CONTINGENCY 

CONTRACTING

State and USAID 

Made Progress 

Assessing and 

Implementing 

Changes, but Further 

Actions Needed

Report to Congressional Committees

February 2014

GAO-14-229

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-229, a report to 

congressional committees

February 2014

CONTINGENCY CONTRACTING

State and USAID Made Progress Assessing and 

Implementing Changes, but Further Actions Needed 

Why GAO Did This Study

For more than a decade, State and 

USAID have used contractors

extensively to help carry out missions 

in contingency operations, such as 

those in Iraq and Afghanistan. While 

State and USAID transition to more 

traditional diplomatic and assistance 

missions in Iraq and Afghanistan, 

contract management and oversight 

challenges remain significant because 

the agencies are likely to be called 

upon again to operate in future 

contingencies. Section 850(a) of the 

Fiscal Year 2013 NDAA directed State 

and USAID to assess their 

organizational structures, policies, and 

workforces related to contract support 

for overseas contingency operations. 

Section 850(c) mandated that GAO

report on the progress State and 

USAID have made in identifying and 

implementing improvements related to 

those areas. GAO analyzed the extent 

to which State and USAID have 

identified and implemented changes to 

their (1) organizational structures and 

policies; and (2) workforces, including 

their use of contractors.

GAO analyzed State and USAID’s 

Section 850 reports to Congress, 

contract policies and procedures, and 

2013 acquisition human capital plans,

and interviewed agency officials. 

What GAO Recommends

GAO recommends that State assess 

whether identified changes achieve 

intended objectives, and that USAID

further assess contingency contracting

related procedures and practices.

State and USAID concurred with the 

recommendations.

What GAO Found

The Department of State (State) and U.S. Agency for International Development 

(USAID) identified a number of changes needed to improve contract support in 

overseas contingency operations, but have not completed implementation efforts.

As required by the Fiscal Year 2013 National Defense Authorization Act (NDAA), 

both agencies determined that their organizational structures were effective, 

though State created a new regional Contract Management Office to better 

support contracting efforts in Iraq. In October 2013, State approved a number of 

actions to improve policies and procedures, including specific initiatives in 

acquisition planning and risk management, among others, and intends to 

institutionalize these changes in its Foreign Affairs Manual in 2014. State 

generally has not, however, developed plans to assess the impact of these 

initiatives. Federal internal control standards highlight the importance of 

managers comparing actual performance to expected results. Accordingly, 

continued management attention is needed to ensure that these efforts achieve 

their intended objectives. USAID focused its efforts on areas such as improving 

contractor performance evaluations and risk management. GAO found that some 

USAID missions and offices that operate in contingency environments have 

developed procedures and practices, but USAID did not consider whether these 

should be institutionalized agency-wide because USAID officials interpreted the 

legislative requirement to include only a review of agency-wide policies. As a 

result, USAID may have missed opportunities to leverage its institutional 

knowledge to better support future contingencies. USAID established a new

working group in October 2013 to develop lessons learned, toolkits, and training

and is expected to complete its efforts in late 2014. This working group could 

further assess the policies and procedures developed by the missions and 

offices, thus potentially affording USAID an opportunity to better leverage its 

institutional knowledge.

State and USAID have increased their acquisition workforce by 53 and 15

percent, respectively, from their 2011 levels and are in various stages of 

assessing their workforce needs for overseas contingency operations. Per Office 

of Management and Budget guidance, both agencies identified competency and 

skill gaps for their acquisition workforce in their 2013 acquisition human capital 

plans. State’s 2013 plan noted that in response to growth in contracting activity in 

areas such as Iraq and Afghanistan, additional acquisition personnel are needed. 

In October 2013, State’s Under Secretary for Management approved the 

formation of a multibureau working group that plans to further explore workforce 

needs for current and future contingency operations. USAID’s 2013 plan cited its

greatest challenge as providing training for its acquisition workforce, as many 

personnel have 5 years or less of contracting experience. USAID established a 

training division in 2013 for its acquisition workforce. State noted in its Section 

850 report that it will increase its focus on conducting risk assessments on the 

reliance, use, and oversight of contractors through the establishment of risk 

management staff. USAID’s Section 850 report did not address reliance on 

contractors, but in October 2013, USAID drafted a revision to its planning policy 

that will require a risk assessment and mitigation plan associated with contractor 

performance of critical functions in overseas contingency operations.

View GAO-14-229. For more information, 

contact Timothy J. DiNapoli at (202) 512-4841

or dinapolit@gao.gov.
Page i GAO-14-229 Contingency Contracting

Letter 1

Background 3

State and USAID Have Efforts Under Way to Address Challenges, 

but Neither Agency Has Fully Implemented Changes for 

Contracting in Overseas Contingency Operations 7

State and USAID Increased Their Acquisition Workforces and 

Continue to Assess Contingency Acquisition Workforce Needs 23

Conclusions 28

Recommendations for Executive Action 29

Agency Comments and Our Evaluation 29

Appendix I Objectives, Scope, and Methodology 33

Appendix II Description of Department of State’s (State) Contracting Organization

for Contingency Operations 36

Appendix III Description of U.S. Agency for International Development’s (USAID) 

Contracting Organization for Contingency Operations 37

Appendix IV Comments from the Department of State 38

Appendix V Comments from the U.S. Agency for International Development 40

Appendix VI GAO Contact and Staff Acknowledgments 42

Tables

Table 1: Status of State’s Actions to Improve Contracting in 

Overseas Contingency Operations 8

Table 2: Status of USAID’s Actions to Improve Contracting in 

Overseas Contingency Operations 17

Contents
Page ii GAO-14-229 Contingency Contracting

Table 3: Comparison of State and USAID Acquisition Personnel, 

Fiscal Years 2011 to 2013 24

Abbreviations

M/OAA Bureau for Management, Office of Acquisition 

and Assistance 

CO contracting officer 

COR contracting officer’s representative 

CPARS Contractor Performance Assessment Reporting System 

DOD Department of Defense 

State Department of State 

FAR Federal Acquisition Regulation 

NDAA National Defense Authorization Act 

OMB Office of Management and Budget 

SPOT Synchronized Predeployment and Operational Tracker

USAID U.S. Agency for International Development 

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 

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necessary if you wish to reproduce this material separately.
Page 1 GAO-14-229 Contingency Contracting

441 G St. N.W.

Washington, DC 20548

February 14, 2014

Congressional Committees

For more than a decade, the Department of State (State) and U.S. 

Agency for International Development (USAID) have used contractors 

extensively to help carry out their missions in contingency operations, 

such as those in Iraq and Afghanistan. From fiscal years 2002 through 

2013, these agencies reported combined obligations of approximately 

$26 billion for contracts with a principal place of performance in either 

country. GAO and others in the accountability community have raised 

issues related to State and USAID’s ability to manage and oversee 

contract support in contingency operations. For example, weaknesses 

have been noted such as limited involvement in acquisition planning, 

collection and reporting of performance evaluations, and overreliance on 

contractors.1 While State and USAID are transitioning to more traditional 

diplomatic and assistance missions in Iraq and Afghanistan, the agencies 

will continue to be called upon to operate in challenging overseas 

environments. For example, State and USAID recently responded to 

instability in South Sudan and Libya. In its 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.2 Within this context, section 

850(a) of the National Defense Authorization Act (NDAA) for Fiscal Year 

2013 directed State and USAID to assess the agencies’ organizational 

structures, policies, and workforces related to contract support for 

overseas contingency operations.3

 1 See for example, GAO, Iraq and Afghanistan: State and DOD Should Ensure 

Interagency Acquisitions Are Effectively Managed and Comply with Fiscal Law, 

GAO-12-750 (Washington, D.C.: Aug. 2, 2012); Commission on Wartime Contracting in 

Iraq and Afghanistan, Transforming Wartime Contracting: Controlling Costs, Reducing 

Risks (Arlington, Va.: Aug. 2011). 

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

the USAID 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).

3 Pub. L. No. 112-239 § 850(a).
Page 2 GAO-14-229 Contingency Contracting

Section 850(c) of the Fiscal Year 2013 NDAA mandated that we report on

the progress State and USAID have made in identifying and implementing 

improvements in those areas.4

To determine the extent to which State and USAID identified and 

implemented changes related to their organizational structures, policies, 

and workforces, we reviewed the reports State and USAID submitted to 

Congress in response to Section 850(a) and other agency documents, 

including draft charters of related working groups, and agency-wide and 

mission-specific contracting policies and guidance. We also reviewed 

State and USAID’s March 2013 acquisition human capital plans, which 

included data on the composition of State and USAID’s acquisition 

workforces from fiscal years 2011 to 2013. We collected updated data on 

State and USAID’s acquisition workforces as of November 2013. We 

used this information to describe characteristics of each agency’s 

acquisition workforce and, as such, did not assess the reliability of the 

data. Further, we compared the areas identified by State and USAID as 

needing changes with challenges previously identified by GAO and others 

in the accountability community to determine the extent to which the 

agencies are addressing these challenges. We also interviewed officials 

at State and USAID in the United States and Afghanistan with related 

program, acquisition, or workforce planning responsibilities to discuss the 

process for identifying changes and the implementation status of 

identified changes.

This report analyzes the extent to which 

State and USAID have identified and implemented changes to the 

agencies’ (1) organizational structures and policies, and (2) workforces, 

including their use of contractors, relative to contingency operations.

