COVID-19 Contracting: Opportunities to Improve Practices to Assess Prospective Vendors (GAO-21-528)
Summary
GAO-21-528, a July 2021 report from the United States Government Accountability Office to congressional addressees on COVID-19 contracting. It reports that as of May 31, 2021, agencies obligated $61.4 billion for contracts in response to the COVID-19 pandemic and cancelled $4 billion in obligations. For a sample of contracts at the Departments of Defense, Health and Human Services, Agriculture, and Homeland Security, contracting officials identified challenges, including working with vendors new to federal contracting. GAO is making 10 recommendations; agencies agreed with nine, and the Office of Management and Budget did not agree to establish time frames for updating its guidance.
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“COVID-19 Contracting: Opportunities to Improve Practices to Assess Prospective Vendors (GAO-21-528).”
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United States Government Accountability Office
Report to Congressional Addressees
COVID-19
July 2021
CONTRACTING
Opportunities to
Improve Practices to
Assess Prospective
Vendors and Capture
Lessons Learned
GAO-21-528
July 2021
COVID-19 CONTRACTING
Opportunities to Improve Practices to Assess
Prospective Vendors and Capture Lessons Learned
Highlights of GAO-21-528, a report to
congressional addressees
Why GAO Did This Study What GAO Found
In response to COVID-19, agencies As of May 31, 2021, agencies obligated $61.4 billion for contracts in response to
awarded contracts for goods and the COVID-19 pandemic. Agencies cancelled $4 billion in obligations, in some
services to vendors from a range of cases due to contract terminations. The proportion of obligations to vendors with
industries and with varying levels of prior federal experience government-wide was 88 percent but varied by agency
federal contracting experience, but (see figure). In calendar year 2020, agencies awarded about 5 times as many
some vendors have been unable to contracts to vendors without prior federal contracting experience for COVID-19,
deliver under those contracts. as compared to contracts awarded overall in preceding calendar years.
The CARES Act included a provision
COVID-19-Related Contract Obligations to Vendors with or without Prior Federal Contracting
for GAO to review COVID-19-related
Experience for the Five Agencies with the Most Obligations, as of May 31, 2021
federal contracting under the act. This
report addresses (1) COVID-19
contract obligations and
characteristics of vendors, (2)
contracting challenges, including with
agency assessments of vendors, and
(3) whether lessons learned efforts
reflect those challenges.
GAO analyzed federal procurement
data on agencies’ reported COVID-19
contract obligations through May 31,
2021. GAO examined a
nongeneralizable sample of 28
contracts with high dollar values or
other characteristics from four
agencies—DOD, HHS, USDA, and
DHS. GAO interviewed officials,
including Office of Management and
Budget (OMB) officials about their
emergency acquisition guidance.
What GAO Recommends For the selected contracts GAO reviewed across four agencies—the
GAO is making 10 recommendations, Departments of Defense (DOD), Health and Human Services (HHS), Agriculture
including that agencies establish (USDA), and Homeland Security (DHS)—contracting officials identified a number
processes to better collect and of challenges, including:
communicate contracting lessons
learned during emergencies such as • working with vendors new to federal contracting or vendors supplying
COVID-19. Agencies agreed with products they had not previously provided;
nine recommendations. OMB did not • operating under limited time frames to make awards; and
agree to establish time frames for • contracting for supplies and services the agency does not typically buy.
updating its guidance. GAO continues
to believe OMB should do so, as The four agencies are collecting and sharing lessons learned related to their
discussed in this report. COVID-19 response. However, HHS and DHS have not included contracting
lessons learned, even though they identified contracting challenges. Collecting
contracting lessons learned could inform future emergency response efforts.
Furthermore, although interagency coordination was critical to the response,
contracting lessons learned are at risk of not being reflected in formal
View GAO-21-528. For more information, interagency lessons learned efforts. Without a process to do so, federal agencies
contact Marie A. Mak at (202) 512-4841 or
makm@gao.gov. risk missing an opportunity to memorialize contracting and coordination practices
that were successful, as well as those that were not, for future emergencies.
United States Government Accountability Office
Contents
Letter 1
Background 5
Federal Agencies Obligated More Than $61 Billion on COVID-19-
Related Contracts 12
Contracting Officers Did Not Always Have Access to or Were Not
Aware of Resources Available to Assess Prospective Vendors 19
Agencies Identified Contracting Challenges and Positive
Practices, but Shortfalls Exist in Lessons Learned Processes 34
Conclusions 48
Recommendations for Executive Action 49
Agency Comments 51
Appendix I Objectives, Scope, and Methodology 55
Appendix II Comments from the Department of Defense 62
Appendix III Comments from the Department of Health and Human Services 64
Appendix IV Comments from the Department of Homeland Security 67
Appendix V GAO Contact and Staff Acknowledgments 71
Tables
Table 1: COVID-19 Small Business Vendors by Obligation Range,
as of May 31, 2021 16
Table 2: Resources that Contracting Officials Identified Using to
Assess Prospective Vendors Across Selected Contracts 22
Table 3: Challenges and Outcomes Identified by Contracting
Officials at the Departments of Defense (DOD), Health
and Human Services (HHS), Agriculture (USDA) and
Homeland Security (DHS) 35
Table 4: Description of Selected Contracts 58
Page i GAO-21-528 COVID-19 Contracting
Figures
Figure 1: COVID-19-Related Contract Obligations and Proportion
of Obligations to Vendors with Prior Federal Contracting
Experience, by Federal Agency, as of May 31, 2021 14
Figure 2: COVID-19-Related Contract Obligations and Proportion
of Obligations to Vendors with Prior Federal Contracting
Experience, by Top Goods and Services, as of May 31,
2021 15
Figure 3: Government-wide COVID-19-Related Contract
Obligations to Top 10 Vendors, as of May 31, 2021 16
Figure 4: Initial COVID-19-Related Contract Obligations and
Subsequent Deobligations, by Agency, as of May 31,
2021 18
Figure 5: Examples of Resources Used by Contracting Officers to
Assess Prospective Vendors for COVID-19-Related
Contracts 21
Figure 6: Examples of Interagency Contracting Coordination
across Selected Contracts 45
Page ii GAO-21-528 COVID-19 Contracting
Abbreviations
AMS Agricultural Marketing Service
ASPR Office of the Assistant Secretary for Preparedness and
Response
BARDA Biomedical Advanced Research and Development
Authority
COVID-19 Coronavirus Disease 2019
CPARS Contractor Performance Assessment Reporting System
DHS Department of Homeland Security
DLA Defense Logistics Agency
DOD Department of Defense
E2A2 Exercise, Evaluation and After Actions Division
FAPIIS Federal Awardee Performance and Integrity Information
System
FAR Federal Acquisition Regulation
FEMA Federal Emergency Management Agency
FPDS Federal Procurement Data System
HHS Department of Health and Human Services
OFPP Office of Federal Procurement Policy
OMB Office of Management and Budget
SAM System for Award Management
USACE U.S. Army Corps of Engineers
USDA U.S. Department of Agriculture
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Page iii GAO-21-528 COVID-19 Contracting
Letter
441 G St. N.W.
Washington, DC 20548
July 29, 2021
Congressional Addressees
Since the declaration of Coronavirus Disease 2019 (COVID-19) as a
national emergency on March 13, 2020, the United States has reported
more than 30 million confirmed cases, and there have been significant
effects from the pandemic on public health and the economy. To help
mitigate these effects, agencies awarded contracts to thousands of
vendors from a wide range of industries and with varying levels of federal
contracting experience for critical goods and services, such as N95
respirators, ventilators, and the development and production of vaccines.
However, during the course of the pandemic, some vendors have been
unable to deliver those goods and services as promised.
Our prior work found that contracts play a key role in federal emergency
response efforts, and that contracting during an emergency can present a
unique set of challenges as officials endeavor to provide critical goods
and services as expeditiously and efficiently as possible. 1 For example,
our work following the 2017 and 2018 hurricanes and wildfires identified
challenges managing, planning, and executing contracts and monitoring
purchase card use. 2 These challenges were due, in part, to shortcomings
in agency contracting guidance and in efforts to assess fraud risks in a
disaster response environment. We have also reported on challenges
agencies face identifying and sharing interagency contracting lessons
learned following an emergency to improve future response efforts. 3
The CARES Act included a provision for GAO to provide a
comprehensive audit and review of federal contracting pursuant to
1GAO, Disaster Contracting: FEMA Continues to Face Challenges with Its Use of
Contracts to Support Response and Recovery, GAO-19-518T (Washington, D.C.: May 9,
2019); 2017 Disaster Contracting: Actions Needed to Improve the Use of Post-Disaster
Contracts to Support Response and Recovery, GAO-19-281 (Washington, D.C.: Apr. 24,
2019); and 2017 Disaster Contracting: Action Needed to Better Ensure More Effective Use
and Management of Advance Contracts, GAO-19-93 (Washington, D.C: Dec. 6, 2018).
2GAO, Disaster Response: Agencies Should Assess Contracting Workforce Needs and
Purchase Card Fraud Risk, GAO-21-42 (Washington, D.C.: Nov. 24, 2020); GAO-19-281;
and GAO-19-93.
3GAO-19-281.
Page 1 GAO-21-528 COVID-19 Contracting
authorities provided in the act. 4 This report is one in a series of reports
examining federal agencies’ contracting in response to COVID-19. 5 This
report examines (1) contract obligations and characteristics of vendors;
(2) the information selected agencies used to assess prospective vendors
and the extent to which the agencies communicated available information
to contracting officers; and (3) the extent to which selected agencies
experienced challenges and established processes to collect and share
contracting lessons learned.
To identify contract obligations and characteristics of vendors involved in
the response to the COVID-19 pandemic, we analyzed data available in
the Federal Procurement Data System (FPDS) as of May 31, 2021.
Though agencies may obligate dollars through various other vehicles
such as grants or cooperative agreements, this report is focused
specifically on contract obligations. 6 We primarily identified these contract
actions and associated obligations related to the COVID-19 response by
using the National Interest Action code. 7 We took additional steps to
ensure contract actions and obligations included in our analysis were
related to COVID-19. For a detailed description of these actions, see
appendix I. We assessed the reliability of FPDS data by reviewing
4Pub. L. No. 116-136, div. B, tit. IX, § 19010, 134 Stat. 281, 579 (2020). We regularly
issue government-wide reports on the federal response to COVID-19. For the latest
report, see GAO, COVID-19: Continued Attention Needed to Enhance Federal
Preparedness, Response, Service Delivery, and Program Integrity, GAO-21-551
(Washington, D.C.: July 19, 2021). Our next government-wide report will be issued in
October 2021 and will be available on GAO’s website at https://www.gao.gov/coronavirus.
5GAO, COVID-19 Contracting: Contractor Paid Leave Reimbursements Could Provide
Lessons Learned for Future Emergency Response, GAO-21-475, (Washington, D.C.: July
28, 2021); COVID-19 Contracting: Actions Needed to Enhance Transparency and
Oversight of Selected Awards, GAO-21-501 (Washington, D.C.: July 26, 2021); Defense
Production Act: Opportunities Exist to Increase Transparency and Identify Future Actions
to Mitigate Medical Supply Chain Issues, GAO-21-108 (Washington, D.C.: Nov. 19, 2020);
COVID-19 Contracting: Observations on Contractor Paid Leave Reimbursement Guidance
and Use, GAO-20-662 (Washington, D.C.: Sept. 3, 2020); and COVID-19 Contracting:
Observations on Federal Contracting in Response to the Pandemic, GAO-20-632
(Washington, D.C.: July 29, 2020).
6For the purposes of this report, “contract obligations” means obligations on contracts that
are subject to the Federal Acquisition Regulation, and does not include, for example,
grants, cooperative agreements, loans, other transactions for research, real property
leases, or requisitions from federal stock.
7National Interest Action codes were established in 2005 after Hurricane Katrina with the
purpose of tracking federal procurements for specific disasters, emergencies, or
contingency events. A National Interest Action code was established on March 13, 2020,
for the COVID-19 pandemic, and contract actions and their associated obligations are
coded as related to the COVID-19 response in a field in FPDS.
Page 2 GAO-21-528 COVID-19 Contracting
existing information about the system and the data it collects—
specifically, the data dictionary and validation rules—and performing
electronic testing. We determined the FPDS data were sufficiently reliable
for the purposes of describing agencies’ reported contract obligations to
vendors in response to COVID-19.
We analyzed the FPDS data to identify the agencies with the highest
COVID-19 contract obligations, the types of goods and services procured,
and vendor characteristics, such as whether a vendor had prior federal
contracting experience and whether the vendor was a small or large
business. We augmented data from FPDS with data from the System for
Award Management (SAM) and the Federal Awardee Performance and
Integrity Information System (FAPIIS) to identify additional information
about vendors receiving COVID-19 contracts. This information included
whether or not vendors were registered in SAM and whether or not there
was a record in FAPIIS identifying prior performance or integrity
concerns.
To determine what information selected agencies used to assess
prospective vendors that were awarded contracts in response to COVID-
19, we selected four of the top five departments with the highest COVID-
19 contract obligations as of August 31, 2020—the Departments of
Defense (DOD), Health and Human Services (HHS), Agriculture (USDA),
and Homeland Security (DHS). 8 Within these departments, we selected
the agencies that collectively accounted for at least two-thirds of each
department’s COVID-19 contract obligations:
• DOD’s Defense Logistics Agency (DLA) and Department of the Army;
• HHS’s Office of the Assistant Secretary for Preparedness and
Response (ASPR);
• USDA’s Agricultural Marketing Service (AMS); and
• DHS’s Federal Emergency Management Agency (FEMA).
We collected and reviewed contract files for a nongeneralizable sample of
28 contracts and task or delivery orders (hereafter referred to as
8We selected August 31, 2020 as it was the time we were beginning and scoping our
review. The other agency with the highest contract obligations was the Department of
Veterans Affairs, which we did not include due to other ongoing work on the department’s
contracting response to COVID-19. See GAO, VA COVID-19 Procurements: Pandemic
Underscores Urgent Need to Modernize Supply Chain, GAO-21-280 (Washington, D.C.:
June 15, 2021).
Page 3 GAO-21-528 COVID-19 Contracting
contracts, unless otherwise specified), seven from each department
awarded between January 2020 and August 31, 2020. 9 We selected the
contracts based on a variety of factors, including dollar amount and
whether the contract was awarded to a vendor with prior federal
contracting experience. 10 For our selected contracts, we gathered and
reviewed contract documentation related to agency assessments of
prospective vendors’ responsibility and capability, such as vendor
proposals, responsibility determinations (where available), and source
selection evaluation reports. We also conducted semi-structured
interviews with contracting officials responsible for the 28 selected
contracts to discuss the resources they used to assess prospective
vendors.
To assess the extent to which selected agencies communicated available
information to contracting officers to assess prospective vendors, we
reviewed agency, department, and government-wide guidance and
regulations related to assessing prospective vendors and emergency
acquisitions. This included the Federal Acquisition Regulation (FAR),
department and agency supplements to the FAR, agency guidance and
job aids, and the Office of Federal Procurement Policy’s (OFPP)
Emergency Acquisitions Guide. We also reviewed federal internal control
standards on risk assessment, information, and communication. 11 We
interviewed acquisition policy and contracting officials responsible for our
selected contracts to determine the contracting officers’ awareness of
information and resources available to assess prospective vendors during
an emergency. We also interviewed OFPP staff to identify efforts, if any,
underway to update or revise the Emergency Acquisitions Guide.
