Office of the Inspector General
U.S. Department of Justice
OVERSIGHT ★ INTEGRITY ★ GUIDANCE

Audit of the Federal Bureau of
Prisons’ Contract Awarded to
Correct Care Solutions, LLC for the
Federal Correctional Complex in
Coleman, Florida

Audit Division 19-37

September 2019

Executive Summary
Audit of the Federal Bureau of Prisons’ Contract Awarded to Correct Care
Solutions, LLC for the Federal Correctional Complex in Coleman, Florida

Objective

Audit Results

In December 2015, the Federal Bureau of Prisons (BOP)
awarded a contract valued at about $65 million to
Correct Care Solutions, LLC (CCS) for comprehensive
medical services at the Federal Correctional Complex
located in Coleman, Florida (FCC Coleman). The
Department of Justice (DOJ) Office of the Inspector
General (OIG) conducted an audit of this contract to
assess the BOP’s award and administration of the
contract, and CCS’s performance and compliance with
the contract and related requirements.

Our audit focused on contract number
DJBP030200000070, which is an indefinite delivery
requirements contract between the BOP and CCS for
about $65 million. The contract period of performance
is January 2016 to December 2020, if all option years
are exercised.
Approval of Prices for Services Provided - The FCC
Coleman contracting officer’s representative
inadvertently approved prices billed for out-of-network
services and services not covered by Medicare pricing
without the proper authority. As a result, the BOP paid
CCS $822,888 for out-of-network services and services
not covered by Medicare pricing and $4,125 for
unauthorized cancellation fees without proper approval
of the prices.

Results in Brief
We found that the BOP did not always properly approve
contract prices, did not provide adequate oversight of
contractor performance and billings, and did not comply
with the reporting requirements of the Contractor
Performance Assessment Reporting System. We also
identified weaknesses in the BOP’s contract with CCS
related to the definition of contract requirements and
the establishment of the contract pricing methodology.
Finally, we identified instances where CCS performance
did not comply with the contract terms. As a result of
these weaknesses, the BOP paid CCS $827,013 for outof-network services and services not covered by
Medicare pricing without proper approval of the prices
billed, made improper payments to CCS totaling
$95,358, and paid Prompt Payment Act penalties
totaling about $97,089 to CCS between January 2016
and February 2019. Additionally, we identified potential
areas of improvement related to pricing the cancellation
of scheduled visits, pricing of onsite services, and
potential cost savings through the use of a secure
hospital unit and telemedicine.

Invoice Errors - CCS did not always submit properly
priced invoices for onsite optometrist and general
physician services as required by the contract. As a
result, the BOP made improper payments to CCS
totaling $95,358.
CCS did not consistently submit timely and accurate
invoices for offsite service claims. In addition, FCC
Coleman did not return CCS’s improper invoices within
7 days as required by the Prompt Payment Act.
Instead, BOP billing clerks reviewed the improper
invoices and expended additional time to research the
correct rates for services performed in the past before
correcting and approving partial invoices for payment.
The additional time required to process the improper
invoices resulted in missed deadlines under the Prompt
Payment Act and triggered penalties on payments not
made within 30 days. As a result of this practice, the
BOP paid $97,089 in penalty interest to CCS.

Recommendations

Contractor Performance - CCS did not establish a
quality control plan prior to beginning performance as
required by the contract. As a result, CCS invoices
were not always properly priced and submitted within
required timeframes. In addition, the BOP had not
established a government contract quality assurance
surveillance plan to monitor the services provided by
CCS as required. Consequently, the BOP was not able

Our report contains 13 recommendations to assist the
BOP in establishing controls to prevent and detect CCS’s
noncompliance with the terms and conditions of the
contract. The BOP agreed with all our
recommendations.

i

Executive Summary
Audit of the Federal Bureau of Prisons’ Contract Awarded to Correct Care
Solutions, LLC for the Federal Correctional Complex in Coleman, Florida

to ensure that services provided by CCS met the
contract requirements.
BOP’s Contract Award - FCC Coleman may not have
adequately defined its requirements in the contract
solicitation and could have more fully considered
proposed enhancements offered by potential contract
awardees. As a consequence, the BOP missed an
opportunity that could have resulted in significant cost
savings.
The contract provided for pricing for some services
based on sessions of 2- and 4-hour duration. However,
the contract allowed billing for the full 2- and 4-hour
sessions regardless of the time actually worked. As a
result, CCS sometimes billed and was paid for a 2-hour
session when the provider did not work the full time
identified as a session. Consequently, the BOP paid
CCS an additional $7,665 for services not provided that
could have been avoided if the contract included a
requirement to prorate the price of partial sessions.

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AUDIT OF THE FEDERAL BUREAU OF PRISONS’ CONTRACT
AWARDED TO CORRECT CARE SOLUTIONS, LLC FOR THE
FEDERAL CORRECTIONAL COMPLEX IN COLEMAN, FLORIDA
Contents
INTRODUCTION ............................................................................................. 1
Background.......................................................................................... 1
The Federal Bureau of Prisons and FCC Coleman.............................. 1
Correct Care Solutions, LLC........................................................... 2
OIG Audit Approach ..................................................................... 2
AUDIT RESULTS............................................................................................. 4
BOP Should Ensure Prices Payments are Properly Approved Before
Authorizing Payment .................................................................... 4
BOP Should Ensure that CCS Submits Timely and Accurate Invoices............ 6
CCS Used Improper Billing Rates ................................................... 6
CCS Submitted Offsite Service Claims After 90 Days ........................ 9
BOP Should Define Proper Invoices and Promptly Return Improper
Invoices .......................................................................... 10
BOP Needs to Improve its Monitoring of CCS’s Performance ..................... 11
BOP Should Review CCS’s Quality Control Plan .............................. 11
BOP Should Establish a Government Quality Assurance Surveillance
Plan for use in Verification of Services Provided .................... 12
BOP Should Implement a Formal Process for Documenting Onsite Clinic
Requests ......................................................................... 12
BOP Should Ensure Timely and Accurate Data is Entered in the
Contractor Performance Assessment Reporting System ......... 13
BOP Should Consider Modifying the Comprehensive Medical Contract at FCC
Coleman to Better Define Requirements and Pricing ....................... 14
BOP May Have Missed Cost Savings Due to Inadequate Pre-Award
Planning .......................................................................... 14
BOP’s Pricing Schedule Should Include Provisions to Prorate Payment
for Service Sessions .......................................................... 15
BOP Should Clearly Identify Payment Terms for Scheduled Visit
Cancellations.................................................................... 16
CONCLUSION AND RECOMMENDATIONS......................................................... 18

