Operational Contract Support: Management and Oversight Improvements Needed in Afghanistan
Published: 2012-03-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In fiscal year 2011, DOD reported obligating over $16 billion for contracts that were executed primarily in Afghanistan. GAO has previously identified the need for DOD to improve its oversight of contractors by non-acquisition personnel, such as CORs, and Congress has addressed this issue in legislation. CORs act as the liaisons between the contractor, the contracting officer, and the unit receiving support.
Following up on previous GAO work on this topic, GAO determined the extent to which (1) DODs required training prepares CORs to perform their contract management and oversight duties, (2) CORs have the subject area-related technical expertise needed to oversee contracts, and (3) the number of CORs is sufficient to oversee the contracts in Afghanistan. GAO conducted field work in Afghanistan and the United States and focused on the preparedness of CORs to manage and oversee contracts in the CENTCOM area of responsibility.
section_title: What GAO Found
paragraphs: The Department of Defense (DOD) has taken steps to enhance its existing training program for contracting officers representatives (CORs), but the required training does not fully prepare them to perform their contract oversight duties in contingency areas such as Afghanistan. DOD requires that CORs be qualified by training and experience commensurate with the responsibilities to be delegated to them. DOD took several actions to enhance its training program, such as developing a CORs training course with a focus on contingency operations. However, GAO found that CORs are not prepared to oversee contracts because the required training does not include specifics on how to complete written statements of work and how to operate in Afghanistans unique contracting environment. For example, DOD contracting personnel told GAO about opening delays and additional expenses related to the construction of a dining facility, which was originally constructed without a kitchen because it was not included in the original statement of work. In some cases, contract-specific training was not provided at all. In addition, not all oversight personnel such as commanders and senior leaders receive training to perform contract oversight and management duties in Afghanistan because such training is not required of them. Because DODs required training does not prepare CORs and other oversight personnel to oversee contracts, units cannot be assured that they receive what they paid for.
CORs do not always have the necessary subject area-related technical expertise to oversee U.S. Central Command (CENTCOM) contracts they were assigned to. Contracting officials noted, for example, that the staircases on guard towers at a forward operating base were poorly constructed and unsafe to climb. The COR assigned to that contract had inadequate subject area-related technical expertise, preventing the early identification of the defective welding on the staircases. According to contracting officials, situations like this often occurred due to the shortage of CORs with expertise in construction. Also, at the time of GAOs field work, CORs for contracts written by CENTCOM contracting officers did not have access to subject matter experts, particularly those with construction experience. According to contracting personnel, because CORs do not have the subject area-related technical expertise needed to oversee contracts or access to subject matter experts, facilities were sometimes deficient and had to be reconstructed at great additional expense to the taxpayer.
DOD does not have a sufficient number of CORs to oversee the numerous contracts in Afghanistan. CENTCOM requires CORs to be nominated for all service contracts over $2,500 that, unless exempted, require significant ongoing technical advice and surveillance from requirements personnel. However, there is no guidance on the number of contracts a single COR should oversee. According to contracting officials and CORs GAO interviewed in Afghanistan, some CORs were responsible for providing oversight to multiple contracts in addition to carrying out their primary military duty. For example, one COR GAO interviewed was assigned to more than a dozen construction projects. According to that COR, it was impossible to be at each construction site during key phases of the project because the projects were occurring almost simultaneously at different locations. Consequently, according to officials, in situations like these, construction was completed without sufficient government oversight and problems were sometimes identified after facilities had been completed.
section_title: What GAO Recommends
paragraphs: GAO recommends that DOD enhance the current strategy for managing and overseeing contracts in contingency areas such as Afghanistan by, for example, developing training standards for providing operational contract support (OCS), fully institutionalizing OCS in professional military education, and developing standards regarding the number of contracts that CORs can oversee based on the technical nature and complexity of the contract. DOD concurred with all of GAOs recommendations.

section_title: Letter
paragraphs: The Department of Defense (DOD) reported that it had obligated over $16  billion in fiscal year 2011 for contracts that were executed primarily in  Afghanistan and that, as of October 2011, contractors made up 49  percent of the department’s workforce there—101,789 DOD contractors  compared with approximately 104,900 U.S. military personnel.  Contractors support the military during contingency operations by, for  example, managing dining facilities; washing uniforms; guarding military  bases; constructing roads to schools; transporting supplies; and building  facilities, such as guard towers, water treatment plants, and hospitals.  Since 1997, we have reported on DOD’s use of contractors to support  contingency operations. For example, we reported in July 2004 that DOD  did not always have sufficient contract oversight personnel to manage  and oversee its logistics support contracts in Iraq and Afghanistan. In  December 2006, we noted that without an adequate number of trained  oversight personnel DOD could not be assured that contractors could  meet contract requirements efficiently and effectively. Effective contract  management is essential for ensuring that U.S. military personnel receive  the support they need and that controls are in place to prevent fraud,  waste, and abuse. Ultimately, failure to manage contracts effectively  could undermine U.S. policy objectives and threaten the safety of U.S.  forces.
It takes a wide range of people to execute an acquisition from start to  finish including personnel outside of the acquisition workforce such as  contracting officer’s representatives (CORs). CORs are military or civilian  DOD personnel that manage and oversee contracts by acting as the eyes  and the ears of DOD’s contracting officers and by serving as the liaisons  between the contractor, the contracting officer, and the unit receiving  support or services. The contracting officer is ultimately responsible for  ensuring that contractors meet the requirements as set forth in the  contract. However, the CORs are non-acquisition personnel that have  acquisition-related responsibilities—particularly those related to contract  management and oversight of service and product acquisitions.
