Operational Contract Support: Additional Actions Needed to Manage, Account for, and Vet Defense Contractors in Africa
Published: 2015-12-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Since its establishment in 2008, AFRICOM has increased its footprint in Africa to support its mission—building African partner capabilities and deterring threats to regional security. In tandem with AFRICOM's growing footprint will be a continued reliance on contractors to support the command's operations. Accordingly, AFRICOM and subordinate commands must be able to plan for and integrate OCS during operations. House Report 113-446 included a provision for GAO to review OCS in Africa.
This report examines the extent to which AFRICOM (1) has an organizational structure in place to manage, plan for, and assess OCS; (2) accounts for contractor personnel; and (3) vets non-U.S. contractors and contractor employees. To conduct this work, GAO evaluated AFRICOM's OCS organizational structures and conducted site visits to Djibouti, Niger, and Uganda to collect information on accountability and vetting processes. GAO selected these locations based on the types of contractor employees represented, among other factors.
section_title: What GAO Found
paragraphs: U.S. Africa Command (AFRICOM) has established a formal operational contract support (OCS) organizational structure at its headquarters to serve as the central coordination point to manage, plan for, and assess OCS. However, except for U.S. Army Africa, AFRICOM's subordinate commands do not have OCS organizational structures with dedicated personnel to manage OCS. Officials from AFRICOM's subordinate commands stated that applying OCS concepts would be helpful to avoid duplication of work and increased costs. One structure that the Department of Defense (DOD) has introduced is an OCS Integration Cell, an entity with dedicated personnel to provide staff integration and promote coordination on OCS issues; such a cell could help identify and address gaps at AFRICOM's commands, especially in a joint environment like Combined Joint Task Force-Horn of Africa, where contracting officials stated that some military tenants have arrived without informing responsible officials about the number of contractors accompanying them. AFRICOM has also developed a scorecard to assess OCS management capabilities at the subordinate commands against certain standards, but these assessments have not always been accurate because the standards have not been clearly defined or consistently applied. Without clearly defined assessment standards, AFRICOM cannot accurately assess the OCS actions taken by subordinate commands.
AFRICOM does not have a complete picture of the number of contractor personnel supporting its operations in the region. AFRICOM uses two primary sources—daily personnel status reports and the Synchronized Predeployment and Operational Tracker, a DOD contractor personnel accountability database—to collect contractor personnel accountability information, but neither source provides comprehensive accountability or visibility of DOD contractor personnel on the continent because the total number of local national contractor personnel are not being included in either, and the numbers of U.S. citizen and third country national contractor personnel vary between the two. Without clear guidance on how to comprehensively account for contractor personnel, it will be difficult for AFRICOM to ensure that it has full visibility over who is supporting its operations.
AFRICOM conducts some limited vetting of potential non-U.S. contractors, also referred to as vendors, but it has not established a foreign vendor vetting process or cell that would preemptively identify vendors who support terrorist or other prohibited organizations. AFRICOM has not yet established a foreign vendor vetting cell because while DOD guidance discusses the benefit of a cell, it does not require it or specify under what conditions it would be appropriate. Additionally, DOD sites in Africa use background investigations to determine the trustworthiness of contractor employees with access to DOD facilities. However, not all AFRICOM sites are incorporating additional screening measures, such as biometric screening or counterintelligence interviews, based on the specific risks at each site. As a result, AFRICOM is at risk of not exercising the appropriate level of vendor vetting or contractor employee screening on the African continent to protect DOD personnel from insider threats.
section_title: What GAO Recommends
paragraphs: GAO made recommendations to DOD regarding types of contractor personnel to account for, foreign vendor vetting process development, and guidance for contractor accountability and employee screening, among others. DOD generally concurred, but did not concur that AFRICOM should develop contractor accountability guidance because it was in the process of doing so. GAO continues to believe the recommendations are valid, as discussed in this report.

section_title: Letter
paragraphs: As major military operations wind down in Afghanistan, the Department of  Defense (DOD) continues to engage with partner nations in other regions  of the world, including Africa, and increasingly relies on contractors to  provide support for a range of activities such as security force assistance  and training. Since 2002 DOD has spent billions of dollars on contract  support for operations in Iraq and Afghanistan, and has taken steps to  address challenges regarding the planning, management, and oversight  of contractors in that region. However, the conditions under which DOD  operates in Africa, such as having limited resources and extensive  distances between DOD locations across the continent, complicated by  efforts to counter violent extremist organizations in a noncombat zone,  create additional challenges in contract support planning and  management.
Accordingly, DOD’s U.S. Africa Command (AFRICOM) and its  subordinate commands must be familiar with how to plan for and  integrate operational contract support (OCS) into military operations and  activities. OCS is the process of planning for and obtaining supplies,  services, and construction from commercial sources in support of joint  operations. In our body of work on OCS, we have reported that DOD  has long experienced challenges in managing OCS. For example, in our  2015 report highlighting high risk issues in the federal government, we  reported that DOD continues to face capacity shortfalls and lacks  performance measures to address operational contract support issues.  In February 2013 we reported that, with the exception of the Army, the  military services had not issued comprehensive service-specific guidance  that described roles, responsibilities, and requirements to help integrate  OCS into their planning efforts for contingency operations. Further, in  June 2010 and again in September 2012 we testified on the need for a  cultural change in DOD that emphasizes an awareness of OCS  throughout the department to address the challenges faced in  contingency operations. In recent years DOD and the Joint Staff have  issued and updated OCS guidance, discussing matters such as  identifying and planning for OCS requirements, OCS roles and  responsibilities, and processes for contractor personnel accountability.
House Report 113-446, accompanying a bill for the National Defense  Authorization Act for Fiscal Year 2015, included a provision for GAO to  examine matters related to OCS in Africa. This report evaluates the  extent to which AFRICOM (1) has an organizational structure in place to  manage, plan for, and assess operational contract support; (2) accounts  for contractors in its area of responsibility; and (3) vets non-U.S.  contractors and contractor employees.
To address these objectives we reviewed relevant documents, including  DOD guidance, and interviewed officials in the Joint Staff and Office of  the Secretary of Defense, military services, AFRICOM, and its  subordinate commands; Special Operations Command Africa; and  Combined Joint Task Force-Horn of Africa. We also conducted site visits  to three locations in Africa: (1) Navy-operated Camp Lemonnier in  Djibouti; (2) Air Force-operated Exercise Reception Facility in Niger; and  (3) multiple facilities operated by the Marine Corps and Special  Operations forces in Uganda. We selected these locations based on  variations in the military services represented, the types of contractor  personnel (U.S., third country, and local national), and the types of  services provided. To determine the extent to which AFRICOM has an  organizational structure in place to manage, plan for, and assess OCS,  we conducted interviews and collected documentation from AFRICOM  headquarters and service component command officials. We also  evaluated all OCS readiness scorecards used by AFRICOM logistics  officials to measure subordinate commands’ OCS management  capabilities. To determine the extent to which AFRICOM accounts for  contractor personnel in its area of responsibility, we reviewed DOD,  AFRICOM, and Joint Staff personnel accountability guidance and  interviewed AFRICOM personnel officials, as well as military service  officials with personnel accountability responsibilities at the AFRICOM  sites that we visited on the continent. To determine the extent to which  AFRICOM vets contractors and contractor employees, we compared  DOD and AFRICOM guidance to information gathered from officials at  AFRICOM and on the continent regarding vendor vetting and contractor  employee screening processes. We also observed contractor screening  and base access procedures at the sites in Djibouti, Niger, and Uganda.  The information gathered from these three sites, while not generalizable  to all AFRICOM sites, provides valuable insights about personnel  accountability, contractor vetting, and contractor employee screening  processes in the AFRICOM area of responsibility. Appendix I describes  our objectives, scope, and methodology in greater detail.
We conducted this performance audit from June 2014 to December 2015  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: AFRICOM is DOD’s newest geographic combatant command and was  designated fully operational in September 2008. The command’s area of  responsibility comprises all the countries on the African continent except  Egypt. According to AFRICOM officials, Camp Lemonnier, Djibouti, is the  only DOD site in Africa with a long-term use agreement, but AFRICOM  has established temporary facilities across the continent to house the  personnel and equipment used for security assistance, training, and other  operations in the region. AFRICOM is supported by its subordinate  commands: U.S. Army Africa, U.S. Naval Forces Africa, U.S. Marine  Corps Forces Africa, U.S. Air Force Africa, and Special Operations  Command Africa. AFRICOM also has a subordinate joint force command,  Combined Joint Task Force-Horn of Africa, which conducts operations in  East Africa to enhance partner nation capacity, promote regional stability,  dissuade conflict, and protect U.S. and coalition interests. U.S. Army  Africa has a dedicated military contracting element, the 414th Contracting  Support Brigade, which provides OCS planning assistance to U.S. Army  Africa and synchronizes and executes contracting solutions across the  continent. AFRICOM’s subordinate commands are located in Europe and  do not have assigned forces, except for the joint task force, which is  located at Camp Lemonnier in Djibouti.