STATEMENT ON INTERNAL CONTROLS............................................................ 20
STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS.......................... 21
APPENDIX 1: OBJECTIVES, SCOPE, AND METHODOLOGY .................................. 22
APPENDIX 2: THE FEDERAL BUREAU OF PRISONS’ RESPONSE TO THE DRAFT AUDIT
REPORT ............................................................................................. 25
APPENDIX 3: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY OF
ACTIONS NECESSARY TO CLOSE THE REPORT........................................ 29

AUDIT OF THE FEDRAL BUREAU OF PRISONS’ CONTRACT
AWARDED TO CORRECT CARE SOLUTIONS, LLC FOR THE
FEDERAL CORRECTIONAL COMPLEX IN COLEMAN, FLORIDA
INTRODUCTION
The Department of Justice Office of the Inspector General has completed an
audit of the Federal Bureau of Prisons’ (BOP) contract number DJBP030200000070,
awarded on December 10, 2015, to Correct Care Solutions, LLC (CCS). The
purpose of the contract is to provide comprehensive medical services at the Federal
Correctional Complex located in Coleman, Florida (FCC Coleman). The contract is
an indefinite-delivery requirements contract for 1 base year and 4 available option
years, extending through December 2020. 1 The original estimated total value of
the contract was $65,314,394. On April 25, 2018, contract modification 10 resulted
in a revised estimated value of $84 million. As of February 2019, the BOP had
exercised the third option year and BOP payments to CCS under the contract
totaled approximately $35 million or 42 percent of the contract value.
Background
The Federal Bureau of Prisons and FCC Coleman
The BOP was established in 1930 to provide more progressive and humane
care for federal inmates, professionalize the prison service, and ensure consistent
and centralized administration. As of February 2019, the BOP was responsible for
the custody and care of 180,413 federal inmates. The BOP seeks to protect society
by confining offenders in the controlled environments of prisons and communitybased facilities that are safe, humane, cost-efficient, and appropriately secure. It
also seeks to obtain cost-effective health care consistent with community standards
by providing essential medical, dental, and mental health services for federal
inmates.
When the BOP's internal resources cannot fully meet inmates' health care
needs, the BOP awards contracts to supplement its in-house medical services.
Comprehensive medical services contracts are intended to provide necessary
professional and facility services for both inpatients and outpatients. Contracts
exceeding the Simplified Acquisition Threshold are awarded by the BOP’s Field
Acquisition Office in Grand Prairie, Texas. 2 After contract award, the Field
Acquisition Office staff provide contract administration assistance and oversight for
institution staff.
The FCC Coleman Complex is comprised of five institutions: two high
security facilities, one medium security facility, one low security facility, and one
minimum security facility. The FCC Coleman Complex Warden is responsible for
1
A requirements contract provides for filling all actual purchase requirements of designated
government activities for supplies or services during a specified contract period.
2

As of July 2019, the Simplified Acquisition Threshold is $250,000.

1

supervision of all aspects of functions within the complex. Each facility is
supervised by a Warden who is assisted by Associate Wardens. The facility
Wardens and Associate Wardens oversee multiple departments such as programs,
operations, medical, mental health, clinical programs, custody, transportation,
industries and education. As of February 2019, FCC Coleman housed 6,258 male
and 501 female inmates. FCC Coleman is a Care Level III facility on a 4-level scale
where Care Level I represents the healthiest inmates and Care Level IV represents
inmates with serious health issues.
Correct Care Solutions, LLC
CCS was founded in 2003 as a privately-owned limited-liability company with
its home office in Nashville, Tennessee. According to CCS officials, in October 2018
CCS and Correctional Medical Group Companies were acquired by an investment
fund and were rebranded as Wellpath. Those officials also said that, when the
company notified the BOP of the transaction, it stated that it would continue to
operate as CCS for all established BOP contracts. In December 2018, CCS changed
its name to Wellpath, LLC. Throughout this report we refer to CCS as the company
contracted with the BOP for comprehensive medical care. As the CCS contracts
with BOP expire, Wellpath will eventually dissolve the CCS brand. Wellpath
provides services to local jails and other detention centers, state and federal
prisons, and state psychiatric hospitals. As of February 2019, Wellpath employed
approximately 14,000 employees at 550 facilities in 37 American states and in
Australia, and it managed care for more than 270,000 patients. Wellpath provides
comprehensive healthcare services including medical, mental health, behavioral
health, dental, pharmacy, electronic medical records, off-site care management,
specialty services, and claims adjudication.
OIG Audit Approach
The objective of the audit was to assess the BOP’s award and administration
of the contract, and CCS compliance with the terms, conditions, laws, and
regulations applicable to this contract in the areas of: (1) contractor performance;
(2) billings and payments; and (3) contract management, oversight, and
monitoring. The scope of this audit, unless otherwise indicated, is the period of
contract performance from January 1, 2016, through December 31, 2017.
To determine whether the BOP adhered to federal regulations during the
contract award and administration processes, we reviewed the Federal Acquisition
Regulation (FAR) to identify compliance requirements that were relevant to the
audit objectives. We reviewed pre-award documents and contract files to
determine whether the BOP’s award process met those requirements. We reviewed
the BOP’s procurement files and monitoring reports to determine whether the BOP’s
process for contract oversight met the requirements of the FAR. We also conducted
interviews with key contract personnel from the BOP to obtain clarity regarding the
BOP’s contract award and administration processes.
To assess whether CCS complied with the terms and conditions of the
contract, we evaluated CCS’s provision of medical care and tested CCS’s billing
2

records and invoices submitted to the BOP. We also evaluated the BOP’s review of
billings and the BOP’s records of medical care provided by subcontracted providers.