We and other oversight entities have identified the need for DOD to  improve the management and oversight of contractors by non-acquisition  personnel, such as the CORs. Congress addressed the need to improve  the management and oversight of non-acquisition personnel, in  legislation. Specifically, Congress included provisions relating to  contingency contracting in the John Warner National Defense  Authorization Act for Fiscal Year 2007 and the National Defense  Authorization Act for Fiscal Year 2008, codified at section 2333 of Title  10, United States Code. The National Defense Authorization Act for  Fiscal Year 2008 amended section 2333 to require that certain DOD joint  policy provide for training of military personnel outside the acquisition  workforce expected to have acquisition responsibility, including oversight  duties during combat operations, post-conflict operations, and  contingency operations. Further, section 2333 requires that the training  be sufficient to ensure that such military personnel understand the scope  and scale of contractor support that they will experience in contingency  operations and are prepared for their roles and responsibilities in regard  to requirements definition, program management (including contractor  oversight), and contingency contracting, which are aspects of operational  contract support (OCS). Specific concerns have been raised about the  training, expertise, and the sufficiency of the number of CORs providing  contract management and oversight. For example, in 2007, the  Commission on Army Acquisition and Program Management in  Expeditionary Operations (known as the Gansler Report) found that  CORs usually had no experience managing contracts and received  contract management training that was not relevant to the Afghanistan  contracting environment. Further, in June 2009, the Commission on  Wartime Contracting reported shortfalls in the number of qualified  oversight personnel in Afghanistan, specifically CORs, and a general lack  of COR training. Then, in August 2011, the Commission on Wartime  Contracting reported that poor planning and oversight by the government  and poor performance by contractors had resulted in wasted resources,  missions not being achieved, and the loss of lives. A recent U.S. Army  Contracting Command article noted that many deploying units were  either unaware of, or simply ignored, a certain Army road map for units to  follow to successfully integrate OCS training, including training CORs into  its pre-deployment preparations; the article concluded that units  continued to deploy unprepared to execute their OCS mission. We  testified in June 2011 that, though DOD had taken some actions to better  prepare CORs for their management and oversight duties, improving  CORs’ performance remained a challenge.
See Pub. L. No. 111-84, § 1108(b)(2) (2009). acquisition personnel, tasked with contract management and oversight  responsibilities in Afghanistan. Specifically, our objectives were to  determine the extent to which (1) DOD’s required training prepares CORs  to perform their contract management and oversight duties, (2) CORs  have the subject area-related technical expertise needed to oversee  contracts, and (3) the number of CORs is sufficient to oversee the  contracts in Afghanistan. ) interview that would be in Afghanistan and available during the time of our  visit based on input from service officials as well as status reports from  the U.S. Army, the U.S. Air Force, and the U.S. Army National Guard. To  facilitate our meetings with CORs and contracting personnel in  Afghanistan, we developed a set of structured questions that we pre- tested and coordinated with service contracting experts to ensure that we  solicited the appropriate responses. See appendix I for our scope and  methodology and a list of defense organizations and units we visited  during the course of this engagement.
We conducted our work from April 2010 to March 2012 in accordance  with generally accepted government auditing standards. Those standards  require that we plan and perform the audit to obtain sufficient and  appropriate evidence to serve as a basis for our findings and conclusions.  We believe that the evidence that we have obtained serves as a  reasonable basis for our findings and conclusions based on our audit  objectives.
subsections: section_title: Background
paragraphs: “Oversight of a contract”—which can refer to contract administration  functions, quality assurance surveillance, corrective action, property  administration, and past performance evaluation—ultimately rests with  the contracting officer who has the responsibility for ensuring that  contractors meet the requirements set forth in the contract. However,  contracting officers are frequently not located in the area or at the  installation where the services are being provided. For that reason,  contracting officers designate CORs via an appointment letter to assist  with the technical monitoring or administration of a contract on their  behalf. CORs serve as the eyes and ears for the contracting officer and  act as the liaisons between the contractor, the contracting officer, and the  unit receiving support or services. CORs are responsible for tasks  identified in the contracting officer’s appointment letter that may include  (1) providing daily contract oversight, (2) performing quality assurance  reviews, (3) monitoring contract performance, and (4) assessing technical  performance. CORs cannot direct the contractor by making commitments  or changes that affect price, quality, quantity, delivery, or other terms and  conditions of the contract. have also been tasked with other contract-related duties such as  preparing statements of work, which provide the requirements or  specifications of the contract, developing requirements approval  paperwork, and preparing funding documents. Although CORs are non- acquisition personnel, they can have acquisition-related responsibilities— particularly those related to contract oversight. CORs are not usually  contracting specialists and often perform contract management and  oversight duties on a part-time basis in addition to performing their  primary military duties, such as those performed by an infantryman or a  quartermaster specialist.
DOD defines the term “contingency contract” as a legally binding agreement for  supplies, services, and construction let by government contracting officers in the  operational area, as well as other contracts that have a prescribed area of performance  within a designated operational area. These contracts include theater support, external  support, and systems support contracts.
Theater Support Contracting Command contracting officers assisted by  CORs. When DCMA is not designated responsibility for administrative  oversight of a contract, the contracting officer who awarded the contract is  responsible for the administration, management, and oversight of the  contract. These contracting officers, such as those from the CENTCOM  Joint Theater Support Contracting Command often appoint CORs to  monitor contractor performance. CORs appointed by the CENTCOM  Joint Theater Support Contracting Command are typically drawn from  units receiving contractor-provided services. In Afghanistan, CORs that  have been appointed to contracts administered by DCMA report oversight  results to DCMA personnel. For contracts not administered by DCMA,  CORs provide oversight information to the contracting officer. In  Afghanistan, the CENTCOM Joint Theater Support Contracting  Command directs requiring activities (units receiving contractor-provided  goods and services) to nominate CORs for all service contracts valued at  more than $2,500 with significant technical requirements that require  ongoing advice and surveillance from technical/requirements personnel.  The contracting officer may exempt service contracts from this  requirement when the following three conditions are all met:  (1) The contract will be awarded using simplified acquisition procedures;  (2) The requirement is not complex; and  (3) The contracting officer documents the file, in writing, as to why the  appointment of a COR is unnecessary.
