OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

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SIGIR 

Special Inspector General for IRAQ Reconstruction 

For more information, contact SIGIR Public Affairs at 

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

Summary of Report: SIGIR 11-001 

Why SIGIR Did This Study 

This report addresses the Department of State’s 

(DoS) management of a $50 million grant to the 

National Democratic Institute (NDI) for 

democracy-building activities in Iraq. This is 

the largest grant awarded to NDI by the Bureau 

of Administration, Office of Acquisitions 

Management (AQM) on behalf of the Bureau of 

Democracy, Human Rights, and Labor (DRL) 

and is intended to support governance, political 

party, and civil society programs in Iraq. DRL’s 

mission is to lead U.S. efforts to promote 

democracy, protect human rights and 

international religious freedom, and advance 

labor rights globally. 

In a prior audit, SIGIR found that both NDI and 

the International Republican Institute (IRI), 

which also received DRL democracy grants, had 

significant security costs, and DRL did not have 

documentation on whether either grant was 

meeting its goals (SIGIR 10-012). 

Subsequently, SIGIR reviewed IRI’s largest 

DRL grant more in depth (SIGIR 10-022). In 

this follow up audit, SIGIR’s objectives are to 

examine for NDI’s $50 million DRL grant, the 

reasonableness, allowability, and allocability of 

NDI’s claimed security costs, and the extent to 

which the grantee documented its success in 

achieving governance, political participation, 

and civil society goals and objectives. 

What SIGIR Recommends 

SIGIR recommends that the U.S. Secretary of 

State take actions to improve grant management 

to include: requiring that NDI’s next A-133 

audit include a comprehensive audit of indirect 

costs and a compliance audit for at least one 

major DRL grant; directing that given the 

similar problems we found in IRI and NDI 

grants, Grants Officers consider requiring these 

more comprehensive A-133 audits for all DRL 

grants; and requiring that the Grants Officer 

Representatives enforce grant requirements that 

NDI provide measurable indicators of their 

success in meeting grant goals and objectives. 

Management Comments 

In written comments on a draft of this report, 

DRL, with AQM input, concurred with both 

recommendations. SIGIR believes the actions 

identified by management are responsive to this 

report’s recommendations. 

October 13, 2010 

NATIONAL DEMOCRATIC INSTITUTE GRANT’S SECURITY COSTS AND 

IMPACT GENERALLY SUPPORTED, BUT DEPARTMENT OF STATE 

OVERSIGHT LIMITED

What SIGIR Found 

NDI’s $13.5 million in security costs charged to the grant were generally 

reasonable, allowable, and allocable in accordance with federal regulations 

except for overhead costs. To assure reasonableness of costs, the grantee 

engaged in open competition and selected the contractor based on a cost 

analysis. Security costs were allocated among its grants to best assure that 

costs were distributed in reasonable proportion to the benefits received from 

the grants as required under Federal regulations governing grant 

management. Additionally, SIGIR’s analysis did not identify any instances 

where the grantee paid for any unallowable items. 

SIGIR found, however, that the grantee appears to have charged more for 

security contract administration, which is an indirect cost, than allowed, 

which reduces the amount of funds available for direct program activities. 

To illustrate, according to a negotiated indirect cost agreement with the U.S. 

Agency for International Development (USAID), in fiscal year 2009, NDI 

should have charged only $17,925 as indirect security costs for all federal 

grants receiving benefits from its security contractor, but instead charged 

$95,311 against just the one DoS grant under review. Therefore NDI 

appears to have overcharged the grant $77,386 in overhead costs. NDI 

officials stated that they were operating in good faith and sought to ensure 

the appropriateness of their approach by maintaining regular 

communications with USAID. However, the USAID official who set the 

rates, and the DoS Grants Officer who was responsible for monitoring the 

grant, stated they were unaware of how the grantee was calculating indirect 

costs. This mirrors our finding from our previous report on IRI. 

Furthermore, required annual audits and progress reports provided limited 

insight into such specific financial management practices. DoS officials 

stated that in response to our work, Grants Officers will take a more active 

role in overseeing awards in the future and have recently received authority 

to hire additional staff. Until that occurs, DoS will not be providing the level 

of financial oversight its internal policy manual, and sound management 

practices, require. Unless a more in-depth audit is conducted, DoS would be 

unable to determine whether any funds should be recouped. 

SIGIR confirmed that the grantee maintained comprehensive information on 

what activities it led to further democratic goals and objectives, and the 

grantee conducted several impact assessments on the extent to which 

progress was made meeting grant objectives. Nevertheless, the grantee does 

not have a systematic approach with clearly defined metrics to measure the 

impact of all of its work in meeting grant goals and objectives. DRL noted 

that it continues to take steps to improve monitoring and evaluation we 

previously noted. For example, it is requiring more comprehensive and 

empirically based impact assessments and is reviewing its staffing structure 

to assure it has adequate oversight. NDI officials stated that the organization 

has incorporated DRL’s increased evaluation requirements in a recently 

awarded grant from DRL. Both in-depth assessments and improved DoS 

oversight will be needed to provide decision makers the capability to ensure 

that activities are designed and implemented to achieve program objectives. 
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

400 Army Navy Drive • Arlington, Virginia 22202 

October 13, 2010 

MEMORANDUM FOR U.S. SECRETARY OF STATE 

SUBJECT: National Democratic Institute Grant’s Security Costs and Impact Generally 

Supported, but Department of State Oversight Limited (SIGIR 11-001) 

We are providing this report for your information and use. It primarily pertains to the Bureau of 

Democracy, Human Rights, and Labor (DRL), and Bureau of Administration, Office of 

Acquisition Management (AQM) oversight of DRL grants to the National Democratic Institute. 

We performed this audit in accordance with our statutory responsibilities contained in Public 

Law 108-106, as amended, which also incorporates the duties and responsibilities of inspectors 

general under the Inspector General Act of 1978. This law provides for independent and 

objective audits of programs and operations funded with amounts appropriated or otherwise 

made available for the reconstruction of Iraq, and for recommendations on related policies 

designed to promote economy, efficiency, and effectiveness and to prevent and detect fraud, 

waste, and abuse. This audit was conducted as SIGIR Project 1007b. 

DRL provided written responses to the recommendations in a draft of this report. Their 

responses incorporated input from AQM. We have included their comments in Appendix F. We 

also obtained technical comments and addressed them in the report as appropriate. 

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

report, please contact Glenn Furbish, Assistant Inspector General for Audits (Washington, DC), 

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

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

Stuart W. Bowen, Jr. 

Inspector General 

cc: Under Secretary of State for Democracy and Global Affairs 

Under Secretary of State for Management 

Assistant Secretary for Democracy, Human Rights, and Labor 

Assistant Secretary for Administration 

U.S. Ambassador to Iraq 

Secretary of Defense 

Commander, U.S. Central Command 

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

Introduction 1

Background 1

Objectives 7

Security Costs Generally Appropriate though DoS Oversight Is Limited and 

Indirect Costs Questionable 8

Security Costs Appear To Be Reasonable, Allocable, and Allowable 8

Indirect Costs Appear To Have Been Overcharged 9

DoS Oversight and Monitoring Needs To Be Improved 10

Grantee Documented Activities and Some Indicators of Impact 12

NDI Documents Activities 12

NDI Conducted Some Impact Assessments 16

Conclusions and Recommendations 23

Conclusions 23

Recommendations 23

Management Comments and Audit Response 25

Appendix A—Scope and Methodology 26

Appendix B—Supporting Documentation Review Results 28

Appendix C—NDI Assessment of Grant 210 Completion Status 30

Appendix D—Acronyms 34

Appendix E—Audit Team Members 35

Appendix F—Department of State–Bureau of Democracy, Human Rights, 

and Labor Comments 36

Appendix G—SIGIR Mission and Contact Information 38
1 

National Democratic Institute Grant’s Security Costs and 

Impact Generally Supported, but Department of State 

Oversight Limited 

SIGIR 11-001 October 13, 2010

Introduction 

On January 26, 2010, the Special Inspector General for Iraq Reconstruction (SIGIR) issued a 

report1

 on the Department of State’s (DoS) Bureau of Democracy, Human Rights, and Labor’s 

(DRL) management of 12 grants awarded between 2004 and 2009. Those grants, valued at 

approximately $248 million, were awarded to the International Republican Institute (IRI) and the 

National Democratic Institute (NDI) for democracy-building activities in Iraq. That audit found 

that the grants had significant security costs, and DRL did not have sufficient documentation on 

whether the grants were meeting their goals and whether the grant funds were being used in the 

most effective and efficient manner. However, IRI and NDI officials assured us they had 

assessments of their success and that the security costs were reasonable under the unique 

circumstances in Iraq.2

 

This report focuses on DoS oversight of NDI’s largest DRL grant valued at $50 million, as well 

as the reasonableness, allocability, and allowability of security costs and NDI’s impact 

assessments for the grant. This grant3

 was awarded with DoS’s fiscal year 2007 Human Rights 

and Democracy Fund4 and is intended to support governance, political party, and civil society 

programs in Iraq. 

Background 

DRL’s mission is to lead U.S. efforts to promote democracy, protect human rights and 

international religious freedom, and advance labor rights globally. DRL uses grants rather than 

contracts to conduct democracy-building activities in Iraq. Because DRL does not have 

dedicated Grants Officers (GO), it relies on the Bureau of Administration, Office of Acquisition 

Management (AQM) to award and amend its grants. Both DRL and AQM have responsibilities 

for managing the grants. 

