World Trade Center Health Program: CDC Should Strengthen Efforts To Monitor and Evaluate Clinic Compliance With Contract Terms

The World Trade Center Health Program (WTCHP) was established in January 2011. Under the WTCHP, CDC's Procurement and Grants Office (PGO) contracted with clinics to provide medical services and pharmacy benefits to eligible responders and survivors with health conditions related to the September 11, 2001, terrorist attacks on the World Trade Center.

We found that the PGO and the National Institute for Occupational Safety and Health (NIOSH) did not monitor and evaluate clinic compliance with contract terms and conditions as required by Federal regulations. Specifically, PGO contracting officers (COs) did not ensure that NIOSH contracting officer representatives (CORs) used the surveillance methodology established in the quality assurance surveillance plans (QASPs) developed to monitor clinic contract performance. In addition, neither the CORs nor the COs took timely or appropriate action when they learned of three instances of clinic contract noncompliance. Furthermore, the CORs' and COs' evaluations of contractor performance were not completed as required and were not always entered into the Contractor Performance Assessment Reporting System and the Past Performance Information Retrieval System.

These inadequacies occurred because the PGO and NIOSH did not (1) consider the QASP surveillance methodology to be mandatory or the QASP performance standards to be realistic or attainable for the clinics and (2) have standard operating procedures to ensure that required performance evaluations were conducted in a timely manner.

We recommended that CDC (1) monitor clinics' performance in accordance with contract terms, (2) address clinics' noncompliance with contract terms as required by Health and Human Services Acquisition Regulation subpart 342.70, and (3) follow Federal Acquisition Regulation section 42.1503 by developing and implementing standard operating procedures for evaluating contract performance. CDC concurred with our recommendations and described the actions that it has taken to address them.