To determine the extent to which selected agencies experienced
challenges when contracting in response to COVID-19 and established
processes to collect and share contracting lessons learned, we
9For DOD, we selected three contracts from DLA and four from the Department of the
Army. Within the Department of the Army, we selected one contract from Army
Contracting Command and three contracts from the U.S. Army Corps of Engineers.
10We initially selected eight contracts and task orders per department for a total of 32
contracts. However, we removed three contracts because they were potentially the
subject of an ongoing Office of Inspector General or other federal investigation. We also
removed one contract that was reported as awarded in FPDS, but that agency officials
told us had, in fact, never been awarded.
11GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: September 2014).
Page 4 GAO-21-528 COVID-19 Contracting
interviewed DOD, HHS, USDA, and DHS contracting officials for our 28
selected contracts. We reviewed available COVID-19 after-action reports
at DOD, USDA, and DHS to identify agencies’ lessons learned and
proposed actions to address these lessons. 12 We also interviewed
contracting officials at each agency or department and officials
responsible for gathering and reporting on lessons learned to assess their
efforts to collect and share lessons against leading practices GAO and
others have previously identified. 13 Appendix I provides more information
about our scope and methodology.
We conducted this performance audit from August 2020 to July 2021 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.
Agencies have contracted to obtain the goods and services needed to
Background respond to COVID-19 within the context of their specific roles and
responsibilities. According to DHS’s National Response Framework—a
guide to how the federal government, states and localities, and other
public and private sector institutions should respond to disasters and
emergencies—the Secretary of Homeland Security is responsible for
ensuring that federal preparedness actions during a national emergency
12HHS had not completed an after-action report at the time of our review.
13GAO, Army Modernization: Army Should Improve Use of Alternative Agreements and
Approaches by Enhancing Oversight and Communication of Lessons Learned, GAO-21-8
(Washington, D.C.: Oct. 1, 2020); DOD Utilities Privatization: Improved Data Collection
and Lessons Learned Archive Could Help Reduce Time to Award Contracts, GAO-20-104
(Washington, D.C.: Apr. 2, 2020); Project Management: DOE and NNSA Should Improve
Their Lessons-Learned Process for Capital Asset Projects, GAO-19-25 (Washington,
D.C.: Dec. 21, 2018); and Federal Real Property Security: Interagency Security
Committee Should Implement a Lessons-Learned Process, GAO-12-901 (Washington,
D.C.: Sept. 10, 2012). GAO-19-25 identified some lessons learned practices from reports
by both the Project Management Institute and Department of the Army, Combined Arms
Center, Center for Army Lessons Learned. Project Management Institute, Inc., A Guide to
the Project Management Body of Knowledge (PMBOK® Guide), Sixth Edition, 2017;
Project Management Institute, Inc., Implementing Organizational Project Management: A
Practice Guide, First Edition, 2014; and Center for Army Lessons Learned, Establishing a
Lessons Learned Program: Observations, Insights, and Lessons (Fort Leavenworth, KS:
June 2011). PMBOK is a trademark of Project Management Institute, Inc.
Page 5 GAO-21-528 COVID-19 Contracting
are coordinated to prevent gaps in the federal government’s response. 14
The framework designates FEMA to lead the coordination of disaster
response efforts across federal agencies. FEMA coordinates disaster
response efforts through mission assignments—work orders that FEMA
issues to direct other federal agencies to use the authorities and the
resources granted to it under federal law. Mission assignments are
authorized by the Robert T. Stafford Disaster Relief and Emergency
Assistance Act and can consist of federal operations support or direct
federal assistance, which includes federal contracts. 15 During the
response to COVID-19, HHS was designated as the lead federal agency
to address the public health and medical portion of the response, and
FEMA was designated to co-lead the overall federal response.
Federal agencies are designated as coordinating agencies across 15
Emergency Support Functions—specific functional areas for the most
frequently needed capabilities during an emergency. The National
Response Framework states that when an Emergency Support Function
is activated in response to an incident, the primary agency and other
support agencies for that emergency support function are responsible for
delivering core capabilities that can include contracting. For example:
• The U.S. Army Corps of Engineers (USACE) within DOD is
responsible for the provision of assets and services related to public
works and engineering. To fulfill this role during the response to
COVID-19, the agency awarded contracts for the construction of
alternate care facilities to treat COVID-19 patients. 16 In addition, DLA
has a standing arrangement with FEMA to acquire goods and
services, and received mission assignments to contract for personal
protective equipment like gloves, surgical masks, and gowns in
support of the pandemic response.
• HHS is the coordinating agency responsible for public health and
medical services, which can include the assessment of public health
and medical needs, provision of medical equipment and supplies, and
public health communication, among other responsibilities. Within
HHS, ASPR leads the nation’s medical and public health
preparedness for, response to, and recovery from disasters and public
14Department of Homeland Security, National Response Framework (October 2019).
15See 42 U.S.C. § 5192(a)(1).
16An alternate care facility is a facility that is temporarily converted for health care use
during a public health emergency to reduce the burden on hospitals and established
medical facilities.
Page 6 GAO-21-528 COVID-19 Contracting
health emergencies. ASPR awarded contracts for a variety of COVID-
19 medical response needs, including vaccine manufacturing capacity
and medical equipment and supplies such as ventilators, N95
respirators, and gloves to replenish the Strategic National Stockpile.
Rebuilding the stockpile, which is designed to supplement state and
local supplies during public health emergencies, falls under ASPR’s
responsibilities.
• USDA is the coordinating agency for agriculture and natural
resources, which includes functions to protect the nation’s food supply
and provide nutrition assistance through programs like the Farmers to
Families Food Box Program. AMS implemented the Farmers to
Families Food Box program in May 2020 to assist commodity
suppliers affected by the pandemic and provide food assistance to the
public. Through the program, AMS contracted with hundreds of
distributors to purchase billions of dollars in fresh fruits, vegetables,
dairy, and meat products. These products were then packaged into
family-sized food boxes for delivery to food banks, community and
faith based organizations, and other non-profit entities around the
country.
Given the unprecedented nature of the response to COVID-19, some
federal agencies relied on interagency agreements to obtain needed
supplies or services from another agency. For example, in April 2020,
ASPR established memorandums of understanding with DOD and FEMA
for those agencies to provide contracting services and support for the
acquisition of medical supplies and services. These supplies and services
included personal protective equipment, testing supplies, and
construction and renovation of facilities for the production of vaccines and
therapeutics. Under the memorandums of understanding, ASPR provided
the acquisition requirements to DOD or FEMA, which then contracted for
the supply or service, and were subsequently reimbursed by HHS
pursuant to the Economy Act. 17
FAR Requirements The FAR requires that agencies take certain steps before awarding
Related to Assessing contracts to prospective vendors:
Prospective Vendors
Contractor responsibility determinations. The FAR requires that no
purchase or award be made from a prospective vendor unless the
contracting officer has made an affirmative determination of
17Economy Act, 31 U.S.C. §§ 1535-1536. The Economy Act authorizes agencies to enter
into agreements for the interagency provision of goods and services.
Page 7 GAO-21-528 COVID-19 Contracting
responsibility. 18 To be determined responsible, a prospective contractor
must:
• have adequate financial resources to perform the contract, or the
ability to obtain them;
• be able to comply with the required or proposed delivery or
performance schedule;
• have a satisfactory performance record;
• have a satisfactory record of integrity and business ethics;
• have the necessary organization, experience, accounting and
operational controls, and technical skills, or the ability to obtain them;
• have the necessary production, construction, and technical equipment
and facilities, or the ability to obtain them; and
• be otherwise qualified and eligible to receive an award under
applicable laws and regulations. 19
In general, the determination of a prospective contractor’s responsibility is
within the broad discretion of the contracting officer, and contracting
officers may collect or review a variety of information to assess a
particular element of contractor responsibility. Financial capability, for
instance, may be assessed by reviewing documentation from a vendor’s
lender about their line of credit or by reviewing the vendor’s financial
statements. Contracting officers have less flexibility in some of the other
resources used to assess prospective vendors. For example, the FAR
requires contracting officers to review the performance and integrity
information available in certain government-wide databases when
determining contractor responsibility. Specifically:
• Federal Awardee Performance and Integrity Information System
(FAPIIS): FAPIIS is designed to assist contracting officers with
making a responsibility determination by providing integrity and
performance information on federal contractors. Specifically, FAPIIS
provides a prospective contractor “Report Card” that includes
information pertaining to the contractor’s past performance on
government contracts (if applicable). This information includes
nonresponsibility determinations, exclusions, and, if a contract was
18FAR § 9.103(b).
19FAR § 9.104-1.
Page 8 GAO-21-528 COVID-19 Contracting
terminated, whether the termination was considered to be at the fault
of the contractor. 20 Before awarding any contract over the simplified
acquisition threshold, a contracting officer must review prospective
contractor’s performance and integrity information in FAPIIS and
document in the contract file how the information in FAPIIS was used
to determine responsibility. 21
• System for Award Management (SAM): SAM is managed by the
General Services Administration and is the primary government
repository for prospective federal awardee information. Subject to
certain exceptions, a vendor must be registered in SAM to comply
with mandatory reporting requirements, which can include providing
ownership, business size, and tax liability information. The exceptions
include contracts awarded without full and open competition due to
unusual and compelling urgency and contracts awarded in emergency
operations, such as responses to national emergencies like COVID-
19. 22
• Contractor Performance Assessment Reporting System
(CPARS): CPARS is an evaluation reporting tool for all past
performance reports on government contracts and orders. Past
performance reports in CPARS reflect ratings and supporting
narratives for various factors, including quality of goods and services,
management and business relations, and adherence to schedules.
Agencies are generally required to prepare performance evaluations
20Contractors may be determined nonresponsible if they do not have a satisfactory record
of performance, integrity, or business ethics. For example, failing to make a sufficient
effort to perform acceptably on a prior contract is strong evidence of nonresponsibility.
According to SAM, exclusions identify those parties excluded from receiving federal
contracts, certain subcontracts, and from certain types of federal financial and non-
financial assistance and benefits, and they are also commonly known as “suspensions”
and “debarments.”
21FAR § 9.104-6. Agencies generally must use simplified acquisition procedures for
purchases of goods or services at or below the simplified acquisition threshold. The
simplified acquisition threshold generally is $250,000, but it increases to $800,000 for
acquisitions in the U.S. determined by the head of the agency to support a response to an
emergency or major disaster declared under the Robert T. Stafford Disaster Relief and
Emergency Assistance Act. FAR § 2.101.
22FAR § 4.1102(a)(3), (5). For contracts awarded in emergency operations, the FAR
instructs contracting officers to modify, if practical, the contract to require SAM
registration, FAR § 4.1102(b).
Page 9 GAO-21-528 COVID-19 Contracting
on contracts and orders at least annually, and when the work under a
contract is completed. 23
Vendors that are new to federal contracting may not have information
reported in the government’s databases. The FAR instructs agencies to
conduct, to the maximum extent practicable, market research on an
ongoing basis to effectively identify the capabilities of small businesses
and new entrants into federal contracting that are available to meet
agency requirements for disaster or emergency relief activities, among
other things. 24
While documents and reports supporting a determination of responsibility,
such as the use of FAPIIS, must be included in the contract file, the
contracting officer’s signature on a contract constitutes the determination
that a prospective vendor is responsible with respect to the contract.
Source selection. The FAR describes several contracting methods that
can vary based on the circumstances of the procurement. For example, a
request for proposals is used in negotiated procurements to communicate
the government’s requirements to prospective vendors and to solicit
proposals. 25 Following the receipt of proposals in competitive negotiated
procurements, agencies are responsible for evaluating the proposals
based solely on the factors and significant subfactors identified in the
solicitation. While the selection of these factors and their relative
importance are at the discretion of agency acquisition officials, price or
cost, the quality of the good or service, and past performance are
generally required to be evaluated in competitive negotiated
procurements. 26 For example, regarding proposal evaluation for
negotiated procurements, the FAR states that past performance is one
indicator of a prospective vendor’s ability to successfully perform the
contract, and that prospective vendors without a record of relevant past
23FAR § 42.1502(a).
24FAR § 10.001(a)(2)(vi).
25FAR § 15.203(a). At a minimum, requests for proposals for competitive negotiated
procurements must describe the government’s requirement, the anticipated terms and
conditions that will apply to the contract, the information required to be in the prospective
vendor’s proposal, and the factors and significant subfactors that will be used to evaluate
the proposal and their relative importance.
26FAR § 15.304(c).
Page 10 GAO-21-528 COVID-19 Contracting
performance cannot be evaluated favorably or unfavorably on that
basis. 27
Agency Regulations and Agencies may issue agency-specific acquisition regulations and internal
Guidance guidance that implements or supplements the FAR. 28 For example, DHS
relies on the Homeland Security Acquisition Regulation and Homeland
Security Acquisition Manual—issued by DHS’s Chief Procurement
Officer—to implement and supplement the FAR. Together, these
documents provide more specific department-wide policies and
procedures for implementing acquisition requirements laid out by the
FAR, such as competition, acquisition planning, and market research.
Similarly, within DOD, the Defense Federal Acquisition Regulation
Supplement implements and supplements the FAR, and the companion
Procedures, Guidance, and Information contains mandatory and non-
mandatory internal procedures and guidance. In addition to these
resources, DLA and the Department of the Army rely on the Defense
Logistics Acquisition Directive and Army Federal Acquisition Regulation
Supplement, respectively, to further implement and supplement federal
and DOD-wide acquisition regulations. Subject to certain authorities,
agencies may issue internal guidance at any organizational level to
designate and delegate authorities, assign responsibilities, and identify
internal reporting requirements. 29 For example, FEMA’s contracting
activity issued a Disaster Contracting Desk Guide that it uses internally to
supplement the emergency acquisition process and ensure its contracting
staff are equipped with the necessary information to conduct its mission.
Government-wide, OFPP provides overall direction for procurement
policies, regulations, and procedures, and promotes economy, efficiency,
and effectiveness in acquisition processes. For example, OFPP issued an
Emergency Acquisitions Guide to supplement agency specific guidance
and to be used in conjunction with the FAR and the National Response
Framework. 30 The guide is intended to assist the federal contracting
community with planning and executing procurement activities during
contingency operations, major disaster declarations, or other
27FAR § 15.305(a)(2).
28Whether agencies communicate information in internal guidance will depend on the
agencies’ determination that legal requirements do not necessitate more formal
regulations.
29See FAR § 1.301(a)(2).
30Executive Office of the President, Office of Management and Budget, Office of Federal
Procurement Policy, Emergency Acquisitions Guide (January 2011).
Page 11 GAO-21-528 COVID-19 Contracting
emergencies by providing strategies for effective acquisition planning and
best practices agencies have developed in response to contracting during
natural disasters and other emergencies.
