GAO 

United States Government Accountability Office

Statement Before the Commission on 

Wartime Contracting in Iraq and 

Afghanistan 

CONTINGENCY 

CONTRACTING 

Further Improvements 

Needed in Agency Tracking 

of Contractor Personnel and 

Contracts in Iraq and 

Afghanistan 

Statement of John P. Hutton, Director 

Acquisition and Sourcing Management 

For Release on Delivery 

Expected at 9:30 a.m. EST 

Monday, November 2, 2009 

GAO-10-187 
Page 1 GAO-10-187 

Chairman Thibault, Chairman Shays, and Commissioners: 

Thank you for inviting me here today to discuss ongoing efforts by the 

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

U.S. Agency for International Development (USAID) to track information 

on contractor personnel and contracts in Iraq and Afghanistan. Reliable, 

meaningful data on contractors and the services they provide are 

necessary to inform agency decisions on when and how to effectively use 

contractors, provide support services to contractors, and ensure that 

contractors are properly managed and overseen. The importance of such 

data is heightened by the unprecedented reliance on contractors in Iraq 

and Afghanistan and the evolving U.S. presence in the two countries. 

My statement focuses on (1) how information on contractor personnel and 

contracts can assist agencies in managing and overseeing their use of 

contractors and (2) the status of DOD, State, and USAID’s efforts to track 

statutorily-required information on contractor personnel and contracts in 

Iraq and Afghanistan, as well as our recent recommendations to address 

the shortcomings we identified in their efforts. This statement is drawn 

from our October 2009 report on contracting in Iraq and Afghanistan,1

which was mandated by section 863 of the National Defense Authorization 

Act for Fiscal Year 2008 (NDAA for FY2008),2

 and a related April 2009 

testimony.3

 Our prior work was prepared in accordance with generally 

accepted government auditing standards. Those standards require that we 

plan and perform the audits 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. 

Section 861 of the NDAA for FY2008 directed the Secretary of Defense, the 

Secretary of State, and the USAID Administrator to sign a memorandum of Background 

 

1

GAO, Contingency Contracting: DOD, State, and USAID Continue to Face Challenges in 

Tracking Contractor Personnel and Contracts in Iraq and Afghanistan, GAO-10-1

(Washington, D.C.: Oct. 1, 2009). 

2

Pub. L. No. 110-181, § 863. 

3

GAO, Contingency Contracting: DOD, State, and USAID Are Taking Actions to Track 

Contracts and Contractor Personnel in Iraq and Afghanistan, GAO-09-538T (Washington, 

D.C.: Apr. 1, 2009). 

 Contingency Contracting 
understanding (MOU) related to contracting in Iraq and Afghanistan.4

 The 

law specified a number of issues to be covered in the MOU, including the 

identification of common databases to serve as repositories of information 

on contract and contractor personnel. The NDAA for FY2008 required the 

databases to track at a minimum: 

• for each contract, 

• a brief description of the contract, 

• its total value, and 

• whether it was awarded competitively, and 

• for contractor personnel working under contracts in Iraq or Afghanistan, 

• total number employed, 

• total number performing security functions, and 

• total number who have been killed or wounded. 

In July 2008, DOD, State, and USAID signed an MOU in which they agreed 

the Synchronized Predeployment and Operational Tracker (SPOT) would 

be the system of record for the statutorily-required contract and 

contractor personnel information. The MOU specified SPOT would include 

information on DOD, State, and USAID contracts with more than 14 days 

of performance in Iraq or Afghanistan or valued at more than the 

simplified acquisition threshold, which the MOU stated was $100,000, as 

well as information on the personnel working under those contracts. 

While DOD is responsible for all maintenance and upgrades to the SPOT 

database, each agency agreed in the MOU to ensure that data elements 

related to contractor personnel, such as the number of personnel 

employed on each contract in Iraq or Afghanistan, are accurately entered 

into SPOT by its contractors. SPOT is designed to track contractor 

personnel by name and record information such as the contracts they are 

working under, deployment dates, and next of kin. Contract data elements, 

such as value and extent of competition, are to be imported into SPOT 

from the Federal Procurement Data System – Next Generation (FPDSNG), the federal government’s system for tracking information on 

contracting actions. 

 

4

Pub. L. No. 110-181, § 861, as amended by Pub. L. No. 110-417, § 854 (2008). 

