Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Need Improvement
Published: 2011-06-08T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Departments of Defense (DOD) and State (State) and the United States Agency for International Development (USAID) have collectively obligated billions of dollars for contracts and assistance to support U.S. efforts in Afghanistan. There are concerns that U.S. funds are being diverted to fund insurgent and criminal activity in Afghanistan. In light of these concerns, under the authority of the Comptroller General of the United States, we initiated a review to identify DOD, State, and USAID efforts to vet non-U.S. contractors and assistance recipients in Afghanistan. GAO examined (1) the extent to which DOD has established a process to vet non-U.S. vendors to ensure that resources are not used to support insurgents; (2) the extent to which State and USAID have established processes to vet vendors and assistance recipients; and (3) the extent to which vetting information is shared among DOD, State, and USAID. GAO reviewed documents and met with a variety of agency officials to address the report's objectives.
section_title: What GAO Found
paragraphs: While DOD's U.S. Central Command (CENTCOM) has established a vetting cell to vet non-U.S. vendors in Afghanistan to minimize the risk of insurgents or criminal groups using contracts to fund their operations, its current approach for selecting vendors to vet has gaps. For example, vendors with contracts below $100,000 are not routinely vetted. In fiscal year 2010 around three-quarters of the command's new contracts with non-U.S. vendors were below $100,000. Subcontractors are also not routinely vetted. Command officials stated that CENTCOM uses other risk factors to prioritize vendors to vet, such as contracts performed in Taliban strongholds, but these factors have not been documented. While officials stated that the vetting cell was created to vet vendors prior to award, CENTCOM is largely vetting vendors with existing contracts, which means it is likely that there are a large number of new vendors that have not been vetted prior to award and may have to be vetted in the future. Also, the vetting effort now includes some U.S. Army Corps of Engineers vendors. However, the vetting cell was not staffed to accommodate this workload, so it is uncertain how its existing resources will be able to vet vendors in a timely manner. Without accurately defining the universe of contracts that may need to be vetted, adopting a formal risk-based approach that incorporates other risk factors to identify non-U.S. vendors that pose the highest risk, and identifying the resources needed to accomplish this, it is uncertain how the vetting cell will be able to meet the additional workload and achieve its goals. In January 2011, USAID created a process intended to vet non-U.S. implementing partners in Afghanistan; however, this process may face similar limitations as CENTCOM's. According to USAID officials, this decision was based on the urgent need to mitigate the risks of USAID funds being diverted to insurgent groups. While USAID's process is in the early stages, it proposes to vet non-U.S. implementing partners and at least first-tier subcontractors with contracts valued at $150,000 or more. USAID officials said that they are considering changing the dollar threshold or vetting other potential assistance recipients based on risk; however, the available documentation does not include other risk factors. As of March 2011, State had not developed a process to vet contractor firms in Afghanistan. Since 2008, State has required that a terrorist financing risk assessment be completed for any new program or activity prior to a request for or obligation of funding. However, it does not use the same information as the CENTCOM or USAID vetting cells. Additionally, its use of Afghan vendors may increase under the Afghan First policy. Absent a way to consider the risk posed by non-U.S. vendors, State may not be well prepared to assess the potential for its funds to be diverted to criminal or insurgent groups. DOD and USAID share vetting information informally, but without a formal mechanism to share vetting results the two agencies cannot ensure that their current practices will endure. Further, as State expands its use of local contractors, it will become imperative that it is part of the data sharing with DOD and USAID.
section_title: What GAO Recommends
paragraphs: GAO is making recommendations related to improving DOD's and USAID's vetting processes and information sharing. GAO is also recommending that State assess the need for and possible options to vet non-U.S. vendors. DOD and USAID concurred with GAO's recommendations. State generally concurred.

section_title: Letter
paragraphs: In fiscal year 2009 and the first half of fiscal year 2010, the Departments of  Defense (DOD) and State (State) and the United States Agency for  International Development (USAID) collectively reported obligations of at  least $17.2 billion on contracts and various assistance instruments to  support U.S. efforts in Afghanistan. The use of non-U.S. vendors—and, in  particular, Afghan vendors—is expected to increase, as the Afghan First  policy adopted by the International Security Assistance Force (ISAF),  United States Forces – Afghanistan (USFOR-A), and the U.S. Embassy in  Kabul, Afghanistan, encourages an increased use of local personnel and  vendors for goods and services as part of the U.S. counterinsurgency  (COIN) strategy. Additionally, in September 2010, the USFOR-A/ISAF  Commander released guidance encouraging the increased use of  contracting with Afghan vendors and hiring of Afghan personnel to  achieve U.S. COIN goals. Although DOD, State, and USAID have long used  contractors and implementing partners to conduct their work, the  agencies’ current reliance on contractors to support U.S. efforts to  stabilize and rebuild Afghanistan is unprecedented. We have previously  reported on the contracting challenges agencies face in contingency  environments. For example, the contracting environment in Afghanistan  poses unique challenges, including the complexity of transporting supplies  and equipment, the limited availability of staff for the needed level of  oversight, the often limited capacity of local vendors, a lack of robust  accounting and record keeping in the country, and a high volume of  complex contracts and large-scale construction projects. Further,  according to DOD officials and officials from other U.S. government  agencies, and as suggested in congressional reports, U.S. contracting  efforts take place in an environment characterized by actual and perceived  widespread corruption in Afghan government and business and face the  risk that some U.S. funds may be used to finance terrorist or insurgent  groups.
The U.S. government has taken a number of steps to prevent resources  from being used to support terrorist activities or organizations—for  example, Executive Order 13,224 was aimed at blocking the financing of  terrorism. As the use of contractors and spending has grown in  Afghanistan, U.S. government agencies and congressional committees  have paid increasing attention to the risks of U.S. contracting and  reconstruction funds being diverted to criminal or insurgent groups. For  example, congressional legislation to address this issue has recently been  proposed, and there have been congressional hearings and recent reports  detailing examples of corruption and financing of insurgents in  Afghanistan. In September 2010 COIN contracting guidance, the  Commander of USFOR-A/ISAF directed contracting officials to establish  systems and standard databases to ensure that contracts are not awarded  to malign actors and funds are not diverted. Additionally, in 2010 DOD and  other agencies spearheaded the creation of interagency efforts in  Afghanistan intended to encourage transparency, prevent corruption, and  identify malign actors. For example, in June 2010 DOD created Task Force  2010, which works to develop greater visibility over contracting networks,  money flows, and the linkages to malign actors to better employ  contracting to support COIN goals. Earlier, in 2009, the Drug Enforcement  Agency, DOD, the Department of the Treasury, and other U.S. agencies  established the Afghan Threat Finance Cell, which aims to identify and  disrupt the funding of criminal and insurgent organizations.