section_title: DOD Took Steps to Enhance Existing Training Program, but Existing Training Does Not Fully Prepare CORs for Contract Management and Oversight Duties
paragraphs: Although DOD requires CORs to receive training and took some actions  to enhance training programs, CORs we met with in Afghanistan do not  always receive adequate training to prepare them for their contract  management and oversight duties. DOD requires that CORs be qualified  by training and experience commensurate with the responsibilities to be  delegated to them. According to DOD officials, the current training might  qualify CORs to monitor contractor performance generally, but it does not  necessarily make them sufficiently capable for their particular  assignments. DOD officials have acknowledged gaps in training. For  example, required DOD training taken by CORs did not fully address the  unique contracting environment that exists in Afghanistan, which includes  large numbers of Afghan contractors with limited experience and  qualifications. Further, the instability and security aspects of remote  locations throughout Afghanistan coupled with an undeveloped  infrastructure impedes the CORs’ ability to communicate with and rely  upon acquisition personnel, such as contracting officers, for support and  guidance. Additionally, not all of the required training for CORs was  conducted, and some other oversight personnel were not being trained.
subsections: section_title: CORs Are Required to Receive Training and DOD Took Some Actions to Enhance Existing Training Programs
paragraphs: In Afghanistan, much of the daily surveillance of contractors supporting  military operations is performed by CORs. The Federal Acquisition  Regulation (FAR) requires that quality assurance, such as surveillance,  be performed at such times and places as may be necessary to  determine that the supplies or services conform to contract requirements.   DOD guidance requires CORs to be trained and assigned prior to  award of a contract. DOD training is intended to familiarize the CORs with  the duties and responsibilities of contract management and oversight.  Contracting organizations such as the CENTCOM Joint Theater Support  Contracting Command require that personnel nominated to be CORs  complete specific online training courseswell as locally developed CORs overview training, and contract-specific  training provided by contracting officers in theater (the latter referred to as   (referred to as Phase I), as  Phase II) before they can serve as CORs in Afghanistan. The guidance  notes that, at a minimum, Phase II training will consist of contract specific  responsibilities, including file documentation; terms and conditions of the  contract; specifics of the performance work statement; acceptance of  services procedures; invoice procedures; technical requirements; monthly  reporting procedures, and contractor evaluation—all specific to their  assigned contract.
DOD has taken some actions to enhance training programs to prepare  CORs to manage and oversee contracts in contingency operations, such  as in Afghanistan. For example, DOD developed a new training course for  CORs, with a focus on contingency operations and developed a more  general certification program for CORs, including the contingency  operations course as a training requirement when it is applicable. DOD  also took steps to institutionalize operational contract support by including  some CORs-related training in professional military education programs  and by emphasizing the need for qualified CORs by discussing their  responsibilities in joint doctrine and other guidance with the publication of  Joint Publication 4-10—Operational Contract Support and the Defense  Contingency Contracting Officer’s Representative Handbook and  memoranda issued by the Deputy Secretary of Defense.
section_title: Available DOD Training Does Not Fully Prepare CORs to Oversee Contracts in Afghanistan
paragraphs: Our analysis of DOD’s CORs training and interviews with over 150 CORs  and contracting personnel from over 30 defense organizations like the  regional contracting centersKandahar, and Camp Leatherneck, Afghanistan, indicated that some  gaps and limitations existed in DOD’s training programs leaving CORs  not fully prepared to perform their contract management and oversight   and the DCMA in Bagram, Kabul,  duties. For example, the training for CORs is generally focused on low- risk contract operations in Afghanistan and does not fully address the  unique contracting environment that exists there, such as the extent of  inexperience of Afghan contractors, the remote and insecure locations of  project sites, the underdeveloped infrastructure, and constraints on the  movement and deployment of oversight personnel, especially acquisition  personnel. More specifically, the required CORs training does not include  information about important issue areas like the Afghan First Program,  which encourages an increased use of local personnel and vendors for  supplies and services as part of the U.S. counterinsurgency strategy,  and working with private security contractors. Some CORs in Afghanistan  told us they were unaware of the challenges in working with Afghan  contractors and thought contracting with them would be similar to  contracting with U.S. vendors. However, according to some of the CORs  and other contracting personnel we interviewed, providing oversight of  Afghan contractors was more challenging than was the case with other  vendors because the Afghan contractors often did not meet the timelines  specified in the contract, did not provide the quality products and the  services the units had anticipated, and did not necessarily have a working  knowledge of English. Further, these officials told us that Afghan  contractors were not always familiar with the business standards and  processes of the U.S. government. For example, one COR told us during  our visit in February 2011 that a unit was still waiting for barriers that it  had contracted for in May 2010. According to that COR, while some of the  barriers had been delivered, the unit had not received all of the barriers it  required even though the contract delivery date had passed. Other CORs,  contracting officials, and commanders described similar situations in  which services were either not provided as anticipated or were not  provided at all. Because of gaps in training, CORs did not always  understand the full scope of their responsibilities and did not always  ensure that the contractor was meeting all contract requirements. As a  result, according to contracting officials, items such as portable toilets,  gates, water, and other items or services were not available when  needed, raising concerns about security, readiness, and morale.
Contracting officials from over 30 defense organizations and units in  Bagram, Kabul, Kandahar, and Camp Leatherneck whom we spoke with  noted similar problems with construction contracts awarded to Afghan  contractors. For example, according to another COR, an Afghan  contractor was awarded a $70,000 contract to build a latrine, shower, and  sink unit. The COR told us that the contractor was unable to satisfactorily  complete the project and so another contract was awarded for  approximately $130,000 to bring the latrine, shower, and sink unit to a  usable condition. Because of inadequacies in training, CORs did not  always understand that they had the responsibility to ensure that the  terms of the contract were met and therefore did not bring contractors’  performance issues to the contracting officer’s attention for resolution.  Similarly, DOD contracting officials provided us with documentation of  other construction problems, including a shower/toilet facility built without  holes in the walls or floors for plumbing and drain (fig. 1), and facilities  that were constructed with poor-quality materials such as crumbling  cement blocks (fig. 2). The Special Inspector General for Afghanistan  Reconstruction has also reported significant construction deficiencies  related to contracting in Afghanistan, including poorly formed and  crumbling cement structures attributable to the lack of CORs training and  oversight.
