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entitled 'Combating Terrorism: Increased Oversight and Accountability 
Needed over Pakistan Reimbursement Claims for Coalition Support Funds' 
which was released on June 24, 2008. 

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Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

June 2008: 

Combating Terrorism: 

Increased Oversight and Accountability Needed over Pakistan 
Reimbursement Claims for Coalition Support Funds: 

Combating Terrorism: 

GAO-08-806: 

GAO Highlights: 

Highlights of GAO-08-806, a report to congressional requesters. 

Why GAO Did This Study: 

The United States has reimbursed Pakistan, a key ally in the global war 
on terror, about $5.56 billion in Coalition Support Funds (CSF) for its 
efforts to combat terrorism along its border with Afghanistan. The 
Department of Defense (Defense) provides CSF to 27 coalition partners 
for costs incurred in direct support of U.S. military operations. 
Pakistan is the largest recipient of CSF, receiving 81 percent of CSF 
reimbursements as of May 2008. 

This report focuses on (1) the extent to which Defense has consistently 
applied its guidance to validate the reimbursements claimed by Pakistan 
and (2) how the Office of the Defense Representative to Pakistan’s 
(ODRP) role has changed over time. To address these objectives, GAO 
reviewed CSF oversight procedures, examined CSF documents, and 
interviewed Defense officials in Washington, D.C., U.S. Central Command 
in Florida, and Pakistan. 

What GAO Found: 

Defense Comptroller issued new guidance in 2003 to enhance CSF 
oversight. The guidance calls for, among other things, CSF 
reimbursement claims to contain quantifiable information that indicates 
the incremental nature of support (i.e., above and beyond normal 
operations), validation that the support or service was provided, and 
copies of invoices or documentation supporting how the costs were 
calculated. While Defense generally conducted macro-level analytical 
reviews called for in its guidance, such as determining whether the 
cost is less than that which would be incurred by the United States for 
the same service, for a large number of reimbursement claims Defense 
did not obtain detailed documentation to verify that claimed costs were 
valid, actually incurred, or correctly calculated. GAO found that 
Defense did not consistently apply its existing CSF oversight guidance. 
For example, as of May 2008, Defense paid over $2 billion in Pakistani 
reimbursement claims for military activities covering January 2004 
through June 2007 without obtaining sufficient information that would 
enable a third party to recalculate these costs. Furthermore, Defense 
may have reimbursed costs that (1) were not incremental, (2) were not 
based on actual activity, or (3) were potentially duplicative. GAO also 
found that additional oversight controls were needed. For example, 
there is no guidance for Defense to verify currency conversion rates 
used by Pakistan, which if performed would enhance Defense’s ability to 
monitor for potential overbillings. 

Defense’s guidance does not specifically task ODRP with attempting to 
verify Pakistani military support and expenses, despite recognition by 
Defense officials that such verification is best performed by U.S. 
officials in Pakistan, who have access to Pakistani officials and 
information. As such, ODRP did not try to verify Pakistan CSF claims 
from January 2004 through August 2006. Beginning in September 2006, 
without any formal guidance or directive to do so from U.S. Central 
Command or the Defense Comptroller, ODRP began an effort to validate 
Pakistani military support and expenses. This increased verification 
effort on the part of ODRP contributed to an increase in the amount of 
Pakistani government CSF claims disallowed and deferred. Prior to 
ODRP’s increased verification efforts, the average percentage of 
Pakistani claims disallowed or deferred for January 2004 through August 
2006 was a little over 2 percent. In comparison, the average percentage 
of Pakistani claims disallowed or deferred for September 2006 through 
February 2007 was 6 percent and for the most recent claims (March 2007 
through June 2007) processed in February 2008, was approximately 22 
percent. However, ODRP’s continued oversight activity is not assured, 
as Defense had not developed formal guidance delineating how and to 
what degree ODRP should attempt to verify Pakistani claims for 
reimbursement. 

GAO recognizes that Defense may not be able to fully verify every 
Pakistani claim without the ability to access Pakistani records or do 
onsite monitoring. However, such ability would enhance CSF oversight. 

What GAO Recommends: 

GAO recommends that Defense consistently implement existing oversight 
criteria, formalize ODRP’s oversight responsibilities, and implement 
additional controls. Defense generally concurred with the 
recommendations but stated that the report lacked sufficient context, 
such as Pakistan’s military contributions enabled by CSF and Defense’s 
broad legal authority to dispense funds. This report does recognize 
Pakistan’s contributions and Defense’s legal authority. 

To view the full product, including the scope and methodology, click on 
[http://www.gao.gov/cgi-bin/getrpt?GAO-08-806]. For more information, 
contact Charles Michael Johnson Jr. at (202) 512-7331 or 
johnsoncm@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Defense Did Not Consistently Apply Its Existing Guidance, and 
Additional Procedures Are Needed to Ensure Accountability over CSF to 
Pakistan: 

ODRP Began Playing a Larger Role in the CSF Oversight Process in Late 
2006; However, ODRP's Continued Oversight Is Not Assured: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Department of Defense: 

Appendix III: Pakistan CSF Reimbursement Claims, January 2004-June 
2007: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: December 2003 CSF Guidance for Embassies, Combatant 
Commanders, and the Comptroller: 

Figures: 

Figure 1: U.S. CSF Reimbursements to Pakistan, October 2001 through 
June 2007: 

Figure 2: CSF Reimbursement Process: 

Figure 3: Comptroller Approvals and Disapprovals of Pakistani Navy CSF 
Reimbursement Claims for Boats, by Month, December 2005 through June 
2007: 

Figure 4: Average Monthly Food Costs Per Person by Force Reimbursed to 
Pakistan Government, September 2004 through June 2007: 

Figure 5: Effect of Exchange Rate Fluctuations on One Fixed Pakistani 
Claimed Cost, September 2004 through August 2005: 

Figure 6: Reimbursement Process for Pakistani Claims, March through 
June 2007: 

Figure 7: Pakistani CSF Reimbursement Claims Disallowed or Deferred, 
January 2004 through June 2007: 

Abbreviations: 

CENTCOM: U.S. Central Command: 

Comptroller: Office of the Under Secretary of Defense for Comptroller: 

CSF: Coalition Support Funds: 

Defense: Department of Defense: 

FATA: Federally Administered Tribal Areas: 

IMF: International Monetary Fund: 

ODRP: Office of the Defense Representative to Pakistan: 

United States Government Accountability Office: 

Washington, DC 20548: 

June 24, 2008: 

Congressional Requesters: 

Following the attacks of September 11, 2001, the United States began 
reimbursing coalition partners for their logistical and combat support 
of U.S. military operations in the global war on terror. These 
reimbursements, known as Coalition Support Funds (CSF), have reimbursed 
27 coalition allies for incremental costs (i.e., costs above and beyond 
the partner country's normal operating costs) incurred in direct 
support of U.S. military operations. Pakistan is the largest recipient 
of CSF payments, receiving $5.56 billion of $6.88 billion (81 percent) 
of all CSF reimbursements as of May 2008. CSF is structured as a 
reimbursement mechanism whereby the U.S. Department of Defense 
(Defense) policy is to validate that support was provided, costs were 
incurred, and that these costs were incremental to a country's normal 
military operations.[Footnote 1] In Pakistan, most of the 
reimbursements through CSF are intended to enable the government of 
Pakistan to attack terrorist networks in the Federally Administered 
Tribal Areas (FATA) and stabilize the border areas.[Footnote 2] 
Congress granted the Secretary of Defense the authority to make CSF 
payments "in such amounts as the Secretary may determine in [his] 
discretion, based on documentation determined by the Secretary of 
Defense to adequately account for the support provided."[Footnote 3] 
Any such determination by the Secretary shall be final and conclusive. 
Despite this broad authority, concerns have been raised, given the 
large amounts of CSF reimbursement payments to Pakistan, about the 
level of accountability and oversight over these funds. 

This report focuses on (1) the extent to which Defense has consistently 
applied its guidance to validate the reimbursements claimed by Pakistan 
and (2) how the Office of Defense Representative to Pakistan's (ODRP) 
role has changed over time. 

To address our objectives, we obtained information on CSF procedures 
from relevant officials at the Office of the Under Secretary of Defense 
for Comptroller (Comptroller), the Office of the Under Secretary of 
Defense for Policy, U.S. Central Command (CENTCOM), ODRP, and the State 
Department's Bureau of Political-Military Affairs. We also examined all 
CSF oversight documentation provided to us, including Pakistani 
government reimbursement claims, ODRP memos, CENTCOM validation memos, 
Comptroller evaluations, and other CSF documentation from February 2002 
through February 2008 (February 2008 was when the latest claim, for 
March through June 2007, was reimbursed). To assess the application of 
current CSF guidance, we examined the CSF oversight documentation noted 
above from January 2004 through February 2008. We chose this time frame 
because a previous Defense Inspector General report had already 
examined the pre-January 2004 CSF oversight controls and made 
recommendations to improve oversight.[Footnote 4] We evaluated these 
controls against all available Comptroller criteria and guidance, as 
well as internal control standards and general cost accounting criteria 
for adequacy, eligibility, and reasonableness. As part of our data 
reliability process, we confirmed that the data provided by the 
Comptroller were accurately recorded in the software we used to analyze 
the data. To assess the oversight role played by ODRP, we met with the 
relevant ODRP, CENTCOM, and Comptroller officials, as well as with 
other officials from the U.S. Embassy and Pakistan's Ministries of 
Defense and Interior. We visited Peshawar, near the FATA, to discuss 
operations being reimbursed with CSF funds with the U.S. consulate and 
Pakistan's 11th Army Corps and Frontier Corps. 

This is the fourth in a series of products we plan to release assessing 
various aspects of the U.S. engagement with Pakistan to combat 
terrorism.[Footnote 5] We plan to issue a fifth product that assesses 
the U.S. security, political, and development assistance activities 
used to meet U.S. strategic goals in Pakistan, as well as the progress 
of these efforts. 

We conducted this performance audit from September 2007 through June 
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 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. (See app. I 
for details on our scope and methodology.) 

Results in Brief: 

We found that Defense did not consistently apply its existing CSF 
oversight guidance and that certain deficiencies existed in Defense's 
oversight procedures. Defense's 2003 guidance calls for, among other 
things, CSF reimbursement claims to contain quantifiable information 
that indicates the incremental nature of support (i.e., above and 
beyond normal operations), validation that the support or service was 
provided, and copies of invoices or documentation supporting how the 
costs were calculated. While Defense generally conducted the macro- 
level analytical reviews called for in its guidance, such as 
determining whether the cost is less than that which would be incurred 
by the United States for the same services, for a large number of 
claims Defense did not obtain sufficient documentation from Pakistan to 
verify that claimed costs were incremental,[Footnote 6] actually 
incurred, or correctly calculated as called for by the Comptroller's 
CSF guidance. For example, as of May 2008, Defense paid over $2 billion 
in Pakistani reimbursement claims for military activities covering 
January 2004 through June 2007 without obtaining detailed information 
that would enable a third party to recalculate these costs.[Footnote 7] 
In addition, Defense often did not adequately document the basis for 
their decisions to allow or disallow claims, and we found 
inconsistencies in Defense payments that were not explained. As a 
result, Defense may have reimbursed costs that (1) were not 
incremental--i.e., above and beyond normal operations; (2) were not 
based on actual activity; or (3) were potentially duplicative. For 
example, Defense paid: 

* more than $200 million for Pakistan's air defense radar before ODRP 
questioned whether this was an incremental cost, as stipulated in CSF 
guidance;[Footnote 8] 

* approximately $30 million for army road construction and $15 million 
for bunker construction without evidence that the roads and bunkers had 
been built; and: 

* an average of more than $19,000 per vehicle per month for Pakistani 
navy reimbursement claims that appeared to contain duplicative charges 
for a fleet of fewer than 20 passenger vehicles. 

We also found that additional oversight controls were needed. 
Comptroller guidance calls for a historical comparison of claimed 
costs; however, the Comptroller's instructions do not indicate how this 
comparison should be performed. In addition, we found that there is no 
guidance for Defense to verify currency conversion rates used by 
Pakistan, which if performed would enhance Defense's ability to monitor 
for potential overbillings. 