Office of Management and Budget (OMB) circulars provide the standards, policies, 

requirements, and guidance that federal agencies and grant recipients must follow in 

 

1 Department of State Grant Management: Limited Oversight of Costs and Impact of International Republican 

Institute and National Democratic Institute Democracy Grants SIGIR 10-012, 1/26/2010. 2

 In July 2010 we issued a report examining DoS management of DRL’s largest grant to IRI, and the reasonableness, 

allocability, and allowability of security costs incurred by the grantee, and the extent to which the grantee 

documented its success in achieving grant goals and objectives. Improved Oversight Needed for State Department 

Grant to the International Republican Institute, SIGIR 10-022, 7/29/10. 3

Grant S-LMAQM-07-GR-210. 

4

Public Law 110-28, “U.S. Troop Readiness, Veterans’ Care, Katrina Recovery, and Iraq Accountability 

Appropriations Act,” 2007. 
2 

administering grant programs. They reflect the relatively limited levels of federal involvement 

and place most of the grant management responsibilities on the recipient. 

Difference between Grants and Contracts 

Grants differ from contracts in purpose and level of anticipated government involvement. The 

Federal Grant and Cooperative Agreement Act of 1977 established standards that agencies are to 

use in selecting the most appropriate funding vehicle to achieve uniformity in their use, a clear 

definition of the relationships they reflect, and a better understanding of the responsibilities of 

the parties to them. The different instruments discussed were: contracts (also known as 

acquisition awards), grants, and cooperative agreements.5

 The act also authorized the Director of 

OMB to provide additional guidance via regulations, including Circulars A-110, A-122, and A133, discussed later in this report. 

According to the act and OMB guidance, contracts are to be used when the government intends 

to acquire property or services for the direct benefit or use of the Federal Government, but grants 

may not directly benefit the government. In addition, grants are to be used when the principal 

purpose of the relationship is to transfer something of value, such as money, property, or 

services, to the recipient to carry out a public purpose of support or stimulation authorized by a 

U.S. law, and substantial involvement is not expected between the agency and the recipient. The 

DoS Federal Assistance Policy Manual6

 summarizes the differences between assistance awards 

(grants or cooperative agreements), and acquisition awards (contracts). These differences are 

highlighted in Table 1. 

Table 1—Distinction between Assistance (Grants and Cooperative Agreements) 

and Acquisition (Contract) Awards 

Assistance Awards Acquisition Awards 

Advance payment allowed if appropriate Pay for delivery after receipt 

Technical/Program competed Price must also be considered 

Recipient can terminate No contractor has right to terminate 

Deliverable is a report or completion of project Product or service required 

Guidance from OMB Circulars Guidance from Federal Acquisition Regulations 

Source: DoS Federal Assistance Policy Manual, 3/2008. 

Regulatory Differences between Grant and Acquisition Instruments 

Federal oversight requirements of grants are less stringent than those for contracts. To illustrate, 

the Federal Acquisition Regulation requires contractors that are awarded cost-reimbursable 

contracts to provide contracting officers detailed bills or invoices for every cost incurred, and 

requires contracting officers to review the invoices to determine if they are appropriate 

expenditures in meeting the terms of the contract. On the other hand, Federal regulations do not 

require similar review for grantee expenditures. Regulations from OMB, specifically OMB 

 

5

 The portion of the act distinguishing grants from contracts was codified in 31 U.S.C. sections 6301-6308. 

6

 DoS Federal Assistance Policy Manual, 3/2008. 
3 

Circular A–110,7 Subpart C, Post Award Requirements, places the day-to-day financial oversight 

responsibility on the grant recipient and, in fact, limits the extent of financial reporting an agency 

can require to at least annually, but not more than four times a year. Grant recipients usually are 

required to simply submit a claim to the GO for reimbursement of their costs quarterly and may 

also obtain advance payments. 

Unlike contracts that have an array of audit requirements under the Federal Acquisition 

Regulation, such as pre-award financial system audits, internal control audits, and post-award 

cost audits that are usually conducted by the Defense Contract Audit Agency, grantees are 

required by OMB Circular A-133 to obtain a single annual audit of the organization, usually 

conducted by a private external audit firm. The awards process is expected to determine the 

appropriateness of the planned grant expenditures, and the organization's OMB Circular A–1338

annual audit conducted by an external audit firm is expected to inform the awarding agency 

about the adequacy of the recipient’s financial management system, both before making the 

award, and afterwards, when the grantee is expending funds. OMB guidance requires that when 

financial issues are brought to the attention of the awarding agency, either through an audit or 

other monitoring mechanism, the agency must exercise its fiduciary responsibility. For example, 

OMB Circular A–133, Subpart D, Federal Agencies and Pass-Through Entities Responsibilities, 

requires the awarding agency to review and resolve audit findings within six months after receipt 

of the audit report and ensure that the recipient takes appropriate and timely corrective action. 

OMB Circular Cost Principles 

In addition to Circulars A–110 and A–133, Circular A–122, Cost Principles for Non-Profit 

Organizations,9

 establishes principles for determining reasonable, allocable, and allowable costs 

that a non-profit organization can claim against a grant award. The circular defines reasonable, 

allowable, and allocable costs as follows. We used these criteria in performing our work. 

Reasonable Costs: a cost is reasonable if, in its nature or amount, it does not exceed that which 

would be incurred by a prudent person under the circumstances prevailing at the time the 

decision was made to incur the costs. The question of the reasonableness of specific costs must 

be scrutinized with particular care in connection with organizations or separate divisions thereof 

which receive the preponderance of their support from awards made by Federal agencies. In 

determining the reasonableness of a given cost, consideration shall be given to: 

 whether the cost is of a type generally recognized as ordinary and necessary for the 

operation of the organization or the performance of the award 

 the restraints or requirements imposed by such factors as generally accepted sound 

business practices, arms-length bargaining, Federal and State laws and regulations, and 

terms and conditions of the award 

 

7

 OMB Circular A–110, Uniform Administrative Requirements for Grants and Agreements with Institutions of 

Higher Education, Hospitals, and Other Non-Profit Organizations, revised 11/19/93, as further amended 9/30/99, 

2 C.F.R. Part 215. 

8

 OMB Circular A–133, Audits of States, Local Governments, and Non-Profit Organizations, revised to show 

changes published in the Federal Register June 27, 2003 and June 26, 2007. 9

 OMB Circular A–122, Cost Principles for Non-Profit Organizations, revised May 10, 2004. 
4 

 whether the individuals concerned acted with prudence in the circumstances, considering 

their responsibilities to the organization, its members, employees, and clients, the public 

at large, and the Federal Government 

 significant deviations from the established practices of the organization which may 

unjustifiably increase the award costs 

Allocable Costs: a cost is allocable to a particular cost objective, such as a grant, contract, 

project, service, or other activity, in accordance with the relative benefits received. A cost is 

allocable to a Federal award if it is treated consistently with other costs incurred for the same 

purpose in like circumstances and if it: 

 is incurred specifically for the award 

 benefits both the award and other work and can be distributed in reasonable proportion to 

the benefits received 

 is necessary to the overall operation of the organization, although a direct relationship to 

any particular cost objective cannot be shown 

Allowable Costs: a cost is allowable if it is not specifically stated as unallowable in Circular A–

122, Attachment B, and in certain provisions of Circular A–110; for example alcoholic 

beverages, bad debts, entertainment, and items that require preapproval of the agency. 

DoS Monitoring Policy Guidance Provides Flexibility in Oversight 

DoS’s standard operating procedures demonstrate that the relatively limited levels of federal 

oversight required do not relieve the department from its fiduciary responsibility to monitor the 

funds it allocates and administers. The DoS Federal Assistance Policy Manual, states, for 

example, that its oversight must include continuous review of a grantee’s “programmatic and 

financial management performance.” Moreover, the policy states that the GO and the Grants 

Officer Representative (GOR) should ensure that a recipient is using the funds for the intended 

purpose, charges allowable costs at the appropriate times, and meets all goals. This can include 

reports, as well as interaction with the recipient through meetings, site visits, or correspondence. 

DoS’s Federal Assistance Policy Manual implements the agency’s grant management and 

monitoring requirements.10 The policy manual describes four methods for GOs and their 

representatives to monitor the financial management aspects of assistance awards: 

 monitoring by telephone or letter 

 periodic financial status and progress reports with their content and frequency determined 

by specific bureau, program and award conditions 

 site visits as warranted by the project/program need or as requested by the recipient to 

substantiate financial progress and compliance with laws, regulations, policies, and to 

provide technical assistance 

 

10 Federal Assistance Policy Manual, U.S. Department of State Bureau of Administration, Office of the Procurement 

Executive, Federal Assistance Division (A/OPE/FA), Version 1.1, March 2008. 
5 

 audits which include the annual audits conducted to examine financial and compliance 

matters, and follow up on any identified material weakness which if not corrected by the 

recipient may be defined as program abuse and lead to suspension or termination 

The manual provides GOs and GORs flexibility in determining the type of oversight mechanism 

to use, and the frequency of its monitoring activities, for each grant. Criteria to judge the extent 

of oversight required includes an assessment of whether the recipient is reliable, has developed a 

well-planned project, and if the expected requirements have been clearly communicated from 

both sides. The manual concludes that if such conditions exist the monitoring can be expected to 

be a simple, positive experience. 

