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Audit of Pharmaceutical Purchases Made Outside the Prime Vendor Contract

Report Information

Issue Date
Report Number
25-02487-143
VA Office
Veterans Health Administration (VHA)
Report Author
Office of Audits and Evaluations
Report Type
Audit
Report Topic
Purchase Cards
Supplies and Equipment
Major Management Challenges
Healthcare Services
Stewardship of Taxpayer Dollars
Recommendations
3
Questioned Costs
$0
Better Use of Funds
$0
Congressionally Mandated
No

Summary

Summary

The VA Office of Inspector General (OIG) assessed whether the Veterans Health Administration (VHA) had adequate controls to ensure medical facilities complied with VA policies when making pharmaceutical purchases through the open market. VA spent about $11.7 billion on pharmaceuticals during the audit period, which was from April 1, 2024, through March 31, 2025. Of that amount, about $11.4 billion was purchased through the prime vendor contract and about $322.5 million—roughly 3 percent—was purchased outside that contract. VHA is required to use the prime vendor as the first source for all contract pharmaceutical purchases. The prime vendor is the main commercial distributor of a broad range of drugs and pharmaceuticals to VA and other agencies with a contracted pricing schedule that leverages the government’s buying power.

The team reviewed $276.7 million of the purchases made outside that contract, excluding purchases made through VHA’s Consolidated Mail Outpatient Pharmacies. The team found VHA facilities did not always comply with policy, which requires staff to document attempts to purchase pharmaceuticals through the prime vendor and conduct market research for cost-effectiveness before making open market purchases. Until VHA fully implements recent executive orders to enhance oversight of government purchase cards and ensures compliance with policy requirements, it will remain limited in its ability to ensure cost-effective purchasing, deter fraud, and safeguard taxpayer resources. VHA leaders generally agreed with the team’s findings and the under secretary concurred in principle with all three of the OIG’s recommendations and submitted action plans to address them.

The OIG’s recommendations seek to strengthen controls over open market pharmaceutical purchases and to ensure medical facilities monitor and evaluate these purchases to improve oversight, enforce policy, and reduce risks of waste or fraud. 

Open Recommendation Image, SquareOpenClosed and Implemented Recommendation Image, CheckmarkClosed-ImplementedNot Implemented Recommendation Image, X character'Closed-Not Implemented
No. 1
Open Recommendation Image, Square
to Veterans Health Administration (VHA)

Develop and establish guidance detailing how medical facility staff must document evidence to support their decisions when they make pharmaceutical purchases through the open market.

No. 2
Open Recommendation Image, Square
to Veterans Health Administration (VHA)

Ensure medical facility leaders conduct routine assessments of pharmaceutical purchases made through the open market so purchases are made in accordance with policy.

No. 3
Open Recommendation Image, Square
to Veterans Health Administration (VHA)

Develop a mechanism, in coordination with VHA’s purchase card program office and VA’s Office of General Counsel, that provides visibility into all pharmaceutical purchases, including purchases outside the prime vendor contract.