Since its establishment AFRICOM has increased its footprint on the  continent to support the command’s missions of building African partner  defense capabilities, responding to crises, and deterring transnational  threats in order to promote regional security. In tandem with AFRICOM’s  growing footprint there has been a continued reliance on contractors to  provide, among other things, logistical, transportation, and intelligence  support to the command’s missions. This reliance on contractors was  highlighted in September 2014 when AFRICOM supported the U.S.  Agency for International Development and Liberia under Operation United  Assistance in responding to the largest Ebola epidemic in history.  AFRICOM reported having approximately 5,600 personnel on the  African continent in October 2014, of whom 569—approximately 10  percent—were U.S. citizen contractor personnel. Moreover, the dollar  value associated with DOD contracts in AFRICOM’s area of responsibility  more than doubled, from $147 million in fiscal year 2009 to $463 million in  fiscal year 2014. While the dollar value associated with these contracts  decreased in most regions from fiscal year 2013 to fiscal year 2014 (see  figure 1), AFRICOM officials expect the need for contract support to  increase as regional instability and responsibilities for protecting U.S.  personnel and facilities continue.
subsections: section_title: OCS Functions
paragraphs: OCS is the process of planning for and obtaining supplies, services, and  construction from commercial sources in support of joint operations. OCS  encompasses three functions: contract support integration, contracting  support, and contractor management. These functions and their  associated tasks are described in figure 2.
Determining OCS requirements, as well as conducting the initial planning  for and coordination of these tasks, is primarily an operational, not a  contracting, function. As a result, all of the directorates within a command  have OCS roles or responsibilities, but the directorates may not fully  understand how to properly define requirements for and manage OCS. In  the 2014 update to Joint Publication 4-10 the Joint Staff introduced the  concept of an OCS Integration Cell as a central coordination point that  can, among other things, provide staff integration by assisting and  advising the directorates on these issues. Figure 3, based on information  from the Joint Staff, demonstrates the integrating role of an OCS  Integration Cell.
section_title: Contractor Personnel Accountability
paragraphs: Personnel accountability is generally the process by which the geographic  combatant command identifies, captures, and records information— usually through the use of a database—about the number and type of  personnel, including contractor personnel, in its area of operations.  DOD’s Synchronized Predeployment and Operational Tracker (SPOT)  was developed to assist the combatant commander in ensuring that  accountability, visibility, force protection, medical support, personnel  recovery, and other related support can be accurately forecasted and  provided for the contractor personnel in the command’s area of  responsibility. SPOT contains personnel accountability data only for  contractor personnel (U.S. citizen, third country, and local national), not  military or civilian personnel. When specified by contract, vendors are  responsible for inputting and maintaining their employees’ personnel data  in SPOT throughout the employees’ periods of performance. SPOT and  service-specific accountability systems typically feed information into  DOD’s accountability system to produce joint personnel status reports.
section_title: Vendor Vetting and Contractor Employee Screening
paragraphs: DOD contracting officers are required to check prospective contractors’  names against a list of prohibited, restricted, or otherwise ineligible  entities in a U.S. government contracting database called the System for  Award Management. The prohibited entities list in the System for Award  Management contains sanctioned and other prohibited entities identified  by the Department of Treasury, Department of State, DOD, and other  U.S. agencies. A foreign vendor vetting cell can also be established to vet  selected local national and third county national companies so as to  prevent DOD from awarding contracts to companies having ties to violent  extremist organizations or other inappropriate entities. The vetting  consists of researching the principal owners and connections of the  company using information provided by owners, and then cross-checking  this information against various intelligence sources.
Subordinate and individual base commanders are responsible for the  security of military facilities within the combatant commander’s area of  responsibility. A contractor employee screening process mitigates the  potential security risk that third country and local national contractor  personnel may pose when they have access to DOD facilities. While  there is no standard DOD methodology for contractor employee  screenings overseas, a background investigation or similar process to  confirm the trustworthiness of contractor personnel should be conducted  to the greatest extent possible.
section_title: AFRICOM Has Established an Organizational Structure to Manage, Plan for, and Assess OCS, but Some Subordinate Commands Have Not Done So
paragraphs: AFRICOM established a formal OCS structure with dedicated  personnel—including an OCS Integration Cell—at the headquarters level  to serve as the central coordination point to integrate OCS in all  directorates, and to manage, plan for, and assess OCS. However, only  one of AFRICOM’s subordinate commands has an organizational  structure in place with dedicated personnel to manage and plan for OCS.  Furthermore, AFRICOM has developed a scorecard to assess OCS  capabilities at the subordinate command level, but portions of each  assessment of the six subordinate commands have been inaccurate  because it is unclear how the performance measures in scorecards  should be applied.
subsections: section_title: AFRICOM Has Established an Organizational Structure to Manage and Plan for OCS
paragraphs: AFRICOM headquarters’ establishment of a formal OCS organizational  structure began in 2011 with three dedicated DOD civilian personnel to  oversee OCS activities in Africa. Since that time, several notable OCS  milestones have been achieved, such as the establishment of an OCS  Integration Cell for the command’s headquarters in early 2014. According  to Joint Publication 4-10, an OCS Integration Cell should be established  as a permanent cell at the geographic combatant command level. The  primary function of the cell is to conduct general OCS planning, provide  advice, promote coordination, and maintain a common OCS operating  picture. In 2015 AFRICOM headquarters expanded its OCS Integration  Cell from three dedicated civilian personnel to five who work alongside  two preexisting OCS planners from the Defense Logistics Agency’s Joint  Contingency Acquisition Support Office, according to AFRICOM officials.  AFRICOM directorates also participate in facilitating OCS. For example,  AFRICOM’s personnel directorate is tasked with maintaining personnel  accountability throughout the area of responsibility. AFRICOM also has  boards and working groups dedicated to coordinating OCS activities,  including a board that synchronizes and optimizes OCS during all phases  of operation. Participants in these boards and working groups include  members of the OCS Integration Cell, such as the Joint Contingency  Acquisition Support Office planners assigned to the combatant command,  as well as staff from the combatant command, service component  commands, and other combat support agencies.
AFRICOM’s OCS Integration Cell has also taken steps to manage OCS  at its subordinate commands by conducting staff assistance visits to  enhance OCS capabilities. Specifically, since March 2014, AFRICOM  OCS Integration Cell officials have conducted staff assistance visits to all  of AFRICOM’s service component commands as well as to Special  Operations Command Africa and Combined Joint Task Force-Horn of  Africa. The purpose of these visits is to assist and partner with  subordinate commands to ensure that current AFRICOM processes,  policies, tools, and procedures for OCS align with DOD policy and joint  doctrine, and to enhance mission execution. Additionally, staff assistance  visits help AFRICOM officials to gain a better understanding of OCS  procedures and challenges at the subordinate commands. Common  observations that have been made during such visits include noting a lack  of standardized OCS organization at the subordinate command levels,  noting constrained subordinate command resources for managing OCS,  and noting a lack of OCS training. AFRICOM officials stated that they  intend to work with the subordinate commands to address these issues.  However, these officials did not provide details or a plan for how they  were to work with the subordinate components.
AFRICOM’s OCS Integration Cell also plays a key role in planning for  OCS by working with operational planners to incorporate OCS concepts  into planning documents. For example, according to officials, the OCS  Integration Cell assisted AFRICOM’s planning directorate officials in  developing OCS annexes for several concept plans, as well as the  theater and regional campaign plans. These OCS annexes generally  contained key considerations discussed in Joint Staff and other DOD  guidance related to OCS, such as force protection, host nation  agreements, and contractor oversight.
AFRICOM OCS Integration Cell officials also developed a template for  subordinate commands to use as they begin to develop their own OCS  planning documents, including OCS annexes to plans and orders when  needed. The OCS planning template is meant to guide AFRICOM  subordinate commands in OCS planning for operations, exercises,  security cooperation activities, and other initiatives. It contains 20 steps,  including identifying mission length and requirements, leveraging  historical contracts, developing acquisition and cross-servicing  agreements, researching vendors, and identifying other factors that may  impact OCS.
section_title: Most AFRICOM Subordinate Commands Have Not Established an OCS Organizational Structure
paragraphs: With the exception of U.S. Army Africa, AFRICOM’s subordinate  commands, including service component and joint force commands,  generally lack formal organizational structures with personnel dedicated  to OCS. Joint Publication 4-10 notes that OCS Integration Cells can be  established at the service component and subordinate joint force  command levels. Specifically, Joint Publication 4-10 indicates that each  service component command determines, based on specific operational  requirements, whether it should establish an OCS Integration Cell. For  details about the functions of OCS Integration Cells at the combatant  command, component command, and joint force command levels, see  figure 4.
