GAO-13-251R Defense Contracting 

United States Government Accountability Office

Washington, DC 20548 

February 25, 2013 

Congressional Addressees 

Subject: Defense Contracting: Actions Needed to Explore Additional Opportunities to Gain 

Efficiencies in Acquiring Foreign Language Support 

According to the Department of Defense (DOD), the ability of U.S. military personnel to 

communicate and interact with multinational partners, security forces, and local indigenous 

populations can be critical factors to mission success, as evidenced by operational 

experiences in Afghanistan and Iraq. DOD utilizes language professionals and regional 

experts within its ranks of military personnel to provide foreign language support,1

 such as 

foreign language skills, regional expertise, and cultural awareness capabilities needed to 

execute missions, as well as contracted interpreters and translators who provide this 

support. To meet increased demands on the need for foreign language support from 

ongoing contingency operations, DOD has relied on contactors to supplement the capability 

provided by military personnel. For example, the number of contractor personnel required to 

provide foreign language translation and interpretation services for contingency operations 

more than tripled from 2004 to 2010 (from about 4,000 to about 14,000). As of November 

2012, the number of contractor personnel required by DOD was approximately 9,000. As a 

result, DOD has made considerable investments in providing contract support. For example, 

DOD obligated about $6.8 billion from fiscal years 2008 through 2012 to acquire a variety of 

foreign language-related services and products to support its forces. 

We have identified opportunities for DOD to improve its approach to contracting from a 

broad perspective as well as in areas related to foreign language support. For example, 

DOD contract management is on our list of high-risk areas in the federal government.2

 In 

2013, we noted that DOD needed to take steps to strategically manage the acquisition of 

services, including developing the data needed to define and measure desired outcomes to 

improve outcomes on the billions of dollars that DOD spends annually on goods and 

services.3

 Furthermore, since 2009 we have identified a number of management challenges 

 

1

DOD has not defined “foreign language support” as a specific set of services or products. However, during the 

course of our review officials representing DOD components, which include the military services, combatant 

commands, and defense agencies, identified a range of services and products that are considered “foreign 

language support,” such as translation and interpretation services and the use of personnel with language skills 

to serve as role players during training exercises. Therefore, in this report we use the term “foreign language 

support” to refer to this range of services and products. 

2

GAO’s High Risk Program highlights major areas that are at high risk for waste, fraud, abuse, or 

mismanagement, or are in broad need of reform. 

3

GAO, High-Risk Series: An Update, GAO-13-283, (Washington, D.C.: February 2013). 
Page 2 GAO-13-251R Defense Contracting 

that DOD has faced in developing a strategic planning process to transform foreign 

language and regional proficiency capabilities, identifying training requirements, and 

reducing unnecessary overlap and duplication in foreign language and cultural awareness 

training products acquired by the military services.4

We conducted this work in response to a congressional mandate set forth in Section 21 of 

Public Law 111-139. That legislation requires that we identify government programs, 

agencies, offices, and initiatives with duplicative goals and activities and report our findings 

to Congress. Our objective for this report was to determine the extent to which DOD has 

taken steps to achieve efficiencies in its approach to contracting for foreign language 

support, and whether additional opportunities exist to gain further efficiencies.

For example, in our 2012 annual report 

to Congress highlighting areas in the federal government where duplication, overlap, and 

fragmentation exists, and where programs may be able to achieve greater efficiencies in 

providing government services, we included DOD’s language and culture training programs 

as one of 51 areas in the federal government where greater efficiencies might be achieved. 

In that report, we identified overlapping and potentially duplicative foreign language and 

culture training products that were either developed or contracted for by the military 

services, and found that DOD had limited visibility into the investments it was making in this 

area. On the basis of our work, DOD has taken positive steps to coordinate contracting for 

language and culture training products and collaborate on the development of future 

products that support their use by multiple services. Notwithstanding these efforts, DOD’s 

considerable investment in foreign language support contracts and the challenges we have 

identified in our prior work suggest that additional opportunities may exist for DOD to gain 

efficiencies in its contracting approach for related services and products.

To determine the extent to which DOD has taken steps to achieve efficiencies in its 

approach to contracting for foreign language support, and whether additional opportunities 

exist, we assessed DOD’s management practices in contracting for foreign language 

support in light of DOD guidance that describes the importance of centralizing and 

standardizing the department’s contracting for foreign language support5 and in light of best 

practices established in our prior work on defense contracting and government acquisition.6

 

4

See, for example, GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and Fragmentation, 

Achieve Savings, and Enhance Revenue, 

We also examined the extent of DOD’s contracting activity for foreign language support. 

