OPERATIONAL 

CONTRACT 

SUPPORT

Management and 

Oversight 

Improvements Needed 

in Afghanistan

Report to Congressional Committees

March 2012

GAO-12-290

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-290, report to 

congressional committees 

March 2012 

OPERATIONAL CONTRACT SUPPORT 

Management and Oversight Improvements Needed in 

Afghanistan

Why GAO Did This Study

In fiscal year 2011, DOD reported 

obligating over $16 billion for contracts 

that were executed primarily in 

Afghanistan. GAO has previously 

identified the need for DOD to improve 

its oversight of contractors by nonacquisition personnel, such as CORs, 

and Congress has addressed this 

issue in legislation. CORs act as the 

liaisons between the contractor, the 

contracting officer, and the unit 

receiving support. 

Following up on previous GAO work on 

this topic, GAO determined the extent 

to which (1) DOD’s required training 

prepares CORs to perform their 

contract management and oversight 

duties, (2) CORs have the subject 

area-related technical expertise 

needed to oversee contracts, and (3) 

the number of CORs is sufficient to 

oversee the contracts in Afghanistan.

GAO conducted field work in 

Afghanistan and the United States and 

focused on the preparedness of CORs 

to manage and oversee contracts in 

the CENTCOM area of responsibility. 

What GAO Recommends

GAO recommends that DOD enhance 

the current strategy for managing and 

overseeing contracts in contingency 

areas such as Afghanistan by, for 

example, developing training standards

for providing operational contract 

support (OCS), fully institutionalizing

OCS in professional military education,

and developing standards regarding 

the number of contracts that CORs can 

oversee based on the technical nature 

and complexity of the contract. DOD 

concurred with all of GAO’s 

recommendations.

What GAO Found

The Department of Defense (DOD) has taken steps to enhance its existing 

training program for contracting officer’s representatives (CORs), but the required 

training does not fully prepare them to perform their contract oversight duties in 

contingency areas such as Afghanistan. DOD requires that CORs be qualified by 

training and experience commensurate with the responsibilities to be delegated 

to them. DOD took several actions to enhance its training program, such as 

developing a CORs training course with a focus on contingency operations. 

However, GAO found that CORs are not prepared to oversee contracts because 

the required training does not include specifics on how to complete written 

statements of work and how to operate in Afghanistan’s unique contracting 

environment. For example, DOD contracting personnel told GAO about opening 

delays and additional expenses related to the construction of a dining facility, 

which was originally constructed without a kitchen because it was not included in 

the original statement of work. In some cases, contract-specific training was not 

provided at all. In addition, not all oversight personnel such as commanders and 

senior leaders receive training to perform contract oversight and management 

duties in Afghanistan because such training is not required of them. Because 

DOD’s required training does not prepare CORs and other oversight personnel to 

oversee contracts, units cannot be assured that they receive what they paid for. 

CORs do not always have the necessary subject area-related technical expertise 

to oversee U.S. Central Command (CENTCOM) contracts they were assigned to. 

Contracting officials noted, for example, that the staircases on guard towers at a 

forward operating base were poorly constructed and unsafe to climb. The COR 

assigned to that contract had inadequate subject area-related technical 

expertise, preventing the early identification of the defective welding on the 

staircases. According to contracting officials, situations like this often occurred 

due to the shortage of CORs with expertise in construction. Also, at the time of 

GAO’s field work, CORs for contracts written by CENTCOM contracting officers

did not have access to subject matter experts, particularly those with construction 

experience. According to contracting personnel, because CORs do not have the 

subject area-related technical expertise needed to oversee contracts or access to 

subject matter experts, facilities were sometimes deficient and had to be 

reconstructed at great additional expense to the taxpayer.

DOD does not have a sufficient number of CORs to oversee the numerous 

contracts in Afghanistan. CENTCOM requires CORs to be nominated for all 

service contracts over $2,500 that, unless exempted, require significant ongoing 

technical advice and surveillance from requirements personnel. However, there 

is no guidance on the number of contracts a single COR should oversee. 

According to contracting officials and CORs GAO interviewed in Afghanistan, 

some CORs were responsible for providing oversight to multiple contracts in 

addition to carrying out their primary military duty. For example, one COR GAO 

interviewed was assigned to more than a dozen construction projects. According 

to that COR, it was impossible to be at each construction site during key phases 

of the project because the projects were occurring almost simultaneously at 

different locations. Consequently, according to officials, in situations like these, 

construction was completed without sufficient government oversight and 

problems were sometimes identified after facilities had been completed. 

View GAO-12-290. For more information, 

contact Cary B. Russell at (404) 679-1808 or 

russellc@gao.gov
Page i GAO-12-290 Operational Contract Support

Letter 1 

Background 6

DOD Took Steps to Enhance Existing Training Program, but 

Existing Training Does Not Fully Prepare CORs for Contract 

Management and Oversight Duties 9

CORs Do Not Always Have the Subject Area-Related Technical 

Expertise Needed to Oversee Some Contracts 18

Number of CORs Is Not Sufficient to Adequately Oversee the 

Contracts in Afghanistan 23

Conclusions 26

Recommendations for Executive Action 27

Agency Comments and Our Evaluation 28

Appendix I Scope and Methodology 32

Appendix II Comments from the Department of Defense 36

Appendix III GAO Contact and Staff Acknowledgments 39

Figures

Figure 1: Shower/Toilet Facility Constructed without Holes in the 

Walls or Flooring for Plumbing and Drain 13

Figure 2: Poor-Quality Materials—Crumbling Cement Blocks 13

Figure 3: Unstable Staircase for Guard Towers 20

Figure 4: Cement Block Wall with Large Holes That Remained 

When Scaffolding Was Removed 21

Figure 5: Compound Comprising Five Buildings Constructed in a 

Non-Secure Location outside the Perimeter of a Base 25

Contents
Page ii GAO-12-290 Operational Contract Support

Abbreviations

C3

 CENTCOM Contracting Command 

C-JTSCC CENTCOM Joint Theater Support Contracting Command 

CORs contracting officer’s representatives 

COIN counterinsurgency 

DCMA Defense Contract Management Agency 

DOD Department of Defense 

FAR Federal Acquisition Regulation 

LOGCAP Logistics Civil Augmentation Program 

OCS Operational Contract Support 

SCO-A Senior Contracting Official-Afghanistan

USD AT&L Under Secretary of Defense for Acquisition, Technology

 and Logistics 

CENTCOM U.S. Central Command

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Page 1 GAO-12-290 Operational Contract Support

United States Government Accountability Office 

Washington, DC 20548

March 29, 2012

Congressional Committees

The Department of Defense (DOD) reported that it had obligated over $16 

billion in fiscal year 2011 for contracts that were executed primarily in 

Afghanistan and that, as of October 2011, contractors made up 49 

percent of the department’s workforce there—101,789 DOD contractors1

compared with approximately 104,900 U.S. military personnel.

Contractors support the military during contingency operations2 by, for 

example, managing dining facilities; washing uniforms; guarding military 

bases; constructing roads to schools; transporting supplies; and building 

facilities, such as guard towers, water treatment plants, and hospitals. 

Since 1997, we have reported on DOD’s use of contractors to support 

contingency operations. For example, we reported in July 2004 that DOD 

did not always have sufficient contract oversight personnel to manage 

and oversee its logistics support contracts in Iraq and Afghanistan.3 In 

December 2006, we noted that without an adequate number of trained

oversight personnel DOD could not be assured that contractors could 

meet contract requirements efficiently and effectively.4

 

1

Office of the Deputy Assistant Secretary of Defense (Program Support), Contractor 

Support of U.S. Operations in the USCENTCOM Area of Responsibility, Quarterly 

Contractor Census Reports, October 2011. As we have noted in previous reports, 

however, agency-reported census data should not be used to identify trends or draw 

conclusions about the number of contractor personnel due to limitations such as 

incomplete and inaccurate data. See GAO, Iraq and Afghanistan: DOD, State, and USAID 

Cannot Fully Account for Contracts, Assistance Instruments, and Associated Personnel,

Effective contract 

management is essential for ensuring that U.S. military personnel receive 

GAO-11-886 (Washington, D.C.: Sept. 15, 2011).

2

A “contingency operation” is a military operation that either (a) is designated by the 

Secretary of Defense as an operation in which members of the armed forces are or may 

become involved in military actions, operations, or hostilities against U.S. enemies or 

against an opposing military force or (b) results in the call or order to, or retention on, 

active duty of members of the uniformed services under certain statutory provisions or any 

other provision of law during a war or during a national emergency declared by the 

President or Congress. See 10 U.S.C. § 101(a)(13).

3

GAO, Military Operations: DOD’s Extensive Use of Logistics Support Contracts Requires 

Strengthened Oversight, GAO-04-854 (Washington, D.C.: July 21, 2004).

4

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).

 
 

Page 2 GAO-12-290 Operational Contract Support

the support they need and that controls are in place to prevent fraud, 

waste, and abuse. Ultimately, failure to manage contracts effectively 

could undermine U.S. policy objectives and threaten the safety of U.S. 

forces.

