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GAO-11-310R: 

United States Government Accountability Office: 
Washington, DC 20548: 

February 17, 2011: 

Congressional Committees: 

Subject: Department of State's Report to Congress and U.S. Oversight 
of Civilian Assistance to Pakistan Can Be Further Enhanced: 

Pakistan is a key U.S. ally in the effort to combat terrorism and 
violent extremism. Taliban, al Qaeda, and other terrorists have used 
parts of Pakistan to plan and launch attacks on Afghan, U.S., and NATO 
security forces in Afghanistan, as well as on Pakistani citizens and 
security forces in Pakistan. Enhancing the effectiveness of civilian 
assistance to Pakistan is one of the U.S. government's top foreign 
policy and national security priorities. Foreign assistance is vital 
to help the government of Pakistan overcome the political, economic, 
and security challenges that threaten Pakistan's long-term stability. 
Since 2002, the United States has provided over $18 billion in foreign 
assistance and reimbursements to Pakistan, about two-thirds of which 
has been security-related. 

In October 2009, Congress passed the Enhanced Partnership with 
Pakistan Act of 2009,[Footnote 1] which authorizes up to $1.5 billion 
a year for development, economic, and democratic assistance 
(henceforth referred to as "civilian assistance") to Pakistan for 
fiscal years 2010 through 2014. In the act, Congress declares that the 
United States requires a balanced, integrated, countrywide strategy to 
support Pakistan's efforts that does not disproportionately focus on 
security-related assistance. The act authorizes civilian assistance 
for a wide range of activities, including projects to build the 
capacity of government institutions, promote sustainable economic 
development, and support investment in people through education and 
health programs. The act also encourages, as appropriate, the use of 
Pakistani organizations to provide this assistance. In several reports 
and testimonies since 2008, GAO identified the need to improve 
planning, monitoring, documentation, and oversight of U.S. assistance 
to Pakistan. For example, in previous reports we have noted the need 
to increase oversight and accountability for Pakistan's reimbursement 
claims for Coalition Support Funds[Footnote 2] and to improve 
planning, performance, and monitoring documentation of U.S. 
development assistance to Pakistan's Federally Administered Tribal 
Areas (FATA).[Footnote 3] 

The Enhanced Partnership with Pakistan Act of 2009 requires the 
Department of State (State) to develop several monitoring and strategy 
reports for U.S. assistance to Pakistan, including the Pakistan 
Assistance Strategy Report and the Semi-Annual Monitoring Report. The 
act also directed the Comptroller General to provide: (1) a review of, 
and comments addressing, State's Pakistan Assistance Strategy Report; 
(2) an assessment of the impact of the civilian assistance on the 
security and stability of Pakistan; (3) a detailed description of the 
expenditures made by Pakistan with Foreign Military Financing (FMF) 
grants; and (4) recommendations relating to any additional actions the 
Comptroller General believes could help improve the efficiency and 
effectiveness of U.S. efforts to meet the objectives of the act. This 
report addresses these issues. We provide information on Pakistan's 
use of FMF grants in enclosure I, and our recommendations to improve 
the efficiency and effectiveness of U.S. efforts are included later 
under "Recommendations for Executive Action." 

To conduct this work, we reviewed relevant legislation and agency 
documents, including the Pakistan Assistance Strategy Report issued on 
December 14, 2009, Quarterly Progress and Oversight Reports, spending 
plans, contracts, grants, and bilateral agreements. We interviewed 
officials from State, the U.S. Agency for International Development 
(USAID), and the Department of Defense in Washington, D.C. Further, we 
also interviewed officials in Islamabad, Pakistan, from State, USAID, 
and the Office of the Defense Representative to Pakistan, as well as 
officials from the government of Pakistan. We also analyzed funding 
and expenditure data. We conducted this performance audit from June 
2010 to February 2011, 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. 

The U.S. Pakistan Assistance Strategy Report Included or Partially 
Included All Required Provisions: 

The Pakistan Assistance Strategy Report mandated by the Enhanced 
Partnership with Pakistan Act describes U.S. policy and strategy for 
the civilian assistance to Pakistan. The act mandates that the report, 
submitted by the Secretary of State to Congress in December 2009, 
include seven reporting requirements. We reviewed the report to assess 
whether each of the seven required items was included. We found that 
the report included five and partially included two of the required 
provisions, as shown in figure 1. 

