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entitled 'Contingency Contracting: DOD, State, and USAID Contracts and 
Contractor Personnel in Iraq and Afghanistan' which was released on 
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United States Government Accountability Office: 
GAO: 

October 2008: 

Report to Congressional Committees: 

Contingency Contracting: 

DOD, State, and USAID Contracts and Contractor Personnel in Iraq and 
Afghanistan: 

GAO-09-19: 

GAO Highlights: 

Highlights of GAO-09-19, a report to congressional committees. 

Why GAO Did This Study: 

The Departments of Defense (DOD) and State and the United States Agency 
for International Development (USAID) have relied extensively on 
contractors to carry out a range of services in Iraq and Afghanistan. 
While recognizing the benefits of using contractors, GAO and others 
have noted the challenges and risks associated with an increased 
reliance on contractors and the ability of agencies to manage their 
growing number of contractors. 

As directed by the National Defense Authorization Act for Fiscal Year 
2008, GAO analyzed DOD, State, and USAID data on contracting activities 
in Iraq and Afghanistan for fiscal year 2007 and the first half of 
fiscal year 2008 including (1) the number and value of contracts and 
the extent they were awarded competitively; (2) the number of 
contractor personnel, including those performing security functions; 
and (3) the number of contractor personnel who were killed or wounded. 
GAO also reviewed the status of the three agencies’ memorandum of 
understanding (MOU) related to maintaining data on contracts and 
contractor personnel. GAO reviewed selected contract files and compared 
personnel data to other available sources to assess the reliability of 
the data reported by the agencies. 

GAO provided a draft of this report to DOD, State, USAID, and the 
Department of Labor for comment. State and USAID provided technical 
comments that were incorporated where appropriate. 

What GAO Found: 

For the 18-month period GAO reviewed, DOD, State, and USAID reported 
obligating at least $33.9 billion on almost 57,000 contracts for 
efforts such as construction, capacity building, security, and a range 
of support services for U.S. forces and other government personnel in 
Iraq and Afghanistan. About three-fourths of the reported obligations 
were for contracts with performance in Iraq. Of the total obligations, 
DOD accounted for almost 90 percent. Most of the three agencies’ active 
contracts were awarded during GAO’s review period and of these, about 
two-thirds were competed to one extent or another. However, during its 
file reviews in Iraq and Afghanistan, GAO found that DOD may have 
understated the extent to which it competed some contracts. 

Complete and reliable data were not available for GAO to determine the 
total number of contractor personnel who worked on DOD, State, and 
USAID contracts in Iraq and Afghanistan. According to DOD’s quarterly 
census, there were 197,718 contractor personnel working on its 
contracts in Iraq and Afghanistan as of April 2008. However, DOD did 
not routinely evaluate the data for accuracy and the number of local 
nationals working on contracts may be underreported. Neither State nor 
USAID had systems in place during our review period to track the number 
of contractor personnel. As a result, they could not provide complete 
personnel data. For example, while State and USAID had information from 
their contractors on the number of personnel performing security and 
demining functions in Afghanistan, they did not have similar 
information on personnel performing other functions in Afghanistan. 

According to DOD and State officials, information on killed and wounded 
contractor personnel was not systematically tracked, which left them 
unable to provide reliable or complete data. While USAID could not 
provide specifics on its contractor personnel, USAID informed us that 
206 individuals working on its projects, including contractor 
personnel, had been killed or injured in Iraq and Afghanistan during 
GAO’s review period. Data available from Labor provides insight into 
the number of contractor personnel killed or injured as a result of 
hostile actions, accidents, and other causes while working on U.S. 
government contracts. Based on data provided by Labor, there were 455 
reports received of contractors killed in Iraq and Afghanistan during 
the period of our review and 15,787 reports of injuries. However, there 
may be additional contractor deaths or injuries that were not reported 
to Labor. 

In July 2008, the three agencies signed an MOU in which they agreed to 
use a DOD database to collect and maintain information on contracts and 
contractor personnel in Iraq and Afghanistan. According to DOD 
officials, as the agencies work together to implement the MOU, the 
agencies’ ability to report on the number and value of contracts and 
the number of contractor personnel should improve. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-09-19]. For more 
information, contact John Hutton at (202) 512-4841 or huttonj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Scope and Methodology: 

Summary: 

Appendix I: Scope and Methodology: 

Appendix II: DOD Contracting in Iraq and Afghanistan: 

Appendix III: State Contracting in Iraq and Afghanistan: 

Appendix IV: USAID Contracting in Iraq and Afghanistan: 

Appendix V: Defense Base Act Cases for Contractor Personnel Killed or 
Injured in Iraq and Afghanistan: 

Appendix VI: Memorandum of Understanding on Contracting in Iraq and 
Afghanistan: 

Appendix VII: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: DOD Active Contracts and Obligations for Iraq and Afghanistan, 
Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Table 2: DOD New Contract Awards and Obligations for Iraq and 
Afghanistan, Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Table 3: DOD's Competition of Iraq and Afghanistan Contracts (excluding 
task orders) Awarded in Fiscal Year 2007 and the First Half of Fiscal 
Year 2008: 

Table 4: CENTCOM Quarterly Census of DOD Contractor Personnel 
Performing Duties in Iraq and Afghanistan: 

Table 5: State Active Contracts and Obligations for Iraq and 
Afghanistan, Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Table 6: State New Contract Awards and Obligations for Iraq and 
Afghanistan, Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Table 7: State's Competition of Iraq and Afghanistan Contracts 
(excluding task orders) Awarded in Fiscal Year 2007 and the First Half 
of Fiscal Year 2008: 

Table 8: USAID Active Contracts and Obligations for Iraq and 
Afghanistan, Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Table 9: USAID New Contract Awards and Obligations for Iraq and 
Afghanistan, Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Table 10: USAID's Competition of Iraq and Afghanistan Contracts 
(excluding task orders) Awarded in Fiscal Year 2007 and the First Half 
of Fiscal Year 2008: 

Table 11: Defense Base Act Cases for Deaths and Injuries in Iraq and 
Afghanistan by Fiscal Year of Death or Injury, Fiscal Year 2007 and the 
First Half of Fiscal Year 2008: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

October 1, 2008: 

Congressional Committees: 

As of July 2008, the Congress has approved a total of about $859 
billion for the military and diplomatic operations launched since 2001 
as part of the Global War on Terror. The majority of this amount has 
been provided for Department of Defense (DOD) military operations in 
Iraq and Afghanistan. Most of the remaining funds have gone to DOD, 
Department of State, and United States Agency for International 
Development (USAID) efforts to develop Iraq and Afghanistan's 
infrastructure, improve their security forces, and enhance their 
capacity to govern.[Footnote 1] DOD, State, and USAID have relied 
extensively on contractors to support troops and civilian personnel and 
to oversee and carry out reconstruction efforts. Contractors provide a 
range of services--including but not limited to--
interpretation/translation, security, weapon systems maintenance, 
intelligence analysis, facility operations support, and road 
construction--that relate to practically every facet of U.S. efforts in 
Iraq and Afghanistan. 

The use of contractors to support U.S. military operations is not new, 
but the number of contractors and the work they are performing in Iraq 
and Afghanistan represent an increased reliance on contractors to carry 
out agency missions. While recognizing the benefits of using 
contractors--such as increased flexibility in fulfilling immediate 
needs--we and others have noted the risks associated with the increased 
reliance on contractors and the challenges that federal agencies have 
in managing the growing number of contractors and overseeing their 
performance.[Footnote 2] Having reliable and meaningful data on 
contractors and the services they provide is critical for agencies to 
effectively manage and oversee their contractors. The Congress has 
taken a number of actions to increase oversight of contracts. Among 
these, section 861 of the National Defense Authorization Act for Fiscal 
Year 2008[Footnote 3] required DOD, State, and USAID to sign a 
memorandum of understanding (MOU) by July 1, 2008, regarding matters 
relating to contracting in Iraq and Afghanistan, including maintaining 
common databases that will provide the three agencies and the Congress 
with information on contracts and contractor personnel in Iraq or 
Afghanistan. 

The Act also directs that we annually review DOD, State, and USAID 
contracts in Iraq and Afghanistan and report on this review each year 
through 2010.[Footnote 4] The Act specifies that for each reporting 
period we provide (1) the total number and value of contracts[Footnote 
5] that were active and those that were awarded[Footnote 6] for 
performance in Iraq or Afghanistan and the extent to which those 
contracts used competitive procedures, (2) the total number of 
contractor personnel that worked on those contracts, including those 
performing security functions,[Footnote 7] and (3) the number of 
contractor personnel killed or wounded. This first report provides the 
results of our analyses of agency-reported data for fiscal year 2007 
and the first half of fiscal year 2008. We are also providing 
information on the status of the agencies' MOU as it relates to 
maintaining data on contracts and contractor personnel in Iraq and 
Afghanistan. 

Scope and Methodology: 

To address our first objective, we obtained data from DOD, State, and 
USAID on the number of active contracts with performance in Iraq and 
Afghanistan during fiscal year 2007 and the first half of fiscal year 
2008 and the amount of funds obligated on those contracts.[Footnote 8] 
We also obtained data on the extent to which contracts were 
competitively awarded during the 18-month period covered by this 
review. After taking steps to standardize the data, such as removing 
duplicates, we compared the reported data to selected contract files in 
the United States, Iraq, and Afghanistan to assess the reliability of 
what was reported. We determined that the reported contract data were 
sufficiently reliable to establish the minimum number of active and 
awarded contracts and obligation amounts, as well as the minimum number 
of competed contracts, for the period of our review. 

To address our second objective, we obtained data from the three 
agencies on the number of contractor personnel for the period of our 
review and discussed with them how they collected and tracked these 
data. To the extent that the agencies were able to provide contractor 
personnel data, we compared that data to other sources, such as 
contract data and information from contracting officers, to determine 
data consistency and reasonableness. We concluded that the personnel 
data were underreported. However, we are presenting the reported data 
along with their limitations as they establish a minimum number of 
contractor personnel and provide insight into the extent to which the 
agencies had information on the number of contractor personnel during 
the period of our review. Given the limitations we found, the data 
presented should not be used to reach conclusions about the total 
number of contractor personnel in Iraq and Afghanistan. 

For our third objective, we requested that agencies provide us with 
data on the number of contractor personnel who had been killed or 
wounded during the period of our review and we discussed with agency 
officials how they collected these data. However, not all of the 
agencies were able to provide complete data, but they did provide what 
data they had available, which for one agency included data on 
individuals other than contractor personnel. We are presenting the 
agencies' data as they provide insight into the extent to which the 
agencies had information on the number of personnel killed or wounded. 
Because of the limitations associated with agencies' data, they should 
not be used to reach conclusions about the total number of contractor 
personnel killed or wounded in Iraq and Afghanistan. Given the 
shortcomings in the three agencies' data, we obtained data from the 
Department of Labor[Footnote 9] on the number of Defense Base Act cases 
for contractor personnel deaths and injuries that occurred in Iraq and 
Afghanistan during our review period to provide further insights on 
contractor casualties.[Footnote 10] To assess the reliability of 
Labor's data, we reviewed existing information about how the data are 
collected and cases are processed and interviewed knowledgeable agency 
officials. We determined that Labor's data were sufficiently reliable 
for the purposes of this report, but the data should not be relied on 
to determine the total number of DOD, State, or USAID contractor 
personnel killed or wounded in Iraq or Afghanistan. 

To provide information on the status of DOD, State, and USAID's MOU as 
it relates to maintaining data on contracts and contractor personnel in 
Iraq and Afghanistan, we obtained and reviewed a copy of the MOU. We 
also met with officials from the three agencies to discuss plans for 
implementing the MOU. 

A more detailed description of our scope and methodology is included in 
appendix I. We conducted this performance audit from March 2008 through 
August 2008 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings 
based on our audit objectives. 