Because of the nature and sensitivity of security contracts, CORs for  private security contractors’ contracts have unique responsibilities. For  example, during the period of our review, under guidance in place prior to  June 2011, CORs were responsible for compiling a monthly weapons  discharge report and for ensuring contractor adherence to contractual  obligations on topics such as civilian arming requirements, personnel  reporting systems, property accountability, and identification badges.  According to a senior military officer with U.S. Forces Afghanistan’s  private security contractor task force, because of gaps in training, CORs  did not always understand the full scope of their responsibilities and so  did not always ensure that a contractor was meeting all contract  requirements. He noted that CORs did not always understand that they  had the responsibility to ensure that the terms of the contract were met  and therefore did not bring contractors’ performance issues to the  contracting officer’s attention for resolution. As a result, DOD may pay  contractors for poor performance and installations might not receive the  level of security contracted for.
Further, we found that the training programs lacked specifics on the  preparation of statements of work or documents required for acquisition  review boards—two contract management responsibilities that CORs in  Afghanistan were routinely tasked to do. Although the development of a  statement of work involves a variety of participants from the contracting  process, a COR may be uniquely suited to have an early impact on the  development of a complete and accurate statement of work. The Defense  Contingency Contracting Officer’s Representative Handbook describes  statements of work as specifying the basic top-level objectives of the  acquisition as well as the detailed requirements of the government. The  statement of work can provide the contractor with “how to” instructions to  accomplish the required work. It could provide a detailed description of  what is expected of the contractor and forms part of the basis for  successful performance by the contractor and effective oversight of  contracts by the government. Well-written statements of work are needed  to ensure that units get the services and goods needed in the required  time frame. As we reported in 2000 and 2004, poorly written statements  of work can also increase costs and the number of substandard supplies  and services provided by the contractor. Based on discussions with  contracting personnel from four major bases in Afghanistan responsible  for reviewing these documents, statements of work prepared by CORs  were vague and lacked the specifics needed to provide units with what  they wanted. We were told by multiple DOD officials that some CORs  routinely cut and paste information from previous statements of work into  their current document without adapting it as needed, resulting in errors  that have to be corrected and further extending the time involved in  procuring a good or service. Contracting personnel told us of instances in  which statements of work had to be rewritten because the original  statements of work did not include all the required contractor actions, or  because they included incorrect requirements. Although there are other  DOD contracting personnel involved in the requirement and procurement  process, CORs can help to ensure that well-articulated needs are more  fully documented at an early stage. DOD contracting personnel  responsible for reviewing and approving requests for contract support told  us that poorly written statements of work were a principal reason units do  not receive the operational contract support they need for sustaining  military operations. Because of gaps in training, CORs were unable to  prepare well-articulated statements of work that clearly define the  warfighters’ needs. For example, DOD contracting personnel told us  about a dining facility in Afghanistan that was built without a kitchen  because it was not included in the original statement of work, resulting in  DOD having to generate a separate statement of work for the kitchen.  According to contracting officials and commanders, poorly written  statements of work increase the procurement process time, the workload  burden on the DOD contracting personnel, and delays and disruptions in  critical supplies and services needed for the mission.
Moreover, according to DOD, one of the acquisition review boards in  Afghanistan, known as the Joint Acquisition Review Board, reviews and  recommends approval or disapproval of proposed acquisitions to ensure  efficiency and cost effectiveness. DOD contracting personnel  responsible for reviewing acquisition proposals told us that delays and  disruptions in supplies and services needed by the unit have been  attributed to incomplete or incorrect documents, such as statements of  work. Since CORs in Afghanistan are heavily relied upon by their units  and the acquisition personnel in the development of these documents, it  is important that they understand what paperwork is required and how to  properly complete it in order to obtain needed goods and services in a  timely manner. Contracting officials acknowledge the challenges with  preparing complete/correct statements of work and DOD is making some  effort to address the gaps in training. For example, the Defense  Acquisition University provides a training course on preparing  requirements documents such as statements of work; however, it is not a  DOD requirement for CORs and contracting personnel to complete this  training before assuming their contract-related roles and responsibilities.
section_title: Not All CORs Receive Required Training
paragraphs: DOD contracting personnel and CORs in Afghanistan told us that the  CENTCOM Joint Theater Support Contracting Command contracting  officers were frequently unable to provide the required contract-specific  training (Phase II) for CORs because they were busy awarding contracts.  For instance, a COR whom we interviewed in Afghanistan was directing a  contractor to perform construction work or correct deficiencies in  performance without authorization from or communication with the  contracting officer. Because the COR had never received the required  training from the contracting officer, he was not aware that this practice  was potentially unauthorized. Without the follow-on Phase II training from  the contracting officer, CORs may lack a clear and full understanding of  the scope of their contract duties and responsibilities. In contrast, DCMA’s  contracting personnel provide specific contract training and mentoring to  its CORs because DCMA has full-time quality assurance personnel who  have been tasked with providing COR training and assistance. According  to DCMA officials, certified quality assurance representatives continue to  mentor CORs after their formal training has been completed.
Moreover, in addition to CORs, other personnel expected to perform  contract oversight and management duties in Afghanistan are not always  being trained. Joint Publication 4-10 states that military departments are  responsible for ensuring that military personnel outside the acquisition  workforce who are expected to have acquisition responsibility, including  oversight duties associated with contracts or contractors are properly  trained. The Joint Publication also highlights the key role of  commanders and senior leaders in operational contract support oversight.  However, contracting personnel that we interviewed in Afghanistan told  us that military personnel such as commanders and senior leaders did not  always receive training on their contract management and oversight  duties in Afghanistan and that commanders, particularly those in combat  units, do not perceive operational contract support as a warfighter task.
