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

Letter

Background

“Oversight of a contract”—which can refer to contract administration functions, quality assurance surveillance, corrective action, property administration, and past performance evaluation—ultimately rests with the contracting officer who has the responsibility for ensuring that contractors meet the requirements set forth in the contract. However, contracting officers are frequently not located in the area or at the installation where the services are being provided. For that reason, contracting officers designate CORs via an appointment letter to assist with the technical monitoring or administration of a contract on their behalf. CORs serve as the eyes and ears for the contracting officer and act as the liaisons between the contractor, the contracting officer, and the unit receiving support or services. CORs are responsible for tasks identified in the contracting officer’s appointment letter that may include (1) providing daily contract oversight, (2) performing quality assurance reviews, (3) monitoring contract performance, and (4) assessing technical performance. CORs cannot direct the contractor by making commitments or changes that affect price, quality, quantity, delivery, or other terms and conditions of the contract. have also been tasked with other contract-related duties such as preparing statements of work, which provide the requirements or specifications of the contract, developing requirements approval paperwork, and preparing funding documents. Although CORs are non- acquisition personnel, they can have acquisition-related responsibilities— particularly those related to contract oversight. CORs are not usually contracting specialists and often perform contract management and oversight duties on a part-time basis in addition to performing their primary military duties, such as those performed by an infantryman or a quartermaster specialist.

DOD defines the term “contingency contract” as a legally binding agreement for supplies, services, and construction let by government contracting officers in the operational area, as well as other contracts that have a prescribed area of performance within a designated operational area. These contracts include theater support, external support, and systems support contracts.

Theater Support Contracting Command contracting officers assisted by CORs. When DCMA is not designated responsibility for administrative oversight of a contract, the contracting officer who awarded the contract is responsible for the administration, management, and oversight of the contract. These contracting officers, such as those from the CENTCOM Joint Theater Support Contracting Command often appoint CORs to monitor contractor performance. CORs appointed by the CENTCOM Joint Theater Support Contracting Command are typically drawn from units receiving contractor-provided services. In Afghanistan, CORs that have been appointed to contracts administered by DCMA report oversight results to DCMA personnel. For contracts not administered by DCMA, CORs provide oversight information to the contracting officer. In Afghanistan, the CENTCOM Joint Theater Support Contracting Command directs requiring activities (units receiving contractor-provided goods and services) to nominate CORs for all service contracts valued at more than $2,500 with significant technical requirements that require ongoing advice and surveillance from technical/requirements personnel. The contracting officer may exempt service contracts from this requirement when the following three conditions are all met: (1) The contract will be awarded using simplified acquisition procedures; (2) The requirement is not complex; and (3) The contracting officer documents the file, in writing, as to why the appointment of a COR is unnecessary.

DOD Took Steps to Enhance Existing Training Program, but Existing Training Does Not Fully Prepare CORs for Contract Management and Oversight Duties

Although DOD requires CORs to receive training and took some actions to enhance training programs, CORs we met with in Afghanistan do not always receive adequate training to prepare them for their contract management and oversight duties. DOD requires that CORs be qualified by training and experience commensurate with the responsibilities to be delegated to them. According to DOD officials, the current training might qualify CORs to monitor contractor performance generally, but it does not necessarily make them sufficiently capable for their particular assignments. DOD officials have acknowledged gaps in training. For example, required DOD training taken by CORs did not fully address the unique contracting environment that exists in Afghanistan, which includes large numbers of Afghan contractors with limited experience and qualifications. Further, the instability and security aspects of remote locations throughout Afghanistan coupled with an undeveloped infrastructure impedes the CORs’ ability to communicate with and rely upon acquisition personnel, such as contracting officers, for support and guidance. Additionally, not all of the required training for CORs was conducted, and some other oversight personnel were not being trained.

CORs Are Required to Receive Training and DOD Took Some Actions to Enhance Existing Training Programs

In Afghanistan, much of the daily surveillance of contractors supporting military operations is performed by CORs. The Federal Acquisition Regulation (FAR) requires that quality assurance, such as surveillance, be performed at such times and places as may be necessary to determine that the supplies or services conform to contract requirements. DOD guidance requires CORs to be trained and assigned prior to award of a contract. DOD training is intended to familiarize the CORs with the duties and responsibilities of contract management and oversight. Contracting organizations such as the CENTCOM Joint Theater Support Contracting Command require that personnel nominated to be CORs complete specific online training courseswell as locally developed CORs overview training, and contract-specific training provided by contracting officers in theater (the latter referred to as (referred to as Phase I), as Phase II) before they can serve as CORs in Afghanistan. The guidance notes that, at a minimum, Phase II training will consist of contract specific responsibilities, including file documentation; terms and conditions of the contract; specifics of the performance work statement; acceptance of services procedures; invoice procedures; technical requirements; monthly reporting procedures, and contractor evaluation—all specific to their assigned contract.