In light of these concerns, under the authority of the Comptroller General  of the United States, we initiated a review to identify DOD, State, and  USAID efforts to vet vendors and assistance recipients in Afghanistan. We  examined (1) the extent to which DOD has established a process to vet  non-U.S. vendors in Afghanistan, both to ensure that resources are not  used to support insurgent or criminal groups and to safeguard U.S.  personnel and assets against security risks; (2) the extent to which State  and USAID have established processes to vet non-U.S. vendors and  assistance recipients in Afghanistan; and (3) the extent to which vetting  information is shared among DOD, State, and USAID.
To conduct this work, we reviewed recent DOD, including U.S. Central  Command (CENTCOM); State; and USAID policies and procedures. These  include the most recent (November 2010) CENTCOM Contracting  Command Acquisition Instruction as well as past versions, USAID’s  Mission Order for Afghanistan 201.03, and an April 2010 memorandum of  understanding among DOD, State, and USAID relating to contracting in  Iraq and Afghanistan. Additionally, we reviewed the DOD contract that  establishes a vendor vetting cell in support of U.S. forces in Afghanistan  and Iraq at CENTCOM headquarters in Tampa, Florida, and the contract’s  associated classified policies and procedures, as well as draft standard  operating procedures for USAID’s vetting support unit in Afghanistan. We  interviewed cognizant DOD, State, and USAID officials in both Afghanistan  and the United States, including DOD policy, logistics, and acquisition  officials from the offices of the relevant Under Secretaries of Defense in  Washington, D.C.; CENTCOM officials in the planning, logistics, and  intelligence directorates, as well as representatives of the vendor vetting  cell in Tampa, Florida; and USAID and State officials in Washington, D.C.,  responsible for contracting, procurement, and security. We do not discuss  the mechanics of the vetting processes used by DOD and USAID in detail  because we did not evaluate the effectiveness of the methods used by the  agencies to conduct the vetting. In Afghanistan, we interviewed a variety  of DOD, USFOR-A, and CENTCOM Contracting Command officials in  Kabul, including the CENTCOM Senior Contracting Official-Afghanistan  and the commanders of Task Force 2010 and other groups. Additionally,  we put out data calls to USAID and State for their procurement data for  fiscal year 2010 in Afghanistan. We present procurement data for fiscal  year 2010 in Afghanistan, based on data calls to USAID and State, to give a  broad context for the scale of awards to U.S. vendors compared to those  to non-U.S. vendors and the amounts obligated and determined the  method used to gather these data to be sufficiently reliable for this  purpose. We also interviewed cognizant U.S. Embassy security and  contracting officials and USAID security and contracting officials, all in  Kabul. Additionally, we interviewed officials from regional contracting  centers in Kabul, Bagram, Camp Leatherneck, and Kandahar; U.S. Army  Corps of Engineers (USACE) officials in Kandahar and other locations;  and ISAF contracting and security officials in Kabul and Kandahar.
We conducted this performance audit from May 2010 through June 2011 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. Details on our objectives, scope, and  methodology are contained in appendix I.
subsections: section_title: Background
paragraphs: In Afghanistan, the use of local vendors by U.S. and international forces as  part of an effort to create economic development is considered to be one  of the key supporting elements of the U.S. COIN strategy. For example,  guidance issued in August 2010 and amplified in September 2010 by the  ISAF/USFOR-A Commander emphasizes the role of contracting in the  implementation of the COIN strategy. In Afghanistan, local personnel  make up a significant portion of DOD’s contractor workforce. According  to CENTCOM’s quarterly census data, in the first quarter of fiscal year  2011, there were more than 87,000 DOD contractor personnel in  Afghanistan. Of those personnel, Afghan nationals made up approximately  53 percent of the contracted workforce. According to DOD, recent  initiatives that have a direct influence on the hiring of local nationals in  Afghanistan include developing a more skilled workforce; increasing  business opportunities; increasing community cash flow; improving public  infrastructure, such as roads and utilities; and enhancing community  organizational capacity. In addition to its importance to DOD, local  contracting is integral to the efforts of other U.S. government agencies,  such as USAID, to rebuild and expand infrastructure and economic  capacity in Afghanistan.
Assisting in this effort by providing contracting support are numerous  agencies, commands, and offices. For U.S. forces, the two primary DOD  contracting entities in Afghanistan based on fiscal year 2010 obligations  are CENTCOM Contracting Command and USACE. CENTCOM  Contracting Command—whose structure includes the Senior Contracting  Officer-Afghanistan and the regional contracting centers—obligated over  $2.7 billion in contracts in fiscal year 2010. Also in fiscal year 2010,  USACE obligated more than $1.8 billion, and it is expected to undertake  approximately $3.7 billion in projects in Afghanistan in fiscal year 2011.  Many of these reconstruction and infrastructure projects are expected to  be built by vendors, including the extensive use of subcontractors.  Further, in fiscal year 2010, USAID obligated over $2.7 billion in program  funds for projects in Afghanistan. According to USAID officials, the  agency is actively involved in using local vendors to provide goods and  services. Additionally, contracts that support forces in Afghanistan may be  awarded in the United States by contracting offices and commands, such  as the Army Materiel Command’s Rock Island Contracting Center and U.S.  Transportation Command. According to State officials, most of the  agency’s contracts in Afghanistan are awarded by contracting officials in  the United States. Further, given the NATO environment in Afghanistan,  contracts that directly or indirectly support U.S. forces may also be  awarded by the contracting offices of coalition partners, such as the  United Kingdom and Germany, and by NATO contracting entities, such as  the NATO Maintenance and Supply Agency.
While the use of local vendors in Afghanistan is a key element of the COIN  strategy, it also brings about challenges. For example, the ISAF/USFOR-A  Commander’s September 2010 guidance cautions that if large quantities of  international contracting funds are spent quickly and with insufficient  oversight, it is likely that some of those funds will unintentionally fuel  corruption, finance insurgent organizations, strengthen criminal patronage  networks, and undermine efforts in Afghanistan. Further, the guidance  suggests that extensive use of subcontractors in Afghanistan, as well as  the lack of visibility of subcontractors by contracting personnel, could  increase the risk of corruption. The September 2010 guidance directs  commanders and contracting officials to gain and maintain visibility of the  subcontractor network, and it warns that excessive subcontracting tiers  provide opportunities for criminal networks and insurgents to divert  contract money from its intended purpose. Additionally, USAID’s Mission  Order for Afghanistan 201.03 seeks to prevent USAID programs and funds  from benefiting terrorists. To prevent resources from being used to  support terrorist activities or organizations, steps have been taken, such as  the issuance of Executive Order 13,224 in September 2001, which blocks  the property of individuals and entities designated as terrorists and  prohibits the support of these listed individuals or entities through dealing  in blocked property. Additionally, various implementing regulations,  found in the Federal Acquisition Regulation, prevent government agencies  from contracting with designated individuals and entities, or require  contracting officers to check potential contract awardees against lists  such as the Excluded Parties List System.