Specifically, we developed a list of DOD contracts administered between October 2007 

GAO-12-342SP (Washington, D.C.: February 28, 2012); Language 

and Culture Training: Opportunities Exist to Improve Visibility and Sustainment of Knowledge and Skills in Army 

and Marine Corps General Purpose Forces, GAO-12-50 (Washington, D.C.: Oct. 31, 2011); Military Training: 

Actions Needed to Improve Planning and Coordination of Army and Marine Corps Language and Culture 

Training, GAO-11-456 (Washington, D.C.: May 26, 2011); and Military Training: DOD Needs a Strategic Plan 

and Better Inventory and Requirements Data to Guide Development of Language Skills and Regional 

Proficiency, GAO-09-568 (Washington, D.C. June 19, 2009).

5

See Department of Defense, Defense Language Transformation Roadmap, (January 2005) and Department of 

Defense Directive 5160.41E, Defense Language Program, (Oct. 21, 2005, incorporating change 1, 

May 27, 2010).

6

See, for example, GAO, Strategic Sourcing: Improved and Expanded Use Could Save Billions in Annual 

Procurement Costs, GAO 12-919, (Washington, D.C.: Sept. 20, 2012); Best Practices: Using Spend Analysis to 

Help Agencies Take a More Strategic Approach to Procurement, GAO-04-870 (Washington, D.C.: 

Sept. 16, 2004); Best Practices: Improved Knowledge of DOD Service Contracts Could Reveal Significant 

Savings, GAO-03-661, (Washington, D.C.: June 9, 2003); and Standards for Internal Control in the Federal 

Government, GAO/AIMD-00-21.3.1, (Washington, D.C.: November 1999).
Page 3 GAO-13-251R Defense Contracting 

through September 2012 using the Federal Procurement Data System – Next Generation 

database (FPDS-NG). Our list included each purchase order, delivery order, task order, and 

agreement used by DOD to obtain foreign language support services and products. We 

chose the 2008 through 2012 timeframe in order to review contracting trends for foreign 

language support during the most recent 5-year period since DOD announced that an 

executive agent would be appointed to arrange for foreign language support for all 

components. From the contract information collected, we performed a content analysis and 

developed categories to identify the different types of missions and activities that were 

supported with foreign language services and products provided by the contracts. To 

calculate the value of DOD’s contracts, we used the contract obligations and deobligations7

We conducted this performance audit from April 2012 to February 2013 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 objective. A more detailed discussion of our scope and methodology can be found 

in enclosure I.

reported in FPDS-NG and in the contract documents. To address potential data reliability 

issues, we took steps to improve the completeness and accuracy of the data included in our 

analysis. For example, to improve completeness, we verified with DOD officials that the 

contracts we identified from the interpretation and translation services query of the FPDS–

NG database should be included in our analysis and requested that these officials identify 

any missing foreign language support contracts that were not on the list. Moreover, in some 

instances the information in FPDS-NG was incomplete or not comprehensive. To improve 

the accuracy of the data for these contracts, we reviewed the associated contract 

documents contained on DOD’s Electronic Document Access website. We believe the data 

analyzed to be sufficiently reliable for the purposes of this engagement.

Results in Brief

DOD has taken some steps to gain efficiencies in its approach to contracting for certain 

types of foreign language support services and products, but its contracting approach for 

other types remains fragmented across multiple components, and DOD has not explored 

whether additional opportunities exist to gain efficiencies across this broader range of 

contracting activity. In 2005, DOD sought to centralize and standardize contracting efforts 

for foreign language support by designating the Army as an executive agent to manage 

contracting in this area. In performing its responsibilities, the executive agent has focused its 

efforts solely on arranging for contracts to acquire translation and interpretation services for 

contingency operations because of the rapidly increasing requirements for these services. 

Specifically, from fiscal year 2008 through 2012, the Army, as executive agent, obligated 

about $5.2 billion for contracts to provide DOD components with translation and 

interpretation services for contingency operations. During the same time period, we found 

that multiple DOD components contracted independently for foreign language support 

outside of the executive agent’s management. Specifically, to support the needs of 

contingency operations, predeployment training, and day-to-day military activities, we 

identified 159 contracting organizations in 10 different DOD components that obligated 

 

7

“Deobligations” are an agency’s cancellation of previously incurred obligations.
Page 4 GAO-13-251R Defense Contracting 

approximately $1.2 billion on contracts for foreign language support outside of those 

managed by the executive agent. In some cases, DOD has gained efficiencies by 

centralizing contracting for certain foreign language support contracts under an executive 

agent, but DOD has not comprehensively assessed whether additional opportunities exist to 

gain efficiencies across a broader range of foreign language support contracts. Best 

practices for service acquisition suggest that DOD’s acquisition approach should provide for 

an agency-wide view of service contract spending and promote collaboration to leverage 

buying power across multiple organizations. Implementing such an approach requires an 

analysis of where an organization is spending its money, which should be the starting point 

for gaining knowledge that can assist agencies in determining which products and services 

warrant a more coordinated acquisition approach.8

In commenting on a draft of this report, DOD agreed with our recommendations. We discuss 

DOD’s comments later in this report. DOD’s comments are reprinted in enclosure II. DOD 

also provided technical comments on a draft of this report, which we incorporated, where 

appropriate. 