U.S. Army Africa has established an organizational structure with  dedicated full-time OCS personnel employed within the logistics  directorate. This OCS Cell works with planners to incorporate OCS  concepts into planning documents. U.S. Army Africa’s OCS Cell has also  issued OCS guidance, which outlines OCS roles and responsibilities,  including those related to development of contract requirements; OCS  programs and procedures; and intra-theater cooperation with other  component commands. Additionally, U.S. Army Africa’s dedicated military  contracting element—414th Contracting Support Brigade—provides OCS  planning assistance to U.S. Army Africa. While U.S. Naval Forces Africa,  U.S. Air Force Africa, and U.S. Marine Corps Forces Africa do not have  formalized OCS organizational structures, all of the service component  commands participate in AFRICOM’s OCS-related working groups. In  addition, Marine Corps Forces Africa has designated one official in its  logistics directorate to serve as the component command’s OCS chief,  but according to Marine Corps officials, this official is also responsible for  OCS policy and coordination in the European Command area of  responsibility. U.S. Air Force Africa and U.S. Naval Forces Africa have  not established OCS organizational structures or dedicated OCS  personnel.
While joint staff guidance does not require the establishment of an OCS  Integration Cell or dedicated OCS personnel at the service component  command level, joint staff has emphasized the benefits of using an OCS  Integration Cell to synchronize requirements and coordinate contracting  actions. Moreover, Navy contracting officials stated that contract  requirements are not always clear, and if they do not have the statements  of work from the requiring activity at an early stage, they may not know  what is needed before the forces arrive on the ground. As a result,  operations might be delayed or might be carried out without sufficient  equipment or support services. An OCS Integration Cell or similar  structure with dedicated OCS personnel at the other service component  commands could help identify contract support issues early in the  requirements development process, thereby enabling the commands to  avoid delays. For example, U.S Army Africa’s dedicated OCS personnel  and the 414th Contracting Support Brigade have corrected potential  issues regarding poor coordination of contracts. U.S. Army Africa officials  stated that an Army unit may fail to inform contracting officials about what  equipment they are bringing along on deployment, or may disregard  training on how to properly draft a performance work statement. The  414th Contracting Support Brigade will incorporate these missing details  into the contracts based on previous experience with units requiring  similar services or goods.
U.S. Naval Forces Africa, U.S. Marine Corps Forces Africa, and U.S. Air  Force Africa logistics officials stated that one of their challenges is the  limited number of personnel who are available to be dedicated to OCS. In  our February 2015 report on high risk issues, we reported that DOD  continues to face capacity shortfalls for addressing OCS issues.  Funding and staffing constraints may prevent the establishment of an  OCS Integration Cell at the service component command level. Joint  Publication 4-10 recognizes that the establishment of an OCS Integration  Cell or similar structure at the service component command level will vary  based on specific operational requirements. Joint guidance also indicates  that there is no set structure or size for an OCS Integration Cell at any  command level; size and configuration are mission-dependent, and a cell  could be as small as two individuals or could be significantly larger,  depending on the operation. Air Force Africa and Navy Africa officials also  cited a lack of service guidance as an impediment to establishing an OCS  organizational structure.
An OCS Integration Cell was established at AFRICOM’s subordinate joint  force command supporting Operation United Assistance in 2014, but not  at the Combined Joint Task Force-Horn of Africa at Camp Lemonnier,  Djibouti, or Special Operations Command Africa. Joint Publication 4-10  indicates that an OCS Integration Cell is normally established at the  subordinate joint force command level, where it leads general OCS  planning, provides advice, promotes coordination of OCS matters, and  maintains an OCS common operating picture, among other tasks. As of  January 2015, according to officials, Combined Joint Task Force-Horn of  Africa had two officials in the contingency contracting office and one  logistics official who received OCS training. Officials further stated that  Combined Joint Task Force-Horn of Africa plans to dissolve its  contingency contracting office entirely by the end of fiscal year 2016, as it  transitions to a more enduring presence at Camp Lemonnier, Djibouti.  DOD officials stated that there are plans to create two dedicated OCS  positions within the Combined Joint Task Force-Horn of Africa’s logistics  directorate. As dedicated personnel, these officials could carry out some  OCS coordinating tasks and could frequently communicate with logistics,  operations, and planning officials about OCS issues. However, an OCS  Integration Cell would provide a permanent centralized coordination point  within the joint environment at Camp Lemonnier. Furthermore, this type of  coordination will be increasingly important in the future, as DOD develops  a more enduring joint presence at Camp Lemonnier.
At the subordinate joint force command level, joint guidance provides that  an OCS Integration Cell should normally exist, depending on mission  conditions, but the guidance does not specify those conditions. As a  result, there is no clear guidance directing Combined Joint Task Force- Horn of Africa or Special Operations Command Africa to establish an  OCS Integration Cell. An OCS Integration Cell or similar structure would  be particularly useful in a joint environment due to the number of military  service contracting elements operating at one location with potentially  limited resources. According to Combined Joint Task Force-Horn of Africa  contracting officials, applying OCS concepts such as establishing an OCS  Integration Cell at Camp Lemonnier would be helpful to avoid duplication  of work and increased costs. For example, there are multiple car rental  contracts for different service components located at Camp Lemonnier,  Djibouti. Combined Joint Task Force-Horn of Africa contracting officials  stated that if they had all contracted with one vendor they would have  gotten a better price. As another example, officials at Camp Lemonnier  stated that some military service tenants have arrived without previously  informing the Navy as the Lead Service for Contracting at Camp  Lemonnier about the number of contractor personnel accompanying  them. Without prior coordination, Navy officials do not know how much  housing, food, and fuel they require at the base. Special Operations  Command Africa officials stated that the contract requirements  development process can be haphazard, and that logistical planners are  often brought into the process later than necessary. An OCS  organizational structure or dedicated OCS personnel could ensure that  OCS requirements are considered and clarified well before operations  have begun.
section_title: AFRICOM Developed a Tool to Assess Subordinate Commands’ OCS Capabilities, but Assessments Do Not Fully Reflect Subordinate Command Performance
paragraphs: In May 2013 AFRICOM developed and began utilizing OCS Readiness  Scorecards to systematically assess its subordinate commands’ progress  in managing OCS. The scorecards document how well OCS is being  incorporated into the subordinate commands’ planning documents,  organizational structures such as boards and working groups, training  exercises, and accountability processes. To that end, the scorecards  comprise 32 OCS tasks divided among four broad categories: (1)  compliance (planning, administration, and training); (2) boards and  working groups; (3) exercises; and (4) common operating picture/SPOT.  The command’s OCS Integration Cell rated each subordinate command  as being either compliant, partially compliant, or non-compliant for each  component task, based on OCS Integration Cell officials’ determination  about the subordinate command’s progress toward completing that task.  For example, according to U.S. Army Africa’s May 2014 OCS readiness  scorecard, personnel had received training for contracting officer’s  representatives prior to their deployment, so it was rated as compliant for  this task. According to AFRICOM officials, the scorecards provide an  overall picture of subordinate commands’ OCS capabilities, promote  collaboration on OCS issues, and identify timely OCS training  requirements and activities.
However, we found that AFRICOM’s assessments do not fully reflect the  extent to which subordinate commands have completed or not completed  OCS tasks. Specifically, in three of AFRICOM’s scorecard assessments it  listed the subordinate command as complying with a task, when the  subordinate command had not accomplished that task. For example, one  component task is to incorporate OCS-specific tasks into exercises.  AFRICOM assessed Air Force Africa as compliant on this task. However,  Air Force Africa officials stated that they did not participate in any  exercises during the assessment time period, so they did not incorporate  OCS tasks into exercises. In another example, Special Operations  Command Africa officials stated that they had processes for awarding  contracts, but they lacked standard processes for incorporating OCS into  planning and requirements determinations. However, AFRICOM listed  Special Operations Command Africa as possessing standardized  processes for support units and activities because the scorecard does not  specify that these processes should specifically involve the incorporation  of OCS into planning and requirements development.
Furthermore, AFRICOM applied different standards of compliance to  different subordinate commands. For example, one component task  focuses on contractor accountability through the utilization of SPOT, a  contractor personnel accountability database. AFRICOM assessed  Marine Forces Africa as partially compliant with its contractor  accountability guidance, and all other components as fully compliant.  However, AFRICOM officials stated that no subordinate command had  processes in place to ensure that contractor personnel were being  included in SPOT—a contractor accountability database—at the time of  the assessment, and that AFRICOM contractor personnel accountability  guidance was unclear about when the commands were required to  account for contractor personnel, and what types of contractor personnel  to include. While AFRICOM did not penalize the subordinate commands  for non-compliance when the guidance they need to comply with is  unclear, the scorecards did not clarify how to assess subordinate  commands under these conditions. As a result, the assessment officials  inconsistently applied the assessment standards.
According to GAO’s performance measure evaluation guidance,  performance measures should be objective and performance data should  be accurate and consistent. According to AFRICOM’s OCS Instruction,  AFRICOM logistics officials are tasked with conducting periodic reviews  or inspections of AFRICOM staff and component commands to ensure  compliance with required OCS tasks. In addition, Standards for Internal  Control in the Federal Government state that control activities need to be  established to monitor performance measures and indicators, and that  these activities should be effective and efficient in accomplishing  objectives. Moreover, according to GAO best practices in performance  measurement, agency officials need to ensure that performance data are  complete, accurate, and consistent enough to document performance and  support decision-making at various organizational levels. Further, to the  greatest extent possible, performance goals and measures should not  require subjective considerations or judgments to dominate the  measurement.