Leading Practices for Our prior work has shown that the use of lessons learned—an approach
Lessons Learned of an organizational culture committed to continuous improvement—can
increase communication and coordination. Collecting and sharing lessons
learned—both positive and negative—allows agencies to communicate
knowledge more effectively and to ensure that beneficial information is
factored into planning, processes, and activities. This approach also
provides a powerful method of sharing ideas for improving current and
future operations. Collecting lessons learned throughout the course of an
event, rather than just at the end, can help to ensure that lessons learned
are captured as close as possible to the learning opportunity. Leading
practices of a lessons learned process we and others identified include
collecting, analyzing, validating, saving or archiving, and disseminating
and sharing information and knowledge gained on positive and negative
experiences. 31
These leading practices generally build upon each other. For example, an
organization with robust data collection methods is better able to gather
enough information to effectively identify critical issues, analyze root
causes, and develop recommendations. Further, an agency with a
consistent, coordinated archiving mechanism, such as an electronic
database, is better able to demonstrate the leading practice for sharing
lessons learned through access to such an archive.
As of May 31, 2021, federal agencies obligated about $61.4 billion in
Federal Agencies response to the COVID-19 pandemic. Most obligations (88 percent or
Obligated More Than $54.0 billion) were on contracts to vendors with prior federal contracting
experience. Almost all vendors that received contract obligations in
$61 Billion on COVID- response to COVID-19 were registered in SAM at the time of award, and
19-Related Contracts less than 1 percent of total COVID-19-related contract obligations went to
vendors with documented records in FAPIIS, the repository for contractor
31GAO-21-8, GAO-20-104, GAO-19-25, and GAO-12-901. Project Management Institute,
Inc., A Guide to the Project Management Body of Knowledge (PMBOK® Guide) and
Implementing Organizational Project Management: A Practice Guide. Center for Army
Lessons Learned, Establishing a Lessons Learned Program.
Page 12 GAO-21-528 COVID-19 Contracting
performance and integrity information. Agencies cancelled or deobligated
about 6 percent of the obligations for various reasons. 32
Agencies Obligated Most As of May 31, 2021, federal agencies obligated about $61.4 billion in
COVID-19 Dollars to response to the COVID-19 pandemic. Most obligations (88 percent or
$54.0 billion) were for contracts with vendors having prior federal
Vendors with Prior Federal
contracting experience. Those vendors also accounted for 88 percent, or
Contracting Experience approximately 11,200, of the almost 12,800 vendors that received
contract awards related to COVID-19. Although most contract obligations
went to vendors with prior federal contracting experience, agencies
awarded contracts to vendors without prior federal contracting experience
at a higher percentage than they do in a typical year. In calendar year
2020, 16 percent of contracts awarded by agencies for the COVID-19
response were to vendors without prior federal contracting experience. In
contrast, in the 5 most recent calendar years, between 2.7 to 3.8 percent
of contracts were awarded to vendors without prior federal contracting
experience.
Five agencies—DOD, HHS, USDA, the Department of Veterans Affairs,
and DHS—accounted for the vast majority (89 percent) of the total
COVID-19-related contract obligations. DOD had the highest obligations,
accounting for 40 percent ($24.4 billion) of government-wide COVID-19-
related contract obligations. The obligations by the top five agencies to
vendors with prior federal contracting experience varied by agency. For
example, DOD had the highest percentage of obligations to vendors with
prior federal contracting experience, at 96 percent. USDA relied less on
vendors with prior federal contracting experience, with only 64 percent of
obligations going to such vendors. Figure 1 shows total obligations by
agency, and the proportion of obligations going to vendors with or without
prior federal contracting experience within each agency.
32A deobligation is a cancellation or reduction of previously incurred obligations.
Page 13 GAO-21-528 COVID-19 Contracting
Figure 1: COVID-19-Related Contract Obligations and Proportion of Obligations to
Vendors with Prior Federal Contracting Experience, by Federal Agency, as of May
31, 2021
Contract obligations and the extent to which agencies relied on vendors
with prior federal contracting experience also varied by the type of good
or service. Government-wide, obligations on drugs and treatments, which
include vaccines and therapeutics, were the highest of any good or
service at $14.3 billion, and 99 percent of these obligations were on
contracts to vendors with prior federal contracting experience (see fig. 2).
The percentage of obligations to vendors with prior federal contracting
experience, however, was lower for other goods or services. For
example, of the $2.4 billion obligated for laboratory testing—which
includes services related to diagnostic testing for COVID-19—48 percent
of obligations were on contracts to vendors with prior federal contracting
experience.
Page 14 GAO-21-528 COVID-19 Contracting
Figure 2: COVID-19-Related Contract Obligations and Proportion of Obligations to Vendors with Prior Federal Contracting
Experience, by Top Goods and Services, as of May 31, 2021
Agencies obligated a majority of COVID-19-related dollars to a small
number of vendors. Seventy-one percent of obligations were for contracts
awarded to 130 vendors, or 1 percent of the roughly 12,800 vendors
receiving COVID-19-related contracts government-wide. Furthermore, as
shown in figure 3, the top 10 vendors accounted for nearly one-third of
the obligations.
Page 15 GAO-21-528 COVID-19 Contracting
Figure 3: Government-wide COVID-19-Related Contract Obligations to Top 10
Vendors, as of May 31, 2021
Overall, agencies awarded contracts to over 8,100 small business
vendors—nearly double the number of vendors awarded contracts that
were not considered small businesses. 33 Small business vendors
received 25 percent of the total COVID-19 contract obligations. Table 1
shows that a majority of small business vendors received less than $1
million in contract obligations.
Table 1: COVID-19 Small Business Vendors by Obligation Range, as of May 31, 2021
Amount Obligated to Percent of Obligations to
Vendors (Obligation range Number of Small Small Business Vendors
in dollars) Business Vendors (within obligation range)
Over 1 billion 1 33
500 million-1 billion 1 10
100 million-499 million 14 14
10 million-99 million 169 30
1 million-9 million 719 47
Less than 1 milliona 7,226 65
Total 8,130 25
Source: GAO analysis of Federal Procurement Data System data. I GAO-21-528
This includes vendors obligated zero or negative dollars due to cancelled contract obligations.
a
33For the purposes of this report, a small business vendor is a vendor that was determined
to be a small business for all of its COVID-19-related contract awards.
Page 16 GAO-21-528 COVID-19 Contracting
Almost All COVID-19 Almost all contract obligations in response to COVID-19 went to vendors
Vendors Were in the registered in SAM at the time of award. Agencies have the flexibility to
award contracts to vendors that are not registered in SAM during an
Government’s Primary
emergency, among other circumstances, and 162 of the approximately
Contractor Registration 12,800 vendors receiving COVID-19-related contract obligations were not
System and Had No Prior registered at the time of award, representing about 1 percent of the total
Reports of Unsatisfactory number of vendors and of the $61 billion in total COVID-19 obligations. 34
Performance or Integrity
A small portion of COVID-19 contract obligations went to vendors with
documented records in FAPIIS, the repository for contractor performance
and integrity information. 35 Such vendors (119 in total) received about
$507 million, less than 1 percent of total COVID-19-related contract
obligations. HHS accounted for 52 percent of the $507 million, the
Department of Veterans Affairs 24 percent, DOD 12 percent, and USDA 1
percent. 36 Contracting officers must document how the information in
FAPIIS was considered when determining responsibility, and any action
taken as a result of the information.
Agencies Cancelled $4 Approximately $4 billion, or 6 percent, of the COVID-19-related contract
Billion in COVID-19- obligations were cancelled or deobligated, and these deobligations varied
depending on the agency or good and service involved. 37 In some
Related Contract
instances, agencies may modify a contract to deobligate funds to
Obligations accommodate changes in the contract requirement, or to terminate a
contract if a vendor does not fulfill the terms of the contract. For example,
34With certain exceptions—such as contracts awarded as responses to national
emergencies—vendors must be registered in SAM at the time an offer or quotation is
submitted to comply with annual representations and certifications requirements. FAR §
4.1102(a). For contracts awarded in emergency operations, the FAR provides that, if
practical, contracting officers should modify the contract or agreement to require SAM
registration. FAR § 4.1102(b).
35Documented records of unsatisfactory performance or integrity of a vendor in FAPIIS
may include one or more of the following: criminal, civil, or administrative proceedings in
connection with the award or performance of a government contract; terminations for
default or cause; determinations of nonresponsibility because the vendor does not have a
satisfactory performance record or a satisfactory record of integrity and business ethics.
36DHS accounted for 0.3 percent of obligations, which rounds to zero. Across the
agencies, HHS awarded contracts to 19 vendors with documented records of
unsatisfactory performance, the Department of Veterans Affairs to 37 vendors, DOD to 49
vendors, USDA to three vendors, and DHS to 11 vendors. Some vendors with
unsatisfactory records of performance received COVID-19 contracts from multiple
agencies.
37Agencies initially obligated $65 billion; however, $4 billion (6 percent) was cancelled.
Given this, the net amount of total obligations was $61 billion.
Page 17 GAO-21-528 COVID-19 Contracting
the federal government can partially or fully end a government contract
before the contractor completes performance by partially or fully
terminating the contract. Depending on the circumstances, the
government can terminate the contract either (1) for the convenience of
the government or (2) for cause or default. A variety of factors can lead to
the government’s decision to terminate a contract. For example, when the
government’s requirements change, rendering continued performance
unnecessary, the government may choose to terminate the contract for
convenience. On the other hand, when a contractor fails or is anticipated
to fail to perform its contractual obligations, the government may
terminate the contract for default or, in the case of commercial item
contracts, cause. DOD and HHS had the highest overall deobligations at
$1.8 billion and $938 million, respectively. See figure 4 for a comparison
of initial obligations and deobligations by agency.
Figure 4: Initial COVID-19-Related Contract Obligations and Subsequent
Deobligations, by Agency, as of May 31, 2021
Page 18 GAO-21-528 COVID-19 Contracting
Our analysis of FPDS data identified a variety of reasons for agencies’
deobligations. The majority of the approximately $4 billion in deobligations
were coded as “Other Administrative Action.” This code may be used due
to, for example, a contract being modified to change the period of
performance or decrease the requirements. Eleven percent of
deobligations were due to contract terminations, with about one-third
($144 million) of these obligations related to contracts terminated for
cause or default, and the other two-thirds ($276 million) related to
contracts terminated for convenience. For example, some of the selected
contracts we reviewed were terminated for cause after the vendor failed
to deliver contracted medical supplies, such as N95 respirators. Other
contracts we reviewed—such as contracts for ventilators or alternate care
facilities—were terminated for convenience because the government no
longer needed the good or service.
The percentage of contract deobligations varied by good or service.
Generally, deobligations among the top goods and services were below 5
percent. For example, agencies deobligated about 1 percent, or $63
million, of initial obligations on fruits and vegetables. However, agencies
deobligated about 13 percent, or $1.4 billion, of initial obligations on
medical equipment and supplies—including personal protective
equipment such as N95 respirators, isolation gowns, and medical gloves.
Government-wide there was little difference between deobligations on
contracts to vendors with prior federal contracting experience compared
to vendors without prior federal contracting experience. About $3.5 billion,
or 6 percent, of the $57.4 billion in initial obligations to vendors with prior
federal contracting experience was deobligated, compared to about $379
million, or 5 percent, of the $7.8 billion in initial obligations to vendors
without prior federal contracting experience.
Contracting officers rely on a variety of resources to assess prospective
Contracting Officers vendors. However, some agencies we reviewed did not have, or did not
Did Not Always Have communicate to contracting officials, the resources available to assess
prospective vendors during an emergency. Contracting officials we spoke
Access to or Were with identified obstacles to assessing prospective vendors during the
Not Aware of COVID-19 response. Further, available government-wide guidance
provides limited information for assessing prospective vendors in an
Resources Available emergency.
to Assess Prospective
Vendors
Page 19 GAO-21-528 COVID-19 Contracting
Contracting Officials at We found that contracting officials at agencies across our four selected
Selected Agencies Used a departments used a variety of resources to assess prospective vendors
for our selected 28 contracts. These resources included government
Variety of Resources to
databases, private sector resources, assistance from other federal
Assess Prospective agencies, specific resources created by agencies in response to COVID-
Vendors 19, and information identified by the contracting officers based on their
own knowledge and experience. Figure 5 details examples of the
resources that contracting officers responsible for our selected contracts
said they used.
Page 20 GAO-21-528 COVID-19 Contracting
Figure 5: Examples of Resources Used by Contracting Officers to Assess Prospective Vendors for COVID-19-Related
Contracts
Page 21 GAO-21-528 COVID-19 Contracting
Overall, the number of contracting officers that used each of these
resources across the contracts we selected varied. Table 2 provides
details on how many of the 28 contracts leveraged each resource.
Table 2: Resources that Contracting Officials Identified Using to Assess Prospective Vendors Across Selected Contracts
Contracting officers used a variety of resources to assess prospective vendors across the seven contracts we selected at each agency.
Department Department of Health U.S. Department Department of
of Defense and Human Services of Agriculture Homeland Security
Resource (DOD) (HHS) (USDA) (DHS)
Government databases
System for Award Management (prospective 7 6 7 7
vendor business information)
Contractor Performance Assessment 6 4 7 5
Reporting System (past performance
information)
Federal Awardee Performance and Integrity 7 5d 7 7
Information System (past performance and
integrity information)
Supplier Performance Risk System (supplier 2 N/A N/A N/A
and product assessments)a
Private sector information
Dun and Bradstreet (financial strength 3 2 2 3
information)
Third party contractor (additional information 0 2 0 0
for vendor assessments)
Assistance from other federal agencies
Defense Contract Management Agency 2 0 0 1
(pre-award surveys)
Defense Contract Audit Agency (pre-award 3 0 0 0
audit services)
Other resources
Internet searches 0 4 0 1
Product photosb 0 0 0 2
Lot numbersb 0 1 0 0
Other resourcesc 1 2 0 1
Source: GAO analysis of selected contract files and interviews with contracting officials. | GAO-21-528
a
The Supplier Performance Risk System is a DOD specific system, and therefore not applicable to
contracts not awarded by DOD contracting officers.
b
Product photos and lot numbers are not applicable to contracts for services.
Other resources include support provided by the Defense Assisted Acquisition Cell and the White
c
House.
d
HHS officials were unable to locate documents to confirm whether they reviewed information in the
Federal Awardee Performance and Integrity Information System for two of the selected contracts.
Page 22 GAO-21-528 COVID-19 Contracting
DOD and FEMA Have and Both DOD and FEMA have resources available to contracting officers to
Are Making Contracting assist them in assessing prospective vendors. We found that contracting
officers responsible for the DOD contracts we reviewed used resources
Officers Aware of
the department had in place. We found limitations in the communication
Resources for Assessing of available resources at FEMA; however, it is currently taking steps to
Prospective Vendors update its guidance to better communicate the availability of these
resources.
DOD Contracting Officers In relation to the seven contracts we reviewed at DOD, officials at DLA
Used Agency-Specific and the Department of the Army leveraged guidance and resources
Guidance to Assess developed to support contracting officers’ efforts to assess prospective
Prospective Vendors vendors. For example:
• DLA: DLA’s Defense Logistics Acquisition Directive instructs
contracting officials to review the Defense Contractor Review List,
which helps identify and communicate contractor performance,
capability, and integrity issues for making a responsibility
determination. The list contains treatment codes with recommended
actions that contracting officials can take to mitigate risks. For
example, the list includes codes that identify whether the contracting
officer should consider requesting a pre-award survey for the vendor,
whether the vendor has experienced financial difficulties that could
jeopardize its ability to complete the contract, or whether the
contracting official should request additional performance history
information. 38 Contracting officers responsible for all three of the DLA
COVID-19-related contracts we selected used the Defense Contractor
Review List in their determinations of vendor responsibility, which
some DLA contracting officials said allowed them to access notes and
information from other DLA contracting officers’ experiences working
with a vendor.
