Rebuilding Iraq: Actions Needed To Improve Use of Private Security Providers
Published: 2005-07-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The United States is spending billions of dollars to reconstruct Iraq while combating an insurgency that has targeted military and contractor personnel and the Iraqi people. This environment created a need for those rebuilding Iraq to obtain security services. GAO evaluated the extent to which (1) U.S. agencies and contractors acquired security services from private providers, (2) the U.S. military and private security providers developed a working relationship, and (3) U.S. agencies assessed the costs of using private security providers on reconstruction contracts.
section_title: What GAO Found
paragraphs: The civilian U.S. government agencies and reconstruction contractors in Iraq that GAO evaluated have obtained security services, such as personal and convoy security, from private security providers because providing security to them is not the U.S. military's stated mission. U.S. military forces provide security for those Department of Defense (DOD) civilians and contractors who directly support the combat mission. In Iraq, the Department of State and other federal agencies contract with several private security providers to protect their employees. Under their contracts, contractors rebuilding Iraq are responsible for providing their own security and have done so by awarding subcontracts to private security providers. As of December 2004, the agencies and contractors we reviewed had obligated more than $766 million for private security providers. The contractors' efforts to obtain suitable security providers met with mixed results, as they often found that their security provider could not meet their needs. Overall, GAO found that contractors replaced their initial security providers on more than half the 2003 contracts it reviewed. Contractor officials attributed this turnover to various factors, including the absence of useful agency guidance. While the U.S. military and private security providers have developed a cooperative working relationship, actions should be taken to improve its effectiveness. The relationship between the military and private security providers is one of coordination, not control. Prior to October 2004 coordination was informal, based on personal contacts, and was inconsistent. In October 2004 a Reconstruction Operations Center was opened to share intelligence and coordinate military-contractor interactions. While military and security providers agreed that coordination has improved, two problems remain. First, private security providers continue to report incidents between themselves and the military when approaching military convoys and checkpoints. Second, military units deploying to Iraq are not fully aware of the parties operating on the complex battle space in Iraq and what responsibility they have to those parties. Despite the significant role played by private security providers in enabling reconstruction efforts, neither the Department of State, nor DOD nor the U.S. Agency for International Development (USAID) have complete data on the costs of using private security providers. Even at the contract level, the agencies generally had only limited information readily available, even though agency and contractor officials acknowledged that these costs had diverted a considerable amount of reconstruction resources and led to canceling or reducing the scope of some projects. For example, in March 2005, two task orders for reconstruction worth nearly $15 million were cancelled to help pay for security at a power plant. GAO found that the cost to obtain private security providers and security-related equipment accounted for more than 15 percent of contract costs on 8 of the 15 reconstruction contracts it reviewed.

section_title: Letter
paragraphs: The United States is spending billions of dollars to reconstruct Iraq while at  the same time is engaged in combating an insurgency that has targeted  military personnel, contractors, and the Iraqi people.  According to the  Department of Defense (DOD) and other sources, as of June 1, 2005, more  than 1,600 U.S. and coalition military forces and 200 contractor personnel  have been killed since major combat operations ended in May 2003.  This  uncertain security environment created a need for U.S. government  agencies and contractors involved in rebuilding Iraq to obtain substantially  more security services than is normally the case when operating in other  countries.  Creating a democratic Iraq and rebuilding its infrastructure is a  U.S. national security and foreign policy priority, and, even without the  need for enhanced security, is a challenging and complex effort.
Prior to the conflict, DOD and the U.S. government agencies responsible  for the reconstruction of Iraq believed that reconstruction would take place  in an environment with little threat from insurgents or terrorists.  By June  2003 the security situation in Iraq began to worsen and it became clear in  August 2003, with the bombing of the United Nations complex, that  insurgents were targeting nonmilitary targets.  The killings of four U.S.  citizens working for a U.S. security provider in Iraq in March 2004 and the  allegations of prisoner abuse at Abu Ghraib prison resulted in significant  congressional concern over the use of private security providers in Iraq  and raised a number of operational, legal, and contracting questions.
Because of the broad level of interest by Congress in issues dealing with  Iraq, the Comptroller General initiated this review under his statutory  authority.  Specifically, we evaluated the extent to which (1) U.S.  government agencies and contractors working in Iraq have acquired  security services from private providers; (2) the U.S. military and private  security providers in Iraq have developed a cooperative working  relationship; and (3) U.S. government agencies assessed the costs  associated with using private security providers on reconstruction  contracts.  Additionally, we assessed the impact of the increased use of  private security providers on attrition in key military skills.
To identify the rules and regulations governing and assigning responsibility  for protecting government and contractor personnel working in Iraq, we  reviewed policies, regulations, instructions, guidance, and orders issued by  DOD, the U.S. Central Command (CENTCOM), and other DOD  components relating to the use of contractors during wartime; orders and  policies issued by the Coalition Provisional Authority (CPA) regarding  contractor operations in Iraq; and Department of State policies regarding  the protection of U.S. government employees working abroad, including  the Foreign Affairs Manual.  We also interviewed military officials who had  been stationed in Iraq as well as selected private security providers to  understand their responsibilities and collaborative working relationship in  Iraq.  To understand the process by which contractors obtained private  security providers, we selected 16 reconstruction contracts using a non- probabilistic methodology that considered such factors as the awarding  agency; the year awarded; the contract’s expected dollar value; and the  type, nature and location of the reconstruction activity.  These 16 contracts  were awarded by various DOD components, including the U.S. Army Corps  of Engineers; the Department of State; and the U.S. Agency for  International Development (USAID).  Nine of these contracts were  awarded in 2003 and 7 were awarded in 2004.  As of December 2004, the  agencies had obligated about $8.6 billion on these contracts. We also  obtained and reviewed six contracts that had been awarded the U.S. Army  Corps of Engineers, the Department of State, USAID, and by Army  activities on behalf of the CPA for the protection of their personnel and  facilities in Iraq.  We then compared the type of security-related  requirements incorporated within U.S. government contracts with those  incorporated into contracts awarded to prime reconstruction contractors  and, in turn, to subcontracts with security providers.  We interviewed  agency and contractor officials, reviewed agency guidance provided to the  contractors, reviewed the reconstruction contracts and security  subcontracts, and analyzed the vouchers and other billing information  submitted by the reconstruction contractors and security providers.  To  assess the impact on military attrition caused by the use of private security  providers we obtained and analyzed DOD attrition data and spoke with  private security providers and representatives of the U.S. Special  Operations Command and the military services. We determined that the  information and data discussed in this report were sufficiently reliable for  the purposes of the report.  Appendix I contains more detail on our scope  and methodology.  We conducted our review from May 2004 to June 2005 in  accordance with generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: The United States, along with its coalition partners and various  international organizations and donors, has continued to support efforts to  rebuild Iraq in the aftermath of the war that replaced Iraq’s previous  regime.  From April 2003 to June 28, 2004, the CPA served as Iraq’s interim  government and was responsible for overseeing, directing, coordinating,  and approving rebuilding efforts.  With the establishment of Iraq’s interim  government, the CPA ceased to exist and its responsibilities were  transferred to the Iraqi government or to other U.S. agencies.  The  Department of State is now responsible for overseeing U.S. efforts to  rebuild Iraq.  DOD’s Project and Contracting Office (PCO) and the U.S.  Army Corps of Engineers have played a significant role in awarding and  managing reconstruction contracts.  USAID has been responsible for  various reconstruction and developmental assistance efforts, including  those related to capital construction projects, local governance, economic  development, education, and public health.
As figure 1 demonstrates, the battle space in Iraq can best be described as  complex.  A complex battle space is one where military forces, civilian U.S.  government agencies, international organizations, contractors,  nongovernmental organizations, and the local population share the same  geographical area.
Included on the complex battle space are private security providers.  While  there is no mechanism in place to track the number of private security  providers doing business in Iraq or the number of people working as  private security employees, DOD estimates that there are at least 60 private  security providers working in Iraq with perhaps as many as 25,000  employees.  The providers may be U.S. or foreign companies and their  staffs are likely to be drawn from various countries, including the United  States, the United Kingdom, South Africa, Nepal, Sri Lanka, or Fiji, and may  include Kurds and Arabs from Iraq.  Generally, private security providers  provide the following services:  Static security – security for housing areas and work sites.
Personal security details – security for high-ranking U.S. officials.
Security escorts – security for government employees, contractor  employees, or others as they move through Iraq.
Convoy security – security for vehicles and their occupants as they  make their way into Iraq or within Iraq.
Security advice and planning.
The CPA issued a number of orders or memoranda to regulate private  security providers and their employees working in Iraq.  Among these are  CPA Order number 3, (Revised)(Amended) which described the types of  weapons that can be used by private security providers; CPA Order number  17 (Revised), which stated that contractors (including private security  providers) will generally be immune from the Iraqi legal process for acts  performed in accordance with the terms and conditions of their contracts;  and CPA memorandum number 17, which stated that private security  providers and their employees must be registered and licensed by the  government of Iraq.