Defense's 2003 guidance does not specifically task ODRP with attempting 
to verify Pakistani military support and expenses, despite recognition 
by Defense officials in Washington and CENTCOM that such verification 
is best performed by U.S. officials in Pakistan, who have access to 
Pakistani officials and information. As such, ODRP did not try to 
verify Pakistan CSF claims from January 2004 through August 2006. 
Beginning in September 2006, without any formal guidance or directive 
to do so from CENTCOM or the Comptroller, ODRP began an effort to 
validate Pakistani military support and expenses. This increased 
verification effort on the part of ODRP contributed to an increase in 
the amount of Pakistani government CSF claims disallowed and deferred. 
Prior to ODRP's increased verification efforts, the average percentage 
of Pakistani claims disallowed or deferred for January 2004 through 
August 2006 was almost 3 percent. In comparison, the average percentage 
of Pakistani claims disallowed or deferred for September 2006 through 
February 2007 was 6 percent, and for the most recent claims (March 2007 
through June 2007), processed in February 2008, was approximately 22 
percent. For example, ODRP observed poor readiness rates of Pakistani 
helicopters and recommended deferring payment for helicopter 
maintenance that had been routinely reimbursed. However, ODRP's 
continued oversight activity is not assured. As of May 2008, Defense 
had not developed formal guidance delineating how and to what degree 
ODRP should attempt to verify Pakistani military support and expenses. 

To improve CSF oversight, we are recommending that Defense consistently 
implement existing oversight criteria, formalize the roles and 
responsibilities of ODRP, work with the government of Pakistan to gain 
greater access, clarify guidance for cost fluctuation analysis, and 
develop criteria to evaluate the effect of currency exchange rates on 
reimbursement claims. Defense generally concurred with our 
recommendations, and indicated they had updated their CSF guidance to 
incorporate our recommendations. We plan to review this guidance when 
it is made available to us. 

Defense provided written comments on the report, which are reproduced 
in appendix II. We also met with cognizant officials from Defense to 
discuss their comments and observations. Defense provided technical 
comments and updates which we incorporated throughout the report, as 
appropriate. 

Defense's comments noted that our report did not give sufficient weight 
to (1) Pakistan's military contributions enabled by CSF; (2) the 
Department's adherence to the law; and (3) Pakistan's accounting 
standards. Our report does reflect Pakistan's contributions and the 
role of CSF, and states that Congress gave Defense broad authority to 
make CSF payments. Regarding Pakistan's accountability standards, we 
acknowledge that there are limitations in any arrangement with another 
sovereign nation, but note that Pakistan provided more detailed 
documentation to support their claims after a request from the 
Comptroller in 2006. 

Background: 

In late 2001, as the United States focused on toppling the Taliban 
regime and fighting al Qaeda in Afghanistan, Pakistan's importance as 
an ally in the global war on terror increased. According to Defense, 
Pakistan's military operations and other contributions to Operation 
Enduring Freedom in Afghanistan quickly threatened to become 
unsustainable on its $2.5 billion defense budget. As a result, Defense 
requested supplemental funding from Congress to provide payments to 
Pakistan for logistical and military support in connection with 
Operation Enduring Freedom. In response, Congress passed the Defense 
Appropriations Act for Fiscal Year 2002, stipulating that the "Defense 
Emergency Response Fund" could be used by the Secretary of Defense to 
reimburse coalition partners for logistical and military support to 
U.S. military operations.[Footnote 9] This funding became known as 
Coalition Support Funds. 

To provide Defense with maximum flexibility, Congress passed the 
Defense Appropriations Act for Fiscal Year 2002, which granted the 
Secretary of Defense the authority to make CSF payments notwithstanding 
any other provision of law in such amounts as the Secretary may 
determine in his discretion, based on documentation determined by the 
Secretary to adequately account for the logistical and military support 
provided by partner nations.[Footnote 10] Any such determination by the 
Secretary shall be final and conclusive. The act did, however, require 
Defense to provide a 15-day notification of upcoming CSF 
reimbursements. Congress continued to provide funding for Pakistan 
through Defense without requiring specific accountability controls 
until 2008.[Footnote 11] Subsequent legislation required Defense to 
provide quarterly reports to the House and Senate Committees on 
Appropriations and the House and Senate Armed Services Committees on 
the use of funds made available for payments to Pakistan and other CSF 
recipients. Despite these revisions to the reporting requirements, 
Congress has consistently left decision-making on the suitability of 
documentation to the discretion of the Secretary of Defense. Defense, 
on its own, has instituted guidance that goes beyond what is mandated 
in law. 

According to Defense, CSF is critical to ensure Pakistan's continued 
support of U.S. efforts to combat terrorism. Defense officials stated 
that without CSF or a similar mechanism to reimburse Pakistan for 
support in Operation Enduring Freedom, Pakistan could not afford to 
deploy military forces along the Pakistan-Afghanistan border to support 
U.S. military operations in Afghanistan. Defense also indicates that 84 
percent of all containerized cargo and approximately 40 percent of all 
fuel for U.S. and coalition forces operating in Afghanistan passes 
through Pakistan. According to Defense officials, CSF has been a major 
factor in Pakistan's ongoing cooperation in support of U.S. goals in 
Pakistan and Afghanistan. 

Defense has used CSF to reimburse Pakistan for Operation Al Mizan, a 
major deployment of the Pakistan army in the North West Frontier 
Province and the Federally Administered Tribal Areas (FATA) that border 
Afghanistan that began in 2001 and has continued in various phases to 
this date.[Footnote 12] Defense also states that CSF payments to 
Pakistan have played a key role in supporting U.S. national security 
goals in Pakistan to combat terrorists that threaten U.S. interests in 
America, Pakistan, Afghanistan, and Western Europe. The CSF 
reimbursements to Pakistan from October 2001 through June 2007 (the 
latest period of support reimbursed by Defense) are shown in figure 1. 

Figure 1: U.S. CSF Reimbursements to Pakistan, October 2001 through 
June 2007: 

This figure is a bar graph showing U.S. CSF reimbursements to Pakistan, 
October 2001 through June 2007. The X axis represents dates, and the Y 
axis represents U.S. dollars (in millions). 

Dates: Oct.-Dec. 2001; 
U.S. dollars: 300. 

Dates: Jan.-Dec. 2002; 
U.S. dollars: 847. 

Dates: Jan.-Dec. 2003; 
U.S. dollars: 753. 

Dates: Jan.-Dec. 2004; 
U.S. dollars: 1221. 

Dates: Jan.-Dec. 2005; 
U.S. dollars: 915. 

Dates: Jan.-Dec. 2006; 
U.S. dollars: 1070. 

Dates: Jan.-June 2007; 
U.S. dollars: 453. 

[See PDF for image] 

Source: GAO analysis of Defense oversight documentation. 

Note: The most recent claims processed during our review were completed 
in February 2008 and covered Pakistani government reimbursement claims 
for the months March 2007 through June 2007. 

[End of figure] 

Evolution of the CSF Oversight Process: 

In a February 2002 internal memo, the Comptroller expressed 
dissatisfaction with Defense's ability to verify the costs claimed in 
Pakistan's December 2001[Footnote 13] reimbursement claim. The 
Comptroller noted that the reimbursement claim contained total costs 
but no supporting details. For example, the claim reported a total cost 
for army airlift without providing information on number of sorties 
flown, the dates, costs, time frames, purpose, number or types of 
aircraft flown, or number of man-hours involved. According to the 
February 2002 memo, the government of Pakistan was unprepared or unable 
to reconstruct these costs in a verifiable manner in line with standard 
U.S. government accounting practices and expectations. Staff at CENTCOM 
in Tampa, Florida, and at ODRP in the embassy were unable to fill in 
such details. Despite this concern, the Defense Office of General 
Counsel concluded, based on the statutory authority provided to the 
Secretary of Defense, that the Secretary of Defense could legally 
reimburse all of the cost categories identified by the Comptroller as 
legally defensible. The United States eventually reimbursed Pakistan 
$300 million. 

In 2003, at the request of the Comptroller, the Defense Inspector 
General performed an audit of the CSF oversight process for all 
countries seeking CSF reimbursements. The report found deficiencies in 
both Defense's CSF guidance, as well as the supporting documentation 
CSF recipients provided to support their claims. It recommended 
improvements in Defense's analysis of CSF reimbursement requests and 
greater documentation requirements for countries seeking reimbursement. 
In response, the Comptroller published guidance in December 2003 to 
clarify the roles and responsibilities of CENTCOM and other regional 
combatant commanders and of the Comptroller in the CSF oversight 
process. The 2003 guidance notes that Congress provided the Secretary 
of Defense with the authority to determine how much to reimburse 
partner countries, and how much documentation was required to 
adequately account for the support provided. However, the guidance also 
stated that CENTCOM and the Comptroller are to obtain sufficient 
documentation to validate that Pakistani military support had been 
provided and that costs were incurred, reasonable, and appropriate 
under the CSF program. Table 1 summarizes the review criteria in the 
December 2003 Comptroller guidance. We address the implementation of 
these and other criteria in greater detail later in this report. 

Table 1: December 2003 CSF Guidance for Embassies, Combatant 
Commanders, and the Comptroller: 

Office responsibility: Defense personnel (such as ODRP) at embassies 
assist host country military personnel in formulating their claims for 
reimbursement before forwarding the claims to their combatant 
commander; 
Guidance: * CSF reimburses countries that have incurred incremental 
costs (i.e., above and beyond normal levels) to provide logistical and 
military support to U.S. military operations in connection with U.S. 
operations in Iraq, Afghanistan, and elsewhere in the global war on 
terrorism; 
* Examples of reimbursable costs: transport of forces, sustainment of 
forces, increased use of equipment or vehicles; 
* Requests for reimbursement must contain quantifiable information that 
clearly indicates incremental nature of support, such as total 
personnel fed, number and types of vehicles repaired, total fuel 
consumed, total number of flight sorties. 

Office responsibility: Combatant commanders (such as CENTCOM) must 
submit documentation to the Comptroller that sufficiently supports the 
country's reimbursement request; 
Guidance: * Identification of who requested the service, for what 
period of time (i.e., a one-time reimbursement requirement versus a 
recurring requirement), and the initial estimate of the cost of the 
support or service; 
* Validation that the support or service was provided, and confirmation 
that the costs incurred were incremental (i.e., that the costs were 
based on the U.S. requirement and would not otherwise have been 
incurred by the country requesting reimbursement); 
* A narrative description of the types of costs incurred and a 
description of how the costs for each were computed; 
* Copies of invoices for support provided, or in the absence of 
invoices, documentation supporting how the costs were derived for each 
category of cost, and their basis of measurement. 

Office responsibility: Comptroller receives the package from CENTCOM 
and evaluates the reasonableness of the reimbursement request; 
Guidance: * Comparison, at a macro level, of claimed costs to the U.S. 
cost to provide the same support; 
* Evaluation of the reasonableness of the individual categories for 
which reimbursement is requested; 
* Comparison of representative U.S. costs for a subset of items (where 
similar comparisons can be made); 
* Assessment that the claimed costs are consistent with previous 
reimbursement requests. 

Source: Defense. 

[End of table] 

Under the December 2003 guidance and oversight process, Pakistan would 
first submit its claim for reimbursement to ODRP at the U.S. Embassy in 
Islamabad. According to Comptroller guidance, ODRP would assist the 
Pakistani military in formulating the reimbursement claim before 
sending the claim to CENTCOM in Tampa, Florida. CENTCOM would then 
conduct its own review in an attempt to link claimed expenses to U.S. 
military operations before forwarding the claim package to the 
Comptroller. Under this process, ODRP and CENTCOM staff can make 
recommendations to defer or disallow costs based on their analysis of 
the Pakistan submission; however, the Comptroller makes the final 
recommendation to the Secretary of Defense on which costs should be 
paid, deferred, or disallowed. 

