Combating Terrorism: U.S. Oversight of Pakistan Reimbursement Claims for Coalition Support Funds
Published: 2008-06-24T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The United States has reimbursed Pakistan, a key ally in the global war on terror, about $5.56 billion in Coalition Support Funds (CSF) for its efforts to combat terrorism along its border with Afghanistan. The Department of Defense (Defense) provides CSF for costs incurred in direct support of U.S. military operations. Pakistan is the largest recipient of CSF, receiving 81 percent of CSF reimbursements. This testimony focuses on (1) the extent to which Defense has consistently applied its guidance to validate the reimbursements claimed by Pakistan and (2) how the Office of the Defense Representative to Pakistan's (ODRP) role has changed over time. This statement is based on a concurrently issued GAO report titled Combating Terrorism: Increased Oversight and Accountability Needed over Pakistan Reimbursement Claims for Coalition Support Funds, GAO-08-806 (Washington, D.C.: June 24, 2008).
section_title: What GAO Found
paragraphs: Defense Comptroller issued new guidance in 2003 to enhance CSF oversight. The guidance calls for, among other things, CSF reimbursement claims to contain quantifiable information that indicates the incremental nature of support (i.e., above and beyond normal operations), validation that the support or service was provided, and copies of invoices or documentation supporting how the costs were calculated. While Defense generally conducted macro-level analytical reviews called for in its guidance, such as determining whether the cost is less than that which would be incurred by the United States for the same service, for a large number of reimbursement claims Defense did not obtain detailed documentation to verify that claimed costs were valid, actually incurred, or correctly calculated. GAO found that Defense did not consistently apply its existing CSF oversight guidance. For example, as of May 2008, Defense paid over $2 billion in Pakistani reimbursement claims for military activities covering January 2004 through June 2007 without obtaining sufficient information that would enable a third party to recalculate these costs. Furthermore, Defense may have reimbursed costs that (1) were not incremental, (2) were not based on actual activity, or (3) were potentially duplicative. GAO also found that additional oversight controls were needed. For example, there is no guidance for Defense to verify currency conversion rates used by Pakistan, which if performed would enhance Defense's ability to monitor for potential overbillings. Defense's guidance does not specifically task ODRP with attempting to verify Pakistani military support and expenses, despite recognition by Defense officials that such verification is best performed by U.S. officials in Pakistan, who have access to Pakistani officials and information. As such, ODRP did not try to verify Pakistan CSF claims from January 2004 through August 2006. Beginning in September 2006, without any formal guidance or directive to do so from U.S. Central Command or the Defense Comptroller, ODRP began an effort to validate Pakistani military support and expenses. This increased verification effort on the part of ODRP contributed to an increase in the amount of Pakistani government CSF claims disallowed and deferred. Prior to ODRP's increased verification efforts, the average percentage of Pakistani claims disallowed or deferred for January 2004 through August 2006 was a little over 2 percent. In comparison, the average percentage of Pakistani claims disallowed or deferred for September 2006 through February 2007 was 6 percent and for the most recent claims (March 2007 through June 2007) processed in February 2008, was approximately 22 percent. However, ODRP's continued oversight activity is not assured, as Defense had not developed formal guidance delineating how and to what degree ODRP should attempt to verify Pakistani claims for reimbursement. GAO recognizes that Defense may not be able to fully verify every Pakistani claim without the ability to access Pakistani records or do onsite monitoring. However, such ability would enhance CSF oversight.

section_title: Letter
paragraphs: I am pleased to be here to discuss the U.S. Department of Defense’s  (Defense) oversight over Coalition Support Funds (CSF) reimbursed to  Pakistan for its support of U.S. efforts to combat terrorism. My testimony  is based on our concurrently issued report, which focuses on Defense’s  efforts to validate Pakistan’s reimbursement claims and the role of the  Office of Defense Representative to Pakistan (ODRP). Following the  attacks of September 11, 2001, the United States began reimbursing  coalition partners for their logistical and combat support of U.S. military  operations in the global war on terror. CSF has reimbursed 27 coalition  allies for their incremental costs (i.e., costs above and beyond the partner  country’s normal operating costs) incurred in direct support of U.S.  military operations. Pakistan is the largest recipient of CSF payments,  having received $5.56 billion (81 percent) of the $6.88 billion total CSF  reimbursements made as of May 2008.