DOD has taken some actions to enhance training programs to prepare CORs to manage and oversee contracts in contingency operations, such as in Afghanistan. For example, DOD developed a new training course for CORs, with a focus on contingency operations and developed a more general certification program for CORs, including the contingency operations course as a training requirement when it is applicable. DOD also took steps to institutionalize operational contract support by including some CORs-related training in professional military education programs and by emphasizing the need for qualified CORs by discussing their responsibilities in joint doctrine and other guidance with the publication of Joint Publication 4-10—Operational Contract Support and the Defense Contingency Contracting Officer’s Representative Handbook and memoranda issued by the Deputy Secretary of Defense.

Available DOD Training Does Not Fully Prepare CORs to Oversee Contracts in Afghanistan

Our analysis of DOD’s CORs training and interviews with over 150 CORs and contracting personnel from over 30 defense organizations like the regional contracting centersKandahar, and Camp Leatherneck, Afghanistan, indicated that some gaps and limitations existed in DOD’s training programs leaving CORs not fully prepared to perform their contract management and oversight and the DCMA in Bagram, Kabul, duties. For example, the training for CORs is generally focused on low- risk contract operations in Afghanistan and does not fully address the unique contracting environment that exists there, such as the extent of inexperience of Afghan contractors, the remote and insecure locations of project sites, the underdeveloped infrastructure, and constraints on the movement and deployment of oversight personnel, especially acquisition personnel. More specifically, the required CORs training does not include information about important issue areas like the Afghan First Program, which encourages an increased use of local personnel and vendors for supplies and services as part of the U.S. counterinsurgency strategy, and working with private security contractors. Some CORs in Afghanistan told us they were unaware of the challenges in working with Afghan contractors and thought contracting with them would be similar to contracting with U.S. vendors. However, according to some of the CORs and other contracting personnel we interviewed, providing oversight of Afghan contractors was more challenging than was the case with other vendors because the Afghan contractors often did not meet the timelines specified in the contract, did not provide the quality products and the services the units had anticipated, and did not necessarily have a working knowledge of English. Further, these officials told us that Afghan contractors were not always familiar with the business standards and processes of the U.S. government. For example, one COR told us during our visit in February 2011 that a unit was still waiting for barriers that it had contracted for in May 2010. According to that COR, while some of the barriers had been delivered, the unit had not received all of the barriers it required even though the contract delivery date had passed. Other CORs, contracting officials, and commanders described similar situations in which services were either not provided as anticipated or were not provided at all. Because of gaps in training, CORs did not always understand the full scope of their responsibilities and did not always ensure that the contractor was meeting all contract requirements. As a result, according to contracting officials, items such as portable toilets, gates, water, and other items or services were not available when needed, raising concerns about security, readiness, and morale.

Contracting officials from over 30 defense organizations and units in Bagram, Kabul, Kandahar, and Camp Leatherneck whom we spoke with noted similar problems with construction contracts awarded to Afghan contractors. For example, according to another COR, an Afghan contractor was awarded a $70,000 contract to build a latrine, shower, and sink unit. The COR told us that the contractor was unable to satisfactorily complete the project and so another contract was awarded for approximately $130,000 to bring the latrine, shower, and sink unit to a usable condition. Because of inadequacies in training, CORs did not always understand that they had the responsibility to ensure that the terms of the contract were met and therefore did not bring contractors’ performance issues to the contracting officer’s attention for resolution. Similarly, DOD contracting officials provided us with documentation of other construction problems, including a shower/toilet facility built without holes in the walls or floors for plumbing and drain (fig. 1), and facilities that were constructed with poor-quality materials such as crumbling cement blocks (fig. 2). The Special Inspector General for Afghanistan Reconstruction has also reported significant construction deficiencies related to contracting in Afghanistan, including poorly formed and crumbling cement structures attributable to the lack of CORs training and oversight.

Because of the nature and sensitivity of security contracts, CORs for private security contractors’ contracts have unique responsibilities. For example, during the period of our review, under guidance in place prior to June 2011, CORs were responsible for compiling a monthly weapons discharge report and for ensuring contractor adherence to contractual obligations on topics such as civilian arming requirements, personnel reporting systems, property accountability, and identification badges. According to a senior military officer with U.S. Forces Afghanistan’s private security contractor task force, because of gaps in training, CORs did not always understand the full scope of their responsibilities and so did not always ensure that a contractor was meeting all contract requirements. He noted that CORs did not always understand that they had the responsibility to ensure that the terms of the contract were met and therefore did not bring contractors’ performance issues to the contracting officer’s attention for resolution. As a result, DOD may pay contractors for poor performance and installations might not receive the level of security contracted for.

