Philadelphia Did Not Meet All of the Requirements for the COVID-19 Screening Testing Program at K-12 Schools, A-05-24-00003
- Document type
- Audit
- Date
- 2021-03-11
Summary
An HHS Office of Inspector General audit report, A-05-24-00003, dated February 2026, on the City of Philadelphia Department of Public Health's COVID-19 screening testing program at K-12 schools funded through CDC's ELC Reopening Schools program under the American Rescue Plan. The audit covered approximately $41.4 million in expenditures, including $27.7 million paid to the School District of Philadelphia as subrecipient. OIG reports that the Public Health Department did not monitor the School District's compliance with background check requirements and reimbursed $10,525 in unallowable costs and $247,095 in overpayments. It recommends updated procedures and a refund to CDC of $257,620. The report states that Philadelphia disagreed with the finding tied to the first recommendation and concurred with the second.
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Full text
February 2026 | A-05-24-00003
Philadelphia Did Not Meet All of
the Requirements for the COVID-19
Screening Testing Program at
K-12 Schools
OIG.HHS.GOV
February 2026 | A-05-24-00003
Philadelphia Did Not Meet All of the Requirements for the COVID-19
Screening Testing Program at K-12 Schools
Why OIG Did This Audit
• The Centers for Disease Control and Prevention (CDC) provided $10 billion in American Rescue Plan
(ARP) funding to 64 State and local health departments to support COVID-19 screening testing for
teachers, staff, and students in K-12 school settings. Philadelphia was one of the recipients awarded
ARP funding to implement a COVID-19 screening testing program at K-12 schools within its jurisdiction.
• This audit is part of a series examining the implementation of COVID-19 screening testing programs at
K-12 schools. Specifically, this audit determined whether Philadelphia monitored the testing program
and whether it used funds in accordance with Federal, subrecipient, and contract requirements.
What OIG Found
Philadelphia did not consistently monitor the implementation of the COVID-19 testing program; however, for
the expenditures we reviewed, Philadelphia generally used the funding in accordance with requirements.
Specifically:
We determined that Philadelphia did not monitor the subrecipient’s compliance with background
check requirements.
Philadelphia reimbursed the subrecipient $10,525 in costs that were unallowable and $247,095 in
overpayments.
What OIG Recommends
We made two recommendations to Philadelphia: that it develop or update procedures for compliance with
Federal, subrecipient, and contract requirements, including: (1) oversight of subrecipients to ensure
background check requirements are followed and (2) monitoring of subrecipients’ contract terms and
conditions, and that it refund CDC $257,620 in costs reimbursed to the subrecipient that were unallowable or
were overpayments.
Philadelphia did not indicate concurrence or nonconcurrence with our first recommendation but stated that it
disagreed with the finding related to our first recommendation, concurred with our second recommendation,
and detailed steps it plans to take in response to our recommendations.
OIG.HHS.GOV
TABLE OF CONTENTS
INTRODUCTION ............................................................................................................................... 1
Why We Did This Audit ....................................................................................................... 1
Objectives............................................................................................................................ 1
Background ......................................................................................................................... 1
CDC’s Epidemiology and Laboratory Capacity for Prevention and Control of
Emerging Infectious Diseases Reopening Schools Program ................................ 1
Philadelphia’s ELC Reopening Schools Program ..................................................... 2
School District of Philadelphia Subrecipient Agreement for COVID-19 Testing in
K-12 Schools ......................................................................................................... 3
How We Conducted This Audit ........................................................................................... 3
FINDINGS ......................................................................................................................................... 4
The Public Health Department Did Not Consistently Monitor the Implementation of
the COVID-19 Screening Testing Program ....................................................................... 5
The Public Health Department Provided Guidance and Conducted Some
Monitoring Activities ............................................................................................ 5
The Public Health Department Did Not Monitor the School District’s
Compliance With Background Check Requirements, and the School
District Did Not Adhere to Contract Requirements ............................................. 6
The Public Health Department Generally Used ELC Reopening Schools Funding in
Accordance With Requirements for the Expenditures Reviewed, but Some
Deficiencies Were Identified ............................................................................................ 8
The Public Health Department Improperly Reimbursed the School District for
Certain Costs Using ELC Reopening Schools Funding .......................................... 8
RECOMMENDATIONS ..................................................................................................................... 9
PUBLIC HEALTH DEPARTMENT COMMENTS AND
OFFICE OF INSPECTOR GENERAL RESPONSE............................................................................... 10