Although some contracting-related training is available for commanders  and senior leaders, it is not required before deployment. DOD has not  expanded the professional military education curriculum by increasing the  number of training offerings on operational contract support with a  particular emphasis on contingency operations to fully institutionalize  operational contract support in professional military education. Based on  our previous findings, it is essential that commanders and senior leaders  complete operational contract support training before deployment to avoid  confusion regarding their contract role and responsibilities in managing  and overseeing contractors, and nominating qualified CORs. In 2006, we  recommended that operational contract support training be included in the  professional military education to ensure that all military personnel  expected to perform contract management duties, including commanders  and senior leaders, receive training prior to deployment. DOD has taken  some actions to implement this recommendation by developing some  Programs of Instruction on contingency acquisition for their non- acquisition workforce to be taught at some of the military and senior staff  colleges. However, commanders and senior leaders are not required to  take these courses before assuming their contract management and  oversight roles and responsibilities.
section_title: CORs Do Not Always Have the Subject Area-Related Technical Expertise Needed to Oversee Some Contracts
paragraphs: CORs did not always have the subject area-related technical expertise or  access to subject matter experts with those skills to manage and oversee  contracts in Afghanistan, especially those contracts of a highly technical  and complex nature. The Defense Contingency Contracting Officer’s  Representative Handbook indicates that CORs are responsible for  determining whether products delivered or services rendered by the  contractor conform to the requirements for the service or commodity  covered under the contract. Further, the Contracting Officer’s  Representative Handbook notes that CORs should have technical  expertise related to the requirements covered by the contract.
However, according to CORs and contracting personnel we interviewed in  Afghanistan, CORs did not have the subject area-related technical  expertise necessary to monitor contract performance for the contracts  they were assigned to oversee. For example, many of these CORs were  appointed to oversee construction contracts without the necessary  engineering or construction experience, in part because their units lacked  personnel with those technical skills. While DCMA had subject matter  experts in key areas such as fire safety available for CORs needing  technical assistance, CORs for contracts written by the CENTCOM Joint  Theater Support Contracting Command did not have subject matter  experts to turn to for assistance, particularly in the construction trades  during the time of our visit. As a result, according to officials, there were  newly constructed buildings that had to be repaired or rebuilt before being  used by U.S. and Afghan troops because the CORs providing the  oversight were not able to adequately ensure proper construction.  According to personnel we interviewed, these practices resulted in  wasted resources, low morale, and risks to the safety of base and  installation personnel where the deficient guard towers, fire stations, and  gates were constructed. Officials stated that it is not uncommon for a  COR to accept a portion of the contractor’s work only to find later upon  further examination that the work was not in accordance with the contract  and substandard. Similarly, officials stated that the LOGCAP personnel  did not accept responsibility for maintenance of a facility that had been  constructed by Afghan contractors until LOGCAP contractors first  repaired or replaced wiring and plumbing to meet building codes.  Although the CORs were not solely responsible for contract oversight, or  for the implications identified above, they could have provided an early  verification of contractor performance. More importantly, in the  Afghanistan contracting environment the DOD contracting personnel  ultimately responsible for oversight—such as contracting officers—were  often removed or absent from the remote locations where the work was  performed and had no ability to communicate electronically. This results  in greater reliance on CORs and reduces the opportunity for CORs to  identify problems early in the process. The following were cases that  further illustrate the impact of CORs not having the technical skills or  support needed to perform contract management and oversight. Although  the CORs did not necessarily bear the sole responsibility for  consequences identified below, a well-trained COR might have been able  to prevent or mitigate the effects of the problems.
According to officials, a COR prepared a statement of work for a  contract to build floors and install tents but failed to include any power  requirements necessary to run air conditioners, heaters, and lights  because the COR and unit personnel did not have the electrical  technical expertise to properly and safely specify the correct power  converter package with the original request. Thus, the tents were  unusable until the unit used a field ordering officer to order, at an  additional cost, the correct power converters so that the tents were  usable and completed in a timely fashion.
Contracting officials told us that guard towers at a forward operating  base were poorly constructed and unsafe to occupy. As shown in  figure 3, the staircase was unstable and not strong enough for  climbing; it had to be torn down and reconstructed. The COR’s  inadequate subject area-related technical expertise or access to  subject matter experts prevented the early identification of defective  welding on the staircase that rendered it unsuitable to use to climb up  the guard tower.
A senior engineer inspector official told us the cement block walls that  had been accepted by a COR were poorly constructed. The COR did  not have the subject area-related technical expertise or access to  subject matter experts necessary to properly inspect and reject  substandard cement block walls. For example, the contracting official  noted large holes in a cement block wall that remained after the wood  scaffolding was removed, which rendered the wall unstable (fig. 4).
A dining facility expected to service 1,000 military personnel was  unused for a year due to emergent construction deficiencies such as  electrical and plumbing issues. Contracting officials attributed the  construction issues to the shortage of oversight personnel with subject  area-related technical expertise or access to subject matter experts in  construction. As a result, according to contracting personnel, repair  work to correct the deficiencies was acquired under LOGCAP for  $190,000 in addition to the original cost of the contract.
The issue of CORs not having adequate subject area-related technical  expertise has been a longstanding problem in DOD. For example, we  have previously reported in 2006, 2008, and again in 2010 that CORs do  not always have the subject area-related technical expertise necessary to  oversee contracts. More recently in November and August 2011, the  Congressional Research Service and the Commission on Wartime  Contracting in Iraq and Afghanistan reported that DOD is still in need of  non-acquisition personnel with the necessary technical and subject matter  expertise to perform contractor oversight, respectively. The Special  Inspector General for Afghanistan Reconstruction has also reported  significant construction deficiencies with contracting in Afghanistan as a  result of inadequate subject area-related technical expertise on the part of  CORs and other contract oversight personnel. Problem areas identified  by the Inspector General included low-quality concrete (similar to  conditions depicted in fig. 2 and fig. 4) and inadequate roofing  installations, which were similar to other deficiencies we identified.