It takes a wide range of people to execute an acquisition from start to 

finish including personnel outside of the acquisition workforce such as 

contracting officer’s representatives (CORs). CORs are military or civilian 

DOD personnel that manage and oversee contracts by acting as the eyes 

and the ears of DOD’s contracting officers and by serving as the liaisons 

between the contractor, the contracting officer, and the unit receiving 

support or services. The contracting officer is ultimately responsible for 

ensuring that contractors meet the requirements as set forth in the 

contract. However, the CORs are non-acquisition personnel that have 

acquisition-related responsibilities—particularly those related to contract 

management and oversight of service and product acquisitions.

We and other oversight entities have identified the need for DOD to 

improve the management and oversight of contractors by non-acquisition 

personnel, such as the CORs. Congress addressed the need to improve 

the management and oversight of non-acquisition personnel, in 

legislation. Specifically, Congress included provisions relating to 

contingency contracting in the John Warner National Defense 

Authorization Act for Fiscal Year 20075 and the National Defense 

Authorization Act for Fiscal Year 2008,6

 

5

Pub. L. No. 109-364 (2006).

codified at section 2333 of Title 

6

Pub. L. No. 110-181 (2008).
 

Page 3 GAO-12-290 Operational Contract Support

10, United States Code.7 The National Defense Authorization Act for 

Fiscal Year 2008 amended section 2333 to require that certain DOD joint 

policy provide for training of military personnel outside the acquisition 

workforce expected to have acquisition responsibility, including oversight 

duties during combat operations, post-conflict operations, and 

contingency operations.8 Further, section 2333 requires that the training 

be sufficient to ensure that such military personnel understand the scope 

and scale of contractor support that they will experience in contingency 

operations and are prepared for their roles and responsibilities in regard 

to requirements definition, program management (including contractor 

oversight), and contingency contracting,9 which are aspects of operational 

contract support (OCS). Specific concerns have been raised about the 

training, expertise, and the sufficiency of the number of CORs providing 

contract management and oversight. For example, in 2007, the 

Commission on Army Acquisition and Program Management in 

Expeditionary Operations (known as the Gansler Report) found that 

CORs usually had no experience managing contracts and received 

contract management training that was not relevant to the Afghanistan 

contracting environment.10

 

7

See Pub. L. No. 109-364, § 854(a)(1); Pub. L. No. 110-181, § 849. The provision in the 

John Warner National Defense Authorization Act for Fiscal Year 2007 required the 

Secretary of Defense to develop joint policies addressing contingency contracting, among 

other matters. See Pub. L. No. 109-364, § 854(a)(1) (codified as amended at 10 U.S.C. § 

2333(d)). Section 2333, as enacted by the provision, also defines “contingency 

contracting” as all stages of the process of acquiring property or services by the 

Department of Defense during a contingency operation. See 10 U.S.C. § 2333(f)(2). We 

reported in June 2010 that DOD had not yet finalized the joint policies required by 

Congress in the National Defense Authorization Acts for Fiscal Years 2007 and 2008. On 

December 20, 2011, DOD reissued Department of Defense Instruction 3020.41 with a 

new title—Operational Contract Support. The revised instruction establishes policy, 

assigns responsibilities, and provides procedures for OCS. DOD issued regulations with 

similar content in an interim final rule published in the Federal Register shortly thereafter. 

See Operational Contract Support, 76 Fed. Reg. 81,807 (Dec. 29, 2011) (to be codified at 

32 C.F.R. pt. 158). We did not assess the recent issuances in this report.

Further, in June 2009, the Commission on 

Wartime Contracting reported shortfalls in the number of qualified 

oversight personnel in Afghanistan, specifically CORs, and a general lack 

8

See Pub. L. No. 110-181, § 849(a)(2) (codified at 10 U.S.C. § 2333(e)).

9

See § 2333(e)(2).

10 Report of the “Commission on Army Acquisition and Program Management in 

Expeditionary Operations”, Urgent Reform Required: Army Expeditionary Contracting, 

(Oct. 31, 2007). 
 

Page 4 GAO-12-290 Operational Contract Support

of COR training.11 Then, in August 2011, the Commission on Wartime 

Contracting reported that poor planning and oversight by the government 

and poor performance by contractors had resulted in wasted resources, 

missions not being achieved, and the loss of lives.12 A recent U.S. Army 

Contracting Command article13 noted that many deploying units were 

either unaware of, or simply ignored, a certain Army road map for units to 

follow to successfully integrate OCS training, including training CORs into 

its pre-deployment preparations; the article concluded that units 

continued to deploy unprepared to execute their OCS mission. We 

testified in June 2011 that, though DOD had taken some actions to better 

prepare CORs for their management and oversight duties, improving 

CORs’ performance remained a challenge.14

Although CORs are non-acquisition personnel, they have acquisitionrelated responsibilities—particularly those related to contract 

management and oversight. In October 2010, in response to a mandate 

in the National Defense Authorization Act for Fiscal Year 2010,15 we 

reported on training provided by the Defense Acquisition University to the 

acquisition workforce.16

 

11Commission on Wartime Contracting in Iraq and Afghanistan, At What Cost? 

Contingency Contracting in Iraq and Afghanistan, Interim Report to Congress (June 2009). 

This review supplements the 2010 and other 

reports focusing on the preparedness of CORs, one such group of non12Commission on Wartime Contracting in Iraq and Afghanistan: Transforming Wartime 

Contracting: Controlling Cost and Reducing Risks, Final Report to Congress (Aug. 31, 

2011). 

13U.S. Army Contracting Command, ACC Today, Professional Workforce Gansler Report 

Findings Help Prioritize Pre-deployment Contracting Planning, by Major Hurcel I. Williams, 

412th Contracting Support Brigade, summer 2011.

14GAO, Operational Contract Support: Actions Needed to Address Contract Oversight and 

Vetting of Non-U.S. Vendors in Afghanistan, GAO-11-771T (Washington, D.C.: June 30, 

2011). 

15See Pub. L. No. 111-84, § 1108(b)(2) (2009).

16GAO, Defense Acquisition Workforce: DOD’s Training Program Demonstrates Many 

Attributes of Effectiveness, but Improvement Is Needed, GAO-11-22 (Washington, D.C.: 

Oct. 28, 2010). In GAO-11-22, the acquisition workforce was described with reference to 

the Defense Acquisition Workforce Improvement Act, Pub. L. No. 101-510, §§ 1201-1211 

(1990) (codified as amended at 10 U.S.C. ch. 87); GAO, Defense Acquisition Workforce: 

Better Identification, Development, and Oversight Needed for Personnel Involved in 

Acquiring Services, GAO-11-892 (Washington, D.C.: Sept. 27, 2011). Following this work, 

in GAO-11-892 we examined personnel outside the workforce defined under the Defense 

Acquisition Workforce Improvement Act who are involved with acquiring services. 
 

Page 5 GAO-12-290 Operational Contract Support

acquisition personnel, tasked with contract management and oversight 

responsibilities in Afghanistan. Specifically, our objectives were to 

determine the extent to which (1) DOD’s required training prepares CORs 

to perform their contract management and oversight duties, (2) CORs 

have the subject area-related technical expertise needed to oversee 

contracts, and (3) the number of CORs is sufficient to oversee the 

contracts in Afghanistan.

To address our objectives, we assessed training requirements, technical 

qualifications, and workload requirements for CORs by reviewing 

guidance such as the Joint Publication 4-10,17 the U.S. Central Command 

(CENTCOM) Joint Theater Support Contracting Command18 Standard 

Operating Procedures addressing the Contracting Officer’s 

Representative Program,19

 

17Joint Chiefs of Staff, Joint Pub. 4-10, Operational Contract Support (Oct. 17, 2008) 

(Hereinafter cited as Joint Pub. 4-10 (Oct. 17, 2008)). According to senior Army officials, 

Joint Publication 4-10 is doctrine, not policy and it is prescriptive in nature.

the Defense Contingency Contracting Officer’s 

Representative Handbook, and the Joint Contingency Contracting 

Officer’s Representative Handbook. We interviewed senior contracting 

personnel from the Office of the Secretary of Defense, the Joint Staff, the 

combatant commands, service headquarters, the Defense Contract 

Management Agency (DCMA), and defense universities to obtain a 

comprehensive understanding of what training was available for CORs 

performing contract-related duties in Afghanistan. To assess the content 

of the training, we attended a weeklong training course for CORs at Fort 

Carson, Colorado, and completed the Defense Acquisition University’s 

online CORs contingency courses. We also reviewed the program of 

instructions (course syllabus) for the training curriculum. In Afghanistan, 

we conducted interviews with over 150 DOD personnel (commanders, 

senior leaders, contracting personnel, and CORs) from over 30 defense 

organizations and units in Bagram, Kabul, Kandahar, and Camp 

Leatherneck to identify the extent to which DOD’s required training had 

prepared CORs to perform their management and oversight duties, CORs 

had the subject area-related technical expertise needed to oversee 

contracts, and the number of CORs was sufficient to oversee the 

contracts in Afghanistan. We selected defense organizations and units to 

18Also known as CENTCOM Contracting Command (C3

) 

19CENTCOM Contracting Command Standard Operating Procedure No. 10-02: 

Contracting Officer’s Representative (COR) Program (Rev. 2, June 2010).
 