Grants Awarded to NDI 

Between August 2004 and February 2010, DRL awarded eight grants to NDI for approximately 

$155 million. Table 2 shows those eight democracy-building grants.11 

Table 2—DRL Grants Awarded to NDI ($ in millions) 

Award 

Date Grant Number Project 

Grant 

Amount 

Expiration 

Date

8/31/04 S-LMAQM-04-GR-140 Political Training $1.5 3/31/06 

6/13/06 S-LMAQM-06-GR-098 Governance Civil Society 53.0 12/31/07

8/31/06 S-LMAQM-06-GR-149 Political Training 0.7 11/30/07 

9/12/07 S-LMAQM-07-GR-210a 

Governance, Political Participation, 

and Civil Society 50.0 3/31/11 

5/12/08 S-LMAQM-08-GR-550 Women’s Political Participation 1.8 12/31/10 

8/18/08 S-LMAQM-08-GR-602

Increasing Accountability and 

Representation in Elections 27.5 1/31/11 

12/09/09 S-LMAQM-10-GR-503 

Promoting the Credibility and 

Transparency of Iraqi National 

Elections 5.0 11/30/10 

2/25/10 S-LMAQM-10-GR-533 

Improving Governance to Help 

Democracy Deliver 15.0 3/31/11 

Total $154.5 

Note: 

a Grant reviewed by SIGIR. 

Source: SIGIR analysis of DRL data, as of 8/25/2010. 

Of those grants, we reviewed a $50 million grant to support governance, political participation, 

and civil society programs in Iraq, in accordance with the goal and strategic objectives of the 

U.S. Strategy for Democracy in Iraq 2007-2010. The grantee focused S-LMAQM-07-GR-210 

(grant 210) on three principal goals: equipping activists with the tools to work toward 

reconciliation and community-building; strengthening Iraq’s still-fledgling institutions of 

 

11 The Iraq Relief and Reconstruction Fund, the Economic Support Fund, and the Human Rights Democracy Fund 

have funded these grants. 
6 

governance; and preparing for a series of elections and referenda likely to be held in the future. 

To achieve these goals, the grantee conducts program activities with Iraqi political parties, civil 

society groups, and members of the Iraqi government: 

 Trainings included voter contact campaign training for political party members and grant 

management training for sub-grantees. 

 Study missions included a trip for nine Iraqi civic activists to Morocco to expose them to 

strategies and techniques that Moroccan civil society organizations have used 

successfully to mobilize their communities and conduct advocacy campaigns that address 

issues of local, regional, and national concern. 

 Sub-grants were also awarded to Iraqi organizations to accomplish grant goals. 

See Figure 1 for a photo of grantee training on media relations for female political party 

members. 

Figure 1—NDI Training for Grant 210 

Source: NDI 1/2008. 
7 

Objectives 

SIGIR’s objectives are to examine NDI’s $50 million DRL grant for the reasonableness, 

allocability, and allowability of the grantee’s claimed security costs, and the extent to which the 

grantee documented its success in achieving governance, political participation, and civil society 

goals and objectives. For a discussion of the audit scope and methodology, see Appendix A. For 

a list of SIGIR’s review of supporting documentation for grantee activities, see Appendix B. For 

information on the grantee’s assessment of grant 210 completion status as of April 30, 2010, see 

Appendix C. For a list of acronyms used in this report, see Appendix D. For a list of the audit 

team members, see Appendix E. For Department of State, Bureau of Democracy, Human 

Rights, and Labor comments, see Appendix F. For the SIGIR mission and contact information, 

see Appendix G. 
8 

Security Costs Generally Appropriate though DoS 

Oversight Is Limited and Indirect Costs Questionable 

NDI security costs charged to the grant were generally reasonable, allocable, and allowable, but 

existing DoS mechanisms were not sufficient to monitor NDI’s financial performance and detect 

a potentially erroneous charge for overhead costs. SIGIR found that NDI appears to have 

charged more overhead costs for security contract administration than allowed which reduces the 

amount of funds available for direct program activities. Grantee officials stated that they were 

operating in good faith and sought to ensure the appropriateness of their approach by maintaining 

regular communications with USAID indirect cost negotiators. However, neither USAID nor the 

DoS GO was aware of how NDI was applying its security contract indirect cost rates. Moreover, 

required annual audits and progress reports provided only limited insight into grantee financial 

management practices. DoS officials stated that GOs will take a more active role in overseeing 

awards in the future, and AQM recently received authority to hire additional staff. Until that 

occurs, DoS will not be providing the level of oversight its internal policy manual, and sound 

management practices, require. Unless a more in-depth audit is conducted, DoS would be unable 

to determine whether any funds should be recouped. 

Security Costs Appear To Be Reasonable, Allocable, and Allowable 

Our review of NDI’s financial management of its security costs for grant 210 indicates that the 

costs incurred were generally reasonable, allocable, and allowable, as defined by OMB Circulars 

A-110 and A-122. Regarding the reasonableness of the costs, NDI took specific measures to 

ensure that the security costs it incurred were not unduly high. NDI awarded its contract to 

Unity Resources Group based on full and open competition and price analyses of the bids 

submitted. To illustrate, NDI submitted a request for proposals outlining its security needs to 

four qualified security vendors. Based on a price analysis between the two vendors responding 

to the solicitation, NDI officials stated that they chose the lowest priced vendor with what it 

assessed to be the best technical solution. Since NDI followed procurement procedures 

contained in OMB Circular A-110, we have concluded that the resulting costs were reasonable. 

Security costs were also appropriately allocated among the grants awarded to the grantee. The 

grantee allocated security costs for services that are shared among its grants to best assure that 

costs are distributed in reasonable proportion to the benefits received from each grant. 

Specifically, NDI informed us that it distributed security costs on the basis of the total value of 

grants active during the month of allocation. To determine if this was the case, we tested the 

accuracy of charges made against grant 210 and the other ongoing grants. To illustrate, in August 

2008, the grantee had three active grants—grant 210 for $50 million, S-LMAQM-08-GR-550 

(grant 550) for $1.8 million, and a National Endowment for Democracy agreement 2008-032 for 

$125,000. It is necessary to include the National Endowment for Democracy agreement in the 

calculation because the work conducted under the agreement received benefits from the security 

contractor. 

The grantee correctly allocated 96.3% of security costs to grant 210 as the value of that grant 

equaled 96.3% of the total value of active NDI grants at that time. Similarly, the grantee 
9 

allocated 3.5% of security costs to grant 550 and 0.2% of security costs to the National 

Endowment for Democracy grant. In doing so, the grantee followed OMB Circular A–122 

which requires that grantees allocate costs among grants according to actual usage.12 

OMB Circular A-122 stipulates costs that are unallowable such as entertainment. To determine 

if the grantee paid for any unallowable costs, we judgmentally sampled 13 of 116 documents 

($1.7 million of $13.5 million NDI security costs claimed) associated with billings from Unity 

Resources Group. These documents included invoices and accounting adjustments. We 

reviewed the documents to determine if any purchases appeared unallowable, according to OMB 

Circular A-122. Our review of the documents did not identify any instances of unallowable 

costs. 

Indirect Costs Appear To Have Been Overcharged 

The grantee appears to have charged more indirect, that is, overhead costs, for security contract 

administration than allowed in its 210 grant agreement. Indirect costs in this case would include, 

for example, headquarters costs associated with administering the security contract. This is 

important as it reduces the amount of funds available for direct program activities. 

According to a signed agreement between NDI and USAID, the grantee is allowed to recover 

indirect costs associated with the administration of any contracts it awards under grants. To 

ensure that the government is not overcharged for these costs, the agreement limits the amount of 

indirect costs that can be applied annually to contracts awarded using grant funds. Specifically, 

NDI must apply the negotiated indirect cost rate to only the first $25,000 of a contract’s value in 

any given year prior to September 30, 2008, and $75,000 of a contract’s value in any given year 

after October 1, 2008. 

For grant 210, the grantee used an inappropriate methodology and applied the $25,000/$75,000 

ceiling on a task order rather than an annual basis. According to the grantee, the task order time 

periods ranged from three to six months each. The grantee reasoned that the task order it 

received from the contractor should be viewed as an individual contract. This approach resulted 

in the grantee charging its indirect cost rate against $150,000 in fiscal year 2008 and $600,000 in 

fiscal year 2009 rather than $25,000 for fiscal year 2008 and $75,000 in fiscal year 2009 for the 

single contract. 

An example of the results of this practice is the amount the grantee charged for the 

administration of the Unity Resources Group contract in fiscal year 2009. According to the 

negotiated indirect cost agreement, the grantee should have charged 23.9% of $75,000 or 

$17,925 as an indirect cost for all federal grants participating in Unity Resources Group security. 

Instead the grantee charged 23.9% of $398,790 or $95,311 against grant 210 alone. Therefore 

NDI appears to have overcharged the grant $77,386 in overhead costs. In addition to grant 210, 

the grantee had three other grants during fiscal year 2009 that were charged similarly for 

overhead for the administration of the fiscal year 2009 security contract. 

 

12 OMB Circular A–122, Cost Principles for Non-Profit Organizations, Attachment A, Paragraph A.4. 
10 

NDI officials said that they discussed their approach for charging indirect cost rates with the 

appropriate USAID official and that their decision to charge indirect costs to each task order was 

based on those discussions. We discussed this approach with the USAID indirect cost negotiator 

who set the rate. This official informed us that a contract is for a specific period of performance, 

and each task order is not a separate contract. He stated that in his view, the grantee’s 

interpretation is incorrect and unallowable. 

The apparent overcharging of indirect costs by NDI mirrors our finding from our previous report 

on IRI; we found that IRI also appeared to have overcharged for these costs. In both cases the 

organizations developed methodologies to calculate indirect costs that the USAID officials who 

set the rates said were inappropriate. 

