GAO-20-701 — COVID-19: Federal Efforts Could Be Strengthened by Timely and Concerted Actions (September 2020)

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The highlights of GAO-20-701, a report to congressional committees by the U.S. Government Accountability Office titled COVID-19: Federal Efforts Could Be Strengthened by Timely and Concerted Actions, dated September 2020. It is the third of the bimonthly reports required by a CARES Act provision and makes 16 new recommendations to agencies. It states that as of September 10, 2020 the country had over 6.3 million cumulative reported cases of COVID-19 and over 177,000 reported deaths, and that as of July 31, 2020 the federal government had obligated $1.6 trillion and expended $1.5 trillion of relief funds. Its sections cover the medical supply chain, vaccines and therapeutics, COVID-19 data, economic impact payments, the Coronavirus Relief Fund, guidance for K-12 schools, contract obligation tracking and cybersecurity, each with the agencies' responses.

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United States Government Accountability Office 
 
  
Highlights of GAO-20-701, a report to 
congressional committees 
 
 
COVID-19 
Federal Efforts Could Be Strengthened by Timely and 
Concerted Actions 
What GAO Found 
In the government’s ongoing response to the COVID-19 pandemic, the Congress 
and the administration have taken action on multiple fronts to address challenges 
that have contributed to catastrophic loss of life and profound economic 
disruption. These actions have helped direct much-needed federal assistance to 
support many aspects of public life, including local public health systems and 
private-sector businesses.  
However, the nation faces continued public health risks and economic difficulties 
for the foreseeable future. Among other challenges, the public health system, 
already strained from months of responding to COVID-19 cases, will face the 
additional task of managing the upcoming flu season. At the same time, many of 
the federal, state, and local agencies responsible for responding to the ongoing 
public health emergency are called on to prepare for and respond to the current 
hurricane season. Timely and concerted federal leadership will be required in 
responding to these and other challenges. 
GAO has identified lessons learned and issues in need of continued attention by 
the Congress and the administration, including the need to collect reliable data 
that can drive decision-making; to establish mechanisms for accountability and 
transparency; and to protect against ongoing cyber threats to patient information, 
intellectual property, public health data, and intelligence. Attention to these 
issues can help to make federal efforts as effective as possible. 
GAO has also identified a number of opportunities to help the federal government 
prepare for the months ahead while improving the ongoing federal response: 
Medical Supply Chain 
The Department of Health and Human Services (HHS) and the Federal 
Emergency Management Agency (FEMA), with support from the Department of 
Defense (DOD), have taken numerous, significant efforts to mitigate supply 
shortages and expand the medical supply chain. For example, the agencies have 
coordinated to deliver supplies directly to nursing homes and used Defense 
Production Act authorities to increase the domestic production of supplies.  
However, shortages of certain types of personal protective equipment and testing 
supplies remain due to a supply chain with limited domestic production and high 
global demand. The Food and Drug Administration (FDA) and FEMA have both 
identified shortages, and officials from seven of the eight states GAO interviewed 
in July and August 2020 identified previous or ongoing shortages of testing 
supplies, including swabs, reagents, tubes, pipettes, and transport media. 
Testing supply shortages have contributed to delays in turnaround times for 
testing results. Delays in processing test results have multiple serious 
consequences, including delays in isolating those who test positive and tracing 
their contacts in a timely manner, which can in turn exacerbate outbreaks by 
allowing the virus to spread undetected. In addition, states and other nonfederal 
entities have experienced challenges tracking supply requests made through the 
federal government and planning for future needs. GAO is making the 
following recommendations: 
• 
HHS, in coordination with FEMA, should immediately document roles
View GAO-20-701. For more information, 
contact A. Nicole Clowers (202) 512-7114 or 
clowersa@gao.gov. 
Why GAO Did This Study 
As of September 10, 2020, the U.S. 
had over 6.3 million cumulative 
reported cases of COVID-19 and over 
177,000 reported deaths, according to 
federal agencies. The country also 
continues to experience serious 
economic repercussions and turmoil.  
Four relief laws, including the CARES 
Act, were enacted as of September 
2020 to provide appropriations to 
address the public health and 
economic threats posed by COVID-19. 
As of July 31, 2020, the federal 
government had obligated a total of 
$1.6 trillion and expended $1.5 trillion 
of the COVID-19 relief funds as 
reported by federal agencies on 
USAspending.gov. 
The CARES Act includes a provision 
for GAO to report bimonthly on its 
ongoing monitoring and oversight 
efforts related to the COVID-19 
pandemic. This third report examines 
key actions the federal government 
has taken to address the COVID-19 
pandemic and evolving lessons 
learned relevant to the nation’s 
response to pandemics. 
GAO reviewed data, documents, and 
guidance from federal agencies about 
their activities and interviewed federal 
and state officials, as well as industry 
representatives. 
What GAO Recommends 
GAO is making 16 new 
recommendations for agencies that are 
detailed in this Highlights and in the 
report. 