However, DOD has not conducted an 

analysis of this type to evaluate the whole range of services and products that are currently 

managed outside the executive agent and determine whether additional efficiencies could 

be gained. Without a more complete understanding of where the department is spending 

resources on foreign language support contracts, DOD does not have all of the information it 

needs to make informed decisions about the types of services and products that could be 

managed by the executive agent and does not have reasonable assurance that it is fully 

leveraging its buying power for foreign language support. As a result, we are recommending 

that the Secretary of Defense direct the Under Secretary of Defense for Personnel and 

Readiness to conduct an assessment of the department’s current approach for managing 

foreign language support contracts to include an analysis of spending for other types of 

foreign language support services and products that have been acquired by DOD 

components outside of the executive agent and a re-evaluation of the scope of the executive 

agent’s management efforts to determine if any adjustments are needed.

Background

The Office of the Secretary of Defense and the military services have taken a number of 

steps in recent years to transform foreign language, regional expertise, and cultural 

capabilities across the department, recognizing that these are critical capabilities for military 

operations, day-to-day activities, and training. In 2005, for example, DOD updated the 

Defense Language Program directive, highlighting the importance of language proficiency 

and regional expertise to DOD missions.9 In addition, in our prior work, we reported that the 

military services are implementing strategies to build and reinforce language and culture 

knowledge and skills through training at various points of a service member’s career through 

formal service institutions, such as professional military education schools, and during 

predeployment training that is focused on the particular area to which a unit will deploy.10

 

8

This training can include self-directed learning, classroom instruction, and interacting with 

foreign language- and culture-enabled role players. Figure 1 shows examples of the various 

GAO-04-870. 

9

Department of Defense Directive 5160.41E, Defense Language Program. 

10GAO-11-456. 
Page 5 GAO-13-251R Defense Contracting 

types of foreign language support that DOD has acquired through contracts to enhance 

language and culture capabilities of its military forces.

Figure 1: Types of Contract Support to Enhance DOD Foreign Language and Culture Capabilities

DOD Has Taken Some Steps to Gain Efficiencies in the Management of Certain 

Types of Foreign Language Support Contracts but Has Not Fully Explored 

Additional Opportunities

DOD contracts for a broad range of foreign language support services and products and has 

taken some steps to gain efficiencies by centralizing and standardizing the contracting for 

certain types of foreign language-related products and services under an executive agent. 

However, the scope of these efforts has been limited to contracts for translation and 

interpretation services in support of contingency operations. DOD had not comprehensively 

assessed whether additional opportunities exist to gain efficiencies for a broader range of 

foreign language support contracts.

DOD Established an Executive Agent to Achieve Efficiencies in Its Approach to 

Contracting for Foreign Language Support

DOD has taken some steps to centralize and standardize its contracting efforts by 

establishing an executive agent for foreign language support to increase collaboration, 

minimize potential duplication, gain efficiencies, and control spending for related services. In 

its 2005 Defense Language Transformation Roadmap, DOD included a goal to centralize 

and standardize contracting for foreign language support. The roadmap called for the 

appointment of an executive agent to arrange for foreign language support for all DOD 

components, which would include establishing procedures for DOD components to request 

and receive this support on a contract basis. Consistent with the roadmap, the Secretary of 

Defense subsequently designated the Army as the DOD executive agent for foreign 

language support contracts and tasked the Under Secretary of Defense for Personnel and 

Readiness with the responsibility for developing and issuing the appropriate policies for the 

implementation and management of the executive agent.11

 

11Department of Defense Directive 5160.41E, Defense Language Program.

In general, the activities 

conducted by the executive agent include:
Page 6 GAO-13-251R Defense Contracting 

• Providing policy guidance: Developing policies and procedures to guide such things as 

requirements identification and allocation to military commands and counterintelligence 

and security screening of contractors.

• Coordinating with DOD components: Working with defense organizations in identifying 

and filling foreign language support requirements, which includes developing a process 

to rapidly increase the number of contractors to support contingency operations.

• Identifying resources: Developing annual budget requests and securing funding to meet 

the program’s requirements.

• Providing oversight: Establishing management controls over the program to ensure 

adherence to established program procedures, applicable DOD directives, Army 

security regulations and policies, and established memorandums of 

agreement/understanding.