Public Health Department Comments .............................................................................. 10
Office of Inspector General Response .............................................................................. 10
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003)
APPENDICES
A: Audit Scope and Methodology ..................................................................................... 12
B: Public Health Department Comments.......................................................................... 14
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003)
INTRODUCTION
WHY WE DID THIS AUDIT
The American Rescue Plan (ARP) Act of 2021 (P.L. No. 117-2) provided relief to address the
continued impact of COVID-19 on the economy, public health, State and local governments,
individuals, and businesses. The Department of Health and Human Services (HHS), Centers for
Disease Control and Prevention (CDC), provided $10 billion in ARP funding for the Epidemiology
and Laboratory Capacity for Prevention and Control of Emerging Infectious Diseases (ELC)
Reopening Schools program. 1 The ELC Reopening Schools program supported COVID-19
screening testing for teachers, staff, and students in K-12 school settings.2
The City of Philadelphia Department of Public Health (Public Health Department) is one of the
ELC program recipients. This audit assessed the Public Health Department’s compliance with
Federal, subrecipient, and contract requirements for the COVID-19 screening testing program in
Philadelphia. It is one of a series of audits examining CDC’s ELC program for COVID-19
screening testing at K-12 schools. 3
OBJECTIVES
Our objectives were to determine whether the Public Health Department: (1) monitored the
implementation of and services provided under the COVID-19 screening testing program and
(2) used ELC Reopening Schools funding in accordance with Federal, subrecipient, and contract
requirements.
BACKGROUND
CDC’s Epidemiology and Laboratory Capacity for Prevention and Control of Emerging
Infectious Diseases Reopening Schools Program
The ARP Act, enacted March 11, 2021, appropriated $47.8 billion to HHS to carry out activities
to detect, diagnose, trace, and monitor COVID-19 infections and related strategies to mitigate
the spread of COVID-19 (§ 2401 of the ARP Act; 42 USC § 247d). CDC utilized the ARP Act
appropriations to provide $10 billion through the ELC program to support COVID-19 screening
1
The ELC program provides strategic investments through its cooperative agreement with health departments
aimed at reducing domestic infectious disease-related illnesses and death. The ELC recipients include all 50 States,
large local governments, and United States territories and affiliate health departments.
2
“Screening testing” was intended to identify people with COVID-19 who were asymptomatic or did not have any
known, suspected, or reported exposure to someone with COVID-19.
3
The first report in the series, CDC Provided Oversight and Assistance; However, ELC Recipients Still Faced
Challenges in Implementing COVID-19 Screening Testing Programs (A-05-22-00010), was issued Sept. 26, 2023.
The second report in the series, Kentucky Did Not Meet All of the Requirements for the COVID-19 Screening Testing
Program at K-12 Schools (A-05-23-00018), was issued July 16, 2025.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 1
testing for teachers, staff, and students with the stated purpose to reopen and keep schools
operating safely. The objectives and goals of the ELC Reopening Schools program were focused
on providing the resources to implement screening testing programs in schools. ELC program
recipients were encouraged to align their approach to testing with CDC recommendations for K-
12 schools whenever possible. 4
According to CDC, screening testing was a tool that schools could utilize to help safely reopen as
part of a comprehensive COVID-19 mitigation approach. CDC awarded the funds to existing ELC
program cooperative agreement recipients to ensure the funding was deployed quickly to help
schools reopen and remain open. In addition to providing diagnostic testing of symptomatic
and exposed individuals, screening testing would help schools identify infected individuals
without symptoms who may be contagious so that prompt action could be taken to prevent
further transmission. With the ELC Reopening Schools funding, ELC program recipients could
support implementing critical screening testing programs that were needed in
schools. Recognizing that establishing a testing program was new for many schools, CDC and
State and local health departments provided support and technical assistance to States and
schools in implementing these programs.
In accordance with the ELC Reopening Schools guidance, most of the funding (at least
85 percent) must directly support prevention efforts in school districts.5 This support could be
provided to schools either directly (e.g., partnering with laboratories) or indirectly (e.g.,
personnel support) to increase screening testing and to support COVID-19 prevention and
mitigation strategies in all K-12 schools within the ELC recipient’s jurisdiction. ELC program
recipients could use a combination of approaches to provide the support and could use up to
15 percent of the funds for coordination, management, technical assistance, monitoring, data
collection, and reporting activities.
Philadelphia’s ELC Reopening Schools Program
The mission of the Public Health Department is to protect and promote the health of all
Philadelphians. The Public Health Department prevents the spread of illness and infectious
disease; encourages healthy behaviors to prevent chronic disease; plans for and responds to
health emergencies; and collects, analyzes, and reports on a variety of public health data.
