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GAO-10-562R: 

United States Government Accountability Office: 
Washington, DC 20548: 

May 27, 2010: 

Congressional Committees: 

Subject: Opportunities to Improve Controls over Department of 
Defense's Overseas Contingency Operations Cost Reporting: 

From September 2001 through January 2010, Congress provided about 
$1.023 trillion in supplemental and annual appropriations in response 
to Department of Defense (DOD) requests for funding to support 
overseas contingency operations (OCO).[Footnote 1] In March 2010, DOD 
reported obligations[Footnote 2] of about $825 billion attributed to 
OCO for the period September 2001 through January 2010.[Footnote 3] 
DOD uses available cost-related information,[Footnote 4] along with 
other financial information, to evaluate OCO trends, formulate OCO 
funding requests, and monitor the costs of overseas operations. In 
addition, Congress considers this information in its deliberations on 
DOD requests for additional OCO funding. 

Our prior reviews have found the financial information in DOD's 
monthly OCO reports to be of questionable reliability.[Footnote 5] For 
example, we identified problems in DOD's processes for recording and 
reporting obligations, such as not including all OCO costs and the 
lack of a systematic process for ensuring that data are correctly 
entered into those systems.[Footnote 6] Consequently, we concluded 
DOD's reported OCO costs should be considered approximations. Based on 
our prior work, we made a number of recommendations to improve the 
reliability of OCO reported costs, with which DOD generally concurred. 

Consistent with our recommendations, DOD has taken steps intended to 
improve OCO cost reliability, such as clarifying cost category 
definitions and requiring military services (Army, Navy, Air Force, 
and Marine Corps) and other DOD components to analyze variances in 
reported OCO costs. Further, in fiscal year 2009, DOD initiated the 
Contingency Operations Reporting and Analysis Service (CORAS), an 
automated system and database through which DOD intended to provide 
more transparent, accurate, and timely reporting on costs attributed 
to OCO. Prior to the CORAS initiative, DOD had relied on manual 
procedures for accumulating data and reporting on costs attributed to 
OCO from the military services. With CORAS, the intent was to (1) 
eliminate such manual practices where feasible and instead use 
automated processes to retrieve and accumulate key financial OCO data 
from the military services' financial systems using a DOD-wide 
database and (2) add the capability to report on OCO-related funding 
(appropriations) and disbursements, as well as obligations. 

On December 18, 2009, we reported on the status of OCO funding and 
cost reporting.[Footnote 7] Among other things, we highlighted our 
preliminary observations related to DOD's internal controls for 
reliably reporting OCO costs. This letter presents our findings with 
respect to those preliminary observations along with related 
recommendations. The objective of our review, conducted under the 
authority of the Comptroller General to undertake work on his own 
initiative, was to determine whether DOD had adequately designed 
internal controls that, if implemented effectively, could enable DOD 
to provide more transparent and reliable cost-related data 
attributable to OCO. 

To determine whether DOD had designed adequate internal controls over 
reporting of OCO cost-related data, we reviewed internal control 
criteria related to reliably reporting financial data as defined in 
GAO's Standards for Internal Control in the Federal Government and 
Internal Control Standards: Internal Control Management and Evaluation 
Tool.[Footnote 8] We also reviewed DOD's requirements and guidance on 
reporting OCO costs, including DOD Financial Management Regulation 
(FMR) 7000.14-R, Volume 12, Chapter 23 on OCO reporting and the Under 
Secretary of Defense, Comptroller's (DOD Comptroller) Fiscal Year 2009 
Instructions for Contingency Cost Reports. We interviewed key 
officials from the Office of the Under Secretary of Defense 
(Comptroller), Defense Finance and Accounting Service (DFAS), and 
military services to understand the design of internal control 
activities over OCO processes and reporting, such as data validation, 
and to obtain any evidence that these activities were performed. We 
reviewed DOD and military service standard operating procedures and 
practices in comparison with federal and department standards and 
guidance to determine whether they contained key controls. 

We conducted this performance audit from January 2010 to May 2010 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. 

Summary of Results: 

While DOD's new cost reporting system and database, CORAS, was 
intended to provide more transparent, accurate, and timely reporting 
on costs that DOD attributes to OCO, we found that the design of 
internal control for reviewing and reporting OCO data did not contain 
key internal control activities. Specifically, we found the following: 

* In fiscal year 2009, the military services did not have clear, 
detailed written procedures for reviewing the reliability of OCO 
reported costs including steps for conducting and documenting 
validation activities such as reconciliations between CORAS data and 
OCO data in the services' official accounting systems; 

* DOD's financial management regulation on accounting for contingency 
operations[Footnote 9] did not clearly define validation activities-- 
such as reconciliations--require documentation of internal control 
activities, or require the DOD Comptroller to monitor the accuracy of 
OCO reported data; and: 

* DOD's implementation guidance for OCO reporting obscures the 
accuracy of current and prior-period OCO cost reporting by directing 
the military services to include, in the monthly data for the current 
period, adjustments for omissions and errors that occurred in prior 
periods. 