While the executive agent’s responsibility generally extends to all foreign language support 

contracts, under certain circumstances DOD components can contract independently for 

foreign language support. Within Department of Defense Directive 5160.41E, DOD also 

established the following two types of exceptions to the directive’s requirement that 

components use the executive agent to manage foreign language support contracts:

• for “personal services contracts”12

• for direct contracting of language services established by a memorandum of agreement 

between the contracting entity and the executive agent.

established by in-theater personnel, intelligence, 

counterintelligence organizations, and U.S. Special Operations Command in 

accordance with Section 129b of Title 10 of U.S. Code

Two organizations within the Army have key roles and responsibilities related to the 

executive agent’s management of foreign language support contracts.

• The Army Deputy Chief of Staff for Intelligence, G-2, has been delegated the executive 

agent responsibility within the Army. It issues policy, coordinates the validation of 

requirements across DOD stakeholders, secures funding, and provides oversight for 

the executive agent’s contracts. The Deputy Chief of Staff for Intelligence, G-2 also 

grants any exceptions to policy requested by DOD components for the direct 

contracting of language services. This office has delegated contract administration 

responsibilities to the Army Intelligence and Security Command.

• The Army Intelligence and Security Command executes and administers the executive 

agent’s contracts. The scope of the command’s contracts has changed over time. 

Initially, when first assigned its responsibilities, the Army Intelligence and Security 

Command established four geographically based contracts, three for foreign language 

 

12A personal services contract is characterized by the employer-employee relationship it creates between the 

government and the contractor’s personnel. Federal Acquisition Regulation (FAR) § 37.104. These contracts, by 

their express terms or as administered, make the contractor personnel appear to be, in effect, government 

employees. FAR § 2.101. Personal services contracts are generally prohibited; however personal services 

contracts that directly support the mission of a defense intelligence component, counter-intelligence organization, 

or the special operations command of the DOD are authorized by statute. 10 U.S.C § 129b(d).
Page 7 GAO-13-251R Defense Contracting 

support and one contract for exercise support, such as predeployment training. 

However, in 2010, the command developed the Department of Defense Language 

Interpretation and Translation Enterprise contract. According to DOD, this contract is 

intended to provide DOD components with an “enterprise-wide” contract from which 

components can acquire the foreign language support needed to meet ongoing, new, 

and/or changing mission requirements.13

To use the executive agent’s contracts, DOD components submit their foreign language 

support requirements to the Army Deputy Chief of Staff, G-2 who then coordinates the 

validation of the requirements with stakeholders and instructs the Intelligence and Security 

Command to contract for the needed services for the respective DOD component. In their 

request for support from the executive agent, components must generally include the 

number of required contractor personnel by language, necessary clearance level, requisite 

skills (i.e., reading, writing, or speaking), and any gender-specific requirements. When 

assigned a contractor, the requesting components are responsible for ensuring that the 

contractor is provided the same protection, living and working conditions, and are housed 

and fed in the same facilities as the unit they support.

Moreover, according to DOD, the contract 

was designed to be sufficiently flexible and comprehensive to provide for the rapid 

delivery of an affordable capability to meet diverse worldwide foreign language support 

requirements.

DOD’s effort to centralize and standardize contracting for certain types of foreign language 

support under an executive agent has resulted in some efficiencies. For example, executive 

agent officials stated that by establishing an executive agent focused on identifying 

efficiencies in the area of translation and interpretation services in support of contingency 

operations, the executive agent was able to build upon department-wide efforts to improve 

the security clearance process for contractor personnel. Specifically, the executive agent 

identified and addressed the need for a standardized process for submitting paperwork and 

conducting security investigations for potential contract interpreter/translators, which helped 

reduce the amount of time it took to complete the security clearance vetting process from 

about 4 months to 6 weeks.

Executive Agent Manages Contracts for Certain Types of Foreign Language Support 

Services and Products

DOD contracts for a broad range of foreign language support products and services, but the 

executive agent, in performing its responsibilities has generally focused its management 

efforts on contracts that provide foreign language translation and interpretation services for 

contingency operations and not other services and products, such as foreign languageenabled role players. From fiscal year 2008 through fiscal year 2012, DOD obligated about 

$6.8 billion to acquire a variety of related services and products, in order to provide foreign 

language support to its forces. Of this amount, the Army, as executive agent, obligated a 

total of approximately $5.2 billion on contracts it manages to provide the DOD components 

with foreign language translation and interpretation services for contingency operations. 

