3rd ed. Vol. 3, ch. 12.B.1. GAO-08-978SP (Washington, D.C.: 

September 2008). 

Departments Have Not 

Resolved Whether State Is 

Required to Pay DOD for 

Certain Costs Prior to 2012 
Page 39 GAO-12-750 Iraq and Afghanistan 

 

agency’s expenditures were thereby increased.43 Direct costs include 

salaries for employees doing the work.44 Actual cost also includes certain 

indirect costs (overhead) proportionately allocable to the transaction, such 

as administrative overhead applicable to supervision.45

Legal officials from both departments informed us that State paid the 

Army’s Rock Island Contracting Center for the costs of the LOGCAP, 

SSS-I, vetting, and FIRST maintenance contracted services. However, 

these officials informed us that State has not paid for the Center’s costs 

associated with the personnel working on these acquisitions on State’s 

behalf or other indirect overhead costs. The departments have not 

resolved their positions with respect to whether State should pay DOD for 

these costs going back to 2010, when coordination activities began for 

these interagency acquisitions. DOD legal officials told us they had 

determined that the Economy Act requires State to pay DOD for the costs 

associated with award and management of the task orders and contract 

modification on State’s behalf, as these costs are part of the interagency 

acquisitions’ actual costs. In response to our questions regarding State’s 

payment for these costs, the Army’s Rock Island Contracting Center 

established a process in April 2012 to document time expended in 

support of State acquisitions going forward and has also identified those 

personnel who have been providing support to State. For example, 

Center officials estimated that approximately 12 full-time equivalent staff 

had been supporting State’s LOGCAP task order alone since the summer 

of 2010, when acquisition planning activities began. The Center has not 

yet finalized its calculation of the hours and associated costs but has 

indicated that upon finalization it will submit this information to State for 

payment. 

 

State legal officials agreed that the department is required, in accordance 

with the Economy Act, to pay DOD on the basis of actual costs—to 

 

43Otherwise, the servicing agency would be penalized to the extent that its funds are used 

to finance the cost of performing another agency’s work, while the requesting agency’s 

appropriations are augmented to the extent that they now may be used for some other 

purpose. 57 Comp. Gen. 674, 682. 

4412 Comp. Gen. 442. 

45Specifically, indirect costs which are funded out of currently available appropriations and 

bear a significant relationship to the service or work performed or the materials furnished 

are recoverable in an Economy Act transaction the same as direct costs. 56 Comp. Gen. 

275. 
Page 40 GAO-12-750 Iraq and Afghanistan 

 

include costs associated with contract award and management—but 

believe this applies only to costs incurred after December 31, 2011. State 

legal officials informed us that State is prohibited from paying DOD for 

support provided prior to December 31, 2011, because doing so would 

improperly augment DOD’s appropriations. State legal officials point to 

language in National Security Presidential Directive 36 directing 

departments to provide support to U.S. activities in Iraq on a nonreimbursable basis and stating that the Director of OMB shall ensure 

budget submissions shall request funding necessary to support the U.S. 

mission in Iraq. State legal officials maintain that DOD was directed to 

include support costs—such as the cost of personnel who awarded and 

administer task orders on State’s behalf and other indirect overhead 

costs—in its budget requests so DOD would receive adequate 

appropriations for these purposes. These officials further maintain that 

providing payment to DOD for the same costs would augment DOD’s 

appropriations. State and DOD’s positions regarding payment 

requirements have not yet been resolved, which leaves the departments 

vulnerable to non-compliance with fiscal law. 

The departments’ positions with respect to payment for certain costs 

associated with the assisted interagency acquisitions we reviewed should 

have been resolved prior to moving forward with the acquisitions through 

formalizing agreements between them. In the September 2010 meeting 

establishing the Executive Steering Group, a draft charter was presented 

to provide organization and operating guidance for DOD to transfer 

equipment and develop sourcing solutions for State requirements. This 

draft charter notes that the Office of the Secretary of Defense,

Comptroller will advise the group to ensure statutory compliance with the 

Economy Act, with general counsel to assist. This charter was never 

finalized, and thus, the departments’ leadership missed an opportunity to 

formalize the role of the Comptroller, who could have clarified the terms of 

payment associated with DOD’s support. Senior State and DOD officials 

who participated in the Executive Steering Group told us they understood 

there to be an agreement in principle for State to pay DOD for actual 

costs. However, they could not provide evidence that DOD was being 

paid for any costs other than the costs of the contracted goods and 

services. 