We are recommending that DOD and the military services clarify their 
respective guidance on validating data in the OCO report, retaining 
documentation on validation activities, and reporting adjustments 
related to prior periods. DOD agreed with four recommendations and 
partially agreed with one as discussed in more detail later in this 
report. 

Design of OCO Controls for Reviewing and Reporting OCO Data Missing 
Key Elements: 

For fiscal year 2009, as shown in table 1, none of the military 
services had fully developed clear, detailed written procedures on how 
to review OCO data to help assure reliability, such as (1) performing 
monthly data variance analysis activities--a DOD FMR requirement to 
review OCO obligation amounts that fluctuate beyond established 
limits; (2) establishing criteria for "additional validation analysis" 
and performing this analysis monthly--a DOD FMR requirement--other 
than variance analysis, to verify that reported data are accurate; and 
(3) maintaining documentation of monthly variance and validation 
activities conducted--a key internal control activity. While the Army, 
Marine Corps, and Air Force had written procedures requiring monthly 
data variance analysis, they did not clearly specify the "additional 
validation analysis" steps required for all appropriations. Navy's 
written procedures did not identify required monthly data variance 
analysis or "additional validation analysis" activities. Also, none of 
the services' written procedures required maintaining documentation of 
the internal controls performed. 

Table 1: Comparison of Military Services' Fiscal Year 2009 Written OCO 
Procedures with Key Internal Control Elements: 

Key internal control elements: Perform monthly data variance analysis 
activities; 
Army: Incorporates the key element to a large extent; 
Navy: Incorporates the key element to little or no extent; 
Marine Corps: Incorporates the key element to a large extent; 
Air Force: Incorporates the key element to a large extent. 

Key internal control elements: Define and perform “additional 
validation analysis” monthly, such as reconciliation of CORAS data 
with official OCO accounting data; 
Army: Incorporates the key element to some extent; 
Navy: Incorporates the key element to little or no extent; 
Marine Corps: Incorporates the key element to little or no extent; 
Air Force: Incorporates the key element to some extent. 

Key internal control elements: Maintain documentation of “additional 
validation analysis” performed; 
Army: Incorporates the key element to little or no extent; 
Navy: Incorporates the key element to little or no extent; 
Marine Corps: Incorporates the key element to little or no extent; 
Air Force: Incorporates the key element to little or no extent. 

Source: GAO analysis. 

[End of table] 

For fiscal year 2010, the Army and Marine Corps issued new OCO 
standard operating procedures in February 2010 and November 2009 
respectively. Although the Army procedures contained a high-level 
description of reconciliation activities, neither contained clearly 
detailed steps necessary to perform the reconciliation nor required 
documentation of the results of validation activities. However, in 
April 2010, the Army provided us with informal desk procedures that 
contain detailed reconciliation steps. Navy and Air Force officials 
told us that they plan to issue new OCO standard operating procedures 
during fiscal year 2010. 

We also identified deficiencies in the DOD FMR regarding the internal 
control policy on budgeting and accounting for contingency operations. 
The FMR requires each service, in its standard operating procedures, 
to include steps for validating OCO reported costs as an accurate and 
fair representation of ongoing OCO activities. As part of the 
validation, the FMR requires variance analysis and "additional 
validation analysis." The FMR does not (1) explain the type of tasks 
required for "additional validation analysis"--such as specifically 
requiring reconciliation and (2) require the military services to 
retain documentation of the performance of internal control activities 
such as variance analysis and data validation. In addition, the DOD 
FMR does not require the DOD Comptroller to prepare a standard 
operating procedure covering its OCO monitoring activities. Internal 
control standards provide that internal controls should be documented 
and all documentation should be properly managed, maintained, and 
readily available for examination. Without detailed guidance that 
clearly defines conducting and documenting service-level variance 
analysis and validation activities and DOD-level monitoring, there is 
an increased risk that internal control activities will not be 
performed, will be performed inconsistently across the military 
services, or will not continue to be performed when key employees 
leave, which can lead to unreliable reporting of OCO data. 