• Army: In December 2019, the Department of the Army released
guidance mandating use of the Contractor Responsibility
Determination Bot. The bot is an automated tool that streamlines the
process to collect responsibility information from government sources,
including SAM and FAPIIS, allowing contracting officials to focus on
making responsibility determinations more quickly and accurately by
collecting relevant information into a memorandum that can be
supplemented with additional vendor information. According to
guidance issued by the Deputy Assistant Secretary of the Army for
Procurement, the tool is intended to reduce the amount of time
38Pre-award surveys can be used to evaluate a prospective contractor’s capability,
experience, and performance history.
Page 23 GAO-21-528 COVID-19 Contracting
needed to make a responsibility determination, which is particularly
important since contracting officers told us they operated under
expedited time frames during the COVID-19 response. For the three
Army contracts in our sample where use of the tool was required,
contracting officials indicated they did so, allowing them to streamline
the collection of required information to determine vendor
responsibility. 39
Additionally, USACE released further guidance and tools to assist
contracting officers in assessing prospective vendors for their COVID-
19 alternate care facility missions. Specifically, based on work
performed for these missions early in the pandemic, USACE
developed a standardized set of 10 questions to include in
solicitations to help provide contracting officers across USACE
districts with key information to assess prospective vendors’ abilities.
USACE contracting officials we spoke with said that using the
previously developed and approved solicitation questions allowed
them to award contracts faster.
DHS Is in the Process of Better DHS and FEMA have developed several resources to assist contracting
Communicating Its Resources officers in assessing prospective vendors. For example:
to Assess Prospective Vendors
• Following Hurricanes Harvey, Irma, and Maria in 2017—which
occurred nearly back-to-back and affected nearly 47 million people or
15 percent of the U.S. population—FEMA developed a disaster
contract verification tool. The tool is a checklist to ensure contracting
officers complete contracting steps, including documenting elements
of responsibility, like satisfactory record of business ethics and
integrity, and ability to comply with proposed delivery or performance
schedules.
• In March 2020, FEMA also began requiring the use of a contractor
assurance statement for prospective vendors to attest to their
capabilities to perform a contract.
• In addition to FEMA’s efforts, when the pandemic started, DHS
Strategic Program Division officials explained that they vetted
thousands of vendors offering goods and services, like personal
protective equipment or other medical supplies, through interviews
39For one of the three Army contracts in our sample, the contracting officer told us that
they used the tool. However, the contracting officer has since left, and the agency was
unable to provide supporting documentation. The fourth Army contract in our sample was
awarded prior to the issuance of the December 2019 guidance requiring use of the tool for
all Army contracts.
Page 24 GAO-21-528 COVID-19 Contracting
using a vendor vetting questionnaire. FEMA contracting officers also
used the questionnaire to assess prospective vendors’ capabilities.
• DHS developed a job aid to assist in responsibility determinations in
November 2020. The job aid states that the responsibility
determination is a first line of defense in determining whether a
vendor can successfully meet the terms of a contract, and notes that
this determination is especially important when a contracting officer is
awarding a contract to a vendor that has no record of successful past
performance or relevant prior experience. The aid identifies specific
considerations for contracting officers related to responsibility factors
identified in the FAR, and examples of additional evidence to request
or collect if concerns arise when assessing a prospective vendor
against those factors.
However, we found inconsistencies in how FEMA contracting officers
used some resources for assessing prospective vendors. For example,
contracting officials were instructed—by email and acquisition alert,
respectively—to use the disaster contract verification tool and insert the
contractor assurance statement in solicitations and contracts. Yet based
on our review of the contract files and interviews with the responsible
contracting officers, none of the officials responsible for the six selected
contracts required to leverage the verification tool did so, and only three
of six contracts in our sample contained the contractor assurance
statement, as required. 40
Based in part on our earlier findings following the 2017 hurricanes and
wildfires, FEMA’s contracting activity is taking steps to better
communicate the resources available to contracting officers. 41
Specifically, FEMA contracting activity officials said that, as of May 2021,
40One of the selected contracts was awarded in 2017, prior to the development of the
disaster contract verification tool and contractor assurance statement. FEMA issued task
orders under this contract during the response to COVID-19.
41Our prior work found that FEMA lacked an updated strategy and guidance on its use of
advance contracts. We recommended that FEMA update the strategy identified in its 2007
Advance Contracting of Goods and Services Report to Congress to clearly define the
objectives of advance contracts, how they contribute to FEMA’s disaster response
operations, and whether and how they should be prioritized in relation to new post-
disaster contract awards. We also recommended that FEMA update its Disaster
Contracting Desk Guide to include guidance for whether and under what circumstances
contracting officers should consider using advance contracts prior to making new post-
disaster contract awards. FEMA agreed with our recommendations and identified the
development of a FEMA Acquisition Manual as a mechanism to communicate FEMA-
specific acquisition policies and processes to contracting personnel. FEMA has since
taken other actions to address these recommendations. See GAO-19-93.
Page 25 GAO-21-528 COVID-19 Contracting
they are finalizing the FEMA Acquisition Manual, which will consolidate
guidance and resources for contracting officers at the agency. Officials
told us that the manual will include guidance for contracting officers to use
the contractor assurance statement and the disaster contract verification
tool, and that they are reviewing the agency’s Disaster Contracting Desk
Guide to ensure consistency on the use of these resources.
Contracting Officers at Contracting officials we spoke with at HHS’s ASPR identified challenges
HHS Did Not Always Have with the time frames for awarding contracts and with working with new
vendors in response to COVID-19. However, based on our review of
Access to or Awareness of
seven selected contracts, we identified limitations in the resources
Resources Available to available to ASPR contracting officials for assessing prospective vendors
Assess Prospective during the COVID-19 emergency and how information about those
Vendors resources was communicated to contracting officers. Standards for
Internal Control in the Federal Government state that management
should use and internally communicate the necessary quality information
to achieve the entity’s objectives. 42
We found that several contracting officers responsible for the contracts
we reviewed either did not have access to or were not aware of resources
that could have been used to assess prospective vendors awarded
contracts in response to COVID-19. For example, contracting officials
responsible for three of our seven selected contracts told us that they did
not think they had access to Dun and Bradstreet credit reports. 43 Some of
these contracting officials said that access to this service would have
helped them to more thoroughly assess prospective vendors during their
COVID-19 response efforts. 44
Additionally, ASPR contracting officers were not always aware of
available resources to help them assess financial capability. For example,
a senior ASPR contracting official stated that ASPR has an audit
evaluation team that contracting officers can use to conduct reviews of a
prospective vendor’s accounting system and financial capabilities.
42GAO-14-704G.
43Dun and Bradstreet is a company that provides information on vendors’ financial
strength, among other things.
44A contracting officer within HHS’s Biomedical Advanced Research and Development
Authority (BARDA), which is housed within ASPR, stated that BARDA contracting officers
may request Dun and Bradstreet reports for specific contracts, but that these are
purchased on an ad hoc basis using purchase cards.
Page 26 GAO-21-528 COVID-19 Contracting
However, contracting officers responsible for four of the seven contracts
we selected were not aware of the types of assistance available from this
team. Moreover, contracting officials responsible for one of our selected
contracts determined that a prospective contractor had “necessary
capacity and credit” to perform the contract, but could not cite any
resources they used to assess whether the prospective vendor had
adequate financial resources to perform the contract. 45
Senior acquisition officials at ASPR told us that the resources available to
contracting officers to determine responsibility were adequate, but that
the agency had not reviewed the resources available to contracting
officers to assess whether other resources could be useful. Yet as noted
earlier, there was uncertainty among ASPR’s contracting officers about
what resources were available to them to assess prospective vendors,
and the circumstances under which they should be used. These same
senior ASPR officials added that they were not certain whether Dun and
Bradstreet was still in use at federal agencies, and said the information
available through Dun and Bradstreet was also available through
SAM.gov. In fact, however, contracting officers at all of the other agencies
we reviewed are using or requesting Dun and Bradstreet information as a
resource to help them assess prospective vendors’ financial capabilities,
supplementing the information that vendors report in SAM.gov.
Further, a senior ASPR acquisition official noted that the audit evaluation
team’s services are not typically needed for contracts awarded through
the Strategic National Stockpile. Officials told us that this is because
stockpile officials are generally working with contractors with whom HHS
has historically worked. However, ASPR, which has responsibility for the
stockpile, accounted for about half, or $1.4 billion, of HHS’s contract
obligations for the COVID-19 response that went to vendors without prior
federal contracting experience, and contracting officials associated with
several of our selected contracts noted they were working with certain
vendors for the first time. Without reviewing the resources that are
available to contracting officers to assess prospective vendors to
determine whether they are adequate and fully communicating the
availability of such resources, ASPR increases the risk that its contracting
45Ultimately, the contract was terminated for cause after the vendor was unable to meet
the required delivery schedule. We did not analyze whether there was any relationship
between the contracting officer’s determination regarding the contractor’s “necessary
capacity and credit” and the termination.
Page 27 GAO-21-528 COVID-19 Contracting
staff will not have access to adequate resources to comprehensively
assess prospective vendors during future emergencies.
In addition to lacking access to or awareness of resources to assess
prospective vendors, several ASPR contracting officers we spoke with
said they also did not have any ASPR-specific guidance or training they
could leverage when assessing prospective vendors in an emergency.
Contracting officers associated with two of our selected contracts noted
the lack of ASPR-specific guidance as a challenge during the response.
Moreover, contracting officers associated with several of our selected
contracts said they relied on their experiences or guidance from working
with other agencies—such as FEMA and the Centers for Disease Control
and Prevention—to assess prospective vendors during the response to
COVID-19.
Our prior work on the COVID-19 response effort has identified similar
contracting issues related to ASPR’s training and guidance for the use of
Defense Production Act authorities—which can allow agencies to mitigate
supply chain issues during an emergency. In November 2020, we
reported that HHS planned to issue additional training and guidance on
using Defense Production Act authorities to priority rate contracts, and
that only three of 20 contracting officers had prior experience using the
authority. 46 These challenges were also noted in a 2019 after-action
report HHS conducted following an emergency exercise on the nation’s
ability to respond to a large-scale outbreak of a novel virus. Further, in
July 2021 we reported that ASPR did not have documented policies and
procedures, including control and monitoring activities, related to its direct
shipment procurement process. 47
While ASPR has some acquisition guidance in place related to, for
example, unsolicited proposals and ratification of unauthorized
commitments, a majority of the policies ASPR officials identified as
relevant to their emergency acquisition practices are still being developed
46GAO-21-108.
47GAO-21-551. ASPR used the direct shipment procurement process in response to
COVID-19 to expedite delivery of medical supplies during the pandemic by allowing
vendors to directly ship supplies to state, local, and territorial governments rather than
shipping supplies directly to replenish the Strategic National Stockpile. We recommended
that the Assistant Secretary for Preparedness and Response should update the policies
and procedures, including related control and monitoring activities, for the Strategic
National Stockpile to document the direct shipment procurement process and payment
integrity risks. HHS did not concur with the recommendation.
Page 28 GAO-21-528 COVID-19 Contracting
or undergoing review. Further, while ASPR officials said they anticipate
identifying additional policies based on the response to COVID-19, ASPR
officials did not state that they plan to develop policies related to
contracting or assessing prospective vendors during emergencies. Senior
ASPR officials also noted that they did not think additional guidance
related to assessing prospective contractors was necessary because
contracting officials know what resources to look at when assessing
prospective vendors based on the FAR. However, as we found,
contracting officials were not always aware of available resources.
Moreover, we found that the Health and Human Services Acquisition
Regulation only addresses responsibility determinations as they relate to
certain procurements made by Indian Health Services. As noted earlier,
contracting officers at other agencies within DOD and DHS have
benefited from specific guidance on resources to assess prospective
vendors, particularly when awarding contracts to vendors without
successful past performance or prior relevant experience.
Standards for Internal Control in the Federal Government state that
management should identify, analyze, and respond to risks related to
achieving their objectives. 48 ASPR’s stated mission is to save lives and
protect Americans from 21st century health security threats and to lead
the nation’s medical and public health preparedness for, response to, and
recovery from disasters and public health emergencies. Without internal
guidance on practices for assessing prospective vendors, particularly
during an emergency, ASPR contracting officials are at risk of not being
aware of the information available to help them more effectively perform
their responsibilities.
USDA Developed a USDA’s AMS developed a draft responsibility checklist for emergency
Checklist to Help Assess acquisitions to assist contracting officers in assessing prospective
vendors, but does not plan to formalize or distribute it. AMS contracting
Vendors but Does Not
officials used elements of the checklist to develop the solicitation for the
Plan to Finalize It Farmers to Families Food Box Program. Specifically, a contracting officer
in AMS’s Commodity Procurement Program responsible for awards in
support of the Farmers to Families Food Box Program said the checklist
was developed for emergency acquisitions to identify information that
contracting officers should reference or request from prospective vendors
to make a responsibility determination. The contracting officer said that
incorporating elements of the checklist into the solicitation for the Farmers
to Families Food Box Program—which was the solicitation for the seven
48GAO-14-704G.
Page 29 GAO-21-528 COVID-19 Contracting
contracts we selected—ensured that vendors’ proposals would explicitly
address certain elements of responsibility.
Additionally, for purposes of evaluating the offers submitted in connection
with the Farmers to Families Food Box Program, AMS developed a step-
by-step guide and an evaluation rubric, and provided training to technical
evaluators on how to consistently assess prospective vendors for the
program. According to AMS officials, they designed these new processes
at the outset of the Farmers to Families Food Box Program to streamline
the procurement process. Further, officials told us that these processes
differed from their regular contracting activities for commodity
procurement, which typically rely on a qualified bidders list. 49
AMS officials said that they will maintain some of the tools, such as the
evaluation rubric and step-by-step guide as reference materials, but that
they do not anticipate the need to use them for future emergencies. AMS
does not plan to formalize or distribute the draft responsibility checklist
developed to assist contracting officers in assessing prospective vendors.
Officials told us that AMS is not typically involved in emergency response
activities, and said that the Farmers to Families Food Box Program was
always intended to be a temporary program to address agricultural supply
chain issues and increased joblessness during the COVID-19 response.
Given these circumstances, officials did not provide the checklist as a tool
to all AMS contracting officers, and officials said that it will not be formally
adopted by the agency.
However, the official responsible for developing the checklist also said
that the checklist was intended to help AMS award contracts during any
declared emergency or disaster, not only during the COVID-19 response.
Further, AMS officials told us they are in the process of determining next
steps for future food distribution efforts following the additional $4 billion
in funding for pandemic response USDA received as part of the American
Rescue Plan Act of 2021 for purchasing and distributing food to
individuals in need. 50
49The FAR defines a qualified bidders list as a list of bidders who have had their products
examined and tested and who have satisfied all applicable qualification requirements for
that product or have otherwise satisfied all applicable qualification requirements. FAR §
9.201.