Page 6 GAO-12-290 Operational Contract Support

interview that would be in Afghanistan and available during the time of our 

visit based on input from service officials as well as status reports from 

the U.S. Army, the U.S. Air Force, and the U.S. Army National Guard. To 

facilitate our meetings with CORs and contracting personnel in 

Afghanistan, we developed a set of structured questions that we pretested and coordinated with service contracting experts to ensure that we 

solicited the appropriate responses. See appendix I for our scope and 

methodology and a list of defense organizations and units we visited 

during the course of this engagement.

We conducted our work from April 2010 to March 2012 in accordance 

with generally accepted government auditing standards. Those standards 

require that we plan and perform the audit to obtain sufficient and 

appropriate evidence to serve as a basis for our findings and conclusions.

We believe that the evidence that we have obtained serves as a 

reasonable basis for our findings and conclusions based on our audit 

objectives.

“Oversight of a contract”—which can refer to contract administration 

functions, quality assurance surveillance, corrective action, property 

administration, and past performance evaluation—ultimately rests with 

the contracting officer who has the responsibility for ensuring that 

contractors meet the requirements set forth in the contract. However, 

contracting officers are frequently not located in the area or at the 

installation where the services are being provided. For that reason, 

contracting officers designate CORs via an appointment letter20

 

20An appointment letter, or letter of designation, specifies among other things the extent of 

the COR’s authority to act on behalf of the contracting officer, identifies limitations on the 

COR’s authority, and specifies the period covered by the designation.

to assist 

with the technical monitoring or administration of a contract on their 

behalf. CORs serve as the eyes and ears for the contracting officer and 

act as the liaisons between the contractor, the contracting officer, and the 

unit receiving support or services. CORs are responsible for tasks 

identified in the contracting officer’s appointment letter that may include 

(1) providing daily contract oversight, (2) performing quality assurance 

reviews, (3) monitoring contract performance, and (4) assessing technical 

performance. CORs cannot direct the contractor by making commitments 

or changes that affect price, quality, quantity, delivery, or other terms and 

Background
 

Page 7 GAO-12-290 Operational Contract Support

conditions of the contract. 21

The Office of the Under Secretary of Defense for Acquisition, Technology, 

and Logistics (USD AT&L) has responsibility for developing overarching 

DOD policy for the management and oversight of contingency contracts.

In addition to their oversight duties, CORs 

have also been tasked with other contract-related duties such as 

preparing statements of work, which provide the requirements or 

specifications of the contract, developing requirements approval 

paperwork, and preparing funding documents. Although CORs are nonacquisition personnel, they can have acquisition-related responsibilities—

particularly those related to contract oversight. CORs are not usually 

contracting specialists and often perform contract management and 

oversight duties on a part-time basis in addition to performing their 

primary military duties, such as those performed by an infantryman or a 

quartermaster specialist.

22

For some contracts, including all contracts under the Logistics Civil 

Augmentation Program (LOGCAP),23

 

21CORs may also not be delegated responsibility to perform functions at a contractor’s 

location that have been delegated to a contract administration office. See 48 C.F.R. § 

201.602-2(2)(iii) (Defense Federal Acquisition Regulation Supplement). 

according to officials, contracting 

officers may delegate contract administration to DCMA to monitor 

contractor performance. The DCMA teams in Afghanistan include (1) 

administrative contracting officers who administer contracts and often 

direct contractors to perform work and (2) quality assurance 

representatives who ensure that the contractors perform work to the 

standards written in the contracts and who oversee certain aspects of the 

performance of CORs assigned to DCMA-administered contracts. The 

DCMA team also includes property administrators and subject matter 

experts who advise the agency on technical issues such as food service, 

electrical engineering, and fire safety. However, construction contracts in 

Afghanistan are generally administered by personnel from the Army 

Corps of Engineers, or they may be administered by CENTCOM Joint 

22DOD defines the term “contingency contract” as a legally binding agreement for 

supplies, services, and construction let by government contracting officers in the 

operational area, as well as other contracts that have a prescribed area of performance 

within a designated operational area. These contracts include theater support, external 

support, and systems support contracts. 

23LOGCAP is a program that provides worldwide logistics and base and life support 

services in contingency environments and provides the majority of base and life support 

services to U.S. forces in Iraq and Afghanistan. 
 

Page 8 GAO-12-290 Operational Contract Support

Theater Support Contracting Command contracting officers assisted by 

CORs. When DCMA is not designated responsibility for administrative 

oversight of a contract, the contracting officer who awarded the contract is 

responsible for the administration, management, and oversight of the 

contract. These contracting officers, such as those from the CENTCOM 

Joint Theater Support Contracting Command often appoint CORs to 

monitor contractor performance.24

(1) The contract will be awarded using simplified acquisition procedures;

CORs appointed by the CENTCOM 

Joint Theater Support Contracting Command are typically drawn from 

units receiving contractor-provided services. In Afghanistan, CORs that 

have been appointed to contracts administered by DCMA report oversight 

results to DCMA personnel. For contracts not administered by DCMA, 

CORs provide oversight information to the contracting officer. In 

Afghanistan, the CENTCOM Joint Theater Support Contracting 

Command directs requiring activities (units receiving contractor-provided 

goods and services) to nominate CORs for all service contracts valued at 

more than $2,500 with significant technical requirements that require 

ongoing advice and surveillance from technical/requirements personnel. 

The contracting officer may exempt service contracts from this 

requirement when the following three conditions are all met:

(2) The requirement is not complex; and

(3) The contracting officer documents the file, in writing, as to why the 

appointment of a COR is unnecessary.25

 

24Although the CENTCOM Joint Theater Support Contracting Command (C-JTSCC ) 

commander is accountable for contract administration of all DOD contracts requiring 

contractors to deploy to theater to support operations, non-C-JTSCC theater support 

contracts that are not delegated to DCMA may be re-delegated back to the originator. See 

CENTCOM Joint Theater Support Contracting Command Acquisition Instruction § 

25.7700(a) (Sept. 1, 2011).

25See CENTCOM Contracting Command Standard Operating Procedure No. 10-02: 

Contracting Officer’s Representative (COR) Program ¶ 4(A) (Rev. 2, June 2010). A 

revised version of this guidance was released while this report was in its final stages; we 

did not have the opportunity to assess this guidance. As such, we refer in this report to the 

guidance that was in effect during the period of our review. 
 

Page 9 GAO-12-290 Operational Contract Support

Although DOD requires CORs to receive training and took some actions 

to enhance training programs, CORs we met with in Afghanistan do not 

always receive adequate training to prepare them for their contract 

management and oversight duties. DOD requires that CORs be qualified 

by training and experience commensurate with the responsibilities to be 

delegated to them. According to DOD officials, the current training might 

qualify CORs to monitor contractor performance generally, but it does not 

necessarily make them sufficiently capable for their particular 

assignments. DOD officials have acknowledged gaps in training. For 

example, required DOD training taken by CORs did not fully address the 

unique contracting environment that exists in Afghanistan, which includes 

large numbers of Afghan contractors with limited experience and 

qualifications. Further, the instability and security aspects of remote 

locations throughout Afghanistan coupled with an undeveloped 

infrastructure impedes the CORs’ ability to communicate with and rely 

upon acquisition personnel, such as contracting officers, for support and 

guidance. Additionally, not all of the required training for CORs was 

conducted, and some other oversight personnel were not being trained.

In Afghanistan, much of the daily surveillance of contractors supporting 

military operations is performed by CORs. The Federal Acquisition 

Regulation (FAR) requires that quality assurance, such as surveillance, 

be performed at such times and places as may be necessary to

determine that the supplies or services conform to contract requirements. 

26 DOD guidance requires CORs to be trained and assigned prior to 

award of a contract. DOD training is intended to familiarize the CORs with 

the duties and responsibilities of contract management and oversight. 

Contracting organizations such as the CENTCOM Joint Theater Support 

Contracting Command require that personnel nominated to be CORs 

complete specific online training courses27

 

26This surveillance generally involves government oversight of contractors with the 

purpose of ensuring that the contractor (the service provider) performs the requirements of 

the contract and the government (the service receiver or customer) receives the service 

as intended. 

 (referred to as Phase I), as 

well as locally developed CORs overview training, and contract-specific 

training provided by contracting officers in theater (the latter referred to as 

27Online CORs training was provided by the Defense Acquisition University; and the Army 

offers an on-line course for deployed CORs, which covered the same information as the 

40-hour course provided by the Army Logistics University. 

DOD Took Steps to 

Enhance Existing 

Training Program, but 

Existing Training 

Does Not Fully 

Prepare CORs for 

Contract Management 

and Oversight Duties

CORs Are Required to 

Receive Training and DOD 

Took Some Actions to 

Enhance Existing Training 

Programs
 

Page 10 GAO-12-290 Operational Contract Support

Phase II) before they can serve as CORs in Afghanistan. The guidance 

notes that, at a minimum, Phase II training will consist of contract specific 

responsibilities, including file documentation; terms and conditions of the 

contract; specifics of the performance work statement; acceptance of 

services procedures; invoice procedures; technical requirements; monthly 

reporting procedures, and contractor evaluation—all specific to their 

assigned contract.