While not routinely documented, according to DOD Comptroller staff and 
military services officials "additional validation analysis" was 
performed to help verify the accuracy of reported OCO costs in CORAS. 
For example, DOD Comptroller staff told us they carried out 
reasonableness checks of the OCO data reported by the military 
services but did not retain documentary evidence of their reviews. 
Army officials told us that they carried out reconciliations of 
accounting system data and the CORAS data. For example, Army officials 
informed us that their data reconciliations disclosed a difference of 
about $3 billion in OCO obligations retrieved by CORAS and OCO 
obligations recorded in its accounting systems, as of July 31, 2009, 
which they used to adjust the CORAS data. They also told us that they 
worked with DFAS to improve the CORAS data retrieval process for 
fiscal year 2010. At Navy, officials told us they have an effort 
underway to determine whether Navy accounting data are being properly 
coded for OCO. Air Force and Marine Corps officials told us that they 
reconcile CORAS to accounting data to some extent. 

We also found that the DOD Comptroller's guidance to the services for 
compiling data for the OCO report directs them to include, in the 
current reporting period, adjustments for omitted or incorrect OCO 
transactions in previously issued OCO reports. This guidance, by not 
requiring separate reporting of costs attributable to other periods, 
obscures the current monthly obligation amounts and thus diminishes 
the transparency of the reported data. For example, on the July 2009 
OCO report, the Army reported, but did not explain, monthly 
obligations of a negative $196 million for fiscal year 2009 Army 
National Guard military personnel appropriations. According to Army 
officials, this amount represented $46.7 million of July 2009 
obligations and a negative $242.7 million of corrections for errors or 
omissions related to prior months' reporting. Clearly reporting the 
actual monthly obligations would provide more useful information for 
monitoring month-to-month financial activity related to actual OCO 
operations in a specific month. 

Conclusions: 

While DOD, by implementing CORAS, has taken steps to improve the 
framework for OCO reporting, further actions are needed to improve the 
reliability and transparency of OCO reports. The services and DOD lack 
sufficient internal control requirements in their guidance and 
regulations. Development, documentation, and effective implementation 
of internal controls are key factors in improving accountability and 
financial reporting. Without complete guidance and regulations, that 
require documentation, there is an increased risk that monthly data 
validation and monitoring activities will not be performed, will be 
performed inconsistently, or will not continue to be performed when 
key employees leave, which can lead to unreliable reporting of OCO 
data. In addition, Congress does not have assurance that the monthly 
OCO reports truly represent that month's costs because DOD 
consolidates corrections for prior periods with current month activity. 

Recommendations for Executive Action: 

We recommend the Secretary of Defense direct the Under Secretary of 
Defense (Comptroller), in coordination with the military service 
secretaries (as appropriate), to take the following five actions: 

* revise the Army procedures to include specific steps required to 
retain documentation of the activities performed and related results; 

* revise the Marine Corps and Air Force procedures to include specific 
steps required to validate data in the OCO report including 
reconciliations and retain documentation of the activities performed 
and related results; 

* establish Navy procedures to include specific steps required to 
validate data in the OCO report including variance analysis and 
reconciliations, and retain documentation of the activities performed 
and related results; 

* revise DOD requirements in FMR 7000.14-R, Volume 12, Chapter 23, 
Contingency Operations, to provide clear, detailed guidance on (1) 
conducting reconciliations and other validations and (2) documenting 
military service-level reviews and DOD Comptroller-level reviews; and: 

* revise DOD Comptroller guidance to provide clear, detailed steps for 
identifying and separately disclosing adjustments related to prior- 
period omissions or errors in current month reporting. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report, reprinted in full in 
enclosure I, DOD agreed with four of our five recommendations and 
partially agreed with our fifth recommendation. DOD also stated it has 
taken action to address our recommendations. 

In agreeing with our first four recommendations, DOD stated it is in 
the process of revising the FMR 7000.14-R, Volume 12, Chapter 23, 
Contingency Operations, to include requiring components to document 
reconciliations, reviews, and validations for monthly cost-of-war 
reporting. DOD partially agreed with our fifth recommendation that it 
revise DOD Comptroller guidance to provide clear, detailed steps for 
identifying and separately disclosing adjustments related to prior- 
period omissions or errors in current-month reporting. DOD noted that 
it issued guidance for fiscal year 2010 dated August 19, 2009, that 
requires all components to provide footnote disclosure for any 
adjustment related to prior-period omissions or errors in current-
month reporting processes. In addition, DOD stated that it will 
explore the possibility of separating current-month obligations and 
prior-period omissions or errors in the monthly cost-of-war reports. 
However, as discussed in our draft report, not requiring separate 
reporting of costs attributable to other periods obscures the current 
monthly obligation amounts and thus diminishes the transparency of the 
reported data. Consequently, we continue to believe DOD should require 
separate disclosure of prior-period omissions and errors from current 
period amounts in its monthly cost-of-war reports. Such a separate 
disclosure would assist Congress in more readily identifying DOD's 
monthly OCO costs. 