Figure 2 shows the executive agent’s annual obligations for foreign language support 

 

13“Enterprise-wide” contracts are agency-wide contracts where one component within an agency awards a 

contract for use by all components of that agency. The use of these contracts is intended to reduce contracting 

costs, such as administrative overhead, and leverage the purchasing power of the agency.
Page 8 GAO-13-251R Defense Contracting 

contracts, which ranged from approximately $707 million in fiscal year 2008 to $1.5 billion in 

fiscal year 2010.

Figure 2: Executive Agent’s Annual Obligations for Foreign Language Support Contracts 

(Fiscal Years 2008 through 2012)

During this same time frame, we found that multiple DOD components contracted 

independently for other types of foreign language support outside the executive agent’s 

contracts to support the needs of contingency operations, predeployment training, and dayto-day military activities. For example, DOD components contracted for foreign language 

translation and interpretation services for both contingency and noncontingency operations, 

foreign language- and culture-enabled role players for training exercises, and foreign 

language instruction for military personnel, among other services and products. Specifically, 

we identified 159 contracting organizations in 10 different DOD components that obligated 

approximately $1.2 billion on foreign language support contracts outside of those managed 

by the executive agent.

Table 1 shows the mission type or activity and associated obligations for contracts managed 

by the executive agent and DOD components outside the executive agent.
Page 9 GAO-13-251R Defense Contracting 

Table 1: Obligations for Contracts Managed by the Executive Agent and other DOD Components (Fiscal 

Years 2008 through 2012) 

Contracting 

organization 

Mission type or 

activity Example of contract service or product Obligation

Contracts under executive agent 

Army Intelligence 

and Security 

Commanda

Contingency 

operations 

 Interpretation and translation services for 

deployed units 

$5,248 millionb

Contracts outside executive agent 

23 contracting 

organizations 

Contingency 

operations 

 Interpretation and translations services 

for legal trials 

 Culture subject matter experts 

 Reference material products 

$143.1 million

29 contracting 

organizations 

Predeployment 

training 

 Foreign language and culture enabled 

role players 

 Culture training 

 Language training 

$828.9 million

119 contracting 

organizations 

Day-to-day military 

activities 

 Interpretation and translation services for 

professional conferences and meetings 

 Translation of training course materials 

 Language training as part of professional 

military education 

$75.7 million

Total outside executive agent $1,047.7 millionb

 DOD-wide total $6,295.7 millionc

Source: GAO analysis. 

Notes: The number of contracting organizations managing contracts outside of the executive agent in the table is 171 and not 

the 159 mentioned earlier in the report because several organizations had contracts for more than one type of foreign language 

support service as well as contracts to provide a combination of services. 

a

The Army Deputy Chief of Staff for Intelligence, G-2, has been delegated the executive agent responsibility within the Army. 

This office delegated contract administration responsibilities to the Army Intelligence and Security Command which executes 

and administers the contracts that support the executive agent’s program. 

b

Obligation dollar amounts include some but not all direct costs for foreign language support contracts. For example, according 

to DOD officials, some costs, such as those to provide contractor personnel with lodging and meals are contained in separate 

contracts from those that provide the foreign language support services. 

c

The total obligation amount does not include $394 million in obligations for contracts that the executive agent considered 

excepted from its program by policy or $134 million in obligations for contracts where we were unable to determine the mission 

type from the contract information. 

DOD Has Not Explored Whether Additional Opportunities Exist to Gain Efficiencies 

in Its Contracting Approach for Other Types of Foreign Language Support

Although DOD has centralized its contracting for certain foreign language services under an 

executive agent, it has not taken steps to comprehensively assess whether additional 

opportunities exist to gain efficiencies in the contracting for other types of foreign language 

support products and services. Our prior work has found that the results of an analysis of an 

organization’s spending can be leveraged to institute changes aimed at moving away from a 

fragmented procurement process to a more efficient and effective process.14 Best practices 

in service acquisition suggest that DOD’s acquisition approach should provide for an 

agency-wide view of service contract spending and promote collaboration to leverage 

 

14GAO-04-870. 
Page 10 GAO-13-251R Defense Contracting 

buying power across multiple organizations.15 Implementing such an approach requires an 

analysis of where an organization is spending its money, which should be the starting point 

for gaining knowledge that can assist agencies in determining what products and services 

warrant a more coordinated acquisition approach. For example, we reported that the 

Department of Veterans Affairs has had significant success using analyses of spending on 

an ongoing basis to take a more strategic approach to pharmaceutical procurement and that 

the use of these analyses led to savings of $394 million in fiscal year 2003 alone. More 

recently, we reported that opportunities exist for agencies to realize significant savings 

through the improved and expanded use of such practices, particularly for the acquisition of 

services.16

Notwithstanding the positive benefits of establishing an executive agent, DOD has not taken 

steps to comprehensively assess spending on foreign language support contracts and 

explore whether additional opportunities exist to gain further efficiencies and reduce 

fragmentation across a broader range of services and products. According to officials, 

