Loma Linda Healthcare System’s Oversight of Community-Based Outpatient Clinic Contracts Needs Strengthening

Report Information

Issue Date
Report Number
23-00324-170
VISN
22
State
California
District
VA Office
Veterans Health Administration (VHA)
Report Author
Office of Audits and Evaluations
Report Type
Review
Report Topic
Contract Integrity
Major Management Challenges
Healthcare Services
Leadership and Governance
Recommendations
9
Questioned Costs
$0
Better Use of Funds
$0
Congressionally Mandated
No

Summary

Summary

VHA provides outpatient services to veterans at community-based outpatient clinics (CBOCs) nationwide. The VA OIG conducted this review to assess contract oversight of staffing and appointment cancellation performance measures at five Loma Linda Healthcare System CBOCs in California.

The OIG found that VA leaders in the Loma Linda healthcare system did not ensure contractor compliance with performance standards for staffing or for the number of appointments canceled by the clinics during FYs 2022 and 2023. Specifically, Loma Linda officials did not effectively monitor contractor-staffed primary care Patient Aligned Care Teams to ensure contract compliance. The contractor did not meet required staffing levels at any of the five contracted CBOCs for at least 22 of 24 months in FYs 2022 and 2023; two CBOCs were noncompliant 100 percent of the time, and the remaining three were noncompliant more than 90 percent of the time.

The contractor also did not consistently meet the appointment cancellation performance standard regarding appointments canceled by clinics at contracted CBOCs. In FYs 2022 and 2023, all five CBOCs under the contract were noncompliant with appointment cancellation standards at least 79 percent of the time, and two CBOCs were noncompliant 100 percent of the time. Finally, the OIG found that the contracting officer’s attempt to recover government funds associated with using VA personnel to cover shortages at the contracted clinics was insufficient.

Contract noncompliance occurred, in part, because the assistant director did not provide effective oversight of the contracting officer’s representative (COR) or the CBOC nurse coordinator. The OIG also found that the assistant director did not effectively coordinate with the COR and the contracting officer to ensure that the contractor’s contingency plan requirement was sufficiently enforced during staffing shortages. The OIG made nine recommendations for VA to improve oversight of CBOC contracts.

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)

Strengthen controls in the Office of the Assistant Director to ensure inclusion of staffing monitoring contract requirements, in coordination with the contracting officer, to meet gradual staffing level goals during start-up periods in future community‑based outpatient clinic contracts.

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

Strengthen controls to ensure data used for monitoring contract performance standards are accurate and comply with the methodology required in the contract’s Quality Assurance Surveillance Plan.

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

Review the medical staff-driven phase of the credentialing process, to ensure action plans implemented to expedite the credentialing process are effective.

No. 4
Open Recommendation Image, Square
to Veterans Health Administration (VHA)

Strengthen controls to ensure contracted staff complete required scheduling training before granting them access to VA’s scheduling system and authorizing them to make veteran appointments.

No. 5
Open Recommendation Image, Square
to Veterans Health Administration (VHA)

Review the healthcare system’s staffing augmentation plan and coordinate with the contracting officer to ensure the full costs are recovered for all Veterans Health Administration staff who provided services for which the contractor was also compensated.

No. 6
Open Recommendation Image, Square
to Veterans Health Administration (VHA)

Review the unilateral memorandum related to staffing augmentation, establish a contract modification in compliance with the Federal Acquisition Regulation provisions regarding contract changes, and ensure relevant documentation is maintained in the contract file.

No. 7
Open Recommendation Image, Square
to Veterans Health Administration (VHA)

Recover government funds expended for Veterans Health Administration staff augmented at contracted community-based outpatient clinics using full cost amounts.

No. 8
Open Recommendation Image, Square
to Veterans Health Administration (VHA)

Review and enforce staffing contingency plan requirements for the Loma Linda Healthcare System contract, including maximizing the contractor’s use of temporary replacements, or locum tenens, to minimize staffing shortages.

No. 9
Open Recommendation Image, Square
to Veterans Health Administration (VHA)

Strengthen oversight mechanisms to ensure the enforcement of staffing requirements during contract start-up in future community‑based outpatient clinic contracts before the clinics become operational.