DoS Oversight and Monitoring Needs To Be Improved 

Although SIGIR found that NDI was generally a good steward of grant security funds, existing 

DoS oversight and monitoring mechanisms would not have been able to prevent, or detect, any 

potentially questionable costs. In the Federal Assistance Policy Manual DoS identifies the 

various alternative methods of performing financial monitoring based upon a risk assessment of 

the grantee such as direct monitoring by telephone or letter, review of financial and progress 

reports, performing site visits of the grantee and performing audits. However, neither the GO 

nor the GOR developed and implemented a monitoring plan for NDI utilizing these methods. 

This situation occurred for a variety of reasons. First, the GO was not sufficiently involved in 

grantee decision making. For example, AQM informed us that it did not know how the grantee 

was applying indirect cost rates and had not received any GOR analyses on grantee quarterly 

reports. Also, severe staff shortages inhibited their ability to actively engage with the grantee. 

According to the AQM Grants Team Lead, in 2007 and 2008, while this grant was active, the number 

of GOs decreased from five to one. While the number of GOs has since increased, adequate staffing 

remains a problem with each officer responsible for approximately 250 open grants. AQM recently 

received authority to hire additional GOs. Moreover, in response to our July 2010 report13 on 

management of the grant to IRI, AQM stated that it was taking steps to address the need for 

adequate GO staffing of DRL grants. 

Financial information available to DoS was also insufficient to detect questionable costs. As 

discussed in a previous audit report, the periodic financial reports that OMB requires were not 

designed to achieve this purpose.14 While the grantee provided DoS with a detailed budget plan 

outlining the anticipated costs to perform the grant objectives, the quarterly reports required by 

OMB provided only a summary figure on expenditures against the grant. Without more detailed 

information, the Department would be unaware of expended line items versus grantee 

performance. 

Additionally, to date, the GO has not visited either NDI headquarters in Washington, D.C. or 

operations in Iraq. Such visits would allow the GO to determine whether the grantee is in 

compliance with applicable OMB Uniform Administrative Practices and the Terms and 

Conditions of the federal assistance awards. The site visit would allow the GO and NDI to 

 

13SIGIR 10-022. 

14SIGIR 10-012. 
11 

identify any cost items that might need advance agreement. According to the AQM Grants Team 

Leader, the GO was scheduled to conduct a site visit to NDI in fiscal year 2010 but has been 

unable to complete the visit due to other demands. The official stated that the office had 

resources to conduct only a limited number of site visits to grantees and relied on the GOR to 

monitor grantee performance in Iraq. We previously reported15 and note later in this report that 

GOR oversight has also been limited. 

Finally, annual audits of the grantee are at a level that is too broad to identify many of the 

questioned costs that might be identified through a more focused review of individual grants. 

For example, NDI’s annual audit did not question the cost base for charging overhead because 

that issue is much more specific than the issues addressed in the audit. Conducted by private 

Certified Public Accounting firms, OMB Circular A–133 audits are primarily audits of an 

organization’s financial statements and general compliance with OMB circular requirements. In 

addition, the compliance aspect of the audit is done on a risk basis, selecting only major 

programs and examining the highest-risk financial transactions within those programs. Unless 

specifically directed to do so by a funding agency, it is unlikely that an A–133 audit for a large, 

global entity like NDI would cover a particular program or grant. Therefore, the annual audit 

reports, by their nature, would not necessarily provide DoS the detail it needs to monitor a 

particular grant. Unless a more in-depth audit is conducted, DoS would not be in a position to 

make a final determination as to whether any funds should be recouped. 

 

15 SIGIR 10-012. 
12 

Grantee Documented Activities and Some Indicators 

of Impact 

The grantee documented the activities it led to foster democratic goals and objectives in Iraq, and 

conducted some assessments of the progress made toward meeting objectives under grant 210. 

SIGIR confirmed that in most cases the grantee maintained comprehensive information on its 

activities, and the number and type of participants. Moreover, the grantee conducted several 

assessments to gauge the impact of specific activities it undertook to achieve some of the grant’s 

objectives. Nevertheless, the grantee does not have a systematic approach with clearly defined 

metrics to measure the impact of all of its work in meeting grant goals and objectives. DRL 

noted that it continues to take steps to improve monitoring and evaluation. For example, it is 

requiring more comprehensive and empirically based impact assessments and assessing its 

staffing structure to assure it has adequate oversight. NDI officials stated that the organization 

has incorporated DRL’s increased evaluation requirements in a recently awarded grant from 

DRL. Both in-depth assessments and improved DoS oversight will be needed to provide 

decision makers the capability to ensure that activities are designed and implemented to achieve 

program objectives. 

NDI Documents Activities 

The grantee documented activities associated with trainings for its largest grant from DRL with 

agendas, sign-in sheets, training materials, and activity reports provided to clients, including 

DRL. For grant 210, DoS included in the grant award standard terms and conditions requiring 

that the grantee submit program progress reports and suggested that reports include supporting 

documentation or products related to project activities (such as articles, meeting lists and 

agendas, and manuals). However, neither the terms and conditions nor DoS specify what 

documentation must be maintained as support that activities occurred. SIGIR previously 

reported that DRL records contained most of the required reports from the grantee, but the 

grantee did not always include documentary evidence of activities in its reports.16 

Quarterly Reports and Grantee Records Contain Evidence of Activity 

Grantee reports to DRL included some supporting documentation to demonstrate that it 

conducted activities it reported to DRL. The grantee submitted eleven quarterly progress reports 

to DRL since the grant was awarded. These reports contain detailed information on training and 

other actions such as election monitoring, and included photos and results from initiatives such 

as opinion polls the organization undertook. While all the quarterly reports for grant 210 include 

some kind of supporting documentation, the reports did not contain backup documents for all 

activities. According to grantee officials, this is to lessen the burden on DRL because of the 

number of activities and the volume of documentation. 

As of December 31, 2009, the grantee reported it had conducted 311 activities for more than 

5,000 Iraqi participants, including trainings, meetings with Iraqi officials, and study missions in 

 

16 SIGIR 10-012. 
13 

support of the objectives for grant 210, according to a grantee official. The official stated NDI 

has conducted 9 additional activities for 368 participants since December 2009. 

SIGIR judgmentally selected for review 32 of the 311 (approximately 10%) grantee-recorded 

trainings that were completed as of December 2009. The grantee provided some kind of 

documentation for each activity though SIGIR found some variation in the type of 

documentation provided as support. To illustrate, the grantee provided sign-in sheets for 26 of 

the 32 sampled activities. Of the six activities without sign-in sheets, two were study missions 

abroad for which the grantee was able to provide trip reports with participant names and receipts 

for airfare and lodging paid for participants. The remaining four activities without sign-in sheets 

were for meetings with one or a small group of Iraqi officials that would not necessarily require 

sign-in sheets since the number of participants was small. Grantee records for five multi-day 

activities were missing at least one sign-in sheet and support for one activity included only a 

printed list of participants without signatures. 

In addition, grantee records included agendas of activities for 21 of the 32 sampled activities. 

The grantee did not provide agendas for the four meetings with one or a small group of Iraqi 

officials. The grantee also did not provide agendas for seven other activities, including proposal 

development training for potential sub-grantees and budget analysis overview training. Records 

for these activities, however, included other supporting documentation, such as participant 

signatures for per diem received and training materials. During our site visit to NDI’s offices in 

Erbil, we observed an NDI session with sub-grantees reviewing results of voter education efforts 

leading up to the March 2010 election. During that session, we observed NDI staff obtaining 

signatures from participants and then providing them money for travel and other expenses. 

The grantee did not always have materials such as training slides or information given to 

participants to demonstrate exactly what training took place. The grantee had some other types 

of supporting material for 14 of the 32 sampled activities. In addition, of the 32 total activities, 

7 were meetings or other activities like focus groups with individuals or small groups, which 

would not necessarily require materials like training slides. However, 11 of the 32 activities 

involved training or study missions abroad where one would reasonably expect that the grantee 

had developed course materials. SIGIR is not raising this issue as a concern, however, because 

neither the grant terms and conditions nor DoS specified what type of documentation the grantee 

must maintain as support and because the grantee maintained some type of documentation for 

each activity. See Appendix B for the detailed results of SIGIR’s document review. 

NDI Provides Information beyond Grant Requirements 

NDI provided information more frequently and in greater detail than the grant required. In 

addition to the quarterly reports required by the grant agreement, NDI provided DRL with 

regular reports designed to summarize activities for stakeholders. These reports, initially 

provided weekly but now on a monthly basis, provide information on activities, participants, 

justification for activities any effect the activities may have on other program elements. NDI 
14 

also contributed accomplishment reports for use by DoS in its regular reporting to Congress, 

which were provided until early 2009, according to grantee officials.17 

According to an NDI official, in February 2010, NDI started using a centralized database to track 

information on whether the planned activities for each grant objective had been completed and 

information as to why certain grant activities may not have been completed or are currently 

unfulfilled. According to the GOR, NDI officials provided information from this database when 

requesting a no-cost extension for the grant. Prior to development of this database, the NDI 

program offices individually tracked information on their activities, but the grantee did not 

collect or summarize this information for the grant as a whole. This new tool allows NDI to 

capture the status of its work, identify gaps, and better plan future work. 

To illustrate, NDI proposed activities in 37 broad categories under the 5 objectives of the grant. 