First, while the report describes plans related to program monitoring 
and impact evaluation research, it does not contain plans specifically 
related to operations research as defined in the act as "the 
application of social science research methods, statistical analysis, 
and other appropriate scientific methods to judge, compare, and 
improve policies and program outcomes, from the earliest stages of 
defining and designing programs through their development and 
implementation, with the objective of the rapid dissemination of 
conclusions and concrete impact on programming."[Footnote 4] 
Furthermore, the act requires that the plans on program monitoring, 
impact evaluation research, and operations research in the Pakistan 
Assistance Strategy Report be updated every 180 days in the Semi-
Annual Monitoring Report. To date, updated versions of these 
monitoring reports have not included plans for operations research. 
Agency officials stated that failure to include information on 
operations research does not indicate that it is not being done and 
provided GAO with some examples of USAID's use of operations research. 

Second, the report did not include a projection of levels of 
assistance to be provided to Pakistan under the act for all 17 of the 
Millennium Challenge Account eligibility indicators, as the act 
requires. This section of the report did not contain information on 7 
of the Millennium Challenge indicators, including, for example, 
natural resource management, business start-up, trade policy, and 
inflation control. We make recommendations to enhance the Pakistan 
Assistance Strategy Report under "Recommendations for Executive 
Action." 

Figure 1: GAO Assessment of the Pakistan Assistance Strategy Report: 

[Refer to PDF for image: illustrated table] 

Section 1: Principal Objectives: 
Describes three key objectives for civilian assistance: (1) improve 
Pakistan’s capacity to address critical infrastructure needs, (2) help 
Pakistan address basic needs and provide improved economic 
opportunities in areas most vulnerable to extremism, and (3) 
strengthen Pakistan’s capacity to pursue economic and political 
reforms that reinforce stability. 
GAO Assessment: included. 

Section 2: Programs: 
Describes three broad categories for the assistance and their 
respective funding levels for fiscal year 2010 through fiscal year 
2014: (1) High-Impact, High-Visibility Infrastructure programs–-$3.5 
billion, (2) Focused Humanitarian and Social Services-–$2 billion, and 
(3) Government Capacity Development-–$2 billion. 
GAO Assessment: included. 

Section 3: Plans for Program Monitoring, Operations Research, and 
Impact Evaluation Research: 
Describes activities related to (1) increasing U.S. government 
staffing to manage and monitor programs, and (2) strengthening U.S. 
audit and investigative capabilities. However, this section lacked 
information on plans for operations research. 
GAO Assessment: partially included. 

Section 4: Role of Pakistani Officials and Leaders: 
Describes U.S. efforts to (1) align assistance with Pakistani 
priorities, (2) incorporate Pakistani input into U.S. planning, and 
(3) increasingly implement programs through a broad range of Pakistani 
institutions, both governmental and nongovernmental. 
GAO Assessment: included. 

Section 5: Prohibit Assistance to Individuals or Entities Affiliated 
with Terrorist Organizations: 
Describes some of the guidelines and required procedures, including 
those specifically used by USAID and State, to prevent U.S. assistance 
from being awarded to terrorist organizations or their supporters. 
GAO Assessment: included. 

Section 6: Projection of the Levels of Assistance Organized by the 
Millennium Challenge Account Categories: 
Organizes 10 of the 17 indicators the Millennium Challenge Account 
uses to determine the eligibility of its candidate countries into the 
three broad program categories described in section 2 of the report. 
However, 7 of the indicators were not addressed. 
GAO Assessment: partially included. 

Section 7: An Analysis for the Replacement of Pakistani Helicopters: 
Summarizes the findings and recommendations of a review of the 
Pakistani Army’s aviation needs. 
GAO Assessment: included. 

Source: GAO analysis of State report. 

[End of figure] 

Most of the Fiscal Year 2010 Funding Has Not Been Disbursed; 
Therefore, the Full Impact of the Assistance Could Not Be Determined: 

* As of December 31, 2010, the full impact of the fiscal year 2010 
civilian assistance could not be determined because most of the 
funding had not yet been disbursed (see figure 2). According to a 
State document, it will take some time before significant outcomes of 
the civilian assistance can be measured. Furthermore, performance 
indicators, targets, and baselines had not yet been established for 
all of the civilian assistance. USAID, for example, is in the process 
of establishing new indicators across all sectors. 

Figure 2: Fiscal Year 2010 Civilian Assistance to Pakistan (as of 
December 31, 2010): 

[Refer to PDF for image: photograph and vertical bar graph] 

Appropriated funds: $1.512 billion; 
Unobligated balance: $171.2 million; 
Obligated balance: $1.163 billion; 
Disbursement: $179.5 million. 