DOD’s “enterprise-wide” contract (the Department of Defense Language Interpretation and 

Translation Enterprise contract) established by the Army Intelligence and Security 

Command and overseen by the executive agent was intended to provide a broad range of 

foreign language support, including both language and culture services to support worldwide 

operations, training, and day-to-day military activities. However, executive agent officials 

noted that their management efforts have been focused on contracts specifically for foreign 

language translation and interpretation services associated with contingencies because of 

the escalating costs to provide these services for ongoing military operations, and therefore 

they have not looked for additional opportunities, including conducting any kind of analysis 

of spending. These officials agreed that a better understanding of the department’s 

spending on contracts for the whole spectrum of foreign language support could better 

inform areas where the executive agent could focus its management efforts. Because of the 

fragmented approach DOD has taken in contracting for some types of foreign language

support, the department has assumed some risk that it is not maximizing opportunities to 

reduce its contracting costs by leveraging its buying power through more coordinated 

contracting approaches, such as by utilizing the executive agent’s Department of Defense 

Language Interpretation and Translation Enterprise contract.

Specifically, we found that selected agencies leveraged only a fraction of their 

buying power and achieved limited savings. For example, in fiscal year 2011, the 

Departments of Defense, Homeland Security, Energy, and Veterans Affairs, accounted for 

80 percent of the $537 billion in federal procurement spending, but reported strategically 

managing about 5 percent or $25.8 billion through efforts designed to leverage their buying 

power. These agencies reported savings of $1.8 billion—less than 0.5 percent of 

procurement spending. While not all procurement spending may be suitable for a more 

centralized effort, this percentage of managed spending and savings is very low compared 

with the practice of leading companies, which generally strategically manage about 90 

percent of their procurement spending and achieve savings of 10 to 20 percent of total 

procurements annually. Further, we found that agencies, including DOD, reported savings 

between 5 and 20 percent when strategic sourcing contracts were used by implementing 

more coordinated acquisition approaches rather than fragmented contracting.

 

15GAO-03-661. 

16GAO-12-919. 
Page 11 GAO-13-251R Defense Contracting 

Conclusions

Current fiscal pressures and budgetary constraints have heightened the need for agencies 

to take full advantage of coordinated acquisition practices and maximize efficiencies. DOD 

has taken steps to centralize contracting for translation and interpretation services for 

contingency operations, which represent a substantial portion of DOD’s contract obligations 

for foreign language support. However, DOD’s acquisition approach for other types of 

foreign language services and products, such as foreign language-enabled role players, 

remains fragmented across multiple DOD components. The executive agent’s decision to 

focus solely on translation and interpretation services associated with contingency 

operations was based on the escalating costs to provide these services for ongoing 

operations and a recognition that opportunities existed to increase collaboration and gain 

efficiencies in contracting for these services. Yet, DOD has not comprehensively assessed 

whether there are additional opportunities to gain efficiencies, such as by conducting an 

analysis of spending for other types of foreign language support services and products that 

have been acquired by DOD components outside the management of the executive agent. 

Without a more complete understanding of the magnitude of the investment it is making to 

contract for foreign language support, DOD does not have the information it needs to 

determine if there are additional types of services or products that are more appropriately 

managed by the executive agent or reasonable assurance that it is fully leveraging its 

buying power for related services and products.

Recommendations for Executive Action

To improve the department’s ability to make more informed decisions about the future 

direction of the Defense Language Program, we recommend that the Secretary of Defense 

direct the Under Secretary of Defense for Personnel and Readiness to assess its current 

approach for managing foreign language support contracts. At a minimum, such an 

assessment should include

• an analysis of spending for other types of foreign language support services and 

products that have been acquired by DOD components outside the management of the 

executive agent

• a re-evaluation (based on the results of the analysis of spending outside the executive 

agent) of the scope of the executive agent’s management of foreign language support 

contracts to determine whether any adjustments are needed.

Agency Comments and Our Evaluation

In written comments on a draft of this report, DOD agreed with our recommendations and 

stated that the Defense Language and National Security Education Office will lead the 

assessment for the Office of the Under Secretary of Defense for Personnel and Readiness. 

DOD stated the target date for completion of this effort is June 2015. 