As of April 2010, it had completed 15 of the 37 planned activities. For example, NDI data 

showed that it had completed 7 out of 13 trainings and other activities required to address its 

objective to strengthen democratic political institutions to facilitate effective governance. On the 

other hand, as shown in Table 3, the data showed that no planned activities to promote increased 

participation of youth in the political process had been completed to address Objective C of the 

grant. Table 3 summarizes the results of NDI’s assessment of completed activities under 

grant 210, as of April 2010. Appendix C contains a complete list of the grant activity status, 

including which activities were assessed as complete, ongoing, incomplete, or unfulfilled. 

Table 3—Completion of Grant 210 Objectives and Activities, as of April 2010 

Activity as Described in Grant Proposal Complete

Objective A: Strengthen democratic political institutions to facilitate effective pluralist 

governance. 

Legislative process - budget analysis, rules of procedure, committee strengthening, 

strategic planning, protocol trainings 

Legislative process - develop and publish legislative drafting manual -

Legislative process - training for Council of Representatives Finance Committee, Budget 

Office 

Legislative process - public hearings -

Legislative process - staff training for Council of Representatives, Council of Ministers 

Secretariat, and the President's Office -

Constituency outreach for Council of Representatives and political parties -

Seminars for non-governmental organizations on gauging public opinion and mobilizing 

civic action 

Support civic group composed of former NDI staff in Baghdad -

Support the development of issues-based coalitions of civic groups 

Political party training on internal democratic practices 

 

17 Section 2207 of the Emergency Appropriations Act for Defense and for the Reconstruction of Iraq and 

Afghanistan, 2004, (P.L. 108-106) required that OMB submit a quarterly report to Congress on the status of Iraq 

Relief and Reconstruction Funds expenditure. Submission of these reports is no longer required. 
15 

Activity as Described in Grant Proposal Complete

Political party training on internal and external communication 

Political party training on organizing conventions and congresses -

Political party training on utilizing media 

Objective B: Provide a neutral space for political opponents to engage in inclusive dialogue and 

decision-making. 

Coalition-building training for political parties -

Council of Representatives study missions 

Community Mobilization Program -

Political party negotiation and conflict resolution training 

Conflict resolution forum in Kirkuk 

Objective C: Promote increased participation of youth in political processes. 

Focus group research on youth attitudes -

Civil society youth training series -

Multi-party Youth Training Academy -

National forum for Youth Training Academy graduates -

Advanced Youth Political Party Organizers Academy -

Annual model youth parliament -

Objective D: Promote increased participation of women in political processes. 

Support the development of a parliamentary women's caucus 

Capacity-building training academy for female legislators -

Build networking capabilities of female activists and civil society organizations to build 

advocacy capacities 

Support and disseminate research on status of women's rights -

Objective E: Support the neutral observation of elections and strengthen party organizational 

skills. 

Election monitoring for provincial elections 

Election monitoring for constitutional amendment referendum -

Produce videos on election observation, constitutional review, and role of provincial 

councils -

National conference in Baghdad to present results of provincial elections -

Media monitoring training for provincial and constitutional elections -

Political party campaign training for provincial elections 

Party agent training for provincial elections -

Party code of conduct for provincial elections -

Political party training on candidate selection 

Source: SIGIR Analysis of NDI information, April 2010. 
16 

Department of State Has Limited Oversight of NDI’s Grant Activities 

SIGIR previously reported that GORs communicate regularly with grantees, but the frequency 

and length of site visits has been affected by limited DRL staffing, travel cost considerations, 

security, and country clearance restrictions.18 As of April 30, 2010, the GOR assigned the NDI 

grant had responsibility for 12 grants which, including grant 210, totaled approximately 

$197.4 million. DRL gains additional insight to grantee activities through two DRL democracy 

advisors in Iraq who communicate with and visit NDI’s office in Erbil. In addition, GORs 

assigned to other grants have also made site visits to NDI, since the number of site visits by the 

assigned GOR has been limited due to the reasons mentioned above. However, the democracy 

advisors and GORs assigned to other grants do not conduct formal oversight of NDI. The 

current GOR has made only one visit to Iraq and neither the GOR nor democracy advisors have 

reviewed grantee documents to determine if there is support for NDI’s quarterly reports to DRL. 

In addition, the GO for NDI’s grants has not conducted any visits to NDI, either in the U.S. or in 

Iraq. GOs attribute their lack of site visits to the large number of grants they must monitor. 

According to these officers, their large workload forces them to rely on the DRL GORs to 

identify issues and bring them to the GO’s attention. 

NDI officials noted that despite limited site visits, they maintain regular communication. 

According to the officials, emails and telephone conversations provide the GOR with 

information on activities and help assure the GOR that the grantee is making progress in meeting 

objectives. The officials also noted that grantee staff based in Washington, D.C. has regular 

meetings with the GOR. 

NDI Conducted Some Impact Assessments 

NDI has made progress in assessing the impact of its work. According to the Federal Assistance 

Policy Manual, impact is defined as the cumulative or net effect of the outcomes or results, and 

there is an abiding U.S. government interest in measuring the success of programs supported by 

federal funds. The grant agreement requires that impact analyses be included in quarterly 

reports. 

Grantee Quarterly Reports 

SIGIR reported in January 2010 that the grantee’s progress reports to DRL did not contain 

assessments of the impact of grant activities.19 Since we completed our analysis for that report, 

the grantee has submitted four quarterly progress reports to DRL. These reports, submitted 

between October 2009 and July 2010, contain detailed information, including photos, results 

from initiatives like polling, and some assessments of grantee activities. In each of the four 

reports, the grantee described assessments of grant impact and success in meeting grant 

objectives but did not always provide qualitative or quantitative results demonstrating their 

success in bringing about positive change. 

For example, NDI reported on the impact of its efforts under the Women’s Empowerment 

Program and the Youth Empowerment Steps. NDI stated in its March 2010 quarterly report that 

 

18SIGIR 10-012. 

19SIGIR 10-012. 
17 

it had assessed the results of the Women’s Empowerment Program under which it trained 

approximately 50 women in 5 training modules from February 2008 through November 2009. 

The training modules focused on management of non-governmental organizations, grant 

proposal development, advocacy, negotiation and conflict resolution, and media skills. To assess 

impact, in March 2010 NDI conducted individual interviews with 30 participants to determine 

what they had done since completing training, identified how the training had affected the lives 

of the women, and gathered feedback to inform future program design. Among the stated 

results: 

 Approximately one quarter of the women interviewed reported that the Women’s 

Empowerment Program helped advance their training skills and professional 

responsibilities. 

 Approximately one third of the women interviewed stated they used strategies from the 

grant proposal development session to apply for funding from international organizations. 

As an example, one participant was successful in receiving funds from the United 

Nations and the USAID. 

 Four participants noted that they became leaders in their organizations. 

 One participant stated that she used skills learned in the advocacy session during her 

successful campaign for a seat in the Council of Representatives. 

Conversely, in the previous quarter, NDI reported it consulted with 14 members of the Council 

of Representatives’ senior executive leadership and technical advisors twice but did not discuss 

the impact these meetings had. For example, the report stated that during the first meeting 

participants identified obstacles to the effective functioning of the Council of Representatives, 

and that the second session was intended, in part, to assess the progress made by the participants 

since the initial gathering. However, the quarterly report did not provide any qualitative or 

quantitative data demonstrating any progress other than a statement that officials who 

participated in the initial session noted that they were successful in applying NDI’s 

recommendations. Such nebulous statements, however, do not provide the empirical evidence 

necessary to assess the program’s impact. 

According to grantee officials, the anticipated impact from this activity has not yet been 

achieved, due to a variety of political reasons, including the lack of a new government. They 

noted that NDI continues to follow-up on these consultations and is anticipating impact. They 

also stated that under a different DRL grant, NDI conducted an assessment of the workings of 

the Council of Representatives that among other things, demonstrated contributions from these 

meetings. 

Limited Monitoring and Evaluation Plan Contributed to Problems in Assessing Impact 

NDI’s monitoring and evaluation plan did not contain metrics to enable the grantee to assess 

impact. DRL’s request for proposals that resulted in the award grant 210 to NDI states that for 

each of the proposed programs conducted under the grant, the recipient should be able to assess 

impact and provide long- and short-term goals with measurable outputs and outcomes. The 

request defines outcomes as specific results a project is intended to achieve that are usually 

measured as an extent of change. The request also states that proposals would be judged in part 
18 

on the merit of the proposed program evaluation plan. In addition, the grant agreement for 

grant 210 from DRL states grantee quarterly progress reports should reflect the grantee’s 

continued focus on measuring project impact on the overarching goals or problems the projects 

set out to address. Assessment of overall impact and/or incremental impact, as appropriate, 

should be included in each quarterly progress report. DRL defines impact as a change in social, 

economic, or civic condition. 

In its application to receive grant 210, NDI stated it would evaluate progress toward its 

objectives by meeting regularly with partners to receive comments and critiques, collect press 

clippings and public announcements, and elicit feedback from participating national and 

international experts. NDI stated it would also measure progress toward indicators that 

demonstrate impact through techniques such as participant evaluations of classes and other 

activities, questionnaires regarding participant opinions of grantee activities, consultations with 

partners and donors, and development and use of focus group research. To achieve such 

analyses, NDI developed 33 indicators20 for 5 grant objectives that it stated would show progress 

toward meeting the objectives. However, not all of the indicators were measurable, and 

assessing progress may not necessarily address the larger issues of program outcome or the 

impact it is having in making substantive changes. For example, for meeting the objective of 

strengthening democratic political institutions to facilitate effective pluralist governance, NDI 

expected its work to result in Iraqi activists gaining more consistent access to government and 

political parties to advocate on behalf of their communities. However, NDI did not describe any 

techniques for measuring “access” or how any increase in access is ultimately strengthening the 

political institutions. The limitations of this approach were noted by one DoS panelist reviewing 

the proposal who stated that assessments relied heavily on output-oriented information, such as 

number of participants trained, and the proposal lacked information on how the grantee would 

measure impact. Table 4 provides grant objectives and NDI’s indicators of progress. 