50American Rescue Plan Act of 2021, Pub. L. No. 117-2, § 1001, 135 Stat. 4.
Page 30 GAO-21-528 COVID-19 Contracting
Departmental guidance—such as the USDA contracting desk guide—
addresses procedures for reporting determinations of non-responsibility
but does not contain information to assist contracting officers in assessing
prospective vendors. Additionally, AMS officials said they do not have any
other regulations or guidance for contracting during emergencies.
According to a 2018 workforce analysis, AMS’s Commodity Procurement
Program previously identified the need to better align contracting
processes across its branches, but staffing shortages and changes
limited its efforts to do so. 51
Standards for Internal Control in the Federal Government state that
management should identify, analyze, and respond to risks related to
achieving its objectives and should internally communicate necessary
quality information, which would include contracting tools and guidance. 52
Although AMS is not typically involved in emergency response activities,
not identifying and incorporating relevant contracting practices used to
procure more than $6 billion worth of food into guidance puts the agency
at risk of losing the knowledge it has gained assessing vendors during an
emergency, particularly as it considers future food distribution efforts.
Government-wide OFPP’s Emergency Acquisitions Guide outlines a number of
Emergency Acquisition management and operational best practices that agencies should
consider when contracting during emergencies, but provides limited
Guidance Provides
information on resources and practices agencies can use to assess
Limited Information on prospective vendors prior to contract award. 53 In the course of our review,
Resources for Assessing contracting officials identified obstacles to assessing prospective vendors
Prospective Vendors during an emergency. Specifically, contracting officials cited urgent time
frames and working with new vendors as factors that challenged their
51GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic Enters Its Second
Year, GAO-21-387 (Washington, D.C.: Mar. 31, 2021). In GAO-21-387, we identified
challenges reporting contract obligations and managing contract documentation
associated with USDA’s Farmers to Families Food Box Program. We recommended,
among other things, that the Administrator of AMS assess the contracting personnel
needed to fully execute the award and administration of contracts in support of the
Farmers to Families Food Box Program or successor future food distribution program, and
take the necessary steps to ensure it has adequate contracting staff in place to award and
administer any future contracts for the program. USDA neither agreed nor disagreed with
our recommendation.
52GAO-14-704G.
53The OFFP guide is intended to supplement, not supplant, agency-specific guidance and
the FAR. It is to be read in conjunction with parts 18 and 26 of the FAR, which address
emergency acquisitions and other socioeconomic programs, respectively, and the
National Response Framework documents published by FEMA.
Page 31 GAO-21-528 COVID-19 Contracting
efforts to assess prospective vendors and that sometimes resulted in
changes from their regular contracting processes. For example:
• Urgent time frames: AMS contracting officials told us that they had to
operate under expedited time frames to award contracts, and that
processes to assess vendors, such as determining responsibility and
evaluating proposals, were sometimes conducted concurrently during
the COVID-19 response rather than sequentially. Similarly,
contracting officials at FEMA and ASPR said that under normal
circumstances they would contact a prospective vendor’s references
to verify its performance information. However, officials said that they
were unable to take this step because of the expedited time frames
they were operating under during the COVID-19 response.
• Working with new vendors: A contracting officer from FEMA
described challenges obtaining information on vendors providing
goods or services during an emergency that differed significantly from
the vendors’ regular line of business. For example, the contracting
officer noted this was the case when searching for information on a
vendor that regularly provided furniture but began offering personal
protective equipment at the beginning of the pandemic. Regarding the
contract we selected, the contracting officer told us that given the
market conditions for personal protective equipment at the beginning
of the pandemic, they obtained the prospective vendor’s business
credit report—which the contracting officer said is not typical for
procuring a commercial item or low dollar value contracts—to mitigate
potential risks.
As previously mentioned, some agencies developed practices or
resources to help address these obstacles, such as the Army’s Contractor
Responsibility Determination Bot and DHS’s job aid for making
responsibility determinations. Further, throughout the pandemic, OFPP
officials explained that they maintained two websites—one publicly
accessible and another strictly for government personnel—to convey
COVID-19 acquisition related information, resources, and guidance.
OFPP’s Emergency Acquisitions Guide also offers a number of resources
and practices for agencies to consider during pre-emergency planning
and in contract management and oversight during an emergency. These
include identifying the products and services the agency required in
previous emergencies, anticipating workforce needs before an
emergency arises, adjusting internal processes to ensure flexibility during
an emergency, and assessing emergency acquisitions following an
emergency.
Page 32 GAO-21-528 COVID-19 Contracting
However, the OFPP guide does not include the practices or resources
contracting officers can use to address obstacles they said they
experienced related to assessing prospective vendors during COVID-19
or other recent emergencies. Specifically, the guide reiterates FAR
requirements that contracts may only be awarded to responsible vendors
and that such requirements are not waived during an emergency, but
provides no additional guidance or best practices related to addressing
potential obstacles contracting officers may encounter when assessing
prospective vendors during an emergency. Furthermore, as previously
discussed, not all agencies had or communicated resources available to
contracting officers to assess prospective vendors during COVID-19, and
some agencies that were involved in contracting for the COVID-19
response have not typically been involved in contracting in response to
other recent disasters and emergencies, particularly AMS and ASPR.
Further, the Emergency Acquisitions Guide has not been updated since
2011, and, as of June 2021, several resources linked in the guide are no
longer active or accessible. For example, the guide references a
community of practice for emergency response—established by the Chief
Acquisition Officers Council Emergency Response and Recovery Working
Group—intended for agencies to share information about their policies
and procedures, best practices, training resources, and other information
of interest. However, OFPP staff told us the group is no longer
operational. OFPP officials also stated that updates to the guide are
driven by periodic discussions with senior procurement executives and by
the rate of inquiries OFPP receives regarding emergency acquisitions,
rather than on a regular schedule.
Our prior work following the 2017 hurricanes also identified other
limitations in the available government-wide guidance on emergency
acquisitions. In April 2019, we found that agencies experienced difficulty
in determining whether a vendor resides or primarily does business in the
local set-aside area after a disaster and recommended that OFPP provide
clarifying information regarding contracting with local vendors after a
disaster. 54 In May 2021, OFPP staff told us they plan to update the
Emergency Acquisitions Guide to provide such clarifying information, but
stated they could not provide a time frame for when the guide would be
updated.
54GAO-19-281.
Page 33 GAO-21-528 COVID-19 Contracting
The intent of the Emergency Acquisitions Guide is to assist with planning
and carrying out procurement activities during contingency operations,
major disaster declarations, or other emergencies. Standards for Internal
Control in the Federal Government state that management should use
and externally communicate quality information that is current and
accurate to achieve the entity’s objectives on a timely basis. 55 The
Emergency Acquisitions Guide does not account for obstacles contracting
officers said they face when performing their responsibilities during an
emergency, or more recent positive practices and resources that
individual agencies have developed to address them. Without updating
the Emergency Acquisitions Guide—including information on the
resources and practices available to contracting officers to assess
prospective vendors during an emergency—OFPP may miss the
opportunity to provide agencies the information they need to mitigate the
types of obstacles they faced during COVID-19 and other recent
emergencies. Moreover, the lack of a regular process for updating the
Emergency Acquisitions Guide leaves agencies, including those not
typically involved in emergency response, without knowledge of the most
current information on resources and practices they can use to mitigate
obstacles during future emergencies.
Contracting officials from across our selected agencies identified a
Agencies Identified number of challenges and positive practices with contracting in response
Contracting to COVID-19. While the agencies in our review are collecting and sharing
lessons learned related to COVID-19, we identified shortfalls in these
Challenges and efforts, such as not including contracting personnel and contracting
Positive Practices, observations in lessons learned processes at some selected agencies
and government-wide.
but Shortfalls Exist in
Lessons Learned
Processes
Agencies Identified Contracting officials we spoke with in relation to the 28 contracts we
Challenges and Positive reviewed identified a number of contracting challenges and positive
practices that they experienced during the response to COVID-19. For
Practices Related to
example, contracting officials at DOD, HHS, and DHS said that the
Contracting Response to response to COVID-19 was unprecedented, and, as previously
COVID-19 discussed, contracting officials at the agencies in our review stated that
the limited time frames and urgency with which they had to assess
55GAO-14-704G.
Page 34 GAO-21-528 COVID-19 Contracting
prospective vendors and award contracts presented challenges. Table 3
describes challenges contracting officials identified across selected
agencies, and the outcomes contracting officials associated with those
challenges.
Table 3: Challenges and Outcomes Identified by Contracting Officials at the Departments of Defense (DOD), Health and
Human Services (HHS), Agriculture (USDA) and Homeland Security (DHS)
DOD
(DLA and HHS’s USDA’s
Challenges Army) ASPR AMS DHS’s FEMA Examples of Outcomes Highlighted by Officials
Lack of contracting - X X - ASPR officials said that as a result of limited contracting
personnel in personnel, ASPR had to contract for support functions,
relation to volume like compiling contract file documentation. ASPR
of contract awards officials also said they relied heavily on interagency
agreements with DOD and FEMA to procure goods and
services and address contracting workforce shortfalls.
Working with X X X X DLA officials said that they often had to explain the
vendors new to federal contracting process—such as System for Award
federal contracting Management requirements or payment terms—when
or vendors working with vendors that did not have prior federal
supplying products experience, which can add time to the contracting
they had not process. A FEMA contracting official noted that one of
supplied before the biggest challenges was determining whether
vendors new to federal contracting or supplying a
product for the first time were responsible and able to
meet the delivery or performance terms of the contract.
Volume of X X X X FEMA officials said that the volume of prospective
communication vendor communication they received was overwhelming
from prospective and that contracting officials needed to work overtime to
vendors review vendor information, and in some cases it still
delayed contract award.
Limited time X X X X An AMS official said the speed with which contracts for
frames and the Farmers to Families Food Box Program were
urgency to make awarded and the sheer volume of awards affected
contract awards contracting officials’ ability to ensure accurate contract
reporting and the compilation of complete contract
files.a
Supply chain X X - X According to DLA and ASPR officials, supply chain
issues challenges related to the availability of supplies and raw
materials and having to ship goods and materials from
abroad led to delays in delivery and the ability to receive
contracted goods.
Contracting for X X - X FEMA officials said they did not have expertise
supplies and contracting for medical supplies, so were unfamiliar with
services the some vendors and technical requirements for things like
agency does not N95 respirators or gowns. As a result, officials said they
typically buy relied heavily on technical expertise from DOD and
HHS to determine whether vendor proposals met
certain requirements.
Page 35 GAO-21-528 COVID-19 Contracting
DOD
(DLA and HHS’s USDA’s
Challenges Army) ASPR AMS DHS’s FEMA Examples of Outcomes Highlighted by Officials
Differing sources of X X - X ASPR officials identified challenges receiving contract
contract requirements from other agencies or the White House.
requirements (e.g., For one selected contract, ASPR officials said that
other agencies, following changes in a White House requirement to
White House) deliver cloth masks to U.S. households, approximately
40 million masks are currently in storage at the
Strategic National Stockpile or other locations. For two
other selected contracts, ASPR contracting officials said
that due to challenges with interagency communication
about the number of ventilators needed for a contract,
they ultimately had to partially terminate one of the
contracts because not all of the ventilators ordered were
needed.
Legend:
DLA = Defense Logistics Agency
Army = Department of the Army
ASPR = Office of the Assistant Secretary for Preparedness and Response
AMS = Agricultural Marketing Service
FEMA = Federal Emergency Management Agency
X = challenge identified by agency contracting officials
- = challenge not identified by agency contracting officials
Source: GAO summary of DLA, Army, ASPR, AMS, and FEMA information. I GAO-21-528
a
In March 2021, we reported that USDA faced data reporting and contract management challenges
for its Farmers to Families Food Box Program. We recommended that USDA issue guidance to
contracting officials on the use of the National Interest Action code for the Farmers to Families Food
Box Program and assess the contracting personnel needed to fully execute the award and
administration of existing contracts in support of the program or a successor food distribution
program. USDA neither agreed nor disagreed with our recommendation. See GAO, COVID-19:
Sustained Federal Action Is Crucial as Pandemic Enters Its Second Year, GAO-21-387 (Washington,
D.C.: Mar. 31, 2021).
Officials also identified positive contracting practices that were
established in response to COVID-19 or that assisted them in their ability
to effectively respond during the pandemic.
• Mechanisms to consolidate vendor communication: Officials at
DLA and USACE said they benefitted from their agencies establishing
mechanisms to consolidate vendor communication about availability
of goods and services. For example, officials at both agencies said
they used centralized inboxes for vendors to communicate available
goods and services. In some instances, these agencies “pre-vetted’
vendors by asking for additional information on product availability,
delivery terms, and pricing, before forwarding this information to
contracting officials. According to USACE contracting officials, this
vendor information was put into a repository that was accessible to
Page 36 GAO-21-528 COVID-19 Contracting
their 43 districts, and having a list of available vendors helped them
when performing market research.
• Pre-existing contract vehicles: Officials at DLA, USACE, ASPR,
and FEMA were able to leverage some contracts that were awarded
prior to the pandemic, which officials said allowed them to provide
needed goods and services quicker. For example, following Hurricane
Katrina in 2005, FEMA was required to establish advance contracts
for goods and services typically needed following a disaster. 56 While
FEMA’s advance contracts are not specific to medical equipment and
supplies, FEMA officials were able to leverage an advance contract
for ambulance services during the response to COVID-19. The
contracting officer associated with this contract said using the
advance contract allowed the acquisition process to be streamlined, in
part because the contractor was already vetted and familiar with the
contract requirement and FEMA’s processes. Similarly, following the
H1N1 pandemic, the Biomedical Advanced Research and
Development Authority (BARDA), within ASPR, awarded contracts to
establish Centers for Innovation in Advanced Development and
Manufacturing to support vaccine and other medical countermeasure
manufacturing needs in support of future pandemics. 57 BARDA
officials said that being able to leverage the already-established
Centers allowed them to be responsive to COVID-19 vaccination
needs during the pandemic. 58
56Pub. L. No. 109-295, § 691 (codified at 6 U.S.C. § 791). We previously reported on
challenges FEMA has faced using, managing, and coordinating advance contracts. See
GAO-19-93.
57We previously reported on BARDA’s efforts to establish Centers for Innovation in
Advanced Development and Manufacturing. See GAO, National Preparedness: HHS Has
Funded Flexible Manufacturing Activities for Medical Countermeasures, but It Is Too Soon
to Assess Their Effect, GAO-14-329 (Washington, D.C.: Mar. 31, 2014).
58However, BARDA officials noted that limited funding for the Centers for Advanced
Development and Manufacturing following the H1N1 pandemic posed challenges.
Specifically, officials said that the Centers—operated by Texas A&M University Systems
(which is one of our selected contracts) and Emergent Biosolutions (which was not one of
our selected contracts)—faced staffing challenges due to limited funding that required
them to quickly hire staff to support COVID-19 vaccine production. Recent Food and Drug
Administration inspections at Emergent Biosolutions facilities responsible for COVID-19
vaccine production identified concerns related to cross-contamination of vaccine
materials, the sanitation, size, and design of the facility, and staff adherence to process
and production control procedures.