Further, we found that the training programs lacked specifics on the preparation of statements of work or documents required for acquisition review boards—two contract management responsibilities that CORs in Afghanistan were routinely tasked to do. Although the development of a statement of work involves a variety of participants from the contracting process, a COR may be uniquely suited to have an early impact on the development of a complete and accurate statement of work. The Defense Contingency Contracting Officer’s Representative Handbook describes statements of work as specifying the basic top-level objectives of the acquisition as well as the detailed requirements of the government. The statement of work can provide the contractor with “how to” instructions to accomplish the required work. It could provide a detailed description of what is expected of the contractor and forms part of the basis for successful performance by the contractor and effective oversight of contracts by the government. Well-written statements of work are needed to ensure that units get the services and goods needed in the required time frame. As we reported in 2000 and 2004, poorly written statements of work can also increase costs and the number of substandard supplies and services provided by the contractor. Based on discussions with contracting personnel from four major bases in Afghanistan responsible for reviewing these documents, statements of work prepared by CORs were vague and lacked the specifics needed to provide units with what they wanted. We were told by multiple DOD officials that some CORs routinely cut and paste information from previous statements of work into their current document without adapting it as needed, resulting in errors that have to be corrected and further extending the time involved in procuring a good or service. Contracting personnel told us of instances in which statements of work had to be rewritten because the original statements of work did not include all the required contractor actions, or because they included incorrect requirements. Although there are other DOD contracting personnel involved in the requirement and procurement process, CORs can help to ensure that well-articulated needs are more fully documented at an early stage. DOD contracting personnel responsible for reviewing and approving requests for contract support told us that poorly written statements of work were a principal reason units do not receive the operational contract support they need for sustaining military operations. Because of gaps in training, CORs were unable to prepare well-articulated statements of work that clearly define the warfighters’ needs. For example, DOD contracting personnel told us about a dining facility in Afghanistan that was built without a kitchen because it was not included in the original statement of work, resulting in DOD having to generate a separate statement of work for the kitchen. According to contracting officials and commanders, poorly written statements of work increase the procurement process time, the workload burden on the DOD contracting personnel, and delays and disruptions in critical supplies and services needed for the mission.

Moreover, according to DOD, one of the acquisition review boards in Afghanistan, known as the Joint Acquisition Review Board, reviews and recommends approval or disapproval of proposed acquisitions to ensure efficiency and cost effectiveness. DOD contracting personnel responsible for reviewing acquisition proposals told us that delays and disruptions in supplies and services needed by the unit have been attributed to incomplete or incorrect documents, such as statements of work. Since CORs in Afghanistan are heavily relied upon by their units and the acquisition personnel in the development of these documents, it is important that they understand what paperwork is required and how to properly complete it in order to obtain needed goods and services in a timely manner. Contracting officials acknowledge the challenges with preparing complete/correct statements of work and DOD is making some effort to address the gaps in training. For example, the Defense Acquisition University provides a training course on preparing requirements documents such as statements of work; however, it is not a DOD requirement for CORs and contracting personnel to complete this training before assuming their contract-related roles and responsibilities.

Not All CORs Receive Required Training

DOD contracting personnel and CORs in Afghanistan told us that the CENTCOM Joint Theater Support Contracting Command contracting officers were frequently unable to provide the required contract-specific training (Phase II) for CORs because they were busy awarding contracts. For instance, a COR whom we interviewed in Afghanistan was directing a contractor to perform construction work or correct deficiencies in performance without authorization from or communication with the contracting officer. Because the COR had never received the required training from the contracting officer, he was not aware that this practice was potentially unauthorized. Without the follow-on Phase II training from the contracting officer, CORs may lack a clear and full understanding of the scope of their contract duties and responsibilities. In contrast, DCMA’s contracting personnel provide specific contract training and mentoring to its CORs because DCMA has full-time quality assurance personnel who have been tasked with providing COR training and assistance. According to DCMA officials, certified quality assurance representatives continue to mentor CORs after their formal training has been completed.

Moreover, in addition to CORs, other personnel expected to perform contract oversight and management duties in Afghanistan are not always being trained. Joint Publication 4-10 states that military departments are responsible for ensuring that military personnel outside the acquisition workforce who are expected to have acquisition responsibility, including oversight duties associated with contracts or contractors are properly trained. The Joint Publication also highlights the key role of commanders and senior leaders in operational contract support oversight. However, contracting personnel that we interviewed in Afghanistan told us that military personnel such as commanders and senior leaders did not always receive training on their contract management and oversight duties in Afghanistan and that commanders, particularly those in combat units, do not perceive operational contract support as a warfighter task.