 

20 NDI presented these indicators in its evaluation plan as a means by which the organization would be able to 

determine success in meeting grant objectives. These differ from the 37 broad categories of activities noted earlier 

in this report. The activities were conducted to accomplish grant objectives while the indicators would demonstrate 

impact. 
19 

Table 4—Grant 210 Proposal Objectives and Indicators of Progress 

Objectives and Indicators 

Objective A: Strengthen democratic political institutions to facilitate effective pluralist 

governance 

 Leadership and members of the Council of Representatives use both formal and informal means 

of exchanging information about policy issues and upcoming legislation 

 Key committees of the Council of Representatives consult with relevant outside experts, civil 

society organizations, and executive branch counterparts on policy and legislation 

 Leadership and Members of the Council of Representatives are informed of and follow the rules 

of procedure 

 Members of Parliament reach out to organizations in policy discussions and consider constituent 

input 

 Iraqi activists gain more consistent access to government and political parties to advocate on 

behalf of their communities 

 Iraqi non-governmental organizations directly engage policy makers on issues central to the 

development of democracy in Iraq through direct meetings, public education, and advocacy 

campaigns 

 Selected Iraqi non-governmental organizations effectively undertake public advocacy activities 

 Selected civic organizations enhance their organizational structures to more effectively work 

towards community needs 

 Selected political parties work toward political collaboration 

 Selected political parties develop more democratic internal practices 

 Selected political parties support public policies that further democratic objectives 

 Selected political parties more effectively engage independent media 

 Selected parties plan and implement effective party conventions 

Objective B: Provide a neutral space for political opponents to engage in inclusive dialogue and 

decision-making 

 Political parties in Parliament form collaborative relationships that allow for internal debate and 

democratic decision-making, express the views of their constituents, and are instrumental in 

shaping policy and legislation 

 Study mission participants participate in constructive dialogue and build partnerships 

 Iraqi civic activists convene to identify local community issues and design cooperative responses 

for positive change 

 Iraqi non-governmental organizations develop a non-sectarian advocacy agenda around issues of 

public concern 

 Iraqi partners use negotiation skills learned in NDI training during debate and discussion 
20 

Objectives and Indicators 

Objective C: Promote increased participation of youth in political processes 

 Youth civic and political party leaders play an active role in policy formation 

 Civic organizations focus on advocating for increased youth political participation 

 Youth build collaborative relationships and coalitions across sectarian lines 

 Youth gain leadership positions with in select political parties and civic organizations 

Objective D: Promote increased participation of women in political processes 

 Women members of parliament, civic leaders and political party activists play an active policy 

formation role in parliament, civic organizations, and in political parties 

 Civic organizations effectively advocate for gender issues and representation 

 Women gain leadership roles with in the Council of Representatives, political parties, and civic 

organizations 

 Select civic organizations and political parties reach out to women throughout the country 

Objective E: Support the observation of elections and strengthen party organizational skills. 

 Civic organizations and political parties develop poll watcher plans that include deployment, 

election day communication, results tracking, and analysis of poll watcher information 

 Civic organizations actively monitor the media for bias 

 Election results as gathered by civic activists are accurately and effectively disseminated to the 

media, to citizens, and to members of the government 

 Select political parties develop campaign plans that include party constituency input 

 Select political parties develop and implement a non-violence code of conduct 

 Select political parties deploy party agents on election day and accurately monitor, report, and 

disseminate results of the election 

 Select political parties incorporate considerations of merit and diversity (especially gender) in 

candidate selection 

Source: SIGIR Summary of NDI information, August 5, 2007. 

Continuing Steps To Improve Impact Assessments 

SIGIR recognizes that collecting information and measurements in Iraq to show impact is 

challenging. According to the GOR and grantee officials, it can be difficult for grantees to 

demonstrate impact because progress toward goals and objectives is often subjective, some 

activities may not immediately effect change, and observation of change may be delayed even 

beyond the life of the grant. The GOR further indicated that the lack of available data in Iraq has 

hindered grantees in establishing a baseline against which they can measure progress. According 

to an NDI official, the organization has taken steps to improve its assessments of all of its work 

in Iraq in part in response to our January 2010 report on DRL management of grants to NDI and 
21 

IRI.21 In that report, we stated the grantee has not provided DRL with information on grant 

impact. 

For example, the grantee is assessing the status of various aspects of Iraqi society to serve as 

baseline data from which the organization will be able to assess the impact of its work and plan 

future work. According to an NDI official, in February 2008, it evaluated the status of the four 

political parties that partner with the organization in areas such as party structure and operations. 

The official reported that the organization used this assessment to provide the parties with 

targeted, party-specific assistance, including internal strategy development, guidance to ensure 

the parties effectively function as political organizations, and assistance in developing 

substantive platforms. The official noted that the grantee is currently conducting a follow-up 

assessment, examining what strategies these parties undertook for the March 2010 election, 

which groups they partnered with, and what results they had after the election. On an even more 

macro scale, both an NDI official and reports indicate that it is assessing specific aspects of Iraqi 

civil society to identify positive developments, challenges, and areas of potential grantee 

influence such as for non-governmental organizations. 

NDI plans to complete a final report when grant 210 expires. According to a NDI official, at that 

time, it will determine what information it needs to include in its final report to DRL. The 

official said she expects the report will have some summary of information from quarterly 

reports, but will also include an overall assessment of grant 210 and its impact. She said this 

assessment should demonstrate the activities the grantee completed under the grant and the 

accomplishments and impact the grantee has observed or gathered from other sources. 

Considering that final progress reports are due 90 days after the grant expires and the grantee 

was recently awarded a no-cost grant extension to March 31, 2011, the final report would not be 

provided to DRL until June 30, 2011. 

Plans To Assess Impact of Future Grants 

In SIGIR’s July 2010 report on DoS's management of IRI grants, we reported that DRL officials 

were taking steps to improve the quality of their evaluation process and determine methods to 

measure the impact of grant programs and assess the overall impact of DRL’s work.22 In that 

report, we noted that in March 2010, DRL published on its website updated proposal submittal 

instructions and included a monitoring and evaluation plan primer with a sample monitoring and 

evaluation plan. The primer states that all proposals being considered for DRL funding must 

include a comprehensive monitoring and evaluation plan. Monitoring and evaluation plans 

consist of indicators with baselines and targets; means for tracking critical assumptions; plans for 

managing the data collection process; and regular collection of data. Grantees should schedule 

and carry out evaluations throughout the course of the program. Plans should include 

performance indicators linked to the program’s strategic objectives with performance measures 

that are specific, measurable, attainable, realistic, and timely. DRL also selected standard 

output-oriented indicators developed by DoS Office of Foreign Assistance under the Foreign 

Assistance Framework.23 The primer states that grantees are required to report on relevant DRL 

 

21SIGIR 10-012. 

22SIGIR 10-022. 

23 The Foreign Assistance Framework is part of the Fiscal Year 2007-2012 Department of State and USAID 

Strategic Plan, 5/7/2007. 
22 

indicators in addition to their own program-specific indicators by each quarter and cumulative 

over the life of the grant. According to an NDI official, DRL’s new monitoring and evaluation 

requirements have been incorporated into recent grants. 

In addition, in our January 2010 report, we recommended that DoS examine DRL’s personnel 

and operations to determine whether the Bureau of DRL is structured and staffed in both 

headquarters and overseas to effectively and efficiently oversee the grants under its 

responsibility.24 According to DRL officials, the office hired a dedicated staff member to lead 

DRL-wide monitoring and evaluation efforts. The office also developed a new internal template 

to provide more comprehensive guidance to GORs responsible for quarterly impact assessments. 

DRL also drafted a new grant memo designed to require greater quarterly financial reporting 

detail, including more explicit instructions about how grantees should detail program progress as 

it relates to the objectives and how grantees should link progress back to their monitoring and 

evaluation plans. DRL also provided guidance to its democracy advisors to clearly define 

oversight roles and integrate these officials with Washington-based oversight efforts. The DRL 

officials said the office organized an internal monitoring and evaluation working group that 

helped develop the new protocols; and DRL program officials and GORs have been spending 

more time with their grantees to strengthen monitoring and evaluation plans before agreements 

are signed. 

 

24SIGIR 10-012. 
23 

Conclusions and Recommendations 

Conclusions 

Federal regulations require less day-to-day government oversight and accountability for grants 

than for contracts. Nevertheless, both NDI and DoS have distinct responsibilities to ensure that 

grant funds are used in accordance with the terms of the grant and OMB regulations. Funds 

should be spent efficiently and effectively to meet grant objectives. In the case of this grant, 

NDI was generally a good steward of security funds although we question whether the 

organization’s charges for indirect security costs are allowable in accordance with USAID 

direction. Additionally, NDI has taken steps to improve its assessments of the extent to which 

their programs were meeting grant goals and objectives. These evaluation efforts are a good start 

but it remains incumbent on the organization to fully demonstrate how its activities are meeting 

the specific goals and objectives of the grant to foster democratic development in Iraq. Without 

such analyses, it is not possible to determine if the U.S. investment is having the desired impact. 