Page 37 GAO-21-528 COVID-19 Contracting
Agencies Are Collecting Agencies across the four selected departments in our review—DOD,
and Sharing COVID-19 HHS, USDA, and DHS—had in place or developed processes to collect
and share lessons learned related to COVID-19, and these processes are
Lessons Learned, but
ongoing or at various stages of completion. However, the lessons learned
Some Agencies Have Not processes at HHS and DHS have not included contracting personnel or
Included Contracting contracting observations.
Issues
• DOD: Within the Army and DLA, efforts to collect and share lessons
learned in response to COVID-19 have been ongoing. For example, in
addition to an “in-stride” review—completed while the alternate care
facility mission was still ongoing in May 2020—USACE headquarters
compiled a final after-action report on its COVID-19 response and
alternate care facility mission in August 2020, which included after-
action reports from across the districts and divisions. According to
DLA officials, they collected acquisition lessons learned internally and
completed a review of selected COVID-19 contracts to identify
additional contracting lessons learned in May 2021.
In addition to these component specific efforts, in December 2020,
DOD’s COVID-19 Task Force completed a strategic review of the
department’s response to COVID-19. 59 According to task force
officials, they collected and analyzed over 2,000 observations from
across the department, including reviewing component specific after-
action reports, based on the department’s existing guidance for the
Chairman of the Joint Chiefs of Staff Joint Lessons Learned
Program. 60 This analysis culminated in 84 recommendations related
to DOD’s organization, people, mission, and support to national and
international response efforts. According to DOD officials, these
recommendations have been archived and shared over the Joint
Lessons Learned Information System. DOD COVID-19 Task Force
officials said they are still analyzing and validating lessons learned
through the development of implementation and action plans for the
recommendations, which they expect to complete in July 2021. DOD
has also continued to gather observations to identify lessons learned
as part of a Comprehensive Review focused on its COVID-19
59DOD, Strategic Review: The Department of Defense Response to the COVID-19
Pandemic (December 2020). DOD’s Strategic Review also included observations from
other federal agencies on the actions DOD took in response to COVID-19, but the review
states it was not intended to provide a detailed examination of the actions taken by the
department’s interagency partners in their response efforts.
60DOD, Chairman of the Joint Chiefs of Staff Instruction 3150.25G, Joint Lessons Learned
Program (Jan. 31, 2018).
Page 38 GAO-21-528 COVID-19 Contracting
response efforts through April 2021, which it anticipates completing in
the fall of 2021.
• HHS: According to ASPR Exercise, Evaluation and After Actions
(E2A2) officials, they are in the process of collecting data on the
response to COVID-19 because the pandemic response is ongoing.
The E2A2 division’s lessons learned process uses after-action reports
and a Corrective Action Program, aligned with DHS’s Homeland
Security Exercise and Evaluation Program, to collect, analyze, and
report on observations following real world public health emergencies
or exercises. To further improve HHS’s ability to provide health and
medical resources, corrective actions from real world public health
emergencies and exercises generally become objectives in future
training and exercises. E2A2 officials said that during and after a real
world event or exercise, they send email surveys to all HHS personnel
requesting input, and perform “hotwashes” with stakeholders to gather
observations before consolidating the information based on trends
and creating an after-action report. 61 Following the completion of the
after-action report, observations and recommendations are resolved
through the development of corrective actions that are then prioritized
and tracked.
• USDA: AMS officials told us they do not have a formal process to
collect lessons learned related to the Farmers to Families Food Box
Program. However, USDA did conduct a preliminary review of its
COVID-19-related commodity purchasing and distribution in January
2021, prior to issuing any new solicitations for the Farmers to Families
Food Box Program, as required by the Consolidated Appropriations
Act, 2021 (P.L. 116-260). The preliminary review identified
observations and lessons learned from throughout the program and
noted that USDA had been collecting, analyzing, and addressing input
on the program from participants, Congress, and the general public,
as the program progressed. According to the preliminary review,
USDA will analyze and apply lessons learned from the program to
improve future commodity procurement efforts. Further, in April 2021,
AMS officials told us that they have continued to collect input from
both internal and external stakeholders and are working with a
contractor to consolidate all of the input received and determine next
steps with USDA leadership.
61A “hotwash” is a facilitated discussion held immediately after an exercise or real world
event among the individuals involved. It captures feedback about any issues, concerns, or
proposed improvements that the individuals may have about the exercise or event.
Page 39 GAO-21-528 COVID-19 Contracting
• DHS: FEMA’s Continuous Improvement Program is responsible for
collecting observations and conducting after-action reviews following
a disaster. In the summer and fall of 2020, the Program provided
preliminary briefings to FEMA leadership on selected after-action
report focus areas. In January 2021, the Continuous Improvement
Program completed its Initial Assessment Report of FEMA’s COVID-
19 Operations from January 2020 through September 2020. 62 FEMA
conducted its assessment by gathering data from across the agency
using interviews, surveys, and “hotwashes,” and analyzing and
validating findings. The initial assessment included 32 findings and 57
recommendations related to coordinating structures and policy;
resources; supporting state, local, tribal, and territorial governments;
preparedness and information analysis; and organizational resilience.
According to FEMA Continuous Improvement Program officials, these
observations have been entered into the issue resolution system for
tracking and shared in a database available to all FEMA employees.
DOD’s and USDA AMS’s lessons learned processes in response to
COVID-19 have included contracting officials and their observations, but
HHS ASPR’s and DHS FEMA’s formal lessons learned processes have
not, posing the risk that contracting challenges and positive practices will
not be appropriately analyzed, validated, archived, and shared to inform
future efforts.
• DOD: Both USACE and DLA have captured contracting lessons
learned related to their COVID-19 response missions. USACE’s “in-
stride” and final after-action report from its alternate care facility
mission included contracting lessons learned, such as developing and
communicating sample documents and templates, establishing lists of
emergency contractors, and promoting internal and external
communication. Following a review of contracts awarded in response
to COVID-19, in May 2021, DLA reported on contracting lessons
learned, such as establishing a group of contingency contracting
officers able to support future emergency response efforts, and
continuing to use a team that was established to assess prospective
vendors. More broadly, as part of DOD’s Strategic Review, DOD
COVID-19 Task Force officials said they included input from
contracting officials as part of their data collection efforts, and we
found that the review highlights findings and recommendations related
to DOD’s establishment of the Joint Acquisition Task Force and
extensive acquisition support to other agencies, like HHS. According
62FEMA, Pandemic Response to Coronavirus Disease 2019 (COVID-19): Initial
Assessment Report, FEMA Operations January through September 2020 (January 2021).
Page 40 GAO-21-528 COVID-19 Contracting
to a DOD COVID-19 Task Force official, contracting lessons learned
continue to be gathered as part of the department’s Comprehensive
Review.
• USDA: While less formal, AMS has also collected internal and
external feedback on the program, and identified and applied
contracting lessons learned to achieve the program’s goals
throughout the Farmers to Families Food Box Program. For example,
based on information collected following initial awards made for the
program, AMS streamlined its contracting process by using basic
ordering agreements, which officials said provided AMS with greater
flexibility to specify requirements as the program progressed. 63
Further, under the basic ordering agreement solicitation, AMS refined
requirements related to the content and quantities of boxes to be
delivered, and required additional documentation related to
subcontractor agreements to ensure that vendors were fully
accounting for the costs of delivering food boxes to their final
destination instead of a distribution center.
• HHS: ASPR’s E2A2 division is still in the process of formally collecting
lessons learned from the response to COVID-19, but in February
2021, officials told us they do not plan to include contracting officials
or lessons learned in their efforts. ASPR contracting officials we spoke
with identified challenges and lessons learned from the response to
COVID-19, and, for most of the contracts in our review, contracting
officials said they had communicated these challenges and lessons
learned informally to their branch leadership or to the ASPR Head of
Contracting Activity. According to senior ASPR contracting officials,
there have been informal discussions about challenges and lessons
learned in response to COVID-19 during monthly meetings with
contracting leadership, and these lessons learned have been
communicated to the Office of Acquisitions—which is responsible for
providing departmental leadership for acquisition functions within the
Office of the Assistant Secretary for Financial Resources. In February
2021, the Office of Acquisitions compiled preliminary contracting
lessons learned from ASPR and other HHS component contracting
activities. As of April 2021, contracting officials within ASPR and the
Office of Acquisitions said they were determining next steps related to
implementing the lessons learned they had identified. However, these
officials said that they had not received any communication from
E2A2 officials about sharing contracting lessons learned or provided
63For subsequent contract awards under the Farmers to Families Food Box Program,
AMS officials established basic ordering agreements with vendors, which then competed
amongst themselves to fulfill specific requirements for the program.
Page 41 GAO-21-528 COVID-19 Contracting
lessons learned through the email surveys E2A2 sends to solicit
feedback. Several ASPR contracting officials we spoke with during
our review emphasized the importance of collecting contracting
lessons learned.
According to E2A2 officials, contracting has not been identified as a
shortfall or priority for reporting by HHS leadership, and E2A2 has not
received contracting input. However, we found that preliminary
contracting lessons learned identified by the Office of Acquisitions and
ASPR contracting officials are related to the topics E2A2 identified for
inclusion in its planned after-action reports. For example, ASPR
contracting officials told us that they did not have to award new
contracts to support the mission to repatriate U.S. citizens from
abroad early in the response to COVID-19 because they already had
pre-existing contracts in place to provide all of the necessary services
and medical support. Further, the Office of Acquisitions identified
cross-agency contracting collaboration and confusion about agencies’
responsibilities acquiring goods and services to protect the public
against COVID-19. That office recommended establishing
memorandums of understanding with other agencies involved in the
response. E2A2 officials said they are issuing an after-action report
focused on the repatriation mission and plan to issue an after-action
report on interagency coordination, but contracting practices and
lessons learned related to these areas have not been provided or
included. 64
• DHS: While FEMA’s Continuous Improvement Program has a formal
process for collecting, analyzing, validating, and archiving lessons
learned, its initial assessment on the response to COVID-19 does not
include contracting lessons. According to an official within FEMA’s
contracting activity, FEMA established community of practice listening
sessions in April 2020 to promote training and educational
opportunities and identify challenges and best practices for knowledge
sharing. The official stated that these listening sessions are intended
to inform the topics covered in the annual disaster webinar that they
provide to contracting officials. However, as of April 2021, senior
64We previously reported that ASPR has not obtained input from key stakeholders—
specifically other emergency support function agencies and territorial governments—as
part of its after-action reporting following the 2017 hurricanes. We recommended that
ASPR take steps to ensure that key external parties are incorporated in the development
of HHS’s after action reports. HHS officials agreed with the recommendation and as of
May 2021, HHS’s efforts to incorporate key external parties in after-action reports were
ongoing. See GAO, Disaster Response: HHS Should Address Deficiencies Highlighted by
Recent Hurricanes in the U.S. Virgin Islands and Puerto Rico, GAO-19-592 (Washington,
D.C.: Sept. 20, 2019).
Page 42 GAO-21-528 COVID-19 Contracting
FEMA procurement officials told us they had not collected challenges
or lessons learned from contracting officials. Further, officials with five
of the seven contracts we reviewed said they had not communicated
their lessons learned within the agency, and our review of the lessons
learned identified in FEMA’s May 2021 annual disaster webinar were
specific to their regional offices and not FEMA headquarters
contracting personnel.
An official from FEMA’s Continuous Improvement Program said they
interviewed FEMA’s Head of Contracting Activity and Deputy Head of
Contracting Activity as part of their initial assessment on the response
to COVID-19. The Continuous Improvement Program official said
contracting was not a priority issue at that time, and procurement
challenges and lessons learned did not align with broader themes
identified in their data collection efforts and so were not included in
their reporting. However, some of the challenges and positive
practices FEMA contracting officials identified to us are related to
findings in FEMA’s initial assessment. For example, FEMA contracting
officials noted that having DOD support the technical evaluation of
vendor proposals for medical supplies was helpful, since FEMA does
not have expertise purchasing medical supplies. FEMA contracting
officials also described significant challenges managing vendor
communication about available goods and services and contracting in
an environment where the availability of medical supplies was limited.
FEMA’s initial assessment on its response to COVID-19 includes
findings related to interagency coordination structures, scarcity of
medical supplies, and consistency of private sector engagement, but
these findings did not include specific perspectives from contracting
officials on their challenges and best practices.
Leading practices of a lessons learned process we and others have
identified include collecting, analyzing, validating, archiving, and sharing
information and knowledge on positive and negative experiences. 65
Further, The Standard for Program Management, produced by the
Program Management Institute, Inc., states that program managers
should actively engage key stakeholders throughout the life cycle of the
program, which would include contracting officials responsible for
awarding contracts worth billions of dollars for needed goods and
65GAO-21-8, GAO-20-104, GAO-19-25, and GAO-12-901. Project Management Institute,
Inc., A Guide to the Project Management Body of Knowledge (PMBOK® Guide) and
Implementing Organizational Project Management: A Practice Guide. Center for Army
Lessons Learned, Establishing a Lessons Learned Program.
Page 43 GAO-21-528 COVID-19 Contracting
services to respond to the pandemic. 66 The response to COVID-19 has
been unprecedented and differed from other disasters and emergencies,
as it affected the entire country and world rather than just one state or
region. In addition, the response to the pandemic is currently in its second
year, compared to typical emergency response efforts that can often be
measured in weeks. Without taking steps to collect, analyze, and validate
contracting lessons learned more than a year into the response, ASPR
and FEMA—agencies that account for 20 percent of the $61 billion in
contract obligations made in response to COVID-19—are at risk of not
being able to apply and share critical contracting lessons learned related
to the pandemic that could inform ongoing and future emergency
response efforts.
Contracting Officials Were Contracting officials we spoke with identified extensive interagency
Not Always Aware of or coordination related to contracting during the response to pandemic, but
they were not always aware of or involved in interagency lessons learned
Involved in Collecting or
processes. For example, as noted earlier, HHS established
Sharing Interagency memorandums of understanding with DOD and FEMA for those agencies
Lessons Learned to provide contracting services and support for the acquisition of medical
supplies and services. ASPR officials noted that these memorandums of
understanding were essential because they did not have sufficient
contracting workforce to meet their steady state mission, let alone the
response to COVID-19. FEMA and DOD contracting officials also noted
that they relied on technical support and expertise from various HHS
components, particularly when awarding contracts for medical supplies
and services that they do not typically purchase.
Moreover, according to contracting officials, 20 of the 21 contracts in our
review awarded by DLA, the Department of the Army, FEMA, and ASPR
involved interagency coordination related to the development of the
requirement, assessment of prospective vendors, or contract
administration efforts. 67 Figure 6 provides examples of the variety of
government entities that were involved in identifying requirements,
providing information in support of or performing vendor assessments, or
contract administration efforts for these selected contracts.
66Program Management Institute, Inc. The Standard for Program Management, Fourth
Edition (2017).
67The other seven contracts we selected for review were from USDA. Given the nature of
those contracts, which were for food distribution efforts under the Farmers to Families
Food Box Program, AMS officials said these contracts did not involve interagency
coordination.