We conducted this performance audit from March 2013 to February 2014 

in accordance with generally accepted government auditing standards. 

These 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. See Appendix I for a more 

complete description of our scope and methodology.

 4 Pub. L. No. 112-239 § 850(c).
Page 3 GAO-14-229 Contingency Contracting

Contingency operations can encompass a number of potentially 

dangerous or uncertain environments, which increase risks to federal 

agencies and personnel, including contractors that support those 

agencies. The U.S. Code defines a contingency operation, in relevant 

part, as a military operation designated by the Secretary of Defense in 

which armed forces are or may become involved in military actions, 

operations, or hostilities against an enemy of the United States or results 

in the call to active duty members of the uniformed services, such as in 

Iraq and Afghanistan.5

USAID officials noted that its personnel operate in challenging 

environments on a daily basis and that the agency uses various terms to 

describe these environments. For example, USAID’s programming policy 

defines high-threat environment as a country, city, area, subregion, or 

region in which USAID is hindered in accomplishing its mission due to 

security risks such as (1) specific targeting of U.S. interests, (2) a 

favorable operating environment for terrorist groups, (3) intelligence 

indicating that a threat is imminent, or (4) other significant risk as 

identified by various security offices.

However, there are other environments that do not 

fall within this definition but potentially pose similar challenges.

6

State operates in similar environments. For example, in its 2010 

Quadrennial Diplomacy and Development Review, State noted that more 

than 25 percent of State and USAID personnel serve in 30 countries 

classified as high risk for conflict and instability, including Yemen, 

Democratic Republic of Congo, Sudan, and Kyrgyzstan. For the purposes 

of this report, we use the term “contingency operations” to encompass the 

range of potentially dangerous or uncertain environments in which USAID 

and State operate.

 5 10 U.S.C. § 101(a)(13). 

6 USAID officials have also developed a working definition of nonpermissive 

environment—any environment in which USAID operates where security concerns are 

elevated or its ability to implement or monitor programs is limited. In addition, a fiscal year 

2012 memorandum from the USAID Inspector General on the most serious management 

and performance challenges for the agency defines critical priority countries as countries 

in which the agency carries out its most challenging assignments. These countries are 

characterized by instability, insecurity, weak governance, and poor control of corruption, 

and according to USAID officials currently include Afghanistan, Iraq, Pakistan, South 

Sudan, and Yemen. 

Background
Page 4 GAO-14-229 Contingency Contracting

Our work over the past 5 years, as well as that of others in the 

accountability community, has found that State and USAID have 

experienced systemic challenges that have hindered their ability to 

manage and oversee contracts in contingency environments. In our 

reports issued annually between 2008 and 2011, we consistently found 

that State and USAID lacked reliable data and systems to report on their 

contracts and contractor personnel in Iraq and Afghanistan.7 Having 

reliable data on contracts and contractor personnel is a starting point for 

informing agency decisions and ensuring proper management. In 2012, 

we reported that the agencies had made improvements to their contractor 

personnel data and related systems that could result in more reliable 

data, but data comparability across years and agencies was limited.8 We 

also reported in 2012 that State had not assessed the skills and 

workforce mix needed to meet future contracting requirements in Iraq and 

Afghanistan. Further, we found that State had insufficient personnel with 

the necessary expertise to conduct acquisition planning and oversight 

functions to support the department’s mission in Iraq, and, as a result, 

relied on the Department of Defense (DOD) for acquisition support.9 We 

also found weaknesses in USAID’s oversight and monitoring of project 

and program performance in Afghanistan. Specifically, we reported that 

USAID did not consistently follow its established performance 

management and evaluation procedures for Afghanistan agriculture and 

water projects.10

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

Contracts, Assistance Instruments, and Associated Personnel, 

USAID subsequently issued new guidance, approved a 

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).

8 GAO, Iraq and Afghanistan: Agencies Are Taking Steps to Improve Data on Contracting 

but Need to Standardize Reporting, GAO-12-977R (Washington, D.C.: Sept. 12, 2012).

9 GAO-12-750.

10 GAO, Afghanistan Development: Enhancements to Performance Management and 

Evaluation Efforts Could Improve USAID’s Agricultural Programs, GAO-10-368

(Washington, D.C.: July 14, 2010); and Afghanistan Development: U.S. Efforts to Support 

Afghan Water Sector Increasing, but Improvements Needed in Planning and Coordination, 

GAO-11-138 (Washington, D.C.: Nov. 15, 2010).
Page 5 GAO-14-229 Contingency Contracting

new performance management plan, and took steps to improve its thirdparty monitoring of projects.

Similarly, others in the accountability community have reported on the 

acquisition challenges faced by State and USAID in contingency 

environments. For example, Inspectors General at both agencies 

identified aspects of contracting in contingency environments as a serious 

management challenge in the agencies’ fiscal year 2012 financial reports. 

State’s Inspector General found that the department continued to face 

challenges managing contracts and procurements, and reported that it 

has identified instances in Iraq and Pakistan in which poor contract 

monitoring resulted in increased costs and poor performance.11 Similarly, 

USAID’s Inspector General identified USAID’s work in high-threat 

environments such as Afghanistan, Pakistan, Iraq, and South Sudan, as 

one of the agency’s most serious management challenges, in part due to 

audits that disclosed weak contract management in these environments.12

In addition, the Special Inspector General for Iraq Reconstruction and the 

Special Inspector General for Afghanistan Reconstruction have reported 

on similar contracting issues. Further, the statutorily established 

Commission on Wartime Contracting in Iraq and Afghanistan made a 

number of recommendations directed to State and USAID in its final 

report, issued in 2011.13

Section 850(a) of the fiscal year 2013 NDAA mandated that State and 

USAID submit, to the appropriate Congressional committees,

assessments of agency policies governing contract support in overseas 

Recommendations include those related to using 

risk factors to decide what functions are appropriate to contract for in 

contingency settings, ensuring the government can provide sufficient 

acquisition management and contractor oversight, and taking actions to 

mitigate the threat of additional waste due to a lack of sustainment by 

host governments.

 11 Department of State, Fiscal Year 2012 Agency Financial Report (Washington, D.C.: 

Nov. 2012).

12 USAID Office of the Inspector General, Most Serious Management and Performance 

Challenges for the U.S. Agency for International Development (Washington, D.C.: Oct.

2012).

13 Commission on Wartime Contracting in Iraq and Afghanistan, Transforming Wartime 

Contracting: Controlling Costs, Reducing Risks (Arlington, Va.: Aug. 2011).
Page 6 GAO-14-229 Contingency Contracting

contingency operations.14

1. Describe and assess the roles and responsibilities of officials and 

offices with contract-related responsibilities in overseas contingency 

operations;

Section 850(a) required State and USAID to 

submit their reports to Congress by July 2, 2013. Section 850(b) of the 

NDAA provided that the reports

15

2. Include procedures and processes associated with eight elements of 

contracting, including collection, inventory, and reporting of data; 

acquisition planning; solicitation and award of contracts; requirements 

development and management; contract tracking and oversight; 

performance evaluations; risk management; and interagency 

coordination and transition planning; and

3. Include strategies and improvements necessary to address workforce 

issues in overseas contingencies, including reliance on contractors.

State and USAID submitted their reports to Congress on June 25 and 

July 1, 2013, respectively.

 14 State and USAID were required to provide their assessments to the Committee on 

Foreign Relations, the Committee on Armed Services, the Committee on Homeland 

Security and Governmental Affairs, and the Committee on Appropriations of the Senate; 

and the Committee on Foreign Affairs, the Committee on Armed Services, the Committee 

on Oversight and Government Reform, and the Committee on Appropriations of the 

House of Representatives.

15 For the purposes of this report, we used the term organizational structure to capture 

State and USAID descriptions and assessments of officials and offices with contracting 

responsibilities in contingency operations. 
Page 7 GAO-14-229 Contingency Contracting

State and USAID identified a number of actions needed to improve 

contracting in contingency environments. Overall, the actions identified by 

State and USAID may help position each agency to better support future 

contingency operations, but many of the identified changes are new or 

have not been fully implemented and the agencies generally have not 

established plans to assess the impact of the changes. Federal internal 

control standards highlight the importance of managers comparing actual 

performance to expected results. For example, in October 2013, State’s 

Under Secretary for Management approved a series of actions, which 

included changing the organizational structure by establishing a new staff 

unit to oversee elements of contracting in overseas contingency 

operations, a new contract risk mitigation effort, and the creation of 

specific contingency contracting policy in its Foreign Affairs Manual. In 

some instances, such as establishing the new risk mitigation staff, State 

intends to assess the impact of the initiatives. According to State officials, 

they are still developing specific plans and time frames to implement 

several other initiatives. We found that State has not indicated whether or 

how it intends to assess the impact of these other initiatives. Continued 

management attention is needed to ensure that these efforts achieve their 

intended objectives. 

USAID identified several actions needed to improve areas such as the 

collection, inventory, and reporting of data; contractor performance 

evaluations; and risk management. In response to long-standing 

challenges that the agency faces in implementing and monitoring 

activities in high-threat environments, USAID established a 

nonpermissive environment working group in October 2013 to develop 

lessons learned, toolkits, and training, but it is not expected to complete 

this effort until the end of September 2014. We found that USAID 

missions and offices with responsibilities for responding to contingencies 

have established procedures and practices, but USAID did not consider 

whether these procedures should be institutionalized agency-wide. 