Source: GAO analysis of USAID and State data (chart). USAID (photo). 

[End of figure] 

For fiscal year 2010, just over $1.5 billion in appropriated funds was 
allocated to carry out civilian assistance activities authorized by 
the act.[Footnote 5] According to U.S. officials, civilian assistance 
to Pakistan includes programs funded through the following 
appropriation accounts: (1) Economic Support Funds--$1.3 billion; (2) 
Global Health and Child Survival--$30 million; (3) International 
Narcotics Control and Law Enforcement--$170 million; and (4) 
Nonproliferation, Antiterrorism, De-mining, and Related Programs--$22 
million.[Footnote 6] According to USAID, there are two common ways in 
which it obligates these appropriated funds: bilateral obligation and 
direct obligation. For bilateral obligations, USAID first develops a 
bilateral assistance agreement with the government of Pakistan, in 
which the detailed projects and activities are typically not yet fully 
developed. USAID considers these funds obligated once the assistance 
agreement is signed. If USAID directly implements activities under 
this assistance agreement, USAID then further "sub-obligates" the 
funds by signing grants, contracts, agreements, or other instruments. 
For direct obligations, funds are obligated directly through 
contracts, grants, or agreements on a case-by-case basis for specific 
implementers' activities. 

Of the approximately $1.5 billion allocated for civilian assistance in 
fiscal year 2010, State and USAID information indicates that there was 
$1.2 billion in an obligated balance as of December 31, 2010. Most of 
the civilian assistance to Pakistan was not obligated until late 
September 2010, when USAID signed a bilateral assistance agreement 
with the government of Pakistan for up to $831 million to support 
programs in the following general areas: democracy and governance, 
health, education, economic opportunity, agriculture, and energy--as 
well as targeted programs implemented in FATA and the Khyber 
Pakhtunkhwa province.[Footnote 7] USAID is currently in the process of 
fully developing projects and activities for this assistance and has 
already "sub-obligated" some of these funds through contracts, grants, 
and agreements. Additional plans for fiscal year 2010 civilian 
assistance from State's Bureau of International Narcotics and Law 
Enforcement Affairs include rule of law programs, aviation support, 
counternarcotics programs, as well as police training, infrastructure, 
and equipment. Recently, State has indicated that up to $500 million 
of this assistance will be used to provide flood relief and fund 
recovery efforts.[Footnote 8] 

According to State and USAID, as of December 31, 2010, $179.5 million 
has been disbursed for the following programs and projects: 

* Benazir Income Support Program ($75 million): U.S. funds will be 
used to provide cash income supplements to approximately 600,000 
beneficiaries through a cash transfer to Pakistan's flagship social 
support program. 

* Higher Education Commission ($45 million): U.S. funds transferred 
directly to the commission will be used for various initiatives, for 
example, to support centers of excellence at Pakistani universities. 

* Flood Assistance ($23.3 million): U.S funds were used to support a 
broad range of flood relief and recovery activities, including 
agriculture recovery, emergency relief supplies, reproductive health 
kits, immunizations for children, water and sanitation activities, and 
support for Pakistan's National Disaster Management Authority. 

* Fulbright Program ($19.5 million): U.S. funds will provide 
scholarships to Pakistani students to obtain postgraduate degrees from 
American universities. 

* International Narcotics Control and Law Enforcement programs ($8.4 
million): U.S. funds were used for an aviation support contract and 
program development. 

* Sindh Agricultural Recovery Program ($6.3 million): U.S. funds will 
be used to help flood-affected farmers in the Sindh province cultivate 
sunflowers by providing seed, fertilizer, and technical assistance. 

* Antiterrorism Training and Program Management ($2.0 million): U.S. 
funds will be used to provide training to Pakistani law enforcement 
officials on a wide range of issues, including tactical operations, 
investigations, support infrastructure, and institution security. 

USAID's Efforts to Oversee Civilian Assistance Awarded to Pakistani 
Organizations Can Be Further Enhanced: 

USAID is planning to shift its program implementers from U.S.-based 
partners to Pakistani organizations, including local, provincial, and 
federal government and nongovernmental organizations. According to 
agency officials, approximately half of all fiscal year 2010 civilian 
assistance will be implemented through these Pakistani organizations, 
some of which may initially lack the capacity to efficiently and 
effectively implement and monitor U.S.-funded projects. State and 
USAID have noted that the limited institutional capacity of new 
implementing partners is a potential challenge and that USAID intends 
to take steps to identify and address weaknesses in these 
organizations. USAID described a number of risk mitigation strategies 
and steps it has already undertaken or intends to take to improve the 
capacity of Pakistani organizations that do not meet minimum standards 
for managing U.S. funds. Figure 3 provides an illustration of these 
steps. 