Further, based on DOD documentation, the nature of contract work in  Afghanistan has become more technical and complex, increasing the  number of CORs needed, the amount of time needed to award contracts,  and the number of errors during the early stages of the contracting  process (e.g., the requirements determination process). Due to the  complexity of construction projects in Afghanistan, DOD established an  initiative in April 2011 to assign construction inspectors to assist CORs in  managing and overseeing construction projects. According to a DOD  memorandum, contracting officers should appoint construction  inspectors, in addition to CORs, when the nature of the project requires  technical assistance to ensure proper performance of work and when  such assistance is available. Because this program was not in effect  during the time of our visit in February 2011, we are unable to assess the  effectiveness of the use of construction inspectors. However, based on  our observations in Afghanistan, there is a shortage of subject area- related technical experts that can serve as construction inspectors in  Afghanistan. CORs and other personnel that we interviewed in  Afghanistan acknowledged the benefit of having subject matter experts in  construction as well as other specialty areas such as food-, fuel-, and  electricity-related services.
section_title: Number of CORs Is Not Sufficient to Adequately Oversee the Contracts in Afghanistan
paragraphs: DOD does not have a sufficient number of CORs to oversee the  numerous contracts in Afghanistan and, according to some government  officials, there are not enough CORs in theatre to conduct adequate  oversight. The CENTCOM Joint Theater Support Contracting Command  requires the nomination of CORs for all service contracts worth over  $2,500 with significant technical requirements that require on-going  advice and surveillance from technical or requirements personnel, unless  exempted by the contracting officer. Although there is no specific  guidance on the number of contracts a single COR should manage, the  CENTCOM Joint Theater Support Contracting Command requires that  CORs nominations signed by the unit commander contain a statement  verifying that the CORs will have sufficient time to perform assigned  tasks. Similarly, the Defense Contingency Contracting Officer’s  Representative Handbook states that the requiring unit must allow  adequate resources (time, products, equipment, and opportunity) for the  CORs to perform their functions. In 2004, 2006, and again in 2010, we  reported that the DOD did not have a sufficient number of trained  oversight personnel, and during the course of our review we noted that  this situation persisted. Further, we found that CORs do not always have  the time needed to complete their oversight responsibilities. While  available data do not enable us to determine the precise number of  contracts that require CORs, in fiscal year 2011, DOD completed over  35,000 contracting actions on over 24,600 contracts and orders that were  executed primarily in Afghanistan.CORs we interviewed in Afghanistan, some CORs are responsible for  providing oversight to multiple contracts in addition to performing their  primary military duty. For example, one COR we interviewed was  assigned to more than a dozen construction projects. According to the  COR, it was impossible to be at each construction site during key phases  of the project, such as for the concrete pouring of building footings, wiring  installation, or plumbing. Consequently, according to contracting officials,  construction on these multiple projects was completed without sufficient  government oversight and problems were not always identified until the  building was completed. This often resulted in significant rework, at a cost  to the U.S. taxpayer.
According to contracting officials and  In another instance, an entire compound of five buildings was built in the  wrong location. According to DOD, based on the statement of work, the  compound should have been constructed on base behind the security  walls but instead was constructed outside the perimeter of the base in a  non-secure location. Contracting officials we spoke with in Afghanistan  attributed the problem to the numerous contracts managed by the COR  and the lack of time to perform contract oversight duties. As a result,  according to officials, the buildings (shown in fig. 5) could not be used.  The cost of the compound including the five buildings was $2.4 million.
In addition, in some cases units did not assign enough CORs to provide  oversight. For example, we were told by one unit that it did not have a  sufficient number of CORs to provide proper oversight of dining facility  services, including ordering and inspecting food and supplies. Although  the unit was able to provide one COR for each dining facility, the dining  facilities operate 24 hours a day. Contracting officials expressed concern  that there were not enough CORs to provide sufficient oversight of the  dining facilities 24 hours a day during all shifts of operation.
section_title: Conclusions
paragraphs: DOD and the services have taken some steps, such as developing a new  CORs training course with a focus on contingency operations to improve  oversight of contracts in contingency operations, such as in Afghanistan;  other more general efforts, such as the COR certification program for  services’ acquisitions, may also lead to improvement. However, in our  work in Afghanistan we found that CORs are still not fully prepared to  oversee the multitude of contracts for which they are assigned, potentially  resulting in a significant waste of taxpayer dollars and an increased risk to  the success of operations. The current mechanism for training CORs that  also perform duties related to the requirements determination process  and to the development of requirements documentation continues to have  weaknesses because DOD has not yet developed training standards to  ensure that these personnel fully understand Joint Operational Area  specific issues such as the Afghan First program, the Counterinsurgency  Contracting Guidance, and the details on the preparation of statements of  work and documents required by the contract review boards. As noted in  an Army Contracting Command publication, what contracting  organizations do and how they do it cannot be foreign to the warfighter.  Military personnel such as commanders, senior leaders, CORs, and other  personnel expected to have a role in operational contract support are  often not familiar with their contract roles and responsibilities until they  reach theater because DOD has not sufficiently expanded the  professional military education curriculum and provided more training on  contract support with a particular emphasis on contingency operations.  Further, having an insufficient number of CORs with the appropriate  subject area-related technical expertise or access to dedicated subject  matter experts in specialty areas hinders DOD’s ability to ensure that  operational units obtain vital supplies and services when needed.  Moreover, contract management and oversight has become more  challenging due to a shortage of oversight personnel, an increase in the  number of contracts, a high personnel turnover rate, training burden  challenges, and an increase in the complexity of the work contracted. All  of these have resulted in delays and errors in the procurement process.  Further, as a result of these workload constraints, military personnel  serving as CORs are limited in the number of contracts that they can  reasonably manage and oversee considering the technical nature and  complexity of each contract. Given DOD’s heavy reliance on contractors  during operations in Afghanistan and given the unpredictability of  potential future contingencies, it is critical that DOD address these  challenges as soon as possible to mitigate the risk to the success of  operations, to obtain reasonable assurance that contractors are meeting  their contract requirements and that troops are getting what they need to  support contingency operations, and to help ensure that tax dollars are  not being wasted.
section_title: Recommendations for Executive Action
paragraphs: To provide for improved oversight of operational contract support, we are  recommending that DOD enhance the current strategy for providing  contract management and oversight in Afghanistan and other areas of  operations. Specifically, we recommend that the Secretary of Defense  take the following four actions:
Direct the CENTCOM Commander in consultation with the  Secretaries of the military departments to develop standards for  training to ensure that CORs are fully trained on the contract support  in Afghanistan, to include information on the Afghan First program,  Counterinsurgency Contracting Guidance, and details on the  preparation of statements of work and documents required by the  contract review boards.