Although some contracting-related training is available for commanders and senior leaders, it is not required before deployment. DOD has not expanded the professional military education curriculum by increasing the number of training offerings on operational contract support with a particular emphasis on contingency operations to fully institutionalize operational contract support in professional military education. Based on our previous findings, it is essential that commanders and senior leaders complete operational contract support training before deployment to avoid confusion regarding their contract role and responsibilities in managing and overseeing contractors, and nominating qualified CORs. In 2006, we recommended that operational contract support training be included in the professional military education to ensure that all military personnel expected to perform contract management duties, including commanders and senior leaders, receive training prior to deployment. DOD has taken some actions to implement this recommendation by developing some Programs of Instruction on contingency acquisition for their non- acquisition workforce to be taught at some of the military and senior staff colleges. However, commanders and senior leaders are not required to take these courses before assuming their contract management and oversight roles and responsibilities.

CORs Do Not Always Have the Subject Area-Related Technical Expertise Needed to Oversee Some Contracts

CORs did not always have the subject area-related technical expertise or access to subject matter experts with those skills to manage and oversee contracts in Afghanistan, especially those contracts of a highly technical and complex nature. The Defense Contingency Contracting Officer’s Representative Handbook indicates that CORs are responsible for determining whether products delivered or services rendered by the contractor conform to the requirements for the service or commodity covered under the contract. Further, the Contracting Officer’s Representative Handbook notes that CORs should have technical expertise related to the requirements covered by the contract.

However, according to CORs and contracting personnel we interviewed in Afghanistan, CORs did not have the subject area-related technical expertise necessary to monitor contract performance for the contracts they were assigned to oversee. For example, many of these CORs were appointed to oversee construction contracts without the necessary engineering or construction experience, in part because their units lacked personnel with those technical skills. While DCMA had subject matter experts in key areas such as fire safety available for CORs needing technical assistance, CORs for contracts written by the CENTCOM Joint Theater Support Contracting Command did not have subject matter experts to turn to for assistance, particularly in the construction trades during the time of our visit. As a result, according to officials, there were newly constructed buildings that had to be repaired or rebuilt before being used by U.S. and Afghan troops because the CORs providing the oversight were not able to adequately ensure proper construction. According to personnel we interviewed, these practices resulted in wasted resources, low morale, and risks to the safety of base and installation personnel where the deficient guard towers, fire stations, and gates were constructed. Officials stated that it is not uncommon for a COR to accept a portion of the contractor’s work only to find later upon further examination that the work was not in accordance with the contract and substandard. Similarly, officials stated that the LOGCAP personnel did not accept responsibility for maintenance of a facility that had been constructed by Afghan contractors until LOGCAP contractors first repaired or replaced wiring and plumbing to meet building codes. Although the CORs were not solely responsible for contract oversight, or for the implications identified above, they could have provided an early verification of contractor performance. More importantly, in the Afghanistan contracting environment the DOD contracting personnel ultimately responsible for oversight—such as contracting officers—were often removed or absent from the remote locations where the work was performed and had no ability to communicate electronically. This results in greater reliance on CORs and reduces the opportunity for CORs to identify problems early in the process. The following were cases that further illustrate the impact of CORs not having the technical skills or support needed to perform contract management and oversight. Although the CORs did not necessarily bear the sole responsibility for consequences identified below, a well-trained COR might have been able to prevent or mitigate the effects of the problems.

According to officials, a COR prepared a statement of work for a contract to build floors and install tents but failed to include any power requirements necessary to run air conditioners, heaters, and lights because the COR and unit personnel did not have the electrical technical expertise to properly and safely specify the correct power converter package with the original request. Thus, the tents were unusable until the unit used a field ordering officer to order, at an additional cost, the correct power converters so that the tents were usable and completed in a timely fashion.

Contracting officials told us that guard towers at a forward operating base were poorly constructed and unsafe to occupy. As shown in figure 3, the staircase was unstable and not strong enough for climbing; it had to be torn down and reconstructed. The COR’s inadequate subject area-related technical expertise or access to subject matter experts prevented the early identification of defective welding on the staircase that rendered it unsuitable to use to climb up the guard tower.

A senior engineer inspector official told us the cement block walls that had been accepted by a COR were poorly constructed. The COR did not have the subject area-related technical expertise or access to subject matter experts necessary to properly inspect and reject substandard cement block walls. For example, the contracting official noted large holes in a cement block wall that remained after the wood scaffolding was removed, which rendered the wall unstable (fig. 4).