AFRICOM’s assessments do not accurately reflect subordinate command  OCS capabilities in that its assessment standards are unclear. In  explaining the errors contained within the scorecards, AFRICOM officials  who conducted the scorecard evaluations stated that they gave the  subordinate commands the benefit of the doubt for certain tasks,  particularly those for which guidance was unclear. AFRICOM officials  further stated that the scorecard process is maturing, that there are  several component tasks in the scorecards that they realize need  improvement or clarification, and that the future Theater Campaign Plan  will provide clearer explanations of the component tasks in terms of  compliance and OCS planning. However, AFRICOM officials stated that  they are in the process of updating the Theater Campaign Plan and did  not give a timeframe for completion.
Without clearly defined assessment standards for the scorecard,  AFRICOM cannot accurately assess the OCS actions taken by  subordinate commands. The lack of accurate assessments threatens the  integrity of those measures and undermines their value in promoting  progress in OCS management. Furthermore, AFRICOM officials stated  that they plan to incorporate OCS scorecards into the Defense Readiness  Reporting System, the system used to gauge readiness across DOD.  Without improvements, either full or partial incorporation of the scorecard  assessments into DOD’s readiness reporting system could compromise  the integrity of that system by capturing an inaccurate picture of OCS  readiness.
section_title: AFRICOM Cannot Comprehensively Account for DOD Contractor Personnel in Africa
paragraphs: Contractors in Africa provide a variety of services in support of U.S.  military operations, such as transportation, construction, and food  services, and officials expect the number of contractor personnel on the  continent to increase. However, AFRICOM does not have a complete  picture of the number of contractor personnel supporting its operations in  the region. AFRICOM uses two primary sources—daily personnel status  reports and SPOT, a DOD contractor personnel accountability  database—to collect contractor personnel accountability information, but  neither source provides comprehensive accountability or visibility of DOD  contractor personnel on the continent because the total number of local  national contractor personnel are not being included in either, and  because the numbers of U.S. citizen and third country national contractor  personnel vary between the two.
subsections: section_title: Contractors Provide a Variety of Services to Support U.S. Military Operations in Africa and AFRICOM Expects to Increase Its Reliance on Them
paragraphs: According to SPOT data, which account for some but not all contractor  personnel, the number of contractor personnel in Africa is more than  1,130—a nine-fold increase since April 2011. DOD contractor personnel  perform a variety of functions and services to support mission needs,  including transportation, linguistics, engineering, construction, cleaning,  and food services. For example, in November 2014 AFRICOM reported  approximately 300 U.S. contractor personnel included in SPOT as  supporting Operation United Assistance in Senegal and Liberia. The  contractor services primarily consisted of construction and engineering of  training and medical units, and basic life support for troops, such as food  and janitorial services. AFRICOM also reported approximately 350 U.S.  contractor personnel at Camp Lemonnier, Djibouti, in October 2014  through its daily personnel status reports. These contractor personnel  performed a number of functions, including transportation, engineering,  and construction.
AFRICOM officials expect the number of contractor personnel on the  continent to continue to increase. Plans for expansion at Camp  Lemonnier in 2015 include numerous projects to increase capacity such  as expansion of emergency troop housing, taxiway extension, living and  working quarters, aircraft loading areas, and upgrades to existing power  plant capabilities. Although AFRICOM officials stated that they expect the  number of contractors at Camp Lemonnier to decrease over time as  construction is completed, they also stated that they expect the total  number of contractor personnel on the African continent to continue to  increase and shift from location to location as missions evolve,  particularly with regard to special operations. For example, officials from  Special Operations Command Africa stated that they are experiencing a  significant increase in contracting actions for Combined Joint Task Force- Horn of Africa and that plans are in place to add 10 contingency  contracting officers to Special Operations Command Africa for fiscal year  2016. Officials stated that it is extremely important to integrate OCS into  planning for the base’s expansion. Due to the austere environment,  officials stated that they intend to rely on contracted solutions because  they are more cost-effective than using military personnel.
section_title: AFRICOM Generally Accounts for U.S. Citizen Contractor Personnel but Does Not Consistently Account for Third Country and Local National Contractor Personnel
paragraphs: AFRICOM generally accounts for U.S. citizen contractor personnel, but it  accounts for third country and local national contractor personnel  inconsistently. AFRICOM uses two sources to capture accountability  information on contractor personnel supporting DOD operations—daily  personnel status reports from the services, and SPOT. According to  AFRICOM guidance, military service components, joint task forces, sub- unified commands, and forward operating sites in the AFRICOM area of  responsibility are responsible for accounting for all military, DOD civilian,  and DOD contractor personnel assigned, attached to, or under their  operational control, and they must submit a daily personnel status report  to AFRICOM personnel officials via email. This information is also to be  inputted into military service personnel accountability systems. DOD’s  personnel accountability system—Joint Personnel Accountability  Reconciliation and Reporting (JPARR)—receives information from  various sources, including service-specific accountability databases and  SPOT, and generates Joint Personnel Status Reports. AFRICOM  personnel officials stated that they have not yet implemented JPARR and  are instead using daily personnel status reports from the services via  email and SPOT to manually develop Joint Personnel Status Reports and  account for contractor personnel. For a depiction of both AFRICOM’s  daily personnel status report and SPOT accountability processes, see  figure 5.
AFRICOM’s daily personnel status reports generally account for U.S.  citizen contractor personnel, but they account for third country and local  national contractor personnel inconsistently. AFRICOM officials generally  rely on daily personnel status reports from service components via email  to provide visibility on the number of personnel on the continent, including  the number of contractor personnel. These reports generally account for  U.S. contractor personnel, but they do not consistently include local or  third country national contractor personnel, or certain U.S. citizen  contractor personnel not directly assigned to a U.S. installation. For  example, the 414th Contracting Support Brigade in Uganda accounts for  local and third country national contractor personnel in its daily personnel  status report, but daily personnel status reports from the Air Force in  Niger do not. In addition, AFRICOM’s daily personnel status reports do  not include some U.S. contractor personnel who are not directly working  on U.S. installations in a given country. For example, personnel recovery  contractor personnel in Niger are not being accounted for in daily  personnel status reports because, according to officials, they do not live  on the installation.
DOD guidance indicates that combatant commands are to establish  policies and procedures to account for contractor personnel. Joint  Publication 4-10 indicates that a key to success in contractor  management is for geographic combatant commands and subordinate  joint force commands to establish clear, enforceable, and well-understood  contractor personnel accountability policies and procedures early in the  planning stages. The guidance notes that the supported commands must  work closely with service components to ensure that proper contract and  contractor management oversight is in place. The guidance further  states that contractor personnel visibility and accountability are essential  to determine and provide the needed resources for government support  requirements such as life support, force protection, and personnel  recovery in uncertain or austere operational environments. Moreover,  Chairman of the Joint Chiefs of Staff policy and guidance on personnel  accountability states that the joint personnel status reports developed by  combatant commanders are meant to satisfy the commander’s  information needs and to authenticate the total number of personnel,  including military, DOD civilian, and DOD contractors, who are physically  present in a geographic combatant commander’s area of responsibility.  Under the policy and guidance, the geographic combatant commander is  responsible for reporting the total number of personnel, including DOD  contractors, via joint personnel status report to the Joint Staff personnel  directorate daily via secure website.
However, this guidance is unclear as to what types of contractors should  be accounted for in the joint personnel status report. The Chairman of the  Joint Chiefs of Staff guidance identifies SPOT as the designated web- based contractor database and lists the types of contractor personnel  included in SPOT—including U.S., local national, host nation, and third  country national—but it does not clearly specify the types of contractor  personnel to report in the daily personnel status report. AFRICOM  officials stated that they interpreted this guidance as directing them to  account only for U.S. citizen contractor personnel in the daily personnel  status reports. Conversely, service component officials at some forward  operating sites included both third country and local national, as well as  U.S. citizen, contractor personnel in their personnel status reports sent to  AFRICOM. AFRICOM guidance indicates that personnel status reports  should include all military, civilian, and contractor personnel assigned,  attached, or under the operational control of the service component, sub- unified command, joint task force, or forward operating site commander.  However, AFRICOM guidance does not specify whether these contractor  personnel include third country or local national contractor personnel such  as linguists, or U.S. citizen contractor personnel who are under the  operational control of the local commander but do not live on the  installation. In addition, AFRICOM officials stated that while they receive  daily personnel status reports from all of the services, they do not have  complete information on how each of the services is collecting this  information. Without consistently recording the number of contractor  personnel in personnel status reports, AFRICOM cannot comprehensively  account for contractor personnel on the continent. Thus, revising the  Chairman of the Joint Chiefs of Staff and AFRICOM policy and guidance  on personnel accountability to clearly specify the types of personnel to be  accounted for in the joint personnel status report would provide  AFRICOM with better assurance that its staff consistently provides it with  comprehensive information.
subsections: section_title: Contractors Are Not Consistently Accounting for Their Employees in SPOT
paragraphs: We found that not all contractors consistently accounted for their  employees in SPOT. Specifically, contractors at two of the three sites we  visited are not reporting third country national and local national  employees in SPOT. For example, the contractor that manages the  primary logistics contract in Uganda reported U.S. citizen, third country,  and local national contractor personnel in SPOT in January 2015, but  another contractor that manages the primary base services contract at  Camp Lemonnier, Djibouti, accounted for U.S. citizen, third country, and  local national contractor personnel only in its company systems and not in  SPOT. DOD contracting officials subsequently modified the primary base  services contract for Camp Lemonnier to include a SPOT accountability  requirement specific to Djibouti. Officials from the primary base services  company at Camp Lemonnier stated that they have plans to report U.S.  citizen and third country national employees in SPOT, but they did not  provide a timeframe for doing so. In addition, according to Camp  Lemonnier officials, construction contractors building facilities at the site  do not account for their U.S. citizen, third country, and local national  contractor personnel in SPOT and do not have plans for doing so.