Further, had the departments executed interagency acquisition 

agreements containing the elements enumerated in the FAR and OMB 

guidance, the departments’ positions regarding payment would have 

been aligned. Under OMB guidance, an interagency acquisition 

agreement should contain specific terms for payment to ensure 

Departments Missed 

Opportunities to Clarify and 

Resolve Payment Terms 
Page 41 GAO-12-750 Iraq and Afghanistan 

 

agreement on these terms between the agencies.46 Without these 

agreements, terms for payment were unclear, resulting in the 

departments’ positions being unresolved for these five interagency 

acquisitions. For example, the September 2010 memorandum signed by 

the Deputy Secretary of Defense authorized the provision of basic life 

support to State through the Army’s LOGCAP contract on a reimbursable 

basis; however, Army officials indicated that there was an open question 

as to whether associated support costs were to be reimbursed. Had the 

departments executed an interagency acquisition agreement prior to 

issuance of the solicitation for the LOGCAP task order supporting State, 

as required under the FAR, the departments would have established a 

mutual understanding with respect to reimbursable costs. In contrast, the 

annual renewals to the memorandum of agreement that State has in 

place with DCAA provide for State to reimburse DCAA for the services 

provided to State in 2011 and 2012 under the Economy Act. The 

memorandum of agreement that State has with DCMA provides for the 

reimbursement of services in fiscal year 2012 under the Economy Act.

In sustaining its presence in Iraq and Afghanistan, State faces important 

decisions for how to acquire critical goods and services as it goes 

forward. To be consistent with FAR requirements, State’s decision to 

continue relying on DOD for the acquisition of critical goods and services 

should entail assessing procurement approaches—such as independently 

acquiring the goods and services—to determine the best approach.

47

 

46OMB’s guidance provides that an interagency agreement must include financial 

information that is required to authorize the transfer and obligation of funds for both the 

acquisition and the assistance provided by the servicing agency in connection with the 

acquisition.

 

However, State has had limited insight into the acquisition process for the 

basic support and security services provided under DOD contracts. 

Further, while the Rock Island Contracting Center has recently begun 

tracking the hours its personnel spend supporting assisted acquisitions on 

State’s behalf, DOD has not yet reported the associated costs to State. 

State’s ability to assess approaches and make informed decisions about 

whether to continue relying on DOD’s contracts through interagency 

acquisitions is hindered until State can fully evaluate the actual costs of 

DOD’s acquisition support. 

47FAR § 17.502-1(a)(1). 

State Lacks Insight to 

Assess Alternative 

Approaches for Future 

Acquisitions 
Page 42 GAO-12-750 Iraq and Afghanistan 

 

To help State identify available procurement alternatives to meet its 

continuing requirements in Iraq, State and DOD established a Transition 

Phase II Working Group in early 2012. However, the amount of time 

available for State to make and implement acquisition decisions is 

shrinking as key contracts are set to expire over the next 18 months. If 

State is to independently acquire needed fuel, food, and basic support 

services, it would need to perform acquisition planning and market 

research under the FAR, as soon as the need is identified.

48

 

48FAR § 7.102. FAR Part 10 describes the policies and procedures for conducting market 

research to determine the most suitable approach to acquiring, distributing, and 

supporting supplies and services. GAO has also reported on important elements of 

successful acquisition planning, such as developing requirements, cost estimating, 

incorporating lessons learned, and allowing sufficient time to conduct acquisition planning. 