According to security industry representatives we contacted, there are no  established U.S. or international standards that identify security provider  qualifications in such areas as training and experience requirements,  weapons qualifications, and similar skills that are applicable for the type of  security needed in Iraq.  Some security industry associations and  companies have discussed the need for and desirability of establishing  standards, but as of March 2005 such efforts are only in the preliminary  stages of development.
section_title: Security for Civilians and Contractors in Iraq Is Provided by a Mix of Military Forces, State Department Security Personnel, and Private Security Providers
paragraphs: U.S. civilian government agencies and reconstruction contractors have had  to contract with private security providers because it is not part of the U.S.  military’s stated mission to provide security to these organizations.  U.S.  forces in Iraq provide security to contractors and DOD civilians who  support military operations.  The Ambassador is charged with generally  ensuring the security of most executive branch employees in Iraq.   Government agencies have contracted with a number of private security  providers to provide personnel, escort, and site security.  Reconstruction  contractors are generally responsible for providing for their own security  according to the terms of their contracts, and they have generally done so  by contracting with private security providers.  The contractors’ efforts to  obtain suitable security providers have met with mixed results. More than  half of the contractors awarded contracts in 2003 replaced their security  providers. Contractor officials attributed this turnover to various factors,  including the contractors’ need to acquire security services quickly, their  lack of knowledge of the security market and potential security providers  available to provide the type of security services required in Iraq, and the  absence of useful agency guidance.  Finally, while the U.S. military is not  responsible for providing security for civilian agencies and reconstruction  contractors, it does provide some services, such as emergency medical  support, to U.S. government-funded contractors.
subsections: section_title: The U.S. Military Provides Security for Civilians and Contractors Who Deploy with the Force
paragraphs: The stated mission of U.S. military forces in Iraq is to establish and  maintain a secure environment, allow the continuance of relief and  reconstruction efforts, and improve the training and capabilities of the Iraq  Security Forces.  As part of this mission, U.S. forces in Iraq provide security  for DOD civilians who deploy with the force, non-DOD U.S. government  employees who are embedded with the combat forces and contractors who  deploy with the combat force.  Among the contractors who deploy with the  force are those that provide maintenance for weapon systems, those who  provide linguistic and intelligence support to combat forces, and those who  provide logistics support.  Contractors who deploy with the force generally  live with and directly support U.S. military forces and receive government- furnished support similar to that provided to DOD civilians.
According to CENTCOM officials, the military uses soldiers rather than  private security providers to provide security to contractors, civilians,  facilities, or convoys which support combat operations because of  concerns regarding the status of security personnel under the law of  international armed conflict.  This body of law considers contractors who  deploy with the force generally to be noncombatant civilians  accompanying the force who may not take a direct part in hostilities.   CENTCOM is concerned that using armed private security employees to  protect clearly military activities would risk a change in status for these  contractors from noncombatants to illegal combatants.  Thus, the private  security employees could lose the protections otherwise granted  contractors accompanying the force under international law.
At the time we published our report, DOD was in the process of  establishing its first departmentwide policy on the military’s security  responsibilities for contractor personnel. The draft directive and  instruction specify that the military shall develop a security plan for  protection of contractor personnel and the contracting officer shall include  in the contract the level of protection to be provided to contractor  personnel.  In appropriate cases, the combatant commander shall provide  security through military means, commensurate with security provided  DOD civilians.  In May 2005, DOD also issued a new standard contract  clause in the Defense Federal Acquisition Regulation Supplement  (DFARS), to be included in all DOD contracts involving support to  deployed forces stating that the Combatant Commander (for example, the  CENTCOM Commander) will develop a security plan to provide protection,  through military means, of contractor personnel engaged in the theater of  operations unless the terms of the contract place the responsibility with  another party.  Prior to the issuance of the new contract clause, the Army’s  policy expressly required Army commanders to provide security for  deployed contractors, while the Air Force’s policy gave the Air Force the  option of whether or not to provide force protection to Air Force  contractors.  It is important to note, however, that the proposed DOD  departmentwide policy, procedures and standard contract clause do not  cover non-DOD government contractors who may be in a military theater  of operations.  As discussed in the following, these contractors are  responsible for providing their own security.
section_title: Civilian U.S. Government Agencies Provide for Their Own Security in Iraq
paragraphs: The State Department is responsible for the security of most of the  executive-branch U.S. Government employees located in Iraq.  According  to the President’s Letter of Instruction, the U.S. Ambassador, as Chief of  Mission, is tasked by the President with full responsibility for the safety of  all United States government personnel on official duty abroad except  those under the security protection of a combatant commander or on the  staff of an international organization.  The embassy’s Regional Security  Officer is the Chief of Mission’s focal point for security issues and as such  establishes specific security policies and procedures for all executive  branch personnel who fall under the Chief of Mission’s security  responsibility.
In June 2004, representatives from the Department of State and DOD  signed two memoranda of agreement to clarify each department’s security  responsibilities in Iraq.  Among other things the agreements specify that  In general, the Chief of Mission is responsible for the physical security,  equipment, and personnel protective services for U.S. Mission Iraq;   The Commander, CENTCOM is responsible for providing for the  security of the International Zone as well as regional embassy branch  offices throughout Iraq;  Military capabilities may be requested by the Chief of Mission to provide  physical security, equipment, and personal protective services only  when security requirements exceed available Marine Security Guard  Detachment, Department of State Diplomatic Security Service, and  Department of State contracted security support capabilities;  U.S. forces will provide force protection and Quick Reaction Force  support outside the International Zone, to the extent possible, for  Embassy personnel and activities; and  The Ambassador has security responsibility for DOD personnel under  the authority of the Chief of Mission. This includes the Marine Security  Detachment and personnel working for the PCO.
In Iraq, the State Department, USAID, the U.S. Army Corps of Engineers,  and the CPA contracted with commercial firms to provide security.  Our  review of six agency-awarded security contracts, awarded between August  2003 and May 2004, showed that as of December 31, 2004, the agencies had  obligated nearly $456 million on these contracts.  In turn, the private  security providers had billed the agencies about $315 million by that date  for providing various services, including personal security details; security  guards; communications; and security management.  The companies  providing security for U.S. government agencies may be U.S. or foreign.   For example, while USAID contracted with a U.S. firm, the U.S. Army  Corps of Engineers and the PCO are using British companies to meet their  security requirements.  Security for the Ambassador is provided by a U.S.  company, and only U.S. citizens are used to provide protection.
Security providers who provide security for executive branch employees  follow the procedures and policies established by the Regional Security  Officer.  For example, one security provider told us that the Regional  Security Officer recently increased the number of cars required for moving  people within Iraq.  The provider’s representative told us that they were  obligated to comply with the Regional Security Officer’s instructions even  though the contract was not awarded by the State Department and the  company does not provide security for State Department personnel.
section_title: Contractors Rebuilding Iraq Obtained Their Own Security with Little Assistance from the Agencies
paragraphs: Contractors engaged in reconstruction efforts were generally required to  provide for their own security, and they have done so by awarding  subcontracts to private security providers.  Contractors did not anticipate  the level of violence eventually encountered in Iraq and found themselves  needing to quickly obtain security for their personnel, lodgings, and work  sites.  As of December 31, 2004, our review of 15 reconstruction contracts  for which we had data found that the contractors had obligated more than  $310 million on security subcontracts, and in turn, the security providers  had billed the contractors more than $287 million.  The contractors’ efforts  to obtain suitable security providers met with mixed results, as many  subsequently found that their security provider could not meet their needs.   Overall, we found that contractors replaced their security providers on five  of the eight reconstruction contracts awarded in 2003 that we reviewed.   This was attributable, in part, to the contractors’ need to acquire security  services quickly, their lack of knowledge of the security market and  potential security providers available for the type of security services  required for Iraq, and the absence of useful agency guidance.  Information  reflected in the agencies’ own contracts for security, such as training and  weapons qualifications requirements, could have assisted the contractors  in identifying potential criteria for evaluating security providers and in  structuring their subcontracts.
Agency officials expected that the post-conflict environment in Iraq would  be relatively benign and would allow for the almost immediate beginning of  reconstruction efforts. During a discussion with DOD we were told that  this expectation was based on determinations made at the most senior  levels of the executive branch and the contracting officials were bound to  reflect that expectation in their requests for proposals. Consequently, they  made few or no plans for any other condition. Reconstruction contractors  shared this perspective, relying upon the language in the agency requests  for proposals and the comments of agency representatives at pre-proposal  and other meetings.  Our discussions with contractor officials found that  they anticipated providing for only a minimal level of security under their  contracts, such as hiring guards to prevent theft and looting at residential  and work sites. In one case, the contractor expected that the military would  provide security for its personnel.
Our review of the agencies’ request for proposals and other documents  found that they were consistent with this expectation.  For example, our  review of five contracts awarded by late July 2003, including four awarded  by USAID and one awarded by the U.S. Army Corps of Engineers, found  that    USAID’s requests for proposals instructed the contractors that work  was to begin only when a permissive environment existed. Contractors  were given little guidance concerning security for their personnel and  facilities and were not asked to estimate security costs as part of their  proposals.
The U.S. Army Corps of Engineers’ request for proposal noted that the  military was expected to provide security for the contractor and, thus,  the contractor was not required to propose any security costs.
According to agency and contractor officials, the Iraqi security  environment began to deteriorate by June 2003, although two contractors  noted that the bombing of the United Nations compound in August 2003  made it apparent that the insurgency was beginning to target nonmilitary  targets (see figure 2).
Contractor officials told us that as the security environment worsened they  unexpectedly found themselves in immediate need of enhanced security  services.  These officials told us that they received little guidance from the  agencies relative to possible security providers.  We found that the  contractors’ efforts to obtain security providers often met with mixed  results.  For example:  One contractor, awarded a contract by the U.S. Army Corps of  Engineers, expected that the U.S. military would provide security for its  personnel.  That contractor expressed concern, however, that the  military protection being provided was insufficient to ensure its  employees’ safety and to allow for the performance of its mission and  subsequently stopped work at one of its locations.  In June 2003, the  Army finally told the contractor that it did not have adequate forces to  continue to provide security as promised, and advised the contractor to  acquire its own security. Following a limited competition, the  contractor awarded a subcontract to a security provider in June 2003.  In  this case, the contractor has been satisfied with the services provided  and retained the security provider when the contractor was  subsequently awarded another reconstruction contract in June 2004.