Page 44 GAO-21-528 COVID-19 Contracting
Figure 6: Examples of Interagency Contracting Coordination across Selected Contracts
Note: Lines from selected agency contracts to various government entities indicate those entities
involvement in identifying contract requirements, providing information in support of or performing
vendor assessments related to the contract, or contract administration efforts.
Page 45 GAO-21-528 COVID-19 Contracting
Although interagency coordination has been critical to the response,
contracting officials we spoke with at DOD, HHS, and DHS were not
consistently aware of or involved in formal interagency lessons learned
collection or reporting. Officials at DOD, HHS, and DHS identified some
methods for communicating interagency lessons learned internally. For
example, DOD’s USACE officials said that in coordination with HHS, they
identified areas to improve or sustain related to their alternate care facility
mission, which included contracting. According to DLA officials, they have
coordinated with the Defense Threat Reduction Agency, other DOD
entities, FEMA, and HHS to capture lessons learned and best practices,
including those related to contracting, from the COVID-19 response as
part of an Interagency Lessons Learned Task Force. However, senior
contracting officials at ASPR, FEMA, and USACE said they were not
aware of and had not participated in this or any other formal efforts to
capture contracting lessons learned across the three agencies.
Further, agency officials responsible for gathering and reporting on
lessons learned told us they have been focusing on their own agency
lessons learned instead of coordinating with other agencies to identify
interagency lessons learned. For example, while both FEMA’s and DOD’s
after-action reports included challenges related to interagency
coordination, both reports state that they are focused on the actions of
their respective agencies versus collecting interagency lessons learned.
During the course of our review, FEMA Continuous Improvement
Program officials told us they have not shared information on challenges,
positive practices, or lessons learned with other agencies, beyond some
informal communication with officials within ASPR. 68 A FEMA Continuous
Improvement Program official further noted that there is no policy
identifying responsibilities for conducting interagency after-action reports.
E2A2 division officials within HHS told us that information sharing among
agencies has been a challenge, and that, while there had been some
informal interagency coordination among FEMA and DOD, none of the
agencies want to tell the others what did not go well.
According to a DOD COVID-19 Task Force official, the Homeland
Preparedness Response Interagency Policy Committee—which replaced
the Domestic Resilience Group Interagency Policy Committee on the
National Security Council—is expected to lead efforts for a government-
68Towards the end of our review, a FEMA Continuous Improvement Program official
stated that FEMA’s initial assessment report is publicly available for other agencies to
review.
Page 46 GAO-21-528 COVID-19 Contracting
wide COVID-19 after-action report. 69 As of April 2021, the Task Force
official said that group’s charter was still being finalized, and the Exercise
and Evaluation sub-Interagency Policy Committee that would lead such
an effort has not yet been established. According to an HHS E2A2 official,
DOD, HHS, and DHS are represented on this sub-Interagency Policy
Committee, and it would be an appropriate interagency body for
identifying and sharing lessons learned in any response.
Further, interagency lessons learned may also be collected by the
Emergency Support Function Leadership Group—a body of senior
officials from each of the emergency support functions tasked with
coordinating responsibilities and resolving operational and preparedness
issues related to interagency response activities. However, according to
officials, as of April 2021, no corrective actions or lessons learned for
COVID-19 contracting, or more broadly, had been identified. Emergency
Support Function Leadership Group officials said that they rely on federal
agencies that lead the Emergency Support Functions to identify corrective
actions and that, while contracting lessons learned may be identified at
some point, there are currently no efforts underway to take action on
agency after-action recommendations because the response to COVID-
19 is ongoing. 70
Leading practices of a lessons learned process we and others have
identified include collecting, analyzing, validating, archiving, and sharing
information and knowledge on positive and negative experiences. 71 The
Center for Army Lessons Learned handbook on Establishing a Lessons
69The National Security Council’s Domestic Resilience Group was a policy group charged
with discussing the authorities, policies, capabilities, and structures in place for a domestic
response.
70Our prior work found that some emergency support function agencies—such as USACE
and the Coast Guard—did not have formal processes to solicit and share input from
officials involved in emergency response efforts to the Emergency Support Functions
Leadership Group. We recommended that USACE and the Coast Guard establish formal
processes to solicit input from officials involved in the agency’s response and recovery
efforts, and share that input with the Emergency Support Function Leadership Group.
Both agencies agreed with the recommendations, and in July 2020, USACE revised its
Response to All Hazards Events Plan with steps to communicate lessons learned
following a disaster to the group. As of April 2021, the Coast Guard’s efforts to update its
After-Action Report Policy were still ongoing. GAO-19-281.
71GAO-21-8, GAO-20-104, GAO-19-25, and GAO-12-901. Project Management Institute,
Inc., A Guide to the Project Management Body of Knowledge (PMBOK® Guide) and
Implementing Organizational Project Management: A Practice Guide. Center for Army
Lessons Learned, Establishing a Lessons Learned Program.
Page 47 GAO-21-528 COVID-19 Contracting
Learned Program—which is intended to assist any government or civilian
organization that wants to develop a lessons learned capability—notes
that performing lessons learned practices throughout the course of an
event, rather than just at the end, can help to ensure that lessons learned
are captured as close to the learning opportunity as possible. 72 Further,
key practices to enhance and sustain collaboration state that, in order for
agencies to identify areas where collaboration could improve, they need
to monitor, evaluate, and report the results of collaborative efforts—such
as those related to interagency contracting during an emergency—to key
decision makers. 73 Without efforts to ensure that key agencies involved in
the response to COVID-19 are collecting and sharing interagency
contracting lessons learned, federal agencies involved in the response
are at risk of missing an opportunity to memorialize contracting and
coordination practices that were successful, as well as those that were
not, for future emergencies.
Federal contracts played a critical role in meeting the unprecedented
Conclusions demand for billions of dollars in goods and services in response to
COVID-19. Contracting during an emergency can pose a unique set of
challenges as officials face a significant amount of pressure to provide
goods and services as quickly as possible under difficult market
conditions. To help contracting officers perform assessments of
prospective vendors under these conditions during COVID-19, some
agencies used or developed resources or guidance to supplement what is
required by federal regulation. However, reviewing and communicating
available resources for assessing prospective vendors and providing
additional guidance for contracting during emergencies could improve
ASPR contracting officers’ ability to perform their responsibilities under
tight time frames during ongoing and future emergencies. Additionally,
identifying and incorporating relevant contracting experiences from its
response to COVID-19 could improve AMS’s food distribution efforts now
and in the future. Further, updating OFPP’s government-wide guidance to
reflect the resources agencies have relied on to mitigate obstacles of
assessing prospective vendors in recent emergencies, and establishing a
process for regular updates to the guidance, will ensure that all federal
agencies can benefit from these practices during future emergency
response efforts.
72Center for Army Lessons Learned, Establishing a Lessons Learned Program.
73GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain
Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
Page 48 GAO-21-528 COVID-19 Contracting
In addition to improvements in communicating resources and guidance
for assessing prospective vendors, agencies’ experiences contracting in
response to COVID-19 provide an important opportunity to capture and
share lessons learned. Agencies identified a number of challenges and
positive practices when contracting in response to COVID-19, but without
established mechanisms to formally collect and share lessons learned
from stakeholders involved with contracting at ASPR and FEMA, these
agencies will be unable to apply lessons learned and positive processes
to their ongoing pandemic response or future emergencies. Moreover,
given the significant role that interagency contracting and coordination
played in agencies’ efforts to procure needed goods and services,
effective coordination and communication among key emergency support
function agencies is critical to ensure that interagency contracting lessons
learned are memorialized in a timely manner.
We are making a total of 10 recommendations, including four to HHS, one
Recommendations for to USDA, one to FEMA, two to OFPP, one to DOD, and one to DHS.
Executive Action
The Secretary of Health and Human Services should direct the Assistant
Secretary for Preparedness and Response to review and fully
communicate the resources available to contracting officers for assessing
prospective vendors—including resources to assess financial capability.
(Recommendation 1)
The Secretary of Health and Human Services should direct the Assistant
Secretary for Preparedness and Response to develop internal guidance
that includes information for contracting officers related to contracting and
assessing prospective vendors during emergencies. (Recommendation 2)
The Secretary of Agriculture should direct the Administrator of the
Agricultural Marketing Service to evaluate the contracting practices
established to assess vendors and implement the Farmers to Families
Food Box Program to determine what practices could be used for future
emergency procurements and incorporate those practices into internal
guidance. (Recommendation 3)
The Administrator of the Office of Federal Procurement Policy should
revise the Emergency Acquisitions Guide, based on outreach to agencies
involved in the COVID-19 response, to account for information on the
obstacles contracting officers may face when assessing prospective
vendors during an emergency and key practices or resources to address
those obstacles, and communicate those revisions to agencies once
complete. (Recommendation 4)
Page 49 GAO-21-528 COVID-19 Contracting
The Administrator of the Office of Federal Procurement Policy should
establish a process and time frames for regularly updating the Emergency
Acquisitions Guide to ensure resources and practices federal agencies
can use when contracting during an emergency are current.
(Recommendation 5)
The Secretary of Health and Human Services should ensure that, as part
of the Exercise, Evaluation and After Actions Division’s ongoing after-
action reporting and corrective action program, contracting lessons
learned in response to COVID-19 and future emergency response efforts
are collected, analyzed, validated, archived, and shared to inform HHS’s
contracting efforts in response to ongoing and future emergencies.
(Recommendation 6)
The Administrator of the Federal Emergency Management Agency should
direct the Head of Contracting Activity to establish a formal process to (1)
collect contracting lessons learned from COVID-19 and future emergency
response efforts; and (2) ensure contracting lessons learned are shared
with the Continuous Improvement Program for inclusion in FEMA’s formal
lessons learned process to inform FEMA’s contracting efforts in response
to ongoing and future emergencies. (Recommendation 7)
The Secretary of Defense, in coordination with the Secretaries of
Homeland Security and Health and Human Services, should ensure that
input from contracting officials on interagency contracting lessons learned
in response to COVID-19 is collected and shared as part of government-
wide efforts to collect, analyze, and report on lessons learned.
(Recommendation 8)
The Secretary of Health and Human Services, in coordination with the
Secretaries of Defense and Homeland Security, should ensure that input
from contracting officials on interagency contracting lessons learned in
response to COVID-19 is collected and shared as part of government-
wide efforts to collect, analyze, and report on lessons learned.
(Recommendation 9)
The Secretary of Homeland Security, in coordination with the Secretaries
of Defense and Health and Human Services, should ensure that input
from contracting officials on interagency contracting lessons learned in
response to COVID-19 is collected and shared as part of government-
wide efforts to collect, analyze, and report on lessons learned.
(Recommendation 10)
Page 50 GAO-21-528 COVID-19 Contracting
We provided a draft of this report to DOD, HHS, USDA, the Department
Agency Comments of Veterans Affairs, DHS, and the Office of Management and Budget
(OMB) for review and comment. DOD, HHS, and DHS provided written
comments, which are reproduced in appendices II, III, and IV, and USDA
and OMB responded via email. Collectively, the agencies concurred with
9 of the 10 recommendations. DHS also provided technical comments,
which we incorporated as appropriate. DOD, HHS, USDA, OMB, and the
Department of Veterans Affairs had no technical comments on the draft
report.
DOD, HHS, DHS, and USDA concurred with the recommendations made
to each of their agencies and generally identified steps they plan to take
to address them. In its concurrence with our seventh recommendation,
FEMA requested that we consider the recommendation resolved and
close as implemented based on actions it had previously taken. In DHS’s
written comments, FEMA cited actions, such as interviews with FEMA’s
Head and Deputy Head of Contracting Activity and other efforts by FEMA
to identify challenges and promote knowledge sharing through listening
sessions. These efforts are, in general, already referenced in our report.
Furthermore, we found that contracting officials involved with most of the
FEMA contracts in our review had not communicated their lessons
learned related to contracting during COVID-19 within the agency.
Moreover, several of the contracting officials we spoke with said they
were not aware of any efforts to collect lessons learned and had not been
asked to provide any, raising concerns about the efficacy of FEMA’s
Office of the Chief Component Procurement Officer’s cited efforts.
Therefore, we encourage FEMA’s Head of Contracting Activity to take
additional action to address the recommendation. Doing so will ensure
that contracting lessons learned from COVID-19 and future emergencies
are effectively captured and available to be shared as part of more formal
lessons learned processes conducted by the Continuous Improvement
Program.
In its response, OMB agreed with our fourth recommendation to update
the Emergency Acquisitions Guide to account for information on the
obstacles contracting officers may face when assessing prospective
vendors during an emergency and key practices or resources to address
those obstacles. OMB did not agree with our fifth recommendation, that
OFPP establish a process and time frames for regularly updating the
Emergency Acquisitions Guide to ensure resources and practices that
can be used during an emergency are current. OMB stated that after it
revises the guide in response to, among other things, our fourth
recommendation, it plans to confer with other federal agencies about the
Page 51 GAO-21-528 COVID-19 Contracting
best way to collect and share information. OMB said it does not want to
assume that maintaining information in the current format of the
Emergency Acquisitions Guide is the most effective form of
communication. We continue to believe that establishing a process and
time frames for updating the resources and practices available in the
Emergency Acquisitions Guide—a tool agencies can use when
contracting during emergencies—will ensure that federal agencies
(particularly those not typically involved in emergency response activities)
have the most up to date information to assist them. As noted in our
findings, the guide and the resources it contains have not been updated
since 2011, precluding agencies from the benefit of the experiences and
practices other federal agencies have encountered in the numerous
disasters and emergencies since then.
We are sending copies of this report to the appropriate congressional
committees and offices; and the Secretaries of Defense, Health and
Human Services, Agriculture, Veterans Affairs, and Homeland Security,
and the Acting Director of OMB. In addition, the report will be made
available at no charge on the GAO website at http://www.gao.gov.
If you or your staff have any questions concerning this report, please
contact me at (202) 512-4841. Contact points for our offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. Staff members making key contributions to this report are
listed in appendix V.
Marie A. Mak
Director, Contracting and National Security Acquisitions
Page 52 GAO-21-528 COVID-19 Contracting
List of Addressees
The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Rosa L. DeLauro
Chairwoman
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives
Page 53 GAO-21-528 COVID-19 Contracting
The Honorable Bennie G. Thompson
Chair
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives
The Honorable Richard E. Neal
Chair
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives
The Honorable Chris Pappas
Chairman
Subcommittee on Oversight and Investigations
Committee on Veterans’ Affairs
House of Representatives
Page 54 GAO-21-528 COVID-19 Contracting
Appendix I: Objectives, Scope, and
Appendix I: Objectives, Scope, and
Methodology
Methodology
The CARES Act included a provision for GAO to provide a
comprehensive audit and review of federal contracting pursuant to
authorities provided in the act. 1 This report examines (1) contract
obligations and characteristics of vendors; (2) the information selected
agencies used to assess prospective vendors and the extent to which the
agencies communicated available information to contracting officers; and
(3) the extent to which selected agencies experienced challenges and
established processes to collect and share contracting lessons learned.