The Department of State, the Office of Management and Budget, and 
Congress also have a role in the CSF oversight process after the 
Comptroller has finished its review. The Department of State and the 
Under Secretary of Defense for Policy must each verify that the CSF 
reimbursement is consistent with the U.S. government's national 
security policy and does not adversely affect the balance of power in 
the region. In addition, Defense is required to consult with the 
Director of the Office of Management and Budget during the CSF process. 
Defense is also required to provide a 15-day notification of the 
upcoming reimbursement, as well as quarterly reports to the House and 
Senate Committees on Appropriations and the House and Senate Armed 
Services Committees on the use of funds made available for payments to 
Pakistan and other CSF recipients. Congress passed the National Defense 
Authorization Act for Fiscal Year 2008, which now requires Defense to 
submit an itemized description of logistic support, supplies, and 
services "provided by Pakistan to the United States for which the 
United States provided reimbursement" during the period beginning 
February 1, 2008 and ending September 30, 2009.[Footnote 14] The CSF 
process is detailed in figure 2. 

Figure 2: CSF Reimbursement Process: 

This figure is a flowchart of CSD reimbursement process. 

[See PDF for image] 

Source: GAO analysis of Defense documentation and discussions with 
OUSD/Comptroller. 

[End of figure] 

In July 2006, the Comptroller provided the Pakistani government with a 
cost template and information intended to clarify the types of costs 
that were reimbursable under CSF and the information the Comptroller 
required to support Pakistan's reimbursement claims. Furthermore, 
according to Defense, the Office of the Under Secretary of Defense for 
Policy emphasized the importance of enhancing transparency within 
Pakistan's CSF claims in a June 2007 letter to the Pakistan Ministry of 
Defense. 

Defense Did Not Consistently Apply Its Existing Guidance, and 
Additional Procedures Are Needed to Ensure Accountability over CSF to 
Pakistan: 

We found that Defense did not consistently apply existing CSF guidance 
and that certain deficiencies existed in their oversight 
procedures.[Footnote 15] We reviewed the Pakistani claims for January 
2004 through June 2007, as well as related CENTCOM and Comptroller 
memos, to determine if DOD had consistently applied the Comptroller 
criteria issued in December 2003. The memos prepared by the Comptroller 
generally included the four macro-level analytical reviews outlined in 
the criteria; however, implementation of these criteria was not 
sufficient to validate claimed costs. For example, the Comptroller 
generally performed a comparison of total claimed costs to the 
estimated U.S. cost to provide the same services; however, there was 
not enough information in the Pakistani claims to determine that the 
claimed amount and the estimated U.S. cost included the same expenses 
or that the claimed costs were valid. Defense guidance developed by the 
Comptroller calls for obtaining sufficient information to validate 
Pakistani claims to determine that costs were incurred, reasonable, and 
appropriate. However, Defense did not fully implement this criteria. 
For example, Defense reimbursed Pakistan over $2 billion for claims 
from January 2004 through June 2007 without obtaining detailed 
documentation that would allow a third party to recalculate the costs. 
In addition, Defense often did not adequately document the basis for 
their decisions to allow or disallow claims, and we found 
inconsistencies in Defense payments that were not explained. As a 
result, Defense may have paid costs that were (1) not incremental, (2) 
not based on actual activity, or (3) potentially duplicative. We also 
found that additional oversight controls were needed. Specifically, 
while Comptroller guidance calls for a historical comparison of claimed 
costs, the guidance does not indicate why or how the comparison should 
be performed. Additionally, Defense did not verify the currency 
conversion rates used by Pakistan from January 2004 through June 2007 
and, as a result, may have overpaid Pakistani claims due to the 
devaluation of the Pakistan rupee. 

Defense Made Payments without Obtaining Detailed Documentation to 
Support Pakistani Claims: 

The Comptroller's CSF guidance states that Pakistani claims should 
include associated invoices. In the absence of such support, CENTCOM 
officials should obtain from Pakistan a detailed description of how 
these costs were computed. For example, claims for fuel should include 
information such as total fuel consumed, the number and types of 
vehicles supported, and best available assessments of the number of 
miles driven or hours employed. However, we found that few of the 
Pakistani claims we reviewed met the criteria contained in the 
Comptroller's guidance. For example, 76 percent of the army's costs 
from January 2004 through June 2007 lacked sufficient information to 
allow Defense to perform basic recalculations needed to verify the 
claims, such as quantity times price.[Footnote 16] Despite the lack of 
documentation, Defense reimbursed Pakistan more than $2.2 billion. An 
official at ODRP with a role in reviewing CSF reimbursement claims 
stated that, based on the scarce details provided in the CSF claims, it 
was nearly impossible to know the actual cost of claimed items. When we 
discussed this issue with the Comptroller's office, they indicated that 
the Pakistani claims do not provide enough detail to explain the 
context of the costs, which makes it difficult to determine whether the 
costs are incremental (i.e., that claimed costs are above and beyond 
the partner country's normal operating costs) and, therefore, whether 
under the Comptroller's guidance the costs should be reimbursed. 

We found other examples where Defense officials did not obtain 
sufficient information necessary to validate the claims and did not 
adequately document the basis for their decisions to allow or disallow 
claims. As a result, there were inconsistencies in Defense's 
reimbursement of certain costs. For example, as illustrated in figure 
3, Defense paid Pakistani navy claimed costs for boats for about half 
of the months and disallowed them the other half, despite no 
discernable differences in the level of support the Pakistani 
government provided for the claims. 

Figure 3: Comptroller Approvals and Disapprovals of Pakistani Navy CSF 
Reimbursement Claims for Boats, by Month, December 2005 through June 
2007: 

This figure is a timeline showing Comptroller approvals and 
disapprovals of Pakistani Navy CSF reimbursement claims for boasts, by 
month, December 2005 through June 2007. 

Month/Year: December 2005; 
Disallowed: [Empty]; 
Paid: [Check].  

Month/Year: January 2006; 
Disallowed: [Empty]; 
Paid: [Check].  

Month/Year: February 2006; 
Disallowed: [Empty]; 
Paid: [Check].  

Month/Year: March 2006; 
Disallowed: [Check]; 
Paid: [Empty].  

Month/Year: April 2006; 
Disallowed: [Check]; 
Paid: [Empty].  

Month/Year: May 2006; 
Disallowed: [Check]; 
Paid: [Empty].  

Month/Year: June 2006; 
Disallowed: [Check]; 
Paid: [Empty].  

Month/Year: July 2006; 
Disallowed: [Check]; 
Paid: [Empty].  

Month/Year: August 2006; 
Disallowed: [Check]; 
Paid: [Empty].  

Month/Year: September 2006; 
Disallowed: [Empty]; 
Paid: [Check].  

Month/Year: October 2006; 
Disallowed: [Empty]; 
Paid: [Check].  

Month/Year: November 2006; 
Disallowed: [Check]; 
Paid: [Empty].  

Month/Year: December 2006; 
Disallowed: [Check]; 
Paid: [Empty]. 

Month/Year: January 2007; 
Disallowed: [Check]; 
Paid: [Empty].  

Month/Year: February 2007; 
Disallowed: [Check]; 
Paid: [Empty].  

Month/Year: March 2007; 
Disallowed: [Empty]; 
Paid: [Check].  

Month/Year: April 2007; 
Disallowed: [Empty]; 
Paid: [Check].  

Month/Year: May 2007; 
Disallowed: [Empty]; 
Paid: [Check].  

Month/Year: June 2007; 
Disallowed: [Empty]; 
Paid: [Check].  

[See PDF for image] 

Source: Defense. 

Note: Figure includes all monthly reimbursement claims that itemized 
costs for navy rigid hull inflatable boats. 

[End of figure] 

We identified additional inconsistently reimbursed costs that contained 
no discernable differences in the level of support. For example, the 
Comptroller generally disallowed Pakistani army claims for bulletproof 
jackets but occasionally paid them. Conversely, the Comptroller 
generally paid for army telephone cables but occasionally disallowed 
these costs. Without better support for the rationale behind disallowed 
costs, we could not determine if these costs were reimbursed consistent 
with the Comptroller's guidance. According to Defense officials, 
payments were made based on informed judgment, however they could not 
provide documentation to support each instance. 

Defense Paid Costs That May Not Have Been Incremental: 

Comptroller guidance states that reimbursement claims must clearly 
indicate the incremental nature of the logistical and military support 
provided--i.e., that claimed costs are above and beyond the partner 
country's normal operating costs. However, we found that the Pakistani 
claims did not provide such information, which led to differences among 
Defense officials as to whether the claims should be disallowed or 
deferred until Pakistan could provide additional support. 

Defense paid Pakistan $200 million in radar expenses from January 2004 
through February 2007. For the March through June 2007 claims, ODRP 
recommended the Comptroller disallow the costs, reasoning that this was 
not an incremental expense, as terrorists in the FATA did not have air 
attack capability. However, the Comptroller took the position that 
Pakistan likely incurred some increased costs by using the radars to 
police the airspace over the Northwest Frontier Province (i.e., to 
patrol, monitor, and provide air traffic control) and provide air 
traffic control for U.S. military support flights into Afghanistan. The 
Comptroller nonetheless agreed that the claims lacked sufficient detail 
to determine whether these charges were definitively incremental. In 
the March through June 2007 claim package, the Comptroller chose to 
defer the air defense radar costs until Pakistan could provide better 
justification for the charges. 

Defense May Have Paid Costs That Were Not Based on Actual Activity or 
Expenses: 

According to the Comptroller's criteria, both the Comptroller and 
CENTCOM are responsible for validating that claimed costs are 
associated with actual activities and are based on documentation that 
adequately accounts for the support provided. However, the 
documentation we reviewed as part of our audit did not provide 
sufficient support that all claimed costs were based on actual activity 
or expenses. For example, Defense paid more than $30 million for army 
road construction[Footnote 17] and over $15 million for army bunker 
construction[Footnote 18] without adequate support. Defense paid these 
costs despite a CENTCOM recommendation to disallow the claims for road 
construction in September and October 2006 due to insufficient 
documentation. For the most recent claims processed in February 2008, 
covering the months March 2007 through June 2007, concerns about the 
validity of these charges led ODRP to request that the Pakistani 
military provide the coordinates of the roads and bunkers built. As of 
June 2008, Pakistan had not provided this additional information, and 
Defense has not paid these costs. 

We also found large unexplained differences between the average costs 
of food per person for each force, as shown in figure 4. 

Figure 4: Average Monthly Food Costs Per Person by Force Reimbursed to 
Pakistan Government, September 2004 through June 2007: 

This figure is a combination line graph showing average monthly costs 
per person by force reimbursed to Pakistan government, September 2004 
through June 2007. The X axis represents the years, and the Y axis 
represents U.S. dollars. 
			
Month/Year: Sep. 2004; 
Cost per (Pakistan air force): 766.23; 
Cost per (Pakistan army): 170.65; 
Cost per (Pakistan navy): 1085.42. 

Month/Year: Oct. 2004; 
Cost per (Pakistan air force): 385.98; 
Cost per (Pakistan army): 170.74; 
Cost per (Pakistan navy): 480. 

Month/Year: Nov. 2004; 
Cost per (Pakistan air force): 390; 
Cost per (Pakistan army): 170.69; 
Cost per (Pakistan navy): 495.79. 

Month/Year: Dec. 2004; 
Cost per (Pakistan air force): 390; 
Cost per (Pakistan army): 170.69; 
Cost per (Pakistan navy): 479.59. 

Month/Year: Jan. 2004; 
Cost per (Pakistan air force): 386.86; 
Cost per (Pakistan army): 164.96; 
Cost per (Pakistan navy): 492.23. 

Month/Year: Feb. 2004; 
Cost per (Pakistan air force): 386.86; 
Cost per (Pakistan army): 164.96; 
Cost per (Pakistan navy): 496.4. 

Month/Year: Mar. 2004; 
Cost per (Pakistan air force): 386.86; 
Cost per (Pakistan army): 164.96; 
Cost per (Pakistan navy): 447.66. 