One USAID reconstruction contractor told us it quickly awarded a non- competitive subcontract to a security provider in July 2003.  Within  three months, the security company notified the reconstruction  contractor that it was pulling its employees out of the country.  As a  former prisoner-transport service firm trying to expand into the  protective services area, it discovered it lacked sufficient capacity to  fulfill its contract requirements in Iraq.  The reconstruction contractor  subsequently conducted a competition among security providers  already operating in Iraq to meet its needs.
Another reconstruction contractor initially hired a security service  provider in October 2003. A contractor official stated that it soon  became apparent that the security provider did not have the capacity to  meet its security needs.  As a result, the contractor awarded another  subcontract, on a sole-source basis, to a security provider to augment  the security services provided to its personnel.
Three of the reconstruction contractors we reviewed hired a newly  established security provider company that was marketing itself in Iraq  in mid- to late 2003. Officials representing one contractor told us that the  provider was the only known provider capable of meeting their needs;  officials for another contractor told us that they selected the provider  based, in part, on its reputation.  Each of the contractors, however, for  various reasons, replaced the security provider.  Subsequently, this  security provider has been suspended from receiving further  government contracts due to allegations of fraudulent billing practices.
Overall, we found that five of the eight reconstruction contractors that  were awarded contracts in 2003 that we reviewed replaced their initial or  second security provider with another company, while in other cases, the  contractors needed to augment the security services provided by their  initial provider.  As shown in figure 3, two contractors have awarded up to  four contracts for security services.
Contractor officials attributed this turnover to various factors, including  the urgent need to obtain security, the increasing threat level, their lack of  knowledge of potential sources and the security market, and the absence of  useful agency guidance.  In this latter regard, the detailed standards and  requirements in their own agency security contracts may have provided  useful assistance to reconstruction contractors in identifying potential  criteria for evaluating security providers and in structuring their  subcontracts.  For example, the USAID security services contract, awarded  in August 2003, contained  a detailed and required organization structure to be used by the  contractor, with titles, duties and responsibilities of various levels of  security providers specified;   requirements for background checks on potential employees and  provisions for agency approval and acceptance of those employees;   detailed standards of conduct for contractor employees;   language, health, and training requirements;   weapons capability requirements; and  instructions regarding providing armored vehicles.
Our review of five other agency security contracts awarded directly to  private security providers from December 2003 through May 2004 for the  protection of agency personnel in Iraq found that, to varying degrees, most  of the cited areas were addressed. Conversely, our review of the  subcontracts awarded by the reconstruction contractors to their security  providers generally contained far less information.
According to most contractor officials with whom we spoke, information  similar to that included in the agency’s contracts would have assisted them  in defining their security needs and structuring their security subcontracts.
Some contractor officials also noted that agency assistance with identifying  and vetting potential security provider companies would have been very  useful or would be useful in future similar situations. They discussed the  possibility of a qualified vendors list, or, if time permitted, the  establishment of a multiple award schedule of qualified security providers,  which contractors could use to quickly contract for their security needs  through competitive task orders.
Agency officials believed that information regarding personnel  qualifications and competent providers could be made available to  contractor personnel in future efforts, especially if the information was  provided for the contractor’s consideration, rather than being a contract  requirement. For example, one agency official noted that his agency’s  requests for proposals for security services are publicly available.  Some  officials believed that making information a contractual requirement would  infringe upon the contractor’s privity of contract with its subcontractors  and might pose a potential government liability should such requirements  later prove inadequate.  Other officials believed that it should be the  contractor’s responsibility to research and decide for itself its own needs  and sources of security services without assistance from the government.
section_title: DOD Provides Emergency Quick Reaction Forces and Other Services to Contractors in Iraq
paragraphs: According to U.S. officials and contractor personnel we interviewed, U.S.  military forces in Iraq will provide, when assets are available, emergency  quick reaction forces to assist contractors who are engaged in hostile fire  situations.  The military is also providing other support services to U.S.  government-funded contractors, to include private security providers.  For  example, U.S. military forces will assist with the recovery and return of  contractor personnel who have been kidnapped or held hostage.   Additionally, the U.S. military also provides medical services above the  primary care level to contractors.  These services include hospitalization,  as well as laboratory and pharmaceutical services, dental services, and  evacuation services, should the patient require them.  In addition, the  military is providing medical support to private citizens, third country  nationals, and foreign nationals when necessary to save life, limb, or eye- sight.  Finally, contractors are entitled to receive mortuary affairs services.   DOD is providing these services pursuant to authorities under Title 10,  United States Code, as well as a variety of DOD Directives, a June 2004  support agreement between DOD and the Department of State, National  Security Presidential Directive 36 (which governs the operations of the U.S.  government in Iraq) and specific contract provisions.
section_title: While the Relationship between Security Providers and the Military Has Improved, Actions Should Be Taken to Further Improve Effectiveness
paragraphs: The military and the private security providers in Iraq have an evolving  relationship based on cooperation and coordination of activities and the  desire to work from a common operating picture.  However, U.S. forces in  Iraq do not have a command and control relationship with private security  providers or their employees.  Initially, coordination between the military  and private security providers was informal.  However, since the advent of  the Reconstruction Operations Center in October 2004, coordination has  evolved into a structured and formalized process.  While contractors and  the military agree that coordination has improved, some problems remain.   First, private security providers continue to report incidents between  themselves and the military when approaching military convoys and  checkpoints.  Second, military units may not have a clear understanding of  the role of contractors, including private security providers, in Iraq or of  the implications of having private security providers in the battle space.
subsections: section_title: U.S. Forces Do Not Have Command and Control over Private Security Providers Working In Iraq
paragraphs: According to CENTCOM officials and military personnel who have been  stationed in Iraq, U.S. military forces in Iraq do not have a command and  control relationship with private security providers or their employees.   According to a DOD report on private security providers working in Iraq,  U.S. military forces in Iraq have no command and control over private  security providers because neither the combatant commander nor his  forces have a contractual relationship with the security providers.  Instead, military and security provider personnel who served in Iraq  described a relationship of informal coordination, where the military and  private security providers meet periodically to share information and  coordinate and resolve conflicts in operations.
Despite a lack of command and control over private security providers and  their employees, commanders always have authority over contractor  personnel, including private security provider personnel, when they enter a  U.S. military installation.  Commanders are considered to have inherent  authority to protect the health and safety, welfare, and discipline of their  troops and installation.  This authority allows the commander to establish  the rules and regulations in effect at each installation.  For example, an  installation commander may determine traffic regulations, weapons  policies, force protection procedures, and visitor escort policies.   Contractors, including private security providers, who fail to follow the  military’s rules and regulations while they are on the installation can be  prohibited from entering the installation and using its facilities.  As an  example, one Army official told us that his unit had barred some private  security employees from using the unit’s dining facilities because the  private security employees insisted on carrying loaded weapons into the  dining facility.  The unit did not allow loaded weapons in the dining facility  for safety reasons.
section_title: Coordination Between the Military and Private Security Providers in Iraq Has Evolved Since the Beginning of Reconstruction
paragraphs: Coordination between the military and the private security providers has  evolved from an informal coordination based on personal relationships to a  more structured, although voluntary, mechanism established by the Project  and Contracting Office (PCO).  According to military officials, contractors,  and security providers coordination between the military and security  providers was initially done informally.  When a private security provider  arrived in a unit’s area of operation, the security provider would try to meet  with key officials of the unit and establish a relationship. A private security  provider we spoke with told us that the results of this informal  coordination varied based on the individual personalities of the military  and provider personnel.  According to some security providers, although  many military commanders were very interested in establishing a  relationship with the security providers, others were not.  Additionally,  coordination was inconsistent.  For example, one officer who had served  with the 4th Infantry Division in Iraq told us that coordination in his area  was mixed.  According to the officer, some security providers, such as the  one providing security for the Iraqi currency exchange program, would  always coordinate with the division before moving through the division’s  area of operations but another contractor rarely coordinated with the  division.  This is similar to information we obtained from officials of the  2nd Armored Cavalry Regiment.  One officer from one of the regiment’s  squadrons told us that contractors that worked within the unit’s area of  operation generally coordinated with the regiment while those who were  traveling in or through his unit’s area of operation generally did not  coordinate with the regiment.  He also told us that on one occasion security  providers escorted the CPA administrator into their area of operation  without the squadron’s knowledge and while the squadron was conducting  an operation in Najaf.  According to the officer, a fire fight broke out at the  CPA administrator’s location and the squadron had to send troops to rescue  the CPA administrator and his party.  This had a significant impact on its  operation, according to the officer.  Another officer, who served on the  Combined Joint Task Force-7 staff, told of instances when contractors  died and the division commander did not know that the contractors were  operating in his area of operations until he was instructed to recover the  bodies.  Finally, according to a military officer serving with the PCO at the  time of our review, the genesis of the Reconstruction Operations Center  (ROC) (discussed next) was the need to improve coordination between  contractors and the major subordinate commanders.
The ROC serves as the interface between the military and the contractors  in Iraq and is located within the PCO.  In May 2004, the Army awarded a  contract to a private security provider to provide security for PCO  personnel and to operate the ROC, shown in figure 4.  The goal of the ROC,  which became operational in October 2004, is to provide situational  awareness, develop a common operating picture for contractors and the  military, and facilitate coordination between the military and contractors.