A dining facility expected to service 1,000 military personnel was unused for a year due to emergent construction deficiencies such as electrical and plumbing issues. Contracting officials attributed the construction issues to the shortage of oversight personnel with subject area-related technical expertise or access to subject matter experts in construction. As a result, according to contracting personnel, repair work to correct the deficiencies was acquired under LOGCAP for $190,000 in addition to the original cost of the contract.

The issue of CORs not having adequate subject area-related technical expertise has been a longstanding problem in DOD. For example, we have previously reported in 2006, 2008, and again in 2010 that CORs do not always have the subject area-related technical expertise necessary to oversee contracts. More recently in November and August 2011, the Congressional Research Service and the Commission on Wartime Contracting in Iraq and Afghanistan reported that DOD is still in need of non-acquisition personnel with the necessary technical and subject matter expertise to perform contractor oversight, respectively. The Special Inspector General for Afghanistan Reconstruction has also reported significant construction deficiencies with contracting in Afghanistan as a result of inadequate subject area-related technical expertise on the part of CORs and other contract oversight personnel. Problem areas identified by the Inspector General included low-quality concrete (similar to conditions depicted in fig. 2 and fig. 4) and inadequate roofing installations, which were similar to other deficiencies we identified.

Further, based on DOD documentation, the nature of contract work in Afghanistan has become more technical and complex, increasing the number of CORs needed, the amount of time needed to award contracts, and the number of errors during the early stages of the contracting process (e.g., the requirements determination process). Due to the complexity of construction projects in Afghanistan, DOD established an initiative in April 2011 to assign construction inspectors to assist CORs in managing and overseeing construction projects. According to a DOD memorandum, contracting officers should appoint construction inspectors, in addition to CORs, when the nature of the project requires technical assistance to ensure proper performance of work and when such assistance is available. Because this program was not in effect during the time of our visit in February 2011, we are unable to assess the effectiveness of the use of construction inspectors. However, based on our observations in Afghanistan, there is a shortage of subject area- related technical experts that can serve as construction inspectors in Afghanistan. CORs and other personnel that we interviewed in Afghanistan acknowledged the benefit of having subject matter experts in construction as well as other specialty areas such as food-, fuel-, and electricity-related services.

Number of CORs Is Not Sufficient to Adequately Oversee the Contracts in Afghanistan

DOD does not have a sufficient number of CORs to oversee the numerous contracts in Afghanistan and, according to some government officials, there are not enough CORs in theatre to conduct adequate oversight. The CENTCOM Joint Theater Support Contracting Command requires the nomination of CORs for all service contracts worth over $2,500 with significant technical requirements that require on-going advice and surveillance from technical or requirements personnel, unless exempted by the contracting officer. Although there is no specific guidance on the number of contracts a single COR should manage, the CENTCOM Joint Theater Support Contracting Command requires that CORs nominations signed by the unit commander contain a statement verifying that the CORs will have sufficient time to perform assigned tasks. Similarly, the Defense Contingency Contracting Officer’s Representative Handbook states that the requiring unit must allow adequate resources (time, products, equipment, and opportunity) for the CORs to perform their functions. In 2004, 2006, and again in 2010, we reported that the DOD did not have a sufficient number of trained oversight personnel, and during the course of our review we noted that this situation persisted. Further, we found that CORs do not always have the time needed to complete their oversight responsibilities. While available data do not enable us to determine the precise number of contracts that require CORs, in fiscal year 2011, DOD completed over 35,000 contracting actions on over 24,600 contracts and orders that were executed primarily in Afghanistan.CORs we interviewed in Afghanistan, some CORs are responsible for providing oversight to multiple contracts in addition to performing their primary military duty. For example, one COR we interviewed was assigned to more than a dozen construction projects. According to the COR, it was impossible to be at each construction site during key phases of the project, such as for the concrete pouring of building footings, wiring installation, or plumbing. Consequently, according to contracting officials, construction on these multiple projects was completed without sufficient government oversight and problems were not always identified until the building was completed. This often resulted in significant rework, at a cost to the U.S. taxpayer.

According to contracting officials and In another instance, an entire compound of five buildings was built in the wrong location. According to DOD, based on the statement of work, the compound should have been constructed on base behind the security walls but instead was constructed outside the perimeter of the base in a non-secure location. Contracting officials we spoke with in Afghanistan attributed the problem to the numerous contracts managed by the COR and the lack of time to perform contract oversight duties. As a result, according to officials, the buildings (shown in fig. 5) could not be used. The cost of the compound including the five buildings was $2.4 million.