Figure 3: Assessment and Capacity Building of Pakistani Organizations 
Implementing U.S. Assistance: 

[Refer to PDF for image: illustration] 

Pakistani organization identified by USAID to implement program; 

Pakistani CPA firm conducts preaward assessment: 
* High or medium-risk: 
Capacity-building program; 
Embed CPA staff; 
Annual Assessment; 
* Low-risk: 
Annual Assessment. 

Source: GAO analysis of USAID information. 

[End of figure] 

Risk mitigation and strategies by USAID include the following: 

* Pakistani organizations receiving U.S. funding for the first time 
would undergo a preaward assessment of their internal controls and 
financial management systems conducted by Pakistani Certified Public 
Accounting (CPA) firms that have been approved by USAID's Office of 
the Inspector General to conduct financial audits.[Footnote 9] The CPA 
firms would identify vulnerabilities and make recommendations for 
actions to address these vulnerabilities before USAID provides funding. 

* Organizations identified as high-risk or medium-risk by the 
Pakistani CPA firms would still receive U.S. funds but would be 
expected to participate in a capacity-building program intended to 
provide training in key areas, such as financial management, human 
resources, and monitoring and evaluation. Organizations may also be 
required to meet other conditions, such as setting up a separate 
account for U.S. funds. 

* In cases where an organization requires additional support, staff 
from a Pakistani CPA firm would be embedded within the organization to 
provide accelerated capacity-building by developing policies and 
procedures, training staff, and providing management support. 

* In addition to the initial preaward assessments for first-time 
funding recipients, all Pakistani organizations would undergo an 
annual assessment to determine their current risk level. Organizations 
identified as high-risk or medium-risk would participate in a capacity-
building program and/or have staff from an approved CPA firm embedded 
within their organization. 

* USAID would require CPA firms to validate all payment requests from 
Pakistani organizations implementing U.S.-funded programs before 
providing funds. 

As per USAID's guidance, the preaward assessments must be used when 
making the determination to award funds to an organization new to 
USAID. However, USAID guidance on preaward assessments does not 
contain information on whether weaknesses identified in the preaward 
assessment must be addressed or whether the assessment's 
recommendations to enhance the accountability of U.S. funds must be 
implemented. For Pakistani organizations that were required to undergo 
a preaward assessment, GAO reviewed their respective contracts, 
grants, or agreements for fiscal year 2010 assistance as well as the 
assessment's results. Our analysis indicated that not all of these 
contracts, grants, and agreements required these organizations to 
address the weaknesses identified in their preaward assessment. For 
example, a grant with a Pakistani organization that had been 
identified as medium-risk did not include any specific provisions to 
address any of the recommendations made in the preaward assessment for 
mitigating identified risks, which, among others, included the need to 
implement a conflict of interest policy and recruit more qualified 
internal audit and procurement staff. 

Conclusions: 

Proper congressional oversight of assistance programs requires 
complete and accurate information. While the Pakistan Assistance 
Strategy Report included most of the required information, it did not 
include (1) plans for operation research and (2) a projection of the 
levels of assistance to be provided to Pakistan for 7 of the 17 
Millennium Challenge Account categories. This information should be 
made available to Congress in a timely manner. Furthermore, given 
prior deficiencies identified in the monitoring and evaluation of U.S. 
assistance to Pakistan, it is important that future implementation of 
U.S. assistance have proper oversight and meet U.S. standards for 
internal controls. Additional risk may be incurred by increasingly 
providing U.S. assistance through Pakistani organizations, some of 
which may initially lack the capacity to efficiently and effectively 
implement and monitor U.S.-funded projects. To help prevent waste, 
fraud, and abuse of U.S. funds, it is important that USAID effectively 
implement and monitor efforts to address the weaknesses and enhance 
the capacity of these organizations, particularly those that are 
identified as having a high-risk or medium-risk of not meeting 
standards for managing U.S. funds. 

Recommendations for Executive Action: 

To supplement the Pakistan Assistance Strategy Report so that 
information reported to Congress complies with all requirements of the 
Enhanced Partnership with Pakistan Act of 2009, we recommend that the 
Secretary of State take the following two actions: 

* include information on plans for operations research, as defined in 
the act, in its forthcoming Semi-Annual Monitoring Report; and: 

* deliver to Congress a projection of the levels of assistance to be 
provided to Pakistan under the act, broken down into the 17 Millennium 
Challenge categories listed in the act. 