My testimony today focuses on (1) the extent to which Defense has  consistently applied its guidance to validate the reimbursements claimed  by Pakistan and (2) how ODRP’s role has changed over time. Over the  course of our work, we reviewed and analyzed information on the CSF  oversight process, including Pakistani government reimbursement claims.  In addition, we interviewed officials at the Undersecretary of Defense for  Comptroller (Comptroller), the Office of the Undersecretary of Defense  for Policy, U.S. Central Command (CENTCOM) in Tampa, Florida, ODRP,  and the State Department’s Bureau of Political-Military Affairs. ODRP  memos, CENTCOM validation memos, Comptroller evaluations, and other  CSF documentation from February 2002 through February 2008 (February  2008 was when the latest claim, for March through June 2007, was  reimbursed). To assess the application of current CSF guidance, we  examined the CSF oversight documentation referenced above from  January 2004 through February 2008. We chose this timeframe because a  previous Defense Inspector General report had already examined the pre- January 2004 CSF oversight controls and made recommendations to  improve oversight. We evaluated these controls against all available  Comptroller criteria and guidance, as well as internal control standards  and general cost accounting criteria for adequacy, eligibility, and  reasonableness. As part of our data reliability process, we confirmed that  the data provided by the Comptroller were accurately recorded in the  software we used to analyze the data. To assess the oversight role played  by ODRP, we met with the relevant ODRP, CENTCOM and Comptroller  officials, as well as with other officials from the U.S. Embassy, and  Pakistan’s Ministries of Defense and Interior. We visited Peshawar, near  the Federally Administered Tribal Areas (FATA), to discuss operations  being reimbursed with CSF funds with the U.S. consulate, Pakistan’s 11th  Army Corps, and Frontier Corps.
We conducted this performance audit from September 2007 through June  2008 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: As the United States focused on toppling the Taliban regime and fighting al  Qaeda in Afghanistan, Pakistan became an important ally. In December  2001, Congress passed the Defense Appropriations Act for fiscal year 2002,  stipulating that the “Defense Emergency Response Fund” could be used by  the Secretary of Defense to reimburse coalition partners like Pakistan for  their logistical and military support of U.S. military operations. This  funding became known as Coalition Support Funds.
To provide Defense with maximum flexibility, Congress passed the  Defense Appropriations Act for Fiscal Year 2002 granting the Secretary of  Defense the authority to make CSF payments notwithstanding any other  provision of law in such amounts as the Secretary may determine in his  discretion, based on documentation determined by the Secretary to  adequately account for the logistical and military support provided by  partner nations. Any such determination by the Secretary shall be final  and conclusive.
The amount of CSF reimbursements to Pakistan from October 2001  through June 2007 are shown in figure 1.
subsections: section_title: Evolution of the CSF Oversight Process
paragraphs: In 2003, at the request of the Comptroller, the Defense Inspector General  performed an audit of the CSF oversight process. The report found  deficiencies in both the CSF guidance and documentation provided by  CSF recipients to support their claims. It recommended improvements in  Defense’s analysis of CSF reimbursement requests and greater  documentation requirements for countries seeking reimbursement.
In response, the Comptroller published guidance in December 2003 to  clarify the roles and responsibilities of the Comptroller, CENTCOM (and  other regional combatant commanders), and ODRP in the CSF process.  The 2003 guidance notes that Congress provided the Secretary of Defense  with the authority to determine how much to reimburse partner countries,  and how much documentation was needed to adequately account for the  support provided. However, the guidance also stated that CENTCOM and  the Comptroller are to obtain sufficient documentation to validate that  Pakistani military support had been provided and that costs were incurred,  reasonable, and appropriate under the CSF program.
Under the December 2003 guidance and oversight process, Pakistan would  first submit its claim to ODRP at the U.S. Embassy in Islamabad, which  would assist the Pakistani military in formulating the claim before sending  it to CENTCOM in Tampa, Florida. CENTCOM would then conduct its own  review in an attempt to link claimed expenses to U.S. military operations  before forwarding the claim package to the Comptroller. Under this  process, ODRP and CENTCOM staff can make recommendations to defer  or disallow costs based on their analysis of the Pakistan submission;  however, the Comptroller makes the final recommendation to the  Secretary of Defense on which costs should be paid, deferred, or  disallowed. The Department of State, the Office of Management and  Budget, and Congress also have a role in the CSF oversight process after  the Comptroller has finished its review. The CSF process and guidance is  detailed in Figure 2.