DOD has taken some actions to enhance training programs to prepare 

CORs to manage and oversee contracts in contingency operations, such 

as in Afghanistan. For example, DOD developed a new training course for 

CORs, with a focus on contingency operations and developed a more 

general certification program for CORs, including the contingency 

operations course as a training requirement when it is applicable.28 DOD 

also took steps to institutionalize operational contract support by including 

some CORs-related training in professional military education programs 

and by emphasizing the need for qualified CORs by discussing their 

responsibilities in joint doctrine and other guidance with the publication of 

Joint Publication 4-10—Operational Contract Support and the Defense 

Contingency Contracting Officer’s Representative Handbook and 

memoranda issued by the Deputy Secretary of Defense.

Our analysis of DOD’s CORs training and interviews with over 150 CORs 

and contracting personnel from over 30 defense organizations like the 

regional contracting centers29

 

28In addition to DOD actions, there are other similar government-wide efforts to revamp 

federal CORs policies. In September 2011, the Office of Federal Procurement Policy 

issued a memorandum describing revisions to the Federal Acquisition Certification for 

CORs. The purpose of the program, which applies to all executive agencies except DOD, 

is to establish general training, experience, and development requirements for CORs that 

reflect the various types of contracts they manage. See Memorandum from Daniel I. 

Gordon, Administrator, Office of Federal Procurement Policy, Revisions to the Federal 

Acquisition Certification for Contracting Officer’s Representatives (FAC-COR) (Sept. 6, 

2011).

and the DCMA in Bagram, Kabul, 

Kandahar, and Camp Leatherneck, Afghanistan, indicated that some 

gaps and limitations existed in DOD’s training programs leaving CORs 

not fully prepared to perform their contract management and oversight 

29Regional Contracting Centers are involved in planning, coordinating, and managing 

theater support contracting for deployed U.S. forces and multinational forces support in 

Afghanistan. 

Available DOD Training 

Does Not Fully Prepare 

CORs to Oversee 

Contracts in Afghanistan
 

Page 11 GAO-12-290 Operational Contract Support

duties. For example, the training for CORs is generally focused on lowrisk contract operations in Afghanistan and does not fully address the 

unique contracting environment that exists there, such as the extent of 

inexperience of Afghan contractors, the remote and insecure locations of 

project sites, the underdeveloped infrastructure, and constraints on the 

movement and deployment of oversight personnel, especially acquisition 

personnel. More specifically, the required CORs training does not include 

information about important issue areas like the Afghan First Program, 

which encourages an increased use of local personnel and vendors for 

supplies and services as part of the U.S. counterinsurgency30

Contracting officials from over 30 defense organizations and units in 

Bagram, Kabul, Kandahar, and Camp Leatherneck whom we spoke with 

strategy, 

and working with private security contractors. Some CORs in Afghanistan 

told us they were unaware of the challenges in working with Afghan 

contractors and thought contracting with them would be similar to 

contracting with U.S. vendors. However, according to some of the CORs 

and other contracting personnel we interviewed, providing oversight of 

Afghan contractors was more challenging than was the case with other 

vendors because the Afghan contractors often did not meet the timelines 

specified in the contract, did not provide the quality products and the 

services the units had anticipated, and did not necessarily have a working 

knowledge of English. Further, these officials told us that Afghan 

contractors were not always familiar with the business standards and 

processes of the U.S. government. For example, one COR told us during 

our visit in February 2011 that a unit was still waiting for barriers that it 

had contracted for in May 2010. According to that COR, while some of the 

barriers had been delivered, the unit had not received all of the barriers it 

required even though the contract delivery date had passed. Other CORs, 

contracting officials, and commanders described similar situations in 

which services were either not provided as anticipated or were not 

provided at all. Because of gaps in training, CORs did not always 

understand the full scope of their responsibilities and did not always

ensure that the contractor was meeting all contract requirements. As a 

result, according to contracting officials, items such as portable toilets, 

gates, water, and other items or services were not available when 

needed, raising concerns about security, readiness, and morale.

 

30Commander, International Security Assistance Force/United States Forces—

Afghanistan, COMISAF’s Counterinsurgency (COIN) Contracting Guidance (Sept. 8, 

2010).
 

Page 12 GAO-12-290 Operational Contract Support

noted similar problems with construction contracts awarded to Afghan 

contractors. For example, according to another COR, an Afghan 

contractor was awarded a $70,000 contract to build a latrine, shower, and 

sink unit. The COR told us that the contractor was unable to satisfactorily 

complete the project and so another contract was awarded for 

approximately $130,000 to bring the latrine, shower, and sink unit to a 

usable condition. Because of inadequacies in training, CORs did not 

always understand that they had the responsibility to ensure that the 

terms of the contract were met and therefore did not bring contractors’ 

performance issues to the contracting officer’s attention for resolution. 

Similarly, DOD contracting officials provided us with documentation of 

other construction problems, including a shower/toilet facility built without 

holes in the walls or floors for plumbing and drain (fig. 1), and facilities 

that were constructed with poor-quality materials such as crumbling 

cement blocks (fig. 2).31 The Special Inspector General for Afghanistan 

Reconstruction32

 

31The photographs in this report were selected from photographs provided by DOD 

personnel and were not necessarily a representation of the contract environment in 

Afghanistan. Any construction problems or other defects identified in the photographs are 

derived from statements from officials or DOD documentation.

has also reported significant construction deficiencies 

related to contracting in Afghanistan, including poorly formed and 

crumbling cement structures attributable to the lack of CORs training and 

oversight.

32Special Inspector General Afghanistan Reconstruction, ANP District Headquarters 

Facilities in Helmand and Kandahar Provinces Have Significant Construction Deficiencies 

Due to Lack of Oversight and Poor Contractor Performance (Oct. 27, 2010).
 

Page 13 GAO-12-290 Operational Contract Support

Figure 1: Shower/Toilet Facility Constructed without Holes in the Walls or Flooring 

for Plumbing and Drain

Figure 2: Poor-Quality Materials—Crumbling Cement Blocks
 

Page 14 GAO-12-290 Operational Contract Support

Because of the nature and sensitivity of security contracts, CORs for 

private security contractors’ contracts have unique responsibilities. For 

example, during the period of our review, under guidance in place prior to 

June 2011, CORs were responsible for compiling a monthly weapons 

discharge report and for ensuring contractor adherence to contractual 

obligations on topics such as civilian arming requirements, personnel 

reporting systems, property accountability, and identification badges. 

According to a senior military officer with U.S. Forces Afghanistan’s 

private security contractor task force, because of gaps in training, CORs 

did not always understand the full scope of their responsibilities and so 

did not always ensure that a contractor was meeting all contract 

requirements. He noted that CORs did not always understand that they 

had the responsibility to ensure that the terms of the contract were met 

and therefore did not bring contractors’ performance issues to the 

contracting officer’s attention for resolution. As a result, DOD may pay 

contractors for poor performance and installations might not receive the 

level of security contracted for.

Further, we found that the training programs lacked specifics on the 

preparation of statements of work or documents required for acquisition 

review boards—two contract management responsibilities that CORs in 

Afghanistan were routinely tasked to do. Although the development of a 

statement of work involves a variety of participants from the contracting 

process, a COR may be uniquely suited to have an early impact on the 

development of a complete and accurate statement of work. The Defense 

Contingency Contracting Officer’s Representative Handbook describes 

statements of work as specifying the basic top-level objectives of the 

acquisition as well as the detailed requirements of the government. The 

statement of work can provide the contractor with “how to” instructions to 

accomplish the required work. It could provide a detailed description of 

what is expected of the contractor and forms part of the basis for 

successful performance by the contractor and effective oversight of 

contracts by the government. Well-written statements of work are needed 

to ensure that units get the services and goods needed in the required 

time frame. As we reported in 2000 and 2004, poorly written statements 

of work can also increase costs and the number of substandard supplies 

and services provided by the contractor.33

 

33GAO, Military Operations: DOD’s Extensive Use of Logistics Support Contracts 

Requires Strengthened Oversight, 

 Based on discussions with 

GAO-04-854 (Washington, D.C.: July 19, 2004).
 

Page 15 GAO-12-290 Operational Contract Support

contracting personnel from four major bases in Afghanistan responsible 

for reviewing these documents, statements of work prepared by CORs 

were vague and lacked the specifics needed to provide units with what 

they wanted. We were told by multiple DOD officials that some CORs 

routinely cut and paste information from previous statements of work into 

their current document without adapting it as needed, resulting in errors 

that have to be corrected and further extending the time involved in 

procuring a good or service. Contracting personnel told us of instances in 

which statements of work had to be rewritten because the original 

statements of work did not include all the required contractor actions, or 

because they included incorrect requirements. Although there are other 

DOD contracting personnel involved in the requirement and procurement 

process, CORs can help to ensure that well-articulated needs are more 

fully documented at an early stage. DOD contracting personnel 

responsible for reviewing and approving requests for contract support told 

us that poorly written statements of work were a principal reason units do 

not receive the operational contract support they need for sustaining 

military operations. Because of gaps in training, CORs were unable to 

prepare well-articulated statements of work that clearly define the 

warfighters’ needs. For example, DOD contracting personnel told us 

about a dining facility in Afghanistan that was built without a kitchen 

because it was not included in the original statement of work, resulting in 

DOD having to generate a separate statement of work for the kitchen. 