See GAO, Acquisition Planning: Opportunities to Build Strong Foundations for Better 

Services Contracts, 

 State 

officials have taken some steps to determine whether independently 

acquiring fuel and food may be a cost-effective procurement alternative to 

DOD-awarded contracts. State officials informed us of plans to award 

their own fuel contract to replace DOD’s contract that expires in 

September 2012. Additionally, in January 2012, State awarded a contract 

for market research on local sources of food, considering factors such as 

quality assurance standards, reliability, and pricing. However, State’s 

current efforts to assess procurement approaches for basic support 

services may not be sufficient to determine whether LOGCAP or a Stateawarded contract is the best approach. According to DOD acquisition 

officials, State would need at least 11 to 12 months of acquisition 

planning to independently acquire basic support services given their 

complexity. State officials have not provided evidence that they are taking

key acquisition planning steps, such as estimating the costs of directly 

acquiring the services or drafting an acquisition plan to identify 

alternatives. Even though DOD’s LOGCAP contract expires in December 

2013, State’s April 2010 request for LOGCAP anticipated using it beyond 

2013 and potentially until 2015. In May 2012 State acquisition officials 

informed us of their intent to transition from LOGCAP to State contracts 

by October 2013; however, they provided no documentation of this

acquisition planning. With respect to security capabilities, DOD has an 

expectation that State will assume contract oversight and sustainment 

support operations for the FIRST maintenance contract in September 

2012, leaving State only months to identify a procurement alternative and 

make a decision. Not only does State have limited time to identify and 

pursue an alternative, but State officials have also acknowledged that 

GAO-11-672 (Washington, D.C.: Aug. 9, 2011).
Page 43 GAO-12-750 Iraq and Afghanistan 

 

DOD’s expertise better positions it to acquire services related to military 

capabilities, such as Sense and Warn. 

For Afghanistan, as the departments prepare to realign their presence to 

meet national security policy objectives, State’s current planning efforts 

similarly may not be sufficient to identify procurement alternatives and 

determine a best procurement approach. State has incorporated some 

knowledge gained through acquiring critical goods and services in Iraq to 

inform planning for Afghanistan. For example, State and DOD officials 

told us they established an Executive Steering Group for Afghanistan 

modeled on the group for Iraq. In addition, State established the 

Management Transition Office in June 2011 to help with transition 

planning in Afghanistan for a post-2014 presence. As part of this office, a

Logistics Support and Services Working Group is expected to determine 

detailed requirements for support areas such as fuel and life support. The 

group will also take on specific tasks, such as developing food service 

contract alternatives that eliminate reliance on DOD contracts. The

Executive Steering Group and State’s working group responsibilities 

represent a key acquisition-planning step—developing requirements. 

However, State has not yet provided evidence that it has taken steps to 

address other key elements of acquisition planning, such as estimating 

the costs of either independently acquiring the goods and services or 

relying on DOD for support. In addition, the description of the working 

group’s membership and activities do not include State’s AQM. As a 

result, State is not formally including key contracting staff responsible for 

determining the best procurement approach as called for in the FAR and 

OMB guidance. 

The Departments of Defense and State faced many challenges in 

completing the transition from a U.S. military to a civilian-led presence in 

Iraq. In particular, planning for the State-led presence in Iraq while 

negotiating for a potential follow-on military force of an unknown size 

placed State and DOD in an uncertain position to make decisions on how 

best to arrange for medical, security, and basic support services and 

associated goods critical to maintaining State’s mission. At the same 

time, both departments were also engaged in carrying out their respective 

missions in Afghanistan. In assisting State with acquisitions to support its 

presence in both Iraq and Afghanistan, DOD leveraged its acquisition 

capacity and expertise to award and manage contracts to meet complex 

requirements in conflict environments. State and DOD officials 

extensively collaborated and took extraordinary measures in some cases 

to ensure that the delivery of critical contracted goods and services were 

Conclusions
Page 44 GAO-12-750 Iraq and Afghanistan 

 

not interrupted to prevent mission failure. However, the way State made 

decisions to request and rely on DOD’s acquisition assistance and how 

the two departments went about implementing those decisions did not 

comply with regulation and guidance. In particular, the departments 

missed opportunities to ensure that sound decisions were made after fully 

considering cost effectiveness and requirements and that agreements for 

the effective management and sufficient oversight of those acquisitions 

were in place. These missed opportunities can be attributed, in part, to an 

outdated State First policy that does not reflect current regulation and 

guidance intended to improve the management of interagency 

acquisitions, as well as efforts by officials under challenging 

circumstances to manage these acquisitions through more informal 

means.