In July 2006, the Comptroller provided the Pakistani government with a  cost template and information intended to clarify the types of costs that  were reimbursable under CSF and the information the Comptroller needed  to support Pakistan’s reimbursement claims.
section_title: Defense Did Not Consistently Apply Its Existing Guidance, and Additional Procedures Are Needed to Ensure Accountability over CSF to Pakistan
paragraphs: We found that Defense did not consistently apply existing CSF guidance  and that certain deficiencies existed in their oversight procedures.  Comptroller generally performed four broad analytical reviews as called  for in its guidance. For example, the Comptroller generally performed a  comparison of total claimed costs to the estimated U.S. cost to provide the  same support. Defense guidance developed by the Comptroller also calls  for obtaining sufficient information to validate Pakistani claims to  determine that costs were incurred, reasonable, and appropriate.  However, Defense did not fully implement this criteria. For example,  Defense reimbursed Pakistan over $2 billion for claims from January 2004  through June 2007 without obtaining detailed documentation that would  allow a third party to recalculate the costs. In addition, Defense often did  not adequately document the basis for their decisions to allow or disallow  claims, and we found inconsistencies in Defense payments that were not  explained. As a result, Defense may have paid costs that were (1) not  incremental, (2) not based on actual activity, or (3) potentially duplicative.  We also found that additional oversight controls were needed. Specifically,  while Comptroller guidance calls for a historical comparison of claimed  costs, the guidance does not indicate why or how the comparison should  be performed. Additionally, Defense did not verify the currency  conversion rates used by Pakistan from January 2004 through June 2007  and, as a result, may have overpaid Pakistani claims due to the devaluation  of the Pakistan rupee.
subsections: section_title: Defense Made Payments without Obtaining Detailed Documentation to Support Pakistani Claims
paragraphs: The Comptroller’s CSF guidance states that Pakistani claims should  include associated invoices. In the absence of such support, CENTCOM  officials are to obtain from Pakistan a detailed description of how these  costs were computed. For example, claims for fuel should include  information such as total fuel consumed, the number and types of vehicles  supported, and best available assessments of the number of miles driven  or hours employed.
We found that few of the Pakistani claims we reviewed met the criteria  contained in the Comptroller’s guidance. Defense reimbursed Pakistan  more than $2.2 billion, or 76 percent, of Pakistani army claims from  January 2004 through June 2007, without obtaining sufficient information  to support how the costs were calculated. In addition, the lack of  documentation led to inconsistencies in Defense’s reimbursement of  certain costs. For example, as illustrated in figure 3, Defense paid  Pakistani navy claimed costs for boats for about half of the months and  disallowed them the other half, despite no discernable differences in the  level of documentation the Pakistani government provided for the claims.
We also identified additional inconsistently reimbursed costs, such as  bulletproof jackets and telephone cables.
subsections: section_title: Defense Paid Costs That May Not Have Been Incremental
paragraphs: Comptroller guidance states that reimbursement claims must clearly  indicate the incremental nature of the logistical and military support  provided—i.e., that claimed costs are above and beyond the partner  country’s normal operating costs. Because the Pakistani claims lacked this  information, Defense officials differed as to whether the claims should be  disallowed or deferred until Pakistan could provide additional support.