Summary: 

DOD, State, and USAID reported that they obligated at least $33.9 
billion during fiscal year 2007 and the first half of fiscal year 2008 
on 56,925 contracts with performance in either Iraq or Afghanistan. 
Almost three-fourths of the reported obligations were for contracts 
with performance in Iraq, with DOD having significantly more 
obligations than the other two agencies combined. The three agencies' 
contracts were for services and supplies related to efforts such as 
construction and capacity building, as well as a range of support 
services for U.S. military forces and other government personnel. Of 
the agencies' active contracts, almost 97 percent were awarded during 
the 18-month review period. The extent to which the agencies were 
required to compete these contracts depended on where the contract was 
awarded and performed, its dollar value, and the contracting method 
used. For all of the contracts awarded during the review period, the 
agencies reported that about two-thirds were competed to one extent or 
another. Competitively awarded contracts accounted for almost 85 
percent of the obligations on new awards. The agencies reported using 
various competitive procedures, including full and open competition and 
simplified acquisition procedures, such as competitions among 
prequalified companies. However, DOD may have understated the extent to 
which it competed new awards. Of the 85 files we reviewed in Iraq and 
Afghanistan, we found 14 instances in which DOD reported that the 
contract had not been competitively awarded but the files indicated 
that competitive procedures were used to award the contract. 

Complete and reliable data were not available for us to determine the 
total number of contractor personnel, including those performing 
security functions, who worked on DOD, State, and USAID contracts in 
Iraq and Afghanistan during fiscal year 2007 and the first half of 
fiscal year 2008.[Footnote 11] During our review period, DOD initiated 
systems to track contractor personnel at the prime and subcontract 
levels in Iraq and Afghanistan. According to its quarterly census, 
there were 197,718 contractor personnel working on DOD contracts in 
Iraq and Afghanistan as of April 2008. However, DOD officials explained 
that data obtained from the census were not routinely evaluated for 
accuracy or completeness and there was reason to believe that the 
number of local nationals working on contracts was underreported. 
Additionally, DOD reported almost 25,000 individuals working on 
security contracts, but based on information from DOD and our analyses, 
that number also appears to be inaccurate with both duplicate and 
missing personnel. Unlike DOD, State and USAID did not have systems in 
place during the period we reviewed to track the number of contractor 
personnel in Iraq and Afghanistan and therefore could not provide 
complete data on their contractor personnel. However, based on queries 
made to their contractors, State reported that 7,192 contractor 
personnel were working in Iraq and Afghanistan as of July 2008, while 
USAID reported 5,150 contractor personnel as of early 2008. These 
numbers understate the number of State and USAID contractor personnel. 
For example, State's numbers for Afghanistan only included personnel 
performing security and demining functions. Similarly, USAID's numbers 
for Afghanistan only included personnel performing security functions, 
with a USAID official acknowledging that not all contractors had 
responded to the request for personnel data. Contractor personnel 
performing other functions, such as police training, in Afghanistan 
were not included in State or USAID's numbers. 

DOD, State, and USAID were unable to provide complete or specific 
information on the number of contractor personnel who had been killed 
or wounded in Iraq or Afghanistan during the period of our review. DOD 
and State officials told us that information on killed or wounded 
contractor personnel was not systematically maintained or tracked in a 
manner that would allow the agencies to provide us reliable or complete 
data. Despite the lack of systems for tracking such data, DOD and State 
provided what information they had available on killed or wounded 
contractor personnel. For example, State informed us that based on an 
inquiry of its contractors, it was aware of 23 personnel who were 
killed in Iraq and Afghanistan during 2007, but it did not have 
information on the number wounded. USAID did have a process for 
tracking contractor personnel who were killed or wounded. USAID 
informed us that 105 individuals working on USAID programs in Iraq and 
Afghanistan had been killed and 101 individuals had been wounded or 
injured. However, USAID was unable to specify how many of these 
individuals were contractor personnel as opposed to individuals working 
on grants or otherwise working to implement USAID programs. Department 
of Labor data provide additional insight into the number of contractor 
casualties in Iraq and Afghanistan. Labor maintains data on cases 
reported to it under the Defense Base Act for contractor personnel 
killed or injured while working on U.S. government contracts overseas, 
including those in Iraq and Afghanistan. According to data provided by 
Labor, there were 455 cases of contractor personnel killed and 15,787 
cases of injuries in Iraq and Afghanistan during our review period. 
[Footnote 12] Deaths or injuries not reported to Labor would not be 
included in its data, so according to Labor officials, it is possible 
that the actual number of deaths or injuries in Iraq and Afghanistan is 
higher than the number of Defense Base Act cases. 

DOD, State, and USAID signed a MOU in July 2008, agreeing to use the 
Synchronized Pre-Deployment and Operational Tracker (SPOT) database 
[Footnote 13] to collect and maintain information on contracts and 
contractor personnel in Iraq and Afghanistan. Although the Act did not 
specify a minimum dollar value threshold above which contracts should 
appear in the database, the MOU established a $100,000 threshold. 
Pursuant to the MOU, DOD is responsible for maintaining the SPOT 
database, but it is the responsibility of each agency to ensure that 
information is accurately entered into SPOT. DOD is already using SPOT 
to track information on some contractor personnel. State has also 
started ensuring that its contractors enter data on their personnel 
into SPOT and USAID is making plans to do so. Because SPOT does not 
currently capture all contract and contractor personnel data specified 
in the MOU, DOD officials informed us that they have planned a number 
of upgrades over the next several months. These include adding a field 
to indicate whether a contractor has been killed or wounded and linking 
SPOT to an existing government wide database on contracts so that data 
on contract value and competition do not have to be entered separately 
into SPOT. According to DOD officials, as the agencies work together to 
implement the MOU provisions and upgrades are made to facilitate SPOT's 
use and track required information, such as contractor casualties, the 
agencies' ability to report on the number and value of contracts and 
the number of contractor personnel should improve. 

We provided a draft of this report to DOD, State, USAID, and Labor for 
review and comment. State and USAID provided technical comments, which 
we incorporated into this report where appropriate, while DOD and Labor 
had no comments. 

Specific information on DOD contracts and contractor personnel can be 
found in appendix II, on State contracts and contractor personnel in 
appendix III, and on USAID contracts and contractor personnel in 
appendix IV, while data from Labor on Defense Base Act claims can be 
found in appendix V. Additional information regarding the agencies' MOU 
can be found in appendix VI. 

We are sending copies of this report to the Secretary of Defense, the 
Secretary of State, the Administrator of the United States Agency for 
International Development, the Secretary of Labor, and interested 
congressional committees. Copies will also be made available to others 
on request. In addition, the report will be available at no charge on 
GAO's Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions concerning this report, please 
contact me at (202) 512-4841. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. GAO staff who made major contributions to this 
report are listed in appendix VII. 

Signed by: 

John Hutton: 
Director: 
Acquisition and Sourcing Management: 

List of Committees: 

The Honorable Carl Levin: 
Chairman: 
The Honorable John McCain: 
Ranking Member: 
Committee on Armed Services: 
United States Senate: 

The Honorable Ike Skelton: 
Chairman: 
The Honorable Duncan Hunter: 
Ranking Member: 
Committee on Armed Services: 
House of Representatives: 

The Honorable Joseph I. Lieberman: 
Chairman: 
The Honorable Susan M. Collins: 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Henry A. Waxman: 
Chairman: 
The Honorable Tom Davis: 
Ranking Member: 
Committee on Oversight and Government Reform: 
House of Representatives: 

The Honorable Joseph R. Biden, Jr. 
Chairman: 
The Honorable Richard G. Lugar: 
Ranking Member: 
Committee on Foreign Relations: 
United States Senate: 

The Honorable Howard L. Berman: 
Chairman: 
The Honorable Ileana Ros-Lehtinen: 
Ranking Member: 
Committee on Foreign Affairs: 
House of Representatives: 

The Honorable John D. Rockefeller IV:
Chairman:
The Honorable Christopher S. Bond:
Vice Chairman:
Select Committee on Intelligence:
United States Senate: 

The Honorable Silvestre Reyes:
Chairman:
The Honorable Peter Hoekstra:
Permanent Select Committee on Intelligence:
House of Representatives: 

[End of section] 

Appendix I: Scope and Methodology: 

Section 863 of the National Defense Authorization Act for Fiscal Year 
2008[Footnote 14](Act) directs GAO to review and report on specific 
elements related to Department of Defense (DOD), Department of State, 
and United States Agency for International Development (USAID) 
contracts in Iraq and Afghanistan. In response to that mandate, we 
analyzed agency-reported data for fiscal year 2007 and the first half 
of fiscal year 2008 regarding (1) the number and value of DOD, State, 
and USAID contracts with work in Iraq and Afghanistan and the extent to 
which that work was awarded competitively, (2) the number of DOD, 
State, and USAID contractor personnel, including those performing 
security functions, that worked on those contracts, and (3) the number 
of contractor personnel that were killed or wounded. We also reviewed 
the status of the agencies’ memorandum of understanding (MOU) as it 
relates to maintaining data on contracts and contractor personnel in 
Iraq and Afghanistan. 

Contracts in Iraq and Afghanistan: 

To address our first objective, we obtained data from DOD, State, and
USAID on the number of active and awarded contracts in Iraq and
Afghanistan during fiscal year 2007 and the first half of fiscal year 
2008, the extent to which those contracts were competitively awarded, 
and the amount of funds obligated on those contracts during the 18-
month period covered by our review.[Footnote 15] As we explain below, 
after we assessed the contract data provided by each agency, we 
determined the data were sufficiently reliable to determine the minimum 
number of active and awarded contracts and obligation amounts,[Footnote 
16] as well as the minimum number of competed contracts, for the period 
of our review. We could not rely on queries of the Federal Procurement 
Data System – Next Generation (FPDS-NG), which is the federal 
government’s current system for tracking information on contracting 
actions, as the primary source of data for our review. This was the 
case, in part, because in a prior related review we found that needed 
data were not always available from FPDSNG due to the way individual 
agencies were and were not reporting individual contract actions. 
[Footnote 17] We found that this continued to be the case. For example, 
individual contract actions by DOD’s Joint Contracting 
Command—Iraq/Afghanistan, as well as some USAID actions, were not 
entered into FPDS-NG. Also, we and others have reported on limitations 
associated with FPDS-NG data.[Footnote 18] 

As the agencies provided us with their contract data, we took steps to
standardize their data to facilitate our analyses. This included 
removing contracts with no obligations or deobligations during our 
period of review,[Footnote 19] obligations that occurred outside the 
period of our review, and duplicate contract actions. In some cases we 
excluded values when the agencies reported the total estimated cost of 
the contract instead of obligations to limit overstating the amounts 
obligated during the period of our review.[Footnote 20] Since the 
agencies used various numbering conventions to identify contracts, 
orders, and modifications, we reformatted the data so we could identify 
the unique contracts and orders and any associated modifications. 
Additionally, we categorized the competition information reported on 
contracts awarded during our review period. In many cases, the agencies 
simply reported “yes” or “no” as to whether the contract was competed, 
but in other cases they reported additional data on the extent of 
competition, such as whether full and open competition occurred. If the
agencies reported any type of competition, such as full and open 
competition or simplified acquisition procedures as defined in the 
Federal Acquisition Regulation, we categorized the contract as 
“competed.”[Footnote 21] We categorized contracts for which agencies 
reported that competition did not occur, such as those reported as sole 
source contracts, as “not competed.” We categorized contracts for which 
the agencies either provided no competition information or provided 
information that was not sufficient to determine whether competition 
occurred as “not reported.” 

In analyzing the reported contract data from the three agencies, we
identified the total number of contracts by counting the unique 
contracts that had obligations each fiscal year. Since some contracts 
had obligations in both fiscal year 2007 and the first half of fiscal 
year 2008, the number of active contracts for the entire period of our 
review is lower than the number of active contracts in fiscal year 2007 
plus the number active in the first half of fiscal year 2008. In 
counting the number of contracts, we excluded the base contracts under 
which task orders were issued. This was done, in part, because such 
base contracts do not have obligations associated with them as the 
obligations are incurred with the issuance of each task order. All 
other contracts, task orders, delivery orders, and purchase orders were 
included in the count along with their associated obligations. The 
agencies were unable to provide data on the number or value of 
individual subcontracts and we were therefore unable to report
these totals as required by the Act. 