As part of the acquisition process, the Federal Acquisition Regulation  indicates that contracts are to be awarded only to responsible prospective  vendors. A contracting officer must make an affirmative determination of  responsibility prior to awarding a contract. Guidance found in the  CENTCOM Contracting Command Acquisition Instruction, which is  intended to implement and supplement, among other regulations, the  Federal Acquisition Regulation and the Defense Federal Acquisition  Regulation Supplement and to establish general contracting procedures,  states that its contracting officers “shall take all practicable steps to  ensure the award of all contracts to responsible contractors.” Both the  Federal Acquisition Regulation and the Defense Federal Acquisition  Regulation Supplement provide a number of elements to be considered in  the determination of responsibility. Several of these are elaborated upon  in the CENTCOM Contracting Command Acquisition Instruction, including  adequate financial resources to perform the contract, the ability to comply  with delivery or performance schedules, a satisfactory past performance  record (when part of the evaluation), and integrity and business ethics.  The integrity and business ethics element requires the contracting officer  to verify that a prospective awardee is not included in the Excluded  Parties List System.
In response to continued congressional attention and concerns from DOD,  USAID, and other agencies about actual and perceived corruption in  Afghanistan and its impact on U.S. and ISAF activities, several DOD and  interagency (including State and USAID) efforts have been established in  Afghanistan to identify malign actors, encourage transparency, and  prevent corruption. These efforts include the establishment of several  interagency task forces, such as Task Force 2010, an interagency  anticorruption task force that aims to provide commanders and civilian  acquisition officials with an understanding of the flow of contract funds in  Afghanistan in order to limit illicit and fraudulent access to those funds by  criminal and insurgent groups, and the Afghan Threat Finance Cell, an  interagency organization that aims to identify and disrupt funding of  criminal and insurgent organizations. Additionally, ISAF and U.S. agencies  have established several other joint task forces, including the Combined  Joint Interagency Task Force Shafafiyat. Task Force Shafafiyat works to  integrate ISAF and U.S. anticorruption efforts, such as Task Force 2010  and Task Force Spotlight, which focuses on private security contracting,  with those of key Afghan government and civil society partners to foster a  common understanding of the corruption problem in Afghanistan.
section_title: DOD Has Recently Begun to Vet Non-U.S. Vendors in Afghanistan, but Its Efforts Could Be Strengthened by a Risk-Based Approach
subsections: section_title: CENTCOM Contracting Command Has Recently Begun to Vet Vendors in Afghanistan
paragraphs: In 2010, DOD began to vet non-U.S. vendors in Afghanistan by establishing  at CENTCOM headquarters in Tampa, Florida, a vetting cell called the  Vendor Vetting Reachback Cell (vetting cell). The purpose of this vetting  process—which includes the examination of available background and  intelligence information—is to reduce the possibility that insurgents or  criminal groups could use U.S. contracting funds to finance their  operations. The vetting cell is staffed by 18 contractor employees  operating from CENTCOM headquarters and is supervised by DOD  officials. The contract used to establish the vetting cell for Afghanistan  was awarded in June 2010, and in August 2010 the cell began vetting non- U.S. vendors.
According to the CENTCOM Contracting Command Acquisition  Instruction, all contract awards or options equal to or above $100,000 to all  non-U.S. vendors in Iraq and Afghanistan are subject to vetting by the  vetting cell. Additionally, all information technology contracts in  Afghanistan, regardless of dollar value, are subject to vetting. The  Acquisition Instruction suggests that although not required, all vendors  should be submitted for vetting—which would include those with  contracts below $100,000. According to the Acquisition Instruction, to vet  a vendor, a contracting officer, generally located in Afghanistan, submits a  request using a Web-based database system known as the Joint  Contingency Contracting System. These requests are ultimately directed  to the vetting cell located at CENTCOM headquarters in Florida for  vetting. The cell vets the vendor and provides a recommendation either to  approve or disapprove it, which first goes to a DOD official in Tampa for  review and then is forwarded to a DOD entity in Afghanistan, which makes  the final determination. If the final determination calls for not contracting  with the vendor, the customer (e.g., the battlespace owner) can request an  exception to the policy proscribing DOD entities from awarding contracts  to rejected vendors. According to the Acquisition Instruction, contracting  officers should plan for the standard vetting process to take at least 14  calendar days. However, urgent vetting requests can be accomplished in 5  days. A request is considered urgent when the customer informs the  contracting officer in writing that a delay will cause an operational crisis  outweighing the risk of awarding to a potential rejected contractor. After  the final determination is made, the approval or disapproval status of the  vendor is entered and maintained within the Joint Contingency  Contracting System database. According to CENTCOM officials, the cell is  currently conducting periodic re-vettings of previously vetted vendors that  are under contract, which the cell will continue to do as part of its duties.  Additionally, while the vetting cell is structured to be able to vet any non- U.S. vendors, the current vetting emphasis is on Afghan vendors and those  from neighboring countries.
section_title: The CENTCOM Vetting Cell Has Recently Begun Vetting Vendors Used by USACE
paragraphs: USACE obligated over $1.8 billion in Afghanistan in fiscal year 2010, but  until recently it did not have a process in place to routinely vet non-U.S.  vendors. According to USACE officials, in fiscal year 2010, well over half  of USACE contract awards and more than half of the dollars obligated  went to non-U.S. vendors. USACE officials told us that recognizing the  potential for overlap among vendors with which USACE and CENTCOM  Contracting Command are contracting in Afghanistan, CENTCOM  Contracting Command requested that USACE send a list of its most  frequently used prime vendors to be vetted, beginning in January 2011.  USACE officials told us that while CENTCOM Contracting Command has  asked for a list of the most frequently used prime vendors as well as major  subcontractors, it specifically asked USACE to stagger the submission of  vendor names so as not to overwhelm the vetting cell. While USACE  officials told us that some prime contractor names have been submitted, it  is unclear when any subcontractor vendor names will be submitted for  vetting. According to USACE officials, CENTCOM Contracting Command  made this request, in part, because at the time USACE did not use the Joint  Contingency Contracting System database, and as such CENTCOM  Contracting Command personnel bear the burden of entering all USACE  vendor data into the database. USACE officials told us that although  USACE has not previously used the Joint Contingency Contracting System  to track contracts and vendors, it has begun to train personnel, both in  Afghanistan and in the United States, to use the database. Once this  training is complete, USACE expects to have approximately 50 personnel  available who could enter vendor information into the database, which  USACE officials expect will relieve the burden of data entry on CENTCOM  Contracting Command personnel.