Highlights of GAO-20-701 (Continued) 
 
and responsibilities for supply chain management functions transitioning to HHS, including continued support from 
other federal partners, to ensure sufficient resources exist to sustain and make the necessary progress in 
stabilizing the supply chain. 
• 
HHS, in coordination with FEMA, should further develop and communicate to stakeholders plans outlining specific 
actions the federal government will take to help mitigate supply chain shortages for the remainder of the 
pandemic. 
• 
HHS and FEMA—working with relevant stakeholders—should devise interim solutions, such as systems and 
guidance and dissemination of best practices, to help states enhance their ability to track the status of supply 
requests and plan for supply needs for the remainder of the COVID-19 pandemic response.  
HHS and the Department of Homeland Security (DHS) objected to GAO’s initial draft recommendations. GAO 
made revisions based on their comments. GAO maintains that implementation of its modified recommendations  
is both warranted and prudent. These actions could contribute to ensuring a more effective response by helping 
to mitigate challenges with the stability of the medical supply chain and the ability of nonfederal partners to 
track, plan, and budget for ongoing medical supply needs.  
Vaccines and Therapeutics 
Multiple federal agencies continue to support the development and manufacturing of vaccines and therapeutics to prevent 
and treat COVID-19. These efforts are aimed at accelerating the traditional timeline to create a vaccine (see figure). 
Traditional Timeline for Development and Creation of a Vaccine 
 
 
Note: See figure 5 in the report.  
As these efforts proceed, clarity on the federal government’s plans for distributing and administering vaccine, as well as 
timely, clear, and consistent communication to stakeholders and the public about those plans, is essential. DOD is 
supporting HHS in developing plans for nationwide distribution and administration of a vaccine. In September 2020, HHS 
indicated that it will soon send a report to Congress outlining a distribution plan, but did not provide a specific date for 
doing so. GAO recommends that HHS, with support from DOD, establish a time frame for documenting and 
sharing a national plan for distributing and administering COVID-19 vaccine, and in developing such a plan 
ensure that it is consistent with best practices for project planning and scheduling and outlines an approach for 
how efforts will be coordinated across federal agencies and nonfederal entities. DOD partially concurred with the 
recommendation, clarifying that it is supporting HHS in developing plans for nationwide distribution and 
administration of vaccine. HHS neither agreed nor disagreed with the recommendation, but noted factors that 
complicate the publication of a plan. GAO maintains that a time frame is necessary so all relevant stakeholders 
will be best positioned to begin their planning. On September 16, 2020, HHS and DOD released two documents 
outlining a strategy for any COVID-19 vaccine. GAO will evaluate these documents and report on them in future 
work. GAO will also continue to conduct related work, including examining federal efforts to accelerate the development 
and manufacturing of COVID-19 vaccines and therapeutics.  
COVID-19 Data 
Data collected by the Centers for Disease Control and Prevention (CDC) suggest a disproportionate burden of COVID-19 
cases, hospitalizations, and deaths exists among racial and ethnic minority groups, but GAO identified gaps in these data. 

Highlights of GAO-20-701 (Continued) 
 
