March 18, 2020 —
Publicly Released: March 20, 2020
The objective of this audit was to determine whether Combined Joint Task Force–Operation Inherent Resolve (CJTF‑OIR) and the U.S. Army ensured that the contractor provided Camp Taji, Iraq, base life support (BLS) services in accordance with contract requirements.
During the audit, we found weaknesses in the Camp Taji BLS contract terms and performance work statement (PWS) requirements. Therefore, we expanded our review to determine whether CJTF‑OIR included DoD and Army criteria related to BLS services in the contract and to determine whether the Army awarded the Camp Taji contract in accordance with Federal and DoD contracting criteria
After the invasion of Iraq, from 2003 to 2011, Coalition forces operated Camp Taji, which is located 15 miles north of Baghdad. When Coalition forces withdrew from Iraq, the Government of Iraq took control over Camp Taji, and on April 22, 2013, the Prime Minister of Iraq awarded an exclusive work authorization to SoS International LLC (SOSi) to operate Camp Taji’s facilities.
On July 1, 2015, the 408th Contracting Support Brigade (CSB) awarded a firm‑fixed price contract to SOSi to provide BLS services to CJTF‑OIR personnel at Camp Taji. On January 1, 2019, Army Contacting Command‑Rock Island (ACC‑RI) awarded the subsequent Camp Taji, BLS contract to SOSi. Under both contracts, costs for BLS services included fixed prices based on the daily Camp Taji population.
The U.S. Embassy requested that the Government of Iraq permit the DoD to issue a new solicitation and award a BLS contract at Camp Taji through a fair and open competition to promote higher contract quality and lower cost. However, as of August 2019, the Government of Iraq has not taken actions to rescind SOSi’s exclusive work authorization and a Senior Management Advisor at the U.S. Embassy stated that the Embassy continues to ask the Government of Iraq to rescind the exclusive work authorization on behalf of the DoD.
The Camp Taji BLS contracts include services such as base security, billeting, lodging, meals, potable water, emergency response, fire response and prevention, hazardous material storage, and electric power generation.
CJTF‑OIR and the Camp Taji Base Operations SupportIntegrator (BOS‑I) are responsible for performing contract planning activities, such as identifying and defining requirements by developing a PWS and a quality assurance surveillance plan, and conducting market research to determine whether commercial item prices are fair and reasonable. The Camp Taji BOS‑I is also responsible for nominating contracting officer’s representatives to the administrative contracting officer.
We determined that for the Camp Taji BLS contracts, CJTF‑OIR did not define DoD and Army‑specific requirements for BLS services; the 408th CSB and ACC‑RI each awarded contracts that caused CJTF‑OIR to pay for services that it did not use; and CJTF‑OIR’s contract oversight personnel did not verify the accuracy of the contractor’s invoices. Specifically:
- CJTF‑OIR did not ensure the contract required the contractor to comply with DoD and Army regulations related to five BLS services, including regulations that required the Army to purchase food from the Defense Logistics Agency and to use incinerators to dispose of solid waste. This occurred because CJTF‑OIR accepted the BLS services the contractor provided to its commercial customers rather than fully defining DoD and Army requirements.
- 408th CSB and ACC‑RI contracting officials awarded contracts with a pricing structure that paid the contractor based on Camp Taji’s daily population; however, the calculation of the daily population included personnel who were not actually on base. This occurred because the 408th CSB and ACC‑RI contracting officials accepted the daily, per‑person pricing structure designed by the contractor and allowed the contractor to charge full price for personnel who were assigned to Camp Taji, but not present.
- CJTF‑OIR officials relied on contractor population counts and did not know whether they were paying for support for the correct number of personnel. This occurred because 408th CSB and ACC‑RI contracting officials did not define in the contracts who was responsible for determining the daily population.
As a result of poorly defined contract requirements, inadequate pricing structure, and lack of invoice oversight since July 2015, CJTF‑OIR paid $116 million more than necessary for the Camp Taji BLS contracts. Specifically, CJTF‑OIR wasted at least:
- $36 million on BLS services for personnel on leave or temporary duty status and therefore not present at Camp Taji; and
- $80 million on food and water by not requiring the contractor to comply with Army requirements for purchasing food from the Defense Logistics Agency. This amount is the difference the CJTF‑OIR paid for food and water at the contracted rates, $126 million, and the amount it would have paid by requiring the contractor purchase food from the Defense Logistics Agency ($45 million).
In addition, in the absence of a contract requirement to dispose of solid waste in accordance with U.S. Central Command environmental guidance, the contractor continued to use its commercially available, and Government of Iraq‑approved, solid waste disposal method of dumping solid waste at a site in the Camp Taji Amber Zone, which the Iraqis would later burn. This solid waste disposal method may have contributed to the exposure of U.S. and Coalition personnel to potential long‑term health effects from the burn pit smoke.