The national ROC is located in Baghdad and six regional centers are co- located with the military’s major subordinate commands, to enhance  coordination between the military and the private security providers.   Figure 5 shows the locations of the regional centers.
Participation in the ROC is voluntary (although some DOD officials told us  that participation should be mandatory) and is open (at no cost) to all U.S.  government agencies, contractors, and nongovernmental organizations  operating in Iraq.  The ROC and the regional centers are staffed with a  combination of military, U.S. government civilian, and contractor personnel  who provide a number of services for private security providers and others.   Among the services the ROC provides are:  Intelligence information.  The military provides unclassified intelligence  information to the ROC for dissemination to contractors.  Intelligence  information is updated daily and information is available on a password- protected Web site and through daily intelligence briefings.  In addition,  contractors can request specific threat assessments on future building  sites and planned vehicle routes.  Contractors use the ROC to pass on  information about incidents and threats to coalition forces as well.
Military assistance.  The ROC serves as the 911 for contractors who  need military assistance.  Contractors who need assistance contact  either the national ROC or the regional ROCs and ROC personnel  contact the closest military unit and ask it to provide assistance.   Assistance, such as a quick reaction force or medical assistance, is  provided if military assets are available.  Security providers we spoke  with said that they rarely call for a quick reaction force because  incidents with insurgents are usually over within a matter of minutes but  on some occasions the quick reaction forces have proved to be very  helpful.  For example, one after action report described an incident in  February 2005 in which a private security team was ambushed by 20  insurgents and attacked by small arms fire and three rocket-propelled  grenades.  The contractors contacted both the regional ROC in Mosul  and the national ROC in Baghdad.  The military responded with fixed  wing assets within 15 minutes and a rotary wing quick reaction force  escorted the team safely back to Mosul.  Contractors more frequently  receive medical assistance from the military and described the  assistance they received as excellent.  Figure 6 depicts the process used  to request assistance through the ROC or the regional ROCs.
Improved communications.  Communications with the military can be  difficult in Iraq because of a lack of radio interoperability between the  military and contractors.  The ROC facilitates communications between  the military and contractors.  First, the ROC provides contact numbers  for the military to private security providers to use when they are  moving around in Iraq.  Second, the ROC will ensure that the military is  aware of contractor movements.  Security providers who so choose can  provide the ROC with information on convoy movements, which the  ROC will forward to the appropriate military commands.  Third, the  ROC can contact the military to provide assistance to contractors, and  finally, the ROC can track convoys through a real-time tracking system  that uses the global positioning system and includes a communications  link with the ROC if assistance is needed.
section_title: Some Coordination Problems Remain between Private Security Providers and the U.S. Military
paragraphs: While security providers, reconstruction contractors, and military  representatives of the PCO believe that the ROC has improved  coordination on the complex battle space in Iraq, both the private security  providers and the military believe that several coordination issues remain  to be resolved.  Security providers and military officials expressed  continuing concern about incidents between security providers and the  military when approaching military convoys and checkpoints and the need  for a better understanding of the complex battle space by both private  security providers and the military.
subsections: section_title: Blue on White Incidents Are of Major Concern to the Military and Private Security Providers
paragraphs: One of the coordination issues that contractors and the military continued  to be concerned about is blue on white violence.  Blue on white violence is  the term used by contractors and the military to describe situations when  the military fires at friendly forces (such as contractors) or, as happens less  frequently, when private security employees fire at military forces.  An  analysis of incident reports completed by the ROC indicates that these  incidents happen most frequently when contractors encounter a military  checkpoint or a military convoy.  Private security providers have told us  that they are fired upon by U.S. forces so frequently that incident reports  are not always filed with the ROC.  According to some incident reports filed  with the ROC, some contractors believe that U.S. forces have fired on  private security provider vehicles without provocation.  For example, one  security company official reported that his convoy was traveling on a route  in Iraq when a U.S. military convoy approached.  According to the report,  the security convoy identified itself using generally recognized  identification procedures and pulled off the road to allow the military  convoy to pass.  After about half of the 20-vehicle convoy had passed, a  gunner in the military convoy began firing at the security convoy.   According to the after incident report filed with the ROC, no injuries or  damage resulted from this incident.  A similar incident happened on the  road from the International Zone to the Baghdad airport.  As in the previous  incident, part of a U.S. military convoy passed the private security convoy  without incident when a gunner in the fourth vehicle of the convoy began  to fire at the lead vehicle in the private security convoy.  After this incident,  the private security team leader received an apology from the  servicemember who had fired on the security company vehicle.  As a result  of this incident, the company’s vehicle was rendered unserviceable.
In another incident report, a private security provider documented an  incident at a U.S. military checkpoint.  According to the report, a security  convoy had slowed to approach the checkpoint, and was then fired on by a  U.S. soldier.  The report went on to say that no verbal or hand warnings  were given and no reason was given for the shooting.  According to  representatives of the security providers and the former director of  security for the PCO, many of these incidents happen because of the  military’s concerns over insurgents using vehicle-borne improvised  explosive devices, as well as the inexperience of some U.S. troops.
Reducing the number of blue on white incidents is a high priority for the  U.S. military, the PCO, private security providers, and the Private Security  Company Association of Iraq, a Baghdad--based association that works  with both the U.S. government and the Iraqi government to resolve issues  related to private security providers.  In late December 2004, in an effort to  reduce the number of blue on white incidents, the Multi National Corps- Iraq (MNC-I) issued an order to major subordinate commands in Iraq  establishing procedures for private security providers to use when  approaching military convoys and military checkpoints.  MNC-I directed  the subordinate commanders to implement the procedures detailed in the  order and to educate all private security providers and military on the  procedures.  Among the procedures were (1) a prohibition on nontactical  vehicles (such as the vehicles used by private security providers) passing  moving military convoys; (2) a requirement that warning shots, when fired,  be aimed away from a vehicle and demonstrate a clear intention to do harm  if directions are not obeyed; and (3) a requirement that vehicles should  maintain a distance of a least 200 meters from a military convoy.
In early 2005, MNC-I completed an analysis of friendly-fire incidents that  occurred between November 1, 2004 and January 25, 2005 to determine the  top 10 lessons learned from such incidents.  Among the top 10 lessons was  the need for U.S. forces to comply with the rules of engagement, which  require that U.S. troops determine that a person’s intent is hostile before  the military uses deadly force.  The other lessons learned were similar to  the procedures included in the order.  According to a PCO official, the top  10 list was provided to the private security providers.
Despite the MNC-I order, blue on white incidents continue to occur and  security providers remain concerned about the frequency of the attacks. In  the 5 months (January to May 2005) since the order was issued, the ROC  has received reports on 20 blue on white incidents and the number of  actual incidents is likely to be higher since, as we noted previously, some  providers no longer report these types of incidents.  Data on the number of  incidents for the 5 months before the order was issued was not available  because the ROC did not start collecting information on blue on white  incidents until November 2004.  A ROC official noted that blue on white  incidents had decreased in April 2005.  He believed that the reduction was  due, in part, to the adoption of the procedures outlined in the order.   However, he also noted that the number of incidents could increase again  as troops rotate in and out of Iraq or if terrorist attacks increase.
section_title: Units Do Not Receive Specific Training or Guidance about Working with Private Security Providers before Deploying
paragraphs: Military units that deployed to Iraq received no guidance or training  regarding the relationship between private security providers and the  military prior to deploying.  Representatives from the 2nd Armored Cavalry  Regiment, the 82nd Airborne Division, and the 1st Marine Expeditionary  Force all told us that they received no guidance from either CENTCOM or  Combined Joint Task Force-7 and that their units had not developed any  written procedures for dealing with private security providers.   Furthermore, a representative of a unit that is preparing to deploy, the 101st  Airborne Division, told us that it had not received any guidance on how to  work with private security providers nor had it been directed to include  information on private security providers, the PCO, or the ROC in its pre- deployment training, even though the 101st will be co-located with a  regional ROC.  To highlight the lack of training and guidance,  representatives from one unit told us that they did not know there were  private security providers in their battle space until the providers began  calling for assistance.  They also noted that any information about who  would be in the battle space and the support the military should be  providing would be useful.