In addition to responding to our recommendations, DOD provided general comments on our 

report. First, DOD noted that requirements for foreign language capability are in constant 

flux and that the department is challenged to meet ad hoc and surge requirements, primarily 

because it takes years to develop organic capacity for these capabilities. DOD noted that it 

turns to contractors to help meet these ad hoc and surge requirements. 
Page 12 GAO-13-251R Defense Contracting 

Second, DOD noted that our report employs a broader definition of “foreign language 

support” than understood between the Office of the Secretary of Defense and the Army G-2 

when establishing their contracts for foreign language support under the executive agent 

relationship. DOD noted that under its definition, language training, cultural training, cultural 

advisors, cultural subject matter experts, and cultural role players would not fall under the 

current contract foreign language support executive agent or be subject to the same foreign 

language support contracts. 

We agree with DOD’s characterization of our definition of the term “foreign language 

support”. As stated in our report, DOD has not defined foreign language support as a 

specific set of services and products. Therefore, we used a broader definition to reflect the 

range of services and products that were identified and considered by DOD officials to be 

foreign language support. Our report also reflects DOD’s point that the executive agent 

chose to focus its efforts solely on arranging for contracts to acquire translation and 

interpretation services for contingency operations because of the rapidly increasing 

requirements for these services. We further noted that because there is a significant amount 

of spending for other types of foreign language-related services and products outside of the 

executive agent’s contract, DOD may be able to gain additional efficiencies if it assesses its 

spending across a broader range of foreign language-related contracting activity. We also

recognize that additional foreign language-related services may involve other variables, 

such as different skill sets, which DOD would need to take into account as it reassesses its 

current approach.

DOD’s comments are reprinted in their entirety in enclosure II. DOD also provided technical 

comments, which we incorporated into the report, where appropriate.

We are sending copies of this report to other interested congressional committees, the 

Secretary of Defense, and other interested parties. In addition, the report is available at no 

charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact me at (202) 512-

9619 or pickups@gao.gov. Contact points for our Offices of Congressional Relations and 

Public Affairs may be found on the last page of this report. Key contributors to this report are 

listed in enclosure III.

Sharon L. Pickup 

Director, Defense Capabilities

and Management

Enclosures - 3 
Page 13 GAO-13-251R Defense Contracting 

List of Addressees 

The Honorable Carl Levin

Chairman

The Honorable James Inhofe

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Ron Johnson

Ranking Member

Subcommittee on Financial and 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 14 GAO-13-251R Defense Contracting 

Enclosure I: Scope and Methodology

To address our objective, we drew heavily on our prior work in defense contracting and 

other areas. Specifically, we compared DOD’s current management practices for contracting 

for foreign language support with best practices established in our prior work on defense 

contracting, government acquisition, and standards for internal controls, to examine areas 

where there may be opportunities to gain efficiencies or effectiveness in the management of 

the current contracts.17 We assessed these efforts in light of DOD guidance that describes 

the importance of centralizing and standardizing the Department’s contracting for foreign 

language support.18

We also examined the extent of DOD’s contracting activity for foreign language support. 

Specifically, we developed a list of DOD contracts for foreign language support from 

October 2008 through September 2012 that were included in the Federal Procurement Data 

System – Next Generation database (FPDS-NG). We included all DOD components, 

including the military services and combat support agencies, that had contracted for foreign 

language support services during the review timeframe and each purchase order, delivery 

order, task order, and agreement these components used to obtain foreign language 

support products and services. Although our analysis included contracts that provided both 

foreign language support services and products, the majority of contracts included in our 

analysis were for services. We chose the 2008 through 2012 timeframe in order to review 

contracting trends for foreign language support during the most recent 5-year period since 

the establishment of the DOD executive agent.

We focused our contract searches in FPDS-NG on three of the types of foreign language 

support that were most frequently discussed by DOD officials – translation, interpretation 

and role playing. For the initial query, we used the North American Industry Classification 

System (NAICS) code for translation and interpretation services, which is the standard used 

by federal statistical agencies in classifying business establishments for the purpose of 

collecting, analyzing, and publishing statistical data related to the U.S. business economy. 

After reviewing the initial findings of this data, we observed that the services recorded by 

DOD components varied under the NAICS codes for cultural and language-enabled role 

player contracts. As a result, we again queried FPDS-NG using a “role player” keyword 

search in the “description of requirement” data field to identify additional contracts for role 

players that were not included in our initial query.

 

17GAO, Strategic Sourcing: Improved and Expanded Use Could Save Billions in Annual Procurement Costs, 

GAO 12-919, (Washington, D.C.: Sept. 20, 2012); Best Practices: Using Spend Analysis to Help Agencies Take 

a More Strategic Approach to Procurement, GAO-04-870, (Washington, D.C.: Sept. 16, 2004); Best Practices: 

Improved Knowledge of DOD Service Contracts Could Reveal Significant Savings, GAO-03-661, (Washington, 

D.C.: June 9, 2003) and; Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1, 

(Washington, D.C.: November 1999).

