Defense Management: Widespread DCAA Audit Problems Leave Billions of Taxpayer Dollars Vulnerable to Fraud, Waste, Abuse, and Mismanagement
Published: 2009-10-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In fiscal year 2008, the Department of Defense (DOD) obligated over $380 billion to federal contractors, more than doubling the amount it obligated in fiscal year 2002. With hundreds of billions of taxpayer dollars at stake, the government needs strong controls to provide reasonable assurance that contract funds are not being lost to fraud, waste, abuse, and mismanagement. The Defense Contract Audit Agency (DCAA) is charged with a critical role in contractor oversight by providing auditing, accounting, and financial advisory services in connection with DOD and other federal agency contracts and subcontracts. However, last year GAO found numerous problems with DCAA audit quality at three locations in California, including the failure to meet professional auditing standards. In a follow-up audit issued this September, GAO found that these problems existed agencywide. Today's testimony describes widespread audit quality problems at DCAA and provides information about continuing contract management challenges at DOD, which underscore the importance of DCAA audits that meet professional standards. It also discusses some of the corrective actions taken by DCAA and DOD and key GAO recommendations to improve DCAA audit quality. In preparing this testimony, GAO drew from issued reports and testimonies. These products contained statements regarding the scope and methodology GAO used.
section_title: What GAO Found
paragraphs: GAO found substantial evidence of widespread audit quality problems at DCAA. In the face of this evidence, DOD, Congress, and American taxpayers lack reasonable assurance that billions of dollars in federal contract payments are being appropriately scrutinized for fraud, waste, abuse, and mismanagement. An initial investigation of hotline allegations at three DCAA field office locations in California revealed that all 14 audits and 62 forward pricing reports GAO examined were not performed in accordance with professional auditing standards. For example, while auditing the satellite launch proposal for a major U.S. defense contractor, a DCAA manager experienced pressure from the contractor and the DOD buying command to drop adverse findings. The manager directed his auditors to drop the findings, and DCAA issued a more favorable opinion, allowing the contractor to win a contract that improperly compensated the contractor for hundreds of millions of dollars in commercial business losses. Specifically, of $271 million in unallowable costs related to commercial losses, the contractor has already been paid $101 million. This incident is under criminal investigation by the DOD Inspector General (IG). In September of this year, GAO followed up on its initial investigation and identified audit quality problems agencywide at DCAA. Audit quality problems included insufficient audit testing, inadequate planning and supervision, and the compromise of auditor independence. For example, of the 69 audits and cost-related assignments GAO reviewed, 65 exhibited serious deficiencies that rendered them unreliable for decisions on contract awards, management, and oversight. DCAA has rescinded 81 audit reports to date as a result of GAO's and DOD IG's work. Because the rescinded reports were used to assess risk in planning subsequent audits, they affect the reliability of hundreds of other audits and contracting decisions covering billions of dollars in DOD contract expenditures. GAO determined that quality problems are widespread because DCAA's management environment and quality assurance structure were based on a production-oriented mission that prevented DCAA from protecting the public interest while also facilitating DOD contracting. GAO has designated both contract management and weapon systems acquisition as high-risk areas since the early 1990s. DOD acquisition and contract management weaknesses create vulnerabilities to fraud, waste, abuse, and mismanagement that leave hundreds of billions of taxpayer dollars at risk, and underscore the importance of a strong contract audit function. In response to GAO's findings and recommendations, DCAA has taken several steps to improve metrics, policies, and processes, and the DOD Comptroller has established a DCAA oversight committee. To ensure quality audits for contractor oversight and accountability, DOD and DCAA will also need to address the fundamental weaknesses in DCAA's mission, strategic plan, metrics, audit approach, and human capital practices that have had a detrimental effect on audit quality.

section_title: Letter
paragraphs: Thank you for the opportunity to discuss our work related to the Defense  Contract Audit Agency (DCAA). DCAA is charged with a critical role in  DOD and other federal agency contractor oversight by providing auditing,  accounting, and financial advisory services in connection with the  negotiation, administration, and settlement of contracts and subcontracts.  DCAA contract audits are intended to be a key control to help ensure that  prices paid by the government for needed goods and services are fair and  reasonable and that contractors are charging the government in  accordance with applicable laws, the Federal Acquisition Regulation  (FAR), Cost Accounting Standards (CAS), and contract terms. DCAA’s  mission encompasses both audit and nonaudit services in support of DOD  contracting and contract payment functions.