To assess the reliability of the contract data each agency reported, we
matched the data on selected contract actions to information in the
agencies’ contract files. While we identified some discrepancies between
what the agencies reported and what appeared in the files, we determined
that the reported data were sufficiently reliable for our purposes when
presented with the appropriate caveats. The following is a summary of 
the review of contract data and files conducted at each agency and our 
results: 

* DOD—Because DOD’s reported data came from multiple DOD components, we 
selected actions for review from the components that collectively 
represented 99 percent of the contracts and 98 percent of the 
obligations reported to us.[Footnote 22] 
- For contracts awarded by the Joint Contracting Command— 
Iraq/Afghanistan, we limited our random sample to contract actions
with contract files identified as being physically located in Baghdad or
Kabul. During the course of our file review in Baghdad, we learned that
some of the randomly selected actions could not be found or
accounted for, but we were able to review 44 actions. We were also
able to complete our review of 41 randomly selected files in Kabul. For
the 85 actions reviewed, we identified relatively few discrepancies
between the information in the files and the data reported to us, with
the exception of the competition data. As discussed in the report, we
identified cases in which competition was underreported.
- For contracts awarded by the Air Force and Navy, we randomly
selected 30 contract actions for each service and reviewed the
associated files on-line using DOD’s Electronic Document Access
(EDA) system to validate all of the information except that pertaining
to competition. Air Force and Navy officials sent us selected portions
of contract files so we could validate the reported competition
information. We identified some discrepancies pertaining to the
modification number and the obligation amounts but determined that
they were not significant enough to affect our count of contracts and
their associated obligations. 
- For contracts awarded by the Army, we reviewed 30 randomly selected
contract actions in EDA and reviewed the associated on-line 
documentation. We identified minor discrepancies between the 
information in EDA and the information reported to us. However, we
did not separately assess the Army’s reported competition information.
- For contracts awarded by the Defense Logistics Agency (DLA), we
took a different approach due to how DLA reported its data to us. We
assessed the reliability of DLA's data by reviewing information about
its data systems and interviewing an agency official knowledgeable
about the data. We determined that the data were sufficiently reliable
for our purposes. 

On the basis of our comparison of the reported data to the information
contained in DOD’s files, we determined that the DOD-reported data were
sufficiently reliable to determine the minimum number of active and
awarded contracts and obligation amounts, as well as the minimum
number of competed contracts. 

* State—We reviewed files for 30 randomly selected contract actions
performed by State’s Office of Acquisition Management. This office
performed 20 percent of the contract actions and 80 percent of the
obligations reported to us. We identified very few discrepancies between
what was reported and what appeared in the files. As a result, we
determined that State’s reported data were sufficiently reliable to
determine the minimum number of active and awarded contracts and
obligation amounts, as well as the minimum number of competed
contracts. 

* USAID—For contracts awarded in Iraq, we compared 36 randomly
selected contract actions to information in files located at the USAID
mission in Baghdad. We identified very few discrepancies between what
was reported to us and what was in the files. For contracts awarded in
Afghanistan, we compared 56 randomly selected contract actions to
information in the files located at the USAID mission in Kabul. In
reviewing those files, we determined that 6 were outside the scope of 
our review. For the remaining 50 actions, we identified very few 
discrepancies. Based on our comparison of the reported data to the 
information contained in USAID’s files, we determined that USAID’s 
reported data were sufficiently reliable to determine the minimum 
number of active and awarded contracts and obligation amounts, as well 
as the minimum number of competed contracts. 

Contractor Personnel in Iraq and Afghanistan: 

To address our second objective, we obtained data from DOD, State, and
USAID on the number of U.S. nationals, third country nationals, and 
local nationals working on contracts with performance in Iraq or 
Afghanistan during the period of our review.[Footnote 23] These data 
included individuals reported to be performing security functions. 
[Footnote 24] DOD provided us with data from the U.S. Central Command’s 
(CENTCOM) quarterly census and the Synchronized Predeployment and 
Operational Tracker (SPOT) databases. We also reviewed relevant DOD 
orders and guidance related to the census and SPOT. As we discuss in 
the report, State and USAID officials told us they did not have data 
systems to track the number of personnel in Iraq and Afghanistan during 
our review period. However, they provided us with data available from 
periodic inquiries they had sent to their contractors. 

To the extent the agencies were able to provide contractor personnel 
data for the period of our review,[Footnote 25] we compared that data 
to other sources, such as contract data and information from 
contracting offices, to determine data consistency and reasonableness. 
All three agencies reported more active contracts than they provided 
personnel data for, which led us to conclude that the personnel data 
were underreported. We also identified discrepancies between the 
agencies’ reported data and the data available from other sources. 
Furthermore, we discussed with agency officials the limitations and 
challenges they experienced in obtaining information on the number of 
contractor personnel, particularly for the period of our review. We are 
presenting the reported data along with their limitations as they 
establish a minimum number of contractor personnel and provide insight 
into the extent to which the agencies had information on the number of 
contractor personnel during the period of our review. Given the 
limitations we found, the data presented should not be used to reach 
conclusions about the total number of contractor personnel in Iraq and 
Afghanistan during our review period. 

Killed or Wounded Contractor Personnel: 

To address our third objective, we requested data from DOD, State, and
USAID on the number of contractor personnel killed or wounded during
the period of our review. After informing us they did not have a 
reliable system for tracking contractor casualties, DOD officials 
directed us to use the Department of Labor’s data on Defense Base Act 
(DBA) cases to determine the number of killed or wounded contractor 
personnel in Iraq and Afghanistan. In addition, some DOD components 
provided us with data they had available on killed or wounded 
contractor personnel, but we could not independently verify the data 
they provided. Similarly, State officials told us they did not have a 
data system to track contractor personnel killed or wounded in Iraq and 
Afghanistan during the period of our review, but they provided what 
information they had available based on contractor reports. USAID 
provided us with information on deaths and injuries it had compiled 
from its implementing partners, including contractors, in Iraq and 
Afghanistan but did not distinguish between contractor personnel and 
others. While we did not establish the reliability of the numbers 
provided to us by the agencies, we are nevertheless providing them as 
they provide insight into the extent to which the agencies had 
oversight of the number of personnel killed or wounded during the 
period of our review. Because of the limitations associated with the 
agencies’ data, they should not be used to reach conclusions about the
total number of DOD, State, or USAID contractor personnel killed or
wounded in Iraq and Afghanistan. 

We also obtained data from Labor on cases reported to it for contractor
injuries or deaths that occurred in Iraq or Afghanistan during fiscal 
year 2007 and the first half of fiscal year 2008. Labor provided us 
with data on cases as of August 7, 2008, for injuries and deaths that 
occurred during the period of our review.[Footnote 26] We assessed the 
reliability of Labor’s data by reviewing existing information about the 
data and interviewing agency officials knowledgeable about the data. We 
determined that the data were sufficiently reliable for providing 
insight into the number of contractor casualties when presented with 
the appropriate caveats. In tracking DBA cases, Labor officials told us 
they do not collect information on the agency or contract that 
claimants worked under and, therefore, could not identify which 
injuries or deaths were sustained by contractor personnel working on 
DOD, State, and USAID contracts. As a result, the data presented are 
for contractor personnel, regardless of nationality, working under all 
U.S. government agencies’ contracts—not just DOD, State, or USAID 
contracts. Labor officials also explained that they do not track how 
deaths or injuries occurred, so it is not possible to determine whether 
a death or injury was the result of hostile actions, accidents, or 
natural and other causes. Labor’s data, therefore, should not be relied 
on to determine the total number of DOD, State, or USAID contractor 
personnel killed or wounded in Iraq or Afghanistan. 

Memorandum of Understanding: 

To provide information on the status of DOD, State, and USAID’s MOU as
it relates to maintaining data on contracts and contractor personnel in 
Iraq and Afghanistan, we obtained and reviewed a copy of the MOU. We 
also met with senior DOD, State, and USAID officials to discuss plans 
for implementing the MOU and making changes to the SPOT database.
Additionally, we talked with officials from all three agencies 
regarding the use of SPOT and how they are or are not currently 
tracking the information that will eventually be captured in SPOT. 

We conducted this performance audit from March 2008 through August 2008 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings based on our audit objectives. We believe that the evidence 
obtained provides a reasonable basis for our findings based on our audit
objectives. 

[End of section] 

Appendix II: DOD Contracting in Iraq and Afghanistan: 

This appendix provides information on the Department of Defense’s (DOD) 
contracts, contractor personnel, and contractor personnel killed or 
wounded in Iraq and Afghanistan during fiscal year 2007 and the first 
half of fiscal year 2008. The first section of this appendix presents 
our analyses of DOD-reported data on the number and value of contracts 
and the extent to which these contracts were competed. In the second 
and third sections, we present DOD-provided information on contractor 
personnel and the number of killed or wounded contractor personnel, as 
well as some of the limitations associated with that information. 

DOD Contracts in Iraq and Afghanistan: 

DOD reported at least $30.3 billion in obligations on 55,603 contracts
active in Iraq or Afghanistan during fiscal year 2007 and the first 
half of fiscal year 2008.[Footnote 27] As shown in table 1, there were 
nearly twice as many contracts with performance in Iraq as in 
Afghanistan, and more than four times more obligations on contracts 
performed in Iraq as in Afghanistan. 

Some DOD contracts with performance in Iraq and Afghanistan also 
included work outside those two countries. For example, the Navy 
reported multiple contracts with work in Iraq, Afghanistan, and the 
United States. Similarly, the Air Force reported that a number of its 
contracts included performance in both Iraq and Kuwait. However, in 
such cases, it was not possible based on the data reported to us to 
determine what portion of the obligated amount was for work in Iraq or 
Afghanistan. As a result, we counted contracts with performance in 
multiple countries and their associated obligations with the Iraq 
contracts if DOD identified the place of performance as including Iraq, 
but not Afghanistan. Similarly, we counted contracts and their 
associated obligations with the Afghanistan contracts if the place of 
performance included Afghanistan, but not Iraq. For contracts with 
performance in both Iraq and Afghanistan as well as contracts where DOD 
indicated that performance was in Iraq or Afghanistan but did not 
specify which country, we counted the contracts and their associated 
obligations as “other.” 

Table 1: DOD Active Contracts and Obligations for Iraq and Afghanistan, 
Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Afghanistan: 
Fiscal year 2007: Number of active contracts: 12,743; 
Fiscal year 2007: Obligation amount (in millions): $3,192.2; 
First half of fiscal year 2008: Number of active contracts: 6,543; 
First half of fiscal year 2008: Obligation amount (in millions): 
$1,903.6; 
Fiscal year 2007 and first half of fiscal year 2008: Number of active 
contracts: 18,889[A]; 
Fiscal year 2007 and first half of fiscal year 2008: Obligation amount 
(in millions): $5,095.7. 

Iraq: 
Fiscal year 2007: Number of active contracts: 24,667; 
Fiscal year 2007: Obligation amount (in millions): $14,182.2; 
First half of fiscal year 2008: Number of active contracts: 12,553; 
First half of fiscal year 2008: Obligation amount (in millions): 
$8,541.5; 
Fiscal year 2007 and first half of fiscal year 2008: Number of active 
contracts: 36,485[A]; 
Fiscal year 2007 and first half of fiscal year 2008: Obligation amount 
(in millions): $22,723.7. 

Other: 
Fiscal year 2007: Number of active contracts: 149; 
Fiscal year 2007: Obligation amount (in millions): $1,621.7; 
First half of fiscal year 2008: Number of active contracts: 123; 
First half of fiscal year 2008: Obligation amount (in millions): 
$861.5; 
Fiscal year 2007 and first half of fiscal year 2008: Number of active 
contracts: 229[A]; 
Fiscal year 2007 and first half of fiscal year 2008: Obligation amount 
(in millions): $2,483.2. 