Various provisions in guidance cover the use of SPOT to account for  contractor personnel. In December 2014 AFRICOM issued an interim  policy for the use of SPOT to account for and maintain visibility of  contractor personnel in the AFRICOM area of responsibility. The  guidance states that AFRICOM requires the use of SPOT, or its  successor, to account for contractor personnel in all phases of operations.  It states that SPOT is to be used for all U.S. citizens and third country  nationals deploying to the area of responsibility, regardless of contract  dollar amount. SPOT is also to be used to report an aggregate count of all  local nationals on a monthly basis for contracts employing these  personnel with periods of performance longer than 30 days. AFRICOM’s  OCS annex to the theater campaign plan indicates that SPOT should be  utilized to account for contractor personnel deploying to the area of  responsibility and that contracting agencies will direct contractors to input  required information, although it does not specify what type of contractor  personnel should be registered in SPOT in these provisions. In addition,  guidance issued by DOD directs the use of clauses that would require  contractors to use SPOT to account for certain contractor personnel  supporting DOD operations in Djibouti and in Operation United  Assistance. However, we found that many of the contracts identified by  DOD as involving performance in Djibouti or in support of Operation  United Assistance did not contain the clauses. Although DOD guidance  directs the inclusion of the clauses for new contracts providing supplies or  services in Djibouti and for Operation United Assistance, and modification  of existing contracts to the extent feasible, in some cases there may be a  good reason for omitting the clause. For example, if the contract is for  hotel lodging, it may not make sense to have hotel employees registered  in SPOT. In other contracts where the personnel will be directly  supporting operations at DOD facilities, such as those for construction or  base support, requiring the contractor to register its personnel in SPOT  would help AFRICOM to identify who is supporting its operations and for  whom it may be responsible in the event of an emergency.
AFRICOM personnel accountability guidance is unclear. As stated earlier,  Chairman of the Joint Chiefs of Staff guidance does not specify what  types of contractor personnel, such as U.S. citizen, third country national,  or local national, should be included in joint personnel status reports. In  addition, there are multiple provisions in guidance issued by different  sources, requiring the registration of different types of employees in  SPOT in various circumstances. Furthermore, AFRICOM’s interim  guidance generally requiring all contractor personnel in its area of  responsibility to be accounted for in SPOT expires in December 2015.  AFRICOM officials stated that they intend to request that this interim  guidance be included in an updated version of the Defense Federal  Acquisition Regulation Supplement. According to DOD officials, as of  October 2015, AFRICOM was in the final stages of drafting proposed  language to this effect. However, as of November 2015, there have been  no changes.
In March 2014, the AFRICOM commander stated that the command is  responsible for helping to protect U.S. personnel in Africa. Without clear  accountability guidance, AFRICOM cannot consistently or  comprehensively determine how many contractor personnel support DOD  operations in the region. Without clarification and deconfliction of  guidance, AFRICOM and its subordinate commands will not know what  types of contractor personnel to include in personnel status reports and in  SPOT, and they could continue to account for these personnel  inconsistently. As a result, commanders are at risk of not having  comprehensive visibility over who is supporting DOD operations in the  area of responsibility. In addition, the AFRICOM area of responsibility lies  in an increasingly high threat environment. The Department of State has  identified 15 high threat posts on the continent. Without comprehensive  and consistent contractor personnel accountability, commanders may be  unaware of whom they are responsible for in the event of an emergency.
section_title: AFRICOM Conducts Limited Vetting of Contractors and Contractor Employees and Does Not Have Guidance to Apply Additional Risk-Based Measures
paragraphs: AFRICOM conducts some limited vetting of potential contractors, also  referred to as vendors, but it has not established a foreign vendor vetting  process or cell that would preemptively identify vendors who support  criminal, terrorist, or other sanctioned organizations. Additionally, in  efforts to conduct individual contractor employee screening, AFRICOM  sites we visited used different types of background investigations to  determine the trustworthiness of contractor employees with access to  DOD facilities. However, these AFRICOM forward operating sites were  not incorporating additional screening measures, such as biometric  screening or counterintelligence interviews, according to the specific risks  at each site. As a result, AFRICOM is at risk of not exercising the  appropriate level of vendor vetting or contractor employee screening on  the African continent.
subsections: section_title: AFRICOM Conducts Limited Vetting but Does Not Have a Foreign Vendor Vetting Process to Prevent Contracting with Prohibited Entities
paragraphs: AFRICOM conducts some limited vendor vetting, but it has not  established a foreign vendor vetting process. The Federal Acquisition  Regulation and DOD guidance require contracting officers to ensure that  they are not contracting with any prohibited entities by vetting potential  vendors’ names against a list of prohibited, restricted, or otherwise  ineligible persons or entities in the System for Award Management. The  System for Award Management is a database used during the  procurement process that, among other things, provides information on  parties that are prohibited or restricted from receiving federal contracts. In  addition to information added by DOD, the database includes entities  identified by the Department of Treasury’s Office of Foreign Assets  Control, Department of State, and other U.S. agencies. All of the  AFRICOM service components with whom we conducted interviews  stated that their contracting officials do check the prohibited entities list in  the System for Award Management. However, as noted by Joint  Publication 4-10 in a related discussion, checking certain lists alone may  be insufficient. Specifically with respect to two lists maintained by the U.S.
Department of Treasury, Joint Publication 4-10 indicates that the  department has traditionally designated only umbrella organizations. In  addition, officials from all of AFRICOM’s service components stated that  in their contracting process they use a list of vendors vetted by the local  U.S. embassy. However, U.S. Embassy and Department of State  headquarters officials stated that vendors on these lists are not vetted for  security risks or to determine whether they are connected to or supporting  any prohibited organizations; rather, they are vetted only for their ability to  provide the required services. As a result, AFRICOM’s current vetting  process is limited in its ability to ensure that DOD is not funding prohibited  organizations in high risk areas.
Current DOD guidance is not clear on what vendor vetting steps or  process should be established at each combatant command to mitigate  the risk of contracting with terrorist or other prohibited organizations. Joint  Publication 4-10 discusses the benefit of establishing a cell, when  circumstances warrant, to vet foreign vendors for possible security  concerns and avoid awarding contracts to companies that have ties to  insurgents. However, the guidance does not require the establishment  of a vendor vetting cell or specify under what conditions it would be  appropriate. Two combatant commands—U.S. Transportation Command  and U.S. Central Command—have established foreign vendor vetting  cells for this purpose. Although AFRICOM does not have its own foreign  vendor vetting cell, during AFRICOM’s most recent contingency  operation—Operation United Assistance—AFRICOM requested  assistance from U.S. Transportation Command’s foreign vendor vetting  cell to provide threat assessments on all of the vendors that had been  awarded AFRICOM contracts. Although U.S. Transportation Command  was able to take on this additional workload, AFRICOM does not have a  written agreement to use that command’s vetting capability, and it may  not be able to leverage U.S. Transportation Command’s capabilities for  future contingencies.
In addition, AFRICOM may not be fully prepared to avoid contracting with  vendors who may also be supporting the enemy should it become actively  engaged in hostilities. In response to recent statutory provisions regarding  contracting with the enemy, DOD has issued guidance for geographic  combatant commands (with the exception of U.S. Northern Command) to  identify persons or entities who directly or indirectly provide funds,  including goods and services, received under covered contracts to person  or entities that are actively opposing U.S. or Coalition forces in a  contingency operation in which the armed forces are actively engaged in  hostilities. According to DOD officials, the list of identified persons and  entities is integrated into the System for Award Management. As noted  above, the guidance also requires contracting officers to check this  database to ensure that contracts are not awarded to prohibited or  restricted persons or entities. According to officials, U.S. Central  Command is the only combatant command that is currently required to  proactively identify these vendors, organizations, and people and add  them to the prohibited entities list because it is the only combatant  command currently engaged in hostilities in a contingency environment.  Although AFRICOM does not currently have any declared contingency  operations involving active hostilities, it operates in a high threat  environment in which hostilities could quickly arise. Without having a  foreign vendor vetting process in place, it will be difficult for AFRICOM to  recognize and thereby avoid instances of contracting with the enemy.