We are sending copies of this report to interested congressional 
committees; the Secretary of Defense; and the Under Secretary of 
Defense (Comptroller). In addition, the report will also be available 
at no charge on GAO's Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-9095 or khana@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 key contributions to 
this report are listed in enclosure II. 

Signed by: 

Asif A. Khan:
Director:
Financial Management and Assurance: 

Enclosures: 

List of Committees: 

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

The Honorable Daniel K. Inouye:
Chairman:
The Honorable Thad Cochran:
Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
United States Senate: 

The Honorable Ike Skelton:
Chairman:
The Honorable Howard P. McKeon:
Ranking Member:
Committee on Armed Services:
House of Representatives: 

The Honorable Norman D. Dicks:
Chairman:
The Honorable C.W. Bill Young:
Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
House of Representatives: 

[End of section] 

Enclosure I: Comments from the Department of Defense: 

Department of Defense: 
Comptroller: 
Under Secretary Of Defense: 
1100 Defense Pentagon: 
Washington, DC 20301-1100: 

May 10, 2010: 
	
Mr. Asif Khan: 
Director" 
Financial Management and Assurance: 
U.S. Government Accountability Office: 
441 G Street N.W. 	
Washington, DC 20548: 

Dear Mr. Khan: 

Enclosed is the Department of Defense (DoD) response to the Government 
Accountability Office (GAO) Draft Report GAO-10-562R, "Opportunities 
to Improve Controls over Department of Defense's Overseas Contingency 
Operations Cost Reporting" dated April 20. 2010. The Department 
concurs with the first four recommendations for executive action and 
partially concurs with the last recommendation, and has taken action 
to address them. Thank you for the opportunity to provide the 
Department's response to GAO's recommendations. 

Sincerely, 

Signed by: 

Robert F. Hale: 

Enclosure: As stated: 

[End of letter] 

GAO Draft Report Dated April 20, 2010: 
GAO-10-562R (GAO Code 197090): 

"Opportunities To Improve Controls Over Department Of Defense's 
Overseas Contingency Operations Cost Reporting" 

Department Of Defense Comments To The GAO Recommendations: 

Recommendation 1: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense (Comptroller) to revise the Army 
procedures to include specific steps required to retain documentation 
of the activities performed and related results. (p. 10/GAO Draft 
Report) 

DOD Response: Concur. The Department is in the process of revising the 
Financial Management Regulation 7000.14-R Volume 12, Chapter 23, 
Contingency Operations, to require components to document 
reconciliations and reviews for monthly Cost of War reporting. 

Recommendation 2: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense (Comptroller) to revise the 
Marine Corps, and Air Force procedures to include specific steps 
required to validate data in the overseas contingency operations (OCO) 
report including reconciliations and retain documentation of the 
activities performed and related results. (p. 10/GAO Draft Report) 

DOD Response: Concur. The Department is in the process of revising the 
Financial Management Regulation 7000.14-R Volume 12, Chapter 23, 
Contingency Operations, to require components to document 
reconciliations and reviews for monthly Cost of War reporting. 

Recommendation 3: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense (Comptroller) to establish Navy 
procedures to include specific steps required to validate data in the 
OCO report including variance analysis and reconciliations, and retain 
documentation of the activities performed and related results, (p. 
10/GAO Draft Report) 

DOD Response: Concur. The Department is in the process of revising the 
Financial Management Regulation 7000.14-R Volume 12, Chapter 23, 
Contingency Operations, to require components to document 
reconciliations and reviews for monthly Cost of War reporting. 

Recommendation 4: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense (Comptroller) to revise DoD 
requirements in Financial Management Regulation 7000.14-R Volume 12, 
chapter 23, Contingency Operations, to provide clear, detailed 
guidance on (I) conducing reconciliations and other validations and 
(2) documenting military service reviews and DoD Comptroller-level 
reviews. (p. 10/GAO Draft Report) 

DOD Response: Concur. The Department is in the process of revising the 
Financial Management Regulation 7000.14-R Volume 12, Chapter 23, 
Contingency Operations, to require components to document 
reconciliations and provide details on validations for monthly Cost of 
War reporting. 

