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What VA OIG Auditors
are Looking for and Finding in Schedule Contract Audits
Presented by:
Maureen Regan
John Ames
VA Office of Inspector General
Office of Contract Review
2
Topics
Overview
of VA00 FSS Contracts
VA OIG00
Role
Types of
Reviews
Services
Schedules
Non-FSS
Areas of Involvement
FY 2006
Results
Pre-award
Process
Qui Tam
Review Process
Voluntary
Disclosure Process
Contact
Information
3
VA00
FSS Contracts
GSA delegated
medical related supplies and service FSS contracts to VA
Pharmaceuticals
Medical
& Surgical Supplies
Services
FSS contracts
awarded by Contracting Officers at the NAC, Hines, IL
4
VA00
FSS Contracts
NAC currently
manages 9 schedules
621 I Professional
Healthcare Svcs
621 II
Medical Laboratory Testing & Analysis Service
65 I B
Pharmaceuticals & Drugs
65 II A
Medical Equipment & Supplies
65 II C
Dental Equipment & Supplies
65 II F
Patient Mobility Devices
cont. on next slide00/b>
5
VA00
FSS Contracts
65 V X-Ray
Equipment & Supplies
65 VII
In-Vitro Diagnostics, Reagents, Test Kits & Test Sets
66 III
Cost-Per-Test for Clinical Laboratory Analyzers
6
OIG Role
Compliance
reviews for FSS and Public Law 102-585
Advisory
role to Contracting Officer
Participate
in educational forums
7
Types of Reviews
Pre-award
Reviews
Post-award
Reviews
Voluntary
Disclosure Reviews
Public
Law 102-585 Reviews
Qui Tam
Reviews
8
Pre-award Reviews
Verify
that CSP and other data is accurate, complete, and current
Provide
assistance and support to Contracting Officer during negotiations
Automatically
referred for pre-award
Sales
> $3 million/year ($5 M for pharmaceuticals)
9
Post-award Reviews
Verify
that CSP and other disclosures were accurate, complete, and current
Price Reductions
compliance
Industrial
Funding Fee compliance
Accurate
billing
Public
Law compliance
Initiated
by OIG, by NAC, or qui tam suit.
10
Voluntary Disclosures
Initiated
by the contractor based on an internal review
OIG looks
at each one and determines the scope of review
Full
post-award
Limited
scope review
11
Public Law 102-585
Ensures
proper calculation of non-FAMP and FCP data for covered drugs
Typically
a review of policies and procedures
Initiated
by OIG, NAC, or contractor
12
621 I and II Services
Schedules
Expect
to expand our post-award work on these schedules
Currently
reviewing contracts for potential post-award candidates
13
Non-FSS Areas of
Involvement
Direct
Delivery
Pharmaceutical
Prime Vendor
Med/Surg
Prime Vendor
Healthcare
Contracting (for scarce medical specialists)
14
FY 2006 Reports
Post-award
Reviews 51
Pre-award
Reviews 33
Other
1
Total 85
15
FY 2006 Dollars
Dollar
Recoveries $19,502,947
Recommended
Potential Contract
Savings $98,754,797
Total
$118,257,744
Voluntary Disclosures
represent $14.3 million of the $19.5 million
16
Pre-award Process
Do not
panic
Cooperation
will make the process go smoothly and quickly
Contracting
Officer first sends request to OIG
OIG sends
an announcement letter with initial data requirements
OIG conducts
data analysis
OIG issues
report to Contracting Officer
17
Pre-award Process
No monetary
impact during the pre-award process00nly on future prices00o refunds
Cooperation
and full disclosure is key and beneficial to the contractor in lowering
the risk of future defective pricing claims
18
Qui Tam Review
Process
What is
a Qui Tam Lawsuit?
Applicable
statute is False Claims Act
Source
is a relator who typically is a former employee with company
Filed in
US District Court with service on Attorney General
Decision
process00ntervene or not
We receive
very few Qui Tams.
In many
cases, relator has no specific evidence, e.g. Government did not get
best price
19
Voluntary Disclosure
Process
What do
we do?
Where do
we go?
Who do
we talk to?
20
Voluntary Disclosure
Process
Determine
the nature of the problem
Determine
if current prices are affected
Determine
the cause of the problem
Determine
the scope of the problem
21
Voluntary Disclosure
Process
Determine
the fix
Disclose
the problem to the Contracting Officer
Determine
the monetary impact of the problem and any potential refunds due to
VA
Be open
with VA and OIG during the review process
22
Contact Information
OIG Contact Information:
John
B. Ames, Director
Office
of Contract Review
801
I Street, NW, Room 1171
Washington,
DC 20001
(express mail only)
Phone: 202-565-4814
E-mail: john.ames@va.gov
Receive very few qui tam suits.
Pre-award reviews are done both at initial
award and substantive modification.
Thresholds do not prohibit a CO from
requesting a pre-award for other reasons for proposal less than thresholds.
Voluntary Disclosures are a type of post-award
review.
Since 1993 we have conducted 276 post-award
reviews, Approximately 120 of the 276 post-awards were initiated
in response to a vendor00 voluntary disclosure.
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