The majority of DCAA audits focus on cost-reimbursable and other  flexibly priced contracts, including progress payments on major weapon  systems and time-and-materials contracts. These contract types pose the  highest risk to the government because the government has agreed to pay  the actual incurred cost, plus profit. DCAA audits of contractor business  systems and related internal controls support decisions on pricing,  contract awards, and billing. For example, the FAR requires government  contracting officers to determine the adequacy of a contractor’s  accounting system before awarding a cost-reimbursement or other flexibly  priced contract. Audits of estimating system controls support negotiation  of fair and reasonable prices. Also, billing system audits support decisions  to authorize contractors to submit invoices directly to DOD payment  offices for payment without government review. Internal control audits  also impact the planning and reliability of other DCAA audits, such as  audits of contractors’ pricing proposals and annual incurred cost claims,  because DCAA uses the results of its internal control audits to assess risk  and plan the nature, extent, and timing of tests for these audits.
Since the early 1990s, we have reported DOD weapon systems acquisition  and contract management as high-risk areas. DOD acquisition and  contract management weaknesses create vulnerabilities that leave  hundreds of billions of taxpayer dollars at risk, and underscore the  importance of a strong contract audit function. Every dollar wasted during  the development and acquisition of weapon systems is money that is not  available for other priorities within DOD and across the government.
Today, I will discuss the findings from our two recent DCAA reports and  note some of the challenges in DOD’s contract management that make  DCAA audits a key control for assuring that prices paid by the government  for needed goods and services are fair and reasonable and that contractors  are not overcharging the government. I will conclude by highlighting some  of the recent actions taken by DCAA and DOD and key recommendations  we have made to improve DCAA audit quality.
In preparing this testimony, we relied on the work we performed during  our DCAA hotline investigations and our DCAA performance audit, as well  as our extensive body of work on DOD’s contract management. A list of  these products is provided at the end of this testimony. Our audit work  was conducted in accordance with generally accepted government  auditing standards (GAGAS). Those standards require that we plan and  perform our audits 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  performed our investigative procedures in accordance with quality  standards set forth by the Council of the Inspectors General on Integrity  and Efficiency (formerly the President’s Council on Integrity and  Efficiency).
subsections: section_title: Widespread DCAA Management Environment and Audit Quality Problems
paragraphs: Our investigation of DCAA hotline allegations and our DCAA-wide follow- up audit document systemic weaknesses in DCAA’s management  environment and structure for assuring audit quality. Last year, our  investigation of hotline allegations substantiated auditor concerns made  on all 14 audits we reviewed at two locations and 62 forward pricing  reports we investigated at a third location. We found that (1) workpapers  did not support reported opinions, (2) DCAA supervisors dropped findings  and changed audit opinions without adequate audit evidence for their  changes, and (3) sufficient audit work was not performed to support audit  opinions and conclusions. In addition, we found that contractor officials  and the DOD contracting community improperly influenced the audit  scope, conclusions, and opinions of some audits—a serious independence  issue. This year, our follow-on audit found DCAA-wide audit quality  problems similar to those identified in our investigation, including  compromise of auditor independence, insufficient audit testing to support  conclusions and opinions, and inadequate planning and supervision.
For example, of the 69 audits and cost-related assignments we reviewed,  65 exhibited serious GAGAS and other deficiencies that rendered them  unreliable for decisions on contract awards and contract management and  oversight. Although not as serious, the remaining four audits also had  GAGAS compliance problems. Of the 69 audits and cost-related  assignments, 37 covered key contractor business systems and related  controls, including cost accounting, estimating, and billing systems.  Contracting officers rely on the results of these audits for 3 or more years  to make decisions on pricing, contract awards, and payments. In addition,  while DCAA did not consider 26 of the 32 cost-related assignments we  reviewed to be GAGAS audits, DCAA did not perform sufficient testing to  support reported conclusions on that work related to contractor billings.