Month/Year: Apr. 2004; 
Cost per (Pakistan air force): 386.86; 
Cost per (Pakistan army): 164.96; 
Cost per (Pakistan navy): 496.3. 

Month/Year: May 2005; 
Cost per (Pakistan air force): 386.86; 
Cost per (Pakistan army): 165; 
Cost per (Pakistan navy): 480. 

Month/Year: Jun. 2005; 
Cost per (Pakistan air force): 386.86; 
Cost per (Pakistan army): 165; 
Cost per (Pakistan navy): 444.34. 

Month/Year: Jul. 2005; 
Cost per (Pakistan air force): 386.86; 
Cost per (Pakistan army): 165; 
Cost per (Pakistan navy): 549.02. 

Month/Year: Aug. 2005; 
Cost per (Pakistan air force): 386.86; 
Cost per (Pakistan army): 165; 
Cost per (Pakistan navy): 528.7. 

Month/Year: Sep. 2005; 
Cost per (Pakistan air force): 368.57; 
Cost per (Pakistan army): 165; 
Cost per (Pakistan navy): 636.7. 

Month/Year: Oct. 2005; 
Cost per (Pakistan air force): 368.57; 
Cost per (Pakistan army): 165; 
Cost per (Pakistan navy): 651.3. 

Month/Year: Nov. 2005; 
Cost per (Pakistan air force): 368.57; 
Cost per (Pakistan army): 165; 
Cost per (Pakistan navy): 630. 

Month/Year: Dec. 2005; 
Cost per (Pakistan air force): 368.57; 
Cost per (Pakistan army): 165; 
Cost per (Pakistan navy): 806. 

Month/Year: Jan. 2006; 
Cost per (Pakistan air force): 368.57; 
Cost per (Pakistan army): 165; 
Cost per (Pakistan navy): 806. 

Month/Year: Feb. 2006; 
Cost per (Pakistan air force): 368.57; 
Cost per (Pakistan army): 165; 
Cost per (Pakistan navy): 806. 

Month/Year: Nov. Mar. 2006; 
Cost per (Pakistan air force): 368.57; 
Cost per (Pakistan army): 181.5; 
Cost per (Pakistan navy): 806. 

Month/Year: Nov. Apr. 2006; 
Cost per (Pakistan air force): 368.57; 
Cost per (Pakistan army): 181.5; 
Cost per (Pakistan navy): 775.81. 

Month/Year: Nov. May. 2006; 
Cost per (Pakistan air force): 368.57; 
Cost per (Pakistan army): 181.5; 
Cost per (Pakistan navy): 775.81. 

Month/Year: Nov. Jun. 2006; 
Cost per (Pakistan air force): 368.57; 
Cost per (Pakistan army): 181.5; 
Cost per (Pakistan navy): 780. 

Month/Year: Nov. Jul. 2006; 
Cost per (Pakistan air force): 409.07; 
Cost per (Pakistan army): 181.5; 
Cost per (Pakistan navy): 806. 

Month/Year: Aug. 2006; 
Cost per (Pakistan air force): 409.07; 
Cost per (Pakistan army): 181.5; 
Cost per (Pakistan navy): 806. 

Month/Year: Nov. Sep. 2006; 
Cost per (Pakistan air force): 409.07; 
Cost per (Pakistan army): 181.5; 
Cost per (Pakistan navy): 181.5. 

Month/Year: Nov. Oct. 2006; 
Cost per (Pakistan air force): 409.07; 
Cost per (Pakistan army): 181.5; 
Cost per (Pakistan navy): 181. 

Month/Year: Nov. Nov. 2006; 
Cost per (Pakistan air force): 408.9; 
Cost per (Pakistan army): 181.49; 
Cost per (Pakistan navy): 431. 

Month/Year: Nov. Dec. 2006; 
Cost per (Pakistan air force): 408.9; 
Cost per (Pakistan army): 181.5; 
Cost per (Pakistan navy): 459. 

Month/Year: Jan. 2007; 
Cost per (Pakistan air force): 408.95; 
Cost per (Pakistan army): 181.5; 
Cost per (Pakistan navy): 462.2. 

Month/Year: Feb. 2007; 
Cost per (Pakistan air force): 408.89; 
Cost per (Pakistan army): 208.74; 
Cost per (Pakistan navy): 378.2. 

[See PDF for image] 

Source: GAO analysis of food cost data from Defense and troop levels 
from Pakistan claims. 

Note: Pakistani reimbursement claims January 2004 through August 2004 
did not provide sufficient information to allow us to calculate average 
food costs per person. 

[End of figure] 

As figure 4 shows, navy monthly food costs per person were generally 
higher than monthly air force and army food costs per person. Navy 
claims for food rapidly increased from approximately $445 per sailor in 
June 2005 to $800 per sailor in December 2005, while air force and army 
food costs per person remained stable. Despite these anomalies, the 
Comptroller continued to pay the navy $800 per sailor for food until 
September 2006, when the Comptroller partially disallowed these costs, 
reducing the cost of navy food to the same amount as that paid for the 
army (approximately $200 per person). In November 2006, Defense 
approved navy food cost at approximately the same level as that paid 
for the air force (approximately $400 per person). However, the 
Comptroller deferred all navy food costs for the March through June 
2007 claim period (processed in February 2008), pending receipt of 
additional justification from Pakistan. 

In addition, we found that Defense paid the Pakistani navy more than 
$1.5 million in possibly inflated costs for damage to navy vehicles. On 
average, Defense paid the Pakistani navy more than $5,700 per vehicle 
per month in damages, in comparison with the army's average claim of 
less than $100 per vehicle per month.[Footnote 19] According to the 
most recent navy claims, these vehicles generally consisted of 
passenger cars and SUVs that were not involved in combat. By contrast, 
the army vehicles were used to conduct military operations in the FATA 
and border region. 

Defense Paid Costs That Were Potentially Duplicative: 

Comptroller guidance calls for CENTCOM to ensure that costs are not 
counted twice; however, none of the CENTCOM memos we reviewed provided 
any indication that a review for duplicate costs had been performed. As 
a result, Defense paid more than $8.9 million in potentially 
duplicative costs. For example, the most recent Pakistani navy claim 
(June 2007) includes cost categories titled "vehicle damage" and "cost 
of vehicles repaired," but there is no detail provided to explain the 
differences between these two categories, and there was insufficient 
detail to determine whether some or all of the claimed costs were 
unique or duplicative. This claim also included the categories "cost of 
fuel for vehicles" and "average cost of running of vehicle deployment 
on operation," which could also contain duplicate charges. The detail 
provided within these categories was insufficient to determine the 
difference between these costs, and therefore they could contain 
duplicate charges. Despite this lack of detail, we found that Defense 
paid the Pakistani navy an average of over $19,000 per vehicle per 
month (more than $3.7 million per year)[Footnote 20] to operate, 
maintain, and repair a fleet of fewer than 20 passenger vehicles 
without sufficient information to determine that these costs were not 
duplicative. 

Opportunities Exist to Improve CSF Oversight Controls: 

We found deficiencies in the Comptroller's guidance concerning 
historical comparison of claimed costs and verification of currency 
conversions. Specifically, we found that while Comptroller guidance 
calls for a historical comparison of claimed costs, it does not 
indicate how this comparison should be performed. In addition, we found 
that CSF guidance does not require Defense to identify or evaluate the 
exchange rates used to convert claimed costs from Pakistani rupees into 
U.S. dollars, and, as a result, potential overbillings may have gone 
undetected. 

Potentially Significant Cost Fluctuations Were Not Investigated: 

The Comptroller guidance calls for the Comptroller to perform a 
historical comparison of claimed costs to previous reimbursements made 
by the United States for similar support. Such an analysis could 
identify costs that do not reflect actual activity levels. However, we 
found that the Comptroller's guidance does not describe how the 
comparison should be performed. In our audit, we found that some of 
Pakistan's claimed costs experienced potentially significant 
unexplained fluctuations from month to month. Although the Comptroller 
noted some of these fluctuations, we found that it did not investigate 
the reasons behind them. For example, Defense paid the army's 
largest[Footnote 21] cost claimed in April 2006, which experienced a 12 
percent ($2.8 million) increase from March, without investigating this 
fluctuation. As a result, Defense may be paying for costs based on 
activities that did not occur. 

Currency Conversions Were Not Verified: 

CSF guidance does not require Defense to identify or evaluate the 
exchange rates used for claims presented in U.S. dollars. Foreign 
currency exchange rates, such as those computed by the International 
Monetary Fund (IMF), fluctuate.[Footnote 22] As a result, transactions 
made in a foreign currency can result in transaction gains or losses. 
Since January 2004, the Pakistani rupee has declined over 6 percent 
against the U.S. dollar. Consequently, fewer dollars should have over 
time purchased more rupees, resulting in a lower cost to the CSF 
program. Pakistani reimbursement claims are presented in U.S. dollars; 
however, the Comptroller did not verify the currency conversions 
calculated by Pakistan. Although the Comptroller was not required to do 
so, lack of such verification may have resulted in overpayment of 
Pakistan claims. For example, on one cost category we reviewed, Defense 
may have overpaid more than $1.25 million over 12 months because it did 
not consider the currency conversion used to calculate the cost. In 
performing our review, we used the claimed amounts[Footnote 23] and 
exchange rates that were stated in Pakistan's September and October 
2004 claims, and we converted the claimed cost into rupees. We then 
converted the claimed cost back into U.S. dollars using the applicable 
IMF exchange rates and compared the resulting figure with the amount 
paid by Defense. Figure 5 illustrates the results of our analysis and 
shows that CSF would have been billed fewer dollars had IMF exchange 
rates been used. 

Figure 5: Effect of Exchange Rate Fluctuations on One Fixed Pakistani 
Claimed Cost, September 2004 through August 2005: 

This figure is a combination line graph showing the effect of exchange 
rate fluctuations on one fixed Pakistani claimed cost, September 2004 
through August 2005. The X axis represents the month and year, and the 
Y axis represents U.S. dollars. The lines represent the amounts 
claimed, and the amounts converted using IMF exchange rates. 

Amounts claimed	Amounts converted using IMF exchange rates

Month and Year: Sept.-04; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5629.87. 

Month and Year: Oct.-04; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5607.5. 

Month and Year: Nov.-04; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5590.04. 

Month and Year: Dec.-04; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5579.81. 

Month and Year: Jan.-05; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5615.74. 

Month and Year: Feb. 2005; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5615.74. 

Month and Year: Mar. 2005; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5615.74. 

Month and Year: Apr. 2005; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5615.74. 

Month and Year: May-05; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5580.71. 

Month and Year: June-05; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5562.74. 

Month and Year: July-05; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5566.74. 

Month and Year: Aug. 2005; 
Amounts claimed: 5700; 
Amounts converted using IMF exchange rates: 5564.4. 

[See PDF for image] 

Source: GAO analysis of Pakistani claims and IMF data. 

Note: IMF data includes market rate, period average, by month, exchange 
rates for U.S. dollars per Pakistan rupee. 

[End of figure] 

Most of the Pakistani claims do not provide enough information to 
determine if the costs were appropriately converted from rupees to 
dollars. Therefore, we were unable to calculate the potential 
overbilling for all claims for the entire period under review. However, 
if Pakistan has been using a fixed exchange rate, then Defense has 
likely overpaid its reimbursements. If the rupee continues to decline 
against the dollar, future Pakistani claims calculated using a fixed 
exchange rate will become more and more inflated over time. 

ODRP Began Playing a Larger Role in the CSF Oversight Process in Late 
2006; However, ODRP's Continued Oversight Is Not Assured: 

Defense's 2003 guidance did not specifically task ODRP with attempting 
to verify Pakistani military support and expenses, despite recognition 
by Defense officials that such verification is best performed by U.S. 
officials in Pakistan, who have direct access to Pakistani officials 
and information. As such, ODRP did not try to verify Pakistani CSF 
claims until September 2006, when, without any formal guidance or 
directive to do so, ODRP began an effort to validate Pakistani military 
support and expenses. This increased verification effort contributed to 
an increase in the amount of disallowals and deferrals of the Pakistani 
government's CSF claims from an average of a little over 2 percent from 
January 2004 through August 2006, an average of 6 percent from 
September 2006 through February 2007, and 22 percent for the most 
recent claims (March 2007 through June 2007) processed in February 
2008. Despite this increased effort, there is no assurance that ODRP 
will continue this level of oversight because Defense has not issued 
formal guidance delineating ODRP verification responsibilities. 