AFRICOM officials agree that a foreign vendor vetting process would  reduce the risk that they would contract with prohibited entities, and they  have drafted guidance on establishing a foreign vendor vetting cell.  However, AFRICOM officials stated that they would need specific  guidance from the Office of the Secretary of Defense or Joint Chiefs of  Staff specifying the conditions under which combatant commands should  establish a vendor vetting cell to effectively implement this process. For a  description of AFRICOM’s current vendor vetting process and how it  would be supplemented by the establishment of the foreign vendor vetting  cell described in its draft guidance see figure 6.
AFRICOM officials also cited resource limitations, specifically a shortfall in  intelligence analyst positions required for the proposed foreign vendor  vetting cell, as one of the challenges it faces to establishing a foreign  vendor vetting process. We have previously concluded that a risk-based  approach can help agencies strategically allocate limited resources to  achieve desired outcomes. In 2011 we recommended that U.S. Central  Command consider a risk-based approach in identifying and vetting the  highest-risk foreign vendors. In response to our recommendation, U.S.  Central Command established a formalized risk-based vetting program.  Its vetting process is designed to ensure that DOD funds are not used for  illicit purposes and to provide a risk management tool to identify foreign  vendors that have ties to the insurgency or that are involved in nefarious  activities. While the establishment of a foreign vendor vetting cell may not  be appropriate for all operations, published DOD guidance specifying  under what circumstances and how a vetting cell should be established  would better position AFRICOM and other commands to avoid contracting  with the enemy in high threat areas or in the event that they become  actively engaged in hostilities.
section_title: AFRICOM Sites That GAO Visited Use Background Investigations to Screen Contractor Employees but Lack Risk-Based Guidance for Incorporating Additional Screening Measures
paragraphs: AFRICOM generally operates in a high threat area of responsibility, and  the screening of non-U.S. personnel entering AFRICOM facilities protects  DOD personnel, equipment, and installations from acts of espionage,  sabotage, or other intelligence activities. According to agency officials and  our observation of contractor personnel screening at the sites we visited,  all of the sites conduct some type of background investigation to screen  non-U.S. contractors, but Camp Lemonnier, Djibouti—the largest and  most enduring site in the AFRICOM area of operations—has the most  comprehensive screening process (see table 1 below). The other sites  that we visited have incorporated additional screening measures to  varying degrees.
AFRICOM officials stated that all DOD sites in the AFRICOM area of  responsibility conduct background investigations for non-U.S. contractors  who require base access. All three sites that we visited use background  investigations to determine the trustworthiness of third country and local  national contractor employees who have access to DOD facilities.  Background investigations at the sites we visited generally consist of  gathering the contractor employee’s biographical information and  crosschecking it with U.S. government intelligence sources and against  local criminal records. However, the utility of these types of background  investigations is limited by the quality of (1) the biographic information  provided by the contractors, and (2) local government records, upon  which the investigations are based. For example, according to base  access officials, Djiboutian local national contractors are often able to  provide the year, but not the specific day and month, in which they were  born. In addition, at the sites we visited, DOD and Department of State  officials stated that local government criminal records in Africa may not be  easily searchable or well-maintained. As a result, additional contractor  employee screening measures may be warranted.
subsections: section_title: Additional Screening Measures
paragraphs: In light of the limitations of background investigations, additional  contractor employee screening measures, such as counterintelligence  interviews, biometric screening, and document and media exploitation,  are incorporated to varying degrees at the three sites we visited (see  table 1). For example, counterintelligence interviews with potential  contractor personnel can be used to confirm the trustworthiness of the  contractor employee and the information provided for the background  investigation. While all of the sites we visited conduct counterintelligence  interviews to varying degrees, according to DOD officials, none of them  conducts interviews with all of its non-U.S. contractor personnel.
Biometric screening is another measure that can be incorporated into the  contractor employee screening process. The collection of biometric  information, such as fingerprints or irises, unequivocally links the  individual’s identity by attaching it to measurable physical characteristics.  Officials can then screen this biometric information against a biometrically  enabled watch list or other intelligence database. In August 2009  AFRICOM issued a Biometrics Concept of Operations stating that, to the  maximum extent allowable under policy and law, persons requiring  access to DOD installations in the AFRICOM area of responsibility will be  enrolled into a biometrics database. However, Camp Lemonnier,  Djibouti, is the only site we visited that has fully incorporated biometrics  screening into its contractor employee screening process. From April to  mid-December 2014 Camp Lemonnier, Djibouti, denied access to six  contractor personnel after finding derogatory information on them through  its biometric screening process.
Security officials at Camp Lemonnier, Djibouti, also use biometric and  document and media exploitation systems to upload contractor  employees’ biometrics and personal documentation to the larger DOD  intelligence enterprise (see figure 7). Uploading of personal  documentation into U.S. intelligence databases refers to document and  media exploitation, which consists of the collection, analysis, and  exploitation of equipment, personal documents, and media to generate  actionable intelligence. This information can then be accessed by  intelligence officials if the contractor employee attempts to access another  DOD site. For example, from April to mid-December 2014 security  officials at Camp Lemonnier, Djibouti, placed 30 contractor employees on  a watch list based on their negative activity.
Moreover, with the exception of Camp Lemonnier, Djibouti, contractor  employee screening processes are not well-documented in local base  security guidance. Joint Publication 4-10 states that commanders must  ensure that local screening and badging policies and procedures are in  place for all contractor personnel requiring access to U.S. facilities. We  found that Camp Lemonnier, Djibouti, was the only site of the three we  visited that had clearly outlined contractor employee screening processes  in local base security guidance. The Air Force’s site in Niamey, Niger, has  base security guidance, but it does not describe its contractor employee  screening process.
One reason cited by officials for not developing local contractor employee  screening procedures and policies was that AFRICOM has not yet  specified what measures should be incorporated into the sites’ contractor  employee screening processes. DOD Instruction 2000.12, providing  guidance for the DOD Antiterrorism Program, states that combatant  commands shall establish antiterrorism policies and programs for the  protection of all DOD elements and personnel in their areas of  responsibility. One of the minimum elements of an antiterrorism  program is risk management. Antiterrorism risk management includes the  determination of how best to employ given resources and force protection  measures to deter, mitigate, or prepare for a terrorist incident. Those  measures could include contractor employee screening measures.  AFRICOM drafted contractor employee screening guidance in November  2014, which it subsequently updated. As of June 2015, AFRICOM  officials stated that the guidance was under review, but they did not  provide a timeframe for its issuance. This draft guidance would provide  that screening measures, including biometric screening, should be in  place when non-U.S. personnel have access to AFRICOM-controlled  facilities. The draft guidance contains a detailed appendix that describes  under what conditions biometric screening should be conducted, and it  discusses document and media exploitation. However, it lacks additional  information regarding when other screening measures should be  implemented. Officials at the sites we visited stated that access to  biometric collection equipment and counterintelligence agents constituted  a challenge due to limited resources. As a result, although AFRICOM’s  draft guidance would direct sites to perform additional screening  measures whenever a non-U.S. contractor employee requires access to  them, the sites may not have the resources to implement the guidance,  when issued.
Furthermore, risk varies from site to site, depending on a number of  factors, such as the location’s threat profile, operations, and numbers and  types of personnel. Risk-based guidance that indicates the specific  measures to be incorporated into contractor employee screening  processes could better position AFRICOM components to conduct the  appropriate level of screening and effectively allocate screening  resources to protect DOD personnel and facilities from insider threats.
section_title: Conclusions
paragraphs: DOD has spent billions of dollars on contract support since 2002, and as  its footprint in Africa increases it is more frequently relying on contractor  support for a range of operations to provide logistical, transportation, and  intelligence support to AFRICOM’s missions. The enhanced capabilities  offered by OCS can be a significant force multiplier in every phase of joint  and coalition operations in Africa. Conversely, the inability to effectively  manage and plan for OCS could yield unintended consequences such as  higher costs and inadvertent contracting with vendors that have ties to  violent extremist organizations that could complicate or even undermine  operational objectives. While AFRICOM has taken steps to manage and  plan for OCS, challenges remain in areas such as development of OCS  structures, assessments of subordinate command capabilities, accounting  of the total number of contractor personnel, and contractor vetting.  Several of AFRICOM’s subordinate commands—service component and  joint force commands—lack organizational structures, such as OCS  Integration Cells, with dedicated personnel to manage and plan for OCS.  A structure such as an OCS Integration Cell would be particularly useful  in a joint environment, such as Combined Joint Task Force-Horn of  Africa, due to the number of military service contracting elements  operating at the same location, with potentially limited resources.  Additionally, clearly defined assessment standards could help AFRICOM  to more accurately assess the OCS actions taken by subordinate  commands. Furthermore, AFRICOM cannot comprehensively account for  DOD contractors on the continent because AFRICOM and joint staff  guidance is unclear regarding the types of contractors who should be  accounted for and by which personnel accountability process. Clear  guidance could help AFRICOM to determine how many contractors  support DOD operations in the region, providing commanders with  greater visibility over who is supporting DOD operations in the area of  responsibility. Also, AFRICOM has not established a foreign vendor  vetting process to preemptively identify vendors that support criminal,  terrorist, or other sanctioned organizations, because there is no DOD  guidance specifying conditions under which combatant commands should  have a vendor vetting process or cell in place to determine whether  potential vendors actively support any terrorist, criminal, or other  sanctioned organizations. Moreover, there is no guidance clarifying when  combatant commands should develop procedures for transmitting names  of vendors identified through such a vendor vetting process for inclusion  in prohibited entities lists. Finally, not all of the AFRICOM forward  operating sites we visited are incorporating additional screening  measures according to the specific risks at each site. The development of  a foreign vendor vetting process and risk-based employee screening  measures could help AFRICOM to determine appropriate levels for  vendor vetting and contractor employee screening on the African  continent.
section_title: Recommendations for Executive Action
paragraphs: We recommend the following seven actions.