To help address these gaps, on July 22, 2020, CDC released a COVID-19 Response Health Equity Strategy. However, 
the strategy does not assess whether having the authority to require states and jurisdictions to report race and ethnicity 
information is necessary to ensure CDC can collect such data. CDC’s strategy also does not specify how it will involve key 
stakeholders, such as health care providers, laboratories, and state and jurisdictional health departments. GAO 
recommends that CDC (1) determine whether having the authority to require the reporting of race and ethnicity 
information for cases, hospitalizations, and deaths is necessary for ensuring more complete data, and if so, seek 
such authority from Congress; (2) involve key stakeholders to help ensure the complete and consistent 
collection of demographic data; and (3) take steps to help ensure its ability to comprehensively assess the long-
term health outcomes of persons with COVID-19, including by race and ethnicity. HHS agreed with the 
recommendations. 
In addition, HHS’s data on COVID-19 in nursing homes do not capture the early months of the pandemic. HHS’s Centers 
for Medicare & Medicaid Services (CMS) began requiring nursing homes to report COVID-19 data to CDC by May 17, 
2020, starting with information as of May 8, 2020, but made reporting prior to May 8, 2020 optional. By not requiring 
nursing homes to submit data from the first 4 months of 2020, HHS is limiting the usefulness of the data in helping to 
understand the effects of COVID-19 in nursing homes. GAO recommends that HHS, in consultation with CMS and 
CDC, develop a strategy to capture more complete data on COVID-19 cases and deaths in nursing homes 
retroactively back to January 1, 2020. HHS partially agreed with this recommendation by noting the value of 
having complete data, but expressed concern about the burden of collecting it. GAO maintains the importance of 
collecting these data to inform the government’s continued response and recovery, and HHS could ease the 
burden by incorporating data previously reported to CDC or to state or local public health offices.  
Economic Impact Payments 
The Department of the Treasury’s (Treasury) Internal Revenue Service (IRS) has issued economic impact payments (EIP) 
to all eligible individuals for whom IRS has the necessary information to do so; however, not everyone eligible was able to 
be initially identified. To help ensure all eligible recipients received their payments in a more timely manner, IRS took 
several actions to address challenges GAO reported on in June, including a policy change—reopening the Non-Filers tool 
registration period for federal benefit recipients and extending it through September 30—that should allow some eligible 
recipients to receive supplemental payments for qualifying children sooner than expected. However, Treasury and IRS 
lack updated information on how many eligible recipients have yet to receive these funds. The lack of such information 
could hinder outreach efforts and place potentially millions of individuals at risk of missing their payment. GAO 
recommends that Treasury, in coordination with IRS, (1) update and refine the estimate of eligible recipients who 
have yet to file for an EIP to help target outreach and communications efforts and (2) make estimates of eligible 
recipients who have yet to file for an EIP, and other relevant information, available to outreach partners to raise 
awareness about how and when to file for EIP. Treasury and IRS neither agreed nor disagreed with the 
recommendations and described actions they are taking in concert with the recommendations to notify around 9 
million individuals who may be eligible for an EIP. 
Coronavirus Relief Fund 
The Coronavirus Relief Fund (CRF) is the largest program established in the four COVID-19 relief laws that provides aid 
to states, the District of Columbia, localities, tribal governments, and U.S. territories. Audits of entities that receive federal 
funds, including CRF payments, are critical to the federal government’s ability to help safeguard those funds. Auditors that 
conduct single audits follow guidance in the Single Audit Act’s Compliance Supplement, which the Office of Management 
and Budget (OMB) updates and issues annually in coordination with federal agencies. OMB issued the 2020 Compliance 
Supplement in August 2020, but the Compliance Supplement specified that OMB is still working with federal agencies to 
identify the needs for additional guidance for auditing new COVID-19-related programs, including the CRF payments, as 
well as existing programs with compliance requirement changes. According to OMB, an addendum on COVID-19-related 
programs, including the CRF payments, will be issued in the fall of 2020. Further delays in issuing this guidance could 
adversely affect auditors’ ability to issue consistent and timely reports. GAO recommends that OMB, in consultation 
with Treasury, issue the addendum to the 2020 Compliance Supplement as soon as possible to provide the 
necessary audit guidance, as many single audit efforts are underway. OMB neither agreed nor disagreed with the 
recommendation. 
Guidance for K-12 Schools 
State and local school district officials tasked with reassessing their operating status and ensuring their school buildings 
are safe are generally relying on guidance and recommendations from federal, state, and local public health and 
education officials. However, portions of CDC’s guidance on reopening K-12 schools are inconsistent, and some federal 
guidance appears misaligned with CDC’s risk-based approach on school operating status. Based on GAO’s review, 
Education has updated the information and CDC has begun to do so. GAO recommends that CDC ensure that, as it 
makes updates to its guidance related to schools’ operating status, the guidance is cogent, clear, and internally 
consistent. HHS agreed with the recommendation.  

Highlights of GAO-20-701 (Continued) 
 
Tracking Contract Obligations 
Federal agencies are tracking contract actions and associated obligations in response to COVID-19 using a National 
Interest Action (NIA) code in the Federal Procurement Data System-Next Generation. The COVID-19 NIA code was 
established in March 2020 and was recently extended until March 31, 2021, while a draft of this report recommending that 
DHS and DOD extend the code beyond September 30, 2020, was with the agencies for comment. GAO has identified 
inconsistencies in establishing and closing these codes following previous emergencies, and has continued concerns with 
the criteria that DHS and DOD rely on to determine whether to extend or close a code and whether the code meets long-
term needs. GAO recommends that DHS and DOD make updates to the 2019 NIA Code Memorandum of 
Agreement so as to enhance visibility for federal agencies, the public, and Congress on contract actions and 
associated obligations related to disaster events, and to ensure the criteria for extending or closing the NIA code 
reflect government-wide needs for tracking contract actions in longer-term emergencies, such as a pandemic. 
DHS and DOD did not agree, but GAO maintains implementation of its recommendation is essential. 
Address Cybersecurity Weaknesses  
Since March 2020, malicious cyber actors have exploited COVID-19 to target organizations that make up the health care 
and public health critical infrastructure sector, including government entities, such as HHS. GAO has identified numerous 
cybersecurity weaknesses at multiple HHS component agencies, including CMS, CDC, and FDA, over the last 6 years, 
such as weaknesses in key safeguards to limit, prevent, and detect inappropriate access to computer resources. 
Additionally, GAO’s March 2019 high-risk update identified cybersecurity and safeguarding the systems supporting the 
nation’s critical infrastructure, such as health care, as high-risk areas. As of July 2020, CMS, FDA, and CDC had made 
significant progress by implementing 350 (about 81 percent) of the 434 recommendations GAO issued in previous reports 
to address these weaknesses. Based on the imminent cybersecurity threats, GAO recommends that HHS expedite 
implementation of GAO’s prior recommendations regarding cybersecurity weaknesses at its component 
agencies. HHS agreed with the recommendation.

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