Defense Never Formally Tasked ODRP to Attempt to Verify That Pakistani 
Military Support Was Provided and That Costs Were Incurred: 

According to the Standards for Internal Control in the Federal 
Government, clear delegation of authority and responsibility is 
important to establishing an effective internal control 
system.[Footnote 24] Defense officials in Washington, at CENTCOM, and 
at the U.S. Embassy in Islamabad stated that U.S. officials in Pakistan 
are best suited to perform primary verification that Pakistani military 
support was provided and that claimed costs were actually incurred. 
ODRP officers have access to a broad range of Pakistani military 
officials, including some involved in military operations, and can 
conduct limited field visits and onsite inspections if permitted by the 
Pakistani government. By contrast, Comptroller staff are located 
thousands of miles from Pakistan and lack the level of access available 
to ODRP officials. Despite this, Defense never explicitly tasked ODRP 
with performing such verification efforts. 

In Pakistan's case, the Comptroller's 2003 guidance did not specify 
whether this verification should take place in Pakistan or from CENTCOM 
in Florida. The guidance simply indicated that ODRP should assist 
Pakistan in formulating their claims. However, the guidance did not 
require or suggest that ODRP attempt to verify that Pakistan's claimed 
military support had been provided or that its costs were actually 
incurred. For example, it did not recommend that ODRP conduct any 
oversight activities, such as onsite inspections of completed Pakistani 
construction or a comparison of flight hours to maintenance costs. 

ODRP Initiated Verification of Pakistani Support and Costs; Contributed 
to Increases in the Amount of Claims Deferred or Disallowed: 

In late 2006, without any formal guidance or directive to do so from 
CENTCOM or the Comptroller, ODRP began an effort to verify that 
Pakistani military support was provided and costs were actually 
incurred as claimed in the military's requests for reimbursement. 
According to ODRP officials, this new effort stemmed from a concern 
that some of Pakistan's reported costs may not have been valid or 
properly supported. They also stated that the Comptroller's July 2006 
presentation to Pakistani officials helped ODRP conduct more detailed 
verification because Pakistan began to provide greater detail in its 
reimbursement claims. ODRP officials who were in Pakistan from July 
2005 through March 2008 stated they had received no training or 
guidance from Defense on whether, or how, to conduct verification of 
Pakistani reimbursement claims. These officials said that the 2006 
presentation was the first time they had seen any guidance on what 
could or could not be reimbursed under the CSF program or what type of 
information was needed to support Pakistan's reimbursement claims. 

As a result, ODRP recommended for the first time that Defense disallow 
or defer costs that it found questionable, beginning with Pakistan's 
September through October 2006 claim. For example, ODRP recommended 
that the Comptroller disallow payments to Pakistan for procurement of 
bulletproof vests, radios, and road construction due to insufficient 
information necessary to verify the costs. Defense eventually 
disallowed approximately $13 million of the September through October 
2006 reimbursement claim. 

ODRP's increased verification efforts contributed to significantly 
larger disallowals and deferrals ($81.2 million) in the most recently 
processed (February 2008) Pakistan government reimbursement claims for 
the months of March through June 2007. ODRP recommended deferring 
payment on $38.1 million in claimed costs until the Pakistani 
government provided information necessary to verify its claims. For 
example, ODRP recommended deferring payment to Pakistan on its 
reimbursement request for $22.3 million in helicopter maintenance 
costs. ODRP found that even though the United States had paid Pakistan 
$55 million in CSF reimbursements for maintenance of helicopters in the 
border area, only a few of these helicopters were fully 
operational.[Footnote 25] According to ODRP officials, the Pakistani 
army was not maintaining the helicopters, causing essential systems to 
malfunction. Given the poor readiness rates, ODRP recommended that the 
Comptroller defer payment on Pakistan's helicopter maintenance claims 
until a process could be implemented to ensure that Pakistan could 
maintain its helicopter fleet. ODRP also recommended disallowing 
payment on an additional $42.3 million to Pakistan for such things as 
air defense radars, procurement of tents and vests, and funding for 
Pakistan's joint staff headquarters operations. 

After ODRP submitted its recommendations, CENTCOM and the Comptroller 
performed their own reviews of the reimbursement claim (see fig. 6). 

Figure 6: Reimbursement Process for Pakistani Claims, March through 
June 2007: 

This figure is a flowchart showing the reimbursement process for 
Pakistani claims, March through June 2007. 

[See PDF for image] 

Source: GAO analysis of Defense oversight documentation. 

[End of figure] 

The Comptroller disagreed with some of ODRP's recommendations. For 
example, ODRP recommended disallowing $26.4 million for the maintenance 
of air defense radars since terrorists in the border region possessed 
no air force. The Comptroller noted, however, that these radars could 
also provide air traffic control for Pakistani military aircraft 
operating in the area and for U.S. military flights to Afghanistan. As 
a result, the Comptroller modified ODRP's recommendations to disallow 
certain costs and instead deferred payment on these costs until 
Pakistan could provide more information to support the reimbursement 
request. However, as of May 2008, Defense has not paid any of these 
deferred CSF costs because Pakistan has not provided evidence to 
indicate that these costs were valid. Figure 7 shows the increased CSF 
disallowals and deferrals during ODRP's increased oversight activity in 
the September through October 2006 claims, and particularly in the 
latest claim period (March through June 2007), when Defense disallowed 
or deferred a total of $81.2 million over these four months. 

Figure 7: Pakistani CSF Reimbursement Claims Disallowed or Deferred, 
January 2004 through June 2007: 

This figure is a line graph showing Pakistani CSF reimbursement claims 
disallowed or deferred, January 2004 through 2007. The X axis 
represents the month/year, and the Y axis represents the U.S. dollars 
(in millions). Between September 2006 and Jube 2007, the graph shows 
increased ODRP oversight. 

Month/year: Jan. 2004; 
U.S. dollars: 2. 

Month/year: Feb. 2004; 
U.S. dollars: 2. 

Month/year: Mar. 2004; 
U.S. dollars: 3. 

Month/year: Apr. 2004; 
U.S. dollars: 3. 

Month/year: May 2004; 
U.S. dollars: 3. 

Month/year: June 2004; 
U.S. dollars: 3. 

Month/year: July 2004; 
U.S. dollars: 7. 

Month/year: Aug. 2004; 
U.S. dollars: 5.7903. 

Month/year: Sept. 2004; 
U.S. dollars: 0. 

Month/year: Oct. 2004; 
U.S. dollars: 0. 

Month/year: Nov. 2004; 
U.S. dollars: 0. 

Month/year: Dec. 2004; 
U.S. dollars: 0. 

Month/year: Jan. 2005; 
U.S. dollars: 2. 

Month/year: Feb. 2005; 
U.S. dollars: 0. 

Month/year: Mar. 2005; 
U.S. dollars: 3. 

Month/year: Apr. 2005; 
U.S. dollars: 0. 

Month/year: May 2005; 
U.S. dollars: 1. 

Month/year: June 2005; 
U.S. dollars: 1. 

Month/year: July 2005; 
U.S. dollars: 1. 

Month/year: Aug. 2005; 
U.S. dollars: 2. 

Month/year: Sept. 2005; 
U.S. dollars: 4. 

Month/year: Oct. 2005; 
U.S. dollars: 0. 

Month/year: Nov. 2005; 
U.S. dollars: 0. 

Month/year: Dec. 2005; 
U.S. dollars: 0. 

Month/year: Jan. 2006; 
U.S. dollars: 2. 

Month/year: Feb. 2006; 
U.S. dollars: 1. 

Month/year: Mar. 2006; 
U.S. dollars: 1. 

Month/year: Apr. 2006; 
U.S. dollars: 1. 

Month/year: May 2006; 
U.S. dollars: 3. 

Month/year: June 2006; 
U.S. dollars: 4. 

Month/year: July 2006; 
U.S. dollars: 1. 

Month/year: Aug. 2006; 
U.S. dollars: 2. 

Month/year: Sept. 2006; 
U.S. dollars: 6. 

Month/year: Oct. 2006; 
U.S. dollars: 7. 

Month/year: Nov. 2006; 
U.S. dollars: 6. 

Month/year: Dec. 2006; 
U.S. dollars: 5. 

Month/year: Jan. 2007; 
U.S. dollars: 5. 

Month/year: Feb. 2007; 
U.S. dollars: 4. 

Month/year: Mar. 2007; 
U.S. dollars: 23. 

Month/year: Apr. 2007; 
U.S. dollars: 22. 

Month/year: May. 2007; 
U.S. dollars: 21. 

Month/year: June. 2007; 
U.S. dollars: 15. 

[See PDF for image] 

Source: Defense. 

Note: There is a lag between the claimed period and Defense's 
reimbursement of claims. At the time of the issue of this report, the 
March through June 2007 claims, reimbursed in February 2008, were the 
latest round of claims reimbursed by Defense. GAO has not verified the 
reliability of Comptroller's data processing. 

[End of figure] 

The amount disallowed or deferred for March through June 2007 
represents a significant increase in CSF oversight by Defense. For 
example, from January 2004 through August 2006, Defense disallowed or 
deferred an average of a little more than 2 percent of each monthly 
Pakistani reimbursement claim, for a total of $59.4 million over a 32- 
month period. In comparison, the average percentage of Pakistani claims 
disallowed or deferred for September 2006 through February 2007 was 6 
percent or $33.3 million over a 6-month period and for the most recent 
claims (March 2007 through June 2007) processed in February 2008, was 
approximately 22 percent, or $81.2 million in a four month period. This 
four month period accounts for approximately 53 percent of the total 
CSF funding disallowed or deferred by Defense since January 2004 
($173.92 million). 

Based on our assessment, it appears that ODRP began this increased 
oversight effort without any formal guidance or directive to do so. The 
Comptroller has provided no formal guidance that stipulates ODRP should 
verify that Pakistani military support has actually been performed and 
that expenses were actually incurred. Furthermore, officials at ODRP 
from 2005 to early 2008 said that the Comptroller had provided no 
guidance or training on the level of oversight they should provide. 
Despite this lack of guidance, in November 2007, officials at the 
Comptroller and the Office of the Under Secretary of Defense for Policy 
stated that ODRP was in fact responsible for performing this oversight. 
However, as of May 2008, Defense had not formalized any new guidance on 
ODRP's verification responsibilities. 

No Guidance to Ensure Continued Oversight by ODRP: 

Despite ODRP's increased oversight activity, continuity of this 
oversight is not assured. According to Standards for Internal Control 
in the Federal Government, clear delegation of authority and 
responsibility is important to establishing an effective internal 
control system.[Footnote 26] However, as of May 2008, ODRP continued to 
lack formal guidance or training that explicitly described either its 
oversight responsibilities or the procedures for conducting such 
oversight. Staff at ODRP stated they had previously received little to 
no guidance or training on their specific role in analyzing Pakistani 
CSF reimbursement claims. Formal guidance is especially important in 
Pakistan, where U.S. officials are generally limited to 1-year tours 
due to the status of the U.S. mission in Islamabad as a high-risk post. 
Because of the constant turnover of Defense officials in Pakistan, 
clear guidance is needed to ensure the continuity of oversight efforts. 