Recommendation 5: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense (Comptroller) to revise DoD 
comptroller guidance to provide clear, detailed steps for identifying 
and separately disclosing adjustments related to prior-period 
omissions or errors in current month reporting. (p. 10/GAO Draft 
Report) 

DOD RESPONSE: Partially Concur. The Department already has established 
guidance titled "Fiscal Year (FY) 2010 Instructions for Contingency 
Operations Cost Reports" dated August 19, 2009, which requires all 
Components to provide footnotes for any adjustments related to prior-
period omissions or errors in current month reporting. However, the 
Department will explore the possibility of separating current month 
obligations and prior-period omissions or errors in the monthly Cost 
of War reports. 

[End of section] 

Enclosure II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Asif A. Khan (202) 512-9095 or khana@gao.gov: 

Acknowledgments: 

In addition to the contact above, Mary Ellen Chervenic, Assistant 
Director; Maxine Hattery; Sheila D. M. Miller; James Moses; and Laura 
Pacheco made key contributions to this report. 

[End of section] 

Footnotes: 

[1] Starting with the fiscal year 2009 supplemental budget request in 
April 2009, the administration has replaced the term, "Global War on 
Terrorism" with "Overseas Contingency Operations (OCO)." 

[2] Obligations are a definite commitment that creates a legal 
liability of the government for the payment of goods and services 
ordered or received, or a legal duty on the part of the United States 
that could mature into a legal liability by virtue of actions on the 
part of the other party beyond the control of the United States. 

[3] The approximately $198 billion difference between DOD's 
appropriations and reported obligations can generally be attributed to 
the remaining unobligated balances of the following: annual fiscal 
year 2010 appropriations; multiyear procurement appropriations; 
military construction appropriations; and research, development, test, 
and evaluation appropriations; as well as to obligations for 
classified and other items, which DOD considers to be non-OCO related, 
that are not reported in DOD's OCO reports. 

[4] For purposes of this report, cost-related means appropriations, 
obligations, and disbursements that DOD attributes to OCO. 

[5] For more information see GAO, Global War on Terrorism: DOD Needs 
to More Accurately Capture and Report the Costs of Operation Iraqi 
Freedom and Operation Enduring Freedom, [hyperlink, 
http://www.gao.gov/products/GAO-09-302] (Washington, D.C.: Mar. 17, 
2009); Global War on Terrorism: DOD Needs to Take Action to Encourage 
Fiscal Discipline and Optimize the Use of Tools Intended to Improve 
GWOT Cost Reporting, [hyperlink, 
http://www.gao.gov/products/GAO-08-68] (Washington, D.C.: Nov. 6, 
2007); and Global War on Terrorism: DOD Needs to Improve the 
Reliability of Cost Data and Provide Additional Guidance to Control 
Costs, [hyperlink, http://www.gao.gov/products/GAO-05-882] 
(Washington, D.C.: Sept. 21, 2005). 

[6] We and the DOD Office of Inspector General have also reported on 
the unreliability of DOD's underlying transaction data, including 
budgetary accounting, and the lack of reasonable assurance over DOD's 
compliance with legal limitations on the use of appropriated funds. 
See GAO, DOD Financial Management: Improvements Are Needed in 
Antideficiency Act Controls and Investigations, [hyperlink, 
http://www.gao.gov/products/GAO-08-1063] (Washington, D.C.: Sept. 26, 
2008) and Department of Defense Office of Inspector General, 
Independent Auditor's Report on the DOD Agency-wide FY 2009 and FY 
2008 Basic Financial Statements, Report No. D-2010-016 (Arlington, 
Va.: Nov. 12, 2009). 

[7] GAO, Overseas Contingency Operations: Funding and Cost Reporting 
for the Department of Defense, [hyperlink, 
http://www.gao.gov/products/GAO-10-288R] (Washington, D.C.: Dec. 18, 
2009). 

[8] GAO, Internal Control Standards: Internal Control Management and 
Evaluation Tool, [hyperlink, http://www.gao.gov/products/GAO-01-1008G] 
(Washington, D.C.: August 2001) and Internal Control: Standards for 
Internal Control in the Federal Government, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-21.3.1] (Washington, D.C.: 
November 1999). 

[9] The DOD FMR 7000.14-R, Volume 12, Chapter 23, Contingency 
Operations (September 2007), states that each component will develop 
and publish a Standard Operating Procedure (SOP) or other supplemental 
guidance that will cover component-specific items for cost reporting 
and validating monthly reporting. At a minimum, the SOP should cover 
data sources, validation, and variance analysis. 

[End of section] 

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