According to contracting officials and commanders, poorly written 

statements of work increase the procurement process time, the workload 

burden on the DOD contracting personnel, and delays and disruptions in 

critical supplies and services needed for the mission.

Moreover, according to DOD, one of the acquisition review boards in 

Afghanistan, known as the Joint Acquisition Review Board, reviews and 

recommends approval or disapproval of proposed acquisitions to ensure 

efficiency and cost effectiveness.34

 

34As described in Joint Publication 4-10, the Joint Acquisition Review Board’s main role is 

to make specific approval and prioritization recommendations for all geographic 

combatant commander directed, subordinate joint force commander controlled, high-value 

and/or high-visibility common user logistics requirements, and to include 

recommendations on the proper source of support for these requirements. See Joint Pub. 

4-10 (Oct. 17, 2008).

DOD contracting personnel 

responsible for reviewing acquisition proposals told us that delays and 

disruptions in supplies and services needed by the unit have been 
 

Page 16 GAO-12-290 Operational Contract Support

attributed to incomplete or incorrect documents, such as statements of 

work. Since CORs in Afghanistan are heavily relied upon by their units 

and the acquisition personnel in the development of these documents, it 

is important that they understand what paperwork is required and how to 

properly complete it in order to obtain needed goods and services in a 

timely manner. Contracting officials acknowledge the challenges with 

preparing complete/correct statements of work and DOD is making some 

effort to address the gaps in training. For example, the Defense 

Acquisition University provides a training course on preparing 

requirements documents such as statements of work; however, it is not a 

DOD requirement for CORs and contracting personnel to complete this 

training before assuming their contract-related roles and responsibilities.

DOD contracting personnel and CORs in Afghanistan told us that the 

CENTCOM Joint Theater Support Contracting Command contracting 

officers were frequently unable to provide the required contract-specific 

training (Phase II) for CORs because they were busy awarding contracts. 

For instance, a COR whom we interviewed in Afghanistan was directing a 

contractor to perform construction work or correct deficiencies in 

performance without authorization from or communication with the 

contracting officer. Because the COR had never received the required 

training from the contracting officer, he was not aware that this practice 

was potentially unauthorized. Without the follow-on Phase II training from 

the contracting officer, CORs may lack a clear and full understanding of 

the scope of their contract duties and responsibilities. In contrast, DCMA’s 

contracting personnel provide specific contract training and mentoring to 

its CORs because DCMA has full-time quality assurance personnel who 

have been tasked with providing COR training and assistance. According 

to DCMA officials, certified quality assurance representatives continue to 

mentor CORs after their formal training has been completed.

Moreover, in addition to CORs, other personnel expected to perform 

contract oversight and management duties in Afghanistan are not always 

being trained. Joint Publication 4-10 states that military departments are 

responsible for ensuring that military personnel outside the acquisition 

workforce who are expected to have acquisition responsibility, including 

oversight duties associated with contracts or contractors are properly 

trained.35

 

35See Joint Pub. 4-10 at II-8 (Oct. 17, 2008).

The Joint Publication also highlights the key role of 

Not All CORs Receive 

Required Training
 

Page 17 GAO-12-290 Operational Contract Support

commanders and senior leaders in operational contract support oversight. 

However, contracting personnel that we interviewed in Afghanistan told 

us that military personnel such as commanders and senior leaders did not 

always receive training on their contract management and oversight 

duties in Afghanistan and that commanders, particularly those in combat 

units, do not perceive operational contract support as a warfighter task.36

Although some contracting-related training is available for commanders 

and senior leaders, it is not required before deployment. DOD has not 

expanded the professional military education curriculum by increasing the 

number of training offerings on operational contract support with a 

particular emphasis on contingency operations to fully institutionalize 

operational contract support in professional military education. Based on 

our previous findings, it is essential that commanders and senior leaders 

complete operational contract support training before deployment to avoid 

confusion regarding their contract role and responsibilities in managing 

and overseeing contractors, and nominating qualified CORs. In 2006, we 

recommended that operational contract support training be included in the 

professional military education to ensure that all military personnel 

expected to perform contract management duties, including commanders 

and senior leaders, receive training prior to deployment. DOD has taken 

some actions to implement this recommendation by developing some 

Programs of Instruction on contingency acquisition for their nonacquisition workforce to be taught at some of the military and senior staff 

colleges. However, commanders and senior leaders are not required to 

take these courses before assuming their contract management and 

oversight roles and responsibilities.

 

36Commanders and senior leaders generally lack the authority to enter into contracts or 

otherwise direct contractors or contract performance. However, as noted in Joint 

Publication 4-10, these personnel play a key role in determining specific contracted 

support requirements, contracting planning, and execution of OCS oversight, which we 

include here in the term “contract management and oversight.” 
 

Page 18 GAO-12-290 Operational Contract Support

CORs did not always have the subject area-related technical expertise or 

access to subject matter experts with those skills to manage and oversee 

contracts in Afghanistan, especially those contracts of a highly technical 

and complex nature. The Defense Contingency Contracting Officer’s 

Representative Handbook indicates that CORs are responsible for 

determining whether products delivered or services rendered by the 

contractor conform to the requirements for the service or commodity 

covered under the contract. Further, the Contracting Officer’s 

Representative Handbook notes that CORs should have technical 

expertise related to the requirements covered by the contract.

However, according to CORs and contracting personnel we interviewed in 

Afghanistan, CORs did not have the subject area-related technical 

expertise necessary to monitor contract performance for the contracts 

they were assigned to oversee. For example, many of these CORs were 

appointed to oversee construction contracts without the necessary 

engineering or construction experience, in part because their units lacked 

personnel with those technical skills. While DCMA had subject matter 

experts in key areas such as fire safety available for CORs needing 

technical assistance, CORs for contracts written by the CENTCOM Joint 

Theater Support Contracting Command did not have subject matter 

experts to turn to for assistance, particularly in the construction trades 

during the time of our visit. As a result, according to officials, there were 

newly constructed buildings that had to be repaired or rebuilt before being 

used by U.S. and Afghan troops because the CORs providing the 

oversight were not able to adequately ensure proper construction. 

According to personnel we interviewed, these practices resulted in 

wasted resources, low morale, and risks to the safety of base and 

installation personnel where the deficient guard towers, fire stations, and 

gates were constructed. Officials stated that it is not uncommon for a 

COR to accept a portion of the contractor’s work only to find later upon 

further examination that the work was not in accordance with the contract 

and substandard. Similarly, officials stated that the LOGCAP personnel 

did not accept responsibility for maintenance of a facility that had been 

constructed by Afghan contractors until LOGCAP contractors first 

repaired or replaced wiring and plumbing to meet building codes. 

Although the CORs were not solely responsible for contract oversight, or 

for the implications identified above, they could have provided an early 

verification of contractor performance. More importantly, in the 

Afghanistan contracting environment the DOD contracting personnel 

ultimately responsible for oversight—such as contracting officers—were 

often removed or absent from the remote locations where the work was 

performed and had no ability to communicate electronically. This results 

CORs Do Not Always 

Have the Subject 

Area-Related 

Technical Expertise 

Needed to Oversee 

Some Contracts
 

Page 19 GAO-12-290 Operational Contract Support

in greater reliance on CORs and reduces the opportunity for CORs to 

identify problems early in the process. The following were cases that 

further illustrate the impact of CORs not having the technical skills or 

support needed to perform contract management and oversight. Although 

the CORs did not necessarily bear the sole responsibility for 

consequences identified below, a well-trained COR might have been able 

to prevent or mitigate the effects of the problems.

• According to officials, a COR prepared a statement of work for a 

contract to build floors and install tents but failed to include any power 

requirements necessary to run air conditioners, heaters, and lights 

because the COR and unit personnel did not have the electrical 

technical expertise to properly and safely specify the correct power 

converter package37

• Contracting officials told us that guard towers at a forward operating 

base were poorly constructed and unsafe to occupy. As shown in 

figure 3, the staircase was unstable and not strong enough for 

climbing; it had to be torn down and reconstructed. The COR’s 

inadequate subject area-related technical expertise or access to 

subject matter experts prevented the early identification of defective 

welding on the staircase that rendered it unsuitable to use to climb up 

the guard tower.

with the original request. Thus, the tents were 

unusable until the unit used a field ordering officer to order, at an 

additional cost, the correct power converters so that the tents were 

usable and completed in a timely fashion.

 

37A power converter package comprises a fuse box, electrical wiring and other electrical 

materials enabling connection to a power supply such as a generator, to run air 

conditioners, heaters, and lights in the tents.
 