The case of the Pakistani radar claims illustrates this point. From January  2004 through February 2007, Defense paid Pakistan more than $200 million  in radar expenses. However, the next month ODRP recommended the  Comptroller disallow the costs. ODRP reasoned that Pakistan’s use of the  radar was not related to U.S. efforts to combat terrorism in the region, as  terrorists in the FATA did not have air attack capability. The Comptroller  took the position that Pakistan likely incurred some increased costs  related to U.S. efforts to combat terror in the region—for example, by  providing air traffic control for U.S. military support flights into  Afghanistan. The Comptroller nonetheless agreed that the claims lacked  sufficient detail and has since deferred payment until Pakistan provides  additional support for the March through June 2007 claims.
section_title: Defense May Have Paid Costs That Were Not Based on Actual Activity or Expenses
paragraphs: According to the Comptroller’s criteria, both the Comptroller and  CENTCOM are responsible for validating that claimed costs are associated  with actual activities and are based on documentation that adequately  accounts for the support provided. However, the documentation we were  provided did not provide sufficient support that all claimed costs were  based on actual activity or expenses. These include costs associated with  construction, food, and vehicle maintenance. For example, Defense paid  Pakistan more than $30 million for army road construction and over $15  million for army bunker construction before concerns about the validity  of these charges led ODRP to ask the Pakistani military for the coordinates  of the roads and bunkers to verify their existence.
We also found large unexplained differences between the average costs of  food per person for each force, as shown in figure 4.
As the figure above shows, navy monthly food costs per person were  generally higher than monthly air force and army food costs per person.  From June 2005, navy claims for food rapidly increased from  approximately $445 per sailor to $800 per sailor in December 2005, while  air force and army food costs per person remained stable. Despite these  anomalies, Defense continued to pay the navy $800 per sailor for food until  September 2006, when the Comptroller began to question these costs.
We also found Defense paid the Pakistani navy more than $1.5 million in  possibly inflated costs for damage to navy vehicles. On average, Defense  paid the Pakistani navy more than $5,700 per vehicle per month in  damages compared with the army’s average claim of less than $100 per  vehicle per month. According to the most recent navy claims, these  vehicles generally consisted of passenger cars and SUVs that were not  involved in combat. By contrast, the army vehicles were used to conduct  military operations in the FATA and border region.
section_title: Defense Paid Costs That Were Potentially Duplicative
paragraphs: Comptroller guidance requires CENTCOM to ensure that costs are not  counted twice; however, none of the CENTCOM memos we reviewed  provide any indication that a review for duplicate costs had been  performed. As a result, Defense paid more than $8.9 million in potentially  duplicative costs.
For example, the most recent Pakistani navy claim (June 2007) includes  cost categories titled “vehicle damage” and “cost of vehicles repaired,” but  no details were provided to explain the differences between these two  categories, and there was insufficient detail to determine whether some or  all of the claimed costs were unique or duplicative. Despite this lack of  detail, we found that Defense paid the Pakistani navy an average of over  $19,000 per vehicle per month (more than $3.7 million per year) to  operate, maintain, and repair a fleet of fewer than 20 passenger vehicles  without sufficient information to determine that these costs were not  duplicative.
An official at ODRP with a role in reviewing CSF reimbursement claims  stated that, based on the scarce details provided in the CSF claims, it was  it was nearly impossible to know the actual cost of claimed items. When  we discussed this issue with officials at the Comptroller’s office, they  indicated that the Pakistani claims do not provide enough detail to explain  the context of the costs. According to the Comptroller, this makes it  difficult to determine whether the costs should be reimbursed as called for  under the Comptroller’s guidance.
section_title: Opportunities Exist to Enhance CSF Oversight Controls
paragraphs: We found deficiencies in the Comptroller’s guidance concerning historical  comparison of claimed costs and verification of currency conversions. The  Comptroller guidance calls for a historical comparison of claimed costs,  and such an analysis could identify costs that do not reflect actual activity  levels. We found that some of Pakistan’s claimed costs experienced  potentially significant unexplained fluctuations from month to month. For  example, Defense paid the army’s largest cost claimed in April 2006,  which experienced a 12 percent ($2.8 million) increase from March,  without investigating this fluctuation. As a result, Defense may be paying  for costs based on activities that did not occur.
In addition, we found that CSF guidance does not require Defense to  evaluate the exchange rates used to convert claimed costs from Pakistani  rupees into U.S. dollars, and as a result, potential overbillings may have  gone undetected. Since January 2004, the Pakistani rupee has declined  over 6 percent against the U.S. dollar. Consequently, fewer dollars should  have, over time, purchased more rupees, resulting in a lower cost to the  CSF program. For one cost category we reviewed, Defense may have  overpaid more than $1.25 million over 12 months because it did not  consider the currency conversion used to calculate the cost. Figure 5  illustrates the results of our analysis and shows that CSF would have been  billed fewer dollars had International Monetary Fund (IMF) exchange  rates been used.