Because the departments did not follow relevant guidance and regulation 

in implementing the interagency acquisitions we reviewed, DOD and 

State now have unresolved positions regarding payment for DOD’s 

assistance. Both departments cited the authority of the Economy Act as 

the mechanism enabling DOD’s assistance, which requires that State pay 

DOD for certain costs incurred in awarding and managing the assisted 

acquisitions on State’s behalf. However, the departments’ positions 

regarding whether State should reimburse DOD for task order award and 

contract management activities in 2010 and 2011 supporting State’s 

current presence in Iraq are unresolved. Without resolution of these 

positions, the departments are at risk of not being in compliance with 

fiscal law. 

How State and DOD made and implemented decisions regarding the 

interagency acquisitions supporting State’s presence in Iraq and 

Afghanistan also has implications for future acquisitions. State is not well 

positioned to make informed decisions as to whether it should continue to 

rely on DOD or independently pursue acquiring critical goods and 

services to maintain its presence in Iraq and Afghanistan. It is important 

for State to determine whether and to what extent interagency 

acquisitions are the appropriate means not only to support its evolving 

presence in Iraq and Afghanistan but also to support the development of 

the expeditionary capacity to address any future conflicts and crises 

around the world called for by State’s Quadrennial Diplomacy and 

Development Review. Such determinations are to be informed by the 

consideration of various factors as to whether interagency acquisitions 

are the best procurement approach to fulfill a specific need. Limitations in 

State’s planning for future basic support services currently provided under 

DOD’s LOGCAP contract increases the risk of repeating the same 
Page 45 GAO-12-750 Iraq and Afghanistan 

 

sequence of events that led State to urgently request DOD’s acquisition 

assistance in April 2010. The Army’s Rock Island Contracting Center is 

now tracking personnel hours expended in the award and management of 

assisted acquisitions on State’s behalf. Use of such information, if 

provided in time, can better inform State’s evaluation of procurement 

approaches for basic support goods and services and security services. 

For State to independently contract for any of the goods and services 

currently provided through DOD contracts to support its presence in Iraq 

and Afghanistan, time is short to plan for how it will proceed after current 

assisted acquisitions end. This planning requires a robust understanding 

of both the support State currently relies on DOD to provide and the 

limitations of State’s own acquisition capacity—including contracting and 

subject matter expertise. Yet State has not taken a number of steps to 

ensure that its acquisition workforce can support future contracting efforts 

in Iraq, Afghanistan, or similar environments, including assessing whether 

its working capital fund is a sufficient mechanism to meet surge 

requirements; it has the proper skill and government/contractor mix in its 

acquisition workforce; and it has sufficient numbers of qualified oversight 

personnel. Both State and DOD currently have an opportunity to assess 

and reach agreement on whether continued reliance is appropriate or 

whether State should develop its own capacity. It is imperative that the 

departments do so now before the lessons from recent experiences are 

lost. Without taking steps to inform those assessments that consider the 

costs and time to build requisite expertise, State risks continued reliance 

on DOD assisted acquisitions by default rather than through sound 

business decisions. 

To ensure that current and future assisted interagency acquisitions in 

support of State’s missions in Iraq and Afghanistan are consistent with 

regulatory requirements and guidance designed to improve the 

management and use of such acquisitions, we recommend that the 

Secretary of State and Secretary of Defense undertake a comprehensive 

review of all existing and proposed assisted interagency acquisitions in 

support of State’s missions in Iraq and Afghanistan to identify and 

implement corrective measures to bring the acquisitions into compliance 

and to strengthen management. Specifically, this should entail

• the Department of State assessing the cost effectiveness and full 

range of requirements, which can be used to inform future best 

procurement approach determinations, 

Recommendations for 

Executive Action
Page 46 GAO-12-750 Iraq and Afghanistan 

 

• the Departments of State and Defense preparing and signing 

interagency acquisition agreements that address the elements 

established in the FAR and OMB guidance, such as roles and 

responsibilities for contract management and oversight, and 

• the Department of State planning for sufficient personnel to perform 

contract oversight.