Total: 
Fiscal year 2007: Number of active contracts: 37,559; 
Fiscal year 2007: Obligation amount (in millions): $18,996.0; 
First half of fiscal year 2008: Number of active contracts: 19,219; 
First half of fiscal year 2008: Obligation amount (in millions): 
$11,306.6; 
Fiscal year 2007 and first half of fiscal year 2008: Number of active 
contracts: 55,603[A]; 
Fiscal year 2007 and first half of fiscal year 2008: Obligation amount 
(in millions): $30,302.6. 

Source: GAO analysis of DOD data. 

Note: Total obligations may not add due to rounding. 

[A] Some contracts were active in both fiscal year 2007 and the first 
half of fiscal year 2008. As a result, the total number of active 
contracts during the 18-month period of our review is less than the 
number that were active each year added together. Obligation amounts 
are unique to each fiscal year so total obligations for the entire 
period are the sum of obligations in each fiscal year. 

[End of table] 

DOD’s contracts, which were awarded by contract offices in the United 
States and abroad, were for a variety of goods and services including 
maintenance of DOD facilities, reconstruction, security, and supplies. 
These goods and services were obtained using different contracting 
methods. The majority of DOD contracts were purchase orders,[Footnote 
28] but purchase orders represented a relatively small amount of the 
reported obligations. In contrast, DOD reported relatively few active 
task orders, but nearly 70 percent of DOD’s obligations were for task 
orders. These included orders against DOD logistic support contracts, 
such as the Army’s Logistics Civil Augmentation Program (LOGCAP) 
contract that provides food service, housing, and other services for 
U.S. military personnel in southwest and central Asia. The Army 
obligated more than $6 billion for a single LOGCAP task order during 
the period of our review. 

While we were mandated to identify the total number and value of all 
DOD contracts, which is defined to mean prime contracts, task orders, 
and subcontracts at any tier, DOD was unable to provide data on the 
number of subcontracts or information on the value of individual 
subcontracts with performance in Iraq and Afghanistan. For the period 
of our review, 

DOD officials informed us that they did not track or maintain data on 
the extent to which DOD contractors subcontracted portions of their 
work. Furthermore, there was no requirement to do so. Although the 
number and value of individual subcontracts cannot be determined from 
the data DOD reported, the value of the subcontracted work is captured 
within the amounts DOD obligated to its prime contractors. 

Of the DOD contracts that were active in Iraq and Afghanistan during 
fiscal year 2007 and the first half of fiscal year 2008, almost all of 
them were awarded during that 18-month period (see table 2). These 
newly awarded contracts accounted for approximately 60 percent of DOD’s 
obligated funds. DOD’s remaining obligations were made on contracts 
awarded in fiscal year 2006 or earlier. 

Table 2: DOD New Contract Awards and Obligations for Iraq and 
Afghanistan, Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Afghanistan: 
Fiscal year 2007: Number of new awards: 12,335; 	
Fiscal year 2007: Obligation amount (in millions): $1,946.9[A]; 
First half of fiscal year 2008: Number of new awards: 6,091; 
First half of fiscal year 2008: Obligation amount (in millions): 
$820.4. 

Iraq: 
Fiscal year 2007: Number of new awards: 23,559; 	
Fiscal year 2007: Obligation amount (in millions): $8,417.4[A]; 
First half of fiscal year 2008: Number of new awards: 11,675; 
First half of fiscal year 2008: Obligation amount (in millions): 
$3,257.9. 

Other: 
Fiscal year 2007: Number of new awards: 113; 	
Fiscal year 2007: Obligation amount (in millions): $1,072.0[A]; 
First half of fiscal year 2008: Number of new awards: 69; 
First half of fiscal year 2008: Obligation amount (in millions): 
$123.2. 

Total: 
Fiscal year 2007: Number of new awards: 36,007; 	
Fiscal year 2007: Obligation amount (in millions): $11,436.2[A]; 
First half of fiscal year 2008: Number of new awards: 17,835; 
First half of fiscal year 2008: Obligation amount (in millions): 
$4,201.5. 

Source: GAO analysis of DOD data. 

Note: Total obligations may not add due to rounding. 

[A] In addition to the obligations in fiscal year 2007, DOD obligated 
$2,474.8 million in the first half of fiscal year 2008 on contracts 
that were awarded in fiscal year 2007. 

[End of table] 

The extent to which DOD was required to compete a contract depended on 
where and for what purpose the contract is awarded and performed, its 
dollar value, and the contracting method used. The level of competition 
required for contracts (other than task orders) was determined based on 
dollar thresholds established in the Federal Acquisition Regulation 
(FAR). For contracts valued in excess of $1 million to be used in 
support of a contingency operation and to be awarded and performed 
outside the United States,[Footnote 29] DOD was required to conduct 
full and open competition.[Footnote 30] 

FAR policy called for the use of simplified acquisition procedures, 
such as standing price quotations and source lists, below that 
threshold.[Footnote 31] For contracts valued below $25,000 to be used 
in support of a contingency operation and to be awarded and performed 
outside the United States,[Footnote 32] the FAR provided that award may 
be made without soliciting competitive quotations if the price was 
determined to be reasonable.[Footnote 33] Pursuant to the FAR,[Footnote 
34] statutory and regulatory competition requirements did not apply to 
the process of issuing task orders. However, where there were multiple 
awardees under the underlying indefinite delivery contract, the FAR 
required the contracting officer to provide each awardee a fair 
opportunity to be considered for each order exceeding $3,000.[Footnote 
35] 

Of the DOD contracts awarded in fiscal year 2007 and the first half of 
fiscal year 2008, about two-thirds were competed to one extent or 
another. DOD reported that of the 12,978 task orders issued, almost 95 
percent were issued competitively, which accounted for about 91 percent 
of obligations on new task orders. For all other contracting methods, 
DOD reported using competitive procedures about 57 percent of the time 
(see table 3). These competitively awarded contracts (excluding task 
orders) accounted for almost 78 percent of the obligations for new 
contract awards. However, for the majority of the newly awarded 
contracts, DOD simply indicated whether or not competition occurred 
without further specifying the competitive procedures used. This is 
partially due to the fact that, according to DOD contracting officials 
in Iraq and Afghanistan, the system used to track contracts only allows 
them to select yes or no to indicate competition. 

Table 3: DOD’s Competition of Iraq and Afghanistan Contracts (excluding 
task orders) Awarded in Fiscal Year 2007 and the First Half of Fiscal 
Year 2008: 

Competed: 
Number of contracts: 23,478; 
Percentage of contracts: 57.3; 
Obligation amount (in millions): $5,909.1; 
Percentage of obligations: 77.6. 

Not competed: 
Number of contracts: 15,474; 
Percentage of contracts: 37.8; 
Obligation amount (in millions): $1,501.2; 
Percentage of obligations: 19.7. 

Not reported: 
Number of contracts: 2,002; 
Percentage of contracts: 4.9; 
Obligation amount (in millions): $203.1; 
Percentage of obligations: 2.7. 

Total: 
Number of contracts: 40,954; 
Obligation amount (in millions): $7,613.3. 
	
Source: GAO analysis of DOD data. 

Note: Total obligations may not add due to rounding. 

[End of table] 

During the course of our file reviews in Iraq and Afghanistan, we found 
evidence that, in some cases, DOD underreported the number of contracts 
it had competitively awarded. Of the 85 files we reviewed, we found 14 
instances in which DOD reported that the contract had not been 
competitively awarded but the files indicated that competitive 
procedures were used to award the contract. For example, for one 
contract that DOD reported as not being competitively awarded, the file 
indicated that a solicitation had been sent to multiple Afghani firms 
to compete for the contract. DOD contracting officials attributed this 
underreporting to multiple factors, including the lack of clear 
guidance on how to report limited competition awards in their 
contracting system. Also, some DOD contracting officials may have 
identified these competitively awarded contracts as not competed 
because they were low value contracts for which competition was not 
required. 

DOD Contractor Personnel in Iraq and Afghanistan: 

In June 2007, DOD’s Central Command (CENTCOM) issued orders to initiate 
a quarterly census of contractor personnel within its Area of 
Responsibility, which includes Iraq and Afghanistan.[Footnote 36] This 
was done to provide CENTCOM commanders with greater visibility over 
deployed contractors and assist them in planning for protection, 
medical, and other support for contractors. At the end of each quarter, 
DOD components are to provide CENTCOM with contractor personnel 
information on active service and construction contracts that have a 
period of performance greater than 45 days. Information to be provided 
for each contract includes services being provided by the contractor 
(such as security, training, and transportation) and the numbers of 
U.S. citizens, third country nationals, and local nationals employed on 
the contract at all tiers. 

DOD officials informed us that data from the quarterly census 
represented the best and most complete data available on DOD contractor 
personnel in Iraq and Afghanistan for the period of our review. As 
shown in table 4, DOD reported that as of April 2008, 197,718 
contractor personnel worked on contracts in Iraq and Afghanistan. 
[Footnote 37] 

Table 4: CENTCOM Quarterly Census of DOD Contractor Personnel 
Performing Duties in Iraq and Afghanistan: 

As of November 2007: 
Afghanistan: 29,473; 
Iraq: 154,825; 
Total: 184,298. 

As of January 2008: 
Afghanistan: 36,520; 
Iraq: 163,591; 
Total: 200,111. 

As of April 2008: 
Afghanistan: 48,340; 
Iraq: 149,378; 
Total: 197,718. 

Source: CENTCOM census. 

[End of table] 

The census relies on contractor firms to self-report their personnel 
data. According to DOD officials, when they receive the data they 
review it to ensure that there are no obvious errors, but they do not 
routinely evaluate the accuracy or completeness of the reported data. A 
senior DOD policy official explained that conducting such an evaluation 
would be extremely labor and time intensive. Additionally, DOD 
contracting officials in Iraq and Afghanistan informed us that they 
have a limited ability to assess the reported data, in part, because 
security concerns hinder their ability to make on-site assessments. 
They told us they had reason to believe the data on local nationals 
were more likely to be incomplete because the number of local nationals 
working on contracts tends to fluctuate daily and local firms do not 
always keep precise track of the number of individuals working on their 
projects. In contrast, they explained that the number of U.S. citizen 
and third country national contractor personnel was likely to be more 
accurate as there tend to be fewer turnovers, which allows the firms to 
more easily track those employees. 

CENTCOM initiated the census as an interim measure for obtaining data 
on contractor personnel until DOD’s Synchronized Predeployment and 
Operational Tracker (SPOT) was fully implemented. SPOT is a Web-based 
system that facilitates the monitoring and control of contractor 
personnel movement throughout a contingency area. SPOT enables the 
validation of contractor personnel associated with specific contracts 
and subcontracts by users of the system. In January 2007, SPOT was 
designated as DOD’s primary system for collecting data on contractor 
personnel, regardless of nationality, for contractor personnel deployed 
with U.S. forces. The requirement to enter data into SPOT excluded 
personnel hired under contracts less than $25,000 and for which the 
period of performance was less than 30 days. Under the phased 
implementation of SPOT, contractor firms were to enter personnel data 
for contracts performed in Iraq and Afghanistan by: 

* November 1, 2007, for DOD security and translator/linguist service 
contracts; 

* March 15, 2008, for DOD-funded construction, as well as external and 
system support contracts; and; 

* May 1, 2008, for other DOD-funded contracts. 

According to the SPOT data provided by DOD, there were 24,499 
individuals working on contracts identified as providing security 
services in Iraq and Afghanistan as of July 2008. However, according to 
a senior DOD official familiar with the data, this number could include 
personnel performing functions other than armed security, such as 
information technology security. Also, in providing us with the data, 
DOD informed us that the number of individuals identified on these 
security contracts in SPOT may be inflated by up to 19 percent due to 
duplicative reporting, particularly for local and third country 
nationals.[Footnote 38] However, in our analyses of the SPOT data, we 
found instances in which contractor personnel performing security 
services appeared to be underreported. Specifically, we identified 47 
contracts categorized by CENTCOM as security contracts that did not 
appear in SPOT but were listed in the census as having at least 5,924 
personnel during the second quarter of fiscal year 2008. 