DCAA has rescinded 81 audit reports in response to our work and the  DOD Inspector General’s (IG) follow-up audit because the audit evidence  was outdated, insufficient, or inconsistent with reported conclusions and  opinions and reliance on these reports for contracting decisions could  pose a problem. About one-third of the rescinded reports relate to  unsupported opinions on contractor internal controls and were used as  the basis for risk-assessments and planning on subsequent internal control  and cost-related audits. Other rescinded reports relate to CAS compliance  and contract pricing decisions. Because the conclusions and opinions in  the rescinded reports were used to assess risk in planning subsequent  audits, they impact the reliability of hundreds of other audits and  contracting decisions covering billions of dollars in DOD expenditures.
subsections: section_title: Investigation of Hotline Allegations Identified Serious Audit Deficiencies
paragraphs: Our hotline investigation found numerous examples where DCAA failed to  comply with GAGAS. For example, contractor officials and the DOD  contracting community improperly influenced the audit scope,  conclusions and opinions, and reporting in three cases we investigated—a  serious independence issue. For 14 audits at two DCAA locations, we  found that (1) audit documentation did not support the reported opinions,  (2) DCAA supervisors dropped findings and changed audit opinions  without adequate evidence for their changes, and (3) sufficient audit work  was not performed to support audit opinions and conclusions. We also  substantiated allegations that forward pricing audit reports at a third  DCAA location were issued before supervisors completed their review of  the audit documentation because of the 20- to 30-day time frames required  to support contract negotiations.
Throughout our investigation, auditors at each of the three locations  addressed in the hotline allegations told us that the limited number of  hours approved for their audits directly affected the sufficiency of audit  testing. Deficient audits do not provide assurance that billions of dollars in  annual payments to these contactors complied with the FAR, CAS, or  contract terms. We also found that DCAA managers took actions against  staff at two locations, attempting to intimidate auditors, prevent them  from speaking with investigators, and creating a generally abusive work  environment. The following discussion highlights some of the examples  from our investigation.
In planning an estimating system audit of a major aerospace company,  DCAA made an up-front agreement with the contractor to limit the  scope of work and basis for the audit opinion. The contractor was  unable to develop compliant estimates, leading to a draft audit opinion  of “inadequate-in-part.” The contractor objected to the draft findings,  and DCAA management assigned a new supervisory auditor. DCAA  management then threatened the senior auditor with personnel action  if he did not delete the findings from the report and change the draft  audit opinion to “adequate.”
Another audit of the above contractor related to a revised proposal that  was submitted after DCAA had reported an “adverse” (inadequate)  opinion on the contractor’s 2005 proposal to provide commercial  satellite launch capability. At the beginning of the audit, the buying  command and contractor officials met with a DCAA regional audit  manager to determine how to resolve CAS compliance issues and  obtain a favorable audit opinion. Although the contractor failed to  provide all cost information requested for the audit, the DCAA    regional audit manager (RAM) instructed the auditors that they could  not base an “adverse” opinion on the lack of information to audit  certain costs. The manager directed the auditors to exclude any  reference to CAS noncompliance in the audit documentation and to  change the audit opinion to “inadequate-in-part.” Based on the more  favorable audit opinion, the buying command negotiated a $967 million  contract which has since grown to over $1.6 billion through fiscal year  2009. The Defense Criminal Investigative Service is completing a  criminal investigation conducted in response to our findings.
The DOD IG performed a follow-up audit and confirmed our findings  that DCAA’s audit was impaired because of a lack of independence; the  audit working papers did not support the reported opinions in the     May 8, 2006, proposal audit report; and the draft audit opinion was  changed without sufficient documentation. In addition, the DOD IG  concluded that the DCAA RAM failed to exercise objective and  impartial judgment on significant issues associated with conducting the  audit and reporting on the work—a significant independence  impairment—and that the RAM did not protect the interests of the  government as required by DCAA policy. The DOD IG also concluded  that the contractor’s unabsorbed Program Management and Hardware  Support (PM&HS) costs represented losses incurred on other contracts  and prior accounting periods, including commercial losses—a CAS  noncompliance. The DOD IG recommended that the Air Force buying  command withhold the balance of $271 million for unabsorbed PM&HS  costs (of which $101 million had already been paid) and that the Air  Force cease negotiations with the launch services contractor on a $114  million proposal for unabsorbed costs. DCAA is currently performing  CAS compliance audits on the commercial satellite launch contract  costs. If DCAA determines that the contractor’s costs did not comply  with CAS related to unallowable costs, cost accounting period, and  allocation of direct and indirect cost, and the FAR related to losses on  other contracts, DCAA findings should provide the basis for  recovering amounts already paid.