DoS oversight of the grant was limited. To date, the agency has not fully overseen grantee 

efforts. DoS was not in a position to determine whether the grantee was using funds 

appropriately. For example, the Department could not determine if NDI overcharged indirect 

costs at the expense of direct program activities. Nor could DoS determine the extent to which 

NDI made progress in meeting grant goals and objectives. This occurred for a variety of reasons 

that we have pointed out in this and previous reports, addressing DoS oversight of not only NDI 

but also IRI grants. An insufficient number of oversight personnel, insufficient knowledge on 

the different roles and responsibilities among the various DoS oversight offices, and less-thancomprehensive audit and financial reporting were major contributing factors. Both DRL and 

AQM have stated that in response to our work, they plan to strengthen their grant management. 

DRL’s recent requirement that grantees provide more comprehensive impact assessments and 

AQM’s plan to hire additional GOs are steps in the right direction. 

We found similar problems in DRL and AQM management and for grantee methodologies to 

determine what costs were allowable, allocable and reasonable for the NDI grant and an IRI 

grant addressed in a previous report. Given that these problems are manifested in at least two 

grants for two different organizations, it is likely that the problems persist to various extents for 

other grants these, and other organizations, receive. 

Recommendations 

To improve DoS grant management, SIGIR is repeating two of the recommendations we 

previously made regarding DoS management of grants to IRI which are applicable in the case of 

NDI with only minor modifications. We are recommending that the U.S. Secretary of State 

direct offices as she determines appropriate to take the following actions: 

1. Require the Grants Officers to instruct NDI to incorporate in its next A–133 audit a 

comprehensive audit of indirect costs and a compliance audit for at least one major DRL 

grant. Given the similar problems we found in IRI and NDI grants, we also recommend that 
24 

Grants Officers consider requiring these more comprehensive A-133 audits for all DRL 

grants. 

2. Require the Grants Officer Representatives to enforce the grant requirements that NDI 

provide measurable indicators of their success in meeting grant goals and objectives. 
25 

Management Comments and Audit Response 

In written comments on a draft of this report, DRL incorporated input from AQM and concurred 

with the draft report recommendations. Specifically DRL stated the Grants Officer will issue a 

letter to NDI requiring that its next A-133 audit present supporting calculations for indirect costs 

and that one major DRL program have a compliance audit. In addition, DRL stated it will 

continue to work with NDI to ensure that it devises an effective evaluation regime that includes 

useful and measurable indicators for grant 210. 

DRL’s comments are reprinted in their entirety in Appendix F. SIGIR also incorporated 

technical comments from DRL, AQM, and NDI, as appropriate. SIGIR believes that the actions 

identified by management, if properly implemented, are responsive to this report’s 

recommendations. 
26 

Appendix A—Scope and Methodology 

Scope and Methodology 

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

Project 1007b to examine the United States Department of State Bureau of Democracy, Human 

Rights, and Labor’s (DRL) management and oversight of democracy-building grants to the 

National Democratic Institute (NDI). SIGIR’s objectives are to examine the reasonableness, 

allocability, and allowability of NDI’s claimed security costs, and the extent to which the grantee 

documented its success in achieving grant goals and objectives for its largest grant from DRL in 

Iraq. We performed this audit under the authority of Public Law 108-106, as amended, which 

also incorporates the duties and responsibilities of inspectors general under the Inspector General 

Act of 1978. SIGIR conducted its work during February through June 2010 in Baghdad, Iraq 

and Arlington, Virginia. 

We first obtained and reviewed all grant documents, interviewed DRL, U.S. Agency for 

International Development, U.S. Embassy Baghdad, and grantee personnel in Washington and in 

Iraq. We obtained and reviewed budget and cost data submitted by the grantee. 

We obtained and reviewed relevant criteria, including Office of Management and Budget (OMB) 

Circular A–110, OMB Circular A–122, and OMB Circular A–133. To review the 

reasonableness, allocability, and allowability of security costs reported by the grantee under 

grant S-LMAQM-07-GR-210 (grant 210), we selected a judgmental sample of invoices 

submitted by the grantee’s security contractor from a schedule of security costs provided by the 

grantee. We then reviewed the contracts issued by the grantee to the security firm to determine 

its compliance with federal regulations as well as any applicable grantee policies and procedures. 

We then reviewed the grantee’s internal controls over contractor performance as well as invoice 

processing. 

To determine the extent to which the grantee assessed the impact of grant 210, we interviewed 

grantee and DRL personnel in both Iraq and Washington, D.C. and reviewed the grantee’s 

quarterly progress reports. To confirm grantee reporting of activities under grant 210, we 

judgmentally selected a sample of approximately 10% of grantee activities conducted under the 

grant and reviewed the grantee’s supporting documentation, including sign-in sheets, agendas, 

and training materials. In addition, we visited grantee headquarters in Erbil, Iraq, where we 

reviewed documentation, interviewed staff, and attended one of NDI’s workshops with subgrantees, performed under another grant. 

We conducted the audit in accordance with generally accepted government auditing standards. 

Those standards require that SIGIR plans and performs 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. 
27 

Use of Computer-processed Data 

We used computer-processed data in this report. The grantee provided security cost data in a 

report from their accounting system, Deltek. In our previous audit, grantee officials stated they 

have not modified the software. We reviewed source documents and gathered other evidence to 

confirm that the data was accurate. We did not review these systems but consider the data 

sufficiently reliable for the purposes of the audit objectives. 

Internal Controls 

We reviewed DRL internal control procedures to oversee and manage these grants. Specifically, 

SIGIR identified and assessed internal controls the grantee used in managing grant costs and 

activities. The results of the review are presented in the report. 

Prior Coverage 

We reviewed the following reports by SIGIR and the Government Accountability Office: 

Special Inspector General for Iraq Reconstruction 

Improved Oversight Needed for State Department Grants to the International Republican 

Institute, SIGIR 10-022, 7/29/10.

Department of State Grant Management: Limited Oversight of Costs and Impact of 

International Republican Institute and National Democratic Institute Democracy Grants, SIGIR 

10-012, 1/26/10.

Opportunities To Enhance U.S. Democracy-Building Strategy for Iraq, SIGIR 09-001, 10/22/08. 

Government Accountability Office 

Grants Management: Enhancing Performance Accountability Provisions Could Lead to Better 

Results, GAO-06-1046, 9/06. 

Rebuilding Iraq: U.S. Assistance for January 2005 Elections, GAO-05-932R, 9/7/05. 
28 

Appendix B—Supporting Documentation Review 

Results 

Table 5—Grant 210 Supporting Documentation 

Training Description

Noted in 

Quarterly 

Reports

Agenda 

in File

Sign-In 

Sheet in 

File

Training 

Material

Voter contact campaign training    - 

Youth round table  -  N/Aa

Party leader meeting  N/Aa N/Aa N/Aa

Training in election monitoring    - 

Budget analysis and oversight training  -  

Political Training Academy module 4 training    

Public analysis and exploration of interests training  -  - 

Intensive Political Training Academy    - 

Meeting  N/Aa N/Aa N/Aa

Media (Spokesperson) training    - 

Grant management training  -  - 

Community mobilization training of trainers    - 

Consultative session    

Democracy steps training of trainers    

Constituency outreach training    - 

Campaign development series modules 1 and 2    

Women’s Empowerment Program (group 1, 

module 3 – conflict resolution)

   

Conflict resolution training    

Proposal development training  -  - 

Focus group presentation  -  N/Aa

Campaign development mini-series    

Bosnia study mission   - - 

Strategic planning session    N/Aa

Grant management training second round sub-grant 

recipients

   

Session  N/Aa N/Aa N/Aa

Meeting  N/Aa N/Aa N/Aa

Sub-grant program proposal development  -  - 

Youth Empowerment Program/advocacy training-    
29 

Training Description

Noted in 

Quarterly 

Reports

Agenda 

in File

Sign-In 

Sheet in 

File

Training 

Material

north region

Independent Tribal National Gathering, National 

Reform Trend, & Iraqi Islamic Party field 

organization/offices training (Political Academy for 

female party activists) 

   

Islamic Supreme Council in Iraq Youth 

Empowerment Steps program training 

   

Study mission to Morocco   - 

Debriefing session with study mission participants    

Total 32 21 26 14 

Note: 

a N/A refers to non-applicable items that would not be associated with an activity. For example, a meeting with one individual would not 

necessitate an agenda, a sign-in sheet, or any training material. 

Source: SIGIR analysis of NDI data, as of 12/31/2009. 
30 

Appendix C—NDI Assessment of Grant 210 

Completion Status 

Table 6—Status of Grant 210 Objectives and Activities, as of April 2010 

Activity as Described in Grant 

Proposal Activity as Implemented and Results Status 

Objective A: Strengthen democratic political institutions to facilitate effective pluralist 

governance. 

