Review of Federal Supply Schedule 621 I -- Professional and Allied Healthcare Staffing Services

The Office of Inspector General, Office of Contract Review conducted a series of pre- and post-award reviews of proposals and contracts awarded by VA’s National Acquisition Center (NAC) for Professional and Allied Healthcare Staffing Services, FSS Schedule 621I. These reviews found that the awarded prices at the contract level were not fair and reasonable and the methodologies used by VA contracting officers to determine fair and reasonable pricing were inadequate. We found that it was not a commercial practice for the vendors to enter into national fixed-price contracts for locum tenens services; that commercial prices were task order specific. The reviews also identified that the negotiated contract prices represented the “worst case” prices, and were not fair and reasonable prices as required by Federal regulations and policy and that purchasers were expected to negotiate fair and reasonable prices at the buying level. We recommended that the Deputy Assistant Secretary for Acquisition and Logistics direct the NAC not to award any contracts unless the contracting officer can determine that the prices offered are fair and reasonable; to eliminate National Not to Exceed Pricing; to use price analysis methodologies that rely on the vendor’s Commercial Sales Practices disclosures; and inform all FSS customers that they should not rely on the FSS 621 I prices in making best value determinations until the other recommendations have been implemented. The reviews also identified additional problems at the buying level. These issues were referred to the OIG Office of Audits and Evaluations for a nationwide audit.