Trust But, Incompetently, Verify

In August 2009, the Pentagon awarded five Theater-wide Internal Security Services (TWISS) contracts for site security in Iraq. These contracts, awarded to EOD Technology, Inc.; Torres Advanced Enterprise Solutions, LLC; Special Operations Consulting-Security Management Group; Triple Canopy, Inc.; and Protection Strategies Inc., have a combined value of $485 million.

U.S base commanders nominate contracting officer's representatives (CORs), who are responsible for verifying the U.S. government receives what it pays for. The Defense Contract Management Agency (DCMA) appoints and trains CORs and manages their activities. DCMA uses Quality Assurance Representatives (QARs) to monitor the CORs' and contractors' performance.

Yet although COR duties are critical to the U.S. government's oversight of the TWISS contracts, almost 40% of the CORs it surveyed said the training they received did not prepare them for their duties and 25% said they lack sufficient time to conduct effective oversight, according to an audit report "Control Weaknesses Remain in Oversight of Theater-wide Internal Security Services Contracts,"
released today by the Office of the Special Inspector General For Iraq Reconstruction (SIGIR).

Why is this important?

Without adequate training, CORs may not be conducting sufficient oversight of the TWISS contractors' services and invoice payments. This training is particularly important since 24 of 28 CORs we surveyed stated they had no previous COR experience.

Considering that as of June 9, 2011, more than half the total value of these TWISS contacts, about $258 million had been disbursed under the contracts this is, to put it mildly, not good news.

This is similar to what SIGIR found the last time it looked at the TWISS contracts in
2009. After that report, DCMA increased training requirements but recognized in an April 2011 internal review that not all training was being conducted and documented.

To get a sense of how nothing has changed note that in April 2009, SIGIR reported that 11 of 27 CORs surveyed stated their COR training did not fully prepare them to oversee the TWISS contractors. In the new audit 11 of 28 CORs SIGIR surveyed stated their training did not prepare them to perform COR duties on the TWISS contracts.

SIGIR also found that CORs are not completing, or DCMA is not maintaining, all monthly review checklists, which DCMA developed to help CORs review contractor compliance with task order requirements. Even when completed, SIGIR noted most reviews appeared to be of questionable value or provided little assurance that CORs' oversight was adequate, a fact DCMA officials acknowledge.

As irony goes, this is hard to beat. In plain English it means DCMA, the agency which is charged with providing proper oversight on military contracts, is itself guilty of not providing proper guidance to its own employees, thus impeding them from doing an effective job.

Furthermore, even if DCMA did provide proper guidance some of the CORs are not particularly good at their jobs.

According to DCMA officials, some TWISS CORs provide excellent oversight and others provide weak oversight. To verify this statement, SIGIR examined the 81 COR Performance Work Statement reviews available from February through April 2011. SIGIR's examination noted that five appeared comprehensive in nature, 21 appeared adequate, and the remaining 55 appeared of questionable value.12 In the auditors' judgment, reviews of "questionable value" provided no reasonable assurance the COR's oversight was sufficient to guarantee the U.S. government received all services for which it paid.