To improve the Camp Taji BLS contract requirements, we recommend that the CJTF‑OIR Commander:
- direct his staff to review and update the PWS to include DoD and Army requirements that are applicable to BLS services at Camp Taji; and
- review the actions of the logistics officials responsible for developing Camp Taji BLS requirements. Based on that review, the Commander should take appropriate action, if warranted, to hold the necessary officials accountable or to improve generation of future contract requirements.
In addition, we recommend that the ACC‑RI Executive Director direct the Camp Taji BLS procuring contracting officer to conduct a cost analysis of the Camp Taji BLS contract in accordance with Federal Acquisition Regulation Subpart 15.4, “Contract Pricing,” and use the results to ensure contract pricing is awarded at the best value to the Government.
To verify the accuracy of the Camp Taji population reported by the contractor, we recommend that the Camp Taji BOS‑I Officer in Charge:
- use the CJTF‑OIR personnel status reports for the BOS‑I’s daily occupancy tracker to ensure CJTF‑OIR is paying for the correct number of personnel;
- implement and use common access card readers to track personnel who enter or depart Camp Taji; and
- include steps in the quality assurance surveillance plan or standard operating procedures to ensure all staff members with responsibilities related to the contractor population are coordinating their activities.
Management Comments and Our Response
The Executive Deputy to the Commanding General of Army Materiel Command, the Commanding General of Army Contracting Command (ACC), and the ACC‑RI Executive Director each provided comments on our finding and stated that we did not thoroughly describe the limitations that the exclusive work authorization and the need to use a sole source contractor imposed on ACC elements when negotiating the Camp Taji BLS contracts. The Executive Deputy expressed concern that our report would cause the public and Congress to draw inappropriate conclusions regarding the Army’s share of responsibility for the conditions we describe in this report.
We disagree with Army Material Command and ACC concerns. Specifically, the exclusive work authorization did not place any restrictions on the services the Camp Taji BLS contractor was able to provide nor prevent ACC‑RI from conducting a cost analysis to ensure definitized contract pricing was awarded at the best value to the Government. In addition, our report clearly states the Iraqi Army, not the DoD or the contractor, controls burning the trash in the Amber Zone.
The ACC‑RI Executive Director did not specifically concur with our recommendation to conduct a cost analysis to facilitate pricing negotiations; however, ACC‑RI provided documents showing that the PCO performed a cost analysis and used the results to negotiate a definitized Camp Taji contract that does not include a daily per‑person price. Therefore, we consider this recommendation closed.
The CJTF‑OIR Chief of Staff stated that its staff members disagreed with our characterization of the solid waste dumping sites as burn pits and that U.S. and coalition personnel were exposed to burn‑pit toxins. We disagree that our characterization of the host‑nation burn pit was inaccurate. CJTF‑OIR provided documents showing that the Camp Taji BOS‑I considered the solid waste dumping site we describe in this report as an Iraqi‑operated burn pit. In addition, those documents show that the Camp Taji BOS‑I was concerned about potential health effects associated with the host nation burn pit.
The Chief of Staff disagreed with our recommendation for the Commander to direct his staff to review and update the PWS to include all DoD and Army requirements that are applicable to BLS services at Camp Taji. The Chief of Staff also disagreed with our recommendation to perform a review of the actions of the logistics officials. The Chief of Staff agreed with our recommendation to improve personnel accountability at Camp Taji.
Although the Chief of Staff disagreed with our recommendations to review his staff’s actions in the development of the Camp Taji BLS contract requirements and to incorporate additional DoD regulations, as appropriate, into the PWS, CJTF‑OIR staff stated that after the project to install incinerators is completed, CJTF‑OIR will update the PWS to include a requirement to dispose of solid waste through incineration. This demonstrates that CJTF‑OIR continues to take action to address weakness in the PWS requirements. Therefore, we urge the Chief of Staff to reconsider his non‑concurrence with our recommendations. We consider these recommendations unresolved, and request CJTF‑OIR provide comments on the final report.
Comments from the Chief of Staff partially addressed the specifics of our recommendations to strengthen oversight of the Camp Taji population reported by the contractor. The Chief of Staff agreed with our recommendations to improve BOS‑I’s tracking of Camp Taji’s population; therefore, these recommendations are resolved but remain open. We will close these recommendations when we verify that the Camp Taji BOS‑I is receiving the Joint Personnel Status and Casualty Report and that the Joint Asset Movement Management System is operational at Camp Taji. The Chief of Staff did not address the specifics of our recommendation to formally document overlapping responsibilities related to the contractor population to ensure oversight personnel coordinate their activities. Therefore, this recommendation is unresolved.
This report is a result of Project No. D2019‑D000RJ‑0161.000.