Several private security providers we spoke with told us that they believed  it would be helpful if U.S. forces who deployed to Iraq received information  on private security providers in Iraq.  For example, the providers believed  that U.S. troops needed more information on why private security  providers are in Iraq, the impact of having private security providers there,  and the operational styles of the private security providers.  Army officials  we spoke with believed that this type of information would be helpful and  suggested that private security providers could use additional information  about working with the U.S. military as well.
section_title: Agencies Have Limited Capabilities to Assess the Cost Impact of Using Private Security Providers
paragraphs: Despite the significant role played by private security providers in enabling  reconstruction efforts to proceed, neither the Department of State, DOD,  nor USAID has complete data on the cost associated with using private  security providers.  For example, the quarterly report submitted by the  Department of State to Congress on the status of reconstruction projects  and funding does not provide information on security costs that are  incurred under reconstruction contracts.  Even at the contract level, the  agencies generally had varying degrees of information on the costs  associated with private security providers.  On 15 reconstruction contracts  we found that the cost to obtain private security providers and security- related equipment at the reconstruction contract level can be considerable,  as it accounted for 15 percent or more on 8 of the 15 contracts we  reviewed; on only 4 of those 8 contracts, however, did the agencies  formally track security costs under a separate task order or contract line  item.  Agency and contractor officials acknowledged that security costs  had diverted planned reconstruction resources and led to canceling or  reducing the scope of certain reconstruction projects, though they also  noted that other factors have affected reconstruction projects.
subsections: section_title: Agencies Do Not Comprehensively Track Costs Associated with Private Security Providers
paragraphs: The Secretary of State is responsible for submitting a quarterly report to  Congress that outlines the current status of programs, initiatives, and funds  dedicated to the Iraq reconstruction efforts.  These quarterly reports  provide information at the project and sector level—such as oil or  electricity—and acknowledge the challenges and costs associated with the  security environment in Iraq.  For example, in its April 2005 report, the  State Department noted that nearly $1.3 billion in funding has been, or will  be, used  in part to (1) cover unanticipated post-battle reconstruction costs,  (2) cover indirect cost increases of contractors operating on cost-plus  contracts that allow them to continue billing even during delays, and  (3) account for increased security costs.  The reports, however, do not  identify the magnitude or impact of the costs associated with security  providers on reconstruction efforts or available funding.  Discussions with  DOD and USAID personnel found that the financial and management  information systems used to help prepare the report are not able to track  costs incurred by reconstruction contractors for security services.  Agency  officials noted that to obtain such information would currently require the  agencies to request such information from the contractors and manually  prepare the information.  Agency officials noted they have made inquiries  on an ad hoc basis in the past, but cautioned that such requests can be  burdensome for both the contractors and agency officials.
Contractor officials acknowledge that the cost of private security services  and security-related equipment, such as armored vehicles, has exceeded  what they originally envisioned.  In some cases, increased security costs  resulted in reducing or canceling the scope of some reconstruction  projects.  For example:  Contractor officials noted they were originally tasked to rehabilitate 23  electrical substations and had conducted site surveys and procured  equipment for all 23 substations.  According to contractor officials,  however, the U.S. Army Corps of Engineers concluded that securing 14  of the substations would not be cost effective, and therefore reduced the  scope to 9 substations.  Contractor officials indicated that the  equipment and materials procured for the 14 substations have been or  will be turned over to the Iraqi Ministry of Electricity.
In February 2004, USAID obligated an additional $33 million on one of  its contracts to pay for unanticipated increases in security costs that left  it short of funds to pay for construction oversight and quality assurance,  as well as fund administrative costs.
In March 2005, USAID cancelled two electrical power generation-related  task orders totaling nearly $15 million to help pay for increased security  costs being incurred at another power generation project in southern  Baghdad.
Contractor officials noted, however, that other factors also affected  reconstruction progress, such as changes in priorities or higher material  costs.  For example, officials at one contractor noted that security had not  been a significant factor delaying their work; rather, they pointed to delays  in reviewing and approving projects and slower than anticipated release of  funding.  Similarly, USAID officials noted that, among other materials, the  cost of concrete is significantly higher than anticipated, driving up the cost  of many reconstruction projects.
We found that at the contract level, agency personnel did not have  consistent insight into security costs and their impact on reconstruction  efforts. For example, agencies often did not require prospective bidders to  propose meaningful security costs as part of their contract cost proposal  nor require contractors to prepare a baseline security cost estimate at the  time of contract award.  Many of the contracts, including those awarded  after the security environment began to deteriorate, were indefinite  delivery contracts, in which the work to be accomplished was often  described in general terms, with the specific work to be accomplished  determined as task orders are issued.  In several cases, agency personnel  provided prospective contractors a sample task order to use in preparing  their proposals.  While the contractors’ cost and technical proposals  described how they would approach security issues and provided an  associated cost estimate, such estimates were only for evaluation purposes  and did not reflect meaningful security costs. Overall, in only 3 of the 16  contracts we reviewed did contractors prepare an initial security cost  estimate for the entire contract.
Further, we found that in only 7 of the 16 contracts did the contractors  regularly provide security-related cost information in either monthly  progress reports or in separate contract line items or task orders.  The level  of information and insight provided varied greatly depending on the  approach taken.  For example, on three contracts, the contractor provided  security cost-related information for each of its projects, but did not  provide information at the total contract level.  In one contract, security  costs were reported on both the task order and contract level.  In one  contract, the security cost information was reported under a separate  contract line item with other expenses, and visibility was more limited.  In  the remaining two contracts, the agency established separate task orders  specifically to track security-related expenses at the contract level.
In 15 of the 16 reconstruction contracts that we reviewed, we were able to  obtain data on the costs of acquiring private security services and related  security equipment by reviewing invoices that private security providers  and security equipment providers submitted to contractors. Our analysis of  this data found that at the reconstruction contract level there was  considerable variation in estimated security costs as a percentage of total  contract billings (see figure 7).  Eight of the 15 contracts had security  costs that exceeded 15 percent of total contract billings as of December 31,  2004; on 4 contracts, the percentage of contract billings accounted for by  the cost of security subcontractors was more than 25 percent.  On only 2  of those 8 contracts in which security costs exceeded 15 percent did  agency personnel require the contractors to formally track and report  security costs under a separate task order or contract line item.  Though  not required, one contractor reported incurred security costs on two  contracts on its own initiative.
While our analysis indicates that at the reconstruction contract level the  cost of obtaining private security services can account for a significant  percentage of the contract’s total cost, it does not reflect total private  security costs.  For example, reconstruction contractors did not always  specifically track security-related costs incurred by their subcontractors or  lower tier suppliers.  According to contractor officials, in seven of the  sixteen reconstruction contracts that we reviewed, at least one of their  subcontractors provided for their own private security; in five of those  seven contracts, all of the subcontractors were required to provide for their  own security.  The cost for a subcontractor to obtain private security  services can be considerable.  For example, in one case, the costs incurred  by a major subcontractor amounted to almost $10 million, or nearly one- third of what the reconstruction contractor was paying for security. In  another case, the costs incurred by a major subcontractor exceeded $3.5  million, or about 8 percent of what the reconstruction contractor was  paying for security.
Our analysis and discussions with agency and contractor officials identified  several factors that influenced security costs, including (1) the nature and  location of the work; (2) the type of security required and the security  approach taken; and (3) the degree to which the military provided the  contractor security services. For example, projects that took place in a  fixed, static location were generally less expensive to secure than a project  that extended over a large geographic location, such as electrical  transmission lines. In other cases, contractors relied on former military  personnel or other highly-trained professionals to provide security to their  employees.  Conversely, some contractors made more extensive use of  local Iraqi labor and employed less costly Iraqi security guards. Lastly,  some contractors were able to make use of security provided by the U.S.  military or coalition forces. For example, several contractors had facilities  within or near U.S.-controlled locations, such as Baghdad’s International  Zone or on military bases, which reduced their need to obtain private  security services. In another case, the contractor was provided a limited  degree of protection by the U.S. Army.
Agency and contractor officials had mixed opinions on the value of  establishing separate reporting or tracking mechanisms.  For example,  some agency officials believed that having visibility into security-related  costs enabled them to provide more effective contract oversight, and  identify security cost trends and their impact on the project. Other officials  noted that many factors affect the cost and progress of reconstruction  efforts, including changes in planned funding or projects, material costs,  and the inability to find qualified workers willing to work in Iraq.   Consequently, they indicated that they generally try to manage the projects  at a total project level, rather than by individual elements, such as security.   For example, they noted that when reviewing project status reports with  the contractors, they will question the contractors on the factors causing  delays or cost increases.  They were not certain that having specific insight  into security costs would help them better manage or oversee their  projects.  Agency program and financial management officials noted that  from a budgeting perspective, tracking security cost information could  enable staff to provide better estimates of future funding requirements.
Contractor officials generally indicated that establishing a separate task  order or contract line item for security enabled them to more efficiently  account for and bill security costs and to more accurately report  reconstruction progress.  For example, officials at one contractor noted  that they often had several projects under way which required security.   Prior to establishing a separate task order, the security provider would be  required to allocate costs to each of the projects even though the security  was provided for a given location, often resulting in lengthy and complex  vouchers, higher potential for error, and increased administrative  expenses.  Once a separate task order was established, its security provider  charged the costs incurred for providing security to the location, rather  than each project, simplifying the billing and review process.  Other  contractor officials noted that the need to obtain security providers and  security-related equipment often occurred during the early stages of the  contract when the agencies had issued only a few task orders for specific  reconstruction projects.  Consequently, contractor officials told us they  found themselves incurring considerable security-related expenses during  the mobilization phase that had to be allocated to subsequent task orders,  thereby increasing costs. These officials noted that allocating security  costs to existing task orders would have resulted in the task’s cost  exceeding the government’s estimate. Contractor officials indicated that a  separate task order for security would have enabled them to better explain  to agency personnel the cost of the reconstruction effort and the impact of  security costs and enable them to account for and bill security costs more  efficiently.
section_title: Expanded Use of Private Security Providers Does Not Appear to Be Increasing Attrition among Military Personnel
paragraphs: Data from the Defense Manpower Data Center (DMDC) show that in  fiscal year 2004, the attrition rates for the occupational specialties  preferred by private security providers returned to the same or slightly  lower levels than those seen prior to the institution of occupational stop  losses in September 2001 despite the increased use of private security  providers.  Private security providers working in Iraq are hiring former  servicemembers with a variety of skills, including servicemembers with  military police or Special Operations experience.  Military officials told us  that they believe that servicemembers with these skills are separating from  the military earlier than in prior years.  We are unable to determine from  this data whether servicemembers are leaving the military for positions  with private security providers as the data can only demonstrate trends in  attrition, not explain why people are leaving the military or what they  intend to do after leaving the military.