For a billing system audit of a contractor with $168 million in annual  billings to the government, the field office manager allowed the original  auditor to work on the audit after being assured that the auditors  would help the contractor correct billing system deficiencies during the  performance of the audit. After the original auditor identified 10  significant billing system deficiencies, the manager removed her from  the audit and assigned a second auditor who then dropped 8 of the 10  significant deficiencies and reported one significant deficiency and one  suggestion to improve the system. The final opinion was “inadequate- in-part.” However, the DCAA field office retained the contractor’s  direct billing privileges—a status conveyed to a contractor based on  the strength of its billing system controls whereby invoices are  submitted directly to the government paying office without prior  review. After we brought this to the attention of DCAA western region  officials, the field office rescinded the contractor’s direct billing status.
section_title: DCAA-wide Audit Identified Widespread Audit Quality Problems Requiring Significant Reform
paragraphs: Our follow-up audit found that a management environment and agency  culture that focused on facilitating the award of contracts and an  ineffective audit quality assurance structure are at the root of the DCAA- wide audit failures that we identified for the 69 audits and cost related  assignments that we reviewed. DCAA’s focus on a production-oriented  mission led DCAA management to establish policies, procedures, and  training that emphasized performing a large quantity of audits to support  contracting decisions and gave inadequate attention to performing quality  audits. An ineffective quality assurance structure, whereby DCAA gave  passing scores to deficient audits compounded this problem. Although the  reports for all 37 audits of contractor internal controls that we reviewed  stated that the audits were performed in accordance with GAGAS, we  found GAGAS compliance issues with all of these audits. The issues or  themes are consistent with those identified in our prior investigation.
Lack of independence. In seven audits, independence was compromised  because auditors provided material nonaudit services to a contractor they  later audited; experienced access to records problems that were not fully  resolved; and significantly delayed report issuance, which allowed the  contractors to resolve cited deficiencies so that they were not included in  the audit reports. GAGAS state that auditors should be free from  influences that restrict access to records or that improperly modify audit  scope.
Insufficient testing. Thirty-three of 37 internal control audits did not  include sufficient testing of internal controls to support auditor  conclusions and opinions. GAGAS for examination-level attestation  engagements require that sufficient evidence be obtained to provide a  reasonable basis for the conclusion that is expressed in the report. For  internal control audits, which are relied on for 2 to 4 years and sometimes  longer, the auditors would be expected to test a representative selection of  transactions across the year and not transactions for just 1 day, 1 month,  or a couple of months. However, we found that for many controls, the  procedures performed consisted of documenting the auditors’  understanding of controls, and the auditors did not test the effectiveness  of the implementation and operation of controls at all.
Unsupported opinions. The lack of sufficient support for the audit  opinions on 33 of the 37 internal control audits we reviewed rendered  them unreliable for decision making on contract awards, direct-billing  privileges, the reliability of cost estimates, and reported direct cost and  indirect cost rates.
Similarly, the 32 cost-related assignments we reviewed did not contain  sufficient testing to provide reasonable assurance that overpayments and  billing errors that might have occurred were identified. As a result, there is  limited assurance that any such errors, if they occurred, were corrected  and that related improper contract payments, if any, were refunded or  credited to the government. Contractors are responsible for ensuring that  their billings reflect fair and reasonable prices and contain only allowable  costs, and taxpayers expect DCAA to review these billings to provide  reasonable assurance that the government is not paying more than it  should for goods and services. Based on our findings that sufficient  voucher testing was not performed to support decisions to approve  contractors for direct-billing privileges, DCAA recently removed over 200  contractors from the direct-bill program.
Production environment and audit quality issues. DCAA’s mission  statement, strategic plan, and metrics all focused on producing a large  number of audit reports and provided little focus on assuring quality audits  that protect taxpayer interest. For example, DCAA’s current approach of  performing 30,000 or more audits annually and issuing over 22,000 audit  reports with 3,600 auditors substantially contributed to the widespread  audit quality problems we identified. Within this environment, DCAA’s  audit quality assurance program was not properly implemented, resulting  in an ineffective quality control process that accepted audits with  significant deficiencies and noncompliance with GAGAS and DCAA policy.  Moreover, even when DCAA’s quality assurance documentation showed  evidence of serious deficiencies within individual offices, those offices  were given satisfactory ratings. Considering the large number of DCAA  audit reports issued annually and the reliance the contracting and finance  communities have placed on DCAA audit conclusions and opinions, an  effective quality assurance program is key to protecting the public   interest. Such a program would report review findings along with  recommendations for any needed corrective actions; provide training and  additional policy guidance, as appropriate; and perform follow-up reviews  to assure that corrective actions are taken. GAGAS require that each audit  organization performing audits and attestation engagements in accordance  with GAGAS should have a system of quality control that is designed to  provide the audit organization with reasonable assurance that the  organization and its personnel comply with professional standards and  applicable legal and regulatory requirements, and have an external peer  review at least once every 3 years. On September 1, 2009, the DCAA  Director advised us that DCAA needs up to 2 years to revise its current  audit approach and establish an adequate audit quality control system  before undergoing another peer review.