To identify contract obligations and the characteristics of vendors, we
analyzed data available in the Federal Procurement Data System (FPDS)
as of May 31, 2021. 2 Though agencies may obligate dollars through
various other vehicles, such as grants or cooperative agreements, this
report is focused specifically on contract obligations. 3 We primarily
identified these contract actions and associated obligations related to the
Coronavirus Disease 2019 (COVID-19) response by using the National
Interest Action code. 4 We supplemented the use of the National Interest
Action code by searching for “coronavirus” and “COVID-19” in the
contract description field to identify a limited number of additional contract
1Pub. L. No. 116-136, div. B, tit. IX, § 19010, 134 Stat. 281, 579 (2020). We regularly
issue government-wide reports on the federal response to COVID-19. For the latest
report, see GAO, COVID-19: Continued Attention Needed to Improve Federal
Preparedness, Response, and Service Delivery and Enhance Program Integrity,
GAO-21-551 (Washington, D.C.: July 19, 2021). Our next government-wide report will be
issued in October 2021 and will be available on GAO’s website at
https://www.gao.gov/coronavirus.
2We accessed FPDS data available on SAM.gov as of May 31, 2021. SAM.gov is the new
System for Award Management and can perform functions of other federal government
systems including FPDS.
3For the purposes of this report, “contract obligations” means obligations on contracts that
are subject to the Federal Acquisition Regulation, and does not include, for example,
grants, cooperative agreements, loans, other transactions for research, real property
leases, or requisitions from federal stock.
4National Interest Action codes were established in 2005 after Hurricane Katrina with the
purpose of tracking federal procurements for specific disasters, emergencies, or
contingency events. A National Interest Action code was established on March 13, 2020
for the COVID-19 pandemic, and contract actions and their associated obligations are
coded as related to the COVID-19 response in a field in FPDS.
Page 55 GAO-21-528 COVID-19 Contracting
Appendix I: Objectives, Scope, and
Methodology
actions and associated obligations. 5 Some contract actions identified as
being related to COVID-19 based on the National Interest Action code
included obligations not specific to the pandemic. 6 Therefore, for contract
actions over $1 million, we removed obligations that were identified in the
contract description as not related to COVID-19. We assessed the
reliability of FPDS data by reviewing existing information about the FPDS
system and the data it collects—specifically, the data dictionary and data
validation rules—and performing electronic testing. We determined the
FPDS data were sufficiently reliable for the purposes of describing
agencies’ reported contract obligations to vendors in response to COVID-
19.
We analyzed the FPDS data to identify the agencies with the highest
COVID-19 contract obligations, the types of goods and services procured,
and other vendor characteristics such as whether a vendor had prior
federal contracting experience—defined in terms of whether a vendor had
any contract awards in the last 15 years—and whether the vendor was a
small or large business. We also reviewed descriptions of contract
modifications to identify cancelled obligations, or deobligations, such as
for contract terminations. We used data from FPDS from calendar years
2005 through 2019 to evaluate the frequency agencies have historically
awarded contracts to first time federal contractors in calendar years 2016
through 2020, compared to the contracts awarded in response to COVID-
19. We augmented data from FPDS with data from the System for Award
Management (SAM) to identify additional information about vendors
receiving COVID-19 contracts, including whether or not vendors were
registered in SAM. We also used data from the Federal Awardee
Performance and Integrity Information System (FAPIIS) to identify
vendors that had a performance or integrity information record in FAPIIS
for prior performance or integrity concerns. We assessed the reliability of
5In November 2019, we identified some inconsistencies in the information agencies report
in the contract description field in FPDS. See GAO, DATA Act: Quality of Data
Submissions Has Improved but Further Action Is Needed to Disclose Known Data
Limitations, GAO-20-75 (Washington, D.C.: Nov. 8, 2019). Data on DOD contract
obligations based on information in the description field were available only through March
1, 2021, due to differences in the time frames for which DOD data are made publicly
available.
6According to the Office of Management and Budget, any contract action affected by
COVID-19 is to be reported using the National Interest Action code, including
modifications that were issued to address COVID-19, irrespective of whether the contract
being modified was originally awarded to address COVID-19. See Office of Management
and Budget, M-20-21 Implementation Guidance for Supplemental Funding Provided in
Response to the Coronavirus Disease 2019 (COVID-19) (Apr. 10, 2020).
Page 56 GAO-21-528 COVID-19 Contracting
Appendix I: Objectives, Scope, and
Methodology
SAM data by reviewing existing information about the data contained in
the system—specifically, the SAM user guide—and performing electronic
testing. We also assessed the reliability of FAPIIS data by performing
electronic testing. We determined that both SAM and FAPIIS data were
sufficiently reliable for the purposes of describing vendor registration
status and prior records of unsatisfactory performance.
To determine what information selected agencies used to assess
prospective vendors awarded contracts in response to COVID-19, we
identified four of the top five departments with the highest COVID-19
contract obligations as of August 31, 2020—the Departments of Defense
(DOD), Health and Human Services (HHS), Agriculture (USDA), and
Homeland Security (DHS). 7 Within these departments, we selected the
agencies that collectively accounted for at least two-thirds of each
department’s COVID-19 contract obligations:
• DOD’s Defense Logistics Agency (DLA) and the Department of the
Army;
• HHS’s Office of the Assistant Secretary for Preparedness and
Response (ASPR);
• USDA’s Agricultural Marketing Service (AMS); and
• DHS’s Federal Emergency Management Agency (FEMA).
We initially selected a nongeneralizable sample of eight COVID-19-
related contracts and task or delivery orders with obligations or
deobligations over $5 million (hereafter referred to as contracts, unless
otherwise specified) per department, for a total of 32 contracts awarded
between January 2020 and August 31, 2020. To obtain a mix of vendor
and contract characteristics, we judgmentally selected five contracts from
each department based on factors such as obligation or deobligation
amount, whether the vendor had prior federal contracting experience,
whether the vendor was registered in SAM.gov when the contract was
awarded, whether the contract was competed, and the vendor’s business
size. After making those selections, we selected three other contracts
from each department randomly. Subsequent to these selections, we
7We selected August 31, 2020 as it was the time we were beginning and scoping our
review. The other agency with the highest contract obligations was the Department of
Veterans Affairs, which we did not include due to other ongoing work on the department’s
contracting response to COVID-19. See GAO, VA COVID-19 Procurements: Pandemic
Underscores Urgent Need to Modernize Supply Chain, GAO-21-280 (Washington, D.C.:
June 15, 2021).
Page 57 GAO-21-528 COVID-19 Contracting
Appendix I: Objectives, Scope, and
Methodology
removed four contracts from our review: three because they were
potentially the subject of an ongoing Office of Inspector General or other
federal investigation; and one because it was reported as awarded in
FPDS, but agency officials told us it was never awarded. This left us with
a total of 28 contracts—seven from each department. 8 See table 4 for
additional details on the selected contracts included in our review.
Table 4: Description of Selected Contracts
Vendor had prior
Obligation Amount federal contracting
Awarding Agency Description as of August 31, 2020 experience
Department of Defense
Defense Logistics Agency Services for operations, maintenance, $147,595,011 X
and repairs of N95 respirator
decontamination system
Defense Logistics Agency Personal protective equipment $862,751,155 X
Defense Logistics Agency Cloth face coverings $5,372,000 X
Army Contracting Command Reservation of vaccine fill and finish $160,000,000 -
capacity
U.S. Army Corps of Engineers Construction of alternate care $8,300,000 X
facilities
U.S. Army Corps of Engineers Construction of alternate care $700,000a X
facilities
U.S. Army Corps of Engineers Construction of alternate care $13,331,415 X
facilities
Department of Health and Human Services
Assistant Secretary for Preparedness Ventilators $646,683,750b X
and Response
Assistant Secretary for Preparedness Surgical face masks $0a -
and Response
Assistant Secretary for Preparedness Cloth face masks $55,250,000 -
and Response
Assistant Secretary for Preparedness N95 respirators $31,241,700 X
and Response
Assistant Secretary for Preparedness Ventilators $31,982,100 X
and Response
Assistant Secretary for Preparedness Reservation and expansion of $264,693,063 X
and Response vaccine manufacturing capacity
8For DOD, we selected three contracts from DLA and four from the Department of the
Army. Within the Department of the Army, we selected one contract from Army
Contracting Command and three contracts from the U.S. Army Corps of Engineers.
Page 58 GAO-21-528 COVID-19 Contracting
Appendix I: Objectives, Scope, and
Methodology
Vendor had prior
Obligation Amount federal contracting
Awarding Agency Description as of August 31, 2020 experience
Assistant Secretary for Preparedness Expansion of COVID-19 test $13,000,000 X
and Response production
U.S. Department of Agriculture
Agricultural Marketing Service Fluid milk $72,898,396 X
Agricultural Marketing Service Fresh fruit and vegetable box $12,220,000 -
Agricultural Marketing Service Dairy products box, fluid milk $16,596,997 -
Agricultural Marketing Service Combination food box $147,456,691 X
Agricultural Marketing Service Fresh fruit and vegetable box $40,000,000c -
Agricultural Marketing Service Fresh fruit and vegetable box $6,916,536 -
Agricultural Marketing Service Pre-cooked meat box $22,001,720 -
Department of Homeland Security
Federal Emergency Management Reusable knit and woven gowns $543,155,000 -
Agency
Federal Emergency Management Powered air purifying respirators $96,434,000 X
Agency
Federal Emergency Management N95 and KN95 respirators and $48,799,999 -
Agency disposable masks
Federal Emergency Management N95 respirators $0a X
Agency
Federal Emergency Management Nitrile gloves and surgical masks $5,860,000 X
Agency
Federal Emergency Management National medical transport and $256,005,094 X
Agency support services
Federal Emergency Management Isolation gowns $17,243,600 X
Agency
Legend:
X = vendor identified as having prior federal contracting experience
- = vendor identified as not having prior federal contracting experience
Source: GAO analysis of selected contract files and Federal Procurement Data System data. | GAO-21-528
a
Prior to August 31, 2020, the agency deobligated most or all of the funds for this contract. For each
of these applicable contracts, the deobligations exceeded $5 million.
b
The contract was partially terminated. A determination on the type of termination is pending.
c
The contract was terminated for the government’s convenience, and, according to agency officials,
negotiations on the termination settlement are ongoing. Accordingly, the final obligation amount is
pending.
To review our selected contracts, we gathered and reviewed contract
documentation related to assessments of prospective vendors, such as
vendor proposals, responsibility determinations (where available), and
source selection evaluation reports. We also conducted semi-structured
interviews with contracting officials responsible for the 28 selected
Page 59 GAO-21-528 COVID-19 Contracting
Appendix I: Objectives, Scope, and
Methodology
contracts to discuss the resources they used to assess prospective
vendors.
To assess the extent to which selected agencies communicated the
information available to contracting officers to assess prospective
vendors, we reviewed agency, department, and government-wide
guidance and regulations related to assessing prospective vendors and
emergency acquisitions. This included the Federal Acquisition Regulation
(FAR), department and agency supplements to the FAR, agency
guidance and job aids, and the Office of Management and Budget’s
Office of Federal Procurement Policy’s (OFPP) Emergency Acquisitions
Guide. We also reviewed federal internal control standards on risk
assessment, information, and communication. 9 We interviewed
acquisition policy and contracting officials responsible for our selected
contracts to determine contracting officers’ awareness of information and
resources available to assess prospective vendors during an emergency.
We also interviewed OFPP staff to identify efforts, if any, underway to
update or revise the Emergency Acquisitions Guide.
To determine the extent to which selected agencies experienced
challenges when contracting in response to COVID-19 and established
processes to collect and share contracting lessons learned, we
interviewed DOD, HHS, USDA, and DHS contracting officials for our 28
selected contracts to identify the challenges they faced, if any, during the
response to COVID-19. We reviewed available COVID-19 after-action
reports at DOD, USDA, and DHS to identify agencies’ lessons learned
and proposed actions to address these lessons. 10 We also interviewed
contracting officials at each agency or department and officials
responsible for gathering and reporting on lessons learned to assess their
9GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: September 2014).
10HHS had not completed an after-action report at the time of our review.
Page 60 GAO-21-528 COVID-19 Contracting
Appendix I: Objectives, Scope, and
Methodology
efforts to collect and share lessons against leading practices we and
others have previously identified. 11
We conducted this performance audit from August 2020 to July 2021 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.
11GAO, Army Modernization: Army Should Improve Use of Alternative Agreements and
Approaches by Enhancing Oversight and Communication of Lessons Learned, GAO-21-8
(Washington, D.C.: Oct. 1, 2020); DOD Utilities Privatization: Improved Data Collection
and Lessons Learned Archive Could Help Reduce Time to Award Contracts, GAO-20-104
(Washington, D.C.; Apr. 2, 2020); Project Management: DOE and NNSA Should Improve
Their Lessons-Learned Process for Capital Asset Projects, GAO-19-25 (Washington,
D.C.: Dec. 21, 2018); and Federal Real Property Security: Interagency Security
Committee Should Implement a Lessons-Learned Process, GAO-12-901 (Washington,
D.C.: Sept. 10, 2012). GAO-19-25 identified some lessons learned practices from reports
by both the Project Management Institute and Department of the Army, Combined Arms
Center, Center for Army Lessons Learned. Project Management Institute, Inc., A Guide to
the Project Management Body of Knowledge (PMBOK® Guide), Sixth Edition, 2017;
Project Management Institute, Inc., Implementing Organizational Project Management: A
Practice Guide, First Edition, 2014; and Center for Army Lessons Learned, Establishing a
Lessons Learned Program: Observations, Insights, and Lessons (Fort Leavenworth, KS:
June 2011).
Page 61 GAO-21-528 COVID-19 Contracting
Appendix II: Comments from the Department
Appendix II: Comments from the Department
of Defense
of Defense
Page 62 GAO-21-528 COVID-19 Contracting
Appendix II: Comments from the Department
of Defense
Page 63 GAO-21-528 COVID-19 Contracting
Appendix III: Comments from the
Appendix III: Comments from the Department
of Health and Human Services
Department of Health and Human Services
Page 64 GAO-21-528 COVID-19 Contracting
Appendix III: Comments from the Department
of Health and Human Services
Page 65 GAO-21-528 COVID-19 Contracting
Appendix III: Comments from the Department
of Health and Human Services
Page 66 GAO-21-528 COVID-19 Contracting
Appendix IV: Comments from the
Appendix IV: Comments from the Department
of Homeland Security
Department of Homeland Security
Page 67 GAO-21-528 COVID-19 Contracting
Appendix IV: Comments from the Department
of Homeland Security
Page 68 GAO-21-528 COVID-19 Contracting
Appendix IV: Comments from the Department
of Homeland Security
Page 69 GAO-21-528 COVID-19 Contracting
Appendix IV: Comments from the Department
of Homeland Security
Page 70 GAO-21-528 COVID-19 Contracting
Appendix V: GAO Contact and Staff
Appendix V: GAO Contact and Staff
Acknowledgments
Acknowledgments
Marie A. Mak, 202-512-4841 or MakM@gao.gov
Contact
In addition to the contact named above, Janet McKelvey (Assistant
Staff Director), Meghan Perez (Analyst in Charge), Dennis Antonio, Matthew T.
Acknowledgments Crosby, Lorraine Ettaro, Betsy Gregory-Hosler, Stephanie Gustafson,
Julia Kennon, Sarah Tempel, and Robin Wilson made key contributions to
this report.
(104499)
Page 71 GAO-21-528 COVID-19 Contracting
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