CDC awarded the Public Health Department approximately $47.7 million on April 8, 2021, to
implement the ELC Reopening Schools program. In response to the award, the Public Health
Department focused on providing resources for K-12 schools to implement COVID-19 screening
4
From April 7−8, 2021, the $10 billion was awarded to the 64 ELC program recipients according to a population-
based formula. The funding was awarded for a 16-month project period ending July 31, 2022. On March 30, 2022,
CDC notified the ELC program recipients that it would be extending the use of the ELC Reopening Schools funding
through July 31, 2023.
5
CDC, “ELC Reopening Schools: Support for Screening Testing to Reopen & Keep Schools Operating Safely.”
Accessed on June 23, 2025.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 2
and diagnostic testing programs, aligning with CDC recommendations. The screening involved
routine testing (e.g., weekly) of all staff, and students involved in sports and performing arts,
regardless of COVID-19 symptoms or known exposures, to help identify cases and contain
outbreaks early. Additionally, COVID-19 testing was conducted on symptomatic staff and
students.
School District of Philadelphia Subrecipient Agreement for COVID-19 Testing in K-12 Schools
The Public Health Department entered into a subrecipient agreement with the School District of
Philadelphia (School District) to provide COVID-19 testing services to students and staff in K-12
schools from July 1, 2021, through June 30, 2023 (subrecipient agreement period). In
accordance with the subrecipient agreement, the School District was required to submit
financial reports and testing data throughout the subrecipient agreement period. Additionally,
the School District was required to submit invoices and other documentation to support the
ELC Reopening Schools award subrecipient expenditures.
During the subrecipient agreement period, the Public Health Department paid the School
District approximately $27.7 million in ELC Reopening Schools funding for subrecipient
expenditures. Most of the School District’s expenditures, $21.5 million, were payments to
contractors that performed COVID-19 testing of students and staff in K-12 schools within the
School District. The School District’s remaining expenditures were for program costs that
included air purifiers, personal protective equipment (PPE), COVID-19 test kits and testing
supplies, and administrative costs.
Prior to commencing any work, the contractors were required to submit background check
documentation for each contracted or subcontracted employee who performed COVID-19
testing of students and staff in K-12 schools within the School District.
HOW WE CONDUCTED THIS AUDIT
Our audit covered approximately $41.4 million in ELC Reopening Schools expenditures the
Public Health Department incurred from April 8, 2021, through July 31, 2023 (audit period).
Of the $41.4 million in expenditures, $27.7 million represented subrecipient expenditures the
School District incurred to provide COVID-19 testing services to students and staff in K-12
schools. The remaining $13.7 million represented non-subrecipient expenditures and other
program costs, such as COVID-19 testing and test kits, PPE, air purifiers and filters, and
transportation costs for private and charter K-12 schools. 6
To address our first objective, we reviewed the Public Health Department’s: (1) implementation
of the testing program, including the terms and conditions of the subrecipient agreement and
contracts; and (2) written procedures, guidance, and documentation regarding technical
6
In this report, “non-subrecipients” refers to contractors and vendors that provided services and supplies to the
Public Health Department.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 3
assistance provided to the School District. We also reviewed the background check
documentation for all 86 contracted and subcontracted employees to determine whether the
employees who conducted testing on School District property or at K-12 schools during the
audit period had background checks completed prior to commencing any work. 7 In addition,
we interviewed Public Health Department officials to obtain an understanding of the Public
Health Department’s oversight activities to administer the COVID-19 screening testing program.
To address our second objective, we reviewed all nine vouchers and related invoices,
supporting documentation, and reconciliations for $27.7 million in subrecipient expenditures to
determine whether the ELC Reopening Schools funding was used in accordance with Federal,
subrecipient, and contract requirements. Of the 104 vouchers for non-subrecipient
expenditures, we reviewed a nonstatistical sample of 28 vouchers and related invoices totaling
approximately $9 million in expenditures to determine whether the ELC Reopening Schools
funding was used in accordance with Federal requirements. Our nonstatistical sample of 28
vouchers included the different types of non-subrecipient expenditures associated with ELC
Reopening Schools funding. The results of our testing of non-subrecipient expenditures
presented in the report cannot be generalized to the population of non-subrecipient
expenditures during our audit period.
We conducted this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.
Appendix A contains the details of our audit scope and methodology.