USAID officials explained that they took a narrow view of the mandate 

and focused their assessment on agency-wide policies. As a result, 

USAID may have missed opportunities to leverage its institutional 

knowledge to better support future contingencies.

State’s Section 850 report to Congress concluded that its organizational 

structure was generally adequate to support overseas contingency 

operations and identified several actions needed to improve areas such 

as acquisition planning, contract oversight, and interagency coordination 

(see table 1). In addition, our review identified other contingency 

State and USAID 

Have Efforts Under 

Way to Address 

Challenges, but 

Neither Agency Has 

Fully Implemented 

Changes for 

Contracting in 

Overseas 

Contingency 

Operations

State Is in the Early 

Stages of Implementing 

Changes Needed
Page 8 GAO-14-229 Contingency Contracting

contracting related actions taken by State, including those identified after 

State submitted its report to Congress.

Table 1: Status of State’s Actions to Improve Contracting in Overseas Contingency Operations

Section 850 elements 

pertaining to organizational 

structure and policy Action description Status

Organizational structure Establish a regional Contract Management 

Office to support efforts in Iraq

Ongoing. The office is currently located in Iraq, 

but will move to Kuwait in mid-2014.

Collection, inventory and 

reporting of data

Additional guidance was issued in 2012.

New regional Contract Management Office will 

be responsible for overseeing contractors’ input 

to data system for Iraq. 

Completed

Ongoing

Solicitation and award State noted that its current approach to soliciting 

and awarding contingency contracts was 

sufficient. 

Not applicable

Requirements development and 

acquisition planning

Establish support cells for opening or reopening 

a post at the start of a potential contingency 

Standard operating procedures were issued in 

May 2013. In 2013, first support cell was 

established for a potential contingency in Syria. 

Contract oversight Revised contracting officer’s representative 

(COR) training

Completed

Reinstituted a COR Council to collect COR data 

and improve effectiveness of the COR function

Completed March 2013

Proposed revision to the Foreign Affairs Manual 

related to training requirements of the COR

Currently under internal review. State expects to 

finalize the update in 2014.

Revised training and issued standards of 

conduct for private security contractors

Completed

Draft update to the Foreign Affairs Manual 

regarding roles and responsibilities of private 

security contractors

Expected to be approved in 2014

Performance evaluations Improve State’s use of government-wide 

contractor performance system

Ongoing

Risk management Establish permanent risk assessment and 

mitigation staff

Conduct contractor vetting pilot program

Established in December 2013, with staffing and 

recruitment actions underway

Ongoing, completion date to be determined.

Interagency coordination and 

transition planning

Continue coordination for Afghanistan through 

the executive steering group and management 

transition office

Ongoing

State is working with DOD to enhance a 

database on interagency agreements.

Ongoing

Source: GAO analysis of State’s Section 850 report to Congress, and State data.
Page 9 GAO-14-229 Contingency Contracting

To identify needed changes, State established working groups comprised 

of key officials from offices across the department to assess State’s 

organizational structure and contracting procedures in overseas 

contingency operations. In October 2013, State’s Under Secretary for 

Management approved a series of recommendations proposed by the 

working groups, which included establishing a new staff unit to oversee 

elements of contracting in overseas contingency operations and other 

critical environments, as well as the creation of a specific contingency 

contracting chapter in the Foreign Affairs Manual, which contains the 

organizational responsibilities and authorities of each of the major 

components of the department. According to State officials, they are still 

developing specific plans and time frames to implement many of the 

changes approved in October, but generally have not developed plans to 

assess the impact of these initiatives. State officials subsequently 

reported that the Critical Environment Contract Analytics Staff, which was 

formally established in December 2013, will be responsible for using 

metrics to assess the effectiveness and performance of State’s planned 

initiatives.

State determined that its centralized organizational structure was 

generally effective and efficient for contract support in overseas 

contingency operations. To improve management and oversight of 

contract performance of major contracts in Iraq, State established a new 

regional Contract Management Office in August 2013. State plans to 

review the effectiveness of the Contract Management Office after it has 

been operational for 1 year to determine gaps and applicability as a 

department-wide model for contracting in future contingency 

environments. State officials noted that the office, currently located in 

Iraq, will move to Kuwait in mid-2014 to allow for administrative support 

for other contracts in the region as resources are available. Appendix II 

describes the roles and responsibilities of State’s contracting organization 

used to support contingency operations.

With regard to tracking of contractors and contractor personnel, State has 

previously taken steps to improve the collection, inventory, and reporting 

of contractor and contractor personnel data within DOD’s Synchronized 

Predeployment and Operational Tracker (SPOT) database for overseas 

contingency operations. In 2008, Congress required DOD, State, and 

Organizational Structure

Data Collection, Inventory, 

and Reporting
Page 10 GAO-14-229 Contingency Contracting

USAID to begin tracking use of contractors in Iraq and Afghanistan.16 To 

do so, the agencies agreed to use DOD’s SPOT database. To implement 

this requirement, State issued a procurement information bulletin in 

March 2008, which directed State contracting officers (CO) to designate 

the use of SPOT for all applicable contracts in Iraq and Afghanistan and 

include a clause requiring contractors to provide certain data within 

SPOT.17 However, we consistently found in reports issued annually since 

2008 that State lacked reliable sources and methods to report on its 

contracts and contractor personnel in Iraq and Afghanistan.18 According 

to State officials, to improve State’s reporting, the Office of Acquisitions 

Management developed additional guidance in fall 2012 which outlined 

the process of inputting contracts, how contractors should enter 

contractor personnel, how to request letters of authorization and 

approvals,19

State’s Section 850 report noted that the use of a centralized acquisition 

office in Washington D.C., and two regional procurement support offices 

help solicit and award contingency contracts. State officials noted that 

approximately 90 percent of its acquisition dollars and all major programs 

are managed by either its Office of Acquisitions Management or its two 

regional procurement support offices in Florida and Germany. Further, it 

noted that contracts for contingency operations in Iraq and Afghanistan 

are managed by its Office of Acquisitions Management. At individual 

missions and posts, State’s general services officers have contracting 

authority limited to noncomplex transactions below $250,000. State noted 

that this approach provided sufficient support in terms of soliciting and 

awarding contracts.

and how to enter data through contract close-out. The new 

regional Contract Management Office will be responsible for overseeing 

contractors’ input of Iraq contractors’ data into SPOT.

 16 The National Defense Authorization Act for Fiscal Year 2008. Pub. L. No. 110-181, § 

861 (as amended). 

17 Department of State, Office of the Procurement Executive, Procurement Information 

Bulletin No. 2008-15.

18 GAO-12-977R; GAO-11-1; GAO-10-1; GAO-09-19.

19 A letter of authorization is a document issued by a government contracting officer or 

designee that authorizes contractor personnel to travel to, from, and within a designated 

area and to identify any additional authorizations, privileges, or government support the 

contractor is entitled to under the contract.

Solicitation and Award 

of Contracts
Page 11 GAO-14-229 Contingency Contracting

State’s Section 850 report noted that contract requirements were 

generally developed either at State’s in-country posts or its functional 

bureaus, and stated that its requirements development process was 

adequate. To improve acquisition planning, State developed a draft 

update to the Foreign Affairs Manual that explains that acquisition 

planning for contingency operations requires special attention and has 

designated staff to facilitate planning in contingency environments. In 

addition, State issued standard operating procedures in May 2013 for 

support cells that will be coordinated on an as-needed basis at the start of 

a contingency. The support cell will assist in the opening or reopening of 

posts based on lessons learned and will be located within the regional 

bureau. The support cell process was incorporated into the Foreign 

Affairs Manual and includes a typical support cell organization chart, a 

work process map documenting the steps that determine a situational 

plan of action, and a checklist document that can be used when creating 

an operational plan to open or reopen a post.20

To carry out contract oversight, State generally relies on contracting 

officer’s representatives (COR) appointed from programs within the 

department’s regional and functional bureaus to help ensure that the 

contractor accomplishes the required work. State’s Section 850 report 

noted, however, that State lacks CORs with certain technical subject 

matter expertise for contingency operations, such as medical and 

aviation. Additionally, State officials noted the need to improve training for 

CORs and cited several actions the department has taken to do so. For 

example, according to State officials, the department has revised COR 

training to be more scenario-based and initiated an effort to better 

manage the COR function across the department due to the growth in the 

number of CORs in areas such as Afghanistan and Pakistan. In March 

2013, State reinstituted a COR council to collect agency COR data and to 

develop plans and actions that improve the effectiveness of the COR 

function. State officials told us that they intend to use the Federal 

Acquisition Institute Training Application System to track COR 

certifications and allow COs and bureaus to identify qualified CORs when 

needed. In October 2013, State proposed a revision to the Foreign Affairs 

According to State 

officials, the new procedures were used in 2013 to establish a support cell 

for a potential contingency in Syria.

 20 U.S. Department of State Foreign Affairs Manual, Volume 2, Part 423, Opening or 

Reopening a Critical Threat or High Risk, High Threat Post. 