3

AUDIT RESULTS
We found that the BOP did not always properly approve contract prices, did
not provide adequate oversight of contractor performance and billings, and did not
report contractor past performance information in the Contractor Performance
Assessment Reporting System (CPARS) as required by the Federal Acquisition
Regulation. 3 We identified weaknesses in the BOP’s contract with CCS related to
the definition of contract requirements and the establishment of the contract pricing
methodology. Finally, we identified instances where CCS performance did not
comply with the contract terms. As a result of these weaknesses, the BOP paid
CCS $827,013 for out-of-network services and services not covered by Medicare
pricing without proper approval of the prices billed. The BOP also made improper
payments to CCS totaling $95,358, and paid Prompt Payment Act penalty interest
totaling about $97,089 to CCS between January 2016 and February 2019. CCS
issued a credit for the improper payments but as of July 19, 2019, the BOP had not
applied the credit to its CCS bills. Additionally, we identified potential areas of
improvement related to pricing the cancellation of scheduled visits, pricing of onsite
services, and potential cost savings through the use of a secure hospital unit and
telehealth.
BOP Should Ensure Prices Payments are Properly Approved Before
Authorizing Payment
The FCC Coleman contracting officer’s representative (COR) inadvertently
approved prices billed for out-of-network services and services not covered by
Medicare pricing without the proper authority. 4 As a result, the BOP paid CCS
$822,888 for out-of-network services and services not covered by Medicare pricing,
and $4,125 for unauthorized cancellation fees without proper approval of the prices.
We discuss additional concerns with the fees paid for cancellation of scheduled
provider visits later in this report.
The contract requires that pricing be determined based on benchmarks using
Medicare reimbursement methodologies. The pricing schedule provided in the
contract is based on premiums applied to the rates for Medicare-covered services.
The contract includes CCS’s guarantee that the hospitals and physician services
delivered through its provider network will be covered by the pricing schedule. For
necessary services provided by the CCS network but not covered by Medicare rates,
the contract provides that a separate rate will be negotiated as a single-case
agreement. 5 The contract does not address a methodology for determining the
3 FAR 42.1501 and 1502 establish responsibilities for recording and maintaining contractor
performance information and require that agencies prepare evaluations of contractor performance at
least annually for each contract that exceeds the simplified acquisition threshold. The policy provides
that past performance information shall be entered into CPARS.

Out-of-network services are services provided by hospitals and physicians outside the CCS
provider network. The contracting officer representative is an individual designated and authorized in
writing by the contracting officer to assist in the technical monitoring and administration of a contract.
4

A single-case agreement is used to establish the price for out-of-network services and
services not covered by Medicare pricing provided under the contract.
5

4

pricing for out-of-network services. However, a Field Acquisition Office official told
us that institution contracting staff are trained to negotiate with contractors a
separate rate for services performed outside the contractor’s provider network.
These negotiations should form the basis for a single-case agreement. However,
during our audit period the FCC Coleman contracting officer assigned to the CCS
contract did not enter into such negotiations and instead allowed the creation of
single-case agreements approved by the COR based solely on CCS-proposed price
for each out-of-network service and service not covered by Medicare pricing.
During our audit period, the COR approved 43 single-case agreements of
which 22 were for services delivered by out-of-network providers or for services not
covered by the pricing schedule in the contract. The remaining 21 single-case
agreements were for cancelation fees, which were not provided for in the contract. 6
We reviewed each of the 43 single-case agreements, under which the BOP paid
$827,013, and found that the price for each was improperly approved by the COR.
The documentation provided by CCS for services was not sufficiently detailed for us
to assess the reasonableness of the prices absent any negotiation. Consequently,
we could not determine what part of the $827,013 would have been found to be
reasonable had the FCC Coleman contracting officer assigned to the CCS contract
properly negotiated for prices.
The COR’s improper approval of the single-case agreement prices apparently
occurred as a result of a misunderstanding of FAR requirements. FAR Subpart
15.402 requires the contracting officer to establish a fair and reasonable price for
services purchased. One of the two contracting officers assigned to the CCS
contract at FCC Coleman did not know that the FAR mandates that a contracting
officer must review and approve pricing. Consequently, the contracting officer
instructed CCS to submit single-case agreements to establish prices for out-ofnetwork services to the COR. The COR was responsible for reviewing CCS billings
and confirming whether the services were provided and funds were available to
make payment. The COR told us that after confirming receipt of services not
covered by the contract, he signed the single-case agreements but did not review
the proposed prices and apparently did not understand that his signature would be
treated as an approval of the price. The FCC Coleman contracting officers told us
that they did not approve the prices for any of the single-case agreements. In
effect, the COR approved the single-case agreements although, in accordance with
the FAR, he lacked the authority to make changes that affect price.7 The Field
Acquisition Office official and one of the FCC Coleman contracting officers agreed
that in signing the single-case agreements, the COR inadvertently made changes
that affect price without the authority to do.
The FAR and Field Acquisition Office guidance for establishing single-case
agreements reflect that the contracting officer needs to negotiate a reasonable
Later in this report we discuss our concern regarding the lack of contract provisions for
payments pertaining to cancelled services.
6

7

price.