Killed or Wounded DOD Contractor Personnel: 

Senior DOD officials informed us that the department does not track the 
number of contractor personnel who have been killed or wounded. As a 
result, the department was unable to provide us with comprehensive data 
on the number of contractor personnel who were killed or wounded in 
Iraq or Afghanistan during fiscal year 2007 and the first half of 
fiscal year 2008. DOD directed us to the Department of Labor’s data on 
cases filed under the Defense Base Act to obtain data on contractor 
casualties (see app. V for data on these cases, which include deaths 
and injuries sustained by DOD and other contractor personnel). 

For most of the period of our review, DOD did not have a requirement to 
track the number of contractor personnel killed or wounded. In January 
2008, DOD issued a revised instruction[Footnote 39] directing DOD 
components to submit casualty reports on all DOD contractor personnel 
outside the continental United States who are injured, missing, or 
killed as the result of hostile or nonhostile action or while 
accompanying armed forces in the field.[Footnote 40] Information from 
the casualty report is to be entered into DOD’s Defense Casualty 
Information Processing System. Additionally, in November 2007, DOD’s 
Joint Staff updated its personnel manual to require the combatant 
commands to submit casualty reports for overseas contractor personnel 
who are declared dead, whereabouts unknown, missing, ill, or injured. 
[Footnote 41] Information from these reports is to be entered into the 
Joint Personnel Status Report. However, according to DOD officials 
within the Office of the Secretary of Defense and the Joint Staff, the 
requirements in the instruction and manual are being phased in and 
neither the casualty system nor the personnel reports currently contain 
useful information for determining the overall number of DOD contractor 
personnel killed or wounded in Iraq and Afghanistan. Additionally, 
neither the quarterly census nor the current version of SPOT has a 
field for recording information on killed or wounded contractor 
personnel. 

Despite the lack of departmentwide data on the number of contractor 
personnel killed or wounded, some DOD components provided us with 
limited information. According to data provided by the Defense 
Logistics Agency, 147 of its contractor personnel were killed, wounded, 
or missing in Iraq and Afghanistan during the period of our review. 
However, the Defense Logistics Agency noted that these data are based 
on correspondence from the contractors and it does not maintain a 
database on killed or wounded contractor personnel. Similarly, the Navy 
informed us that based on inquiries to its contractors, none of its 
contractor personnel had been killed or wounded. The Defense 
Intelligence Agency also informed us that none of its contractor 
personnel had been killed or wounded. 

Appendix III: State Contracting in Iraq and Afghanistan: 

This appendix provides information on the State’s contracts, contractor 
personnel, and contractor personnel killed or wounded in Iraq and 
Afghanistan during fiscal year 2007 and the first half of fiscal year 
2008. The first section of this appendix presents our analyses of State-
reported data on the number and value of contracts and the extent to 
which those contracts were competed. In the second and third sections, 
we present State-provided information on contractor personnel and the 
number of killed or wounded contractor personnel, as well as some of 
the limitations associated with that information. 

State Contracts in Iraq and Afghanistan: 

State reported at least $1.9 billion in obligations on 1,046 contracts 
with performance in Iraq or Afghanistan during fiscal year 2007 and the 
first half of fiscal year 2008.[Footnote 42] As shown in table 5, 
approximately 60 percent of both the contracts and their associated 
obligations were for performance in Iraq. While most of the remaining 
contracts and obligations were for performance in Afghanistan, State 
also reported three contracts that had performance in multiple 
countries, including Iraq and Afghanistan. 

State’s contracts, which were primarily awarded by its headquarters 
contracting office and posts in Iraq and Afghanistan, were for a 
variety of goods and services, such as construction and poppy 
eradication. To obtain these goods and services, State used different 
contracting methods. Most of State’s active contracts—nearly 80 
percent—were purchase orders. In contrast, task orders accounted for 85 
percent of State’s obligations during our review period. Most notably, 
State obligated over $500 million for a single task order, which 
accounted for more than one-quarter of its obligations. 

Table 5: State Active Contracts and Obligations for Iraq and 
Afghanistan, Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Afghanistan; 
Fiscal year 2007: Number of active contracts: 319; 	
Fiscal year 2007: Obligation amount (in millions): $562.5; 
First half of fiscal year 2008:	Number of active contracts: 111; 	
First half of fiscal year 2008:	Obligation amount (in millions): 
$215.0; 
Fiscal year 2007 and first half of fiscal year 2008: Number of active 
contracts: 422[B]; 
Fiscal year 2007 and first half of fiscal year 2008: Obligation amount 
(in millions): $777.4. 

Iraq: 		
Fiscal year 2007: Number of active contracts: 452; 	
Fiscal year 2007: Obligation amount (in millions): $986.3; 
First half of fiscal year 2008:	Number of active contracts: 191; 	
First half of fiscal year 2008:	Obligation amount (in millions): 
$148.1; 
Fiscal year 2007 and first half of fiscal year 2008: Number of active 
contracts: 621[B]; 
Fiscal year 2007 and first half of fiscal year 2008: Obligation amount 
(in millions): $1,134.4. 

Other[A]: 
Fiscal year 2007: Number of active contracts: 2; 	
Fiscal year 2007: Obligation amount (in millions): $1.7; 
First half of fiscal year 2008:	Number of active contracts: 2; 	
First half of fiscal year 2008:	Obligation amount (in millions): $1.0; 
Fiscal year 2007 and first half of fiscal year 2008: Number of active 
contracts: 3[B]; 
Fiscal year 2007 and first half of fiscal year 2008: Obligation amount 
(in millions): $2.7. 

Total: 
Fiscal year 2007: Number of active contracts: 773; 	
Fiscal year 2007: Obligation amount (in millions): $1,550.4; 
First half of fiscal year 2008:	Number of active contracts: 304; 	
First half of fiscal year 2008:	Obligation amount (in millions): 
$364.1; 
Fiscal year 2007 and first half of fiscal year 2008: Number of active 
contracts: 1,046[B]; 
Fiscal year 2007 and first half of fiscal year 2008: Obligation amount 
(in millions): $1,914.5. 

Source: GAO analysis of State data. 

Note: Total obligations may not add due to rounding. 

[A] “Other” includes contracts that State reported as having 
performance in multiple countries, including Iraq and/or Afghanistan. 

[B] Some contracts were active in both fiscal year 2007 and the first 
half of fiscal year 2008. As a result, the total number of active 
contracts during the 18-month period of our review is less than the 
number that were active each year added together. Obligation amounts 
are unique to each fiscal year so total obligations for the entire 
period are the sum of obligations in each fiscal year. 

[End of table] 

While we were mandated to identify the total number and value of all 
State contracts, which is defined to mean prime contracts, task orders, 
and subcontracts at any tier, State was unable to provide data on the 
number of subcontracts or information on the value of individual 
subcontracts with performance in Iraq and Afghanistan. For the period 
of our review, State officials informed us that they did not track or 
maintain data on the extent to which State contractors subcontracted 
portions of their work. Furthermore, there was no requirement to do so. 
Although the number and value of individual subcontracts cannot be 
determined from the data State reported, the value of the subcontracted 
work is captured within the amounts State obligated to its prime 
contractors. 

Of the State contracts with performance in Iraq and Afghanistan during 
fiscal year 2007 and the first half of fiscal year 2008, most were 
awarded in that 18-month period (see table 6). However, these newly 
awarded contracts accounted for a small percentage of State’s 
obligations. Of the newly awarded contracts, 75 percent had obligations 
of less than $25,000 during our 18 month review period. Obligations on 
contracts awarded in fiscal year 2006 or earlier accounted for more 
than 82 percent of State’s obligations in Iraq and Afghanistan during 
fiscal year 2007 and the first half of fiscal year 2008. 

Table 6: State New Contract Awards and Obligations for Iraq and 
Afghanistan, Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Afghanistan: 
Fiscal year 2007: Number of new awards: 299; 
Fiscal year 2007: Obligation amount (in millions): $53.6[B]; 	
First half of fiscal year 2008: Number of new awards: 101; 
First half of fiscal year 2008: Obligation amount (in millions): $1.9. 

Iraq: 
Fiscal year 2007: Number of new awards: 419; 
Fiscal year 2007: Obligation amount (in millions): $223.5[B]; 	
First half of fiscal year 2008: Number of new awards: 153; 
First half of fiscal year 2008: Obligation amount (in millions): $21.6. 

Other[A]: 
Fiscal year 2007: Number of new awards: 0; 
Fiscal year 2007: Obligation amount (in millions): $0.0[B]; 	
First half of fiscal year 2008: Number of new awards: 1; 
First half of fiscal year 2008: Obligation amount (in millions): $0.2. 

Total: 
Fiscal year 2007: Number of new awards: 718; 
Fiscal year 2007: Obligation amount (in millions): $277.1[B]; 	
First half of fiscal year 2008: Number of new awards: 255; 
First half of fiscal year 2008: Obligation amount (in millions): $23.7. 

Source: GAO analysis of State data. 

Note: Total obligations may not add due to rounding. 

[A] “Other” includes contracts that State reported as having 
performance in multiple countries, including Iraq and/or Afghanistan. 

[B] In addition to the obligations in fiscal year 2007, State obligated 
$31.3 million in the first half of fiscal year 2008 on contracts that 
were awarded in fiscal year 2007. 

[End of table] 

The extent to which State was required to compete a contract depended 
on where and for what purpose the contract was awarded and performed, 
its dollar value, and the contracting method used. The level of 
competition required for contracts (other than task orders) was 
determined based on dollar thresholds established in the Federal 
Acquisition Regulation (FAR). For contracts valued in excess of $1 
million to be used in support of a contingency operation and to be 
awarded and performed outside the United States,[Footnote 43] State was 
required to conduct full and open competition.[Footnote 44] FAR policy 
called for the use of simplified acquisition procedures, such as 
standing price quotations and source lists, below that threshold. 
[Footnote 45] For contracts valued below $25,000 to be used in support 
of a contingency operation and to be awarded and performed outside the 
United States,[Footnote 46] the FAR provided that award may be made 
without soliciting competitive quotations if the price was determined 
to be reasonable.[Footnote 47] Pursuant to the FAR,[Footnote 48] 
statutory and regulatory competition requirements did not apply to the 
process of issuing task orders. However, where there were multiple 
awardees under the underlying indefinite delivery contract, the FAR 
required the contracting officer to provide each awardee a fair 
opportunity to be considered for each order exceeding $3,000.[Footnote 
49] 

Of the State contracts awarded in fiscal year 2007 and the first half 
of fiscal year 2008, almost 61 percent were competed to one extent or 
another. State reported that of the 110 task orders issued, 24 percent 
were done so competitively. However, State did not report the extent of 
competition for almost 52 percent of the orders issued during our 
review period, which accounted for nearly 80 percent of its obligations 
on new task orders. For all other contracting methods, State reported 
using competitive procedures about two-thirds of the time (see table 
7). For the 569 new contracts (excluding task orders) that State 
reported as competed, the department generally reported using full and 
open competition. However, for 5 percent of its contracts, State either 
did not provide competition information or the information provided was 
not sufficient to determine whether competition occurred. 

Table 7: State’s Competition of Iraq and Afghanistan Contracts 
(excluding task orders) Awarded in Fiscal Year 2007 and the First Half 
of Fiscal Year 2008: 

Competed: 
Number of contracts: 569; 
Percentage of contracts: 65.6; 
Obligation amount (in millions): $61.1; 
Percentage of obligations: 55.7. 

Not competed: 
Number of contracts: 252; 
Percentage of contracts: 29.1; 
Obligation amount (in millions): $39.4; 
Percentage of obligations: 35.9. 