FINDINGS
The Public Health Department did not consistently monitor the implementation of the COVID-
19 screening testing program. While the Public Health Department provided guidance and
technical assistance to the School District and provided oversight of the subrecipient
agreement, the Public Health Department did not monitor the School District’s compliance with
background check requirements. Specifically, we found that the Public Health Department did
not ensure that the School District maintained background check documentation and that the
contractors complied with background check requirements prior to commencing work for
contracted employees who performed COVID-19 testing of students. We determined that the
School District did not obtain, and the contractors did not maintain, sufficient background
7
Of the 86 contracted employees who performed COVID-19 testing, 49 were contracted to perform COVID-19
testing of students and staff at mobile sites within the School District, 21 were subcontracted to perform COVID-19
testing of students in K-12 schools within the School District, and 16 were contracted to perform COVID-19 testing
of students and staff at private and charter K-12 schools within the Public Health Department’s jurisdiction.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 4
check documentation for 70 contracted and subcontracted employees who performed COVID-
19 testing of K-12 students on School District property. 8
For the expenditures we reviewed, the Public Health Department generally used ELC Reopening
Schools funding in accordance with Federal, subrecipient, and contract requirements.
Specifically, we determined the Public Health Department and School District maintained
documentation to support subrecipient expenditures for COVID-19 testing services for students
and staff in K-12 schools. However, of the $27.7 million in subrecipient expenditures, we found
that the Public Health Department reimbursed the School District for $10,525 in costs that were
unallowable and $247,095 in overpayments. For the non-subrecipient expenditures we
reviewed, we also determined that the Public Health Department maintained documentation to
support the non-subrecipient expenditures charged against the testing program such as COVID-
19 testing in private and charter K-12 schools, PPE, COVID-19 test kits, air purifiers and filters,
and transportation costs.
The issues we identified occurred because the Public Health Department: (1) did not monitor
the School District’s compliance with contract requirements for background checks of
contracted and subcontracted employees who performed COVID-19 testing of students and (2)
failed to identify that certain costs were not reimbursable in accordance with Federal
requirements and terms of the ELC Reopening Schools Award.
THE PUBLIC HEALTH DEPARTMENT DID NOT CONSISTENTLY MONITOR THE IMPLEMENTATION
OF THE COVID-19 SCREENING TESTING PROGRAM
The Public Health Department Provided Guidance and Conducted Some Monitoring Activities
The Public Health Department provided guidance on K-12 schools’ COVID-19 testing protocols
and monitored the COVID-19 screening testing program throughout the audit period by:
• meeting regularly with the School District to review school-based activities including
COVID-19 testing, reporting, and the implementation of other mitigation measures;
• monitoring the School District’s budget, including the review and approval of revisions
to the budget; and
• reviewing invoices and supporting documentation submitted by the School District,
including an invoice reconciliation process that was documented by the Public Health
Department throughout the subrecipient agreement period.
8
Of the 86 contracted employees reviewed, we determined there was sufficient background check documentation
for all 16 contracted employees who performed COVID-19 testing of students and staff at private and charter K-12
schools.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 5
The Public Health Department Did Not Monitor the School District’s Compliance With
Background Check Requirements, and the School District Did Not Adhere to Contract
Requirements
According to Federal regulations, non-Federal entities are responsible for oversight of the
operations of Federal award-supported activities. The non-Federal entity must monitor the
subrecipient’s activities under Federal awards to assure compliance with applicable Federal
requirements and performance expectations are being achieved. 9 Additionally, the School
District was required to maintain all records pertaining to contracts for at least 3 years from the
date of submission of the final expenditure report. 10
In accordance with State law and the terms and conditions of the contracts to perform COVID-
19 testing of students and staff in K-12 schools, before starting any work the contractors must
submit to the School District, for each contracted or subcontracted employee, the following:
• State criminal history record report,
• State child abuse history certification, 11 and
• Federal Bureau of Investigation (FBI) Federal criminal history record report.12
Additionally, the contractors were required to retain all records and documentation pertaining
to the contract for at least 6 years following the expiration of the contract.
According to State law, the criminal history of employees and prospective employees of public
and private schools, including independent contractors and their employees, must not include a
felony offense of the first, second, or third degree. The individual will be eligible for continued
or prospective employment only if a period of 10 years has elapsed from the date of expiration
of the sentence for the offense. 13
We determined that the Public Health Department did not monitor the School District’s
compliance with background check requirements of the contracted and subcontracted
9
45 CFR § 75.342 and 45 CFR § 75.352(d).
10
45 CFR § 75.361 and 45 CFR § 75.101(b).
11
A “child abuse history certification” is defined as a certification from the Pennsylvania Department of Human
Services as to whether the applicant is named in the Statewide database as the alleged perpetrator in a pending
child abuse investigation or as the perpetrator of a founded report or an indicated report (23 Pa. Cons. Stat. Ann.