Direct the Chairman of the Joint Chiefs of Staff and the Secretaries of  the military departments to fully institutionalize operational contract  support in professional military education to ensure that CORs,  commanders, senior leaders, and other personnel expected to  perform operational contract support duties are prepared to do so by  integrating and expanding the curriculum and by increasing the  number of training offerings on operational contract support with a  particular emphasis on contingency operations.
Direct the Under Secretary of Defense for Acquisition, Technology,  and Logistics in consultation with the appropriate CENTCOM officials  to establish and maintain a sufficient number of subject matter experts  in specialty areas dedicated to the CENTCOM Joint Theater Support  Contracting Command to assist CORs with providing contract  oversight.
Direct the Under Secretary of Defense for Acquisition, Technology,  and Logistics to develop standards regarding the number of contracts  that a COR can manage and oversee based on the technical nature  and complexity of the contract.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DOD for comment. In written  comments, DOD concurred with our recommendations. DOD’s comments  are reprinted in their entirety in appendix II. DOD also provided technical  comments, which we incorporated into the report as appropriate.
DOD concurred with our recommendation that the Secretary of Defense  direct the CENTCOM Commander in consultation with the Secretaries of  the military departments to develop standards for training to ensure that  CORs are fully trained in contract support in Afghanistan, to include  information on the Afghan First program, Counterinsurgency Contracting  Guidance, and details on the preparation of statements of work and  documents required by the contract review boards. DOD stated that  CENTCOM has identified COR training in its pre-deployment requirement  for units and personnel being deployed to Afghanistan, referring to  fragmentary order 09-1700, which lists theater training requirements for  forces deploying to the CENTCOM area of responsibility. Although the  fragmentary order identifies COR training as a training requirement for  certain personnel, the wording in this order lacks the specificity to  adequately prepare CORs for contract support in Afghanistan. For  example, the fragmentary order does not require that CORs be trained on  how to use the Afghan First Program and the Counterinsurgency  Contracting Guidance and on how to prepare the statements of work and  other documents required by the contract review boards. DOD further  stated that CENTCOM reviewed and updated pre-deployment training  requirements during a conference in early January 2012, but did not  provide any specific information on what those updates entailed. DOD  also stated that the COR training requirement will remain as required pre- deployment training and that an updated version of the pre-deployment  requirement will be finalized and released no later than April 2012.  Because DOD did not provide any specific details on what, if any,  changes to training requirements will be included in its April 2012 update,  we are unable evaluate the extent to which DOD’s proposed actions  would address our recommendations.
DOD concurred with our recommendation that the Secretary of Defense  direct the Chairman of the Joint Chiefs of Staff and the Secretaries of the  military departments to fully institutionalize OCS in professional military  education by increasing the number of training offerings with a particular  emphasis on contingency operations to ensure that CORs, commanders,  senior leaders, and other personnel expected to perform OCS duties are  prepared to do so. DOD stated that the Deputy Assistant Secretary of  Defense for Program Support in the Office of the Under Secretary of  Defense for Acquisition, Technology and Logistics and the Director of  Logistics in the Joint Staff are currently engaged in a study to develop a  strategy for OCS professional military education and that DOD recognizes  the need for a holistic view of the entire OCS education requirement.  DOD said it will assess existing professional military education to  recommend OCS learning objectives for appropriate places in existing  curricula. Additionally, DOD stated that the Army has recently taken major  steps to improve training for commanders, senior leaders, and personnel  expected to perform OCS duties. However, DOD did not describe what  specific steps DOD has taken to fully institutionalize OCS in professional  military education. Further, while it is commendable that DOD is  developing a strategy for the OCS professional military education, DOD  did not indicate when its strategy would be completed. Until DOD  expands the curriculum and increases the number of training offerings on  OCS, contract management and oversight in Afghanistan will continue to  be hindered.
DOD concurred with our recommendation that the Secretary of Defense  direct the Under Secretary of Defense for Acquisition, Technology, and  Logistics in consultation with the appropriate CENTCOM officials to  establish and maintain a sufficient number of subject matter experts in  specialty areas dedicated to the CENTCOM Joint Theater Support  Contracting Command to assist CORs with providing contract oversight.  DOD stated that the Undersecretary of Defense for Acquisition,  Technology, and Logistics will work through the Joint Staff to have  CENTCOM identify the requirements for dedicated subject matter experts  and the military departments to source these positions within budget  constraints, and that the subject matter experts will be sourced through  the normal requirements process. We agree that this proposed strategy  has the potential to address our recommendation to establish and  maintain a sufficient number of subject matter experts in specialty areas.
DOD concurred with our recommendation that the Secretary of Defense  direct the Under Secretary of Defense for Acquisition, Technology, and  Logistics develop standards regarding the number of contracts that a  COR can manage and oversee based on the technical nature and  complexity of the contract. DOD agreed that there is a limit to the number  of contracts that a COR can support. Further, DOD stated that the Under  Secretary of Defense for Acquisition, Technology, and Logistics will  develop and publish appropriate standards based on the technical nature  and complexity of the contract. We agree that these actions, if fully  implemented, would address the intent of our recommendation.