In addition, in some cases units did not assign enough CORs to provide oversight. For example, we were told by one unit that it did not have a sufficient number of CORs to provide proper oversight of dining facility services, including ordering and inspecting food and supplies. Although the unit was able to provide one COR for each dining facility, the dining facilities operate 24 hours a day. Contracting officials expressed concern that there were not enough CORs to provide sufficient oversight of the dining facilities 24 hours a day during all shifts of operation.

Conclusions

DOD and the services have taken some steps, such as developing a new CORs training course with a focus on contingency operations to improve oversight of contracts in contingency operations, such as in Afghanistan; other more general efforts, such as the COR certification program for services’ acquisitions, may also lead to improvement. However, in our work in Afghanistan we found that CORs are still not fully prepared to oversee the multitude of contracts for which they are assigned, potentially resulting in a significant waste of taxpayer dollars and an increased risk to the success of operations. The current mechanism for training CORs that also perform duties related to the requirements determination process and to the development of requirements documentation continues to have weaknesses because DOD has not yet developed training standards to ensure that these personnel fully understand Joint Operational Area specific issues such as the Afghan First program, the Counterinsurgency Contracting Guidance, and the details on the preparation of statements of work and documents required by the contract review boards. As noted in an Army Contracting Command publication, what contracting organizations do and how they do it cannot be foreign to the warfighter. Military personnel such as commanders, senior leaders, CORs, and other personnel expected to have a role in operational contract support are often not familiar with their contract roles and responsibilities until they reach theater because DOD has not sufficiently expanded the professional military education curriculum and provided more training on contract support with a particular emphasis on contingency operations. Further, having an insufficient number of CORs with the appropriate subject area-related technical expertise or access to dedicated subject matter experts in specialty areas hinders DOD’s ability to ensure that operational units obtain vital supplies and services when needed. Moreover, contract management and oversight has become more challenging due to a shortage of oversight personnel, an increase in the number of contracts, a high personnel turnover rate, training burden challenges, and an increase in the complexity of the work contracted. All of these have resulted in delays and errors in the procurement process. Further, as a result of these workload constraints, military personnel serving as CORs are limited in the number of contracts that they can reasonably manage and oversee considering the technical nature and complexity of each contract. Given DOD’s heavy reliance on contractors during operations in Afghanistan and given the unpredictability of potential future contingencies, it is critical that DOD address these challenges as soon as possible to mitigate the risk to the success of operations, to obtain reasonable assurance that contractors are meeting their contract requirements and that troops are getting what they need to support contingency operations, and to help ensure that tax dollars are not being wasted.

Recommendations for Executive Action

To provide for improved oversight of operational contract support, we are recommending that DOD enhance the current strategy for providing contract management and oversight in Afghanistan and other areas of operations. Specifically, we recommend that the Secretary of Defense take the following four actions:

Direct the CENTCOM Commander in consultation with the Secretaries of the military departments to develop standards for training to ensure that CORs are fully trained on the contract support in Afghanistan, to include information on the Afghan First program, Counterinsurgency Contracting Guidance, and details on the preparation of statements of work and documents required by the contract review boards.

Direct the Chairman of the Joint Chiefs of Staff and the Secretaries of the military departments to fully institutionalize operational contract support in professional military education to ensure that CORs, commanders, senior leaders, and other personnel expected to perform operational contract support duties are prepared to do so by integrating and expanding the curriculum and by increasing the number of training offerings on operational contract support with a particular emphasis on contingency operations.

Direct the Under Secretary of Defense for Acquisition, Technology, and Logistics in consultation with the appropriate CENTCOM officials to establish and maintain a sufficient number of subject matter experts in specialty areas dedicated to the CENTCOM Joint Theater Support Contracting Command to assist CORs with providing contract oversight.

Direct the Under Secretary of Defense for Acquisition, Technology, and Logistics to develop standards regarding the number of contracts that a COR can manage and oversee based on the technical nature and complexity of the contract.

Agency Comments and Our Evaluation

We provided a draft of this report to DOD for comment. In written comments, DOD concurred with our recommendations. DOD’s comments are reprinted in their entirety in appendix II. DOD also provided technical comments, which we incorporated into the report as appropriate.