Page 20 GAO-12-290 Operational Contract Support

Figure 3: Unstable Staircase for Guard Towers

• A senior engineer inspector official told us the cement block walls that 

had been accepted by a COR were poorly constructed. The COR did 

not have the subject area-related technical expertise or access to 

subject matter experts necessary to properly inspect and reject 

substandard cement block walls. For example, the contracting official 

noted large holes in a cement block wall that remained after the wood 

scaffolding was removed, which rendered the wall unstable (fig. 4). 
 

Page 21 GAO-12-290 Operational Contract Support

Figure 4: Cement Block Wall with Large Holes That Remained When Scaffolding 

Was Removed

• A dining facility expected to service 1,000 military personnel was 

unused for a year due to emergent construction deficiencies such as 

electrical and plumbing issues. Contracting officials attributed the 

construction issues to the shortage of oversight personnel with subject 

area-related technical expertise or access to subject matter experts in 

construction. As a result, according to contracting personnel, repair 

work to correct the deficiencies was acquired under LOGCAP for 

$190,000 in addition to the original cost of the contract.

The issue of CORs not having adequate subject area-related technical 

expertise has been a longstanding problem in DOD. For example, we 

have previously reported in 2006, 2008, and again in 2010 that CORs do 

not always have the subject area-related technical expertise necessary to 

oversee contracts.38

 

38

More recently in November and August 2011, the 

Congressional Research Service and the Commission on Wartime 

Contracting in Iraq and Afghanistan reported that DOD is still in need of 

non-acquisition personnel with the necessary technical and subject matter 

GAO-07-145, GAO-08-1087, and GAO-10-472. 
 

Page 22 GAO-12-290 Operational Contract Support

expertise to perform contractor oversight, respectively.39 The Special 

Inspector General for Afghanistan Reconstruction40

Further, based on DOD documentation, the nature of contract work in 

Afghanistan has become more technical and complex, increasing the 

number of CORs needed, the amount of time needed to award contracts, 

and the number of errors during the early stages of the contracting 

process (e.g., the requirements determination process). Due to the 

complexity of construction projects in Afghanistan, DOD established an 

initiative in April 2011 to assign construction inspectors to assist CORs in 

managing and overseeing construction projects. According to a DOD

memorandum,

has also reported 

significant construction deficiencies with contracting in Afghanistan as a 

result of inadequate subject area-related technical expertise on the part of 

CORs and other contract oversight personnel. Problem areas identified 

by the Inspector General included low-quality concrete (similar to 

conditions depicted in fig. 2 and fig. 4) and inadequate roofing 

installations, which were similar to other deficiencies we identified.

41

 

39Congressional Research Service, Report Number R42084, Wartime Contracting in 

Afghanistan: Analysis and Issues for Congress, by Moshe Schwartz, November 14, 2011 

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

Contracting: Controlling Cost and Reducing Risks, Final Report to Congress, August 

2011.

contracting officers should appoint construction 

inspectors, in addition to CORs, when the nature of the project requires 

technical assistance to ensure proper performance of work and when 

such assistance is available. Because this program was not in effect 

during the time of our visit in February 2011, we are unable to assess the 

effectiveness of the use of construction inspectors. However, based on 

our observations in Afghanistan, there is a shortage of subject arearelated technical experts that can serve as construction inspectors in 

Afghanistan. CORs and other personnel that we interviewed in 

Afghanistan acknowledged the benefit of having subject matter experts in 

construction as well as other specialty areas such as food-, fuel-, and 

electricity-related services. 

40Special Inspector General Afghanistan Reconstruction, ANP District Headquarters 

Facilities in Helmand and Kandahar Provinces Have Significant Construction Deficiencies 

Due to Lack of Oversight and Poor Contractor Performance, October 27, 2010.

41Senior Contracting Official-Afghanistan (SCO-A), Memorandum for SCO-A Contracting 

Officers-Inspector Duties for Construction Contractors (Apr. 27, 2011).
 

Page 23 GAO-12-290 Operational Contract Support

DOD does not have a sufficient number of CORs to oversee the 

numerous contracts in Afghanistan42 and, according to some government 

officials, there are not enough CORs in theatre to conduct adequate 

oversight.43 The CENTCOM Joint Theater Support Contracting Command 

requires the nomination of CORs for all service contracts worth over 

$2,500 with significant technical requirements that require on-going

advice and surveillance from technical or requirements personnel, unless 

exempted by the contracting officer.44

 

42We did not review every contract in Afghanistan managed by CORs. Our findings were 

based on information obtained from DOD contracting personnel in Afghanistan—units that 

we selected based on availability. 

Although there is no specific 

guidance on the number of contracts a single COR should manage, the 

CENTCOM Joint Theater Support Contracting Command requires that 

CORs nominations signed by the unit commander contain a statement 

verifying that the CORs will have sufficient time to perform assigned 

tasks. Similarly, the Defense Contingency Contracting Officer’s 

Representative Handbook states that the requiring unit must allow 

adequate resources (time, products, equipment, and opportunity) for the 

CORs to perform their functions. In 2004, 2006, and again in 2010, we 

reported that the DOD did not have a sufficient number of trained 

oversight personnel, and during the course of our review we noted that 

this situation persisted. Further, we found that CORs do not always have 

the time needed to complete their oversight responsibilities. While 

available data do not enable us to determine the precise number of 

contracts that require CORs, in fiscal year 2011, DOD completed over 

35,000 contracting actions on over 24,600 contracts and orders that were 

43Congressional Research Service, Report Number R42084, Wartime Contracting in 

Afghanistan: Analysis and Issues for Congress, by Moshe Schwartz, November 14, 2011, 

p.5.

44Contracting officers may exempt service contracts from the requirement when the 

following three conditions are met: (1) the contract will be awarded using simplified 

acquisition procedures; (2) the requirement is not complex; and (3) the contracting officer 

documents the file, in writing why the appointment of a COR is unnecessary.

Number of CORs Is 

Not Sufficient to 

Adequately Oversee 

the Contracts in 

Afghanistan
 

Page 24 GAO-12-290 Operational Contract Support

executed primarily in Afghanistan.45

In another instance, an entire compound of five buildings was built in the 

wrong location. According to DOD, based on the statement of work, the 

compound should have been constructed on base behind the security 

walls but instead was constructed outside the perimeter of the base in a 

non-secure location. Contracting officials we spoke with in Afghanistan 

attributed the problem to the numerous contracts managed by the COR 

and the lack of time to perform contract oversight duties. As a result, 

according to officials, the buildings (shown in fig. 5) could not be used.

The cost of the compound including the five buildings was $2.4 million.

According to contracting officials and 

CORs we interviewed in Afghanistan, some CORs are responsible for 

providing oversight to multiple contracts in addition to performing their 

primary military duty. For example, one COR we interviewed was 

assigned to more than a dozen construction projects. According to the 

COR, it was impossible to be at each construction site during key phases 

of the project, such as for the concrete pouring of building footings, wiring 

installation, or plumbing. Consequently, according to contracting officials, 

construction on these multiple projects was completed without sufficient 

government oversight and problems were not always identified until the 

building was completed. This often resulted in significant rework, at a cost 

to the U.S. taxpayer.

 

45Data based on GAO analysis of Federal Procurement Database System-Next 

Generation Data as of January 2012. The number of contracts includes stand-alone 

contracts for goods and services, as well as purchase, delivery, and task orders; Blanket 

Purchase Agreements and Indefinite Delivery/Indefinite Quantity contracts are not 

included, but the orders under them are. The number of contract actions includes 

contracts and orders awarded or modified where the place of performance was identified 

as Afghanistan. Federal Procurement Database System-Next Generation Data includes 

unclassified contracts that are estimated to be $3,000 or more and any modifications to 

these contracts regardless of dollar value. Although modifications do not themselves 

necessarily require the appointment of a new COR, they may indicate contract activity that 

would necessitate continued COR involvement.
 

Page 25 GAO-12-290 Operational Contract Support

Figure 5: Compound Comprising Five Buildings Constructed in a Non-Secure 

Location outside the Perimeter of a Base

In addition, in some cases units did not assign enough CORs to provide 

oversight. For example, we were told by one unit that it did not have a 

sufficient number of CORs to provide proper oversight of dining facility 

services, including ordering and inspecting food and supplies. Although 

the unit was able to provide one COR for each dining facility, the dining 

facilities operate 24 hours a day. Contracting officials expressed concern 

that there were not enough CORs to provide sufficient oversight of the 

dining facilities 24 hours a day during all shifts of operation.

A significant factor that might contribute to a shortage of CORs is that 

contract oversight is often assigned a lower priority for units than tasks 

associated with their primary missions. Army officials stated that 

commanders, particularly those in combat units, do not perceive contract 

management and oversight as a warfighter task. In a March 2010 report, 

we noted that commanders and senior leaders often view operational 

contract support as a logistics problem or a contracting problem and not 

as a responsibility of the entire force. Most of the CORs we interviewed 

performed their contract duties as an additional duty to their military 

responsibilities. As a result, these CORs said they did not always have 

the time to complete their oversight responsibilities or that not enough 

CORs were assigned to a contract to provide sufficient oversight. In fact, 

some commanders and other personnel we interviewed questioned the 

idea that units should be responsible for contract oversight, and believed 
 

Page 26 GAO-12-290 Operational Contract Support

that contract oversight should be provided by other organizations. While 

DOD is experiencing a shortage of CORs in Afghanistan, the amount of 

money spent on contracts has increased as evidenced by the increase in 

reported DOD obligations for contracts—from $11 billion in fiscal year

2010 to $16 billion in fiscal year 2011. Additionally, the turnover rate of 

CORs is high due to unit rotations, frequently leaving gaps in contract 

coverage. Based on guidance from the Commander of the International 

Security Assistance Force and United States Forces-Afghanistan issued 

in September 2010,46 even more personnel are needed to oversee 

contracts as a result of this increase.