To enhance the accountability of U.S. civilian assistance to Pakistan, 
we recommend that the USAID Administrator should ensure that U.S. 
assistance to Pakistani organizations identified as high-or medium-
risk be provided through contracts, grants, or agreements that require 
these organizations to address weaknesses identified in their preaward 
assessment that would improve the accountability of U.S. funds. These 
measures can include such steps as implementing a conflict of interest 
policy, recruiting more qualified internal audit and procurement 
staff, embedding approved CPA staff, and participating in a capacity-
building program. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Departments of Defense and 
State and USAID. State and USAID provided written comments, which are 
reprinted in enclosures II and III. All three agencies provided 
technical comments, which we incorporated throughout the draft as 
appropriate. 

In commenting on a draft of this report, State agreed with our 
recommendations to include information on plans for operations 
research in a future Semi-Annual Monitoring Report and noted that 
operations research to track performance and impact program design and 
implementation for civilian assistance is already ongoing. State also 
agreed with our recommendation to provide Congress with a projection 
of the levels of assistance to be provided to Pakistan under the 
Enhanced Partnership with Pakistan Act, broken down into the 17 
Millennium Challenge categories listed in the act. 

Further, both State and USAID agreed with our recommendation made to 
USAID to ensure that U.S. assistance being implemented by Pakistani 
organizations identified as high-risk or medium-risk be provided 
through contracts, grants, or agreements that require these 
organizations to address weaknesses identified in their preaward 
assessment. State noted that there are USAID mechanisms in place to 
address weaknesses identified in preaward assessments, and USAID 
provided examples of steps taken to address the weaknesses identified. 
USAID also stated that all contracts, grants, and agreements awarded 
to high-risk or medium-risk recipients take into consideration 
weaknesses identified in the preaward assessments and requested 
closure of this recommendation. However, as previously noted, our 
analysis indicated that not all contracts, grants, and agreements 
required high-and medium-risk Pakistani organizations to address the 
weaknesses identified in their preaward assessment. We reiterate our 
recommendation that USAID take steps to ensure that all future 
contracts, grants, and agreements with high-and medium-risk Pakistani 
organizations include provisions that address the weaknesses 
identified in their preaward assessment that would improve the 
accountability of U.S. funds. 

We are sending copies of this report to the appropriate congressional 
committees, the Secretaries of Defense and State, the Administrator of 
USAID, and other interested parties. The report also is available at 
no charge on the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact me at (202) 512-7331 or johnsoncm@gao.gov. Contact 
points for our Offices of Public Affairs and Congressional Relations 
may be found on the last page of this report. GAO staff who made key 
contributions to this report are listed in enclosure IV. 

Signed by: 

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

Enclosures (4): 

List of Congressional Committees: 

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

The Honorable John Kerry:
Chairman:
The Honorable Richard Lugar:
Ranking Member:
Committee on Foreign Relations:
United States Senate: 

The Honorable Howard McKeon:
Chairman:
The Honorable Adam Smith:
Ranking Member:
Committee on Armed Services:
House of Representatives: 

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

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

The Honorable Patrick Leahy:
Chairman:
The Honorable Lindsey Graham:
Ranking Member:
Subcommittee on State, Foreign Operations, and Related Programs:
Committee on Appropriations:
United States Senate: 

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

The Honorable Kay Granger:
Chairwoman:
The Honorable Nita Lowey:
Ranking Member:
Subcommittee on State, Foreign Operations, and Related Programs:
Committee on Appropriations:
House of Representatives: 

[End of section] 

Enclosure I: Foreign Military Financing Grants to Pakistan: 

GAO Objective: 

To provide a detailed description of the expenditures made by Pakistan 
with FMF grants. 

FMF Background: 

The Foreign Military Financing (FMF) program, pursuant to Sec. 23 of 
the Arms Export Control Act (22 U.S.C. § 2763), provides grants to 
eligible countries for the acquisition of U.S. defense articles, 
services, or training. 

According to the Department of State (State), the goals of FMF grants 
to Pakistan are to promote closer security ties between the United 
States and Pakistan, enhance the institutional capacity of Pakistan's 
military, and support force modernization. FMF supports broader U.S. 
strategy designed to enhance regional stability, combat terrorist 
groups that threaten the stability of Pakistan and the region, and 
promote Pakistani participation in stability operations. 