Requirements Development 

and Acquisition Planning

Contract Oversight
Page 12 GAO-14-229 Contingency Contracting

Manual that would assign responsibility to the individual bureaus to define 

specialized training or experience requirements for CORs to ensure 

effective contract oversight. State reported that staffing the newly 

established regional Contract Management Office in Iraq with specific 

technical skills and identifying individuals with previous COR experience 

represents a continuing challenge that they will try to address through 

training and mentoring, among other things.

In prior reports, we found that State had taken actions to address the 

challenges it encountered in overseeing private security contractors in 

Iraq.21

State’s Section 850 report noted that reporting contractor performance 

evaluations in the government-wide Contractor Performance Assessment 

Reporting System (CPARS) needed improvement. The Federal

Acquisition Regulation (FAR) requires agencies to prepare an evaluation 

of contractor performance for each contract that exceeds the simplified 

acquisition threshold at the time the work is completed and gives 

agencies discretion to include interim evaluations for contracts with a 

In July 2013, the Under Secretary for Management testified that 

private security contractors are critical to State’s readiness and capability 

to carry out U.S. foreign policy under dangerous and uncertain security 

conditions. The Under Secretary emphasized that maintaining this 

capability is particularly important when the department is taking on 

expanding missions in contingency operations or areas that are 

transitioning from periods of intense conflict, such as in Iraq and 

Afghanistan. State officials noted that the department continues to 

improve its program for private security contractors in contingency 

operations. For example, the department revised its training requirements 

and issued contractor standards of conduct to ensure the professionalism 

of private security contractors. In addition, State’s draft update to the 

Foreign Affairs Manual outlines the roles and responsibilities and training 

standards of private security contractors. Officials expect revisions to the 

Foreign Affairs Manual will be approved in 2014.

 21 GAO-12-750 and GAO, 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). 

Performance Evaluations
Page 13 GAO-14-229 Contingency Contracting

performance period exceeding 1 year.22 To do so, State has started 

several initiatives, including more dedicated staff time to manage 

reporting, monthly meetings held by the Office of Acquisitions 

Management and the Office of the Procurement Executive to track 

reporting progress, and increased training on past performance reporting 

and evaluations. Further, the Office of the Procurement Executive is 

working with the human resources division to incorporate work elements 

into CORs’ performance appraisals. State officials indicated that they 

have established a goal that contractor past performance reporting will be 

at a 45-percent completion rate by December 31, 2013.23

In December 2013, State established the Critical Environment Contract 

Analytics Staff to centrally coordinate and perform, among other things, 

contract risk assessments and mitigation plans. As outlined in the 

October 2013 action memorandum, this group will be responsible for 

coordinating with other U.S. government agencies and monitoring 

contracting readiness in critical environments. The group also will be 

expected to expand the contract risk assessments in Afghanistan and 

other high-threat, high-risk posts, such as locations with major 

multibureau contracts. According to State officials, the Critical 

Environment Contract Analytics Staff will be comprised of three 

individuals and as of January 2014, staffing and recruitment efforts were 

underway.

State also 

intends to incorporate a requirement within its Foreign Affairs Manual for 

State personnel to conduct contractor program reviews of contracts over 

$25 million for contingency operations at least semi-annually, and 

document them in the government-wide database.

In 2011, we found that State had not developed a process to vet 

contractor firms in Afghanistan and recommended that State assess the 

need to vet non-U.S. vendors to ensure that resources are not diverted to 

 22 FAR § 42.1502. The FAR defines the simplified acquisition threshold as $150,000, 

except for acquisitions of supplies or services that, as determined by the head of the 

agency, are to be used to support a contingency operation or to facilitate defense against 

or recovery from nuclear, biological, chemical, or radiological attack, the term means —(1) 

$300,000 for any contract to be awarded and performed, or purchase to be made, inside 

the United States; and (2) $1 million for any contract to be awarded and performed, or 

purchase to be made, outside the United States.

23 This target is consistent with Office of Management and Budget (OMB) March 2013 

guidance on improving the collection and use of information about contractor performance 

and integrity.

Risk Management
Page 14 GAO-14-229 Contingency Contracting

insurgent or criminal groups.24

State’s Section 850 report noted that interagency coordination was an 

area that needed improvement. In September 2010, DOD and State 

established an Executive Steering Group, co-chaired by the DOD’s 

Deputy Assistant Secretary for Program Support and State’s Deputy 

Assistant Secretary for Logistics Management, to help State identify 

critical requirements in Iraq for which it had previously relied on DOD and 

address other issues associated with the transition. State reported that ad 

hoc working groups, such as the Executive Steering Group, provide 

timely coordination on specific implementation issues in contingency 

environments. In addition, officials told us in September 2013 that the Iraq 

contract transition working group continued to host biweekly meetings 

between State and DOD to address requirements and post-transition 

activity in Iraq.

In response, State launched a pilot 

program in October 2012 to vet contractors and grantees for links to 

terrorists or their supporters. The pilot was designed to assess risk and 

test the utility of vetting across the range of department operations and 

risk profiles. The department works in tandem with regional posts and 

USAID on the current pilot program, which includes Lebanon, Guatemala, 

Kenya, Ukraine, and the Philippines. In addition to these countries, 

Afghanistan and Syria have been included to reflect vetting in high-risk 

countries. The pilot was scheduled to be completed in October 2013, but 

State officials stated that it will be extended and that the completion date 

has not been determined. State noted that as of August 2013, preliminary 

results suggest that the effectiveness of vetting is related to the 

prevalence of conflict, but that few data are available from the five pilot 

countries due to the limited number of contracts and grants in those 

countries.

An Executive Steering Group modeled after the group in Iraq was also 

established for Afghanistan in May 2011. In addition, State established 

the Management Transition Office in Kabul in June 2011 to help with the 

transition planning in Afghanistan for a post-2014 presence. State officials 

have noted that they are less dependent on DOD for services in 

Afghanistan, but they are taking lessons learned from Iraq and 

implementing them as appropriate. According to State officials, no 

 24 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Needs Improvement, 

GAO-11-355 (Washington D.C.: June 8, 2011). 

Interagency Coordination 

and Transition Planning
Page 15 GAO-14-229 Contingency Contracting

agreements have been finalized on requirements for the post-2014 

presence as they are waiting for drawdown and security plans to be 

finalized. In addition to the groups already established in Iraq and 

Afghanistan, State reported that it will coordinate with other agencies at 

the outset of future contingencies to define which working groups should 

be initiated. In addition, the newly approved contract risk assessment and 

mitigation staff described above will act as the coordinator for interagency 

acquisition agreements during contingency operations.

The FAR requires, among other things, that agencies carefully consider 

whether an interagency acquisition is based on a sound business 

decision and formally document the terms and conditions in an 

interagency agreement.25 In August 2012, we found that State and DOD 

did not comply with requirements for use and management of assisted 

interagency acquisitions. To respond to recommendations we made in 

this 2012 report, State officials indicated that the department is working 

with DOD to enhance a database used to store information on joint 

interagency agreements. For any existing interagency agreements, the 

department continues to work with DOD to identify where any required 

justifications are not already existent and rectify them in accordance with 

FAR requirements.26 Additionally, in response to previous 

recommendations, State issued a procurement information bulletin in 

January 2013 defining the process and requiring the use of interagency 

agreements.27 We also previously found that interagency coordination in 

Iraq began late, which caused State to have limited insights into its use of 

interagency acquisitions and hindered contract oversight.28

 25 FAR § 17.502 and OMB, Office of Federal Procurement Policy, Improving the 

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

State officials 

told us that they want to focus on longer-term continuity by 

institutionalizing interagency agreements before determining how they 

would handle interagency coordination and transition planning for future 

contingencies.

26 GAO-12-750.

27 Department of State, Procurement Information Bulletin No. 2013-03, Subject: 

Acquisition Agreements. 

28 GAO-11-774; GAO-08-578.
Page 16 GAO-14-229 Contingency Contracting

State intends to assess the impact of some initiatives, such as 

establishing the regional Contract Management Office and the contractor 

vetting pilot program. According to State officials, they are still developing 

specific plans and time frames to implement many of the changes 

discussed above. We found that State has not indicated whether or how it 

intends to assess the impact of some initiatives. For example, as outlined 

in the October 2013 action memorandum, State plans to establish a new 

staff to centrally coordinate and assist in managing contract risk 

assessments and mitigation plans but has not yet determined how to 

assess the impact of the office. Federal Internal Control Standards 

highlight the importance of reviews by management at the functional level 

to compare actual performance to planned or expected results and 

analyze significant differences.29 Accordingly, without management 

reviews to assess planned and actual performance, State may not be 

able to determine whether these initiatives better enable it to support 

future contingency operations. State officials subsequently reported that 

the Critical Environment Contract Analytics Staff will be responsible for 

assessing the effectiveness and performance of the planned initiatives.

USAID concluded that its organizational structure was adequate to 

support contingency contracting efforts, but identified several actions 

needed to improve areas such as collection, inventory, and reporting of 

data; contractor performance evaluations; and risk management (see 

table 2). Our review also identified other contingency contracting-related 

actions taken by USAID that were not included in its report to Congress or 

were identified after USAID submitted its report to Congress.

 29 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington D.C.: November 1999).