section_title: Contract Management Issues That Require Greater Oversight
paragraphs: For fiscal year 2008, DOD reported that it obligated over $380 billion for  payments to federal contractors, more than double the amount it obligated  for fiscal year 2002. With hundreds of billions in taxpayer dollars at stake,  the government needs strong controls to provide reasonable assurance  that these contract funds are not being lost to fraud, waste, abuse, and  mismanagement. Moreover, effective contract audit capacity is  particularly important as DOD continues its use of high-risk contracting  strategies. For example, we have found numerous issues with DOD’s use  of time-and-materials contracts, which are used to purchase billions of  dollars of services across the government. Under these types of contracts,  payments to contractors are based on the number of labor hours billed at a  fixed hourly rate—which includes wages, overhead, and profit—and the  cost of any materials. These contracts are considered high risk for the  government because the contractor’s profit is tied to the number of hours  worked. Because the government bears the responsibility for managing  contract costs, it is essential that the government be assured, using DCAA  as needed, that the contractor has a good system in place to keep an  accurate accounting of the number of hours billed and materials acquired  and used.
In addition, we have said that DOD needs to improve its management and  oversight of undefinitized contract actions, under which DOD can  authorize contractors to begin work and incur costs before reaching a final  agreement on contract terms and conditions, including price. These  contracts are high risk because the contractor has little incentive to  control costs while the contract remains undefinitized. In one case, we  found that the lack of timely negotiations on a task order issued to restore  Iraq’s oil infrastructure increased the government’s risk when DOD paid  the contractor nearly all of the $221 million in costs questioned by DCAA.
More timely negotiations, including involvement by DCAA, could have  reduced the risk to the government of possible overpayment.
section_title: DCAA Actions and Additional GAO Recommendations
paragraphs: DCAA initiated a number of actions to address findings in our July 2008  report as well as findings from DOD follow-up efforts, including the DOD  Comptroller/Chief Financial Officer (CFO) August 2008 “tiger team”  review and the Defense Business Board study, which was officially  released in January 2009. Examples of recent DCAA and DOD actions  include the following.
Eliminating production metrics and implementing new metrics  intended to focus on achieving quality audits.
Establishing an anonymous Web site to address management and  hotline issues. In addition, DCAA’s Assistant Director for Operations  has been proactive in handling internal DCAA Web site hotline  complaints.
Revising policy guidance to address auditor independence, assure  management involvement in key decisions, and address audit quality  issues. DCAA also took action to halt auditor participation in nonaudit  services that posed independence concerns.
DCAA also has enlisted assistance from other agencies to develop a  human capital strategic plan, assist in cultural transformation, and  conduct a staffing study.
Further, in March 2009, the new DOD Comptroller/CFO established a  DCAA Oversight Committee to monitor and advise on DCAA corrective  actions.
While these are positive steps, much more needs to be done to address  fundamental weaknesses in DCAA’s mission, strategic plan, metrics, audit  approach, and human capital practices that have resulted in widespread  audit quality problems. DCAA’s production-oriented culture is deeply  imbedded and will likely take several years to change. DCAA’s mission  focused primarily on producing reports to support procurement and  contracting community decisions with no mention of quality audits that  serve taxpayer interest. Further, DCAA’s culture has focused on hiring at  the entry level and promoting from within the agency and most training  has been conducted by agency staff, which has led to an insular culture  where there are limited perspectives on how to make effective  organizational changes. To address these issues, our September 2009  report contained 15 recommendations to improve the quality of DCAA’s  audits and strengthen auditor effectiveness and independence.  Key GAO recommendations relate to the need for DCAA to develop a risk- based audit approach and develop a staffing plan in order to match audit  priorities to available resources. To develop an effective risk-based audit  approach, DCAA will need to work with key DOD stakeholders to  determine the appropriate mix of audit and nonaudit services it should  perform and determine what, if any, of these responsibilities should be  transferred or reassigned to another DOD agency or terminated in order  for DCAA to comply with GAGAS requirements. We also made  recommendations for DCAA to establish in-house expertise or obtain  outside expertise on auditing standards to (1) assist in revising contract  audit policy, (2) provide guidance on sampling and testing, and (3) develop  training on professional auditing standards. In addition, we recommended  that DOD conduct an independent review of DCAA’s revised audit quality  assurance program and follow-up to assure that appropriate corrective  actions are taken.