To enable AFRICOM’s component commands to better plan, advise, and  coordinate for OCS, we recommend that the AFRICOM Commander, as  part of AFRICOM’s ongoing efforts to update related guidance and  emphasize the importance of OCS integration at the subordinate  command level, take the following actions:
Direct the service components to designate elements within their  respective staffs to be responsible for coordinating OCS, and consider  the establishment of an OCS Integration Cell or similar structure with  these dedicated OCS personnel, as needed.
Clarify under what conditions a subordinate joint force command,  such as Combined Joint Task Force-Horn of Africa, should establish  an OCS Integration Cell.
To enable AFRICOM to better identify, address, and mitigate OCS  readiness gaps at its component commands before inaccurate  information is incorporated into formal defense readiness reporting  systems, we recommend that the AFRICOM Commander take the  following action:
Clarify the scorecard process, including assessment standards, for  OCS Readiness Scorecards to ensure that evaluators can accurately  assess subordinate commands’ OCS capabilities.
To enable AFRICOM to comprehensively and consistently account for  contractor personnel in Africa, we recommend that:
The Secretary of Defense, in coordination with the Chairman of the  Joint Chiefs of Staff, direct Joint Staff to clarify what types of  contractor personnel should be accounted for in its guidance on  personnel status reports.
The AFRICOM Commander develop area of responsibility-wide  contractor personnel accountability guidance on or before December  2015, when the current guidance expires, that clarifies which types of  contractor personnel should be accounted for using SPOT, and when  SPOT accountability requirements should be incorporated into  contracts.
To ensure that combatant commands are not contracting with entities that  may be connected to or supporting prohibited organizations, we  recommend that the Secretary of Defense, in coordination with the  Chairman of the Joint Chiefs of Staff, take the following action:
Develop guidance that clarifies the conditions under which combatant  commands should have a foreign vendor vetting process or cell in  place to determine whether potential vendors actively support any  terrorist, criminal, or other sanctioned organizations, including  clarifying when combatant commands should develop procedures for  transmitting the names of any vendors identified through this process  for inclusion in prohibited entities lists in the appropriate federal  contracting databases, such as the System for Award Management.
To ensure that AFRICOM applies a risk-based approach to contractor  employee screening in Africa, we recommend that the Secretary of  Defense take the following action:
Direct AFRICOM to complete and issue guidance that specifies the  standard of contractor employee screening for forward operating sites,  based on factors such as the number of DOD personnel on base, type  of operations, and local security threat.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments on a draft of this report, DOD concurred with four of  our recommendations, partially concurred with two, and did not concur  with our recommendation related to AFRICOM contractor personnel  accountability guidance. DOD’s comments are summarized below and  reprinted in appendix II. DOD also provided technical comments, which  we incorporated where appropriate.
DOD partially concurred with our first recommendation, that AFRICOM  direct its service components to designate elements within their  respective staffs to be responsible for coordinating OCS, and consider the  establishment of an OCS Integration Cell or similar structure with  dedicated OCS personnel. DOD stated that AFRICOM is assessing its  subordinate commands’ OCS structures to determine the best way  forward, and acknowledges that there are clear advantages and benefits  to establishing an OCS Integration Cell at the service-component level  even though there is no doctrinal requirement to do so. As we discuss in  the report, while joint staff guidance does not require the establishment of  an OCS Integration Cell or dedicated OCS personnel at the service  component command level, joint staff has emphasized the benefits of  using an OCS Integration Cell to synchronize requirements and  coordinate contracting actions. This recommendation was intended to  provide service component commands with the flexibility to develop OCS  Integration Cells or similar structures with dedicated OCS personnel who  can address these concerns. Moreover, an OCS Integration Cell or  similar structure could help identify contract support issues early in the  requirements development process, thereby enabling the service  component commands to avoid delays in receiving needed equipment or  services. Further, this designation would better ensure AFRICOM’s  component commands effectively plan, advise, and coordinate OCS  activities and meet the intent of the recommendation.
DOD concurred with our second recommendation, that AFRICOM clarify  under what conditions a subordinate joint force command, such as  Combined Joint Task Force-Horn of Africa, should establish an OCS  Integration Cell. In its comments, AFRICOM stated that all subordinate  joint force commands should establish an OCS Integration Cell.  AFRICOM further stated that it had scheduled a staff assistance visit to  Combined Joint Task Force-Horn of Africa to assess and develop a plan  for establishing an OCS Integration Cell. We acknowledge that  AFRICOM’s statement in its comments clarifies that an OCS Integration  Cell should be established at a subordinate joint force command, and  believe that the scheduling of a staff assistance visit to Combined Joint  Task Force-Horn of Africa is a positive first step toward establishing a cell  there. However, we also believe that providing that clarification in  AFRICOM guidance would better ensure the establishment of such a cell  at various types of subordinate joint force commands. As we noted in the  report, an OCS Integration Cell was established at AFRICOM’s  subordinate joint force command supporting Operation United Assistance  in 2014, but not at the Combined Joint Task Force-Horn of Africa in  Djibouti, or Special Operations Command Africa. Furthermore, AFRICOM  officials stated they conducted a staff assistance visit to Combined Joint  Task Force-Horn of Africa in August 2015 to assess and develop a plan  to establish an appropriate OCS structure there. Guidance clarifying  under what conditions a subordinate joint force command should  establish an OCS Cell, if fully implemented, would meet the intent of our  recommendation.
DOD partially concurred with the third recommendation, that AFRICOM  clarify the scorecard process, including assessment standards, for OCS  Readiness Scorecards to ensure that evaluators can accurately assess  subordinate commands’ OCS capabilities. DOD stated that the scorecard  is a command initiative designed to drive discussion about OCS issues  with subordinate commands, but is not a replacement for the Defense  Readiness Reporting System to report OCS. We agree that the scorecard  is not such a replacement. However, as noted in the report, AFRICOM  officials stated that they plan to incorporate OCS scorecards into the  Defense Readiness Reporting System, the system used to gauge  readiness across DOD. This recommendation was intended to ensure  that OCS scorecard assessment standards are clearly defined so that  AFRICOM can accurately assess OCS actions taken by subordinate  commands. Without improvements, either full or partial incorporation of  the scorecard assessments into DOD’s readiness reporting system could  compromise the integrity of that system by capturing an inaccurate picture  of OCS readiness.
DOD concurred with our fourth recommendation, that the Secretary of  Defense, in coordination with the Chairman of the Joint Chiefs of Staff,  direct Joint Staff to clarify what types of contractor personnel should be  accounted for in its guidance on personnel status reports. In its  comments, DOD stated that Chairman of the Joint Chiefs of Staff Manual  3150.13C, Joint Personnel Reporting Structure-Personnel Manual  provides policy and guidance on what types of contractor personnel to  account for in personnel status reports, but that additional training and  amplifying local procedures issued by AFRICOM’s personnel directorate  may be needed to fully implement its provisions and ensure consistent  interpretation of the guidance. As we noted in the report, the Chairman of  the Joint Chiefs of Staff guidance identifies SPOT as the designated web- based contractor database and lists the types of contractor personnel  included in SPOT—including U.S., local national, host nation, and third  country national—but it does not clearly specify the types of contractor  personnel to report in the daily personnel status report, and as a result,  service component officials at some forward operating sites inconsistently  included various types of contractors in personnel status reports. While  we believe that additional guidance provided by AFRICOM’s personnel  directorate would provide further clarification on this issue, we continue to  believe that clarifying Joint Staff guidance to clearly specify the types of  contractor personnel to be accounted for in joint personnel status reports  would provide AFRICOM better assurance that its staff consistently  provides it with comprehensive information.