Not reported: 
Number of contracts: 46; 
Percentage of contracts: 5.3; 
Obligation amount (in millions): $9.3; 
Percentage of obligations: 8.4. 

Total: 
Number of contracts: 867. 
Obligation amount (in millions): $109.7. 

Source: GAO analysis of State data. 

Note: Total obligations may not add due to rounding. 

[End of table] 

State Contractor Personnel in Iraq and Afghanistan: 

During fiscal year 2007 and the first half of fiscal year 2008, State 
did not have a centralized system for tracking the number of contractor 
personnel. As a result, State was unable to provide us with 
comprehensive data on contractor personnel, including those performing 
security functions, in Iraq and Afghanistan during our review period. 
However, in response to our request for data, State provided limited 
personnel data it had received through inquiries made to its 
contractors. State reported that as of July 2008, 6,341 contractor 
personnel were working in Iraq and an additional 851 were working in 
Afghanistan. State’s contractor personnel are likely understated. 
According to the information provided by State, these contractor 
personnel were working on approximately 40 contracts in Iraq and 3 in 
Afghanistan, which is considerably less than the number of active 
contracts State reported to us. Of the contractor personnel State 
reported to be working in Iraq, 73 percent were reported to be 
performing security functions. However, of the contractor personnel in 
Afghanistan, 650 were reported to be performing security functions 
while the remainder was supporting demining efforts, which means that 
contractor personnel performing other services in Afghanistan, such as 
construction and translation, were not reported to us. We previously 
reported that for one contract in Afghanistan, there were 540 
contractor personnel training and mentoring the Afghan national police 
as of April 2008—these personnel were not included in the numbers State 
reported to us.[Footnote 50] 

Killed or Wounded State Contractor Personnel: 

For the period of our review, State did not have a system to track the 
number of contractor personnel killed or wounded in Iraq or 
Afghanistan. State officials noted that they were not required to track 
such information, but they were able to provide partial data on the 
number of contractor personnel who had been killed or wounded. They 
indicated that the information provided to us was the best available. 
In 2007, State sent an inquiry to its contractors to obtain information 
on contractor deaths. In response, State’s contractors reported that 
during fiscal year 2007, 23 contractor personnel had been killed in 
Iraq and Afghanistan. Of these, 19 were reported to have been killed in 
Iraq. State officials explained that they did not verify the 
information provided by contractors. Additionally, they explained that 
they have not requested information on the number of contractor deaths 
or the number of contractor personnel wounded in fiscal year 2008. 

[End of section] 

Appendix IV: USAID Contracting in Iraq and Afghanistan: 

This appendix provides information on United States Agency for 
International Development’s (USAID) contracts, contractor personnel, 
and contractor personnel killed or wounded in Iraq and Afghanistan 
during fiscal year 2007 and the first half of fiscal year 2008. The 
first section of this appendix presents our analyses of USAID-reported 
data on the number and value of contracts and the extent to which those 
contracts were competed. In the second and third sections, we present 
USAID-provided information on contractor personnel and the number 
killed or wounded, as well as some of the limitations associated with 
that information. 

USAID Contracts in Iraq	and Afghanistan: 

USAID reported at least $1.7 billion in obligations on 276 contracts 
active in Iraq or Afghanistan during fiscal year 2007 and the first 
half of fiscal year 2008.[Footnote 51] As shown in table 8, the number 
of contracts and obligations were relatively equal for both Iraq and 
Afghanistan over the 18-month period of our review. These contracts, 
which were primarily awarded by USAID contract offices overseas, were 
for a range of goods and services, such as building roads and 
supporting local governance programs. These also include contracts for 
individuals to work as personal services contractors in Iraq and 
Afghanistan.[Footnote 52] Eighty-three percent of USAID’s active 
contracts were stand-alone contracts, which made up approximately 43 
percent of USAID’s obligations. In comparison, task orders made up 12 
percent of USAID’s active contracts but accounted for 45 percent of its 
obligations. 

Table 8: USAID Active Contracts and Obligations for Iraq and 
Afghanistan, Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Afghanistan: 
Fiscal year 2007, Number of active contracts: 99; 
Fiscal year 2007, Obligation amount (in millions): $427.5; 
First half of fiscal year 2008, Number of active contracts: 82; 
First half of fiscal year 2008, Obligation amount (in millions): 
$529.8; 
Fiscal year 2007 and first half of fiscal year 2008, Number of active 
contracts: 154[A]; 
Fiscal year 2007 and first half of fiscal year 2008, Obligation amount 
(in millions): $957.3. 

Iraq: 
Fiscal year 2007, Number of active contracts: 91; 
Fiscal year 2007, Obligation amount (in millions): $767.4; 
First half of fiscal year 2008, Number of active contracts: 35; 
First half of fiscal year 2008, Obligation amount (in millions): $43.5; 
Fiscal year 2007 and first half of fiscal year 2008, Number of active 
contracts: 122[A]; 
Fiscal year 2007 and first half of fiscal year 2008, Obligation amount 
(in millions): $810.9. 

Total: 
Fiscal year 2007, Number of active contracts: 190; 
Fiscal year 2007, Obligation amount (in millions): $1,194.8; 
First half of fiscal year 2008, Number of active contracts: 117; 
First half of fiscal year 2008, Obligation amount (in millions): 
$573.3; 
Fiscal year 2007 and first half of fiscal year 2008, Number of active 
contracts: 276[A]; 
Fiscal year 2007 and first half of fiscal year 2008, Obligation amount 
(in millions): $1,768.1. 

Source: GAO analysis of USAID data. 

Note: Total obligations may not add due to rounding. 

[A] Some contracts were active in both fiscal year 2007 and the first 
half of fiscal year 2008. As a result, the total number of active 
contracts during the 18-month period of our review is less than the 
number that were active each year added together. Obligation amounts 
are unique to each fiscal year so total obligations for the entire 
period are the sum of obligations in each fiscal year. 

[End of table] 

While we were mandated to identify the total number and value of all 
USAID contracts, which is defined to mean prime contracts, task orders, 
and subcontracts at any tier, USAID was unable to provide data on the 
number of subcontracts or information on the value of individual 
subcontracts with performance in Iraq and Afghanistan. USAID officials, 
who noted that there was no requirement to do so, explained that they 
did not track or centrally maintain data on the extent to which USAID 
contractors subcontracted portions of their work. However, they noted 
that some individual contract files contain information on subcontracts 
but that information is not readily available. Although the number and 
value of individual subcontracts cannot be determined from the data 
USAID reported, the value of the subcontracted work is captured within 
the amounts USAID obligated to its prime contractors. 

Of the USAID contracts that were active in Iraq and Afghanistan during 
fiscal year 2007 and the first half of fiscal year 2008, two-thirds 
were awarded during that 18-month period (see table 9). However, the 
majority of USAID’s obligations were made on contracts awarded in 
fiscal year 2006 or earlier. In fiscal year 2007, newly awarded 
contracts accounted for one-quarter of the obligations, while newly 
awarded contracts accounted for only 17 percent of the obligations in 
the first half of fiscal year 2008. 

Table 9: USAID New Contract Awards and Obligations for Iraq and 
Afghanistan, Fiscal Year 2007 and the First Half of Fiscal Year 2008: 

Afghanistan: 
Fiscal year 2007, Number of new awards: 66; 
Fiscal year 2007, Obligation amount (in millions): $70.9[A]; 
First half of fiscal year 2008, Number of new awards: 46; 
First half of fiscal year 2008, Obligation amount (in millions): $56.8. 

Iraq: 
Fiscal year 2007, Number of new awards: 43; 
Fiscal year 2007, Obligation amount (in millions): $227.0[A]; 
First half of fiscal year 2008, Number of new awards: 21; 
First half of fiscal year 2008, Obligation amount (in millions): $38.1; 

Total: 109	$297.9a	67	$94.8
Fiscal year 2007, Number of new awards: 109; 
Fiscal year 2007, Obligation amount (in millions): $297.9[A]; 
First half of fiscal year 2008, Number of new awards: 67; 
First half of fiscal year 2008, Obligation amount (in millions): $94.8; 

Source: GAO analysis of USAID data. 

Note: Total obligations may not add due to rounding. 

[A] In addition to the obligations in fiscal year 2007, USAID obligated 
$100.2 million in the first half of fiscal year 2008 on contracts that 
were awarded in fiscal year 2007. 

[End of table] 

The extent to which USAID was required to compete a contract depended 
on where and for what purpose the contract is awarded and performed, 
its dollar value, and the contracting method used. The level of 
competition required for contracts (other than task orders) was 
determined based on dollar thresholds established in the Federal 
Acquisition Regulation (FAR). For contracts valued in excess of $1 
million to be used in support of a contingency operation and to be 
awarded and performed outside the United States,[Footnote 53] USAID was 
required to conduct full and open competition.[Footnote 54] FAR policy 
called for the use of simplified acquisition procedures, such as 
standing price quotations and source lists, below that threshold. 
[Footnote 55] For contracts valued below $25,000 to be used in support 
of a contingency operation and to be awarded and performed outside the 
United States,[Footnote 56] the FAR provided that award may be made 
without soliciting competitive quotations if the price was determined 
to be reasonable.[Footnote 57] Pursuant to the FAR,[Footnote 58] 
statutory and regulatory competition requirements did not apply to the 
process of issuing task orders. However, where there were multiple 
awardees under the underlying indefinite delivery contract, the FAR 
required the contracting officer to provide each awardee a fair 
opportunity to be considered for each order exceeding $3,000.[Footnote 
59] 

Of the USAID contracts awarded in fiscal year 2007 and the first half 
of fiscal year 2008, almost 97 percent were competed to one extent or 
another. USAID reported that it competitively issued all six of its 
task orders with performance in Iraq and Afghanistan. For all other 
contracting methods, USAID reported using competitive procedures 97 
percent of the time (see table 10). For the new 175 contracts 
(excluding task orders) that USAID reported as competed, 12 were 
reported as awarded under full and open competition and 2 were awarded 
under simplified acquisition procedures. For the rest of the competed 
contracts, USAID only indicated that the contracts were competed 
without indicating the extent. 

Table 10: USAID’s Competition of Iraq and Afghanistan Contracts 
(excluding task orders) Awarded in Fiscal Year 2007 and the First Half 
of Fiscal Year 2008: 

Competed: 
Number of contracts: 175; 
Percentage of contracts: 96.7; 
Obligation amount (in millions): $474.4; 
Percentage of obligations: 99.5. 

Not competed: 
Number of contracts: 6; 
Percentage of contracts: 3.2; 
Obligation amount (in millions): $2.6; 
Percentage of obligations: 0.5. 

Total: 
Number of contracts: 181; 
Obligation amount (in millions): $476.9. 

Source: GAO analysis of USAID data. 

[End of table] 

During fiscal year 2007 and the first half of fiscal year 2008, USAID 
did not have a centralized system for tracking the number of contractor 
personnel. However, USAID officials explained they had made efforts to 
collect data on contractor personnel performing security functions in 
Iraq and Afghanistan. USAID made periodic inquiries of its contractors 
to obtain personnel information. As a result, USAID was able to provide 
us with some data on the number of security contractors but could only 
provide limited data on personnel performing other functions. USAID 
reported that, as of February 2008, 1,975 contractor personnel worked 
on contracts in Iraq and 840 of those individuals performed security 
functions. For Afghanistan, USAID reported that as of April 2008 there 
were 3,175 contractor personnel, all of whom performed security 
functions. 

USAID contractor personnel data are likely underreported as they 
reflect contractor personnel working on 50 contracts, which is less 
than the 276 active contracts USAID reported to us. Also, USAID 
officials identified a number of limitations associated with the data 
provided to us. According to a senior USAID official in Afghanistan, 
not all of the contractor firms responded to USAID’s request for data 
on contractor personnel and no effort was made to verify the 
information that was reported. Nevertheless, he explained that these 
data were the best available. Similarly, USAID officials in Iraq told 
us they were unable to verify the completeness or accuracy of the 
number reported to us. 