In addition, the Comptroller has never provided guidance on how ODRP 
and Defense representatives in other sovereign countries should verify 
that the countries actually provided military support and that expenses 
were actually incurred. ODRP is largely dependent upon the quality of 
information supplied by the Pakistani military. According to Defense 
officials, Defense lacks the authority to audit the internal finances 
of the Pakistani military. Because of this, ODRP staff described their 
analysis as "macro-level verification," whereby the reasonableness of 
high-level costs reported in the Pakistani claim is judged through a 
comparison with other information. For example, ODRP's recommendation 
to defer helicopter maintenance costs in the March through June 2007 
claims stemmed from their comparison of Pakistan's reported maintenance 
costs against ODRP's knowledge of the low readiness rates of Pakistan's 
helicopters. Although such analyses can be supplanted by anecdotal 
information from discussions with Pakistani military officials or 
through occasional visits to the field, according to ODRP, the 
Pakistani government strictly controls foreigners' access to the FATA, 
making spot-checks difficult. The Pakistani submissions are, therefore, 
the chief component of the ODRP analysis. 

ODRP officials said they doubted that ODRP would ever be able to fully 
verify actual costs in Pakistan. First, the Pakistani military reports 
costs to ODRP that are already aggregates of many smaller costs. For 
example, food cost would include costs for procurement, transport, 
storage, and field preparation that ODRP cannot directly monitor. 
Furthermore, according to ODRP, although the Pakistani government 
generally keeps detailed financial records, these records are usually 
in paper form and electronic record keeping is rare. Additionally, the 
Pakistani military does not possess automated systems to track 
logistics and supplies. Because of these factors, information retrieval 
from the field and collation at the Pakistani joint staff level can 
take a great deal of time and may entail a certain amount of 
approximation and averaging. Given Pakistan's record-keeping systems, 
it is unclear to what level of precision ODRP should be expected to 
verify Pakistani support and incurred costs. 

Conclusions: 

Coalition Support Funds are critical components of America's global war 
on terror and the primary support for Pakistani operations to destroy 
the terrorist threat and close the terrorist safe haven in Pakistan's 
FATA. Following the attacks of September 11, 2001, Congress quickly 
authorized emergency funding to prevent another attack, and given the 
grave and immediate threat at the time, Congress recognized that 
ensuring accountability for these funds was secondary to protecting the 
nation from another attack. However, given the large amounts of funding 
provided to Pakistan since October 2001, and indications that Pakistan 
will continue to receive such payments in the future, we believe that 
Defense should ensure it follows its own guidance and consider what 
other guidance is needed. 

Our assessment found that while CSF played a key role in Pakistan's 
support for our war on terror, Defense had not followed its existing 
guidance and provided little oversight of the effort at the embassy in 
Pakistan. Defense had concerns about the accuracy of Pakistan's claims 
from the very first claim submitted in 2001. Based on the lack of 
supporting evidence in the Pakistani claims from January 2004 through 
June 2007 (the latest claims reimbursed by Defense), we found that 
neither Defense nor we could determine if Pakistan had actually 
incurred most of the costs in their claims. Prior to 2004, it appears 
that there was even less evidence to support Pakistan's claims. As a 
result, we conclude that Defense cannot accurately determine how much 
of the $5.56 billion in costs reimbursed to Pakistan since 2001 were 
actually incurred. 

As a result of these and other findings, we believe that Defense should 
consistently implement its own CSF guidance to fully verify Pakistani 
claims and ensure the effective use of CSF in meeting key U.S. national 
security goals. While we recognize that CSF is used to support 27 
countries in fighting terrorism, the fact that Pakistan receives 81 
percent of these funds indicates that Defense should provide oversight 
procedures that reflect the role Pakistan plays as both the major 
recipient of CSF and its role in supporting U.S. national security 
objectives in Pakistan and Afghanistan. Additionally, we recognize that 
Defense may not be able to fully verify all Pakistani claims without 
having the ability to access the Pakistani government's records and 
make site visits or conduct spot checks. ODRP's recent increased 
efforts, however, show that greater oversight may be achieved through 
the use of U.S. representatives in Pakistan. 

Recommendations for Executive Action: 

To improve the impact and oversight of CSF payments to Pakistan, we 
make the following five recommendations to the Secretary of Defense: 

* Consistently implement existing criteria to disallow or defer 
Pakistani claims that do not include the documentation needed to verify 
the claims. 

* Define and formalize the roles and responsibilities of ODRP. 

* Work with the government of Pakistan to develop procedures to allow 
ODRP or other U.S. representatives to conduct greater oversight of CSF 
use in Pakistan, including the potential use of onsite inspections. 

* Clarify guidance for Comptroller analysis of cost fluctuations. 

* Develop and apply criteria to evaluate currency exchange rates to 
ensure that the U.S. government is not overpaying for Pakistan 
operations. 

Agency Comments and Our Evaluation: 

Defense provided written comments on the report, which are reproduced 
in appendix II. 

Defense generally concurred with our recommendations, and indicated 
they had updated their CSF guidance to incorporate our recommendations. 
We plan to review this guidance when it is made available to us. In 
addition, Defense's comments noted that our report did not give 
sufficient weight to three areas. These include the Pakistan's 
significant contributions to the global war on terror enabled by CSF; 
the fact that the Department has adhered to the law; and that Pakistan 
is a sovereign country that may not meet U.S. accounting and 
administration standards. However, our report does reflect Pakistan's 
efforts in combating terrorism and the role of CSF. Furthermore, we 
note several times that Congress granted the Secretary of Defense the 
authority to make CSF payments in such amounts as the Secretary may 
determine in his discretion, based on documentation determined by the 
Secretary of Defense to adequately account for the support provided. 

Although we acknowledge that there are limitations in any arrangement 
with another sovereign nation, we believe that Defense should work more 
closely with Pakistan to improve their capacity to support these 
claims. We note that the information provided by Pakistan has improved 
over time, particularly when Defense has provided additional guidance 
to Pakistan. For example, following the Comptroller's visit to Pakistan 
in 2006, Pakistan's more detailed submissions allowed ODRP to conduct 
greater oversight of Pakistan's claims, leading to the increases in 
deferrals and disallows in late 2006 and 2007. In addition, we did not 
assume that Pakistan could provide receipts for all items; we assessed 
whether Defense followed its guidelines. According to the Comptroller's 
guidelines, a recipient country's reimbursement claim must contain 
quantifiable information and supporting documentation on how costs were 
derived so Defense can validate the claim. Most of Pakistan's claims 
that we reviewed lacked this information. 

We also received technical comments from Defense, which we have 
incorporated throughout the report, where appropriate. 

We are sending copies of this report to interested congressional 
committees, as well as the Secretaries of State and Defense. We will 
also make copies available to others upon request. In addition, the 
report will be available at no charge on the GAO Web site at 
[hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-7331 or johnsoncm@gao.gov. 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 IV. 

Signed by: 

Charles Michael Johnson Jr.: 
Director, International Affairs and Trade: 

List of Requesters: 

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

The Honorable Gary L. Ackerman: 
Chairman: 
The Honorable Mike Pence: 
Ranking Member: 
Subcommittee on the Middle East and South Asia: 
Committee on Foreign Affairs: 
House of Representatives: 

The Honorable John F. Tierney: 
Chairman: 
The Honorable Christopher Shays: 
Ranking Member: 
Subcommittee on National Security and Foreign Affairs: 
Committee on Oversight and Government Reform: 
House of Representatives: 

The Honorable Tom Harkin: 
The Honorable Robert Menendez: 
United States Senate: 

[End of section] 

Appendix I: Scope and Methodology: 

Legislation governing the Coalition Support Funds (CSF) program states 
that the Secretary of Defense's determination whether documentation 
adequately supports reimbursement to key cooperating nations is final 
and conclusive. Our review therefore focused on the extent to which 
Defense has applied its own guidance to validate reimbursements and on 
Office of the Defense Representative to Pakistan's (ODRP) role in this 
process. To conduct our review, we obtained information on current 
procedures from relevant officials at the Office of the Under Secretary 
of Defense for Comptroller (Comptroller), the Office of the Under 
Secretary of Defense for Policy, U.S. Central Command (CENTCOM), ODRP, 
and the State Department's Bureau of Political-Military Affairs. We 
also examined all CSF oversight documentation provided to us, including 
Pakistani government reimbursement claims, ODRP memos, CENTCOM 
validation memos, Comptroller evaluations, and other CSF documentation 
from February 2002 through June 2007 (the latest period of support 
reimbursed by Defense.) Additionally, we examined all Defense CSF 
guidance provided to us. 

To examine the extent to which Defense has applied its guidance to 
validate costs claimed by Pakistan, we first reviewed a December 2003 
Defense Inspector General report[Footnote 27] that cited deficiencies 
in the CSF oversight process from October 2001 through May 2003. 
Because this report led to new CSF oversight guidance in December 2003, 
our assessment of Defense's oversight controls focused on 42 monthly 
reimbursement claims submitted by the Pakistani government from January 
2004 to June 2007. As part of our data reliability process, we 
confirmed that the data provided by the Comptroller were accurately 
recorded in the software we used to analyze the data. We did not verify 
the reliability of Comptroller's data processing. As part of this 
review, we examined all available Comptroller criteria and guidance-- 
including the December 2003 guidance, as well as the July 2006 
presentation to the Pakistani government and the February 2008 
flowchart. Using the Comptroller criteria, the internal control 
standards, and general cost accounting criteria for adequacy, 
eligibility, and reasonableness, we: 

* recalculated selected portions of Pakistani claims for mathematical 
accuracy; 

* reviewed items included in claims and noted items that may be 
nonincremental under CSF, duplicative charges, and questionable dollar 
amounts for the charges; 

* compared selected claims and payments over time to analyze 
consistency of charges disallowed; 

* reviewed ODRP cables and memos, CENTCOM analyses, and Comptroller 
analyses for support for charges, disallowed amounts, and fluctuations 
in claimed amounts; 

* compared supporting documentation to Comptroller-issued criteria to 
determine compliance; and: 

* compared supporting documentation to internal control criteria to 
determine the sufficiency of Comptroller criteria and current oversight 
procedures. 

To assess the oversight role played by ODRP, we met with the officials 
noted above, as well as with other officials from the U.S. Embassy and 
Pakistan's Ministries of Defense and Interior. We visited Peshawar, 
near the Federally Administered Tribal Areas, to conduct discussions 
with the U.S. consulate and Pakistan's 11th Army Corps and Frontier 
Corps regarding operations being reimbursed with CSF funds. We also 
examined all of the previously mentioned CSF oversight documents and 
guidance. 

We conducted this performance audit from September 2007 to June 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 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. 

[End of section] 

Appendix II: Comments from the Department of Defense: 

The Assistant Secretary Of Defense: 
2700 Defense Pentagon: 
Washington, DC 20301-2700: 

Asian & Pacific Security Affairs: 

Mr. Charles Johnson Jr.: 
Director, International Counterterrorism Issues, International Affairs 
and Trade: 
Government Accountability Office: 
441 G Street, N.W.: 
Washington, D.C. 20548: 

Mr. Johnson: 

This is the Department of Defense (DoD) response to the GAO Draft 
Report, "Combating Terrorism: Increased Oversight and Accountability 
Over Pakistan Reimbursement Claims for Coalition Support Funds Needed 
(GAO-08-806)," dated June 16, 2008.

We have enclosed comments addressing the report. My point of contact is 
Mr. Eric Lebson, 703-697-3754, or e-mail: eric.lebson@osd.mil.

Sincerely,

Signed: 

for James J. Shinn: 

GAO Draft Report Dated June 16, 2008 Gao-08-806: 

"Combating Terrorism: Increased Oversight and Accountability Over 
Pakistan Reimbursement Claims for Coalition Support Funds Needed," 

Department Of Defense Comments On The Draft Report By GAO On Coalition 
Support Funds: 

The Department of Defense (DoD) appreciates the opportunity to comment 
on this draft report. DoD welcomes periodic reviews on the 
administration of critical DoD programs like Coalition Support Funds 
(CSF) and looks forward to recommendations to enhance effectiveness and 
oversight. In the case of this investigation, however, DoD believes the 
draft of the final report fails to give sufficient weight to three key 
areas: 

* The context in which CSF evolved, the significant contribution to the 
Global War on Terror (GWoT) that Pakistan has made and that CSF 
enabled, and the required flexibility in guidance and processes for 
contingency environments. 