DOD and the services have taken some steps, such as developing a new 

CORs training course with a focus on contingency operations to improve 

oversight of contracts in contingency operations, such as in Afghanistan; 

other more general efforts, such as the COR certification program for 

services’ acquisitions, may also lead to improvement. However, in our 

work in Afghanistan we found that CORs are still not fully prepared to 

oversee the multitude of contracts for which they are assigned, potentially 

resulting in a significant waste of taxpayer dollars and an increased risk to 

the success of operations. The current mechanism for training CORs that 

also perform duties related to the requirements determination process 

and to the development of requirements documentation continues to have 

weaknesses because DOD has not yet developed training standards to 

ensure that these personnel fully understand Joint Operational Area 

specific issues such as the Afghan First program, the Counterinsurgency 

Contracting Guidance, and the details on the preparation of statements of 

work and documents required by the contract review boards. As noted in 

an Army Contracting Command publication, what contracting 

organizations do and how they do it cannot be foreign to the warfighter. 

Military personnel such as commanders, senior leaders, CORs, and other 

personnel expected to have a role in operational contract support are 

often not familiar with their contract roles and responsibilities until they 

reach theater because DOD has not sufficiently expanded the 

professional military education curriculum and provided more training on 

contract support with a particular emphasis on contingency operations. 

Further, having an insufficient number of CORs with the appropriate 

 

46 Commander, International Security Assistance Force/United States Forces - 

Afghanistan, COMISAF’s Counterinsurgency (COIN) Contracting Guidance (Sept. 8, 

2010).

Conclusions
 

Page 27 GAO-12-290 Operational Contract Support

subject area-related technical expertise or access to dedicated subject 

matter experts in specialty areas hinders DOD’s ability to ensure that 

operational units obtain vital supplies and services when needed. 

Moreover, contract management and oversight has become more 

challenging due to a shortage of oversight personnel, an increase in the 

number of contracts, a high personnel turnover rate, training burden 

challenges, and an increase in the complexity of the work contracted. All 

of these have resulted in delays and errors in the procurement process. 

Further, as a result of these workload constraints, military personnel 

serving as CORs are limited in the number of contracts that they can 

reasonably manage and oversee considering the technical nature and 

complexity of each contract. Given DOD’s heavy reliance on contractors 

during operations in Afghanistan and given the unpredictability of 

potential future contingencies, it is critical that DOD address these 

challenges as soon as possible to mitigate the risk to the success of 

operations, to obtain reasonable assurance that contractors are meeting 

their contract requirements and that troops are getting what they need to 

support contingency operations, and to help ensure that tax dollars are 

not being wasted.

To provide for improved oversight of operational contract support, we are 

recommending that DOD enhance the current strategy for providing 

contract management and oversight in Afghanistan and other areas of 

operations. Specifically, we recommend that the Secretary of Defense 

take the following four actions:

• Direct the CENTCOM Commander in consultation with the 

Secretaries of the military departments to develop standards for 

training to ensure that CORs are fully trained on the contract support 

in Afghanistan, to include information on the Afghan First program, 

Counterinsurgency Contracting Guidance, and details on the 

preparation of statements of work and documents required by the 

contract review boards.

• Direct the Chairman of the Joint Chiefs of Staff and the Secretaries of 

the military departments to fully institutionalize operational contract 

support in professional military education to ensure that CORs, 

commanders, senior leaders, and other personnel expected to 

perform operational contract support duties are prepared to do so by 

integrating and expanding the curriculum and by increasing the 

number of training offerings on operational contract support with a 

particular emphasis on contingency operations.

Recommendations for 

Executive Action
 

Page 28 GAO-12-290 Operational Contract Support

• Direct the Under Secretary of Defense for Acquisition, Technology, 

and Logistics in consultation with the appropriate CENTCOM officials 

to establish and maintain a sufficient number of subject matter experts 

in specialty areas dedicated to the CENTCOM Joint Theater Support 

Contracting Command to assist CORs with providing contract 

oversight.

• Direct the Under Secretary of Defense for Acquisition, Technology, 

and Logistics to develop standards regarding the number of contracts 

that a COR can manage and oversee based on the technical nature 

and complexity of the contract.

We provided a draft of this report to DOD for comment. In written 

comments, DOD concurred with our recommendations. DOD’s comments 

are reprinted in their entirety in appendix II. DOD also provided technical 

comments, which we incorporated into the report as appropriate.

DOD concurred with our recommendation that the Secretary of Defense 

direct the CENTCOM Commander in consultation with the Secretaries of 

the military departments to develop standards for training to ensure that 

CORs are fully trained in contract support in Afghanistan, to include 

information on the Afghan First program, Counterinsurgency Contracting 

Guidance, and details on the preparation of statements of work and 

documents required by the contract review boards. DOD stated that 

CENTCOM has identified COR training in its pre-deployment requirement 

for units and personnel being deployed to Afghanistan, referring to 

fragmentary order 09-1700, which lists theater training requirements for 

forces deploying to the CENTCOM area of responsibility. Although the 

fragmentary order identifies COR training as a training requirement for 

certain personnel, the wording in this order lacks the specificity to 

adequately prepare CORs for contract support in Afghanistan. For 

example, the fragmentary order does not require that CORs be trained on 

how to use the Afghan First Program and the Counterinsurgency 

Contracting Guidance and on how to prepare the statements of work and 

other documents required by the contract review boards. DOD further 

stated that CENTCOM reviewed and updated pre-deployment training 

requirements during a conference in early January 2012, but did not 

provide any specific information on what those updates entailed. DOD 

also stated that the COR training requirement will remain as required predeployment training and that an updated version of the pre-deployment 

requirement will be finalized and released no later than April 2012. 

Because DOD did not provide any specific details on what, if any, 

changes to training requirements will be included in its April 2012 update, 

Agency Comments 

and Our Evaluation
 

Page 29 GAO-12-290 Operational Contract Support

we are unable evaluate the extent to which DOD’s proposed actions 

would address our recommendations.

DOD concurred with our recommendation that the Secretary of Defense 

direct the Chairman of the Joint Chiefs of Staff and the Secretaries of the 

military departments to fully institutionalize OCS in professional military 

education by increasing the number of training offerings with a particular 

emphasis on contingency operations to ensure that CORs, commanders, 

senior leaders, and other personnel expected to perform OCS duties are 

prepared to do so. DOD stated that the Deputy Assistant Secretary of 

Defense for Program Support in the Office of the Under Secretary of 

Defense for Acquisition, Technology and Logistics and the Director of 

Logistics in the Joint Staff are currently engaged in a study to develop a 

strategy for OCS professional military education and that DOD recognizes 

the need for a holistic view of the entire OCS education requirement. 

DOD said it will assess existing professional military education to 

recommend OCS learning objectives for appropriate places in existing 

curricula. Additionally, DOD stated that the Army has recently taken major 

steps to improve training for commanders, senior leaders, and personnel 

expected to perform OCS duties. However, DOD did not describe what 

specific steps DOD has taken to fully institutionalize OCS in professional 

military education. Further, while it is commendable that DOD is 

developing a strategy for the OCS professional military education, DOD 

did not indicate when its strategy would be completed. Until DOD 

expands the curriculum and increases the number of training offerings on 

OCS, contract management and oversight in Afghanistan will continue to 

be hindered.

DOD concurred with our recommendation that the Secretary of Defense 

direct the Under Secretary of Defense for Acquisition, Technology, and 

Logistics in consultation with the appropriate CENTCOM officials to 

establish and maintain a sufficient number of subject matter experts in 

specialty areas dedicated to the CENTCOM Joint Theater Support 

Contracting Command to assist CORs with providing contract oversight. 

DOD stated that the Undersecretary of Defense for Acquisition, 

Technology, and Logistics will work through the Joint Staff to have 

CENTCOM identify the requirements for dedicated subject matter experts 

and the military departments to source these positions within budget 

constraints, and that the subject matter experts will be sourced through 

the normal requirements process. We agree that this proposed strategy 

has the potential to address our recommendation to establish and 

maintain a sufficient number of subject matter experts in specialty areas.
 

Page 30 GAO-12-290 Operational Contract Support

DOD concurred with our recommendation that the Secretary of Defense 

direct the Under Secretary of Defense for Acquisition, Technology, and 

Logistics develop standards regarding the number of contracts that a 

COR can manage and oversee based on the technical nature and 

complexity of the contract. DOD agreed that there is a limit to the number 

of contracts that a COR can support. Further, DOD stated that the Under 

Secretary of Defense for Acquisition, Technology, and Logistics will 

develop and publish appropriate standards based on the technical nature 

and complexity of the contract. We agree that these actions, if fully 

implemented, would address the intent of our recommendation.