According to agency officials, the Defense Security Cooperation Agency 
is responsible for formulating and administering security cooperation 
programs. It acts as the executive agent for administering the FMF 
program on behalf of State. 

Pakistan Has Used $1.86 Billion in FMF Grants to Acquire Various 
Items, Including Aircraft Modernization, Radios, Ammunition, and 
Training: 

Since fiscal year 2002, a total of $2.11 billion has been appropriated 
for FMF grants to Pakistan. Of that amount, Pakistan has used about 
$1.86 billion to acquire various defense articles, services, or 
training (see figure 4). Some of these funds have been used to 
refurbish or upgrade defense articles that were given to Pakistan 
under the Excess Defense Articles program, including Cobra 
helicopters, armored personnel carriers, and the frigate U.S.S. 
McInerney. As of the end of calendar year 2010, Pakistan still had 
approximately $250 million available to purchase U.S defense articles, 
services, or training. According to agency documents, some of these 
funds will be used to acquire naval surveillance aircraft, 
communications equipment, upgrades to TOW missile launchers, and 
additional helicopters. 

Figure 4: Items Purchased by Pakistan with FMF Grants as of 12/31/10: 

[Refer to PDF for image: illustrated table] 

Description and (quantity): P-3C Avionics Maritime Patrol Aircraft 
Upgrades and Related Support (7 aircraft); 
Year(s)[A]: 2003, 2005, 2006, 2008; 
Value: $507.6 million. 

Description and (quantity): F-16 Mid-Life Updates (35 jets); 
Year(s)[A]: 2006; 
Value: $476.4 million. 

Description and (quantity): TOW IIA Anti-Tank Missile Launchers and 
Missiles (121 launchers, 6,212 missiles); 
Year(s)[A]: 2005, 2007, 2010; 
Value: $215.5 million. 

Description and (quantity): Harris Radios (2,335 radios); 
Year(s)[A]: 2004, 2005, 2007, 2010; 
Value: $213.1 million. 

Description and (quantity): TPS-78 Radar Systems (6 systems); 
Year(s)[A]: 2004; 
Value: $96.9 million. 

Description and (quantity): Technical Support Team at Shahbaz Air 
Force Base; 
Year(s)[A]: 2010; 
Value: $82.1 million. 

Description and (quantity): C-130E Transport Aircraft Refurbishments 
(6 aircraft); 
Year(s)[A]: 2003; 
Value: $75.9 million. 

Description and (quantity): U.S.S. McInerney Frigate Refurbishment; 
Year(s)[A]: 2010; 
Value: $58.8. million. 

Description and (quantity): Cobra Helicopter Refurbishments and 
Support (12 helicopters); 
Year(s)[A]: 2003, 2004; 
Value: $53.5 million. 

Description and (quantity): Self-Propelled M-109A5 Howitzers (115 
howitzers); 
Year(s)[A]: 2006; 
Value: $52.5 million. 

Description and (quantity): Aircraft Training; 
Year(s)[A]: 2002; 
Value: $7.6 million. 

Description and (quantity): Frigate Training; 
Year(s)[A]: 2010; 
Value: $6.0 million. 

Description and (quantity): 20 mm Ammunition (600,000 cartridges); 
Year(s)[A]: 2009, 2010; 
Value: $5.2 million. 

Description and (quantity): Helicopter Spare Parts; 
Year(s)[A]: 2004; 
Value: $2.6 million. 

Description and (quantity): Electronic Warfare Equipment (signal 
jammers, expendable chaff, flares, etc.); 
Year(s)[A]: 2002; 
Value: $1.9 million. 

Description and (quantity): PVS-7 Night Vision Devices (300 devices); 
Year(s)[A]: 2004; 
Value: $1.5 million. 

Description and (quantity): Aircraft Spare Parts; 
Year(s)[A]: 2003[B]; 
Value: $1.3 million. 

Total committed: $1.858 billion. 

Source: Department of Defense. 

[A] This represents the year(s) officials from both the U.S. and 
Pakistani governments signed the agreement and the initial payment was 
deposited for the defense articles, services, and training. 

[B] This case was initially implemented in 1984 and was amended in 
2003. 

Source: Department of Defense. 

[End of figure] 

[End of section] 

Enclosure II: Comments from the Department of State: 

United States Department of State: 
Chief Financial Officer: 
Washington, D.C. 20520: 

February 9, 2011: 

Ms. Jacquelyn Williams-Bridgers: 
Managing Director: 
International Affairs and Trade: 
Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548-0001: 

Dear Ms. Williams-Bridgers: 

We appreciate the opportunity to review your draft report,
"State Department's Report to Congress and U.S. Oversight of Civilian 
Assistance to Pakistan Can Be Further Enhanced," GAO Job Code 320829.
The enclosed Department of State comments are provided for 
incorporation with this letter as an appendix to the final report.
If you have any questions concerning this response, please contact 
James Thrower, Foreign Affairs Officer, Bureau of South and Central 
Asian Affairs at (202) 736-7906. 