FAR 1.602-2(d)(5) states that a COR has no authority to make any changes that affect

5

price. Accordingly, a contracting officer should have reviewed and approved all of
the single-case agreements to determine if the prices were fair and reasonable.
However, once the COR had signed the proposal, it was returned to CCS. CCS then
generated an invoice that was submitted to the FCC Coleman Business Office along
with the signed proposal. The COR signed the invoice for payment. The Associate
Warden for the Business Office at FCC Coleman told us that the business office staff
thought the COR’s signature confirmed that services were provided and that the
prices were valid. Based on that understanding, the business office paid the
invoices.
The BOP’s Field Acquisition Office acknowledged that the COR’s approval of
the single-case agreements was not in compliance with the FAR because the COR
did not have the authority to make a change that affects the price. The officials
agreed that procedures are needed at FCC Coleman to address how pricing for outof-network services and services not covered by Medicare pricing will be established
to ensure compliance with the FAR. FCC Coleman contracting officers told us that
henceforth for new single-case agreements the FCC Coleman contracting staff will
determine price reasonableness by coordinating with the billing clerks to identify
relevant Medicare rates and conducting market research. A contracting officer at
FCC Coleman would then seek, when necessary, to negotiate lower prices with CCS.
One of the contracting officers also told us that the COR and a contracting officer
with the appropriate authority would both review and sign the proposal, confirming
the provision of services and approving the price, and then forward the approved
proposal to CCS for agreement.
Consequently, we recommend that the BOP establish procedures to
specifically address how pricing should be established for out-of-network services
and services required during the performance of the contract but not covered by
Medicare pricing.
BOP Should Ensure that CCS Submits Timely and Accurate Invoices
CCS Used Improper Billing Rates
CCS did not always submit properly priced invoices for onsite optometrist and
general physician services as required by the contract terms and conditions. As a
result, the BOP made improper payments to CCS totaling $95,358.
We found that CCS submitted some invoices based on incorrect rates for
both the optometrist and general physician services. The contract included a
pricing schedule and methodology that CCS is required to use to prepare invoices
for services rendered. CCS submitted 261 invoices for onsite services during
January 2016 through January 2018. We initially selected a judgmental sample of
66 of the 261 invoices for onsite services to determine if the invoices were properly
priced. Our sample included: 26 invoices for onsite optometrist services; 27 invoices
for onsite general physician services; and 13 invoices for onsite Mammography,
Magnetic Resonance Imaging, and Sexual Assault Nurse Examiner services. For
12 of the 26 optometrist invoices (46 percent) and 5 of the 27 general physician
invoices (19 percent), CCS incorrectly billed the BOP. Based on the error rate in
6

our initial sample, we expanded the sample to include all invoices submitted for
onsite optometrist and general physician services. Our final sample of 180 invoices
included: 94 invoices for onsite optometrist services; 73 invoices for onsite general
physician services; and 13 invoices for onsite Mammography, Magnetic Resonance
Imaging, and Sexual Assault Nurse Examiner services.
We determined that 54 of the 94 optometrist invoices (57 percent) and 16 of
the 73 general physician invoices (22 percent) were inaccurately billed using
incorrect rates. The contract provided a pricing schedule based on premiums
ranging from 73 to 80 percent over the respective Medicare rates. Specific pricing
was established for optometrists at a rate of $280 per 2-hour session. Contract
modification 1 established the price per session for general physician onsite
services at $150 per hour for the base year and for option year 1 (January 2016
through December 2017), and at $175 per hour for the remainder of the contract
period, beginning in January 2018.
We found that between January 2016 and December 2016, CCS billed the
BOP for optometrist services at $280 per hour rather than $280 per 2-hour session
as prescribed in the contract, which resulted in overpayments for optometrist
services totaling $80,133. We also found that CCS began billing the BOP $175 per
hour for general physician onsite services in December 2016, which resulted in the
BOP making $15,225 in overpayments to CCS for general physician onsite services.
The invoice review process at FCC Coleman did not detect the improper
invoices. At FCC Coleman, the billing clerks responsible for processing medical
claims invoices are employees of another contractor that provides medical billing
services. The billing clerks relied on FCC Coleman’s Health Service Administrator
for guidance and direction until May 2018 when the responsibility was transferred
to the Business Administrator because the billing clerks were relocated to the FCC
Coleman Business Office. The Health Service Administrator told us that when
reviewing invoices he primarily confirmed that services were provided and he
addressed any discrepancies identified by the billing clerks during their review of
the invoices.
The Health Service Administrator told us that in January 2018 the billing
clerks noticed that the session length on CCS invoices for optometrist services
changed from $280 per 1 hour of service to $280 for 2 hours of service. According
to one billing clerk, a contracting officer at FCC Coleman provided the billing clerks
with a summary of the contract pricing schedule, including the per-session rate for
optometrist services, but did not inform the billing clerks that the pricing was for a
2-hour session. The billing clerk notified the Health Service Administrator when the
session length in the CCS invoices for optometrist services changed from 1-hour
sessions to 2-hour sessions and asked for clarification. The Health Service
Administrator told us that he contacted a contracting officer at FCC Coleman for
clarification and the contracting officer confirmed that the per-session rate for
optometrist services is based on 2-hour sessions. Neither the Health Service
Administrator nor contracting officer at FCC Coleman took action to address the
prior payments that had been erroneously invoiced as 1-hour sessions.
Consequently, the billing clerks were not instructed to identify previously accepted
7

improper CCS invoices, which had resulted in overpayments to CCS totaling
$80,133.
For the onsite general physician services, the Health Service Administrator
and a billing clerk told us that they were not provided a copy of the contract
modification that established the general physician rates. To understand the effect
of contract modifications, the billing clerks relied on updates from routine
teleconferences between BOP and CCS personnel. According to the Health Service
Administrator and the billing clerk, during a teleconference billing clerks were
informed that the general physician rate would increase from $150 per hour to
$175 per hour starting on January 1, 2017. Based on the billing clerks’ belief that
January 2017 was the effective date of the change, the clerks identified the
overbilling for services provided in December 2016, but did not identify any
overbilling for services beginning in January 2017. According to the billing clerk,
CCS later informed the BOP and the billing clerks that the effective date for the rate
change was incorrect and that the effective date for the new rate was actually
January 1, 2018. Although CCS recognized its error and began invoicing correctly
for services delivered in May 2017, it did not correct the overcharges for services
provided between January 2017 and April 1, 2017 and subsequently paid by the
BOP. The Health Service Administrator told us that he discussed the concern
regarding the general physician rate with the BOP contracting officer, but neither he
nor the contracting officer took any action to address the overpayments totaling
$15,225.
We discussed these billing errors with the FCC Coleman Complex Warden and
the Associate Warden for the Business Office. The Complex Warden and the
Associate Warden for the Business Office told us that until our audit they did not
know CCS incorrectly applied the billing rates for optometrist services and onsite
general physician services. We discussed the billing rates with CCS officials who
acknowledged to us that they incorrectly billed the BOP for the optometrist onsite
services and general physician onsite services. The CCS officials told us they
noticed the billing errors in 2017 and corrected the errors for future billings.
However, during our review CCS officials were initially unable to locate any record
of issuing a credit for prior billings. Consequently, CCS officials calculated the
amount that should be repaid and issued credit invoices against the contract for
that amount in November 2018. When applied to the improper payments, these
credit invoices have the effect of reimbursing the appropriated funds from which
the original payments were made. But as of July 19, 2019, the BOP had not
applied those credit invoices toward an open invoice.
We recommend that the BOP review all of the optometrist and general
physician onsite service invoices paid after July 2018, to identify any additional
overpayments and request a reimbursement for any additional overpayments
identified. We also recommend that the BOP revise its billing review process to
ensure billing clerks are provided complete and current pricing schedules that
clearly define the duration of a session for pricing purposes and notes the effective
dates of changes to the pricing schedule.