To better inform future decisions regarding the use of assisted 

interagency acquisitions and to better manage and more consistently 

implement their use, we recommend that the Secretary of State revise the 

State First policy to fully align with current FAR and OMB requirements 

regarding interagency acquisitions. 

To ensure proper payment between the departments in accordance with 

fiscal law, we recommend that the Secretary of Defense and the 

Secretary of State work to jointly resolve their positions with respect to 

payment for DOD’s direct and indirect costs of providing the goods and 

services to State under the interagency acquisitions we reviewed and 

take appropriate action according to their resolution.

To ensure that its acquisition workforce has sufficient capacity to meet the 

need for acquiring critical goods and services for unique and complex 

environments like Iraq and Afghanistan that the Department of State may

choose to independently acquire, we recommend that Secretary of State

• identify, in consultation with DOD, areas of contracting and subject 

matter expertise needed, along with the number of personnel needed, 

to acquire goods and services in such environments; assess the 

extent to which the current acquisition workforce meets those needs; 

and based on the results of that assessment, incorporate efforts to 

build that expertise and personnel numbers into State’s acquisition 

workforce planning and 

• based on those identified needs and resulting workforce planning, 

assess whether the acquisition workforce working capital fund as it 

currently operates is a sufficient mechanism to surge State’s 

acquisition workforce capacity with the appropriate personnel, both in 

terms of expertise and numbers, and mix of government and 

contractor personnel to support State’s missions in such environments 

and evaluate whether changes to the fund or other actions are 

needed.
Page 47 GAO-12-750 Iraq and Afghanistan 

 

We provided a draft of this report to DOD and State for their review and 

comment. Both DOD and State concurred with our recommendations in 

their written comments, which are reproduced in appendix I and appendix 

II respectively. In concurring with our recommendations, State noted it is 

revising its policies to align with current FAR and OMB requirements and 

it has engaged with DOD to ensure proper payment between the 

departments in accordance with fiscal law. State also indicated an 

expectation to use our assessment and a recently initiated State Office of 

Inspector General review to guide its efforts to address our 

recommendation regarding its acquisition workforce. DOD also provided a 

technical comment that was incorporated into the final report. 

We are sending copies of this report to interested congressional 

committees, the Secretary of State, and the Secretary of Defense. In 

addition, the report will be available at no charge on GAO’s website at 

http://www.gao.gov. 

If you or your staff have questions about this report, please contact me at 

(202) 512-4841 or huttonj@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix III. 

John P. Hutton

Director

Acquisition and Sourcing Management

Agency Comments
Page 48 GAO-12-750 Iraq and Afghanistan 

 

List of Committees

The Honorable Carl Levin

Chairman

The Honorable John McCain

Ranking Member

Committee on Armed Services

United States Senate

The Honorable John Kerry

Chairman

The Honorable Richard G. Lugar

Ranking Member

Committee on Foreign Relations

United States Senate

The Honorable Joseph I. Lieberman

Chairman

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Claire McCaskill

Chairman

The Honorable Rob Portman

Ranking Member

Ad Hoc Subcommittee on Contracting Oversight

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Howard P. “Buck” McKeon

Chairman

The Honorable Adam Smith 

Ranking Member

Committee on Armed Services

House of Representatives
Page 49 GAO-12-750 Iraq and Afghanistan 

 

The Honorable Ileana Ros-Lehtinen

Chairman

The Honorable Howard Berman

Ranking Member

Committee on Foreign Affairs 

House of Representatives

The Honorable Darrell E. Issa

Chairman 

The Honorable Elijah E. Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives
Appendix I: Comments from the Department of 