USAID Has Identified and 

Implemented Changes, 

but May Have Missed 

Opportunities to Leverage 

Its Institutional Knowledge
Page 17 GAO-14-229 Contingency Contracting

Table 2: Status of USAID’s Actions to Improve Contracting in Overseas Contingency Operations

Section 850 elements 

pertaining to organizational 

structure and policy Action description Status

Organizational structure No actions identified Not applicable

Collection, inventory, and 

reporting of data

Develop proposal to limit SPOT use solely as a 

tool to track contractor personnel 

To be determined

Solicitation and award Deploy contracting writing system worldwide to 

allow personnel to write, manage, oversee, and 

report on USAID awards from any location.

Completed fall 2011

Requirements development and 

acquisition planning

Finalize acquisition planning policy Completed in April 2013. 

Contract oversight Individual USAID missions establish operational 

procedures as necessary for contracting, such 

as monitoring programs in remote areas of 

Afghanistan and Pakistan. For example, USAID 

in Afghanistan introduced monitoring methods to 

verify project performance, including third-party 

monitors, among other methods.

Establish as needed

Performance evaluations Improve reporting of contractor performance 

evaluations in CPARS

Ongoing

Risk management Revise acquisition planning policy to incorporate 

risk assessment requirement for using 

contractor support in overseas contingency 

operations

Ongoing. Agency officials expect that the policy 

will be finalized in January 2014.

Complete deployment of Partner Vetting System Completed in April 2013

Individual USAID missions establish operational 

procedures as necessary to address 

environment-specific risks

Establish as needed

Interagency coordination and 

transition planning

Office of Afghanistan and Pakistan Affairs detail 

staff to DOD and State

Ongoing

Source: GAO analysis of USAID’s Section 850 report and agency data.

To develop its Section 850 report, USAID officials told us that USAID’s 

Office of Acquisition and Assistance in the Bureau for Management 

(M/OAA)—the office responsible for developing, issuing, and maintaining 

the agency’s acquisition regulations, procedures, and standards—was 

tasked with assessing agency-wide acquisition policies, such as its 

Automated Directives System and the FAR, to determine if new policies 

or changes to existing policies or procedures were needed to improve 

contracting in overseas contingency operations. Section 850 required 

USAID to assess its policies and procedures related to contract support of 

contingency operations. USAID officials said that they took a narrow view 
Page 18 GAO-14-229 Contingency Contracting

of the mandate and did not include operational procedures from missions 

that have played key roles in contingency operations in their assessment 

because they interpreted the legislative requirement to include only 

agency policy rather than operational procedures developed by individual 

missions. Further, according to agency officials, the Office of Foreign 

Disaster Assistance and the Office of Transition Initiatives within USAID’s 

Bureau for Democracy Conflict and Humanitarian Assistance did not 

participate in developing USAID’s Section 850 report as these offices do 

not create contracting policy. However, officials from these two 

organizations noted that they are often the first to respond to disasters or 

contingencies and play a key role in successfully transitioning from shortterm, quick-impact interventions to longer-term traditional development 

programming. For example, working in-country the Office of Transition 

Initiatives designs acquisition instruments and develops relationships with 

implementing partners—information that could benefit the mission if 

leveraged. As a result, USAID may have missed opportunities to leverage 

its institutional knowledge to better support future contingencies.

In response to long-standing challenges that the agency faces in 

implementing and monitoring activities in high-threat environments, 

however, USAID established a nonpermissive environment working group 

in October 2013.30 By September 2014, the working group plans to 

develop a compendium of best practices and lessons learned for 

implementing and monitoring projects in nonpermissive environments; an 

operations security toolkit that will include tools for enhanced monitoring, 

and possibly a field information technology support package; and a 

targeted set of training and learning tools that focus on how USAID 

prepares staff for managing risks inherent in working in overseas 

contingency environments. This working group affords USAID another 

opportunity to leverage its institutional knowledge, such as that residing at 

its missions and other offices with contingency contracting related 

responsibilities.

 30 USAID’s limited ability to implement and monitor activities in high-threat environments 

was identified as a significant operational deficiency in USAID’s fiscal year 2012 financial 

management report. In addition, the USAID Inspector General identified working in critical 

priority countries such as Afghanistan, Pakistan, Iraq, and South Sudan as one of the 

agency’s most serious management and performance challenges in its annual 

memorandum to the USAID Administrator for fiscal years 2010 through 2012.
Page 19 GAO-14-229 Contingency Contracting

USAID described the offices that support contingency contracting in its 

Section 850 report and identified that its decentralized organizational 

structure for contracting activities is an effective and efficient model for 

overseas contingency operations. USAID delegates authority to heads of 

USAID contracting activities to carry out the programs and activities for 

which they are responsible—including execution of contracts and the 

establishment of procurement policies, procedures, and standards 

appropriate for their programs and activities, subject to government-wide 

and USAID regulations and policy. USAID reported that the agency works 

on a daily basis in countries characterized by many of the same 

conditions found in contingency operations; therefore, USAID concluded 

that its existing organizational structure for contracting activities can be 

easily applied, when necessary, in contingency operations. Further, 

USAID reported that its decentralized model gives staff flexibility in 

addressing issues that arise in contingency operations. Appendix III 

describes the roles and responsibilities of USAID’s contracting 

organization used to support contingency operations.

USAID is in the early stages of developing a proposal to use SPOT solely 

as a tool to track contractor personnel in contingency environments rather 

than the number and value of contracts. USAID officials stated that other 

data systems, such as the Federal Procurement Data System–Next 

Generation and its Global Acquisition and Assistance System, provide 

more reliable information on the number and value of contracts. USAID 

plans to present this proposal to DOD and State for their consideration.

With regard to solicitation and award of contracts, USAID reported that its 

contracting writing system, the Global Acquisition and Assistance System,

has been deployed worldwide and will allow personnel to write, manage, 

oversee, and report on USAID awards from any location. According to 

USAID, 80 percent of USAID-obligated funds are now managed through 

the Global Acquisition and Assistance System.

USAID did not identify any additional changes needed to its requirements 

development or acquisition planning processes for contingency 

operations in its Section 850 report. USAID’s missions and bureaus are 

responsible for establishing requirements prior to contract award and 

preparing a written acquisition plan that defines these requirements, if 

necessary. We previously identified that written acquisition plans, 

requirements development, cost estimating, incorporating lessons 

learned, and allowing sufficient time to conduct acquisition planning are 

several important elements of successful acquisition planning. In 2011, 

GAO found that USAID did not require written acquisition plans for 

Organizational Structure

Data Collection, Inventory, 

and Reporting

Solicitation and Award 

of Contracts

Requirements Development 

and Acquisition Planning
Page 20 GAO-14-229 Contingency Contracting

individual contracts. We recommended that USAID establish 

requirements for written acquisition plans and enhance guidance for 

lessons learned in acquisition planning, among other things.31

While USAID did not identify contract oversight as an area needing 

improvement in its Section 850 report, USAID reported that it has 

completed or is taking steps at the mission level to improve contract 

oversight in overseas contingency operations. For example:

In 

response to our recommendation, in April 2013 USAID finalized its 

acquisition planning chapter in the Automated Directives System, which 

provides the agency’s policy directives, required procedures, and internal 

guidance for the planning of USAID direct acquisition and assistance 

activities, including requirements for preparing written acquisition plans 

for individual contracts. However, we found that the policy does not 

require a discussion of lessons learned, including insights on the 

performance of the contract and any issues the program may have 

encountered.

• In Iraq, USAID reported that it made a number of management 

changes to meet mission needs, including modifying contracts to 

include more stringent reporting requirements. USAID also increased 

the number of CORs in-country and provided them with additional 

guidance on ensuring compliance related to reporting.

• As the U.S. military presence draws down in Afghanistan, USAID 

officials acknowledged that they may be challenged to adequately 

monitor project progress. To address this concern, USAID created onsite monitors at project sites to devolve project monitoring 

responsibilities to USAID personnel in the five regional commands in 

September 2010. In addition, USAID/Afghanistan provided training for 

on-site monitors on the acquisition process. According to M/OAA 

officials in Kabul, the USAID mission in Afghanistan recently 

established support units for contracting activities. For example, 

mission officials told us that they established a compliance division 

approximately 1 year ago to ensure that implementing partners and 

M/OAA are in compliance with USAID acquisition policy. Further, 

USAID officials told us that the mission in Afghanistan staffed a 

contract management team in 2012 to support COs by tracking audit 

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

Services Contracts, GAO-11-672 (Washington D.C.: Aug. 9, 2011).

Contract Oversight
Page 21 GAO-14-229 Contingency Contracting

recommendations and ensuring implementation and performing 

contract closeout.

• In addition, USAID is planning to implement a remote monitoring 

program in Afghanistan that will verify project performance through 

individuals hired by the contractor to verify activities that implementing 

partners have completed at project sites. This initiative will be 

composed of a set of monitoring methods that will be used to verify 

project performance, including third-party monitors, Global Positioning 

System tracking, photography, and data collections with mobile 

devices, among other methods. To implement this initiative, USAID 

issued a draft request for proposals in May 2013 publicizing its intent 

to negotiate up to as many as three contracts. According to USAID 

officials, as of October 2013, the agency is in the process of finalizing 

the request for proposals.

• The USAID mission in Pakistan reported that it has developed several 

monitoring and evaluation mechanisms that are especially useful in 

geographically remote areas where USAID staff have limited access 

due to security restrictions. For example, USAID contracts with 

several independent local contractors to monitor implementation in 

insecure areas. In May 2013, the Inspector General recommended 

that the USAID mission in Pakistan implement a mission‐wide 

monitoring and evaluation plan to cover all aspects of mission 

programs. USAID/Pakistan concurred with this recommendation.