8

CCS Submitted Offsite Service Claims After 90 Days
CCS does not always submit timely invoices for offsite services. Offsite
service invoices contain up to 50 “claims” for individual services performed at
various times. The contract requires that CCS’s invoices for medical claims be
submitted to the BOP within 90 calendar days of an inmate’s discharge, outpatient
encounter, or other provision of service. Because a single invoice may contain both
timely and untimely claims, we analyzed the timeliness of submission from the
perspective of the claims contained within the invoices.
FCC Coleman’s Business Office personnel told us that CCS had submitted
claims as late as 18 months after services had been provided. We determined that
from January 2016 through January 2018, CCS submitted invoices for 24,683
separate claims for offsite services to the BOP. Of these, 7,286 claims (30 percent)
valued at approximately $7,800,000, were invoiced more than 90 days after the
date of service. Of the 7,286 claims submitted after 90 days, 1,937 (8 percent of
total claims) were submitted more than 180 days after the service date and 252
(1 percent of total claims) were submitted more than 365 days after the service
date. CCS officials stated to us that the company recognizes the importance of the
submission of timely invoices and strives to submit invoices within 90 calendar days
after an inmate’s discharge, outpatient encounter, or other service under the
contract, which is consistent with the contract. CCS officials also stated that in
instances where the company has been unable to submit invoices within this
timeframe, such delays are typically the result of a provider’s failure to timely
submit accurate claims consistent with the timeline described in the contract, or the
services provided need approval before billing the BOP as those services are the
result of a single-case agreement.
Contract performance began in January 2016, and the first invoices
submitted for processing in April 2016 were found to have incorrect or missing
information. The billing clerks process each invoice according to instructions from
the FCC Coleman Business Office and Health Services staff. Invoices are reviewed
based on Centers for Medicare and Medicaid Services (CMS) guidelines. The CMS
publishes a fee schedule of Medicare rates for each year. The CCS contract
provides for pricing to be based on a premium applied to the CMS fee schedule.
Excessively late invoicing increases the risk the premium will be applied to the
wrong CMS fee schedule, resulting in incorrect or inflated rates. In addition, the
billing clerk expends additional time processing late invoices because they have to
locate the prior period CMS rates applicable to the services identified in the
invoices. A billing clerk told us that the billing review had identified instances
where CCS invoices were based on rates established for a period other than the
period when services were provided. Although these instances were identified and
corrected as a result of the billings review process, the risk remains that other
overcharges were submitted and not identified. In addition to the risk of
overcharges, the additional time required for expanded rate reviews for late
invoices contributed to late payments made by the BOP resulting in penalty
payments under the Prompt Payments Act, which is discussed later in this report.

9

According to the CCS contract, failure to submit timely invoices should result
in the identification of performance deficiencies in the contractor’s performance
evaluation. In March 2019, the former Associate Warden for the Business Office at
FCC Coleman confirmed that the BOP does not yet have a plan for tracking the
90-day invoice submission requirement.
We recommend that the BOP consider the timeliness of invoice submissions
by CCS in its evaluation of CCS’s contract performance and report deficiencies
appropriately in the Contractor Performance Assessment Reporting System. We
discuss additional concerns about the BOP’s compliance with the Contractor
Performance Assessment Reporting System later in this report.
BOP Should Define Proper Invoices and Promptly Return Improper Invoices
When CCS submitted improper invoices, FCC Coleman did not return those
invoices to CCS within 7 days as required by the Prompt Payment Act. The FCC
Coleman contracting officer instructed the billing clerks to correct any errors found
in the invoices and recalculate the appropriate invoice amount rather than return
the improper invoices to CCS for correction. The corrected invoice amount is the
amount the BOP eventually paid to CCS. A billing clerk told us the correction
process takes additional time because of the required documentation and
explanation needed to support each correction. Consequently, the review resulted
in missed deadlines under the Prompt Payment Act and triggered the accrual of
penalties for payments not completed within 30 days as required by the Prompt
Payment Act. Improper invoices should be rejected within the 7-day timeframe, as
specified in the Prompt Payment Act, which would have placed the responsibility for
correcting the improper invoices on CCS. The CCS contract states that a medical
claim containing inaccurate, incomplete, or misleading information shall be held by
the contractor and not submitted until it is accurate and complete. However, FCC
Coleman contracting officer’s decision to instruct billing clerks to correct invoice
errors relieved CCS of the responsibility for correcting the invoices. As a result of
FCC Coleman’s practices, the Business Administrator determined that the BOP
made penalty interest payments totaling approximately $97,089 to CCS between
January 2016 and February 2019.
We discussed the improper invoice concerns with the Complex Warden and
Business Office officials at FCC Coleman. A contracting officer at FCC Coleman told
us that CCS officials complained about invoices being rejected because, in their
opinion, FCC Coleman never provided CCS clear guidance on the requirements for a
proper invoice. The Associate Warden for the Business Office at FCC Coleman told
us that FCC Coleman, the Field Acquisition Office, and CCS have had discussions
about the invoice requirements. However, the contracting officer at FCC Coleman
told us that the CCS contract was not modified to reflect any changes that were
discussed.
Consequently, we recommend that the BOP clearly define and communicate
to CCS what constitutes a proper invoice and establish a process wherein only
proper invoices are accepted and processed. We also recommend that FCC