§ 6344(b)(2)).
12
24 Pa. Stat. § 1-111, as amended, and 23 Pa. Cons. Stat. Ann. §§ 6344 & 6344.2.
13
24 Pa. Stat. § 1-111, as amended.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 6
employees who performed COVID-19 testing of students, in accordance with Federal and
contract requirements. The contractors did not submit background check documentation to
the School District for any of the contracted and subcontracted employees who performed
COVID-19 testing of K-12 students on School District property during the audit period.
Additionally, the contractors did not maintain sufficient background check documentation in
accordance with requirements. Specifically, of the 70 contracted and subcontracted employees
who performed COVID-19 testing of K-12 students on School District property, we found that:
• Of 49 contracted employees:
o 48 employees had State criminal history record reports that were dated after the
contract had ended, and 1 employee’s criminal history record report was not
provided;
o 6 employees had State child abuse history certifications dated before performing
COVID-19 testing, 6 employees had State child abuse history certifications dated
after the employees began performing COVID-19 testing, 5 employees had State
child abuse history certifications dated after the contract had ended, and 32
employees’ State child abuse history certifications were not provided; and
o 49 employees’ FBI Federal criminal history record reports were not provided;
and
• 21 subcontracted employees did not have copies of the State criminal history records
report, State child abuse history certification, or the FBI criminal history record report;
however, 19 subcontracted employees had attestations that the employees’
backgrounds were checked, but 2 did not.
Of the State criminal history record reports and child abuse history certifications we reviewed,
we found that one of the contracted employees was not eligible for employment. Specifically,
the contracted employee was convicted of a third-degree felony, and fewer than 10 years had
elapsed since the expiration of the sentence for that offense.
The Public Health Department stated that it did not obtain or monitor the contracts the School
District awarded to contractors and that monitoring of background checks was outside of its
oversight responsibilities. Additionally, the Public Health Department did not have procedures
for monitoring subrecipients’ management of contracts, and the School District did not have
procedures in place to ensure contractors submitted the background check documentation for
contracted and subcontracted employees who performed COVID-19 testing of K-12 students.
Failure of the Public Health Department to monitor the School District’s management of
contracts, specifically, ensuring that required background checks were conducted in accordance
with Federal and contract requirements, placed the safety of children at an increased risk.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 7
THE PUBLIC HEALTH DEPARTMENT GENERALLY USED ELC REOPENING SCHOOLS FUNDING IN
ACCORDANCE WITH REQUIREMENTS FOR THE EXPENDITURES REVIEWED, BUT SOME
DEFICIENCIES WERE IDENTIFIED
For the expenditures we reviewed, the Public Health Department generally used ELC Reopening
Schools funding in accordance with Federal, subrecipient, and contract requirements.
Specifically, we determined the Public Health Department and School District maintained
documentation to support subrecipient expenditures for COVID-19 testing services for students
and staff in K-12 schools. However, of the $27.7 million in subrecipient expenditures, we found
that the Public Health Department reimbursed the School District $10,525 in costs that were
unallowable and $247,095 in overpayments. Additionally, for the $9 million in non-subrecipient
expenditures we reviewed, we determined that the Public Health Department maintained
documentation to support the expenditures charged against the testing program.
The Public Health Department Improperly Reimbursed the School District for Certain Costs
Using ELC Reopening Schools Funding
In the role as a pass-through entity, the Public Health Department was required to monitor
activities of the subrecipient to ensure: (1) the awards were used for authorized purposes in
compliance with Federal statutes, regulations, and the terms and conditions of the awards and
(2) award performance goals were achieved.14, 15 Additionally, an improper payment is any
payment that should not have been made or that was made in an incorrect amount, including
overpayments. 16 Payments made for costs determined to be unallowable must be refunded to
the Federal Government. 17
Unallowable Entertainment Costs
Costs of entertainment, including amusement, diversion, and social activities and any
associated costs, are unallowable except where specific costs that might otherwise be
considered entertainment have a programmatic purpose and are authorized either in the
approved budget for the Federal award or with prior written approval of the HHS awarding
agency. 18 Additionally, in accordance with CDC guidance, the financial resources provided were
to support school COVID-19 testing, prevention, and mitigation activities intended to support
14
45 CFR § 75.352(d).
15
A “pass-through entity” is a non-Federal entity that receives a Federal award and provides a subaward to a
subrecipient to carry out part of a Federal program. A subaward may be provided through any form of legal
agreement, including an agreement that the pass-through entity considers a contract (45 CFR § 75.2).