Killed or Wounded USAID Contractor Personnel: 

For the period of our review, USAID relied on reports from its 
implementing partners, which include contractors, to maintain a count 
of the number of individuals that had been killed or wounded while 
working on USAID programs. In providing us with the information from 
those reports, USAID was unable to specify how many of these 
individuals were contractor personnel as opposed to individuals working 
on grants or otherwise working to implement USAID programs. USAID 
informed us that in fiscal year 2007 and the first half of fiscal year 
2008, 22 individuals had been killed in Iraq and 83 had been killed in 
Afghanistan. An additional 18 individuals were reported wounded in Iraq 
and 83 were reported injured or disabled in Afghanistan. In providing 
the information on individuals killed or injured in Afghanistan, USAID 
noted that several deaths and injuries were the result of traffic 
accidents. 

[End of section] 

Appendix V: Defense Base Act Cases for Contractor Personnel Killed or 
Injured in Iraq and Afghanistan: 

The Congress enacted the Defense Base Act (DBA) in 1941 to provide 
workers’ compensation protection to employees of government contractors 
working at U.S. defense bases overseas. Subsequent amendments to DBA 
extended coverage to other classes of government contractor employees. 
The insurance required under DBA provides employees with uniform levels 
of disability and medical benefits or—in the event of death—provides 
benefits to eligible dependents. Contractors, including subcontractors, 
are required to provide DBA insurance to all of their employees 
regardless of nationality, working outside the United States on U.S. 
military bases or under a contract with the U.S. government for public 
works or for national defense. The Department of Labor administers DBA 
and, as such, maintains data on the number of deaths and injuries 
reported to it.[Footnote 60] 

According to Labor, there were 16,242 cases for deaths or injuries that 
occurred in Iraq and Afghanistan in fiscal year 2007 and the first half 
of fiscal year 2008 (see table 11). Of these, 455 were deaths and 
15,787 were injuries. The majority of the injuries reported involved 
incidents that did not result in contractor personnel missing work. 
Nearly 85 percent of the cases were for deaths or injuries that 
occurred in Iraq. 

Table 11: Defense Base Act Cases for Deaths and Injuries in Iraq and 
Afghanistan by Fiscal Year of Death or Injury, Fiscal Year 2007 and the 
First Half of Fiscal Year 2008: 

Deaths: 
Afghanistan, Fiscal year 2007: 40; 
Afghanistan, First half fiscal year 2008: 12; 
Iraq, Fiscal year 2007: 337; 
Iraq, First half fiscal year 2008: 66. 

Injuries: 
Afghanistan, Fiscal year 2007: 1,962; 
Afghanistan, First half fiscal year 2008: 567; 
Iraq, Fiscal year 2007: 9,148; 
Iraq, First half fiscal year 2008: 4,110. 

Source: GAO analysis of Labor data. 

Note: Cases may be for contractor personnel who are under contract with 
U.S. government agencies other than DOD, State, and USAID. 

[End of table] 

DBA cases are likely to represent the minimum number of contractor 
deaths and injuries that occurred during our review period. Labor 
officials told us that a DBA case record is created in their database 
once they are notified of a contractor death or injury. However, they 
informed us that there may be contractor deaths or injuries that are 
not reported and, as a result, do not appear in Labor’s data. They 
stated it is more likely that injuries to local and third country 
nationals, particularly those working on subcontracts, are 
underreported. They noted that there have been a number of efforts to 
help ensure that all contractor personnel, regardless of nationality, 
are aware of their rights under DBA and are encouraged to claim 
benefits as appropriate. 

In tracking DBA deaths and injuries, Labor does not collect information 
on the agency or contract that the contractor personnel worked under 
and therefore could not identify which claims were made by contractor 
personnel working on DOD, State, and USAID contracts. Labor also does 
not maintain data on how deaths and injuries occurred, so it is not 
possible to determine whether a death or injury was the result of 
hostile actions, accidents, or natural and other causes. Such 
information can only be obtained by reviewing individual case files. 

[End of section] 

Appendix VI: Memorandum of Understanding on Contracting in Iraq and 
Afghanistan: 

The National Defense Authorization Act for Fiscal Year 2008 (Act) 
directed the Secretary of Defense, the Secretary of State, and the 
Administrator of the United States Agency for International Development 
(USAID) to sign a memorandum of understanding (MOU) related to 
contracting in Iraq and Afghanistan.[Footnote 61] The law specified a 
number of matters to be covered in the MOU, including the 
identification of each agency’s roles and responsibilities for matters 
relating to contracting in Iraq or Afghanistan, responsibility for 
establishing procedures for the movement of contractor personnel in the 
two countries, and identifying common databases that will serve as 
repositories of information on contracts and contractor personnel in 
Iraq or Afghanistan. After negotiations between the Department of 
Defense (DOD), Department of State, and USAID were completed, the final 
signature was added to the MOU on July 10, 2008. No later than 120 days 
after signing the MOU, the three agencies are required to issue 
policies or guidance and develop regulations, as necessary, to 
implement the MOU at their respective agencies. 

In the MOU provisions regarding the identification of common databases 
for contracts and contractor personnel, the three agencies agreed that 
DOD’s Synchronized Pre-Deployment and Operational Tracker (SPOT) 
database will be the system of record for the contract and contractor 
personnel information required by section 861. The MOU specified that 
SPOT will include information on contracts in Iraq and Afghanistan with 
performance periods of more than 14 days or valued at more than 
$100,000 and their associated personnel, as appropriate. While the Act 
specified the 14 days or more threshold, it did not specify a minimum 
dollar value threshold regarding which contracts should appear in the 
database. 

According to the MOU, DOD is responsible for all maintenance and 
upgrades to SPOT, which it originally designed and used. Each agency 
will be responsible for ensuring that data elements related to 
contractor personnel, such as the number of personnel employed on 
contracts in Iraq or Afghanistan, are entered into the system and for 
requiring its contractors to input that information accurately. Other 
data elements that are related to the contract, such as the value of 
the contract and whether it was awarded competitively, will be pulled 
into SPOT from the Federal Procurement Data System – Next Generation 
(FPDS-NG), which is the federal government’s current system for 
tracking information on contracting actions. 

The three agencies are at various stages in implementing and using 
SPOT. DOD has been using SPOT since early 2007 to track its contractor 
personnel in Iraq and Afghanistan. DOD has drafted new instructions 
that detail the requirements for the expanded use of SPOT by 
contractors to conform with the Act and MOU. DOD officials explained 
that as is currently the case, contractors will be required to enter 
information on their contractor personnel into SPOT once the DOD 
contracting officer enters the contract number into the system. In 
terms of ensuring that contract information is pulled into SPOT, 
information on individual contracts awarded by DOD in Iraq and 
Afghanistan are not currently entered into FPDS-NG. However, DOD 
officials told us that there are plans underway to ensure that 
information on these contracts is entered into FPDS-NG so their 
information can be pulled into SPOT. State officials told us that they 
have been using SPOT on a limited basis as part of a pilot program, but 
they expect information on State’s contracts and contractors to be 
entered into SPOT by early November 2008. USAID and its contractors 
have not started using SPOT. According to USAID officials, they are 
currently working to educate contractors on the use of SPOT. USAID is 
initially focusing on contractors that have large security subcontracts 
and will then focus on all other contractors with security 
subcontracts. While USAID officials were uncertain as to when its 
contractors will start entering data into SPOT, they stated that they 
fully expect to comply with the provisions of the MOU. 

DOD has already begun taking actions to have SPOT ready to fulfill the 
MOU. Plans have been developed to add new fields to SPOT, specifically 
to record information on contractor personnel who have been killed or 
wounded. According to DOD officials, as the agencies work together to 
implement the provisions of the MOU and upgrades are made to SPOT to 
facilitate its use and track required information, such as contractor 
casualties, the ability of the agencies to report on the number and 
value of contracts, as well as on the number of contractor personnel, 
will improve. Similarly, State officials indicated that having a 
centralized system for tracking contractor personnel will be beneficial 
as it will reduce concerns about limited visibility over contractors 
and allow the department to more readily respond to requests for 
contract and contractor personnel information. 

[End of section] 

Appendix VII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 
John Hutton (202) 512-4841 or huttonj@gao.gov. 

Acknowledgments: 
In addition to the contact above, Johana R. Ayers, Assistant Director; 
Jessica M. Berkholtz; E. Brandon Booth; Brendan S. Culley; Art James, 
Jr.; Lisa A. McMillen; Jean McSween, and Karen Thornton made key 
contributions to this report. 

[End of section] 

Footnotes: 

[1] The Congressional Research Service (CRS) estimated that about 94 
percent of the funds were for DOD and 6 percent were for foreign aid 
and embassy operations. CRS also estimated that about 76 percent of the 
funds have been for efforts in Iraq and 20 percent for Afghanistan. 
CRS, The Cost of Iraq, Afghanistan, and Other Global War on Terror 
Operations Since 9/11, RL33110 (Washington, D.C.: July 14, 2008). 

[2] See GAO, Defense Management: DOD Needs to Reexamine Its Extensive 
Reliance on Contractors and Continue to Improve Management and 
Oversight, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-572T] 
(Washington, D.C.: Mar. 11, 2008) and Stabilizing and Rebuilding Iraq: 
Actions Needed to Address Inadequate Accountability over U.S. Efforts 
and Investments, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-
568T] (Washington, D.C.: Mar. 11, 2008). See also, Special Inspector 
General for Iraq Reconstruction, Contracting in Iraq Reconstruction, 
SIGIR 07-010T (Washington, D.C.: May 10, 2007) and Department of 
Defense Inspector General, Challenges Impacting Operations Iraqi 
Freedom and Enduring Freedom Reported by Major Oversight Organizations 
Beginning FY 2003 through FY 2007, D-2008-086 (Arlington, Va.: July 18, 
2008). 

[3] Pub. L. No. 110-181. 

[4] Pub. L. No. 110-181, §863. While the mandate and our report address 
DOD, State, and USAID contracting in Iraq and Afghanistan, other 
federal agencies such as the Departments of Agriculture, Justice, and 
the Treasury have contracts with performance in Iraq and Afghanistan 
that are not included in the scope of the mandate or our report. 

[5] For the purposes of our annual report and the three agencies’ MOU, 
section 864 of the Act defines a “contract in Iraq or Afghanistan” as 
“a contract with the Department of Defense, the Department of State, or 
the United States Agency for International Development, a subcontract 
at any tier issued under such a contract, or a task order or delivery 
order at any tier issued under such a contract (including a contract, 
subcontract, or task order or delivery order issued by another 
Government agency for the Department of Defense, the Department of 
State, or the United States Agency for International Development) if the
contract, subcontract, or task order or delivery order involves work 
performed in Iraq or Afghanistan for a period longer than 14 days.” The 
Federal Acquisition Regulation (FAR) defines a subcontract as a 
contract entered into by a subcontractor to furnish supplies or 
services for performance of a prime contract or other subcontracts. The 
FAR defines a task order as an order for services placed against an 
established contract or government sources. For the purposes of this 
report, when we use the term contract, we intend it to refer to a 
“contract in Iraq or Afghanistan” as defined in the act. However, due to
limitations in how the agencies track their contracts, we included in 
our analyses contracts reported to us regardless of whether they had a 
performance period of more than 14 days. Also, the agencies were unable 
to provide data on the number or value of individual subcontracts. 

[6] Since the Act did not define what constitutes an “active” contract, 
we considered a contract as active if an obligation or deobligation of 
funds was made on that contract in fiscal year 2007 and/or the first 
half of fiscal year 2008. There are other contracts that had 
performance in Iraq or Afghanistan during that time period but had no 
obligations or deobligations; these contracts were not included in our 
analyses. Contracts awarded in fiscal year 2007 and the first half of 
fiscal year 2008 are a subset of the active contracts. 