10

Coleman establish the practice of returning improper invoices to the contractor
within 7 days as required in accordance with the Prompt Payment Act.
BOP Needs to Improve its Monitoring of CCS’s Performance
BOP Should Review CCS’s Quality Control Plan
CCS did not establish, as required by the terms of the contract, a quality
control plan (QCP) prior to beginning performance. FAR Part 46 requires the
contractor to be responsible for the quality of its performance under the contract.
Consequently, the contract with CCS requires CCS to submit a QCP for FCC
Coleman’s approval. FCC Coleman contracting officers did not ensure CCS
submitted a QCP for approval before beginning work under the contract.
On December 28, 2017, 24 months after CCS began performance under the
contract, the FCC Coleman contracting officer requested the required QCP. On
January 3, 2018, CCS submitted its QCP for BOP review and approval. As of
March 7, 2019, the QCP had not been approved by the BOP contracting officer. The
FCC Coleman contracting officer told us guidance was being sought from the Field
Acquisition Office on how to properly approve the proposed QCP. We reviewed the
proposed QCP and determined it does not contain specific criteria to properly
measure performance. For example, the proposed QCP lists a general requirement
to ensure that medical invoices are received within the required time frame, but it
does not identify specific contract requirements for proper invoices or the 90-day
requirement for timeliness. Another example pertains to review of medical referrals
to ensure the referrals are scheduled within 14 days as required by the contract.
The proposed QCP makes no mention of the 14-day time frame. In addition, the
proposed QCP states that at least 20 medical invoices will be reviewed to determine
if each invoice properly documents the complete patient name, register number,
and invoice number. However, the proposed QCP does not require review of all of
the invoice elements required by the contract. Absent these elements, we believe
the proposed QCP does not ensure compliance with significant contract
requirements.
Although the proposed QCP requires reevaluations in 120-day intervals, as of
February 11, 2019, CCS had not yet submitted the first periodic QCP report. CCS
officials told us they were unable to complete these QCP reports because they had
been unable to secure interviews with FCC Coleman’s Health Service Administrator
or Clinical Director, as required in the proposed QCP. FCC Coleman’s Health Service
Administrator confirmed on December 6, 2018, that the interview has not yet been
held. On December 14, 2018, an FCC Coleman contracting officer confirmed FCC
Coleman’s Health Service Administrator and Clinical Director were instructed not to
conduct interviews with CCS regarding performance because only contracting
officers are allowed to discuss contractor performance with the contractor. The lack
of an approved QCP and the continued lack of quality control evaluations, increase
the risk that the deficiencies previously described will continue to go unnoticed.

11

We recommend that the BOP review the proposed QCP for adequacy as
required by the CCS contract and ensure CCS timely submits the QCP reports as
required.
BOP Should Establish a Government Quality Assurance Surveillance Plan for use in
Verification of Services Provided
As of March 2019, the BOP had not established a quality assurance
surveillance plan to monitor the services provided by CCS as required by the FAR.
According to FAR Part 46, quality assurance surveillance plans should be prepared
in conjunction with the preparation of the statement of work and should specify the
work requiring surveillance and the method of surveillance. FCC Coleman
contracting officers told us that they believed the Performance-Based Outcome
Measure Indicators document that they used to measure the contractor’s
performance met the requirements of a quality assurance surveillance plan. We
determined that the Performance-Based Outcome Measure Indicators document
does not meet the requirements for a quality assurance surveillance plan because
the document does not specify the method of surveillance. We discussed this
document with an official at the BOP’s Field Acquisition Office who confirmed that
the Performance-Based Outcome Measure Indicators document was not a quality
assurance surveillance plan. As a result, BOP was unable to ensure that services
provided by CCS met the contract requirements.
Consequently, we recommend that the BOP establish a government contract
quality assurance surveillance plan to use as a basis for monitoring performance
and to determine if the services CCS provided meet the contract requirements.
BOP Should Implement a Formal Process for Documenting Onsite Clinic Requests
The contract does not establish a process for scheduling onsite clinics. The
contract provides that, upon the BOP’s request, CCS will provide onsite specialty
clinics for: Dermatologists; Ear, Nose, and Throat (ENT) Specialists; General
Surgeons; Neurologists; Orthopedic Surgeons; Psychiatrists; Urologists;
Optometrists; and Oral Surgeons. FCC Coleman’s Health Service Administrator told
us that onsite clinics save the BOP money by reducing the number and cost of trips
required to transport inmates outside the prison for these specialty services. The
Health Service Administrator told us that, in practice, onsite clinics are requested by
the BOP via verbal communications between FCC Coleman and CCS staff during biweekly meetings.
The FCC Coleman Health Services Administrator told us that during the
period January 2016 through October 2018, FCC Coleman had requested onsite
clinics for Orthopedic Surgeons, Neurologists, Urologists, General Surgeons, ENT
Specialists, Oral Surgeons, and Optometrists. However, CCS had not provided two
requested clinics, one for Neurologists and one for ENT Specialists. CCS officials
told us these clinics were not provided because they were not aware of the BOP
requests. We discussed the apparent breakdown in communication concerning the
two missing clinics with BOP officials who told us the clinics were requested verbally
during meetings between BOP and CCS. However, the requests were not reflected
12