DOD concurred with our recommendation that the Secretary of Defense direct the CENTCOM Commander in consultation with the Secretaries of the military departments to develop standards for training to ensure that CORs are fully trained in contract support in Afghanistan, to include information on the Afghan First program, Counterinsurgency Contracting Guidance, and details on the preparation of statements of work and documents required by the contract review boards. DOD stated that CENTCOM has identified COR training in its pre-deployment requirement for units and personnel being deployed to Afghanistan, referring to fragmentary order 09-1700, which lists theater training requirements for forces deploying to the CENTCOM area of responsibility. Although the fragmentary order identifies COR training as a training requirement for certain personnel, the wording in this order lacks the specificity to adequately prepare CORs for contract support in Afghanistan. For example, the fragmentary order does not require that CORs be trained on how to use the Afghan First Program and the Counterinsurgency Contracting Guidance and on how to prepare the statements of work and other documents required by the contract review boards. DOD further stated that CENTCOM reviewed and updated pre-deployment training requirements during a conference in early January 2012, but did not provide any specific information on what those updates entailed. DOD also stated that the COR training requirement will remain as required pre- deployment training and that an updated version of the pre-deployment requirement will be finalized and released no later than April 2012. Because DOD did not provide any specific details on what, if any, changes to training requirements will be included in its April 2012 update, we are unable evaluate the extent to which DOD’s proposed actions would address our recommendations.

DOD concurred with our recommendation that the Secretary of Defense direct the Chairman of the Joint Chiefs of Staff and the Secretaries of the military departments to fully institutionalize OCS in professional military education by increasing the number of training offerings with a particular emphasis on contingency operations to ensure that CORs, commanders, senior leaders, and other personnel expected to perform OCS duties are prepared to do so. DOD stated that the Deputy Assistant Secretary of Defense for Program Support in the Office of the Under Secretary of Defense for Acquisition, Technology and Logistics and the Director of Logistics in the Joint Staff are currently engaged in a study to develop a strategy for OCS professional military education and that DOD recognizes the need for a holistic view of the entire OCS education requirement. DOD said it will assess existing professional military education to recommend OCS learning objectives for appropriate places in existing curricula. Additionally, DOD stated that the Army has recently taken major steps to improve training for commanders, senior leaders, and personnel expected to perform OCS duties. However, DOD did not describe what specific steps DOD has taken to fully institutionalize OCS in professional military education. Further, while it is commendable that DOD is developing a strategy for the OCS professional military education, DOD did not indicate when its strategy would be completed. Until DOD expands the curriculum and increases the number of training offerings on OCS, contract management and oversight in Afghanistan will continue to be hindered.

DOD concurred with our recommendation that the Secretary of Defense direct the Under Secretary of Defense for Acquisition, Technology, and Logistics in consultation with the appropriate CENTCOM officials to establish and maintain a sufficient number of subject matter experts in specialty areas dedicated to the CENTCOM Joint Theater Support Contracting Command to assist CORs with providing contract oversight. DOD stated that the Undersecretary of Defense for Acquisition, Technology, and Logistics will work through the Joint Staff to have CENTCOM identify the requirements for dedicated subject matter experts and the military departments to source these positions within budget constraints, and that the subject matter experts will be sourced through the normal requirements process. We agree that this proposed strategy has the potential to address our recommendation to establish and maintain a sufficient number of subject matter experts in specialty areas.

DOD concurred with our recommendation that the Secretary of Defense direct the Under Secretary of Defense for Acquisition, Technology, and Logistics develop standards regarding the number of contracts that a COR can manage and oversee based on the technical nature and complexity of the contract. DOD agreed that there is a limit to the number of contracts that a COR can support. Further, DOD stated that the Under Secretary of Defense for Acquisition, Technology, and Logistics will develop and publish appropriate standards based on the technical nature and complexity of the contract. We agree that these actions, if fully implemented, would address the intent of our recommendation.

We are sending copies of this report to interested congressional committees, the Secretary of Defense, the Chairman of the Joint Chief of Staff, the Under Secretary of Defense for Personnel and Readiness, the Under Secretary of Defense for Acquisition, Technology & Logistics, Secretaries of the Army, Navy and Air Force, the Commandant of the Marine Corps, and the Commander of CENTCOM. This report will be available at no charge on GAO’s website, http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (404) 679-1808 or russellc@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this letter. GAO staff who made key contributions are listed in appendix III.