* The fact that the Department has consistently adhered to the letter 
and spirit of the law while continuously providing oversight and 
analysis of submissions. 

* That Pakistan and several other recipients of reimbursements under 
the CSF authority are sovereign countries that may not meet U.S.-
comparable standards of accounting and administration. 

CSF Context: 

During the buildup and initial phases of Operation Enduring Freedom 
(OEF), Pakistan allowed the U.S. nearly unlimited use of its airspace, 
made available four of its air bases and one seaport for staging and 
onward movement of deploying coalition forces, provided jet fuel and 
other utilities at these locations, and deployed substantial ground 
forces to provide force protection. In December 2001, at U.S. request, 
the Pakistan Army deployed major ground forces for the first time in 
its history into the largely ungoverned Federally Administered Tribal 
Areas (FATA) to attempt to capture remnants of Al Qaeda and Afghan 
Taliban forces fleeing into Pakistan from the Tora Bora area of 
Afghanistan. 

As of October 2007, approximately 40 percent of fuel (roughly 120,000 
gallons per day) and 84 percent of all containerized cargo for delivery 
to Coalition forces operating in Afghanistan passed through Pakistan. 
Pakistan's cooperation in facilitating this support is a critical 
component of the Coalition's ability to operate in Afghanistan. 

The financial demands of military operations and other contributions to 
OEF on the relatively restricted Pakistan defense budget (approximately 
$2.5 billion in 2001) quickly threatened to become unsustainable. 
Initially, the U.S. used a variety of methods to reimburse Pakistan and 
other coalition partners for their contributions to OEF and the GWoT, 
which eventually resulted in Congress providing the CSF authority. 

Without the CSF authority or a similar mechanism to reimburse Pakistan 
for its level of effort in OEF, it is unlikely that Pakistan would have 
the financial capacity to deploy and maintain sizable military forces 
in the FATA and other locations along the Pakistan- Afghanistan border 
to support U.S. and International Security Assistance Force (ISAF) 
military operations in Afghanistan. Such support has been significant. 
Since December 2001, Pakistan has conducted 91 major and countless 
small operations in the FATA and other locations along the border with 
Afghanistan. 

The cost to Pakistan of these operations, in human terms, has been 
significant. Approximately 1,400 Pakistani security forces members have 
lost their lives since 2001 in the GWoT; since July 2007, over 700 
Pakistanis have been killed by suicide bombings. CSF reimbursements to 
Pakistan have been a significant factor in Pakistan's ability to assist 
U.S. operations in the GWoT. 

DoD Oversight of CSF: 

DoD regularly reviews implementation of the CSF program to ensure it is 
effective and complies with Congressional intent. DoD frequently 
refines the review and approval process for CSF reimbursements to adapt 
to coalition country systems and to apply lessons learned in the 
contingency environment. A series of meetings with involved parties 
took place in conjunction with the 2006 revision. OSD Comptroller is 
presently promulgating revised 2008 guidance. Useful inputs from 
independent entities – such as the DoD Inspector General and the 
Government Accountability Office (GAO) – combined with our internal 
initiatives and visits with responsible parties throughout the process 
have, and will continue to, enhance oversight and facilitate improved 
communications and consistency. The various offices within the U.S. 
Embassy in Islamabad, U.S. Central Command, and the Office of the 
Secretary of Defense each play a role in managing the program and in 
identifying opportunities for enhancement. 

Pakistan – like the other 26 recipient nations of CSF – is a sovereign 
country. Their bookkeeping standards, processes and sensitivity about 
military operations are different and, at times, less transparent than 
our own. The political circumstances under which nations like Pakistan 
operate make their processes somewhat different from our own. In 
addition, the tribal areas of Pakistan are `denied areas' – not only to 
U.S. forces, but largely to Pakistani military forces as well. This 
impacts their responsiveness, apparent transparency, and ability to 
work with us on the ground to conduct on-site verification of claimed 
expenses. The Government of Pakistan provides documentation for all of 
its CSF claims. However, the GAO appears to operate on a presumption 
that receipts are available for all items, when the reality is that 
receipts are not readily available for helicopter flying hours, road 
building and maintenance of tracks in a combat zone. In cases where 
receipts are not available, DoD procedures provide for the use of a 
comparison with U.S. costs for similar operations as an important tool 
in analyzing reasonableness. 

DoD Responses to GAO Recommendations: 

* Recommendation 1: The GAO recommends that the Secretary of Defense 
consistently implement existing criteria to disallow or defer Pakistani 
claims that do not supply the documentation needed to verify their 
claims. (p. 39/GAO Draft Report) 

DOD Response: Partially concur. The Department concurs with the 
importance of following a set of criteria to support approval of 
payments while simultaneously accommodating the fact that partner 
countries often do not have financial systems, recordkeeping 
procedures, and data transparency comparable to the United States. The 
Department has clarified its guidance to emphasize the criteria used to 
approve payments when invoices, receipts, or contracts are not 
available to substantiate claims. Such criteria will include non-
financial indicators such as the size and scope of the mission for 
which costs are claimed. In the absence of detailed documentation, the 
Department will continue to evaluate claims under authority provided by 
statute. 

* Recommendation 2: The GAO recommends that the Secretary of Defense 
define and formalize the roles and responsibilities of the Office of 
Defense Representative to Pakistan (ODRP). (p. 39/CIAO Draft Report) 

DOD Response: Concur. The Department updated its guidance to clarify 
the roles and responsibilities of the U.S. Embassy personnel assigned 
to interact with cooperating nations on the subject of CSF 
reimbursements. 

* Recommendation 3: The GAO recommends that the Secretary of Defense 
work with the Government of Pakistan to develop procedures to allow the 
Office of Defense Representative to Pakistan or other U.S. 
representatives to conduct greater oversight of coalition support funds 
use in Pakistan, including the potential use of on-site monitoring. (p. 
39/GAO Draft Report) 

DOD Response: Concur. The Government of Pakistan does not permit access 
to the FATA to U.S. forces; therefore, certain operations require 
Pakistani forces to perform actions unaccompanied by U.S. on-site 
monitors. Pakistan has legitimate concerns about the safety of U.S. 
government representatives on tribal territory when they are operating 
in such close proximity to Al Qaeda and/or the Taliban. Because CSF is 
a reimbursement for expenses already incurred by Pakistan, on-site 
monitoring is not a realistic verification requirement. However, to the 
degree possible, Embassy and ODRP personnel work with Pakistani 
officials to conduct on-site inspections as a regular element of our 
security assistance relationship. DoD will continue to seek out such 
opportunities. 

* Recommendation 4: The GAO recommends that the Secretary of Defense 
clarify guidance for Comptroller analysis of cost fluctuations. (p. 
39/GAO Draft Report) 

DOD Response: Concur. The Department has already incorporated this 
recommendation into its revised guidance. 

* Recommendation 5: The GAO recommends that the Secretary of Defense 
develop and apply criteria to evaluate currency exchange rates to 
ensure that the U.S. Government is not overpaying for Pakistan 
operations. (p. 39/GAO Draft Report) 

DOD Response: Concur. The Department has already incorporated this 
recommendation into its revised guidance. 

[End of section] 

Appendix III Pakistan CSF Reimbursement Claims, January 2004-June 
2007A: 

Table 2: 

Date: Jan. 04; 
Pakistan request: $60,531,000; 
Defense reimbursement: $58,251,000; 
Disallowed or deferred: $2,280,000; 
Percentage of claim disallowed or deferred: 3.77%. 

Date: Feb. 04; 
Pakistan request: 65,334,100; 
Defense reimbursement: 62,981,000; 
Disallowed or deferred: 2,353,100; 
Percentage of claim disallowed or deferred: 3.60. 

Date: Mar. 04; 
Pakistan request: 79,541,600; 
Defense reimbursement: 76,886,000; 
Disallowed or deferred: 2,655,600; 
Percentage of claim disallowed or deferred: 3.34. 

Date: Apr. 04; 
Pakistan request: 84,890,100; 
Defense reimbursement: 82,094,200; 
Disallowed or deferred: 2,795,900; 
Percentage of claim disallowed or deferred: 3.29. 

Date: May 04; 
Pakistan request: 79,861,372; 
Defense reimbursement: 77,287,372; 
Disallowed or deferred: 2,574,000; 
Percentage of claim disallowed or deferred: 3.22. 

Date: June 04; 
Pakistan request: 95,048,300; 
Defense reimbursement: 327,033,276[B]; 
Disallowed or deferred: 3,097,000; 
Percentage of claim disallowed or deferred: 3.26. 

Date: July 04; 
Pakistan request: 96,857,000; 
Defense reimbursement: 90,345,700; 
Disallowed or deferred: 6,511,300; 
Percentage of claim disallowed or deferred: 6.72. 

Date: Aug. 04; 
Pakistan request: 115,104,000; 
Defense reimbursement: 109,313,700; 
Disallowed or deferred: 5,790,300; 
Percentage of claim disallowed or deferred: 5.03. 

Date: Sept. 04; 
Pakistan request: 93,246,580; 
Defense reimbursement: 92,784,580; 
Disallowed or deferred: 462,000; 
Percentage of claim disallowed or deferred: 0.50. 

Date: Oct. 04; 
Pakistan request: 89,067,574; 
Defense reimbursement: 88,625,574; 
Disallowed or deferred: 442,000; 
Percentage of claim disallowed or deferred: 0.50. 

Date: Nov. 04; 
Pakistan request: 79,928,000; 
Defense reimbursement: 79,856,000; 
Disallowed or deferred: 72,000; 
Percentage of claim disallowed or deferred: 0.09. 

Date: Dec. 04; 
Pakistan request: 75,478,500; 
Defense reimbursement: 75,114,600; 
Disallowed or deferred: 363,900; 
Percentage of claim disallowed or deferred: 0.48. 

Date: Jan. 05; 
Pakistan request: 87,255,700; 
Defense reimbursement: 85,661,800; 
Disallowed or deferred: 1,593,900; 
Percentage of claim disallowed or deferred: 1.83. 

Date: Feb. 05; 
Pakistan request: 80,535,500; 
Defense reimbursement: 80,219,300; 
Disallowed or deferred: 316,200; 
Percentage of claim disallowed or deferred: 0.39. 

Date: Mar. 05; 
Pakistan request: 89,853,500; 
Defense reimbursement: 86,698,400; 
Disallowed or deferred: 3,155,100; 
Percentage of claim disallowed or deferred: 3.51. 

Date: Apr. 05; 
Pakistan request: 67,431,200; 
Defense reimbursement: 67,102,600; 
Disallowed or deferred: 328,600; 
Percentage of claim disallowed or deferred: 0.49. 

Date: May 05; 
Pakistan request: 70,048,300; 
Defense reimbursement: 68,608,500; 
Disallowed or deferred: 1,439,800; 
Percentage of claim disallowed or deferred: 2.06. 

Date: June 05; 
Pakistan request: 70,072,000; 
Defense reimbursement: 68,722,000; 
Disallowed or deferred: 1,350,000; 
Percentage of claim disallowed or deferred: 1.93. 

Date: July 05; 
Pakistan request: 73,036,600; 
Defense reimbursement: 71,646,500; 
Disallowed or deferred: 1,390,100; 
Percentage of claim disallowed or deferred: 1.90. 

Date: Aug. 05; 
Pakistan request: 74,050,500; 
Defense reimbursement: 72,467,600; 
Disallowed or deferred: 1,582,900; 
Percentage of claim disallowed or deferred: 2.14. 

Date: Sept. 05; 
Pakistan request: 82,246,400; 
Defense reimbursement: 78,564,600; 
Disallowed or deferred: 3,681,800; 
Percentage of claim disallowed or deferred: 4.48. 

Date: Oct. 05; 
Pakistan request: 89,090,868; 
Defense reimbursement: 88,856,000; 
Disallowed or deferred: 234,868; 
Percentage of claim disallowed or deferred: 0.26. 

Date: Nov. 05; 
Pakistan request: 75,446,693; 
Defense reimbursement: 75,446,693; 
Disallowed or deferred: 0; 
Percentage of claim disallowed or deferred: 0.00. 