section_title: Vendor Vetting Process Faces Limitations
subsections: section_title: Vetting Cell Does Not Routinely Vet Vendors below $100,000 Threshold
paragraphs: The CENTCOM Acquisition Instruction requires that non-U.S. vendors  competing for awards equal to or above $100,000 be vetted by the vetting  cell. The Acquisition Instruction also encourages the vetting of prospective  vendors competing for contracts below $100,000, but these contracts are  not routinely vetted, and CENTCOM could not provide us with the specific  number of vendors below the threshold that have been vetted to date. In  Afghanistan, a significant portion of CENTCOM’s new contracts and  options exercised for fiscal year 2010 awarded by CENTCOM Contracting  Command are below the $100,000 threshold. According to CENTCOM  Contracting Command officials, with the increased focus on local  contracting, the number of contracts below the threshold is expected to  grow. See table 1 for a breakdown of the number and total obligated value  of new contracts and blanket purchase agreements awarded and options  exercised in fiscal year 2010, where the vendor was non-U.S. vendor, at or  above and below the $100,000 threshold. This table shows that although  more money is obligated to contracts and options at or above $100,000,  there may be many more contracts awarded and options exercised below  the $100,000 threshold.
Additionally, USFOR-A and CENTCOM officials told us it is possible that  the same contractor may have multiple contracts with them that taken  individually fall below the $100,000 mark but when viewed collectively  could meet or exceed the $100,000 threshold.
FPDS-NG is the federal government’s primary data system for tracking information on  contracting actions. While FPDS-NG is known to have some limitations, we have tried to  mitigate any potential issues by relying on more recent data and by using more than one  data element in our analysis. For further information on FPDS-NG, please see GAO,  Defense Contracting: Enhanced Training Could Strengthen DOD’s Best Value Tradeoff  Decisions, GAO-11-8 (Washington, D.C.: Oct. 28, 2010), and Federal Contracting:  Observations on the Government’s Contracting Data Systems, GAO-09-1032T  (Washington, D.C.: Sept. 29, 2009).
According to DOD contracting officials and supervisors of the vetting cell,  the contract terms do not specifically exclude vendors below the dollar  threshold from what the cell can vet. Further, CENTCOM Contracting  Command officials stated that if a contracting officer or his or her  representative knows of a specific prospective vendor holding or  competing for numerous contracts below the threshold, officials are free  to recommend that the vendor be vetted. Officials also stated that they are  currently considering the vetting of non–information technology vendors  that fall below the dollar threshold. However, there is no policy or  guidance for this; any such vetting would be conducted on an ad hoc basis.  And while CENTCOM Contracting Command officials have stated that  vetting additional prospective vendors would more fully address potential  risks, they have expressed concern that available vetting cell capacity may  not be able to accommodate a large increase should vendors below the  threshold be included.
section_title: Vetting Cell Does Not Routinely Vet Subcontractors
paragraphs: Currently, CENTCOM Contracting Command does not routinely vet  subcontractor vendors—even when the value of a subcontractor’s work  exceeds the $100,000 threshold. Officials from multiple DOD contracting  entities with whom we spoke said that subcontractors conduct much of  the work in Afghanistan, with some contracts having multiple tiers of  subcontractors. For example, USACE contracting officials stated that  prime vendors that are awarded large construction contracts often use  multiple subcontractor tiers in Afghanistan, and officials recognize that  given the high dollar value of their contracts, a significant risk is  introduced at the subcontractor level. In addition, officials from USFOR-A  stated that the Host Nation Trucking contract—the contract by which  most of the goods needed to support U.S. warfighters are transported  throughout Afghanistan—utilizes multiple tiers of trucking and security  subcontractors. In September 2010, ISAF/USFOR-A released additional  COIN contracting guidance that directs officials to gain more visibility  over the networks of subcontractors in Afghanistan. The guidance further  states that officials are to contract with vendors that have fewer  subcontractors since excessive subcontracting can provide opportunities  for criminal networks and insurgents to divert contract money from its  intended purpose.
USACE contracting officials stated that they plan to submit major  subcontractors through CENTCOM Contracting Command’s vendor  vetting process, though officials did not know when this would occur or  what number of subcontractors the vetting cell would be able to support.  As with the dollar threshold, CENTCOM officials stated that while the  vendor vetting cell contract does not specifically preclude officials from  submitting subcontractors to be vetted, the cell was not designed, in terms  of its number of staff, to vet subcontractors. However, contracting officials  who administer the vetting cell contract, as well as vetting cell officials  who conduct the work, stated that the contract was created with the  flexibility to enable a reallocation of staff between the Iraq and  Afghanistan cells if CENTCOM Contracting Command wanted to vet  vendors below the $100,000 threshold and to vet subcontractors.  Contracting officials have also indicated that the lack of visibility over  subcontractors impairs their ability to provide subcontractor names to the  vendor vetting cell. In August 2010, in order to gain more visibility over  subcontractors, CENTCOM Contracting Command issued Policy  Memorandum No. 10-09, which directs that effective August 31, 2010,  contracting officers must make a subcontractor responsibility  determination in writing, when the prime contractor identifies that it  intends to subcontract a portion of the contract, regardless of a contract’s  dollar value.
section_title: Vetting Cell’s Requirements and Resources Not Clearly Defined
paragraphs: When CENTCOM Contracting Command established the vendor vetting  cell for Afghanistan, it did so without clearly defining the command’s  requirements. According to CENTCOM Contracting Command officials,  the requirements in the contract that established, staffed, and resourced  the Afghanistan vetting cell were defined with the intention of determining  a non-U.S. vendor’s eligibility to be awarded a contract in Afghanistan  prior to award. However, according to command officials, the vetting cell  has been focused on vetting vendors that have already been awarded  contracts. According to CENTCOM Contracting Command officials, they  began vetting vendors who had already received contracts in order to  address immediate corruption and illicit funding concerns. As of   March 12, 2011, CENTCOM Contracting Command officials stated that a  total of 248 vendors, most of which are on existing contracts, had been  vetted, 19 of which had been rejected. Additionally, officials added that the  most recent output average is 15 vendors vetted per week and that  contracts valued at $100,000 were awarded to 1,042 Afghan vendors in  fiscal year 2010. At the current average of 15 vets per week it would take  another 53 weeks, or until late March 2012, just to complete the vetting of  host-nation vendors with contracts of $100,000 or more awarded in fiscal  year 2010. Furthermore, the number of vendors awarded contracts prior to  vetting continues to grow as contracts continue to be awarded in  Afghanistan by CENTCOM Contracting Command during fiscal year 2011.