in the meeting minutes we reviewed, and it appears that the BOP did not follow-up
with CCS regarding the need for the clinics. Although few clinics were not held by
CCS as requested, the failure to schedule clinics could result in significant additional
cost to the BOP if inmates had to be transported for services.
We recommend BOP implement a formal process for documenting requests
for required onsite clinics to ensure the contractor is informed of the changing
needs of the FCC Coleman Complex.
BOP Should Ensure Timely and Accurate Data is Entered in the Contractor
Performance Assessment Reporting System
The BOP did not enter into the Contractor Performance Assessment Reporting
System (CPARS) timely and accurate contractor performance information as
required by the FAR. 8 BOP staff entered data for calendar year 2016 on April 27,
2018, and entered data for calendar year 2017 on April 30, 2018. According to FCC
Coleman officials, the contractor performance data was entered late because
contracting officials relied on the COR who was unable to access the CPARS system
and did not enter the performance information. When FCC Coleman staff
eventually entered the data, it did not reflect CCS’s late submission of invoices and
failure to prepare a QCP, as previously discussed in this report, because they had
not completed required monitoring and consequently were not aware of these
problems.
CPARS is the government-wide electronic contractor evaluation system used
to record contractor past performance information and is used in procurement
source selection evaluations. This information is critical to ensuring that the federal
government only does business with companies that provide quality products and
services. The FAR and BOP policy require that the BOP collect and submit
contractor performance information for contracts that exceed the Simplified
Acquisition Threshold into CPARS at least annually. This information is made
available online so BOP and other source selection officials can use it to make
informed business decisions when awarding federal contracts. 9 As a result of BOP’s
untimely and inaccurate entry of CCS’s performance information, other source
selection officials across the government lack critical information regarding CCS’s
past performance on government contracts.
We recommend that the BOP clearly define responsibility for entering
contractor performance information into CPARS and ensure information is entered
in a timely and accurate manner.

FAR Subpart 42.1502(a), General, states that past performance evaluations shall be
prepared at least annually and at the time the work under the contract or order is completed.
8

9

and (b).

FAR Subpart 42.15, Contractor Performance Information, 42.1502, Policy, 42.1502(a)

13

BOP Should Consider Modifying the Comprehensive Medical Contract at FCC
Coleman to Better Define Requirements and Pricing
BOP May Have Missed Cost Savings Due to Inadequate Pre-Award Planning
FCC Coleman may not have adequately defined its requirements in the
contract solicitation and could have more fully considered proposed enhancements
offered by potential contract awardees. The BOP solicited proposals for the contract
to provide comprehensive medical services at FCC Coleman in accordance with the
FAR and the Bureau of Prisons Acquisition Policy. However, we identified concerns
regarding the BOP’s pre-award planning.
We are uncertain that the acquisition plan included all of the specified needs
identified by FCC Coleman management. In 2012, prior to the pre-award planning
for the contract with CCS, the Warden who supervised contracting at FCC Coleman
had identified the need for a secure hospital unit to be included in the
comprehensive medical contract. In correspondence sent to other FCC Coleman
officials, the Warden stated that a secure hospital unit could provide cost savings
and improve security. However, at the time of the pre-award planning, the Health
Services Administrator at FCC Coleman did not include the secure hospital unit in
the development of the Request for Contract Action provided to the Field Acquisition
Office preparing the contract solicitation.
The Field Acquisition Office created a solicitation without specifying a need
for a secure hospital unit or telehealth, although the solicitation encouraged offerors
to propose enhancements to the basic contract requirements that could result in
cost savings. The solicitation specified that offers exhibiting ways to assist the BOP
in mitigating security concerns would be considered beneficial to the government
and evaluated for merit. We reviewed the award decision documents and noted
that two offerors proposed an enhancement for a secure unit at the local hospital.
One offeror also proposed the use of telehealth technologies as a cost-saving
measure. Telehealth involves the remote delivery of health care using
telecommunications technologies. The BOP began implementing the use of
telehealth for psychiatry and radiology services in FY 2000.
A BOP technical evaluation panel comprised of the FCC Coleman Health
Services Administrator, Clinical Director, and Associate Warden assessed the
proposals and enhancements submitted. The Health Service Administrator served
as the chairperson for the panel. The panel reviewed the offers and made final
recommendations to the Field Acquisition Office for the contract award decision. In
the final recommendation, the technical evaluation panel stated that telehealth
would be viewed as a valuable enhancement if the BOP had the desire and
capability to implement it but, because it was unlikely to be used, it had little
overall value. The Health Service Administrator stated in the final recommendation
that a secure hospital unit offered little value to FCC Coleman because few FCC
Coleman inmates required extended stay at the local hospital named in the offer.
These statements made by the technical evaluation panel and the Health Service
Administrator were considered in the decision for contract award, which did not
accept enhancements for a secure hospital unit or telehealth. Despite this, the FCC
14

Coleman managerial officials we interviewed told us that they believe use of a
secure hospital unit and telehealth would reduce costs and staffing requirements
while also improving security.
We reviewed FCC Coleman’s security staffing for hospitalizations. According
to FCC Coleman’s Associate Warden for Health Services, from January 2014
through July 2018 an average of 10 inmates were hospitalized each day requiring
an average of 62 BOP staff members to transport and provide security for the
inmates. The Associate Warden estimated that the BOP staff members would be,
on average, Law Enforcement General Schedule grade 8, step 5. Using the FY 2018
Law Enforcement General Schedule base rate of $54,975 for grade 8, step 5 for
FCC Coleman’s location, we calculated the FY 2018 estimated cost of staffing for
hospitalized inmates was approximately $4.8 million. This amount does not
consider overtime, night differential, holiday, or Sunday pay differential.
The Associate Warden also told us that staffing a secure hospital unit would
require approximately 16 BOP staff members daily, which is 46 fewer than currently
required. The 16 BOP staff members would cost approximately $1.2 million
annually. The introduction of a secure hospital unit would result in a potential
annual cost savings of about $3.5 million for security staffing. These savings would
be offset by other potential cost increases such as additional hospital fees or
expenses associated with constructing and maintaining a secure hospital unit.
While we were unable to assess these additional costs, BOP leadership at FCC
Coleman expressed their belief that the complex would benefit from both a secure
hospital unit and a telehealth program.
According to the BOP, because of its escort policy, inmate security levels, and
various other correctional concerns, it is impossible to use a simple formula to
verify the amount of savings possible, and whether those savings would offset the
additional cost of establishing a secure unit. Consequently, we recommend that the
BOP further assess opportunities to utilize a secure hospital unit and telehealth in
future contracts at FCC Coleman.
BOP’s Pricing Schedule Should Include Provisions to Prorate Payment for Service
Sessions
The BOP paid for full sessions even when the necessary services did not
require and the provider did not work the full time identified as a session. For
subcontracted oral surgeons, the contract established a price for services to be
performed during 4-hour sessions. Similarly, for subcontracted optometrists, the
contract established a price for services to be performed during 2-hour sessions.
However, the contract did not establish that the prices for these services would be
prorated when the full 4- or 2-hour session was not required. Consequently, the
contract allows, and CCS has practiced, billing for full sessions or partial sessions
worked at the agreed upon rate for a session. BOP Field Acquisition Office officials
told us that the contract solicitation and award documents should have included
proration language but that provision was omitted as the result of an oversight.