Legislative process—budget 

analysis, rules of procedure, 

committee strengthening, 

strategic planning, protocol 

trainings 

Legislative Drafting Training for Council of 

Ministers Secretariat and Presidency Bureau 

(November 2007), Strategic Planning for Council 

of Ministers Secretariat (August 2008), Capacitybuilding Training for Committees (10 sessions), 

Capacity-building with Research Directorate 

Completea 

Legislative process—develop 

and publish legislative drafting 

manual 

Rules on legislative drafting to be completed Incompletec 

Legislative process—training for 

Council of Representatives 

Finance Committee, Budget 

Office 

6 budget analysis trainings (November 2007, 

December 2008, January 2009) 

Completea

Legislative process—public 

hearings 

Manual on public hearings to be completed Incompletec

Legislative process—staff 

Training for Council of 

Representatives, Council of 

Ministers Secretariat, and the 

President's Office 

Council of Representatives Economic Committee 

(March 2008), Office of Vice President Tareq alHashemi (May 2009); Confirm contractor portfolio 

in order to determine training needs 

Incompletec

Constituency outreach for 

Council of Representatives and 

political parties (training, 

constituency templates, 

database, directory of provinciallevel ministers, caucus 

coordination) 

Constituency database training for Da'wa party 

(1 session); development of case-tracking 

database with information technology team in 

Washington, D.C. to be completed 

Incompletec

Seminars for non-governmental 

organizations on gauging public 

opinion and mobilizing civic 

action 

Presented focus group research to civil society 

organizations and political parties; women’s focus 

group conducted December 30, 2007 to 

January 9, 2008; Community Mobilization 

Program, public opinion research sessions, 

estimated completion May 2010 

Completea

Support civic group composed of 

former NDI staff in Baghdad 

NDI was providing technical assistance 

throughout the non-governmental organization 

registration process, but at the end of 2007, the 

non-governmental organization was not 

registered. Work then ceased because the 

organization decided to disband of its own 

volition. 

Unfulfilledd
31 

Activity as Described in Grant 

Proposal Activity as Implemented and Results Status 

Support the development of 

issues-based coalitions of civic 

groups 

Sub-grants disbursed: Round 1 (9 civil society 

organizations); and Round 2 (10 civil society 

organizations) 

Complete 

Political party training on internal 

democratic practices 

Democracy principles training of trainers sessions Completea

Political party training on internal 

and external communication 

Constituency outreach training, voter contact 

training, internal party communication 

Completea

Political party training on 

organizing conventions and 

congresses 

To be determined, based on party assessments 

and interests. This will be part of the postelection assessment process to review 

possibilities for upcoming activities. 

Incompletec

Political party training on utilizing 

media 

Media training, party spokesperson training (Iraqi 

Nation Party, Patriotic Union of Kurdistan, Da'wa, 

Multi-Party Women’s Caucus) 

Completea

Objective B: Provide a neutral space for political opponents to engage in inclusive dialogue 

and decision making. 

Coalition-building training for 

political parties (inside and 

outside the Council of 

Representatives) 

This will be re-examined for appropriateness in 

the post-national election period. 

Unfulfilledd

Council of Representatives study 

missions 

Northern Ireland (October 25-November 3, 2007), 

United Kingdom/European Union Parliament 

(March 2009) 

Completea

Community Mobilization Program 

(initial conference in Erbil, 

trainings on community 

mobilization, conflict 

management, project 

management, study mission to 

Morocco) 

Trainings and Morocco study mission 

(November 8-18, 2009), estimated completion 

August 2010 

Ongoingb

Political party negotiation and 

conflict resolution training 

(3 phases) 

Phase 3 (Phase 1 and 2 reported under different 

DRL grants) 

Completea

Conflict resolution forum in Kirkuk Kirkuk forum: October 24-25, 2007 Completea

Objective C: Promote increased participation of youth in political processes. 

Focus group research on youth 

attitudes 

Youth focus groups (August 15-

September 7, 2007) Reported under another DRL 

grant; Possibly used in trainings under different 

DRL grants 

Unfulfilledd

Civil society youth training series 

(conference, study mission) 

Youth Empowerment Program (Youth for Change 

camp, training, study mission planning 

underway), estimated completion July 2010 

Ongoingb

Multi-party Youth Training 

Academy (5 modules) 

Youth Empowerment Steps—Round 1 complete, 

Round 2 to be completed 

Ongoingb

National forum for Youth Training 

Academy graduates 

 Unfulfilledd

Advanced Youth Political Party Youth Empowerment Steps – Round 1 complete, Ongoingb
32 

Activity as Described in Grant 

Proposal Activity as Implemented and Results Status 

Organizers Academy (trainings, 

study missions, internships) 

Round 2 to be completed 

Annual model Youth Parliament 

(with Council of Representatives 

Sports and Youth Committee) 

Parliament internship program was undertaken. Unfulfilledd

Objective D: Promote increased participation of women in political processes. 

Support the development of a 

parliamentary women's caucus 

Limited consultations and technical assistance to 

the parliamentary women's caucus, which was 

announced in September 2007 with support from 

United Nations Development Fund for Women 

Completea

Capacity-building training 

academy for female legislators 

Broadened scope of activity to conduct political 

academy for female party activists (3 of 

5 modules complete, estimated completion 

September 2010); political academy for female 

Council of Representatives Members of 

Parliament to be completed 

Ongoingb 

Build networking capabilities of 

female activists and civil society 

organizations to build advocacy 

capacities 

Women's Empowerment Program (trainings and 

Jordan study mission) 

Completea

Support and disseminate 

research on status of women's 

rights 

To be determined by mid-2010, only if other 

activities associated with post-election grant 

would benefit from research 

Incompletec

Objective E: Support the neutral observation of elections and strengthen party organizational 

skills. 

Election monitoring for provincial 

elections (master trainers, training 

of trainers, code of conduct, 

training materials) 

Election monitoring training for civil society 

organizations, capacity-building for Iraqi Election 

Information Network 

Completea

Election monitoring for 

constitutional amendment 

referendum 

No vote on constitutional referenda scheduled, 

making completion of activity impossible 

Unfulfilledd

Produce 3 videos on election 

observation, constitutional review, 

and role of Provincial Councils 

Current program needs would not benefit from 

videos; the need for these has been largely met 

through local engagement and training by 

provincial coordinators. 

Unfulfilledd

National Conference in Baghdad 

to present results of provincial 

elections 

Not possible with Iraqi Election Information 

Network, the original domestic monitoring 

network with which NDI worked. 

Unfulfilledd

Media monitoring training for 

provincial and constitutional 

elections 

All media monitoring trainings have been 

reported under another DRL grant; the activity 

was not possible for the constitutional election as 

those were not held and are not currently 

scheduled. 

Unfulfilledd

Political party campaign training 

for provincial elections 

Campaign development series Module 1 to 6, 

Bulgaria study mission (June 29-July 7, 2009) 

Completea

Party code of conduct for 

provincial elections 

Lack of interest from parties in time for 

completion. 

Unfulfilledd 
33 

Activity as Described in Grant 

Proposal Activity as Implemented and Results Status 

Party agent training for provincial 

elections (simulation video) 

All party agent trainings have been reported 

under another DRL grant; the need for the video 

was fulfilled by other training activities. 

Unfulfilledd

Political party training on 

candidate selection 

Patriotic Union of Kurdistan; strategy discussions 

with parties 

Completea

Notes: 

a Complete: the grantee has finished all activities. 

b

 Ongoing: the grantee has initiated work on activities, but has not completed them. c

 Incomplete: the grantee has conducted a portion of the work in these activities, but remaining work is either pending or being reevaluated due to 

changes in the political environment. d

 Unfulfilled: the grantee has not yet begun work on these activities. 

Source: SIGIR analysis of NDI information, as of April 2010. 
34 

Appendix D—Acronyms 

Acronym Description 

DoS United States Department of State 

DRL Bureau of Democracy, Human Rights, and Labor 

GO Grants Officer 

GOR Grants Officer Representative 

IRI International Republican Institute 

NDI National Democratic Institute 

OMB Office of Management and Budget 

SIGIR Special Inspector General for Iraq Reconstruction 

USAID U.S. Agency for International Development 
35 

Appendix E—Audit Team Members 

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

Inspector General for Audits, Office of the Special Inspector General for Iraq Reconstruction. 

The staff members who conducted the audit and contributed to the report include: 

Bill Bedwell 

Daniel Chen 

Joan Hlinka 

Whitney Miller 

Robert Whiteley 
36 

Appendix F—Department of State–Bureau of 

Democracy, Human Rights, and Labor Comments
37 
38 

Appendix G—SIGIR Mission and Contact Information 

SIGIR’s Mission Regarding the U.S. reconstruction plans, programs, and 

operations in Iraq, the Special Inspector General for Iraq 

Reconstruction provides independent and objective: 

 oversight and review through comprehensive audits, 

inspections, and investigations 

 advice and recommendations on policies to promote 

economy, efficiency, and effectiveness 

 deterrence of malfeasance through the prevention and 

detection of fraud, waste, and abuse 

 information and analysis to the Secretary of State, the 

Secretary of Defense, the Congress, and the American 

people through Quarterly Reports 

Obtaining Copies of SIGIR 

Reports and Testimonies 

To obtain copies of SIGIR documents at no cost, go to 

SIGIR’s Web site (www.sigir.mil). 

To Report Fraud, Waste, and 

Abuse in Iraq Relief and 

Reconstruction Programs 

Help prevent fraud, waste, and abuse by reporting 

suspicious or illegal activities to the SIGIR Hotline: 

 Web: www.sigir.mil/submit_fraud.html 

 Phone: 703-602-4063 

 Toll Free: 866-301-2003 

Congressional Affairs Hillel Weinberg 

Assistant Inspector General for Congressional 

Affairs 

Mail: Office of the Special Inspector General 

for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone 703-428-1059 

Email hillel.weinberg@sigir.mil 

Public Affairs Deborah Horan 

Director of Public Affairs 

Mail: Office of the Special Inspector General for Iraq 

Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1217 

Fax: 703-428-0817 

Email: PublicAffairs@sigir.mil