As of April 2011 CENTCOM Contracting Command has not determined  how many of the remaining non-U.S. vendors that have already been  awarded contracts valued above $100,000 will be vetted in the future, a  timeline for when it will begin vetting vendors prior to award, or an  estimate number of anticipated prospective vendors that will be vetted for  the remainder of the fiscal year. As we have previously reported, without a  sufficient understanding of projected needs, it is difficult to define  accurate requirements, which can result in diminished operational  capability. Further, leading federal management practices for improving  performance state that when planning activities, defined goals, such as  desired output, must be linked with resources in order to effectively and  efficiently achieve results. Since the backlog of vendors not vetted  continues to grow, it is uncertain how the current vetting process and  existing resources will bear the addition of other existing non-U.S.  vendors, prospective CENTCOM Contracting Command vendors, and  vendors from other contracting commands, such as the January 2011  addition of some USACE contracts.
section_title: CENTCOM Contracting Command Considers Other Factors in Prioritizing Vetting Needs but Has Not Formalized or Documented a Risk-Based Approach
paragraphs: CENTCOM Contracting Command and other contracting officials stated  that it would be beneficial to include certain contracts below $100,000 and  large subcontractors in its vetting process. We have previously reported  that a risk-based approach can help DOD and other executive agencies  strategically allocate resources to achieve desired outcomes, including  those for contract oversight, and DOD has also recognized the usefulness  of such an approach to effectively use existing resources in its  acquisitions. For example, we reported that dollar value alone may not  be a good proxy for risk for every type of contract and that other facto rs  could also be used to identify potential risk, such as the characteristics of  the activity being performed, the location, or the type of contract. CENTCOM Contracting Command officials stated in February 2011 that  because of their concerns regarding the vetting cell’s capacity, as well as  their desire to use the vetting cell resources efficiently and immediately,  they prioritized the first tranche of vendors vetted based on a variety of  factors in addition to the dollar threshold and vendor type given in the  Acquisition Instruction. Specifically, officials stated that the first set of  vendors vetted were drawn from contracts performed in Kandahar  province, which is generally accepted as a Taliban stronghold; high-value  and high-risk contracts, such as private security contracts; complex  contracts, such as the Host Nation Trucking contract; and some high-value  construction projects in certain high-threat regions.
GAO-07-20. approach, for example, in a set of standard operating procedures or white  paper; however, these documents have not yet been completed, and  officials could not provide any further information. Utilizing a risk-based  approach to identify high-risk vendors below the $100,000 threshold, as  well as subcontractors, could enable CENTCOM Contracting Command to  expand its ability to prevent contracts from going to criminal or insurgent  groups within existing resource constraints, particularly as CENTCOM  Contracting Command balances vetting existing contracts, those prior to  award, and vendors from other commands. For instance, while officials  have stated that the USACE’s subcontractors pose a large risk because the  high value of their construction contracts, they stated that some of the  larger subcontractors are prime vendors for other projects, and many of  the USACE subcontractors are also used by CENTCOM Contracting  Command, either as prime contractors or subcontractors. USACE officials  also stated that as of February 2011, their hope is that their large  subcontractors that are not vetted through their roles as prime contractors  will be submitted to the CENTCOM vetting cell soon, and that USACE  aims to decrease the data entry burden on CENTCOM Contracting  Command by beginning to use its own personnel to enter information into  the Joint Contingency Contracting System. However, as of February 2011,  CENTCOM Contracting Command and USACE officials could not specify  when USACE will begin submitting subcontractors for vetting because of  CENTCOM Contracting Command’s questions regarding the vetting cell’s  capacity, and to date CENTCOM has no plans to begin routinely vetting its  subcontractors.
section_title: USAID Has Begun to Develop a Vendor Vetting Process, but State Has Not
subsections: section_title: USAID Has Recently Established a Unit to Vet Non-U.S. Implementing Partners in Afghanistan, Though Details of the Process Have Not Been Finalized
paragraphs: In January 2011, in order to counter potential risks of U.S. funds being  diverted to support criminal or insurgent activity, USAID created a process  for vetting prospective non-U.S. contract and assistance recipients (i.e.,  implementing partners) in Afghanistan, which is similar to a vetting  process it has used in the West Bank and Gaza since 2006. Previously, as  of October 2010, USAID officials indicated that they expected to use the  CENTCOM Contracting Command vetting cell to vet potential non-U.S.  implementing partners—whether through a formal interagency agreement,  shared system or platform, or some other information-sharing  arrangement. At the time, officials expressed that they wanted to have one  consistent U.S. government approach for vetting non-U.S. vendors in  Afghanistan to ensure that no USAID implementing partners engage in or  support criminal or insurgent groups with contract or other assistance  funds. As illustrated in table 2, in fiscal year 2010 USAID reported 114 new  contracts and other awards to U.S. partners valued at over $285 million,  and 126 to non-U.S. partners valued at almost $46 million. While the  number of dollars USAID reported as obligated to non-U.S. partners is  substantially lower than that to U.S. partners, the numbers of awards given  is higher. In addition, as with DOD, USAID officials said the use of  subcontractors/subawardees is extensive, and the use of host-nation  partners is expected to increase.
According to USAID officials, the agency had long been interested in  vetting its non-U.S. implementing partners in Afghanistan and, with the  establishment of the CENTCOM vetting cell, USAID had been working  with CENTCOM’s Senior Contracting Official in Afghanistan to do so.  However, in late 2010 several factors emerged that led USAID to  immediately begin exploring whether the CENTCOM Contracting  Command vetting cell best met its needs or, alternatively, the agency  needed to establish its own vetting process. For example, USAID officials  said that in October 2010 they received a report by the Afghan Threat  Finance Cell that found that a certain percentage of USAID dollars were  being diverted in certain Afghan provinces and in some cases funneled to  insurgent groups. Additionally, in determining if CENTCOM’s vetting cell  could meet its needs, officials stated that they sent a test vetting through  the cell and that it took nearly 3 months for the vetting cell to provide  results. Once USAID began looking into the possibility of setting up a  vetting unit, officials said they assessed that the agency had existing  capabilities from its vetting process used in the West Bank and Gaza with  which to implement a process similar to CENTCOM’s without having to  establish a duplicative system. According to USAID officials, given the  urgent need to mitigate the issues reported by the Afghan Threat Finance  Cell, the timelines experienced with the CENTCOM vetting cell, and the  availability of existing vetting resources within USAID, the agency, in  consultation with the Coordinating Director for Development and  Economic Affairs for the U.S. Embassy in Kabul, decided that a Kabul- based USAID vetting support unit separate from CENTCOM’s process  would most immediately and effectively meet the agency’s needs.