If the rupee continues to decline against the dollar, future Pakistani claims  calculated using a fixed exchange rate will become more and more  inflated over time.
section_title: ODRP Began Playing a Larger Role in the CSF Oversight Process in Late 2006; However, ODRP’s Continued Oversight Is Not Assured
paragraphs: Defense’s 2003 guidance did not specifically task ODRP with attempting to  verify Pakistani military support and expenses, despite recognition by  Defense officials that such verification is best performed by U.S. officials  in Pakistan, who have direct access to Pakistani officials and information.  Because of this, ODRP did not try to verify Pakistani CSF claims until  September 2006, when, without any formal guidance or directive to do so,  ODRP began an effort to verify that Pakistani military support was  provided and costs were actually incurred as claimed in the military’s  requests for reimbursement. According to ODRP officials, this new effort  stemmed from a concern that some of Pakistan’s reported costs may not  have been valid or properly supported. They also stated that the  Comptroller’s July 2006 presentation to Pakistani officials helped ODRP  conduct more detailed verification because Pakistan began to provide  greater detail in its reimbursement claims.
For the March through June 2007 claims, ODRP recommended deferring  payment to Pakistan for $22.3 million in helicopter maintenance costs.  ODRP found that, despite $55 million in Defense reimbursements to  Pakistan for helicopter maintenance, only a few of these helicopters were  fully operational. According to ODRP officials, the Pakistani army was  not maintaining the helicopters, causing essential systems to malfunction.  Given the poor readiness rates, ODRP recommended that the Comptroller  defer payment on Pakistan’s helicopter maintenance claims until a process  could be implemented to ensure that Pakistan could maintain its  helicopter fleet. ODRP also recommended disallowing Pakistani claims for  bulletproof vests, radios, road construction, air defense radars, tents, and  funding for Pakistan’s joint staff headquarters operations, all due to  insufficient information to verify the costs.
Figure 6 shows the increased CSF disallowals and deferrals during ODRP’s  increased oversight activity in the September through October 2006  claims, and particularly in the latest claim period (March through June  2007), when Defense disallowed or deferred a total of $81.2 million over  these four months.
The amount disallowed or deferred for March through June 2007  represents a significant increase in CSF oversight by Defense. For  example, from January 2004 through August 2006, Defense disallowed or  deferred an average of a little more than 2 percent of each monthly  Pakistani reimbursement claim, for a total of $59.4 million over a 32-month  period. In comparison, the average percentage of Pakistani claims  disallowed or deferred for September 2006 through February 2007 was 6  percent or $33.3 million over a 6-month period and for the most recent  claims (March 2007 through June 2007) processed in February 2008, was  approximately 22 percent, or $81.2 million in a four month period. This  four month period accounts for approximately 53 percent of the total CSF  funding disallowed or deferred by Defense since January 2004 ($173.92  million).
subsections: section_title: No Guidance to Ensure Continued Oversight by ODRP
paragraphs: Despite ODRP’s increased oversight activity, the continuity of this  oversight is not assured. According to Standards for Internal Control in the  Federal Government, clear delegation of authority and responsibility is  important to establishing an effective internal control system. However,  as of May 2008, ODRP continued to lack formal guidance or training that  explicitly described either its oversight responsibilities or the procedures  for conducting such oversight. Defense has never provided ODRP with  guidance on how, and to what extent, it should verify that Pakistan  actually provided military support and that expenses were actually  incurred. ODRP is largely dependent upon the quality of information  supplied by the Pakistani military. According to Defense officials, Defense  lacks the authority to audit the internal finances of the Pakistani military.