Sincerely, 

Signed by: 

James L. Millette: 

cc: GAO — Charles Johnson: 
SCA — Robert Blake: 
State/OIG — Evelyn Klemstine: 

[End of letter] 

Department of State Comments on GAO Draft Report: 

Pakistan Assistance Strategy: State Department's Report to Congress 
and U.S. Oversight of Civilian Assistance to Pakistan Can Be 
Further Enhanced (GAO-11-310R, GAO Code 320829): 

The Department of State appreciates the opportunity to comment on 
GAO's draft report entitled "Pakistan Assistance Strategy: State 
Department's Report to Congress and U.S. Oversight of Civilian 
Assistance to Pakistan Can Be Further Enhanced." 

Recommendation: To supplement the Pakistan Assistance Strategy Report 
so information reported to Congress complies with all requirements of 
the Enhanced Partnership with Pakistan Act of 2009, the Secretary of 
State should: include information on plans for operations research, as 
defined in the act, in its forthcoming Semi-Annual Monitoring Report; 
and deliver to Congress a projection of the levels of assistance to be 
provided to Pakistan under the act, broken down into the 17 Millennium 
Challenge categories listed in the act. 

Response: The Department concurs with the GAO's recommendation to 
include information on plans for operations research (described as 
"the application of social science research methods, statistical 
analysis, and other appropriate scientific methods to judge, compare, 
and improve policies and program outcomes, from the earliest stages of 
defining and designing programs through their development and 
implementation, with the objective of the rapid dissemination of 
conclusions and concrete impact on programming") in future Semi-Annual 
Monitoring Reports. The Department notes that, as described in the GAO 
draft report itself, operations research to track performance and 
impact program design and implementation for civilian assistance is 
already ongoing and information on such plans can be included in 
monitoring reports beginning in 2011. The Department will also 
separately provide a one-time projection of the levels of assistance 
to be provided to Pakistan under the act, broken down into the 17 
Millennium Challenge categories listed in the act. 

Recommendation: To enhance the accountability of U.S. civilian 
assistance to Pakistan, the USAID Administrator should ensure that 
U.S. assistance to Pakistani organizations identified as medium or 
high risk be provided through contracts, grants, or agreements that 
require these organizations to address weaknesses identified in their 
pre-award assessment that would improve accountability of U.S.
funds. These measures can include such steps as implementing a 
conflict of interest policy, recruiting more qualified internal audit 
and procurement staff, and embedding approved Certified Public 
Accounting staff and/or participation in a capacity-building program. 

Response: The Department concurs with the recommendation in principle, 
as ensuring accountability of civilian assistance to Pakistan is a 
high priority, but notes that USAID mechanisms are already in place to 
address weaknesses identified in pre-award assessments in award 
agreements. In particular, pre-award assessment recommendations are 
incorporated into activity agreements by the USAID Mission, based on 
judgments about how best to strengthen accountability and control and 
facilitate the smooth execution of the program. 

[End of section] 

Enclosure III: Comments from the U.S. Agency for International 
Development: 

USAID: 
From The American People: 

Charles Michael Johnson Jr. 
Director, International Affairs and Trade: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Johnson: 

I am pleased to provide the U.S. Agency for International 
Development's (USAID) formal response to the GAO draft report entitled 
U.S. Pakistan Assistance Strategy Report (GAO-11-310R). 

The enclosed USAID comments are provided for incorporation with this 
letter as an appendix to the final report. 

Thank you for the opportunity to respond to the GAO draft report and 
for the courtesies extended by your staff in the conduct of this audit 
review. 

Sincerely, 

Signed by: 

Sean Carroll: 
Chief Operating Officer: 
U.S Agency for International Development: 

Enclosure: a/s: 

[End of letter] 

USAID Comments on GAO Report on "U.S. Pakistan Assistance Strategy 
Report" GAO-11-310R. 