USAID officials stated that in preparation for standing up the vetting  support unit, the agency sent representatives from its Office of Security to  observe the CENTCOM vendor vetting cell’s process. According to USAID  officials, after observing the CENTCOM process they concluded that  USAID had the existing resources and ability to similarly vet its  implementing partners within timelines that met the agency’s needs. In  January 2011, USAID issued a cable outlining the initial structure of its  newly created vetting support unit in Afghanistan, and as of March 2011  USAID officials were in the process of drafting standard operating  procedures. According to USAID officials and the January 2011 cable, the  purpose of the vetting support unit is to help ensure that U.S. government  funds do not support malign actors, such as insurgents, corrupt power  brokers, and criminal patronage networks. The unit is to comprise an  intelligence analyst and two or more permanent support staff stationed in  Kabul, who would reach back to existing vetting analysts in USAID’s  Office of Security in Washington, D.C., who would conduct the vetting. As  with the CENTCOM process, the actual vetting would take place in the  United States, while information identifying the prospective non-U.S.  partners would be forwarded from the support unit in Afghanistan to  USAID’s vetting database. If USAID analysts find derogatory information,  the final decision about whether to use the partner would reside with  USAID officials in Afghanistan. Although the vetting unit is currently  situated within the Office of Acquisition and Assistance in Kabul, USAID  officials stated that the responsibilities of the unit are more closely aligned  with security-related functions rather than the formal acquisition process,  and that many details of the unit are still being determined. As of February  2011, USAID officials stated that the vetting support unit is currently  staffed with temporary personnel, and they expect the process of hiring  permanent staff to be complete in 3 to 6 months.
The USAID vetting process, as it is described by officials and in  preliminary documentation, may have limitations that are similar to those  of CENTCOM. For example, USAID’s January 2011 cable indicates that  there is a $150,000 award threshold for selecting potential implementing  partners to vet, and USAID is still finalizing the extent to which it will vet  subcontractors/subawardees. In addition, according to USAID officials, as  a first step while the unit hires permanent staff, it will focus first on host- nation partners when it plans to begin vetting in April 2011. However,  USAID officials indicated that the agency’s vendor vetting process was still  in the early stages, and it is expected to be an iterative implementation  process—aspects of which could change, such as the vetting threshold and  expanding vetting to other non-U.S. partners. Officials stated that  ultimately, the formalized vetting criteria will likely incorporate the  assessment of other risk factors, such as which province the activity is  located in and local knowledge of USAID officials; however, these criteria  have not yet been included in preliminary documents. In addition, in  March 2011 officials noted that the vetting support unit will vet at least  first-tier potential subcontractors/subawardees that have been identified  as apparent recipients of awards with a value of $150,000 or more, and will  likely go beyond first-tier subcontractors/subawardees for certain awards,  though this has also not been finalized. Further, officials pointed to their  experience developing and implementing USAID’s vetting efforts in the  West Bank and Gaza—which has included trying different monetary  thresholds, as well as vetting contract recipients whose cumulative awards  reach the threshold in order to capture frequently used partners—and  indicated that they expect to include such considerations as they continue  to develop the vetting process. As previously discussed, we have  frequently reported the value of using a risk-based approach to effectively  achieve desired results. Incorporating such an approach into determining  what implementing partners to vet—as USAID officials have indicated will  occur but has not yet been documented—would increase USAID’s ability  to address the greatest risk with existing resources.
section_title: State Has Not Created a Vendor Vetting Process for Afghanistan
paragraphs: As of March 2011, State was not vetting vendors in Afghanistan. State  officials told us that currently many of their contracts are awarded to U.S.  prime contractors, and they award relatively few contracts to non-U.S.  vendors. However, table 3 shows that based on our analysis, State does  work with many non-U.S. vendors in Afghanistan, but embassy officials in  Kabul told us that they do not do any vetting or background checks on the  vendors other than for the security risks posed by individual personnel  with physical access to the embassy property or personnel. See table 3 for  a comparison between quantities of awards to U.S. vendors and those to  non-U.S. vendors.
Further, State has endorsed the Afghan First policy, which will likely  result in increased contracting with Afghan vendors in the future, which  will in turn increase the potential for funds to be diverted to terrorist or  insurgent groups. Given this potential increase in local contracting, and  without a way to consider—after specific vendors are known to be  candidates—the risk posed by funding non-U.S. vendors to perform  particular activities in Afghanistan, the department may increasingly  expose itself to contracting with malign actors.
While State does not have a vendor vetting program, in 2008 State issued a  cable that applies to both State and USAID, requiring personnel to  complete a terrorist financing risk assessment for any new program or  activity prior to requesting or obligating program funds. Periodic updates  to the risk assessment are also completed for ongoing programs and  activities, though these do not examine vendors against the same  information as the CENTCOM or USAID vetting cells. The risk assessment  is intended to ensure that projects and activities are not providing  benefits, even inadvertently, to terrorists or their supporters, including  people or organizations that are not specifically designated by the U.S.  government as such but that may, nevertheless, be linked to terrorist  activities. This risk assessment weighs the likelihood that a program or  activity will inadvertently be funding or benefiting terrorists against the  consequences of that occurring—a risk that varies greatly depending on  the type and location of the program or activity. USAID and DOD’s vendor  vetting processes are intended to be conducted once a potential vendor for  a specific contract or activity is known in order to determine whether  awarding to a particular entity will increase the likelihood of U.S. funds  being diverted to insurgent or other criminal actors, and additionally use  law enforcement and intelligence information.
section_title: DOD, USAID, and State Have Not Developed a Formal Method of Sharing Vendor Vetting Information in Afghanistan
paragraphs: Although DOD, USAID, and State likely utilize many of the same vendors  in Afghanistan, the agencies have not developed a formalized process to  share vendor vetting information. Currently, DOD and USAID officials in  Afghanistan have established informal communication such as biweekly  meetings, ongoing correspondence, and mutual participation in working  groups. Further, DOD and USAID officials said that their vetting efforts are  integrally related and are complementary to the work of the various  interagency task forces, such as Task Force 2010 and the Afghan Threat  Finance Cell, and that their mutual participation in these task forces  contributes to interagency information sharing in general and vetting  results in particular. However, a formal arrangement for sharing  information such as would be included in a standard operating procedure  or memorandum of agreement between DOD and USAID has not been  developed. In addition, though the U.S. Embassy also participates in  various interagency task forces, such as Task Force 2010, there is no  ongoing information sharing of vendor vetting results, either ad hoc or  formal. According to CENTCOM Contracting Command officials, the  command is in the process of developing a standard operating procedure  for sharing the vendor vetting results specifically with USAID, but this  document has not yet been completed.