Private security providers prefer to hire former military members,  particularly Special Operations forces, for their unique skills and  experience.  Servicemembers with Special Operations background are  often hired to fill key positions, such as security advisors and project  managers, and to provide personal security to high ranking government  officials.  These positions may pay as much as $33,000 a month.  Other  servicemembers may be hired to provide security to civilians in vehicle  convoys with salaries between $12,000 and $13,000 per month, while some  may be hired to provide site security for buildings and construction  projects at somewhat lower salaries.  For the most part, employees only  receive these salaries when they are working in Iraq, typically 2 to 3 months  at a time.  All of the U.S.-based private security providers we spoke with  told us that they do not actively recruit current servicemembers; however,  they do recruit at military-sponsored transition job fairs, through the  Internet, and with advertisements in military magazines and newspapers.
subsections: section_title: Officials from the Special Operations Command and Army Military Police Believe Attrition Is Increasing Due, in Part, to Security-Related Job Opportunities
paragraphs: Both Special Forces and military police personnel officials believe that  attrition is increasing in their military specialties.  For example, during a  July 2004 hearing before the House Armed Services Committee,  Subcommittee on Terrorism, Unconventional Threats and Capabilities,  representatives from the U.S. Special Operations Command and the  military services’ Special Operations commands noted that the number of  Special Forces enlisted personnel retiring at 20 years (the first time they  are eligible) has been increasing due, in part, to the increased opportunities  available in civilian government and with contractors.  In addition,  representatives of the Naval Special Operations Command and the Air  Force Special Operations Command also noted that they were seeing  increased attrition rates among those servicemembers with 8 to 12 years of  service.  According to these representatives, servicemembers leaving at  this point in their careers are also leaving for opportunities with  contractors.
Army officials have also expressed concerns about attrition in the military  police force.  For example, officials from the military police personnel  office at the Army’s Human Resources Command told us that they have  seen a significant number of senior noncommissioned officers leave the  military police for positions with private security providers.  These officials  also told us they have seen the average length of service for colonels in the  military police branch decrease from 28 to 25 years.  Furthermore, in an e- mail provided by the Army’s Human Resources Command, a senior  noncommissioned officer at the 16th Military Police Brigade noted that the  brigade did not meet its reenlistment targets in fiscal year 2004.  Finally, the  Army Central Command’s Provost Marshall in July 2004 told us that he had  lost four of his eight senior noncommissioned officers to higher paying  private security providers within the last year and was expecting to lose  two more senior noncommissioned officers.  He also noted that he had lost  more than half of his company grade officers as well.
Efforts are being taken by both the military police and Special Forces  communities to address retention concerns.  For example, the Army plans  to double the size of its military police force from 15,500 to 30,000 by 2006  and the Special Operations Command plans to increase its force size from  13,200 to 15,900 over the next 5 to 6 years.  Increasing the size of the Army  military police and Special Operations will decrease the high operational  tempo and relieve some of the stress on military personnel, which these  communities believe contributed to higher attrition.  In addition, DOD  recently began to offer reenlistment bonuses to Special Operations  personnel with 19 or more years of experience which range from $8,000 to  those who reenlist for one year to as much as $150,000 for those who  reenlist for an additional 6 years.
section_title: Attrition Rates for 2004 Returned to Level Seen Prior to Stop Loss Issuance
paragraphs: While data from several sources indicate increased attrition in fiscal year  2004 compared to fiscal years 2002 and 2003 in the military skills sought by  private security providers, these data also showed that attrition rates in  fiscal year 2004 had returned to the levels seen in fiscal years 2000 and  2001, prior to the majority of the stop loss policies that have been instituted  by the services at various times since September 2001.  Table 1 shows the  dates of occupational stop losses for each of the services.
Each of the services added and released occupations from stop loss as the  needs of the service dictated.  For example, the Air Force placed all  occupational specialties under a stop loss in September 2001 and then  released a number of occupations from the stop loss in January and June  2002.  As we noted, the Air Force ended all stop loss activities in June 2003.   In the Army, Special Operations forces were placed under stop loss in  December 2001 and were released from the stop loss in June 2003, while  enlisted servicemembers who served as military police were placed under  stop loss in February 2002 and were released from the stop loss in July  2003.  Army officers serving as military police were placed under the stop  loss in February 2002 and were released from the stop loss in June 2003.
Data obtained from DMDC on the military occupational specialties  preferred by private security providers revealed that several of these  specialties show increased attrition in fiscal year 2004 over the attrition  rates in fiscal year 2003.  These specialties include:    Air Force:  Officer military police  Army:  Enlisted and Officer Infantry, military police, and Special Forces  Marine Corps:  Enlisted and Officer Infantry and military police  Navy:  Enlisted military police, Officer Special Forces, and Enlisted  SEALs.
For the specialties listed, the average attrition rates for each fiscal year are  shown in figure 8.  As seen in figure 8, the attrition rates for these  specialties decreased in fiscal year 2002 and 2003 from their 2000 and 2001  levels and showed an increase in attrition in fiscal year 2004.  These data  also show that the levels of attrition seen in fiscal year 2004 were actually  lower than those seen in fiscal years 2000 and 2001.
The decrease in attrition rates seen in fiscal years 2002 and 2003 as  compared to the rates seen in fiscal years 2000 and 2001 reflect attrition  patterns that are seen during stop losses.  Service officials told us that stop  loss policies affect attrition rates; they can temporarily delay separations  and artificially decrease attrition rates for the year of the stop loss.   Officials at the Army Human Resources Command also found that stop loss  policies can also increase attrition rates for the year preceding the stop  loss.  For example, the Army saw increased separations in 2002 for military  police colonels in anticipation of their occupation-specific stop loss.  Given  the impact of stop loss policies on attrition, data may not accurately convey  the typical personnel losses that would have occurred had the stop loss not  been in effect as people left the military both in anticipation of stop loss  and after stop loss was lifted.  Thus, we are unable to determine whether  the increase in attrition rates in fiscal year 2004 was due to the lifting of the  stop loss policy or true increases in military attrition.
Figure 9 shows a pattern of decline in attrition rates during the stop loss  period followed by a rebound for Army Special Forces in fiscal year 2004.   Attrition rates for enlisted Army Special Forces were almost identical in  fiscal years 2000 and 2001, and declined through 2003 during the Army  Special Forces specific stop loss, which was in effect from December 2001  to June 2003.  However, after the stop loss was lifted, attrition rates for the  enlisted Army Special Forces almost doubled from 6.5 percent in fiscal year  2003 to 12.9 percent in fiscal year 2004, a level which was about 25 percent  higher than the fiscal year 2000 rate.  Attrition rates for Army Special  Forces officers also declined during the stop loss period and returned to  just below the fiscal years 2000 and 2001 levels in fiscal year 2004.
The Special Operations Command also provided us with continuation rates  calculated by DMDC for the Army, Navy, and Air Force Special Operations  Commands.  Continuation rates were calculated by determining which  personnel remained on active duty from one year to the next and are an  alternative method used to demonstrate retention and attrition.  The  continuation rates showed an increase in losses in 2004 for the Army  Special Operations and Navy Special Warfare Commands senior  noncommissioned officers, as well as Army Special Operations warrant  officers.  Similar to the DMDC data provided to us, these commands also  saw a decrease in losses (or a decrease in attrition rates) in 2002 after a  stop loss was issued and, with the exception of the Navy Special Warfare  warrant officers, an increase in losses (or an increase in attrition rates)  after the stop loss was lifted.
Additionally, as shown in figure 10, the continuation data for Army Enlisted  Special Operations personnel with 14 through 19 years of service separated  at only a slightly higher rate in 2004 than in the pre-stop loss years — fiscal  years 2000 and 2001.  In the July 2004 hearing before the House Armed  Services Committee, Subcommittee on Terrorism, Unconventional Threats  and Capabilities, the Senior Enlisted Advisor for the United States Special  Operations Command stated that the loss of these mature, operationally  experienced personnel creates critical operational risk for the Special  Forces.  According to the Special Operations Command officials with  whom we spoke, because the command is losing some of its most  experienced personnel, younger less experienced servicemembers are  being promoted to leadership positions more quickly than in the past.  This  need to rely on less experienced personnel has created some concerns for  the command.
section_title: Many Factors Influence the Decision to Separate from the Military
paragraphs: While available data indicate that attrition, in almost all of the military  specialties favored by private security providers, has returned to pre- September 11, 2001 levels, the data do not indicate why personnel are  leaving the military and what they are doing after they leave.  Exit surveys  conducted with servicemembers leaving the military do not include  questions on the servicemembers’ future employment plans.  Officials at  the Army Human Resources Command told us that after September 11,  2001, the opportunities for employment in the security field became more  widespread as government agencies as well as private companies and  organizations recognized the need to improve their security.  These officials  as well as officials from the Special Operations Command noted that they  are losing personnel not only to private security firms operating in Iraq but  also to security management companies operating in the United States, and  security operations in other government agencies.  Service officials at these  commands also attributed the attrition rates to other factors, such as the  attraction of a strong civilian economy, high operational tempo, and  concerns about various quality of life conditions.
section_title: Conclusions
paragraphs: The reconstruction effort in Iraq is complex, costly, and challenging, in  part, due to an urgent need to begin and execute reconstruction projects in  an uncertain security environment.  The extensive use of private security  providers has raised a number of issues, particularly regarding how to  facilitate methods contractors use to obtain capable providers.  And, once  security providers are actively working in an area, they must determine  how best to establish effective coordination mechanisms with nearby  military forces.  While the experience in Iraq was certainly unique relative  to historical reconstruction and assistance efforts, it is far less certain  whether or not the future will find the United States engaged in  reconstruction and assistance efforts in other hostile environments with  costs that are likely to be significant.  Much has been learned in Iraq over  the past two years on this subject that can serve the United States and its  contractors well in planning for and executing future reconstruction or  assistance efforts.
section_title: Recommendations for Executive Action
paragraphs: We are making four recommendations to address a number of immediate  and long term issues:   To assist contractors operating in hostile environments in obtaining  security services required to ensure successful contract execution, we  recommend that the Secretary of State, the Secretary of Defense, and  the Administrator, U.S. Agency for International Development, explore  options that would enable contractors to obtain such services quickly  and efficiently.  Such options may include, for example, identifying  minimum standards for private security personnel qualifications,  training requirements and other key performance characteristics that  private security personnel should possess; establishing qualified vendor  lists; and/or establishing contracting vehicles which contractors could  be authorized to use.