In response to the referenced draft audit report, please find below 
the management response: 

Recommendation I: We recommend that the USAID Administrator ensure 
that U.S. assistance to Pakistani organizations identified as medium 
or high risk be provided through contracts, grants, or agreements that 
require these organizations to address weaknesses identified in their 
pre-award assessment that would improve the accountability of U.S. 
funds. These measures can include such steps as implementing a 
conflict of interest policy, recruiting more qualified internal audit 
and procurement staff, embedding approved Certified Public Accounting 
staff and/or participation in a capacity-building program. 

Response: USAID agrees with this recommendation. All contracts, 
cooperative agreements, and grants awarded to medium to high risk 
recipients take into consideration weaknesses identified in the pre-
award assessments and identify requirements necessary to address them. 
Weaknesses emanate from areas such as: (1) conflict of interest, (2) 
formation of audit committees, (3) compliance capability with 
applicable laws, (4) roadmap for the implementation of policies and 
procedures including capacity building, (5) development of policies 
and (6) embedding approved CPA firm for the capacity building of the 
organization, etc. 

The USAID Mission in Pakistan has already taken the steps to address 
the weaknesses identified. These steps include: issuance of conflict 
of interest policy directive (attached at annex 1); execution of two 
contracts for implanting of CPA firms in two implementing partners 
viz., Federally Administered Tribal Areas (FATA) Secretariat and 
Provincial Reconstruction, Rehabilitation & Settlement Authority 
(PaRRSA) (attached at annex 2); increasing Mission financial 
management and procurement staff from 22 in September 2009 to 51 in 
January 2011; and establishing the Mission's Assessment and 
Strengthening Program (ASP) through three cooperative agreements with 
local implementing partners to (1) conduct pre-award assessments on 
potential recipients' financial, procurement and administrative 
management and internal controls, (2) build institutional capacity of 
local implementing partners, and (3) provide training in financial, 
procurement and management to local implementing partners. ASP will 
provide required institutional support for enhancing accountability 
and building partner organization capacity to effectively manage U.S. 
Government resources. The Mission has a comprehensive financial 
management strategy in place which establishes a risk mitigation 
approach and provides a framework for all the efforts that the Mission 
is undertaking to address accountability and reduce vulnerabilities. 

Accordingly, USAID requests closure of this recommendation. 

[End of section] 

Enclosure IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

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

Staff Acknowledgments: 

Major contributors to this report were Hynek Kalkus, Assistant 
Director; Claude Adrien; Erin O'Brien; David Dayton; Virginia Chanley; 
and Mary Moutsos. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 111-73, 123 Stat. 2060 (Oct. 15, 2009). 

[2] GAO, Combating Terrorism: Increased Oversight and Accountability 
Needed Over Pakistan Reimbursement Claims for Coalition Support Funds, 
[hyperlink, http://www.gao.gov/products/GAO-08-806] (Washington, D.C.: 
June 24, 2008). 

[3] GAO, Combating Terrorism: Planning and Documentation of U.S. 
Development Assistance in Pakistan's Federally Administered Tribal 
Areas Need to Be Improved, [hyperlink, 
http://www.gao.gov/products/GAO-10-289] (Washington, D.C.: Apr. 15, 
2010). 

[4] Pub. L. No. 111-73, 123 Stat. 2060, 2061 (Oct. 15, 2009), codified 
at 22 U.S.C. § 8401. 

[5] Funds were appropriated through the Consolidated Appropriations 
Act, 2010, Pub. L. No. 111-117, 123 Stat. 3034 (Dec. 16, 2009) and the 
Supplemental Appropriations Act, 2010, Pub. L. No. 111-212, 124 Stat. 
2302 (July 29, 2010). 

[6] The amount of time the funds from these appropriation accounts 
remain available for obligation depends on the appropriation account 
from which they originate. The Economic Support funds; International 
Narcotics Control and Law Enforcement funds; Global Health and Child 
Survival funds; and Nonproliferation, Antiterrorism, De-mining, and 
Related Programs funds appropriated in the 2010 annual appropriations 
act remain available until the end of fiscal year 2011. The Economic 
Support funds and International Narcotics Control and Law Enforcement 
funds appropriated in the 2010 supplemental act remain available until 
the end of fiscal year 2012. 

[7] The Khyber Pakhtunkhwa province was previously known as the 
Northwest Frontier Province. 

[8] In late summer 2010, monsoon rains caused massive flooding 
throughout Pakistan. 

[9] According to USAID's Office of the Inspector General, while the 
CPA firms used to conduct the preaward assessments were approved to 
conduct financial audits, they were not approved for non audit work 
such as consulting or other non audit services. USAID used the list of 
approved audit firms to choose its consultants as a means of ensuring 
a minimum level of quality. 

[End of section] 

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