Standards for internal control for the federal government highlight the  importance of establishing and documenting communication and  information-sharing capabilities to enable agencies to achieve their goals.
In addition, prior GAO work has highlighted the importance of interagency  information sharing and collaboration to achieve common outcomes.  USAID and CENTCOM Contracting Command officials stated that  interagency information sharing is active and effective; that ISAF, USFOR- A, and USAID are in constant communication in order to establish a  common picture of ongoing vetting efforts and results; and that officials  have emphasized their strong working relationships. Further, according to  USAID officials, sharing vendor vetting results would greatly assist the  agency’s efforts to ensure that it is not conducting business with known  malign actors in Afghanistan. However, in a workforce environment  characterized by frequent personnel rotations, maintaining continuity of  processes and procedures can be a challenge. Without documented,  formalized procedures, DOD and USAID cannot ensure that their current  information-sharing practices will endure. Further, sharing information on  vetting results could be especially beneficial for State, since it currently  has no plans to perform vetting of the type done by DOD and USAID for  any of its non-U.S. vendors in Afghanistan.
section_title: Conclusions
paragraphs: In Afghanistan, the use of local vendors by U.S. government agencies such  as DOD, USAID, and State is a key component of the COIN strategy. But  awards to local vendors in Afghanistan pose particular challenges because  of the potential for fraud, corruption, or the siphoning of funds to  organizations hostile to U.S. forces. These concerns highlight the  importance of establishing processes for mitigating the risk that malign  actors could profit from U.S. government contracts. Both CENTCOM  Contracting Command and USAID have established processes to vet non- U.S. vendors in Afghanistan, but these processes are time- and resource-  intensive. Given these restraints, it is not feasible to vet every non-U.S.  vendor that contracts with the U.S. government in Afghanistan, and it is  important that vendors are selected for vetting based on a variety of  factors, including the risk level for the service being provided and the risk  estimate based on the geographic area in which the service is to be  performed. Understanding the capacity and resources available to  CENTCOM Contracting Command is also essential to devising an  appropriate risk-based approach to effectively use the vendor vetting cell  to achieve its goals with existing resources in the short term and  evaluating what resources will be needed to accommodate any further  increase in the workload in the future. Further, as USAID begins to finalize  its vetting process, the consideration of a risk-based approach may help  the agency to address limitations similar to those of the CENTCOM  process. While State has not yet developed a specific vendor vetting  process, given the number of non-U.S. vendors it currently uses, and as it  goes forward with implementing Afghan First, the need to vet these  vendors may become more acute in order to mitigate the risk of  contracting with these vendors. Given the multiagency operational  environment in Afghanistan, it is imperative that U.S. efforts be  coordinated and that information about malign actors be shared among all  contracting parties. This information sharing may be particularly  important for State because it does not currently vet its non-U.S. vendors.  Otherwise, agencies may unknowingly contract with vendors that have  been deemed a risk by other agencies.
section_title: Recommendations for Executive Action
paragraphs: To safeguard U.S. personnel against security risks and help ensure that  resources are not used to support insurgent or criminal groups, we  recommend that the Commander of U.S. Central Command direct  CENTCOM Contracting Command to    consider formalizing a risk-based approach to enable the department to  identify and vet the highest-risk vendors—including those vendors with  contracts below the $100,000 threshold—as well as subcontractors and    work with the vendor vetting cell to clearly identify the resources and  personnel needed to meet the demand for vendor vetting in Afghanistan  using a risk-based approach.
To help ensure that resources are not used to support terrorist or criminal  groups, we recommend that the Director of the Office of Security and the  USAID Mission Director, Kabul, Afghanistan, consider formalizing a risk- based approach that would enable USAID to identify and vet the highest- risk vendors and partners, including those with contracts below the  $150,000 threshold.
To help ensure that State resources are not diverted to insurgent or  criminal groups, we recommend that the Secretary of State direct the  appropriate bureau(s) to assess the need and develop possible options to  vet non-U.S. vendors, which could include leveraging existing vendor  vetting processes, such as USAID’s, or developing a unique process.
To promote interagency collaboration so as to better ensure that vendors  potentially posing a risk to U.S. forces are vetted, we also recommend that  the Commander of U.S. Central Command; USAID Mission Director,  Kabul, Afghanistan; and the Coordinating Director for Development and  Economic Affairs, U.S. Embassy, Kabul, Afghanistan, consider developing  formalized procedures, such as an interagency agreement or memorandum  of agreement, to ensure the continuity of communication of vetting results  and to support intelligence information, so that other contracting activities  may be informed by those results.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DOD, USAID, and State. We received  written comments from all three, which we have reprinted in appendixes  II, III, and IV, respectively. DOD concurred with our recommendations. In  response to our second recommendation to CENTCOM to work with the  vendor vetting cell to identify the resources and personnel needed to meet  the demand for vendor vetting in Afghanistan, DOD provided additional  clarification about the limitations that currently exist on its resources,  including limitations on expanding its joint manning document and the  current mandate to reduce staff at CENTCOM. USAID concurred with our  recommendations, and in its response also noted that the GAO team’s field  work and draft report contributes positively to USAID/Afghanistan’s  efforts to implement a system to help ensure that resources are not used  to support terrorist or criminal groups.
State partially concurred with our recommendation that the Secretary  direct the appropriate bureaus to assess the need and develop possible  options to vet non-U.S. vendors.  State noted in its written comments that  it recognizes the risk of U.S. funds under State’s management being  diverted for the benefit of terrorists or their supporters, and has devoted a  good deal of time to defining the issue and seeking appropriate processes  to mitigate the risk of this occurring. However, State noted that significant  legal concerns relating to contracting law, competition requirements, and  the conflict between open competition and the use of classified databases  to vet contractors and grantees have required analysis and discussion. We  recognize these concerns and encourage State to continue to address the  various issues if they develop and implement a vetting process.  Additionally, State said that the Department of State, Foreign Operations,  and Related Programs Appropriations Act for Fiscal Year 2010 (which is  Division F of the Consolidated Appropriations Act, 2010, Pub. L. No. 111- 117) prohibited the use of State funds to implement a partner vetting  program but authorized creation of a pilot program for contractor vetting  to apply to both State and USAID programs and activities. State noted that  the department has assigned responsibility for developing such a pilot  vetting program and has begun work on the pilot’s design. We appreciate  State’s efforts to begin the pilot program and the need for State and USAID  to act consistently with the funding restriction described above in all their  vetting efforts. However, as we previously noted, State and USAID officials  both indicated that the pilot program would not apply to Afghanistan.  Additionally, based on its written comments, State is beginning to address  our recommendation as it noted that Afghanistan is under active review  for inclusion in a vetting effort that would apply specifically to that  country.