To ensure that MNF-I has a clear understanding of the reasons for blue  on white violence, we recommend that the Secretary of Defense direct  the Combatant Commander, U.S. Central Command, to direct the  Commander, MNF-I, to further assess all of the blue on white incidents  to determine if the procedures outlined in the December 2004 order are  sufficient.  Furthermore, if the procedures have not proven to be  effective, we recommend that the Commander, MNF-I, develop  additional procedures to protect both U.S. military forces and private  security providers.
To ensure that commanders deploying to Iraq have a clear  understanding of the role of private security providers in Iraq and the  support the military provides to them, we recommend that the Secretary  of Defense develop a training package for units deploying to Iraq which  provides information on the Reconstruction Operations Center, typical  private security provider operating procedures, any guidance or  procedures developed by MNF-I or MNC-I applicable to private security  providers (such as procedures outlined in the December 2004 order to  reduce blue on white incidents), and DOD support to private security  provider employees.  The training package should be re-evaluated  periodically and updated as necessary to reflect the dynamic nature of  the situation in Iraq.
To improve agencies’ ability to assess the impact of and manage security  costs in future reconstruction efforts, we recommend that the Secretary  of State, the Secretary of Defense, and the Administrator, U.S. Agency  for International Development, establish a means to track and account  for security costs to develop more accurate budget estimates.
section_title: Agency Comments and Our Evaluation
paragraphs: DOD, the Department of State and USAID provided written comments on a  draft of this report.  Their comments are discussed below and are reprinted  in appendixes II, III, and IV, respectively.
DOD concurred with each of our recommendations, noting that it  welcomed our assistance in improving how DOD and its contractors can  plan for and effectively execute contracts in a complex and changeable  security environment. Moreover, DOD described the steps it would take to  implement some of our recommendations.
The Department of State disagreed with our recommendation to explore  options to assist contractors in obtaining private security services, citing  concerns that the government could be held liable for performance  failures.  For example, while the Department noted that it could provide the  criteria it utilizes to select its contractors on a non-mandatory basis, it  expressed concern that contractors relying on government minimum  standards could assert that performance failures were the result of the  government establishing poor standards. The Department also noted it was  unclear that a government-managed security contractor program would  result in enhanced contractor security, compared to a contractor-managed  security program.  While our work found that contractors had difficulty in  obtaining security providers that met their needs and that they would have  benefited from the agencies’ assistance, we did not recommend a particular  course of action nor recommend a government-managed security program.   Rather, we recommended that the Department, working jointly with DOD  and USAID, explore options to assist contractors that are unfamiliar with  obtaining the type of security services needed in Iraq.  Such an effort would  necessarily entail a thorough assessment of the advantages, disadvantages  and risk mitigation strategies of the potential options.  Given the  significance of contractors in accomplishing reconstruction objectives and  the mixed results that they encountered when selecting their security  providers, we continue to believe that thoroughly exploring potential  options would be prudent.
The Department of State did not indicate whether it agreed with our  recommendation to establish a means to track and account for security  costs in order to develop more accurate budget estimates. It noted that it  can capture costs associated with direct security providers and work with  prime reconstruction contractors to determine the feasibility of providing  subcontract security costs.  It is not clear to us from the Department’s  comments how it intends to work with DOD and USAID to establish a  uniform means to track and account for private security costs, which is  essential given that DOD and USAID are the principal agencies responsible  for awarding and managing the majority of reconstruction contracts.
In written comments on a draft of this report, USAID found the report  factually correct, but did not comment on the recommendations.
We are sending copies of this report to the Chairman and Ranking Minority  Member, House Committee on Government Reform; the Chairman and  Ranking Minority Member, House Committee on Energy and Commerce;  the Chairman and Ranking Minority Member, Senate Committee on  Governmental Affairs; and other interested congressional committees. We  are also sending a copy to the Secretary of Defense; the Secretary of State;  the Administrator, U.S. Agency for International Development; and the  Director, Office of Management and Budget, and will make copies available  to others upon request. In addition, the report will be available at no charge  on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions, please contact Bill Solis at 202-512- 8365 or by e-mail at solisw@gao.gov.  Contact points for our Offices of  Congressional Relations and Public Affairs are found on the last page of  this report.  GAO staff who made major contributions to this report are  included in appendix V.
section_title: Scope and Methodology
paragraphs: To determine the extent to which U.S. government agencies and  contractors working in Iraq at the behest of the U.S. government have  acquired security services from private security providers, we reviewed a  wide array of documents to determine who was responsible for providing  security to those types of organizations, including   warning orders and fragmentary orders issued by the U.S. Central  Command (CENTCOM), Combined Joint Task Force-7, Multi National  Forces–Iraq, and Multi National Corps-Iraq to determine if any orders  had been issued regarding providing security to U.S. government  employees or contractors rebuilding Iraq;  contracting documents such as statements of work, requests for  proposals and contracts and contact modifications;  Department of Defense (DOD) regulations and instructions that relate  to the management of contractors during contingency operations;   Departments of State and Defense memoranda of understanding  regarding security and support;  proposed guidance between the Department of State and the  Department of Defense regarding contractor support;  guidance to contractors prepared by the Coalition Provisional Authority  (CPA) regarding contractor operations in Iraq; and  Department of State rules and regulations, including the Foreign Affairs  Manual.
We also met with officials from CENTCOM to obtain the command’s  position on the extent of the military’s responsibility to provide security to  civilian government employees and contractors, including both contractors  supporting military forces and those engaged in rebuilding Iraq.  In  addition, we met with or obtained information from Army and Marine  Corps units that served in Iraq to discuss their understanding of the  military’s responsibility to provide security to contractors and civilian  government employees and interviewed representatives of the State  Department’s Office of Diplomatic Security to discuss the State  Department’s use of private security providers in Iraq as well as  representatives of other government agencies working in Iraq who have  contracted with private security providers to provide security to employees  and facilities.
To determine how agencies addressed security needs when planning for  and awarding Iraq reconstruction contracts, we interviewed officials at the  CPA; DOD, including the U.S. Army Corps of Engineers and the Project and  Contracting Office (PCO); the Department of State; and the U.S. Agency for  International Development (USAID).  We discussed the guidance and  direction they received prior to awarding contracts and how such  information was provided to the contractors.  We reviewed various  acquisition documents, including agency acquisition plans, requests for  proposals, price negotiation memoranda, correspondence between  contractors, and other relevant documents.  We met with agency and  contractor officials to discuss the nature and type of guidance provided  relative to the expected security environment, the need for obtaining  security services, and requirements and standards for security personnel or  security-related equipment.
We identified how security-related requirements were reflected in  reconstruction contracts by selecting 16 contracts that were awarded to  10 reconstruction contractors. We selected these contracts using a  nonprobabilistic methodology that considered such factors as the awarding  agency; the year awarded; the contract’s expected dollar value; and the  type, nature and location of the reconstruction activity.  Nine of these  contracts were awarded in 2003 and 7 were awarded in 2004. For each of  these contracts, we obtained the contract and contract modifications  issued as of December 31, 2004, totaling about $8.6 billion; relevant  sections of the contractor's cost and technical proposal; security plans;  security-related subcontracts; and other pertinent documents.  We also  obtained and reviewed 6 contracts that had been awarded by the U.S. Army  Corps of Engineers, the Department of State, USAID and by an Army  contracting agency for the CPA, for the protection of their personnel and  facilities in Iraq to compare the type of security-related requirements  incorporated within U.S. government contracts with those incorporated  into contracts awarded to reconstruction contractors and, in turn, to  subcontracts with security providers.
We identified whether there are existing government or international  standards relative to security providers that were applicable to the Iraqi  security environment.  We also spoke with agency security personnel,  including the Department of State’s Office of Diplomatic Security and the  Overseas Security Advisory Council.  We also contacted representatives  from relevant industry associations, including the International Peace  Operations Association, International Security Management Association,  and the American Society for Industrial Security.  We also researched  European security-provider standards and conducted a literature review of  articles relating to the security provider industry.
To assess the military’s relationship with private security providers, we met  with or spoke to representatives of CENTCOM, Army Central Command,  and the PCO (at the Pentagon and in Baghdad) to discuss issues related to  the military’s authority over private security providers and reviewed a  Department of Defense report to Congress addresses the use of private  security providers in Iraq.  We also met with or contacted representatives  of Army and Marine Corps units that had been stationed in Iraq to  determine if they had been provided guidance on working with private  security providers and discussed issues related to command and control of  private security providers.