DOD did not concur with the fifth recommendation, that the Secretary of  Defense, in coordination with the Chairman of the Joint Chiefs of Staff,  direct AFRICOM to develop area of responsibility-wide contractor  personnel accountability guidance on or before December 2015, when  the current guidance expires, that clarifies which types of contractor  personnel should be accounted for using SPOT and when SPOT  accountability requirements should be incorporated into contracts. DOD  stated that there is not a requirement for the Secretary of Defense to  direct AFRICOM to develop this guidance. We agree that it may not be  necessary for the Secretary of Defense to direct this action and  accordingly adjusted the language of the recommendation directly to  AFRICOM. Additionally, DOD stated it is coordinating a draft class  deviation to the Defense Federal Acquisition Regulation Supplement on  accountability requirements for contractor personnel performing in the  AFRICOM area of responsibility, which it expects to be approved and  published by December 2015. We acknowledge that this class deviation,  when completed, may provide further clarity on the types of contractor  personnel to include in SPOT. However, we continue to believe that  AFRICOM could benefit from developing and issuing contractor personnel  accountability guidance for its area of responsibility. Specifically, as we  noted in the report, there have been no changes to the Defense Federal  Acquisition Regulation Supplement to date on this topic, DOD has not  issued a Class Deviation, and AFRICOM’s existing interim guidance  expires in December 2015. Thus, we continue to believe that clear  accountability guidance would enable AFRICOM to more consistently and  comprehensively determine how many contractor personnel support DOD  operations in the region.
DOD concurred with our sixth recommendation, that the Secretary of  Defense, in coordination with the Chairman of the Joint Chiefs of Staff,  develop guidance that clarifies the conditions under which combatant  commands should have a foreign vendor vetting process or cell in place  to determine whether potential vendors actively support any terrorist,  criminal or other sanctioned organizations, including clarifying when  combatant commands should develop procedures for transmitting the  names of any vendors identified through this process for inclusion in  prohibited entities list in the appropriate federal contracting databases,  such as the System for Award Management. In its comments, DOD  stated that OSD has established a joint working group to identify key  stakeholders and develop DOD policy requiring combatant commands to  develop foreign vendor vetting processes. When fully implemented, we  believe these actions would meet the intent of our recommendation.
DOD concurred with our seventh recommendation, that AFRICOM  continue to complete and issue guidance that specifics the standard of  contractor employee screening for forward operating sites, based on  factors such as the number of DOD personnel on base, type of  operations, and local security threat. In its comments, DOD stated that  AFRICOM has completed the staffing of a draft instruction that will  provide guidance and specify the standards for contractor employee  screening for forward operating sites, including a risk-based approach to  contractor employee screening based on applicable mitigating factors that  include the type of contractor, operations and local security threat. While  we have not seen an updated version of this draft guidance that includes  a risk-based approach to screening, if it is fully implemented as described  above, it would meet the intent of our recommendation.
We are providing copies of this report to the appropriate congressional  committees, the Secretary of Defense, the Chairman of the Joint Chiefs of  Staff and the AFRICOM Commander. In addition, this report is available  at no charge on the GAO website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-5431 or russellc@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The objectives of our review were to determine the extent to which  AFRICOM: (1) has an organizational structure in place to manage, plan  for, and assess operational contract support; (2) accounts for contractor  personnel in its area of responsibility; and (3) vets non-U.S. contractors  and contractor employees. The focus of this review was on AFRICOM  and its subordinate commands, including the service component  commands, as well as Special Operations Command Africa in Europe,  and the Combined Joint Task Force-Horn of Africa at Camp Lemonnier in  Djibouti. Further, in terms of our review of AFRICOM contractor personnel  accountability and contractor vetting, our scope included only contract  support on the African continent, excluding contract support located at  AFRICOM headquarters.
To determine the extent to which AFRICOM has an organizational  structure in place to manage, plan for, and assess operational contract  support, we gathered information from and conducted interviews with  officials at AFRICOM headquarters, as well as the AFRICOM service  component command headquarters in Europe. To determine the extent to  which AFRICOM assesses OCS capabilities, we evaluated the OCS  readiness scorecards created by AFRICOM J4 (Logistics Directorate) to  measure its service components’ OCS capabilities in 2014. In its  assessment of the component commands, AFRICOM J4 rated each  service component as compliant, partially compliant, or non-compliant  with OCS tasks for four performance measure categories: planning,  policy, operations/exercises/security cooperation, and administration. We  evaluated the ratings that J4 applied to the service components in these  categories to determine whether they were accurate. Specifically, to  evaluate the accuracy of the scorecard ratings, we validated the ratings  using evidence gathered from the service components and compared  ratings of the service components with similar conditions against one  another to determine whether they received the same ratings. To  evaluate the extent to which AFRICOM plans for OCS, we reviewed OCS  annexes—Annex W’s—to AFRICOM’s theater campaign plan and its  regional campaign plans to determine the extent to which they included  key OCS concepts outlined in DOD and joint staff guidance.
To determine the extent to which AFRICOM accounts for contractor  personnel, we reviewed DOD, AFRICOM, and Joint Staff personnel  accountability guidance and interviewed AFRICOM J1 officials, as well as  military service officials with personnel accountability responsibilities at  the AFRICOM forward operating sites we visited. In addition, we reviewed  contracts with place of performance in Djibouti from March 2013 to  February 2014, as well as Operation United Assistance (OUA) contracts  from December 2014 to February 2015 listed in the All Government  Contract Spend data, to determine whether they included clauses to  register employees supporting the contracts in the Synchronized  Predeployment and Operational Tracker (SPOT). The different  timeframes used for the selection of those contracts were based, in part,  on the timing of various DOD requirements to use clauses that included  SPOT-related provisions. Finally, we reviewed monthly SPOT data from  2011 to 2015 provided by AFRICOM personnel officials to determine  whether the numbers of contractor personnel had increased or decreased  within the past 5 years. We conducted a data reliability analysis of this  information, including corroborating the data with agency officials to  ensure that it is accurate, up-to-date and reasonable. We determined the  data to be sufficient and reliable for the purposes of this report.
To determine the extent to which AFRICOM vets contractors and  contractor employees we reviewed DOD and military department  contracting, anti-terrorism, and physical security guidance and compared  it to information gathered from AFRICOM J2X (counterintelligence) and  three forward operating sites concerning their vendor vetting and  contractor employee screening processes. In addition, we observed  contractor screening and base access procedures at the forward  operating sites in Djibouti, Niger, and Uganda. We selected these  locations based on variations in the military services represented, the  types of contractors (U.S., third country, and local national), and the types  of contract services provided. The information gathered from these three  sites, while not generalizable to all AFRICOM sites, provides valuable  insights about personnel accountability, contractor vetting, and contractor  employee screening processes in the AFRICOM area of responsibility.
subsections: section_title: Department of Defense
section_title: Department of the Air Force
section_title: Department of the Army
section_title: Department of the Navy
section_title: Department of State
paragraphs: Office of Acquisitions Management, Washington, D.C.
Office of Logistics Management, Washington, D.C.
Bureau of African Affairs, Washington, D.C.
Bureau of Diplomatic Security, Washington, D.C.
U.S. Embassy, Djibouti, Djibouti
U.S. Embassy, Niamey, Niger
U.S. Embassy, Kampala, Uganda  We conducted this performance audit from June 2014 to December 2015  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Comments from the Department of Defense
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Carole Coffey and James A.  Reynolds, Assistant Directors; Gregory Hellman; Courtney Reid; Michael  Shaughnessy; Michael Silver; Amie Steele; Cheryl Weissman; and  Amanda Weldon made key contributions to this report.
section_title: Related GAO Products
paragraphs: Operational Contract Support: Actions Needed to Enhance the Collection,  Integration, and Sharing of Lessons Learned. GAO-15-243. Washington,  D.C.: March 16, 2015.
Contingency Contracting: Contractor Personnel Tracking System Needs  Better Plans and Guidance. GAO-15-250. Washington, D.C.: February  18, 2015.
High Risk Series: An Update. GAO-15-290. Washington, D.C.: February  11, 2015.
Defense Acquisitions: Update on DOD’s Efforts to Implement a Common  Contractor Manpower Data System. GAO-14-491R.Washington, D.C.:  May 19, 2014.
Warfighter Support: DOD Needs Additional Steps to Fully Integrate  Operational Contract Support into Contingency Planning.  GAO-13-212.Washington, D.C.: February 8, 2013.
Operational Contract Support: Management and Oversight Improvements  Needed in Afghanistan. GAO-12-290. Washington, D.C.: March 29, 2012.
Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Need Improvement.  GAO-11-355. Washington, D.C.: June 8, 2011.
Warfighter Support: Cultural Change Needed to Improve How DOD Plans  for and Manages Operational Contract Support. GAO-10-829T.  Washington, D.C.: June 29, 2010.
Warfighter Support: DOD Needs to Improve Its Planning for Using  Contractors to Support Future Military Operations.  GAO-10-472.Washington, D.C.: March 30, 2010.
Contingency Contract Management: DOD Needs to Develop and Finalize  Background Screening and Other Standards for Private Security  Contractors. GAO-09-351. Washington, D.C.: July 31, 2009.
Military Operations: DOD Needs to Address Contract Oversight and  Quality Assurance Issues for Contracts Used to Support Contingency  Operations. GAO-08-1087. Washington, D.C.: September 26, 2008.
Military Operations: Background Screenings of Contractor Employees  Supporting Deployed Forces May Lack Critical Information, but U.S.
Forces Take Steps to Mitigate the Risk Contractors May Pose.  GAO-06-999R. Washington, D.C.: September 22, 2006.