ODRP officials said they doubted that ODRP would ever be able to fully  verify actual costs in Pakistan. First, the Pakistani military reports costs to  ODRP that are already aggregates of many smaller costs that ODRP cannot  directly monitor. Furthermore, according to ODRP, electronic record  keeping is rare in the Pakistani government, and collation may entail a  certain amount of approximation and averaging.
section_title: Conclusions
paragraphs: Coalition Support Funds are a critical component of America’s global war  on terror, as well as the primary support for Pakistani operations to  destroy the terrorist threat and close the terrorist safe haven in Pakistan’s  FATA. Following the attacks of September 11, 2001, Congress quickly  authorized emergency funding to prevent another attack, and because of  the grave and immediate threat at the time, Congress recognized that  ensuring accountability for these funds was secondary to protecting the  nation from another attack. However, given the large amounts of funding  provided to Pakistan since October 2001, and the indications that Pakistan  will continue to receive such payments in the future, we believe that  Defense should ensure it follows its own guidance and considers what  other guidance is needed.
Our assessment found that while CSF played a key role in Pakistan’s  support for the war on terror, Defense has not followed its existing  guidance and has provided little oversight of the effort at the embassy in  Pakistan. Defense had concerns about the accuracy of Pakistan’s claims  from the very first claim submitted in 2001. Based on the lack of  supporting evidence in the Pakistani claims from January 2004 through  June 2007 (the latest claims reimbursed by Defense), we found that neither  Defense nor we could determine if Pakistan had actually incurred most of  the costs in their clams. Prior to 2004, it appears there was even less  evidence to support Pakistan’s claims. As a result, we conclude that  Defense cannot accurately determine how much of the $5.56 billion in  costs reimbursed to Pakistan since 2001 were actually incurred.
As a result of these and other findings, we believe that Defense should  consistently implement its own CSF guidance to fully verify Pakistani  claims and ensure the effective use of CSF in meeting key U.S. national  security goals. While we recognize that CSF is used to support 27  countries in fighting terrorism, the fact that Pakistan receives 81 percent  of these funds indicates that Defense should provide oversight procedures  that reflect the role Pakistan plays as both the major recipient of CSF and  its role in supporting U.S. national security objectives in Pakistan and  Afghanistan. Additionally we recognize that Defense may not be able to  fully verify all Pakistani claims without having the ability to access the  Pakistani government’s records and make site visits or conduct spot  checks. ODRP’s recent increased efforts, however, show that greater  oversight may be achieved through the use of U.S. representatives in  Pakistan.
section_title: Recommendations for Executive Action
paragraphs: To improve the impact and oversight of CSF payments to Pakistan, we  make the following five recommendations to the Secretary of Defense:    Consistently implement existing criteria to disallow or defer Pakistani  claims that do not supply the documentation needed to verify their claims.
Define and formalize the roles and responsibilities of ODRP.
Work with the government of Pakistan to develop procedures to allow  ODRP or other U.S. representatives to conduct greater oversight of CSF  use in Pakistan, including the potential use of on-site inspections.
Clarify guidance for Comptroller analysis of cost fluctuations.
Develop and apply criteria to evaluate currency exchange rates to ensure  that the U.S. government is not overpaying for Pakistan operations.
section_title: Agency Comments and Our Evaluation
paragraphs: In response to our concurrently issued report, Defense generally  concurred with our recommendations, and indicated they had updated  their CSF guidance to incorporate our recommendations.  We plan to  review this guidance when it is made available to us. In addition, Defense’s  comments noted that our report did not give sufficient weight to (1)  Pakistan’s military contributions enabled by CSF; (2) the Department’s  adherence to the law; and (3) Pakistan’s accounting standards. Our report  does recognize Pakistan’s contributions and the role of CSF, and stated  that Congress gave Defense broad authority to make CSF payments.  Regarding Pakistan’s accounting for CSF, we acknowledge that there are  limitations in any arrangement with another sovereign nation, but we  noted that Pakistan provided more detailed documentation to support  their claims after a request from the Comptroller in 2006.
Mr. Chairman and Members of the Subcommittee, this concludes my  prepared statement. I would be pleased to answer any questions that you  may have.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: For questions regarding this testimony, please contact Charles Michael  Johnson Jr. at (202) 512-7331 or johnsoncm@gao.gov. Other contributors  to this statement were Steve Sebastian, Director; Hynek Kalkus, Assistant  Director; Roger Stoltz, Assistant Director; Edward J. George; David W.  Hancock; Claude Adrien; Jeffrey S. Beelaert; Cara Bauer; Janice  Friedeborn; Arthur James; Karen Deans; Mark Dowling; and Jena  Sinkfield.
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