Appendix I: Scope and Methodology

To determine the extent to which the required Department of Defense (DOD) training prepares contracting officer’s representatives (COR) to perform their management and oversight duties in Afghanistan, we examined guidance, evaluated the content of the required training, and interviewed CORs and senior contracting personnel from over 30 defense organizations and units in Bagram, Kabul, Kandahar, and Camp Leatherneck, Afghanistan. We examined guidance such as the Joint Publication 4-10, the Defense Contingency Contracting Officer’s Representative Handbook and the U.S. Central Command (CENTCOM) Joint Theater Support Contracting Command Standard Operating Procedures addressing the CORs program to identify training requirements for CORs in contingency areas such as Afghanistan. To evaluate the content of the training, we attended training for CORs at Fort Carson, Colorado, and completed the Defense Acquisition University’s online CORs contingency courses. We reviewed documents such as the program of instructions or course syllabus and other related training documents on the curriculum. We interviewed commanders, senior leaders, and contracting personnel from the Office of the Secretary of Defense, the Joint Staff, the combatant commands, service headquarters, the Defense Contract Management Agency, and defense universities to obtain a comprehensive understanding of what training was available for CORs in Afghanistan. To help determine what knowledge CORs needed to perform their management and oversight responsibilities, we reviewed contract-related documents such as contracts, purchase requisitions, and statements of work.

To determine the extent to which CORs have the appropriate subject area-related technical expertise to oversee contracts in Afghanistan, we reviewed the CENTCOM Joint Theater Support Contracting Command Standard Operating Procedure addressing the CORs program and the Defense Contingency Contracting Officer’s Representative Handbook. We spoke with commanders, senior leaders, senior contracting personnel, and CORs in Afghanistan to understand the degree of subject area-related technical expertise possessed by CORs for contracts they were assigned to manage and the extent to which subject matter experts were available to provide technical support to CORs. We examined contract-related documents such as contracts and training transcripts to assess the technical requirements of the contract as well as the technical background of CORs.

To determine the extent to which the number of CORs is sufficient to manage the contracts in Afghanistan, we examined the CENTCOM Joint Theater Support Contracting Command guidance and the Defense Contingency Contracting Officer’s Representative Handbook to identify requirements related to the workload of CORs. We interviewed senior DOD contracting personnel and CORs to determine whether there was a sufficient number of CORs to manage the contracts in Afghanistan. In addition, we met with CORs to identify their contract workload and the nature of contracts they were assigned to manage.

We selected units to interview that would be in Afghanistan and available during the time of our visit based on input from service officials as well as status reports from the U.S. Army, the U.S. Air Force, and the U.S. Army National Guard. To facilitate our meetings with CORs and contracting personnel in Afghanistan, we developed a set of structured questions that were pre-tested and coordinated with service contracting experts to help ensure that we had solicited the appropriate responses. We selected and examined photographs of supplies and services provided to us by the DOD personnel to best illustrate the nature of the contract support issues we encountered in Afghanistan.

During our review, we visited or contacted key officials, CORs, senior contracting and other contracting personnel from DOD components and entities in the United States and in Afghanistan.

DOD Components and Entities in the United States

DOD Components and Entities in Afghanistan

U.S. Forces Afghanistan, South

Joint Sustainment Command Afghanistan

Defense Contract Management Agency

Logistics Civil Augmentation Program

Regional Contracting Center

101th Combat Aviation Brigade

3rd Naval Construction Regiment

451st Air Expeditionary Wing

1st Brigade Combat Team/4th Infantry Division

Defense Contract Management Agency

Logistics Civil Augmentation Program

Regional Support Command

Logistics Civil Augmentation Program

Division/Marine Headquarters Group, I Marine Expeditionary Force

Marine Aircraft Wing Marine Logistics Group, I Marine Expeditionary

Operational Contract Support team, I Marine Expeditionary Force

C-8 Comptroller, I Marine Expeditionary Force

Camp Leatherneck Commandant, I Marine Expeditionary Force

U.S. Central Contracting Command

Defense Contract Management Agency

Logistics Civil Augmentation Program

Senior Contracting Officer – Afghanistan

Task Force Spotlight

Task Force 2010

717th Expeditionary Air Support Operations Squadron

Regional Contracting Center

Combined Joint Task Force Four

Defense Contract Management Agency

Defense Contract Audit Agency

2nd Brigade, 34th Infantry Division

17th Combat Support Sustainment Brigade

Combined Joint Task Force-101 CJ 4 & 8

46th Military Police We performed our audit work from April 2010 to March 2012 in accordance with generally accepted government auditing standards. Generally accepted government auditing standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for this assessment based on our audit objectives.

Appendix II: Comments from the Department of Defense

Appendix III: GAO Contact and Staff Acknowledgments

GAO Contact

Cary B. Russell, (404) 679-1808 or russellc@gao.gov.

Staff Acknowledgments

In addition to the contact named above, William Solis, Director; David Schmitt, Assistant Director; Carole Coffey, Assistant Director; Tracy Burney, Alfonso Garcia, Christopher Miller, Michael Shaughnessy and Natasha Wilder made key contributions to this report. Peter Anderson, Kenneth Cooper, Branch Delaney, Mae Jones and Amie Steele provided assistance in report preparation.