We are sending copies of this report to interested congressional 

committees, the Secretary of Defense, the Chairman of the Joint Chief of 

Staff, the Under Secretary of Defense for Personnel and Readiness, the

Under Secretary of Defense for Acquisition, Technology & Logistics,

Secretaries of the Army, Navy and Air Force, the Commandant of the 

Marine Corps, and the Commander of CENTCOM. This report will be 

available at no charge on GAO’s website, http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (404) 679-1808 or russellc@gao.gov. Contact points for our Offices 

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

page of this letter. GAO staff who made key contributions are listed in 

appendix III.

Cary B. Russell, 

Acting Director, Defense Capabilities and Management
 

Page 31 GAO-12-290 Operational Contract Support

List of Committees

The Honorable Carl Levin

Chairman

The Honorable John McCain

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Daniel Inouye

Chairman

The Honorable Thad Cochran

Ranking Member

Subcommittee on Defense

Committee on Appropriations

United States Senate

The Honorable Howard P. McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable C.W. Bill Young

Chairman

The Honorable Norman D. Dicks

Ranking Member

Subcommittee on Defense

Committee on Appropriations

House of Representatives
Appendix I: Scope and Methodology

Page 32 GAO-12-290 Operational Contract Support

To determine the extent to which the required Department of Defense 

(DOD) training prepares contracting officer’s representatives (COR) to 

perform their management and oversight duties in Afghanistan, we 

examined guidance, evaluated the content of the required training, and 

interviewed CORs and senior contracting personnel from over 30 defense 

organizations and units in Bagram, Kabul, Kandahar, and Camp 

Leatherneck, Afghanistan. We examined guidance such as the Joint 

Publication 4-10, the Defense Contingency Contracting Officer’s 

Representative Handbook and the U.S. Central Command (CENTCOM) 

Joint Theater Support Contracting Command Standard Operating 

Procedures addressing the CORs program1

To determine the extent to which CORs have the appropriate subject 

area-related technical expertise to oversee contracts in Afghanistan, we 

reviewed the CENTCOM Joint Theater Support Contracting Command 

Standard Operating Procedure addressing the CORs program and the 

Defense Contingency Contracting Officer’s Representative Handbook. 

We spoke with commanders, senior leaders, senior contracting 

personnel, and CORs in Afghanistan to understand the degree of subject 

area-related technical expertise possessed by CORs for contracts they 

were assigned to manage and the extent to which subject matter experts 

were available to provide technical support to CORs. We examined 

contract-related documents such as contracts and training transcripts to 

to identify training 

requirements for CORs in contingency areas such as Afghanistan. To 

evaluate the content of the training, we attended training for CORs at Fort 

Carson, Colorado, and completed the Defense Acquisition University’s 

online CORs contingency courses. We reviewed documents such as the 

program of instructions or course syllabus and other related training 

documents on the curriculum. We interviewed commanders, senior 

leaders, and contracting personnel from the Office of the Secretary of 

Defense, the Joint Staff, the combatant commands, service headquarters, 

the Defense Contract Management Agency, and defense universities to 

obtain a comprehensive understanding of what training was available for 

CORs in Afghanistan. To help determine what knowledge CORs needed 

to perform their management and oversight responsibilities, we reviewed 

contract-related documents such as contracts, purchase requisitions, and 

statements of work.

 

1

CENTCOM Contracting Command Standard Operating Procedure No.10-02: Contracting 

Officer’s Representative (COR) Program (Rev. 2, June 2010).

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 33 GAO-12-290 Operational Contract Support

assess the technical requirements of the contract as well as the technical 

background of CORs.

To determine the extent to which the number of CORs is sufficient to 

manage the contracts in Afghanistan, we examined the CENTCOM Joint 

Theater Support Contracting Command guidance and the Defense 

Contingency Contracting Officer’s Representative Handbook to identify 

requirements related to the workload of CORs. We interviewed senior 

DOD contracting personnel and CORs to determine whether there was a 

sufficient number of CORs to manage the contracts in Afghanistan. In 

addition, we met with CORs to identify their contract workload and the 

nature of contracts they were assigned to manage.

We selected units to interview that would be in Afghanistan and available 

during the time of our visit based on input from service officials as well as 

status reports from the U.S. Army, the U.S. Air Force, and the U.S. Army 

National Guard. To facilitate our meetings with CORs and contracting 

personnel in Afghanistan, we developed a set of structured questions that 

were pre-tested and coordinated with service contracting experts to help 

ensure that we had solicited the appropriate responses. We selected and 

examined photographs of supplies and services provided to us by the 

DOD personnel to best illustrate the nature of the contract support issues 

we encountered in Afghanistan.

During our review, we visited or contacted key officials, CORs, senior 

contracting and other contracting personnel from DOD components and 

entities in the United States and in Afghanistan.

• Office of the Under Secretary of Defense for Personnel and 

Readiness, Arlington, Virginia

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

and Logistics, Defense Procurement Acquisition Policy, Arlington, 

Virginia

• U.S. Central Command, MacDill Air Force Base, Tampa, Florida

• U.S. Joint Forces Command, Suffolk, Virginia

• U.S. Army

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

Technology, Arlington, Virginia

• U.S. Army Material Command, Fort Belvoir, Virginia

• U.S. Army Expeditionary Contracting Command, Fort Belvoir, 

Virginia

• U.S. Army Forces Command, Fort McPherson, Georgia

DOD Components and 

Entities in the United 

States
Appendix I: Scope and Methodology

Page 34 GAO-12-290 Operational Contract Support

• U.S. Army Training and Doctrine Command, Fort Monroe, Virginia

• U.S. Army Budget Office, Arlington, Virginia

• U.S. Army Acquisition, Logistics, and Technology Integration 

Office, Fort Lee, Virginia

• U.S. Air Force

• U.S. Air Force, Air Force Contracting, Arlington, Virginia

• U.S. Navy

• Navy Expeditionary Combat Command, Joint Expeditionary Base 

Little Creek-Fort Story, Virginia Beach, Virginia

• U.S. Marine Corps

• U.S. Marine Corps Headquarters, Installation and Logistics 

Contracting Division, Arlington, Virginia

• National Guard Bureau, Arlington, Virginia

• Defense Contract Management Agency, Alexandria, Virginia

Kandahar

• U.S. Forces Afghanistan, South

• Joint Sustainment Command Afghanistan

• Defense Contract Management Agency

• Logistics Civil Augmentation Program

• Regional Contracting Center

• 101th Combat Aviation Brigade

• 3rd Naval Construction Regiment

• 451st Air Expeditionary Wing

• 1st Brigade Combat Team/4th Infantry Division

Camp Leatherneck

• Defense Contract Management Agency

• Logistics Civil Augmentation Program

• Regional Support Command

• Logistics Civil Augmentation Program

• Division/Marine Headquarters Group, I Marine Expeditionary Force

• Marine Aircraft Wing Marine Logistics Group, I Marine Expeditionary 

Force

• Operational Contract Support team, I Marine Expeditionary Force

• C-8 Comptroller, I Marine Expeditionary Force

• Camp Leatherneck Commandant, I Marine Expeditionary Force

DOD Components and 

Entities in Afghanistan
Appendix I: Scope and Methodology

Page 35 GAO-12-290 Operational Contract Support

Kabul

• U.S. Central Contracting Command

• Defense Contract Management Agency

• Logistics Civil Augmentation Program

• Senior Contracting Officer – Afghanistan

• Task Force Spotlight

• Task Force 2010

• 717th Expeditionary Air Support Operations Squadron

Bagram

• Regional Contracting Center

• Combined Joint Task Force Four

• Defense Contract Management Agency

• Defense Contract Audit Agency

• 2nd Brigade, 34th Infantry Division

• 17th Combat Support Sustainment Brigade

• Combined Joint Task Force-101 CJ 4 & 8

• 46th Military Police

We performed our audit work from April 2010 to March 2012 in 

accordance with generally accepted government auditing standards. 

Generally accepted government auditing standards require that we plan 

and perform the audit to obtain sufficient, appropriate evidence to provide 

a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable 

basis for this assessment based on our audit objectives.
Appendix II: Comments from the Department 

of Defense

Page 36 GAO-12-290 Operational Contract Support

Appendix II: Comments from the Department 

of Defense
Appendix II: Comments from the Department 

of Defense

Page 37 GAO-12-290 Operational Contract Support
Appendix II: Comments from the Department 

of Defense

Page 38 GAO-12-290 Operational Contract Support
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 39 GAO-12-290 Operational Contract Support

Cary B. Russell, (404) 679-1808 or russellc@gao.gov. 

In addition to the contact named above, William Solis, Director; David 

Schmitt, Assistant Director; Carole Coffey, Assistant Director; Tracy 

Burney, Alfonso Garcia, Christopher Miller, Michael Shaughnessy and 

Natasha Wilder made key contributions to this report. Peter Anderson,

Kenneth Cooper, Branch Delaney, Mae Jones and Amie Steele provided 

assistance in report preparation. 

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(351474)
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