To assess the level of cooperation and coordination between the military  and private security providers both before and after the advent of the  Reconstruction Operations Center (ROC), we spoke with 9 private security  providers working in Iraq as well as representatives of military units which  had served in Iraq to determine the state of coordination prior to and after  the ROC became operational.  We spoke with representatives of the PCO to  discuss the ROC’s role in coordinating the interactions between the military  and private security providers and any actions the PCO was taking to  improve coordination between private security providers and U.S. military  forces.  We also discussed coordination issues with the executive director  of the Private Security Company Association of Iraq and several  reconstruction contractors.  We also reviewed information posted on the  ROC Web site related to security and reviewed documents developed by  the ROC to explain its operations and functions.
To determine the extent to which government agencies assessed the costs  associated with using private security providers and security-related costs,  we reviewed various contractual documents, including the 16  reconstruction contracts and subsequent modifications, consent to  subcontract requests, and monthly cost and progress reports submitted by  the contractors we reviewed.  We also met with agency and contractor  officials to determine the means by which they maintained visibility over  security providers and security-related expenses, as well as their general  experiences in Iraq, the impact of security on reconstruction efforts, and  the process by which they obtained security providers.
We collected data on the costs associated with acquiring and using private  security providers or in-house security teams; and the cost associated with  acquiring security-related equipment, such as armored vehicles, body  armor, communication equipment, and other security-related costs. We did  not attempt to quantify the impact of the security environment on  increased transportation or administrative expenses, on the pace of  reconstruction efforts caused by security-related work stoppages or delays,  or the cost associated with repairing the damage caused by the insurgency  on work previously completed. We also excluded the cost associated with  the training and equipping of Iraqi security forces, or the costs borne by  DOD in maintaining, equipping, and supporting U.S. troops in Iraq.
For the 16 contracts we reviewed, we identified whether the agencies or  the contractors had initially projected the cost of obtaining private security  services. We reviewed various documents, including agency acquisition  strategy plans and price negotiation memoranda; the contractor’s cost  proposals and security plans; and interviewed agency and contractor  officials.  We identified the actual costs incurred for security services and  equipment by reviewing various cost documentation, including invoices,  vouchers, and billing logs submitted by the contractors and their security  provider(s) through the period ending December 31, 2004.  We analyzed  this information to determine  the total amount billed by the contractor to the government;  the amount billed by security subcontractors to the contractor; and  the amount billed for other security-related expenses, such as armored  vehicles, body armor, communication, transportation costs, lodging, and  other security-related equipment.
We estimated the percentage of costs accounted for by private security  providers and for security-related equipment by comparing the combined  amount billed for these activities to the total amount billed by the  reconstruction contractor to the government. We did not attempt to  comprehensively identify costs that may have been incurred by  subcontractors or lower tier contractors.  We did, however, request  information from the contractors as to whether their subcontractors  required security above that which would typically be required, and if so,  whether the subcontractor arranged for its own security or relied on  security provided by the reconstruction contractor.  We obtained examples  and cost information on selected cases in which subcontractors provided  their own security.
As part of our efforts, we reviewed pertinent sections of the Federal  Acquisition Regulation, and in particular, the subcontractor competition  and notification requirements provided for under Part 44; and relevant  CPA, DOD, State Department, and USAID acquisition regulations, policy  memoranda and guidance.  We coordinated our work with and reviewed  reports prepared by the Inspectors General for DOD, State, and USAID; the  Special Inspector General for Iraq Reconstruction; and the Defense  Contract Audit Agency.
To determine whether private security providers were hiring former  military servicemembers, we interviewed three private security providers  from the United States that are working in Iraq and discussed the skill sets  they hire.  Additionally, we spoke with officials at the Marine Corps and  Navy human resources commands; the Air Force’s Deputy Chief of Staff,  Personnel; the Army's Human Resources Command Military Police Branch  and the Special Operations Command Personnel Division to ascertain  whether certain military occupational specialties and ranks were seeing  increased attrition and if private security providers were affecting military  attrition.  We also reviewed a transcript of a congressional hearing on  Special Operations Forces personnel issues held in July 2004.
To assess the extent to which military occupational specialties utilized by  private security providers in Iraq are seeing increased attrition we obtained  attrition information from the Defense Manpower Data Center’s Active  Duty Military Officer and Enlisted Master Files, which is an inventory of all  individuals on active duty in the services.  Our analysis was limited to  active duty personnel and did not include reservists.  The Center provided  information on personnel numbers and losses for fiscal years 2000, 2001,  2002, 2003, and 2004.  Attrition for the purposes of this report is an active  duty member who is on active duty at the start of a given fiscal year and is  no longer on active duty in the same service in the same pay category at the  end of that fiscal year.  An enlisted member who becomes a warrant or  commissioned officer (or vice versa) or a member who changes services is  considered to be a loss.  The fiscal year lasts from October 1st of the  previous year to September 30th of the named year.  For example, fiscal  year 2000 lasted from October 1, 1999 to September 30, 2000.  Personnel  numbers were calculated as the total number of members at the start of the  fiscal year (for example, October 1, 1999 for fiscal year 2000).  Losses are  the endforce members who have attrited during the fiscal year (For  example, for fiscal year 2000, losses would be the number of personnel  attrited from October 1, 1999 to September 30, 2000.).
We received data from the Defense Manpower Data Center on active duty  attrition rates for five military occupational specialties: special forces,  military police, infantry, para-rescue, and combat controller.  These military  occupational groupings were selected because they represented military  occupational skills most sought after by private security providers working  in Iraq, as determined through interviews with officials at the human  resources commands and private security companies.  These data were  then analyzed to determine whether attrition rates had increased in the  past five years and whether servicemembers were separating from the  military at increasing rates in certain ranks or number of years of service.
We assessed the reliability of the Defense Manpower Data Center’s Active  Duty Military Personnel Master file by (1) reviewing existing information  about the data and the system that produced them, and (2) interviewing  agency officials knowledgeable about the data.  We determined that the  data were sufficiently reliable for the purpose of this report.
We visited or interviewed officials from the following organizations during  our review:  Bureau of Diplomatic Security, Washington, D.C.;   U.S. Embassy, Amman, Jordan;   The U.S. Agency for International Development, Washington, D.C.,  Baghdad, Iraq; and Amman, Jordan.
Office of the Under Secretary of Defense, Personnel and Readiness,  Military Personnel Policy, the Pentagon;   The Defense Contract Audit Agency, Fort Belvoir, Virginia.
Department of the Air Force  Office of the Deputy Chief of Staff, Personnel, Force Management  Division.
United States Army Human Resources Command Military Police  Branch, Alexandria, Virginia;  United States Army Central Command (Rear), Fort McPherson, Georgia;  Project and Contracting Office (Rear), the Pentagon;  U.S. Army Corps of Engineers, Washington, D.C.;   Southwestern Division, Dallas, Texas;   Transatlantic Program Center, Winchester, Virginia;  Gulf Regional Division, Baghdad, Iraq;  The Army Contracting Agency, Fort Eustis, Virginia;   1st Armored Division, Wiesbaden, Germany;  82nd Airborne Division, Fort Bragg, North Carolina;   2nd Armored Cavalry Regiment, Fort Polk, Louisiana;   1st Cavalry Division, Fort Hood, Texas.
Naval Personnel Command, Millington, Tennessee;  Marine Corps Manpower Plans and Policy Division, Washington, D.C.;   1st Marine Corps Expeditionary Force, Camp Pendleton, California.
United States Central Command, MacDill Air Force Base, Florida;  United States Special Operations Command Personnel Division, MacDill  Air Force Base, Florida.
Aegis Defence Services, Ltd., London, United Kingdom;  ArmorGroup, London, United Kingdom;  BearingPoint Inc., McLean, Virginia;  Bechtel National, Inc., San Francisco, California;  Blackwater USA, Moyock, North Carolina;  CONTRACK International, Inc., Arlington, Virginia;  Control Risk Group, London, United Kingdom;  Creative Associates International, Inc., Washington, D.C.;  DynCorp International, Irving, Texas;  Fluor Intercontinental, Inc., Greenville, South Carolina;  General Electric, Atlanta, Georgia;  Global Risk Strategies, London, United Kingdom;  Kellogg Brown and Root Services, Inc., Houston, Texas;  Olive Security, London, United Kingdom;  Parsons Corporation, Pasadena, California;  Perini Corporation, Framingham, Massachusetts;   Research Triangle Institute, Research Triangle Park, North Carolina;  Triple Canopy, Lincolnshire, Illinois;   The Hart Group, London, United Kingdom; and  Washington Group International, Inc., Boise, Idaho; and Princeton, New  Jersey.
American Society for Industrial Security International, Alexandria,   International Peace Operations Association, Washington, D.C.;  International Security Management Association, Buffalo, Iowa;  Private Security Company Association of Iraq, Baghdad, Iraq;  Professional Services Council, Arlington, Virginia.
We conducted our review from May 2004 through June 2005 in accordance  with generally accepted government auditing standards.
section_title: Comments from the Department of Defense
section_title: Comments from the Department of State
section_title: Comments from U.S. Agency for International Development
section_title: GAO Contacts and Staff Acknowledgements
subsections: section_title: GAO Contacts
section_title: Acknowledgments
paragraphs: In addition to the contacts named above, Steve Sternlieb, Timothy  DiNapoli, Carole Coffey, Gary Delaney, John Heere, William Petrick,  Timothy Wilson, Moshe Schwartz, Kate Walker, Robert Ackley, David  Mayfield, and Sylvia Schatz made key contributions to this report.