We are sending copies of this report to interested congressional  committees, the Secretary of Defense, the Chairman of the Joint Chief of  Staff, the Under Secretary of Defense for Personnel and Readiness, the  Under Secretary of Defense for Acquisition, Technology & Logistics,  Secretaries of the Army, Navy and Air Force, the Commandant of the  Marine Corps, and the Commander of CENTCOM. This report will be  available at no charge on GAO’s website, http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (404) 679-1808 or russellc@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this letter. GAO staff who made key contributions are listed in  appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine the extent to which the required Department of Defense  (DOD) training prepares contracting officer’s representatives (COR) to  perform their management and oversight duties in Afghanistan, we  examined guidance, evaluated the content of the required training, and  interviewed CORs and senior contracting personnel from over 30 defense  organizations and units in Bagram, Kabul, Kandahar, and Camp  Leatherneck, Afghanistan. We examined guidance such as the Joint  Publication 4-10, the Defense Contingency Contracting Officer’s  Representative Handbook and the U.S. Central Command (CENTCOM)  Joint Theater Support Contracting Command Standard Operating  Procedures addressing the CORs program to identify training  requirements for CORs in contingency areas such as Afghanistan. To  evaluate the content of the training, we attended training for CORs at Fort  Carson, Colorado, and completed the Defense Acquisition University’s  online CORs contingency courses. We reviewed documents such as the  program of instructions or course syllabus and other related training  documents on the curriculum. We interviewed commanders, senior  leaders, and contracting personnel from the Office of the Secretary of  Defense, the Joint Staff, the combatant commands, service headquarters,  the Defense Contract Management Agency, and defense universities to  obtain a comprehensive understanding of what training was available for  CORs in Afghanistan. To help determine what knowledge CORs needed  to perform their management and oversight responsibilities, we reviewed  contract-related documents such as contracts, purchase requisitions, and  statements of work.
To determine the extent to which CORs have the appropriate subject  area-related technical expertise to oversee contracts in Afghanistan, we  reviewed the CENTCOM Joint Theater Support Contracting Command  Standard Operating Procedure addressing the CORs program and the  Defense Contingency Contracting Officer’s Representative Handbook.  We spoke with commanders, senior leaders, senior contracting  personnel, and CORs in Afghanistan to understand the degree of subject  area-related technical expertise possessed by CORs for contracts they  were assigned to manage and the extent to which subject matter experts  were available to provide technical support to CORs. We examined  contract-related documents such as contracts and training transcripts to  assess the technical requirements of the contract as well as the technical  background of CORs.
To determine the extent to which the number of CORs is sufficient to  manage the contracts in Afghanistan, we examined the CENTCOM Joint  Theater Support Contracting Command guidance and the Defense  Contingency Contracting Officer’s Representative Handbook to identify  requirements related to the workload of CORs. We interviewed senior  DOD contracting personnel and CORs to determine whether there was a  sufficient number of CORs to manage the contracts in Afghanistan. In  addition, we met with CORs to identify their contract workload and the  nature of contracts they were assigned to manage.
We selected units to interview that would be in Afghanistan and available  during the time of our visit based on input from service officials as well as  status reports from the U.S. Army, the U.S. Air Force, and the U.S. Army  National Guard. To facilitate our meetings with CORs and contracting  personnel in Afghanistan, we developed a set of structured questions that  were pre-tested and coordinated with service contracting experts to help  ensure that we had solicited the appropriate responses. We selected and  examined photographs of supplies and services provided to us by the  DOD personnel to best illustrate the nature of the contract support issues  we encountered in Afghanistan.
During our review, we visited or contacted key officials, CORs, senior  contracting and other contracting personnel from DOD components and  entities in the United States and in Afghanistan.
subsections: section_title: DOD Components and Entities in the United States
section_title: DOD Components and Entities in Afghanistan
paragraphs: U.S. Forces Afghanistan, South
Joint Sustainment Command Afghanistan
Defense Contract Management Agency
Logistics Civil Augmentation Program
Regional Contracting Center
101th Combat Aviation Brigade
3rd Naval Construction Regiment
451st Air Expeditionary Wing
1st Brigade Combat Team/4th Infantry Division
Defense Contract Management Agency
Logistics Civil Augmentation Program
Regional Support Command
Logistics Civil Augmentation Program
Division/Marine Headquarters Group, I Marine Expeditionary Force
Marine Aircraft Wing Marine Logistics Group, I Marine Expeditionary
Operational Contract Support team, I Marine Expeditionary Force
C-8 Comptroller, I Marine Expeditionary Force
Camp Leatherneck Commandant, I Marine Expeditionary Force
U.S. Central Contracting Command
Defense Contract Management Agency
Logistics Civil Augmentation Program
Senior Contracting Officer – Afghanistan
Task Force Spotlight
Task Force 2010
717th Expeditionary Air Support Operations Squadron
Regional Contracting Center
Combined Joint Task Force Four
Defense Contract Management Agency
Defense Contract Audit Agency
2nd Brigade, 34th Infantry Division
17th Combat Support Sustainment Brigade
Combined Joint Task Force-101 CJ 4 & 8
46th Military Police  We performed our audit work from April 2010 to March 2012 in  accordance with generally accepted government auditing standards.  Generally accepted government auditing standards require that we plan  and perform the audit to obtain sufficient, appropriate evidence to provide  a reasonable basis for our findings and conclusions based on our audit  objectives. We believe that the evidence obtained provides a reasonable  basis for this assessment based on our audit objectives.
section_title: Appendix II: Comments from the Department of Defense
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
paragraphs: Cary B. Russell, (404) 679-1808 or russellc@gao.gov.
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, William Solis, Director; David  Schmitt, Assistant Director; Carole Coffey, Assistant Director; Tracy  Burney, Alfonso Garcia, Christopher Miller, Michael Shaughnessy and  Natasha Wilder made key contributions to this report. Peter Anderson,  Kenneth Cooper, Branch Delaney, Mae Jones and Amie Steele provided  assistance in report preparation.