USAID reported that it has identified increasing the submission of 

contractor performance evaluations in CPARS as one of the agency’s 

highest acquisition priorities. To do so, M/OAA has established quarterly 

targets for reporting in the contractor past performance database to 

measure its progress in meeting the agency’s 65-percent reporting goal 

for fiscal year 2013 and embarked on a communications and training 

effort for COs and CORs.

USAID has taken actions to address contracting risks in contingency 

environments, including reliance on contractors and the risk of terrorist 

financing. For example, USAID’s Bureau for Policy, Planning and 

Learning revised the agency’s planning policy to incorporate a risk 

assessment requirement for using contractor support in overseas 

contingency operations as required by the 2013 NDAA.32

 32 Pub. L. No. 112-239 § 846.

According to 

Performance Evaluations

Risk Management
Page 22 GAO-14-229 Contingency Contracting

agency officials, they expect the draft revised policy will be finalized in 

January 2014. Further, in 2011, we found that USAID’s vendor vetting 

process in Afghanistan faced limitations and recommended that USAID 

consider formalizing a risk-based approach that would enable them to 

identify and vet the highest-risk vendors and partners.33

In addition, individual USAID missions develop and implement operational 

procedures as necessary to address environment-specific risks. For 

example, USAID reported that, in Afghanistan, USAID launched the 

Accountable Assistance for Afghanistan initiative to further protect 

taxpayer dollars from being diverted from their development purpose in 

the fall of 2010. The initiative consists of several components, including 

limiting the number of layers of subcontracts and financial controls such 

as auditing all locally incurred costs and ensuring close review of 

contractor claims prior to payment.

USAID concurred 

with the recommendation and in April 2013 USAID completed deployment 

of its Partner Vetting System—a centralized database used to support the 

vetting of individuals—to decrease the risk of terrorist financing, and is 

preparing templates and implementation guidance for COs.

USAID’s Office of Afghanistan and Pakistan Affairs represents USAID in 

interagency discussions related to the contingency operation in 

Afghanistan. Further, the Office of Afghanistan and Pakistan Affairs 

provides support to the USAID mission in Afghanistan so that it may 

provide input to key interagency stakeholders. While USAID did not 

identify interagency coordination as an area needing improvement in its 

Section 850 report, according to USAID officials the Office of Afghanistan 

and Pakistan Affairs details staff on an ongoing basis to State and DOD 

offices to strengthen interagency coordination. Further, according to 

USAID officials, the Office of Afghanistan and Pakistan Affairs and the 

USAID mission in Afghanistan have conducted extensive planning 

regarding management and oversight of procurements in light of the

upcoming transition from a DOD to a State-led presence in Afghanistan. 

Principal procurement management responsibilities are expected to 

remain with USAID staff based in Kabul, in consultation with Washington, 

D.C.-based staff.

 33 GAO-11-355.

Interagency Coordination 

and Transition Planning
Page 23 GAO-14-229 Contingency Contracting

Since 2011, State and USAID have increased their overall acquisition 

workforces and are in various stages of assessing their workforce needs 

for overseas contingency operations. Per Office of Management and 

Budget (OMB) guidance, both agencies identified competency and skill 

gaps for their acquisition workforces in their 2013 acquisition human 

capital plans. State’s 2013 plan noted that, in response to growth in 

contracting activity in areas such as Iraq and Afghanistan, additional 

acquisition personnel were needed. In October 2013, State’s Under 

Secretary for Management approved the formation of a multibureau 

working group that plans to further explore workforce needs for current 

and future contingency operations. USAID launched a program in 2008 

that has worked to rebuild a cadre of contracting officers and USAID’s 

2013 plan cited providing training for a young acquisition workforce as the 

agency’s greatest challenge. State noted in its Section 850 report that it 

will increase its focus on conducting risk assessments on the reliance, 

use, and oversight of contractors through the establishment of risk 

management staff. USAID’s Section 850 report did not address reliance 

on contractors, but in October 2013, USAID drafted a revision to its 

planning policy to require a risk assessment and mitigation plan 

associated with contractor performance of critical functions in overseas 

contingency operations.

Since 2011, both State and USAID have increased the size of their 

acquisition workforces.34 State reported that its workforce has grown by 

53 percent, while USAID’s workforce grew by about 15 percent (see table 

3).

 34 In 2005, OMB issued guidance to civilian agencies which, among other things, defined 

the acquisition workforce to include, as a minimum, contracting specialists, COs, 

program/project managers, and CORs. State and USAID are required to use this definition 

for the purposes of defining their acquisition workforces.

State and USAID 

Increased Their 

Acquisition 

Workforces and 

Continue to Assess 

Contingency 

Acquisition Workforce 

Needs

State and USAID Have 

Increased Their Overall 

Levels of Acquisition 

Personnel Since 2011
Page 24 GAO-14-229 Contingency Contracting

Table 3: Comparison of State and USAID Acquisition Personnel, Fiscal Years 2011 to 2013

Source: State and USAID reported data.

a At State, this category indicates Foreign Service positions.

b The majority of USAID’s technical personnel are program and/or project managers, however the 

numbers presented here are only those that are certified under the Federal Acquisition Institute’s 

Federal Acquisition Certification for Program and Project Managers program.

State’s 2013 acquisition human capital plan noted that, in response to 

growth in contracting activity in areas such as Iraq and Afghanistan, 

additional acquisition personnel were needed. To increase their 

acquisition workforce, State officials told us that they realigned and 

designated existing staff as acquisition personnel and undertook limited 

hiring. Further, State officials noted that the department’s acquisition 

workforce growth was in part aided by the use of its working capital fund, 

which is generated through a 1-percent fee on all procurements. In 2012, 

we found that State had not assessed the extent to which the working 

capital fund has helped State surge its workforce to meet requirements 

for Iraq and Afghanistan.35

While USAID also reported increasing its overall acquisition workforce 

from fiscal year 2011 to 2013, USAID officials told us that they 

experienced a decrease in 2013 due to a number of factors, including a 

temporary loss in their direct hiring authority for hard-to-fill positions and a 

slowdown in hiring due to budget cuts as a result of sequestration. USAID 

officials stated that they anticipate that the number of acquisition 

 35 For more information on State’s working capital fund, see GAO-12-750. 

Category State

Total 

Increase

(percent) USAID

Total

Increase

(percent)

2011 2012 2013 2011 2012 2013

Contracting 

specialists: GS-1102

176 195 213 121 150 143

Contracting officers 

outside of the 1102 

series

458

a

695 734 226 274 257

Program/project 

managers

39 b 80 80 2 2 2

Total 673 970 1,027 53 349 426 402 15
Page 25 GAO-14-229 Contingency Contracting

personnel will increase in future years as personnel are hired to fill vacant 

positions. USAID officials do not anticipate an increase in the total 

number of authorized positions at this time.

Responsible for ensuring the technical and administrative functions of the 

contract, CORs are an integral part of the acquisition workforce. USAID 

officials reported that their Global Acquisition and Assistance System 

identified 3,629 personnel in fiscal year 2013 who have been designated 

to serve as a COR since 2008. However, USAID officials cautioned that 

they are continuing to improve the reliability of the data and that relying 

on the number of employees who have been certified as a COR may 

overstate the COR workforce at USAID. Further, USAID officials 

explained that the number of CORs reported by Global Acquisition and 

Assistance System who have been designated to serve as a COR on a 

specific award—which totaled about 1,116 as of November 2013—may 

be a more accurate representation of USAID’s COR workforce. State 

officials told us that 2,367 CORs were certified in fiscal year 2013.

State and USAID are in various stages of assessing their workforce 

needs for overseas contingency operations and have identified skills and 

competency gaps in their acquisition workforces. OMB’s 2009 

memorandum, Acquisition Workforce Development Strategic Plan for 

Civilian Agencies—FY 2010-2014, requires agencies to develop annual 

acquisition workforce human capital plans that identify strategies and 

goals for increasing the capacity and capability of the acquisition 

workforce. For example, the plan is to include recruitment and retention 

strategies for obtaining the acquisition workforce resources and skills 

required to meet future agency mission needs. We also identified leading 

practices agencies should follow when developing workforce plans,

including determining the occupations, skills, and competencies that are 

critical to achieving their missions and goals, as well as identifying any 

gaps between their current workforce and the workforce they will need in 

the future.36

State’s March 2013 acquisition human capital plan provided information 

on identified skill and competency gaps in its acquisition workforce, as 

 36 GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning, 

GAO-04-39 (Washington D.C.: Dec. 11, 2003). 

State and USAID Are 

in Various Stages of 

Assessing Their Workforce 

Needs for Overseas 

Contingency Operations
Page 26 GAO-14-229 Contingency Contracting

well as agency plans to address them. For example, State’s report 

identified that its contracting professionals had strong technical skills in 

contract award and administration, but noted weakness in acquisition 

planning, among other areas. State reported that it is focusing on pairing 

interns and recently hired staff with senior staff and mentoring them in the 

competencies that need additional attention. State is also continuing to 

use internal expertise and resources to provide in-house training sessions 

to supplement external training.

