Contingency Contracting: Agency Actions to Address Recommendations by the Commission on Wartime Contracting in Iraq and Afghanistan Page: 3 of 36
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presence in Iraq.4 Of these 51 total recommendations, 19 were directed to DOD, State, and/or
USAID; 15 were directed to Congress; and 17 were not directed to a specific entity. For the
recommendations not directed to a specific entity, we relied on each agency to identify which
recommendations were applicable to it. In total, 30 recommendations were identified as
applicable to DOD; 27 as applicable to State; and 25 as applicable to USAID. We did not
evaluate the CWC's recommendations; our focus was on the actions the agencies took related
to the recommendations. Specifically, we categorized the agencies' respective efforts to
address each applicable recommendation as either (1) "actions taken or planned that directly
align with the specific recommendation" or (2) "no actions taken or planned that directly align
with the specific recommendation." To determine whether each agency had taken or planned
actions that directly aligned with each applicable recommendation, we collected the agencies'
self-reported information using a data collection template; corroborated reported actions with
related documentation, when available; and conducted structured interviews with
knowledgeable agency officials to clarify responses. We categorized the agencies' efforts as
"actions taken or planned that directly align with the specific recommendation" even when the
agencies' actions (1) were started or completed before the issuance of the CWC's final or last
two special reports or (2) only partially addressed the recommendation, such as when an
agency took an action that directly aligned with the recommendation in either Iraq or
Afghanistan but not agencywide, or when an agency took an action that directly aligned with a
portion of a recommendation but did not address another portion of the recommendation. For
instances in which agencies reported not having taken or planned actions that directly align with
a specific recommendation, we documented the rationale for this course of action and reviewed
available documentation. However, we did not assess the appropriateness or sufficiency of any
actions taken or planned by the agencies. Finally, we did not assess the agencies' positions on
the CWC's recommendations to Congress, although we included the agencies' positions on
those recommendations when the agencies provided them to us.
We conducted this performance audit from February 2012 to August 2012 in accordance with
generally accepted government auditing standards. These standards require that we plan and
perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit objectives.
In summary, DOD reported having taken or planned actions that directly align with about half of
the CWC recommendations applicable to it, and State and USAID each reported having taken
or planned actions that directly align with about one-third of the recommendations applicable to
each of them. Officials from the three agencies explained that for the remaining
recommendations no actions were taken or planned that directly aligned with the specific
recommendation. This was because, for example, the agencies had determined that existing
policies or practices already meet the intent of the recommendations or had disagreed with the
recommendations. The following are examples of actions that DOD, State, and USAID have
taken or planned that directly align with specific CWC recommendations:
* DOD issued a final rule to amend the Defense Federal Acquisition Regulation Supplement
(DFARS) in February 2012 to improve the oversight of contractor business systems,
including the ability to withhold a percentage of payments on certain covered contracts when
a contractor's business systems contain significant deficiencies. This action aligns with the
4The recommendations from the CWC's Special Report 5 were incorporated into the final report. Therefore, we have
not counted recommendations from Special Report 5 separately.
GAO-12-854R Contingency Contracting
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United States. Government Accountability Office. Contingency Contracting: Agency Actions to Address Recommendations by the Commission on Wartime Contracting in Iraq and Afghanistan, text, August 1, 2012; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc301510/m1/3/: accessed February 22, 2019), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.