Page 2 GAO-10-187 Contingency Contracting
The need for information on contracts and contractor personnel to inform 

decisions and oversee contractors is critical given DOD, State, and 

USAID’s extensive reliance on contractors to support and carry out their 

missions in Iraq and Afghanistan. We have reported extensively on the 

management and oversight challenges of using contractors to support 

contingency operations and the need for decision makers to have 

accurate, complete, and timely information as a starting point to address 

those challenges. Although much of our prior work has focused on DOD, 

the lessons learned can be applied to other agencies relying on contractors 

to help carry out their missions. The agencies’ lack of complete and 

accurate information on contractors supporting contingency operations 

may inhibit planning, increase costs, and introduce unnecessary risk, as 

illustrated in the following examples: 

Contractor and 

Contractor Personnel 

Information Can Help 

Agencies Address 

Management and 

Oversight Challenges 

• Limited visibility over contractors obscures how extensively agencies 

rely on contractors to support operations and help carry out missions. 

In our 2006 review of DOD contractors supporting deployed forces, we 

reported that a battalion commander in Iraq was unable to determine 

the number of contractor-provided interpreters available to support his 

unit.5

 Such a lack of visibility can create challenges for planning and 

carrying out missions. Further, knowledge of who is on their 

installation, including contractor personnel, helps commanders make 

informed decisions regarding force protection and account for all 

individuals in the event of hostile action. 

• Without incorporating information on contractors into planning 

efforts, agencies risk making uninformed programmatic decisions. As 

we noted in our 2004 and 2005 reviews of Afghanistan reconstruction 

efforts, when developing its interim development assistance strategy, 

USAID did not incorporate information on the contractor resources 

required to implement the strategy.6

 We determined this impaired 

USAID’s ability to make informed decisions on resource allocations for 

the strategy. 

 

5

GAO, Military Operations: High-Level DOD Action Needed to Address Long-standing 

Problems with Management and Oversight of Contractors Supporting Deployed Forces, 

GAO-07-145 (Washington, D.C.: Dec. 18, 2006). 

6

GAO, Afghanistan Reconstruction: Deteriorating Security and Limited Resources Have 

Impeded Progress; Improvements in U.S. Strategy Needed, GAO-04-403 (Washington, D.C.: 

June 2, 2004) and Afghanistan Reconstruction: Despite Some Progress, Deteriorating 

Security and Other Obstacles Continue to Threaten Achievement of U.S. Goals, 

GAO-05-742 (Washington, D.C.: July 28, 2005). 

Page 3 GAO-10-187 Contingency Contracting
• A lack of accurate financial information on contracts impedes 

agencies’ ability to create realistic budgets. As we reported in July 

2005, despite the significant role of private security providers in 

enabling Iraqi reconstruction efforts, neither State, DOD, nor USAID 

had complete data on the costs associated with using private security 

providers.7

 Agency officials acknowledged such data could help them 

identify security cost trends and their impact on the reconstruction 

projects, as increased security costs resulted in the reduction or 

cancellation of some projects. 

• Lack of insight into the contract services being performed increases 

the risk of paying for duplicative services. In the Balkans, where 

billions of dollars were spent for contractor support, we found in 2002 

that DOD did not have an overview of all contracts awarded in support 

operations. 8

 Until an overview of all contractor activity was obtained, 

DOD did not know what the contractors had been contracted to do 

and whether there was duplication of effort among the contracts that 

had been awarded. 

• Costs can increase due to a lack of visibility over where contractors 

are deployed and what government support they are entitled to. In our 

December 2006 review of DOD’s use of contractors in Iraq, an Army 

official estimated that about $43 million was lost each year to free 

meals provided to contractor employees at deployed locations who 

also received a per diem food allowance.9

Many recommendations from our prior work on contractors supporting 

contingency operations focused on increasing agencies’ ability to track 

contracts and contractor personnel so that decision makers—whether out 

in the field or at headquarters—can have a clearer understanding of the 

extent to which they rely on contractors, improve planning, and better 

account for costs. While actions have been taken to address our 

recommendations, DOD, State, and USAID officials have told us that their 

ability to access information on contracts and contractor personnel to 

inform decisions still needs improvement. Specifically, information on 

contracts and the personnel working on them in Iraq and Afghanistan may 

 

7

GAO, Rebuilding Iraq: Actions Needed to Improve Use of Private Security Providers, 

GAO-05-737 (Washington, D.C.: July 28, 2005). 