18See Department of Defense, Defense Language Transformation Roadmap, (January 2005), and Department 

of Defense Directive 5160.41E, Defense Language Program.
Page 15 GAO-13-251R Defense Contracting 

We have previously reported that FPDS-NG has had various data reliability issues, such as 

data inaccuracy.19 To address potential data reliability issues, we took steps to improve the 

completeness and accuracy of the data included in our analysis. For example, to improve 

completeness, we verified with DOD officials that the contracts we identified from the 

interpretation and translation services query of the FPDS–NG database should be included 

in our analysis and requested that these officials identify any missing foreign language 

support contracts that were not on the list. In addition, in the case of DOD combat support 

agencies, such as the Defense Intelligence Agency and the National Security Agency, some 

contract information was classified and, as such, information regarding these agencies’ 

contracts was not available in FPDS-NG. For these contracts we met with the relevant 

agency officials and obtained their foreign language support contracts. However, due to the 

lack of a standard definition for “foreign language support” and the fact that various NAICS 

codes were assigned to similar types of services, we were unable to identify the universe of 

foreign language support contracts. Moreover, in some instances the information in FPDSNG was incomplete or not comprehensive. To improve the accuracy of the data for these 

contracts, we reviewed the associated contract documents contained on DOD’s Electronic 

Document Access website. From the contract information collected from FPDS-NG, the 

Electronic Document Access website, and during interviews with agency officials, we 

performed a content analysis and developed categories to identify the different types of 

activities and missions that were supported with foreign language services and products by 

the contracts. To complete the content analysis, two GAO analysts independently reviewed 

the contract information and coded them into separate types of foreign language support 

missions and activities. When the coding was completed, both analysts reviewed every code 

made by the other analyst and indicated whether they agreed or disagreed with the code. 

The analysts then met to discuss their coding determinations and to reach agreement where 

there were any discrepancies. To calculate the value of DOD’s contracts, we used the 

contract obligations reported in FPDS-NG and in the contract documents contained on 

DOD’s Electronic Document Access website and obtained directly from agency officials. In 

some instances, the data found in the contract documents included deobligations, in which 

case, we subtracted the respective amounts from our obligation total.20

We obtained documentation, where appropriate, and interviewed officials at the following 

locations:

We believe the data 

analyzed to be sufficiently reliable for the purposes of this engagement.

Office of the Secretary of Defense

• Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics

• Office of the Under Secretary of Defense for Personnel and Readiness

• Office of the Under Secretary of Defense for Intelligence

 

19GAO, Federal Contracting: Observations on the Government’s Contracting Data Systems, GAO-09-1032T 

(Washington, D.C.: Sept. 29, 2009) and Interagency Contracting: Need for Improved Information and Policy 

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

20“Deobligations” are an agency’s cancellation of previously incurred obligations.
Page 16 GAO-13-251R Defense Contracting 

Department of the Army

• Office of the Assistant Secretary of the Army for Acquisition, Logistics, and 

Technology

• Office of the Deputy Chief of Staff, G2

• Intelligence and Security Command

• 66th Military Intelligence Brigade

• European Cryptologic Center

• United States Army Europe

• 409th Contracting Support Brigade

Department of the Navy

• Marine Corps Office of the Director for Intelligence

• Office of the Deputy Assistant Secretary of the Navy, Acquisition and Procurement

Department of the Air Force

• Secretary of the Air Force, Acquisition and Contracting

• Intelligence, Surveillance, and Reconnaissance Agency

Other DOD Components

• Defense Intelligence Agency

• Defense Security Cooperation Agency

• National Geospatial-Intelligence Agency

• National Security Agency

• U.S. Africa Command

• U.S. Central Command

• U.S. European Command

• U.S. Forces Afghanistan

• U.S. Special Operations Command

Other Federal Government Entities

• General Services Administration

• National Virtual Translation Center

We conducted this performance audit from April 2012 to February 2013 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 objective.
Page 17 GAO-13-251R Defense Contracting 

Enclosure II: Comments from the Department of Defense
Page 18 GAO-13-251R Defense Contracting 
Page 19 GAO-13-251R Defense Contracting 
Page 20 GAO-13-251R Defense Contracting 

Enclosure III: GAO Contact and Staff Acknowledgments

GAO Contact

Sharon L. Pickup, (202) 512-9619 or pickups@gao.gov

Staff Acknowledgments

In addition to the contact named above, Matthew Ullengren, Assistant Director; Shawn 

Arbogast; Richard Burkard; Carolynn Cavanaugh; Carole Coffey; David Hancock; 

Mae Jones; Julia Kennon; Susan Langley; Michael Silver; and John Van Schaik made 

significant contributions to this report.

(351726)
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