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Priority review Enforcement Amended Final

Philadelphia K-12 Schools COVID-19 Testing Program Audit

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Filed February 4th, 2026
Detected February 11th, 2026
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Summary

The HHS Office of Inspector General found that Philadelphia did not consistently monitor its COVID-19 screening testing program for K-12 schools, leading to $257,620 in unallowable costs and overpayments. The OIG recommended Philadelphia update its procedures for oversight and compliance.

What changed

The HHS Office of Inspector General (OIG) issued a report (A-05-24-00003) finding that Philadelphia failed to meet all requirements for its COVID-19 screening testing program funded by the CDC through the American Rescue Plan. Specifically, Philadelphia did not consistently monitor subrecipient compliance with background check requirements and reimbursed a subrecipient $10,525 in unallowable costs and $247,095 in overpayments, totaling $257,620.

The OIG recommends that the Philadelphia Department of Public Health develop or update procedures for compliance with Federal, subrecipient, and contract requirements, including oversight of subrecipients and monitoring of contract terms. Philadelphia is also recommended to refund the $257,620 to the CDC. Philadelphia has indicated concurrence with the second recommendation and disagreement with the finding related to the first, detailing planned corrective actions. The update for these recommendations is expected by August 3, 2026.

What to do next

  1. Develop or update procedures for subrecipient oversight and contract monitoring.
  2. Ensure compliance with background check requirements for subrecipients.
  3. Address the refund of $257,620 in unallowable costs and overpayments to the CDC.

Penalties

Refund of $257,620 in unallowable costs and overpayments to the CDC.

Source document (simplified)

Philadelphia Did Not Meet All of the Requirements for the COVID-19 Screening Testing Program at K-12 Schools

Issued on

02/04/2026

| Posted on

02/05/2026

| Report number: A-05-24-00003


Report Materials

Why OIG Did This Audit

  • The Centers for Disease Control and Prevention (CDC) provided $10 billion in American Rescue Plan (ARP) funding to 64 State and local health departments to support COVID-19 screening testing for teachers, staff, and students in K-12 school settings. Philadelphia was one of the recipients awarded ARP funding to implement a COVID-19 screening testing program at K-12 schools within its jurisdiction.
  • This audit is part of a series examining the implementation of COVID-19 screening testing programs at K-12 schools. Specifically, this audit determined whether Philadelphia monitored the testing program and whether it used funds in accordance with Federal, subrecipient, and contract requirements.

What OIG Found

Philadelphia did not consistently monitor the implementation of the COVID-19 testing program; however, for the expenditures we reviewed, Philadelphia generally used the funding in accordance with requirements. Specifically:

  • We determined that Philadelphia did not monitor the subrecipient’s compliance with background check requirements.
  • Philadelphia reimbursed the subrecipient $10,525 in costs that were unallowable and $247,095 in overpayments.

What OIG Recommends

We made two recommendations to Philadelphia: that it develop or update procedures for compliance with Federal, subrecipient, and contract requirements, including: (1) oversight of subrecipients to ensure background check requirements are followed and (2) monitoring of subrecipients’ contract terms and conditions, and that it refund CDC $257,620 in costs reimbursed to the subrecipient that were unallowable or were overpayments.

Philadelphia did not indicate concurrence or nonconcurrence with our first recommendation but stated that it disagreed with the finding related to our first recommendation, concurred with our second recommendation, and detailed steps it plans to take in response to our recommendations.

Recommendation Details (2)

26-A-05-036.01 to CDC - Open Unimplemented Update expected on
08/03/2026 We recommend that the Philadelphia Department of Public Health develop or update ELC procedures for compliance with Federal, subrecipient, and contract requirements, including: oversight of subrecipients to ensure background check requirements are followed and monitoring of subrecipients' contract terms and conditions.
26-A-05-036.02 to CDC - Open Unimplemented Update expected on
08/03/2026 We recommend that the Philadelphia Department of Public Health refund CDC $257,620 for costs reimbursed to the subrecipient that were unallowable or were overpayments.
View in Recommendation Tracker Report Type Audit HHS Agencies Centers for Disease Control and Prevention Issue Areas COVID-19 Laboratories Target Groups – Financial Groups Grants

Notice

This report may be subject to section 5274 of the National Defense Authorization Act Fiscal Year 2023, 117 Pub. L. 263.

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
Various Federal Agencies
Filed
February 4th, 2026
Compliance deadline
August 3rd, 2026 (142 days)
Instrument
Enforcement
Legal weight
Non-binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Government agencies Educational institutions
Geographic scope
National (US)

Taxonomy

Primary area
Public Health
Operational domain
Compliance
Topics
COVID-19 Grants Management Auditing

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