In October 2013, State’s Under Secretary for Management approved the 

formation of a multibureau working group that plans to explore workforce 

needs for current and future contingency operations. Specifically, the 

working group will assess the existing COR structure, further analyze skill 

gaps to meet the department’s demands for surge personnel, and 

develop expanded legislative authority for hiring personal services 

contractors in contingencies.37

OMB’s July 2009 multisector workforce guidance directed agencies to 

determine the best mix of skills of contractors and federal employees and 

the appropriate workforce size for the agency. To do so, agencies were 

directed to conduct a pilot human capital analysis of at least one program 

where the agency has concerns about the extent of reliance on 

contractors and to adopt a framework for planning and managing a 

multisector workforce that is built on strong strategic human capital 

planning. According to State officials, in response to OMB’s guidance, 

they created a multisector workforce methodology, conducted two pilot 

programs, and realized efficiencies and cost savings. In August 2012, we 

found that State had not fully assessed whether its effort to increase its 

workforce was sufficient to meet requirements; whether it had the proper 

skills; whether it had the appropriate mix of government/contractor 

personnel; or whether it had sufficient numbers of qualified oversight 

personnel to support its future acquisition efforts in Iraq and Afghanistan. 

We recommended that State assess the extent to which the current 

For example, the group plans to review the 

feasibility of special pay incentives for critically needed COR skills and 

study whether a new career track for CORs with specialized training is 

needed. State did not identify when the working group is expected to 

complete its efforts.

 37 The FAR defines “personal services contracts” as contracts that, by their express terms 

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

employees. FAR § 2.101.
Page 27 GAO-14-229 Contingency Contracting

acquisition workforce, both government and contracting personnel, meets 

its needs for acquiring goods and services in complex environments such 

as Iraq and Afghanistan.38

Similar to State, USAID’s 2013 acquisition human capital plan provided 

information on identified skill and competency gaps in its acquisition 

workforce. For example, USAID’s report identified that its contracting 

professionals had strong technical skills in contract administration and 

proposal evaluation, but noted weaknesses with acquisition planning, 

among other things. Similarly, USAID reported that its CORs had strong 

skills in project management and contract administration and weaknesses 

in market research and acquisition planning. In response, USAID 

developed training to improve COR technical skills through scenariobased learning. In addition, USAID launched an e-based resource in 

March 2013 that provides tools to guide personnel through the 

procurement process; the resource includes references for CORs at each 

stage of the contract award process.

State concurred with this recommendation 

and, in September 2013, State officials noted that they are still 

considering options to address this recommendation, such as relying on 

the resources of an Afghanistan interagency coordination group to 

determine skill sets needed. Further, State noted in its Section 850 report 

that it will increase its focus on conducting risk assessments on the 

reliance, use, and oversight of contractors through the establishment of 

risk management staff. In addition, State issued an updated workforce 

policy on October 1, 2013, that directed bureaus on a regular basis to 

consider using federal employees to perform new or expanded functions 

performed by contractors.

USAID’s 2013 acquisition human capital plan cited providing training for a 

young acquisition workforce as the agency’s greatest challenge and 

USAID launched a program in 2008 that has worked to rebuild a cadre of 

contracting officers. According to USAID’s 2013 acquisition human capital 

plan, the average procurement professional within M/OAA has five years 

or less of experience in federal procurement policy and procedures. 

USAID established a Professional Development and Training Division in 

the fourth quarter of fiscal year 2013 to implement acquisition and 

assistance training. This division is intended to develop a formal process 

 38 GAO-12-750.
Page 28 GAO-14-229 Contingency Contracting

for learning across the acquisition workforce, but it is not focused 

specifically on training needs in contingency environments. 

USAID’s Section 850 report did not address reliance on contractors in 

connection with contingency operations, but in October 2013, USAID 

drafted a revision of its planning policy to require a risk assessment and 

mitigation plan associated with contractor performance of critical functions 

in overseas contingency operations. The draft revision will undergo an 

agency clearance process before becoming policy in 2014. According to 

the draft policy, the risk assessments will consider the core capabilities of 

government personnel and the risk of overreliance on contractors to 

monitor other contractors, among other things. The draft policy notes that 

the mitigation plan will include specific actions to mitigate or reduce the 

risks and impacts noted in the risk assessment, including the 

development of alternative capabilities to reduce reliance on contractors 

for critical functions.

State and USAID have faced numerous contract management and 

oversight challenges while operating in contingency environments such 

as Iraq and Afghanistan. These challenges highlight the importance of 

effectively leveraging knowledge and developing ways to identify, 

mitigate, or avoid contracting pitfalls before new contingencies arise. 

Each agency has to varying degrees assessed, identified, and started 

implementing changes to improve its ability to overcome inherent risks of 

contracting in uncertain environments. State has outlined a series of 

initiatives to address weaknesses in areas such as the collection of 

contractor data, acquisition planning, contract oversight, risk 

management, and interagency coordination, and plans to institutionalize 

many of these changes in the department’s Foreign Affairs Manual within 

the next year. Except for a limited number of cases, State generally has 

not developed plans to assess the impact of these initiatives. Federal 

internal control standards highlight the importance of reviews by 

management to compare actual performance to planned or expected 

results and analyze significant differences. As a result, continued 

management attention is needed to ensure that these efforts achieve their 

intended objectives. While USAID has identified some needed 

improvements, such as completing contractor performance evaluations, it 

did not assess whether the procedures and practices created by the 

missions or offices that operate in contingency environments should be 

reflected in agency-wide policy or guidance. As a result, USAID may have 

missed opportunities to leverage its institutional knowledge. USAID 

recently established a nonpermissive working group responsible for

Conclusions
Page 29 GAO-14-229 Contingency Contracting

developing lessons learned, toolkits, and training, which affords USAID 

another opportunity to take better advantage of its institutional knowledge. 

State and USAID have increased the size of their acquisition workforces 

in the past 3 years, and both have efforts in place to better ensure 

acquisition personnel are equipped with the skills needed to support 

future contingency operations. Both agencies have taken some initial 

steps to address reliance on contractors and to assess the appropriate 

mix of government and contractor personnel, but these efforts are in their 

infancy.

To ensure that State is in a better position to support future 

contingencies, we recommend that the Secretary of State develop plans 

to assess whether planned initiatives are achieving their intended 

objectives. 

To ensure that USAID has the necessary policies and procedures to 

better position itself to address future contingency challenges, we 

recommend that the Administrator of USAID ensure that its 

nonpermissive working group consider procedures and practices 

developed by missions and offices with contingency-related 

responsibilities during the course of its efforts.

We provided a draft of this report to State and USAID. In their written 

comments, the two agencies concurred with our recommendations and 

provided information on actions taken or planned to address them. 

Specifically, State created the Critical Environment Contract Analytics 

Staff on December 19, 2013 to develop and prepare department-wide 

contracting risk assessments and risk mitigation plans, coordinate efforts 

with other agencies, and monitor procurement readiness for contracting 

operations in critical environments. Additionally, the staff will be 

responsible for using metrics to assess the effectiveness and 

performance of planned initiatives. USAID plans to create a 

supplementary working group to the nonpermissive environment working 

group that will reach out to missions, offices, and contracting personnel 

with contingency operations experience to collect and disseminate a set 

of best practices for contracting in support of contingency operations and 

other potentially dangerous or uncertain environments. State’s letter is 

reprinted in appendix IV and USAID’s letter is in Appendix V. Both 

agencies provided technical comments which we incorporated into the 

report as appropriate. 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 30 GAO-14-229 Contingency Contracting

We are sending copies of this report to interested congressional 

committees, the Secretary of State, and the Administrator of USAID. 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 dinapolit@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 VI.

Timothy J. DiNapoli

Director

Acquisition and Sourcing Management
Page 31 GAO-14-229 Contingency Contracting

List of Committees

The Honorable Barbara A. Mikulski

Chairman

The Honorable Richard C. Shelby

Vice Chairman

Committee on Appropriations

United States Senate

The Honorable Carl Levin

Chairman

The Honorable James M. Inhofe

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Robert Menendez

Chairman

The Honorable Bob Corker

Ranking Member

Committee on Foreign Relations

United States Senate 

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate 

The Honorable Harold Rogers

Chairman

The Honorable Nita M. Lowey

Ranking Member

Committee on Appropriations

House of Representatives 

The Honorable Howard P. “Buck” McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives
Page 32 GAO-14-229 Contingency Contracting

The Honorable Edward R. Royce

Chairman

The Honorable Eliot L. Engel

Ranking Member

Committee on Foreign Affairs

House of Representatives

The Honorable Darrell E. Issa

Chairman

The Honorable Elijah Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-14-229 Contingency Contracting

Section 850(c) of the National Defense Authorization Act (NDAA) for 

Fiscal Year 2013 mandated that we report on the progress that the 

Department of State (State) and the U.S. Agency for International 

Development (USAID) have made in identifying and implementing 

improvements in a range of areas related to contract support for overseas 

contingency operations.1 The objectives for this review were to examine 

the extent to which State and USAID have identified and implemented 

changes to the agencies’ (1) organizational structures and policies; and 

(2) workforces, including their use of contractors. For the purposes of our 

review, we used the definition of overseas contingency operations set 

forth in Title 10 of the U.S. Code, as well as other contingency 

environments with characteristics such as unique security and logistical 

challenges; the need to contract quickly; difficulty in conducting oversight; 

difficulty traveling to dangerous or remote locations; events occurring 

unexpectedly; and frequent rotations among personnel.2

For all objectives, we reviewed State and USAID’s Section 850 reports 

submitted to Congress in June and July, 2013, respectively; interviewed 

officials at State and USAID in the United States and Afghanistan with 

related program, acquisition, or workforce planning responsibilities to 

discuss their role in identifying and implementing changes, as 

appropriate; and reviewed and analyzed GAO and other oversight 

reports, including those from State and USAID’s Offices of the Inspector 

General, the Commission on Wartime Contracting, and the Special 

Inspectors General for Iraq and Afghanistan to identify key challenges 

reported by the accountability community.