16
45 CFR § 75.2.
17
45 CFR 75.410.
18
45 CFR § 75.438.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 8
open, in-person K-12 school environments during the COVID-19 pandemic. 19 Mitigation
activities included public health events that included students and other community members
and were aimed at providing opportunities for increased detection and prevention of
COVID-19.
The School District used $10,525 in ELC Reopening Schools funding for entertainment costs
invoiced by a contractor that was contracted to perform COVID-19 testing for students and
staff. Specifically, the $10,525 in costs that were invoiced were categorized as a community
event, and the supporting documentation provided included receipts for bounce house rentals,
audio equipment rental for a disk jockey, security guards, custom and pre-printed t-shirts, face
painting, photobooth rental, and snacks. The costs were associated with a music festival.
The documentation provided did not include evidence that the music festival was to support
school COVID-19 testing, prevention, and mitigation activities intended to support open, in-
person K-12 school environments during the COVID-19 pandemic. Additionally, there was no
documentation that pre-approval for the entertainment costs was received prior to the music
festival. However, the Public Health Department reimbursed the School District $10,525 for
unallowable entertainment costs utilizing ELC Reopening Schools funding.
Overpayment to the School District
An improper payment is any payment that should not have been made or that was made in an
incorrect amount, including overpayments. 20 Additionally, payments made for costs
determined to be unallowable must be refunded to the Federal Government. 21
The School District submitted four invoices to the Public Health Department for air purifiers
purchased from a supplier totaling $788,960 in expenditures; however, the Public Health
Department incorrectly reimbursed the School District $1,036,055 because it paid one of the
invoices twice. As a result, the Public Health Department made an overpayment to the School
District totaling $247,095 in ELC Reopening Schools funding.
RECOMMENDATIONS
We recommend that the Philadelphia Department of Public Health:
• develop or update ELC procedures for compliance with Federal, subrecipient, and
contract requirements, including:
19
CDC, “ELC Reopening Schools: Support for Screening Testing to Reopen & Keep Schools Operating Safely.”
Accessed on June 23, 2025.
20
45 CFR § 75.2.
21
45 CFR 75.410.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 9
o oversight of subrecipients to ensure background check requirements are
followed and
o monitoring of subrecipients’ contract terms and conditions; and
• refund CDC $257,620 for costs reimbursed to the subrecipient that were unallowable or
were overpayments.
PUBLIC HEALTH DEPARTMENT COMMENTS AND OFFICE OF INSPECTOR GENERAL RESPONSE
In written comments on our draft report, the Public Health Department did not indicate
concurrence or nonconcurrence with our first recommendation but stated it disagreed with the
finding related to the first recommendation. The Public Health Department concurred with our
second recommendation. The Public Health Department detailed steps it plans to take to
address our recommendations.
PUBLIC HEALTH DEPARTMENT COMMENTS
The Public Health Department disagreed with the finding related to the first recommendation.
Specifically, the Public Health Department stated that monitoring the School District’s
compliance with State background check requirements was outside its oversight responsibilities
under the Federal award. Furthermore, the Public Health Department stated that it was the
School District’s responsibility under State law to ensure that employees, including independent
contractors and their employees, have all the required background checks. However, the Public
Health Department stated that its Division of Disease Control is in the process of updating the
standard operating procedures for subrecipient monitoring. The Public Health Department
indicated that these protocols will detail necessary processes for efficient and effective
subrecipient monitoring.
The Public Health Department concurred with our second recommendation to refund CDC costs
reimbursed to the subrecipient that were unallowable or were overpayments. The Public
Health Department indicated that corrective actions will include: (1) reviewing, updating, and
providing training to ensure all requested reimbursements are allowable; (2) implementing
additional checkpoints for the invoice reconciliation process to ensure no charges are
duplicative; and (3) working with appropriate City agencies to refund the unallowable costs and
overpayments to CDC.
The Public Health Department’s comments are included in their entirety as Appendix B.