[7] Section 864 of the Act defines private security functions, in part, 
as the “guarding of personnel, facilities or property of a Federal 
agency, the contractor or subcontractor, or a third party” and “any 
other activity for which personnel are required to carry weapons in
the performance of their duties.” This definition applies to 
contractors under a covered contract in an area of combat operations. 
The Act requires us to report “the total number of contractor 
personnel, on average, performing security functions.” However, the data
were not sufficiently reliable to calculate the average number of 
personnel providing security functions. 

[8] Amounts obligated in fiscal year 2007 and the first half of fiscal 
year 2008 were used to determine value as opposed to a contract’s total 
estimated cost or price ceiling, for example, because obligations 
represent a specified sum of money that will require government 
expenditures as opposed to estimates. 

[9] The Defense Base Act requires all contractors that enter into 
contracts with the U.S. government and their subcontractors to secure 
workers' compensation insurance for their employees working overseas, 
including those who are not U.S. citizens. 42 U.S.C. §§ 1651-54. The 
Department of Labor administers the Defense Base Act. 

[10] Labor initiates a case when it receives a notice of an injury or 
death. These notices include reports filed by employers and claims for 
benefits submitted by injured workers or by their survivors. 

[11] The term contractor personnel, as used throughout this report, 
refers to individuals, regardless of nationality, working for a prime 
contractor or subcontractor at any tier. Contractor personnel also 
include individuals who are working under personal services contracts 
with a government agency. 

[12] The Act directs that we report on the number of wounded contractor 
personnel, but it does not provide a definition of wounded. Defense 
Base Act cases may be for injuries that occur while working under a 
U.S. government contract performed overseas and are not limited to 
injuries that are the result of hostile action. 

[13] SPOT is a Web-based system initially created by DOD to provide 
greater visibility over contractors deployed with U.S. forces. In 
January 2007, DOD designated SPOT as its central repository for 
information on deployed contractors. 

[14] Pub. L. No. 110-181. 

[15] For the purposes of our annual report, section 864 of the Act 
defines a “contract in Iraq or Afghanistan” as “a contract with the 
Department of Defense, the Department of State, or the United States 
Agency for International Development, a subcontract at any tier issued
under such a contract, or a task order or delivery order at any tier 
issued under such a contract (including a contract, subcontract, or 
task order or delivery order issued by another Government agency for 
the Department of Defense, the Department of State, or the United 
States Agency for International Development) if the contract, 
subcontract, or task order or delivery order involves work performed in 
Iraq or Afghanistan for a period longer than 14 days.” The Federal 
Acquisition Regulation (FAR) defines a subcontract as a contract 
entered into by a subcontractor to furnish supplies or services for 
performance of a prime contract or other subcontracts. The FAR defines 
a task order as an order for services placed against an established 
contract or government sources. For purposes of this report, when we 
use the term contract, we intend it to refer to a “contract in Iraq or
Afghanistan” as defined in the Act. However, due to limitations in how 
the agencies track their contracts, we included in our analyses 
contracts reported to us regardless of whether they had a performance 
period of more than 14 days. 

[16] Amounts obligated in fiscal year 2007 and the first half of fiscal 
year 2008 were used to determine contract value as opposed to a 
contract’s total estimated cost or price ceiling,
for example, because obligations represent a specified sum of money 
that will require government expenditures as opposed to estimates. 

[17] GAO, Rebuilding Iraq: Status of Competition for Iraq 
Reconstruction Contracts, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-07-40] (Washington, D.C.: Oct. 6, 2006). 

[18] GAO, Improvements Needed to the Federal Procurement Data System-
Next Generation, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-
960R] (Washington, D.C.: Sept. 27, 2005) and Acquisition Advisory 
Panel, Report of the Acquisition Advisory Panel to the Office of 
Federal Procurement Policy and the United States Congress (Washington, 
D.C.: January 2007). 

[19] Since the Act did not define what constitutes an “active” 
contract, we considered a contract as active if an obligation or 
deobligation of funds was made on that contract in fiscal year 2007 
and/or the first half of fiscal year 2008. There are other contracts 
that had performance in Iraq or Afghanistan during that time period but 
had no obligations or deobligations; such contracts were not included 
in our analyses. 

[20] For some obligations, USAID did not indicate the fiscal year in 
which the obligation occurred. In several of those cases, after 
consulting with USAID officials, we substituted the contract start date 
for the obligation date. However, for some of the obligations, we were 
unable to determine when they occurred and we, therefore, did not 
include those obligations in our totals for either fiscal year 2007 or 
the first half of fiscal year 2008. Also, for some of its contracts, 
the Navy reported the total obligated amount over the life of a 
contract rather than the obligations for our review period. In those 
cases using the contract numbers provided by the Navy, we replaced the 
obligation amounts and dates provided with more detailed information 
from FPDS-NG. 

[21] In analyzing the agencies’ data on competition, we did not 
evaluate the acquisition strategy used to award the contract actions, 
whether justifications for issuing awards noncompetitively were 
adequate, or whether task orders were within the scope of the 
underlying contract. 

[22] We did not attempt to validate the contract data reported by DOD’s 
Business Transformation Agency, Counterintelligence Field Activity, 
Defense Advanced Research Projects Agency, Defense Intelligence Agency, 
National Geospatial Agency, Special Operations Command, or 
Transportation Command as their contracts represented a small portion 
of DOD’s total number of contracts and obligations. 

[23] Third country nationals are individuals who are neither U.S., 
Iraq, nor Afghanistan nationals. Local nationals, also referred to as 
host country nationals, are Iraqis or Afghanis who are working on 
contracts in their respective countries. 

[24] Section 864 of the Act defines private security functions as the 
“guarding of personnel, facilities, or property of a Federal agency, 
the contractor or subcontractor, or a third party” and “any other 
activity for which personnel are required to carry weapons in 
performance of their duties.” This definition applies to contractors 
under a covered contract in an area of combat operations. 

[25] The term contractor personnel, as used throughout this report, 
refers to individuals, regardless of nationality, working for a prime 
contractor or subcontractor at any tier, as well as individuals working 
under personal services contracts with a government agency. 

[26] According to Labor officials, they typically report data on when 
the cases are filed instead of when the incident that caused the death 
or injury occurred. 

[27] In counting the number of contracts, we excluded the base 
contracts under which task orders were issued. This was done, in part, 
because the base contracts do not have obligations associated with them 
as the obligations are incurred with the issuance of each task order. 
All other contracts, task orders, delivery orders, and purchase orders 
are included in the count along with their associated obligations. The 
count and obligations also do not include small dollar purchases (below 
$3,000) made by DOD field ordering officers as information on these 
purchases, while maintained in log books, has not been tracked in DOD’s 
contracting systems. 

[28] Under the Federal Acquisition Regulation (part 2.101), a purchase 
order is an offer by the government to buy supplies or services, 
including construction and research and development, upon specified 
terms and conditions, using simplified acquisition procedures. 

[29] Section 2.101 of the FAR defines the simplified acquisition 
threshold. The threshold is lower for contracts awarded and performed 
in the United States, which were not in the scope of our review. 

[30] Section 6.101 of the FAR implements the Competition in Contracting 
Act (CICA) requirement for contracting officers to provide for full and 
open competition in awarding government contracts. The FAR also 
implements exceptions to CICA that permit contracting without providing 
for full and open competition where an appropriate justification 
supports the use of such authority. FAR 6.302. 

[31] FAR 13.003 (a) and Subpart 13.1. 

[32] Section 2.101 of the FAR defines the micro-purchase threshold. The 
threshold is lower for contracts awarded and performed in the United 
States, which were not in the scope of our review. 

[33] FAR 13.201 (g) and 13.202 (a). 

[34] FAR 16.505 (b)(1)(ii). 

[35] FAR 16.505 (b)(1)(i). 

[36] CENTCOM is one of DOD’s six geographic combatant commands. It is 
responsible for overseeing U.S. military operations that take place in 
27 nations located in the Horn of Africa, the Arabian Gulf region, and 
Central Asia. 

[37] Per CENTCOM guidance, this number includes personnel working at 
the prime contract level and subcontract levels. 

[38] DOD also informed us that for all contractor personnel, not just 
those performing security functions, numbers in SPOT may be inflated by 
up to 7 percent. 

[39] Department of Defense Instruction 1300.18, Department of Defense 
Personnel Casualty Matters, Policies, and Procedures, § 6.1.1 (Jan. 8, 
2008). This instruction replaced the December 2000 version, which did 
not address contractor casualties. 

[40] At their own discretion, the services and DOD components may also 
submit casualty reports for DOD contractor personnel on travel status. 

[41] Chairman of the Joint Chiefs of Staff Manual 3150.13B, Joint 
Reporting Structure - Personnel Manual, Enclosure D, para. 10.r (Nov. 
1, 2007). This manual replaced the February 2005 version, which did not 
address contractor casualties. 

[42] In counting the number of contracts, we excluded the base 
contracts under which task orders were issued. This was done, in part, 
because such contracts do not have obligations associated with them as 
the obligations are incurred with the issuance of each task order. All 
other contracts, task orders, delivery orders, and purchase orders are 
included in the count along with their associated obligations. 

[43] Section 2.101 of the FAR defines the simplified acquisition 
threshold. The threshold is lower for contracts awarded and performed 
in the United States, which were not in the scope of our review. 

[44] Section 6.101 of the FAR implements the Competition in Contracting 
Act (CICA) requirement for contracting officers to provide for full and 
open competition in awarding government contracts. The FAR also 
implements exceptions to CICA that permit contracting without providing 
for full and open competition where an appropriate justification 
supports the use of such authority. FAR 6.302. 

[45] FAR 13.003 (a) and Subpart 13.1. 

[46] Section 2.101 of the FAR defines the micro-purchase threshold. The 
threshold is lower for contracts awarded and performed in the United 
States, which were not in the scope of our review. 

[47] FAR 13.201 (g) and 13.202 (a). 

[48] FAR 16.505 (b)(1)(ii). 

[49] FAR 16.505 (b)(1)(i). 

[50] GAO, Afghanistan Security: Further Congressional Action May Be 
Needed to Ensure Completion of a Detailed Plan to Develop and Sustain 
Capable Afghan National Security Forces, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-661] (Washington, D.C.: June 
18, 2008). 

[51] In counting the number of contracts, we excluded the base 
contracts under which task orders were issued. This was done, in part, 
because such contracts do not have obligations associated with them as 
the obligations are incurred with the issuance of each task order. All 
other contracts, task orders, delivery orders, and purchase orders are 
included in the count along with their associated obligations. 

[52] USAID is authorized under §636 of the Foreign Assistance Act of 
1961 (Pub. L. No. 87-195) to contract for personal services. The FAR 
(Part 2.101) defines personal services contracts as contracts that, by 
their express terms or as administered, make the contractor personnel 
appear to be, in effect, government employees. 

[53] Section 2.101 of the FAR defines the simplified acquisition 
threshold. The threshold is lower for contracts awarded and performed 
in the United States, which were not in the scope of our review. 

[54] Section 6.101 of the FAR implements the Competition in Contracting 
Act (CICA) requirement for contracting officers to provide for full and 
open competition in awarding government contracts. The FAR also 
implements exceptions to CICA that permit contracting without providing 
for full and open competition where an appropriate justification 
supports the use of such authority. FAR 6.302. 

[55] FAR 13.003 (a) and Subpart 13.1. 

[56] Section 2.101 of the FAR defines the micro-purchase threshold. The 
threshold is lower for contracts awarded and performed in the United 
States, which were not in the scope of our review. 

[57] FAR 13.201 (g) and 13.202 (a). 

[58] FAR 16.505 (b)(1)(ii). 

[59] FAR 16.505 (b)(1)(i). 

[60] Labor initiates a case when it receives a notice of a death or 
injury. Notices include reports filed by employers and claims for 
benefits submitted by injured workers or by their survivors. 

[61] Pub. L. No. 110-181, § 861. 

[End of section] 

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