State did not comment on our recommendation that DOD, USAID, and  State consider developing formalized procedures to ensure the continuity  of communication of vetting results and to support intelligence  information, so that other contracting activities may be informed by those  results.
We are sending copies of this report to the appropriate congressional  committees and the Secretaries of Defense and State and the  Administrator of the United States Agency for International Development.  This report also is available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-8365 or solisw@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made major contributions to this report are  listed in appendix V.
section_title: Appendix I: Scope and Methodology
paragraphs: Under the authority of the Comptroller General of the United States, we  initiated a review to identify what efforts, if any, are under way to ensure  that U.S. contracting funds or resources are not diverted to support  corruption or insurgent organizations. Specifically, we examined (1) the  extent to which the Department of Defense (DOD) has established a  process to vet non-U.S. vendors in Afghanistan, both to ensure that  resources are not used to support insurgent or criminal groups and to  safeguard U.S. personnel and assets against security risks; (2) the extent to  which the Department of State (State) and the United States Agency for  International Development (USAID) have established processes to vet  non-U.S. vendors and other assistance recipients in Afghanistan; and   (3) the extent to which vetting information is shared among DOD, State,  and USAID.
As the use of host nation and regional contractors is expected to increase  through the use of various agreements, such as Afghan First, in which the  United States and NATO have demonstrated a commitment to obtain  products and services locally, we focused our review on non-U.S.  contractors and nongovernmental organizations, as well as based on  congressional interest. Further, legal protections, policy considerations,  and business practices in the United States could constrain the U.S.  Government from investigating U.S. citizens, so vetting of U.S. contractors  would be more constrained.
To identify and examine the efforts DOD has taken to vet non-U.S vendors  in Afghanistan and the extent to which State and USAID have established  processes to vet non-U.S. vendors in Afghanistan and to share this vetting  information, we reviewed recent DOD, State, and USAID policies and  procedures, including fragmentary orders; the recently updated November  2010 U.S. Central Command (CENTCOM) Contracting Command’s  Acquisition Instruction as well as a previous version USAID’s Mission  Order for Afghanistan 201.03; and an April 2010 memorandum of  understanding between DOD, State, and USAID relating to contracting in  Iraq and Afghanistan. Additionally, we reviewed the DOD contract that  establishes a vendor vetting cell in support of U.S. forces in Afghanistan  and Iraq at CENTCOM headquarters in Tampa, Florida, and the contract’s  associated classified policies and procedures, as well as draft standard  operating procedures for USAID’s vetting support unit in Afghanistan. We  do not discuss the mechanics of the vetting processes used by DOD and  USAID in detail because we did not evaluate the effectiveness of the  methods used by the agencies to conduct the vetting. We also reviewed a  2008 State cable that applies to both USAID and State regarding risk  assessments to mitigate the threat of financing terrorism. In addition, we  reviewed prior GAO and other audit agency work that was related to  contract management and oversight in Afghanistan, as well as vetting.
We interviewed cognizant DOD, State, and USAID officials in both  Afghanistan and the United States, including DOD policy, logistics, and  acquisition officials from the offices of the relevant Under Secretaries of  Defense in Washington, D.C.; CENTCOM officials in the planning, logistics,  and intelligence directorates, as well as representatives of the vendor  vetting cell in Tampa, Florida; and USAID and State officials in  Washington, D.C., responsible for contracting, procurement, and security.  We do not discuss the mechanics of the vetting processes used by DOD  and USAID in detail because we did not evaluate the effectiveness of the  methods used by the agencies to conduct the vetting. In Afghanistan, we  interviewed a variety of DOD, United States Forces – Afghanistan  (USFOR-A), and CENTCOM Contracting Command officials in Kabul,  including the CENTCOM Senior Contracting Official there, and the  commanders of Task Force 2010, Task Force Spotlight, and other groups.  Additionally, we put out data calls to USAID and the Department of State  for their procurement for fiscal year 2010 in Afghanistan.  We present  procurement data for fiscal year 2010 in Afghanistan, based on data calls  to USAID and the Department of State, and our own data pulls to give a  broad context for the scale of awards to U.S. compared to non-U.S. and  the amount obligated and determined the method used to gather this data  to be sufficiently reliable for this purpose. We also interviewed cognizant  U.S. Embassy security and contracting officials and USAID security and  contracting officials, all in Kabul. Additionally, we interviewed officials  from USFOR-A regional contracting centers in Kabul, Camp Leatherneck,  and Kandahar; U.S. Army Corps of Engineers (USACE) officials in  Kandahar, as well as USACE officials in other locations via teleconference;  and International Security Assistance Force contracting and security  officials in Kabul and Kandahar. We also held teleconferences with  contracting officials at Bagram Air Force Base and in Qatar.
We retrieved contract data from the Federal Procurement Data System- Next Generation to present information about the amount of obligations  for USACE and both the obligations and the number of awards above and  below $100,000 for CENTCOM Contracting Command in fiscal year 2010 in  Afghanistan. Additionally, we put out data calls to USAID and State for  their procurement data for fiscal year 2010 in Afghanistan. We presented  these data in our report to give a broad context for the scale of awards to  U.S. vendors compared to those to non-U.S. vendors and the amounts  obligated, and we determined the method used to gather these data to be  sufficiently reliable to present the information in this context.
We conducted this performance audit from May 2010 through June 2011 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.
We visited or contacted the following organizations during our review:    Office of the Under Secretary of Defense for Acquisition, Technology and  Logistics, Washington, D.C.
section_title: Appendix II: Comments from the Department of Defense
section_title: Appendix III: Comments from the United States Agency for International Development
section_title: Appendix IV: Comments from the Department of State
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, major contributors to this report  were Carole Coffey, Assistant Director; Johana Ayers; Vincent Balloon;  Laura Czohara; Timothy DiNapoli; Melissa Hermes; Jason Jackson;  Natasha Wilder; and Sally Williamson. In addition, Michael Shaughnessy  provided legal support, Julia Kennon provided technical support, and  Cheryl Weissman and Kimberly Young provided assistance in report  preparation.