Defense 

 

Page 50 GAO-12-750 Iraq and Afghanistan 

Appendix I: Comments from the Department

of Defense 
Appendix I: Comments from the Department of 

Defense 

 

Page 51 GAO-12-750 Iraq and Afghanistan 
Appendix II: Comments from the Department 

of State

 

Page 52 GAO-12-750 Iraq and Afghanistan 

Appendix II: Comments from the Department 

of State
Appendix II: Comments from the Department 

of State

 

Page 53 GAO-12-750 Iraq and Afghanistan 
Appendix II: Comments from the Department 

of State

 

Page 54 GAO-12-750 Iraq and Afghanistan 
Appendix II: Comments from the Department 

of State

 

Page 55 GAO-12-750 Iraq and Afghanistan 
 

Page 56 GAO-12-750 Iraq and Afghanistan 

John P. Hutton, (202) 512-4841 or huttonj@gao.gov. 

In addition to the contact named above, Johana R. Ayers, Assistant 

Director; Jessica Bull; Carole Coffey; Tara Copp; Thomas Costa; David 

Hancock; Meg Hardy; Kristine Hassinger; Melissa Hermes; Brandon L. 

Hunt; Hynek Kalkus; Gilbert Kim; Claire Li; Felicia M. Lopez; Judith A.

McCloskey; Anne McDonough-Hughes; Lisa McMillen; Christopher 

Mulkins; Kenneth Patton; Jared Sippel; Roxanna T. Sun; Daniel Ramsey; 

Michael Rohrback; Anna Russell; Gwyneth B. Woolwine; and Matthew R. 

Young made key contributions to this report. 

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Acknowledgments
 

Page 57 GAO-12-750 Iraq and Afghanistan 

The following is a list of related products. For a full list of the most recent 

publications related to Iraq and Afghanistan, see 

http://www.gao.gov/docsearch/featured/oif.html. 

Contingency Contracting: Agency Actions Needed to Address 

Recommendations by the Commission on Wartime Contracting in Iraq 

and Afghanistan. GAO-12-854R. Washington, D.C.: August 1, 2012.

Mission Iraq: State and DOD Face Challenges in Finalizing Support and 

Security Capabilities. GAO-12-856T. Washington, D.C.: June 28, 2012. 

Operational Contract Support: Management and Oversight Improvements 

Needed in Afghanistan. GAO-12-290. Washington, D.C.: March 29, 2012.

Afghanistan: Improvements Needed to Strengthen Management of U.S. 

Civilian Presence. GAO-12-285. Washington, D.C.: February 27, 2012.

Iraq Drawdown: Opportunities Exist to Improve Equipment Visibility, 

Contractor Demobilization, and Clarity of Post-2011 DOD Role. 

GAO-11-774. Washington, D.C.: September 16, 2011.

Iraq and Afghanistan: DOD, State, and USAID Cannot Fully Account for 

Contracts, Assistance Instruments, and Associated Personnel. 

GAO-11-886. Washington, D.C.: September 15, 2011. 

Contingency Contracting: Observations on Actions Needed to Address 

Systemic Challenges. GAO-11-580. Washington, D.C.: April 25, 2011. 

Contingency Contracting: Improvements Needed in Management of 

Contractors Supporting Contract and Grant Administration in Iraq and 

Afghanistan. GAO-10-357. Washington, D.C.: April 12, 2010. 

Warfighter Support: DOD Needs to Improve Its Planning for Using 

Contractors to Support Future Military Operation. GAO-10-472. 

Washington, D.C.: March 30, 2010.

Rebuilding Iraq: DOD and State Department Have Improved Oversight 

and Coordination of Private Security Contractors in Iraq, but Further 

Actions Are Needed to Sustain Improvements. GAO-08-966. Washington, 

D.C.: July 31, 2008. 

Interagency Contracting: Need for Improved Information and Policy 

Implementation at the Department of State. GAO-08-578. Washington, 

D.C.: May 8, 2008. 

Related GAO Products 

(120976)
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