To determine the extent to which State and USAID have identified and 

implemented changes related to their organizational structures, we 

reviewed State and USAID’s organizational charts and agency policy 

outlining roles and responsibilities in overseas contingency operations. To 

complement this information, we conducted interviews with key offices 

identified in the agencies’ Section 850 reports to obtain additional 

information regarding their roles and responsibilities in overseas 

contingency operations. In the case of State, these offices included the 

Office of Management Policy, Rightsizing, and Innovation; Office of 

Acquisitions Management; Deputy Assistant Secretary for Logistics 

 1 Pub. L. No. 112-239 § 850(c).

2 10 USC § 101(a)(13).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-14-229 Contingency Contracting

Management; Kabul General Services Office; and the Afghanistan 

Transition Office. In the case of USAID, these offices included the Bureau 

for Management/Office of Acquisition and Assistance, the Office of 

Afghanistan and Pakistan Affairs, and the Office of Foreign Disaster 

Assistance and the Office of Transition Initiatives within USAID’s Bureau 

for Democracy Conflict and Humanitarian Assistance. We did not 

independently assess the adequacy of either State or USAID’s 

organizational structure.

To determine the extent to which State and USAID have identified and 

implemented changes to the agencies’ contract award and management 

policies, we collected and analyzed agency documentation, such as 

descriptions of related working groups, acquisition and quality assurance 

plans, and draft working group charters. We also reviewed agency-wide 

and individual mission contracting policies and guidance, such as 

USAID’s Automated Directives System and Acquisition and Assistance 

Policy Directive, and State’s Foreign Affairs Manual and Procurement 

Information Bulletins, as well as relevant sections of the Federal 

Acquisition Regulation. We compared changes identified by the agencies 

in their Section 850 reports to challenges and potential changes identified 

in prior GAO and other oversight reports, to determine the extent to which 

the agencies are addressing these challenges.

To determine the extent to which State and USAID have identified and 

implemented changes related to their workforces for contract support in 

overseas contingency operations, we collected and analyzed detailed 

data on the composition of State and USAID’s acquisition workforces. 

Specifically, we reviewed and compiled acquisition workforce data for 

fiscal years 2011 to 2013 from each agency’s March 2013 acquisition 

human capital plan. We included data from the following categories: 

contracting officers, contracting specialists, contracting officer 

representatives, and program or project managers. We collected updated 

data on State and USAID’s acquisition workforces as of November 2013. 

We used this information to describe characteristics of each agency’s 

acquisition workforce and, as such, did not assess the reliability of the 

data. We reviewed a March 2013 USAID report on worldwide staffing 

patterns and other USAID data on its acquisition workforce for its five 

critical priority countries. We also reviewed various workforce related 

reports, such State and USAID’s 5-year succession plans and the Federal 

Acquisition Institute annual federal acquisition workforce reports. We also 

reviewed acquisition workforce guidance and memorandums from the 

2009 Office of Management and Budget multisector workforce guidance 

and its acquisition workforce development strategic plan.
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-14-229 Contingency Contracting

We conducted this performance audit from March 2013 to February 2014 

in accordance with generally accepted government auditing standards. 

These 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.
Appendix II: Description of Department of 

State’s (State) Contracting Organization for 

Contingency Operations

Page 36 GAO-14-229 Contingency Contracting

Contracting organization Roles and responsibilities

Under Secretary for Management The Under Secretary for Management leads several bureaus, such as Administration and 

Diplomatic Security. As the leader of these bureaus, the Under Secretary is responsible 

for major contingency contracting policy decisions.

Assistant Secretary for Administration The Assistant Secretary for Administration serves as State’s Chief Acquisition Officer and 

advises the Under Secretary for Management on the applicability of relevant policy on 

contracts for overseas operations, including contingency operations, and ensuring 

compliance of the contracts and contracting activities with such policies.

Office of the Procurement Executive The Office of the Procurement Executive supports the Chief Acquisition Officer and is 

responsible for promulgating acquisition policy, providing oversight, and defining and 

presenting acquisition training.

Office of Acquisitions Management The Office of Acquisitions Management 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. The office 

reports to the Deputy Assistant Secretary for Logistics Management.

Deputy Assistant Secretary for Logistics 

Management

The Deputy Assistant Secretary for Logistics Management oversees the integration of 

logistics and acquisition and ensures complete supply chain accountability.

Functional Bureaus Functional bureaus such as the International Narcotics and Law Enforcement Affairs, 

Overseas Buildings Operations, Human Resources, and Diplomatic Security are 

responsible for identifying and defining contracting requirements, providing technical 

contract administration, providing program and project management support, and training 

within their mission.

Regional Bureaus Regional Bureaus are responsible for working with overseas posts to identify contracting 

requirements not under the purview of functional bureaus

Source: Department of State.

Appendix II: Description of Department of 

State’s (State) Contracting Organization for 

Contingency Operations
Appendix III: Description of U.S. Agency for 

International Development’s (USAID) 

Contracting Organization for Contingency 

Operations

Page 37 GAO-14-229 Contingency Contracting

Contracting organization Roles and responsibilities

Bureau for Management, Office of 

Acquisition and Assistance

The Office of Acquisition and Assistance within the Bureau for Management is responsible 

for (1) developing, issuing, and maintaining the agency’s acquisition regulations, 

procedures, and standards in accordance with established agency delegations and 

requirements; and (2) evaluating the agency’s procurement system, providing 

recommendations for selecting and appointing contracting officers and terminating their 

appointments, and providing technical support to overseas contracting officers. 

Additionally, in accordance with Section 849 of the 2013 NDAA, the Director of the Office 

of Acquisition and Assistance advises the agency on the applicability of relevant policies 

on contracts for overseas contingency operations as defined in 10 U.S.C. § 101(a)(13) 

and ensures the compliance of contracting activities with this policy.

Bureau for Democracy, Conflict, and 

Humanitarian Assistance 

The Assistant Administrator for the Bureau for Democracy, Conflict, and Humanitarian 

Assistance has authority to negotiate, execute, and amend contracts for the purpose of 

immediately responding to disasters overseas. This authority is limited to grants and 

cooperative agreements up to $3 million, and contracts up to $500,000. The Office of 

Foreign Disaster Assistance and Office of Transition Initiatives are typically USAID’s first 

responders to a contingency situation. The Office of Civilian Response provides 

reconstruction and stabilization support, and provides staff surge support for contracting, 

including those seconded to the Office of Acquisition and Assistance for assignment.

USAID Overseas Missions USAID acquisition and assistance staff at overseas missions provide advice and support 

to mission staff that design and manage assistance activities; they also have overall 

responsibility for the administration of acquisition instruments at overseas missions. 

Acquisition offices are typically headed by a contracting officer, who reports to the mission 

director, the principal USAID officer at post, or deputy mission director. At most bilateral 

missions, contracting officers are co-located with acquisition specialists and contracting 

officer’s representatives (COR). However, under USAID’s regional mission structure, 

contracting officers provide acquisition support to more than one mission and are not 

necessarily co-located with either the CORs or the acquisition specialists who assist them. 

Some missions with no on-site contracting officers may instead have on-site acquisition 

specialists who provide support to CORs.

Source: GAO analysis of USAID data.

Note: USAID reported that divisions within the Office of Acquisition and Assistance that provide 

support for contingency operations include the Foreign Operations Division; Transportation Division; 

Cost, Audit and Support Division; Policy Division; Compliance Division; and Operations Division.

Appendix III: Description of U.S. Agency for 

International Development’s (USAID) 

Contracting Organization for Contingency 

Operations
Appendix IV: Comments from the Department 

of State

Page 38 GAO-14-229 Contingency Contracting

Appendix IV: Comments from the 

Department of State
Appendix IV: Comments from the Department 

of State

Page 39 GAO-14-229 Contingency Contracting
Appendix V: Comments from the

U.S. Agency for International Development

Page 40 GAO-14-229 Contingency Contracting

Appendix V: Comments from the

U.S. Agency for International Development

Note: GAO received 

USAID's letter on 

2/3/2014
Appendix V: Comments from the

U.S. Agency for International Development

Page 41 GAO-14-229 Contingency Contracting
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 42 GAO-14-229 Contingency Contracting

Timothy J. DiNapoli, 202-512-4841 or dinapolit@gao.gov

In addition to the contact named above, W. William Russell, Assistant 

Director; Peter Anderson; Lynn Cothern; Leigh Ann Haydon; Amber 

Keyser; John Krump; Anne McDonough-Hughes; Eddie Uyekawa; and 

Andrea Yohe made key contributions to this report.

Appendix VI: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(121119)
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