Publicly Released: July 20, 2021
Objective
The objective of this audit was to determine to what extent U.S. Army Corps of Engineers (USACE) officials conducted appropriate quality assurance and contract administration related to alternative care site (ACS) facilities. We determined whether USACE officials appropriately developed quality assurance control plans (or used appropriate waivers), designated properly trained personnel to conduct quality assurance, coordinated the process, completed contractor assessments, and initiated contract closeout procedures in a timely manner.
Background
An ACS is a facility that is temporarily converted for healthcare use during a public health emergency. ACS facilities are intended to reduce the burden on hospitals and other permanent healthcare facilities, help infected patients maintain isolation, and allow low acuity patients to be monitored, minimally treated, and quickly moved to other facilities if their condition worsens.
USACE officials appoint one or more contracting officer’s representatives (COR) to each contract to review work completed, provide updates on the progress and quality assurance of the work, and accept closeout information. The COR must provide quality assurance, preferably daily, in the form of written reports or pictures of progress. CORs are to stay up‑to‑date on training.
A quality assurance surveillance plan (QASP) prescribes policies and procedures to ensure that supplies and services acquired under Government contract conform to the contract’s quality and quantity requirements. If the contracting officer waives the QASP requirement, they must state the reason for the waiver. We considered waivers, because of the urgency of the ACS requirement, a valid justification given the coronavirus disease–2019 (COVID‑19) pandemic conditions officials were operating under.
The Contractor Performance Assessment Reporting System (CPARS) is the official source for past performance information. Contracting officers are required to prepare past performance evaluations at the time the contracted work or order is completed.
Finding
Considering that contracting officials were operating in a pandemic environment, USACE contracting officers conducted the following appropriate quality assurance and contract administration actions for the 35 contracts and contract actions, valued at $686.6 million, used for ACS conversions.
- Developed or appropriately completed a waiver for the QASP for 33 of the 35 contracts. USACE contracting officers issued the remaining two contracts as construction contracts, which are exempt from QASP requirements by the Federal Acquisition Regulation.
- Designated CORs to conduct quality assurance oversight for 34 of the 35 contracts. The contracting officer for the remaining contract elected not to appoint a COR and retained quality assurance responsibilities.
- Completed CPARS reports for 33 of the 35 contracts to evaluate contractor performance. Contracting officers were not required to complete a CPARS report for one of the contracts because the dollar value of the acquisition was below the threshold requiring a CPARS report. A USACE official stated that the CPARS report for the second contract was expected to be completed by the end of June 2021.
- Performed steps to close out contracts by obtaining a final invoice or contractor release of claims for 33 of the 35 contracts. Although USACE contracting officers were unable to fully close out two of the ACS contracts, officials have taken actions to obtain missing contractor documentation. Contractors have been unable to provide final invoices and releases of claims because of labor pricing disputes, pricing change orders during the conversion, and subcontractor billing issues.
As a result, USACE personnel were able to ensure that controls were in place to conduct quality assurance and contract administration because they had personnel available during the conversions to oversee contractors, coordinate changes in site conditions and Government requirements with the contractors, and ensure the contract files contained the necessary documents. Furthermore, USACE personnel were able to complete the ACS conversions and determine through the quality assurance conducted that the Government obtained the services established by the contract terms. USACE personnel completed actions after the conversions to document contractor performance to ensure that contracting personnel can assess past performance during any future potential contracting opportunities.
This report is a result of Project No. D2021-D000AV-0041.000.