Date: Dec. 05; 
Pakistan request: 71,453,834; 
Defense reimbursement: 71,453,495; 
Disallowed or deferred: 339; 
Percentage of claim disallowed or deferred: 0.00[C]. 

Date: Jan. 06; 
Pakistan request: 80,939,674; 
Defense reimbursement: 79,400,674; 
Disallowed or deferred: 1,539,000; 
Percentage of claim disallowed or deferred: 1.90. 

Date: Feb. 06; 
Pakistan request: 78,962,330; 
Defense reimbursement: 78,406,260; 
Disallowed or deferred: 556,070; 
Percentage of claim disallowed or deferred: 0.70. 

Date: Mar. 06; 
Pakistan request: 89,039,426; 
Defense reimbursement: 87,766,027; 
Disallowed or deferred: 1,273,399; 
Percentage of claim disallowed or deferred: 1.43. 

Date: Apr. 06; 
Pakistan request: 93,058,372; 
Defense reimbursement: 92,032,823; 
Disallowed or deferred: 1,025,549; 
Percentage of claim disallowed or deferred: 1.10. 

Date: May 06; 
Pakistan request: 89,588,661; 
Defense reimbursement: 86,283,491; 
Disallowed or deferred: 3,305,170; 
Percentage of claim disallowed or deferred: 3.69. 

Date: June 06; 
Pakistan request: 104,869,074; 
Defense reimbursement: 100,877,374; 
Disallowed or deferred: 3,991,700; 
Percentage of claim disallowed or deferred: 3.81. 

Date: July 06; 
Pakistan request: 100,918,230; 
Defense reimbursement: 99,607,230; 
Disallowed or deferred: 1,311,000; 
Percentage of claim disallowed or deferred: 1.30. 

Date: Aug. 06; 
Pakistan request: 99,609,440; 
Defense reimbursement: 97,656,140; 
Disallowed or deferred: 1,953,300; 
Percentage of claim disallowed or deferred: 1.96. 

Date: Sept. 06; 
Pakistan request: 89,480,274; 
Defense reimbursement: 83,249,465; 
Disallowed or deferred: 6,230,809; 
Percentage of claim disallowed or deferred: 6.96. 

Date: Oct. 06; 
Pakistan request: 95,299,466; 
Defense reimbursement: 88,126,587; 
Disallowed or deferred: 7,172,879; 
Percentage of claim disallowed or deferred: 7.53. 

Date: Nov. 06; 
Pakistan request: 95,785,981; 
Defense reimbursement: 90,183,688; 
Disallowed or deferred: 5,602,293; 
Percentage of claim disallowed or deferred: 5.85. 

Date: Dec. 06; 
Pakistan request: 91,370,854; 
Defense reimbursement: 86,146,231; 
Disallowed or deferred: 5,224,623; 
Percentage of claim disallowed or deferred: 5.72. 

Date: Jan. 07; 
Pakistan request: 90,750,144; 
Defense reimbursement: 85,535,351; 
Disallowed or deferred: 5,214,793; 
Percentage of claim disallowed or deferred: 5.75. 

Date: Feb. 07; 
Pakistan request: 89,482,052; 
Defense reimbursement: 85,628,299; 
Disallowed or deferred: 3,853,753; 
Percentage of claim disallowed or deferred: 4.31. 

Date: Mar. 07; 
Pakistan request: 95,392,884; 
Defense reimbursement: 71,899,270; 
Disallowed or deferred: 23,493,614; 
Percentage of claim disallowed or deferred: 24.63. 

Date: Apr. 07; 
Pakistan request: 92,914,150; 
Defense reimbursement: 71,145,810; 
Disallowed or deferred: 21,768,340; 
Percentage of claim disallowed or deferred: 23.43. 

Date: May 07; 
Pakistan request: 90,265,124; 
Defense reimbursement: 69,536,440; 
Disallowed or deferred: 20,728,684; 
Percentage of claim disallowed or deferred: 22.96. 

Date: June 07; 
Pakistan request: 84,353,540; 
Defense reimbursement: 69,153,140; 
Disallowed or deferred: 15,200,400; 
Percentage of claim disallowed or deferred: 18.02. 

Date: Totals; 
Pakistan request: $3,597,488,897; 
Defense reimbursement: $3,658,654,790[B]; 
Disallowed or deferred: $173,916,083; 
Percentage of claim disallowed or deferred: [Empty]. 

Date: Prior to increased ODRP role. 

Date: Jan. 2004-Aug. 2006 avg. monthly disallow/defer; 
Disallowed or deferred: 2.15%; 
Percentage of claim disallowed or deferred: [Empty]. 

Date: Jan. 2004-Aug. 2006 total disallow/defer; 
Disallowed or deferred: $59,425,895; 
Percentage of claim disallowed or deferred: [Empty]. 

Date: Post increased ODRP role. 

Date: Sept. 2006-Feb. 2007 avg. monthly disallow/defer; 
Disallowed or deferred: 6.02%; 
Percentage of claim disallowed or deferred: [Empty]. 

Date: Sept. 2006-Feb. 2007 total disallow/defer; 
Disallowed or deferred: $33,299,150; 
Percentage of claim disallowed or deferred: [Empty]. 

Date: Mar.-June 2007 avg. monthly disallow/defer; 
Disallowed or deferred: 22.26%; 
Percentage of claim disallowed or deferred: [Empty]. 

Date: Mar.-June 2007 total disallow/defer; 
Disallowed or deferred: $81,191,038; 
Percentage of claim disallowed or deferred: [Empty]. 

Source: GAO analysis of Defense data. 

Notes: GAO has not verified the accuracy of Defense Comptroller's data 
processing. 

[A] The last U.S. reimbursement to Pakistan covered March through June 
2007 and was processed in February 2008. 

[B] June 2004 reimbursement includes a one-time Bell helicopter 
procurement totaling $235,081,976. The disallow/defer percentage for 
June 2004 does not take into account this figure. 

[C] Percent rounded to two decimal places. 

[End of table] 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Charles Michael Johnson Jr., (202) 512-7331 or johnsoncm@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Steve Sebastian, Director; 
Hynek Kalkus, Assistant Director; Roger Stoltz, Assistant Director; 
Edward J. George; David W. Hancock; Claude Adrien; Cara Bauer; Janice 
Friedeborn; Arthur James; Jeffrey S. Beelaert; Lynn Cothern; Mark 
Dowling; and Jena Sinkfield made key contributions to this report. 

[End of section] 

Footnotes: 

[1] CSF has funded a broad range of Pakistani military operations, 
including navy support for maritime patrols and interdiction 
operations; air force support for combat air patrol, reconnaissance and 
close air support missions, airlift support, and air traffic control; 
army military operations in the FATA; and increased management 
requirements at the Pakistan Joint Staff Headquarters. 

[2] According to U.S. embassy officials in Islamabad and unclassified 
U.S. intelligence documents, since 2002, al Qaeda and the Taliban have 
used Pakistan's FATA and the border region to attack Pakistani, Afghan, 
U.S., and coalition troops; plan and train for attacks against U.S. 
interests; destabilize Pakistan; and spread radical Islamist ideologies 
that threaten U.S. interests. 

[3] Reimbursements are made only after the Office of Management and 
Budget is consulted, the Secretary of State concurs and the 15 day 
notification to the appropriate congressional committees has taken 
place. 

[4] Department of Defense Inspector General, Financial Management: 
Coalition Support Funds, D-200420045 (Washington, D.C., Jan. 16, 2004). 
This is a classified report. 

[5] See GAO, Combating Terrorism: The United States Lacks Comprehensive 
Plan to Destroy the Terrorist Threat and Close the Safe Haven in 
Pakistan's Federally Administered Tribal Areas, GAO-08-622 (Washington, 
D.C.: Apr. 17, 2008); Preliminary Observations on the Use and Oversight 
of U.S. Coalition Support Funds Provided to Pakistan, GAO-08-735R 
(Washington, D.C.: May 6, 2008); and Combating Terrorism: U.S. Efforts 
to Address the Terrorist Threat in Pakistan's Federally Administered 
Tribal Areas Require a Comprehensive Plan and Continued Oversight, GAO-
08-820T (Washington, D.C.: May 20, 2008). 

[6] Defense guidance defines incremental costs as those costs that are 
above and beyond the partner country's normal operating costs. 

[7] This example is based on our analysis of Pakistani army claims and 
does not include the other service's claims. However, we found 
generally that the navy claims' documentation was similar to the army's 
and the other services' claims had less documentation. 

[8] The Comptroller took the position that Pakistan likely incurred 
some increased costs by using the radars to police the airspace over 
the Northwest Frontier Province and provide air traffic control for 
U.S. military support flights into Afghanistan. The Comptroller 
nonetheless agreed that the claims lacked sufficient detail to 
determine whether these charges were definitively incremental. 

[9] Pub. L. 107-117, sec 301, January 10, 2002. 

[10] Pub. L. 107-206, Operation and Maintenance, Defense-Wide, August 
2, 2002. 

[11] See, for example, Pub. L. 107-206; Pub. L. 108-11, sec 1310; Pub. 
L. 110-161. Beginning in 2003, with the passage of the Emergency 
Wartime Supplemental Appropriations Act, 2003 (Pub. L. 108-11), 
Congress required that CSF payments be made with concurrence of the 
Secretary of State and in consultation with the Director of OMB. The 
Secretary of Defense's determination with respect to the documentation 
supporting payments is final and conclusive. 

[12] The goal of this operation was to combat al Qaeda, Taliban, and 
other militants attempting to escape the U.S. invasion of Afghanistan 
by fleeing into Pakistan. According to Defense, Pakistan has deployed 
about 120,000 army and paramilitary troops in support of this 
operation, incurred more than 1,400 casualties, and killed hundreds of 
al Qaeda, Taliban, and other terrorists. 

[13] This reimbursement claim received by Defense in December 2001 
covered activity from October through December 2001. 

[14] Pub. L. 110-181, sec 1232(b). 

[15] Because a previous Defense Inspector General report led to new CSF 
oversight guidance in December 2003, our assessment focused on 
reimbursement claims submitted by Pakistan between January 2004 and 
June 2007. 

[16] This example is based on our analysis of Pakistani army claims and 
does not include the other service's claims. However, we found 
generally that the navy claims' documentation was similar to the 
army's, and the other services' claims had less documentation. Payments 
made to the Pakistani army constituted over 85 percent of total 
payments made to Pakistan from January 2004 through June 2007. 

[17] Army road construction costs were included as a specific line item 
beginning in September 2004. These costs were claimed and paid each 
month from September 2004 through February 2007. 

[18] Army bunker construction costs were included as a specific line 
item beginning in July 2006. These costs were claimed and paid each 
month from July 2006 through February 2007. 

[19] Average vehicle damage cost paid was calculated using claims in 
which vehicle damage was listed as a specific category (September 2004 
through June 2007). 

[20] These figures include the $5,700 average navy cost per vehicle per 
month for "vehicle damages" discussed previously. In addition, these 
figures do not include claims prior to September 2004, as these claims 
did not contain specific categories. 

[21] This cost category was the largest for April 2006 based on the 
percentage of total dollars claimed that was included in each category. 
This cost category accounted for 28 percent of the entire claim for 
April 2006. 

[22] GAO used the IMF market rate, period average, by month, in our 
analysis because this rate takes into account economic variables such 
as gross domestic product (GDP), revenue, and wages. 

[23] These claimed amounts did not fluctuate over the 12-month period 
and were presented in U.S. dollars. 

[24] See GAO, Standards for Internal Control in the Federal Government, 
GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). 

[25] Defense reimbursed Pakistan approximately $55 million for 
maintenance of the Pakistan army's MI-17 and AH-1 Cobra helicopter 
wings in the border area from July 2006 through February 2007. 

[26] See GAO/AIMD-00-21.3.1. 

[27] Department of Defense Inspector General, Financial Management: 
Coalition Support Funds, D-200420045 (Washington, D.C., Jan. 16, 2004). 
This is a classified report. 

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