8

GAO, Defense Budget: Need to Strengthen Guidance and Oversight of Contingency 

Operations Costs, GAO-02-450 (Washington, D.C.: May 21, 2002). 

9

GAO-07-145. 

Page 4 GAO-10-187 Contingency Contracting
reside solely with the contractors, be stored in a variety of data systems, 

or exist only in paper form in scattered geographical regions. These 

officials indicated that the use of SPOT has the potential to bring some of 

this dispersed information together so that it can be used to better manage 

and oversee contractors. 

DOD, State, and USAID have made progress in implementing SPOT. 

However, as we reported last month, DOD, State, and USAID’s on-going 

implementation of SPOT currently falls short of providing agencies with 

information that would help facilitate oversight and inform decision 

making, as well as fulfill statutory requirements. Specifically, we found 

that the agencies have varying criteria for deciding which contractor 

personnel are entered into the system and, as a result, not all required 

contractor personnel have been entered. While the agencies have used 

other approaches to obtain personnel information, such as periodic 

contractor surveys, these approaches have provided incomplete data that 

should not be relied on to identify trends or draw conclusions. In addition, 

SPOT, which was intended to serve as a central repository of information 

on contracts performed in Iraq or Afghanistan, currently lacks the 

capability to track required contract information as agreed to in the MOU. 

Despite Some 

Progress, SPOT Not 

Yet Fully 

Implemented to Track 

Contractor Personnel 

and Contracts 

Tracking Information on 

Contractor Personnel in 

Iraq and Afghanistan 

DOD, State, and USAID have been phasing in the MOU requirement to use 

SPOT to track information on contracts and the personnel working on 

them in Iraq and Afghanistan. In January 2007, DOD designated SPOT as 

its primary system for collecting data on contractor personnel deployed 

with U.S. forces and directed contractor firms to enter personnel data for 

contracts performed in Iraq and Afghanistan. State started systematically 

entering information for both Iraq and Afghanistan into SPOT in 

November 2008. In January 2009, USAID began requiring contractors in 

Iraq to enter personnel data into SPOT. However, USAID has not yet 

imposed a similar requirement on its contractors in Afghanistan and has 

no time frame for doing so. 

In implementing SPOT, DOD, State, and USAID’s criteria for determining 

which contractor personnel are entered into SPOT varied and were not 

consistent with those contained in the MOU, as the following examples 

illustrate: 

• Regarding contractor personnel in Iraq, DOD, State, and USAID 

officials stated the primary factor for deciding to enter contractor 

personnel into SPOT was whether a contractor needed a SPOTPage 5 GAO-10-187 Contingency Contracting
generated letter of authorization (LOA).10 However, not all contractor 

personnel, particularly local nationals, in Iraq need LOAs and agency 

officials informed us that such personnel were not being entered into 

SPOT. 

• For Afghanistan, DOD offices varied in their treatment of which 

contractor personnel should be entered into SPOT. Officials with one 

contracting office stated the need for an LOA determined whether 

someone was entered into SPOT. As a result, since local nationals 

generally do not need LOAs, they are not in SPOT. In contrast, DOD 

officials with another contracting office stated they follow DOD’s 2007 

guidance on the use of SPOT. According to that guidance, contractor 

personnel working on contracts in Iraq and Afghanistan with more 

than 30 days of performance and valued over $25,000 are to be entered 

into SPOT—as opposed to the MOU threshold of 14 days of 

performance or a value over $100,000. 

These varying criteria and practices stem, in part, from differing views on 

the agencies’ need to collect and use data on certain contracts and the 

personnel working on them. For example, some DOD officials we spoke 

with questioned the need to track contractor personnel by name as 

opposed to their total numbers given the cost of collecting detailed data 

compared to the benefit of having this information. However, DOD 

officials informed us that the agencies did not conduct any analyses of 

what the appropriate threshold should be for entering information into 

SPOT given the potential costs and benefits of obtaining such information 

prior to establishing the MOU requirements. As a result of the varying 

criteria, the agencies do not have an accurate or consistent picture of the 

total number of contractor personnel in Iraq and Afghanistan. 

Although officials from all three agencies expressed confidence that SPOT 

data were relatively complete for contractor personnel who need LOAs, 

they acknowledged SPOT does not fully reflect the number of local 

nationals working on their contracts. Agency officials further explained 

ensuring SPOT contains information on local nationals is challenging 

 

10An LOA is a document issued by a government contracting officer or designee that 

authorizes contractor personnel to travel to, from, and within a designated area and to 

identify any additional authorizations, privileges, or government support the contractor is 

entitled to under the contract. Contractor personnel need SPOT-generated LOAs to, among 

other things, enter Iraq, receive military identification cards, travel on U.S. military aircraft, 

or, for security contractors, receive approval to carry weapons. 