OFFICE OF INSPECTOR GENERAL RESPONSE
Regarding our first recommendation, we maintain that monitoring compliance with the terms
and conditions of the subrecipient agreement, which included compliance with State
background check requirements, was part of the Public Health Department’s oversight
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 10
responsibilities in its role as a pass-through entity. Federal regulations (45 CFR §§ 75.342 &
75.352(d)) require the Public Health Department to monitor the activities of the subrecipient
(i.e., School District) to ensure the subrecipient agreement is used for authorized purposes, in
compliance with Federal statutes, regulations, and terms and conditions of the subrecipient
agreement. In this case, the terms and conditions of the subrecipient agreement between the
Public Health Department and the School District specifically required the School District to
comply with all Federal and State laws applicable to the School District, including compliance
with background check requirements. Therefore, monitoring compliance with background
check requirements under State law was within the Public Health Department’s responsibilities
in accordance with the terms and conditions of the subrecipient agreement.
We appreciate the Public Health Department’s cooperation throughout our audit and the
actions the Public Health Department plans to take to address our recommendations. We
maintain that our first recommendation is valid.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 11
APPENDIX A: AUDIT SCOPE AND METHODOLOGY
SCOPE
Our audit covered approximately $41.4 million in ELC Reopening Schools award expenditures
the Public Health Department incurred from April 8, 2021, through July 31, 2023 (audit period).
We reviewed the Public Health Department’s implementation of the testing program and
oversight provided to the School District and K-12 schools during the audit period. Additionally,
for the 86 contracted and subcontracted employees who performed COVID-19 testing on
School District property and at private and charter K-12 schools during our audit period, we
reviewed the background check documentation. Finally, we reviewed $27.7 million in
subrecipient expenditures and a nonstatistical sample of 28 vouchers totaling approximately
$9 million in non-subrecipient expenditures to determine whether the ELC Reopening Schools
funding was used in accordance with Federal, subrecipient, and contract requirements.
We did not assess the overall internal control structure of the Public Health Department.
Rather, we limited our review of internal controls to those applicable to our audit objectives.
Specifically, we assessed the Public Health Department’s: (1) processes and procedures for
monitoring the COVID-19 screening testing program, including contract management, and
(2) procedures for monitoring and maintaining documentation to support ELC Reopening
Schools award expenditures. Any internal control deficiencies we found are discussed in this
report.
We conducted our audit from October 2023 through September 2025.
METHODOLOGY
To accomplish our objective, we:
• reviewed applicable Federal, State, subrecipient, and contract requirements;
• met with Public Health Department officials to gain an understanding of how the Public
Health Department monitored the implementation of and services provided by the
School District and K-12 schools under the testing program;
• obtained and reviewed the Public Health Department’s procedures for obtaining and
maintaining documentation to support ELC Reopening Schools award expenditures;
• obtained and reviewed ELC Reopening Schools award expenditures incurred by the
Public Health Department during the audit period;
• identified the 86 contracted and subcontracted employees who performed COVID-19
testing on the School District’s property and in private and charter K-12 schools during
our audit period;
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 12
• reviewed background check documentation associated with the 86 contracted and
subcontracted employees;
• reviewed all 9 vouchers and related invoices totaling $27.7 million in subrecipient
expenditures;
• selected a nonstatistical sample of 28 vouchers totaling approximately $9 million in non-
subrecipient expenditures, out of 104 vouchers totaling approximately $13.7 million, to
ensure we reviewed the different types of non-subrecipient expenditures associated
with ELC Reopening Schools funding;
• reviewed documentation supporting the nonstatistical sample of 28 vouchers for the
non-subrecipient expenditures; and
• discussed the results of our audit with Public Health Department and School District
officials.
We conducted this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 13
APPENDIX B: PUBLIC HEALTH DEPARTMENT COMMENTS
DEPARTMENT OF PUBLIC HEALTH
CITY OF PHILADELPHIA 1101 Market Street
Philadelphia, PA 19107
PALAK RAVAL-NELSON, PhD, MPH
Health Commissioner
JESSICA CAUM, MA, MPH
Director, Division of Disease Control
October 10, 2025
U.S. Department of Health and Human Services
Office of Inspector General
Office of Audit Services, Region V
233 North Michigan Avenue, Suite 802
Chicago, IL 60601
Report Number: A-05-24-00003
Dear Ms. Fulcher:
This letter is provided in response to a letter received on September 4, 2025 that included the
draft report “Philadelphia Did Not Meet All of the Requirements for the COVID-19 Screening
Testing Program at K-12 Schools,” which is the final draft of the preliminary report received in
February 2025 titled “Philadelphia Generally Monitored the Implementation of and Services
Provided Under the COVID-19 Screening Testing Program However Some Deficiencies Were
Identified.” The purpose of this letter is to respond to the audit findings described in the report
and to outline proposed corrective actions for the two recommendations issued by the
Department of Health and Human Services, Office of Inspector General (OIG).