Mr. Chairman and Members of the Panel, this concludes my statement. We  would be pleased to answer any questions that you may have at this time.
section_title: Contacts and Acknowledgments
paragraphs: For further information about this testimony, please contact Gregory D.  Kutz at (202) 512-6722 or kutzg@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this testimony. Major contributors to our testimony include William T.  Woods, Director, Acquisition and Sourcing Management; F. Abe Dymond,  Assistant General Counsel; Gayle L. Fischer, Assistant Director; Financial  Management and Assurance; Richard Cambosos; Jeremiah Cockrum;  Shawnda Lindsey; Andrew McIntosh; Lerone Reid, and Angela Thomas.
section_title: Related GAO Reports
subsections: section_title: High-Risk Series
paragraphs: DOD’s High-Risk Areas: Actions Needed to Reduce Vulnerabilities and  Improve Business Outcome, GAO-09-460T, Washington, D.C.: March 12,  2009.
High-Risk Series: An Update, GAO-09-271, Washington, D.C.: January 2009.
section_title: DCAA Audits
paragraphs: DCAA Audits: Widespread Problems with Audit Quality Require Significant  Reform, GAO-09-468, Washington, D.C.: Sept. 23, 2009.
DCAA Audits: Widespread Problems with Audit Quality Require Significant  Reform, GAO-09-1009T, Washington, D.C.: Sept. 23, 2009.
DCAA Audits: Allegations That Certain Audits at Three Locations Did Not  Meet Professional Standards Were Substantiated, GAO-08-993T,  Washington, D.C.: Sept. 10, 2008.
DCAA Audits: Allegations That Certain Audits at Three Locations Did Not  Meet Professional Standards Were Substantiated, GAO-08-857,  Washington, D.C.: July 22, 2008.
section_title: Contract Management
paragraphs: Contract Management: Minimal Compliance with New Safeguards for  Time-and-Materials Contracts for Commercial Services and Safeguards  Have Not Been Applied to GSA Schedules Program, GAO-09-579,  Washington, D.C.: June 24, 2009.
Defense Acquisitions: Charting a Course for Lasting Reform, GAO-09-663T,  Washington, D.C.: April 30, 2009.
Defense Management: Actions Needed to Overcome Long-standing  Challenges with Weapon Systems Acquisition and Service Contract  Management, GAO-09-362T, Washington, D.C.: Feb. 11, 2009.
Defense Acquisitions: Perspectives on Potential Changes to Department of  Defense Acquisition Management Framework, GAO-09-295R, Washington,  D.C.: February 27, 2009.
Space Acquisitions: Uncertainties in the Evolved Expendable Launch  Vehicle Program Pose Management and Oversight Challenges,  GAO-08-1039, Washington, D.C.: September 26, 2008.
Defense Contracting: Post-Government Employment of Former DOD  Officials Needs Greater Transparency, GAO-08-485, Washington, D.C.: May  21, 2008.
Defense Contracting: Army Case Study Delineates Concerns with Use of  Contractors as Contract Specialists, GAO-08-360, Washington, D.C.: March  26, 2008.
Defense Contracting: Additional Personal Conflict of Interest Safeguards  Needed for Certain DOD Contractor Employees, GAO-08-169, Washington,  D.C.: March 7, 2008.
Defense Contract Management: DOD’s Lack of Adherence to Key  Contracting Principles on Iraq Oil Contract Put Government Interests at  Risk, GAO-07-839, Washington, D.C.: July 31, 2007.
Defense Contracting: Improved Insight and Controls Needed over DOD’s  Time-and-Materials Contracts, GAO-07-273, Washington, D.C.: June 29,  2007.
Defense Contracting: Use of Undefinitized Contract Actions Understated  and Definitization Time Frames Often Not Met, GAO-07-559, Washington,  D.C.: June 19, 2007.
Defense Acquisitions: Improved Management and Oversight Needed to  Better Control DOD’s Acquisition of Services, GAO-07-832T, Washington,  D.C.: May 10, 2007.
Defense Acquisitions: Tailored Approach Needed to Improve Service  Acquisition Outcomes, GAO-07-20, Washington, D.C.: November 9, 2006.
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