Page 6 GAO-10-187 Contingency Contracting
because their numbers tend to fluctuate due to the use of day laborers and 

local firms do not always track the individuals working for them. 

Absent robust contractor personnel data in SPOT, DOD, State, and USAID 

have relied on surveys of their contractors to obtain information on the 

number of contractor personnel. However, we determined the resulting 

data from these surveys are similarly incomplete and unreliable and, 

therefore, should not be used to identify trends or draw conclusions about 

the number of contractor personnel in each county. Additionally, officials 

from all three agencies stated that they lack the resources to verify the 

information reported by the contractors, particularly for work performed 

at remote sites where security conditions make it difficult for U.S. 

government officials to regularly visit. 

• According to DOD officials, the most comprehensive information on 

the number of DOD contractor personnel in Iraq and Afghanistan 

comes from the U.S. Central Command’s (CENTCOM) quarterly 

census.11 As shown in table 1, DOD’s census indicated there were 

200,807 contractors working in Iraq and Afghanistan as of the second 

quarter of fiscal year 2009, which is 83,506 more than what was 

reported in SPOT. However, DOD officials acknowledged the census 

numbers represent only a rough approximation of the actual number 

of contractor personnel in each country. For example, an Army-wide 

review of fiscal year 2008 third quarter data determined approximately 

26,000 contractors were not previously counted. Information on these 

contractors was included in a subsequent census. As a result, 

comparing third and fourth quarter data would incorrectly suggest that 

the number of contractors increased, while the increase is attributable 

to more accurate counting. Conversely, there have also been instances 

of contractor personnel being double counted in the census. 

 

11CENTCOM is one of DOD’s unified combatant commands. It is responsible for overseeing 

U.S. security interests in 20 countries—including Iraq and Afghanistan—that stretch from 

the Arabian Gulf region into Central Asia. CENTCOM initiated its quarterly census of 

contractor personnel in June 2007 as an interim measure until SPOT is fully implemented. 

The census relies on contractor firms to self-report their personnel data to DOD 

components, which then aggregate the data and report them to CENTCOM at the end of 

each quarter. 

Page 7 GAO-10-187 Contingency Contracting
Table 1: DOD-Reported Data on the Number of Contractor Personnel in Iraq and 

Afghanistan, Second Half of Fiscal Year 2008 and First Half of Fiscal Year 2009 

Fiscal year 2008 Fiscal year 2009 

Third quarter Fourth quarter First quarter Second quarter

Iraq 162,428 163,446 148,050 132,610

Afghanistan 41,232 68,252 71,755 68,197

Total 203,660 231,698 219,805 200,807

Source: GAO analysis of CENTCOM census data. 

• Although State reported most of its contractor personnel are currently 

entered into SPOT, the agency relied on periodic inquiries of its 

contractors to obtain a more complete view of contractor personnel in 

the two countries. State reported 8,971 contractor personnel were 

working on contracts in Iraq and Afghanistan during the first half of 

fiscal year 2009. Even relying on a combination of data from SPOT and 

periodic inquiries, it appeared State underreported its contractor 

personnel numbers. For example, although State provided obligation 

data on a $5.6 million contract for support services in Afghanistan, 

State did not report any personnel working on this contract. 

• USAID relied entirely on contractor surveys to determine the number 

of contractor personnel working in Iraq and Afghanistan. The agency 

reported 16,697 personnel worked on its contracts in Iraq and 

Afghanistan during the first half of fiscal year 2009. However, we 

identified a number of contracts for which contractor personnel 

information was not provided, including contracts to refurbish a 

hydroelectric power plant and to develop small and medium 

enterprises in Afghanistan worth at least $6 million and $91 million, 

respectively. 