The Philadelphia Department of Public Health (PDPH) is proud of the successful school testing
program that was implemented in the City of Philadelphia and supported by funding provided by
the United States Department of Health and Human Services Centers for Disease Control and
Prevention (CDC) Epidemiology and Laboratory Capacity (ELC) Reopening Schools program.
The health, social, and economic impacts of the COVID-19 pandemic were devastating.
Reopening Schools funding enhanced our capacity for COVID-19 readiness and response in
schools and other childcare settings, which was a critical component of the City’s overall
response to the pandemic. Between April 2021 and July 2023, ELC funding allowed for the
administration of 1,126,963 COVID-19 tests in schools. In addition, funding was dedicated to
the distribution of personal protective equipment (PPE) and testing supplies, such as over-the-
counter (OTC) and point-of-care (POC) test kits and pediatric and adult KN95 masks, which
were essential to protecting students and staff and allowing schools to reopen and stay open. The
distribution of OTC kits aided in the rapid identification and isolation of cases, thus enabling
schools to rapidly respond to cases and limit transmission. Furthermore, with the allowance from
ELC to distribute OTC kits to summer camps, children were able to attend camp in safe and
healthy conditions. In summary, this funding enabled Philadelphia to protect staff and students,
while also helping the City begin the path to recovery through the reopening of schools.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 14
While this program had many positive health, social, and economic impacts, we acknowledge the
audit findings identified in the report and offer our responses to the two recommendations as
outlined below:
• Recommendation: Develop or update ELC procedures for compliance with Federal,
subrecipient, and contract requirements, including:
o oversight of subrecipients to ensure background check requirements are followed
and
o monitoring of subrecipients’ contract terms and conditions.
Philadelphia Department of Public Health’s response:
We disagree with this finding and maintain that monitoring the School District of
Philadelphia’s compliance with State background check requirements was outside of PDPH’s
oversight responsibilities under the Federal award. Federal regulations require non-Federal
entities to monitor the activities of the subrecipient to ensure that the subaward is used for
authorized purposes, in compliance with Federal statutes, regulations, and terms and
conditions of the subaward.1 Monitoring compliance with background check requirements
under State law was outside the scope of PDPH’s monitoring responsibilities under Federal
regulations and the terms and conditions of the Federal award. Further, as the largest school
district in the Commonwealth, it is the School District’s responsibility under State law to
ensure that employees and prospective employees of public and private schools, including
independent contractors and their employees, have all of the required background checks and
are not barred from performing services that have direct contact with children.2 For those
reasons, PDPH takes no position on the report’s finding related to the School District’s
enforcement of background check provisions in its subcontracts.
Notwithstanding the foregoing, PDPH’s Division of Disease Control (DDC) is in the process
of updating Standard Operating Procedures (SOPs) for subrecipient monitoring. These
protocols will detail necessary processes for efficient and effective subrecipient monitoring,
including creation of a comprehensive checklist to guide monitoring of grant requirements to
ensure compliance with federal statutes and regulations and manage adherence to contract
terms and conditions. All staff involved in management of subrecipients funded via ELC will
be trained to these updated protocols.
• Recommendation: Refund CDC $257,620 for costs reimbursed to the subrecipient that
were unallowable or were overpayments.
Philadelphia Department of Public Health’s response:
We concur with the audit finding regarding unallowable costs and overpayment and this
recommendation. Corrective actions include: 1) review, update, and provide training on
internal controls to ensure that fiscal analysts who review invoices evaluate all supporting
documentation to ensure all requested reimbursements are allowable costs per funding
guidelines; 2) implement additional checkpoints in the invoice reconciliation process to
ensure no charges are duplicative; 3) work with the appropriate City agencies to refund
$257,620 of unallowable costs/overpayments to the CDC.
1
45 CFR § 75.342 and 45 CFR § 75.352(d).
2
24 Pa. Stat. § 1-111, as amended, and 23 Pa. Cons. Stat. Ann. §§ 6344 & 6344.2.
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 15
Please contact me if you have any questions or require any additional information.
Sincerely,
Palak Raval-Nelson, PhD, MPH
Health Commissioner
Philadelphia’s COVID-19 Screening Testing Program at K-12 Schools (A-05-24-00003) 16
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