Tracking Information on 

Contracts with 

Performance in Iraq and 

Afghanistan 

Although some information on contracts is being entered into SPOT, the 

system currently lacks the capability to accurately import and track the 

contract data elements as agreed to in the MOU. While the MOU specifies 

contract values, competition information, and descriptions of the services 

being provided would be pulled into SPOT from FPDS-NG, this capability 

is not expected to be available until 2010. Once the direct link is 

established, pulling FPDS-NG data into SPOT may present challenges 

because of how data are entered. While contract numbers are the unique 

identifiers that will be used to match records in SPOT to those in FPDSNG, SPOT users are not required to enter the numbers in a standardized 

manner. In our review of SPOT data, we identified that at least 12 percent 

of the contracts had invalid contract numbers and, therefore, could not be 

Page 8 GAO-10-187 Contingency Contracting
matched to records in FPDS-NG.12 Additionally, using contract numbers 

alone may be insufficient since specific task orders are identified through 

a combination of the contract and task order numbers. However, SPOT 

users are not required to enter task order numbers. For example, for one 

SPOT entry that only had the contract number without an order number, 

we found that DOD had placed 12 different orders—ranging from a few 

thousand dollars to over $129 million—against that contract. Based on the 

information in SPOT, DOD would not be able to determine which order’s 

value and competition information should be imported from FPDS-NG. 

As SPOT is not yet fully operational as a repository of information on 

contracts with performance in Iraq and Afghanistan, DOD, State, and 

USAID relied on a combination of FPDS-NG, agency-specific databases, 

and manually compiled lists of contract actions to provide us with the 

contract information necessary to fulfill our mandate. None of the 

agencies provided us with a cumulative listing of all their contract actions 

for Iraq and Afghanistan. Instead, they provided a total of 48 separate data 

sets that we then analyzed to identify almost 85,000 contracts with 

performance in Iraq and Afghanistan that totaled nearly $39 billion in 

obligations in fiscal year 2008 and the first half of fiscal year 2009. Our 

analyses involved compiling the data from the multiple sources, removing 

duplicate entries, and standardizing the data that were reported. 

To address the shortcomings we identified in the agencies’ implementation 

of SPOT, we recommended in our October 200913 report that the 

Secretaries of Defense and State and the USAID Administrator jointly 

develop and execute a plan with associated timeframes for their continued 

implementation of the NDAA for FY2008 requirements, specifically 

Prior 

Recommendation for 

Executive Action and 

Concluding 

Observations • ensuring that the agencies’ criteria for entering contracts and 

contractor personnel into SPOT are consistent with the NDAA for 

FY2008 and with the agencies’ respective information needs for 

overseeing contracts and contractor personnel; 

 

12Contract numbers consist of 13 alphanumeric characters. We considered a contract 

number invalid if the contract number entered into SPOT had a different number of 

characters. 

13GAO-10-1. 

Page 9 GAO-10-187 Contingency Contracting
• revising SPOT’s reporting capabilities to ensure that they fulfill 

statutory requirements and agency information needs; and 

• establishing uniform requirements on how contract numbers are to be 

entered into SPOT so that contract information can accurately be 

pulled from FPDS-NG as agreed to in the MOU. 

In commenting on our recommendation, DOD and State disagreed with the 

need for a plan to address the issues we identified. They cited ongoing 

coordination efforts and anticipated upgrades to SPOT as sufficient. While 

USAID did not address our recommendation, it similarly noted plans to 

continue meeting with DOD and State regarding SPOT. We believe 

continued coordination among the three agencies is important. They 

should work together to implement a system that is flexible across the 

agencies but still provides detailed information to better manage and 

oversee contractors. However, they also need to take the actions 

contained in our recommendation if the system is to fulfill its potential. By 

jointly developing and executing a plan with time frames, the three 

agencies can identify the concrete steps they need to take and assess their 

progress in ensuring the data in SPOT are sufficiently reliable to fulfill 

statutory requirements and their respective agency needs. Absent such a 

plan and actions to address SPOT’s current shortcomings, the agencies 

will be reliant on alternative sources of data—which are also unreliable 

and incomplete. As a result, they will continue to be without reliable 

information on contracts and contractor personnel that can be used to 

help address some longstanding contract management challenges. 

Messrs. Chairmen, this concludes my prepared statement. I would be 

happy to respond to any questions you or the other commissioners may 

have. 

For further information about this statement, please contact John P. 

Hutton (202) 512-4841 or huttonj@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this statement. Individuals who made key contributions to this 

statement include Johana R. Ayers, Assistant Director; Noah Bleicher; Raj 

Chitikila; Christopher Kunitz; Heather Miller; and Morgan Delaney 

Ramaker. 

GAO Contacts and 

Acknowledgement 

(120875) Page 10 GAO-10-187 Contingency Contracting
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