15

Because the CCS contract with BOP does not require proration of the price
for partial sessions, the BOP paid CCS $7,665 more than necessary for the services
provided. During January 2016 through January 2018, CCS submitted and the BOP
paid 94 invoices for optometrist services. Of these invoices, 54 were inaccurately
billed using incorrect rates as previously discussed in the Billing Rates section of
this report and 40 were billed based on the number of sessions worked, in
accordance with the contract terms. Of the 40 invoices billed based on the number
of sessions worked, 28 invoices were billed and the BOP paid for optometrist
services based on full sessions worked. However, the optometrist did not work the
full sessions billed. According to a CCS employee, when billing the BOP for
optometrist services provided, CCS identified the hours worked and rounded up to
the next full session as allowed by the contract. We used the supporting
documentation provided by the BOP to determine the hours worked during each
site visit and to identify the number of full sessions and partial sessions worked.
We then determined the number of sessions that could be billed under the terms of
the contract as supported by the records of the optometrist’s visits. We considered
the unworked hours included in the sessions that could be billed under the terms of
the contract and compared that to the number of hours represented by the sessions
billed. We subsequently discussed our analysis with a CCS employee regarding the
practice of paying the subcontracted optometrist for full sessions when only partial
sessions were worked. The CCS employee told us that CCS pays the optometrist
based on the hours actually worked and not per session.
As of October 2018, CCS had not provided oral surgeon services under the
contract because an oral surgeon had not been credentialed to provide the services.
However, absent any contract modification to provide for proration of session costs,
additional unnecessary costs may result when an oral surgeon is credentialed and
begins work under the provision for pricing established based on 4-hour sessions.
During the audit, we discussed with FCC Coleman officials our concerns
regarding proration of optometrist and oral surgeon sessions. In response, FCC
Coleman officials began considering a contract modification with CCS to prorate
session prices to the nearest quarter hour. As of March 2019, the modification had
not been implemented.
Therefore, we recommend that BOP complete the modification to the CCS
contract to prorate reimbursement for session-based services.
BOP Should Clearly Identify Payment Terms for Scheduled Visit Cancellations
The CCS contract does not provide for cancellation fees to be paid to CCS
when the BOP cancels scheduled provider visits to FCC Coleman. The contract
states that the BOP will provide CCS a 48-hour written or verbal notice prior to
canceling a visit unless circumstances beyond the control of the BOP require the
cancellation without notice. Such circumstances may involve an inmate
unexpectedly refusing a procedure when notified of it on the day of the
appointment. Although the contract does not address cancellation fees, we found
21 instances from January 2016 through February 2018 for which the BOP paid a

16

total of $4,125 in cancellation fees to CCS and its providers. For these instances,
CCS sought payment of cancellation fees based on claims made by its providers.
The contract provides that CCS is reimbursed for services according to a
Medicare benchmark rate plus a premium. A CCS employee told us that there is no
provision in the contract regarding cancellation fees and no Medicare code for
cancellation fees. However, absent a specific prohibition on cancellation payments,
CCS submitted claims to the BOP for reimbursements to providers who submitted
charges to CCS for the cancellations. Not all of CCS’s providers submit claims for
cancellations. When CCS’s providers submit claims, CCS submits to the BOP a
proposal for a single-case agreement to recover the cost.10
We discussed with FCC Coleman officials the 21 instances of cancellation fees
paid to CCS. The Associate Warden for the Business Office told us in a meeting on
December 3, 2018, that FCC Coleman had stopped paying cancellation fees to CCS.
To ensure CCS and the BOP have a clear understanding of cancellation fees,
we recommend that the BOP modify the contract to state the terms under which
compensation would or would not be made for cancellations.

The authorization for this reimbursement is through the use of a single-case agreement,
which is a separate contract action resulting from a proposed price submitted by CCS to obtain
payment for services not specifically covered by the contract.
10

17

CONCLUSION AND RECOMMENDATIONS
We identified areas of improvement related to the BOP’s award and
administration of the contract. Specifically, the BOP needs to improve the
processes for invoice reconciliation and monitoring of the contractor’s performance.
Also, the BOP needs to clearly develop and define contract terms particularly for
pricing methodology and enhancements. We found that CCS generally complied
with the terms and conditions of the contract applicable to contract management,
oversight, and monitoring. However, we found that CCS did not comply with the
terms and conditions of the contract applicable to quality assurance and submission
of timely and accurate billings.
We recommend that the BOP:
1.

Establish procedures to specifically address how pricing should be established
for out-of-network services and services required during the performance of
the contract but not covered by Medicare pricing.

2.

Review all of the optometrist and general physician onsite service invoices
paid after July 2018, to identify any additional overpayments and request a
reimbursement for any additional overpayments identified.

3.

Revise its billing review process to ensure billing clerks are provided
complete and current pricing schedules that clearly define the duration of a
session for pricing purposes and notes the effective dates of changes to the
pricing schedule.

4.

Consider the timeliness of invoice submissions by CCS in its evaluation of
CCS’s contract performance and report deficiencies appropriately in the
Contractor Performance Assessment Reporting System.

5.

Clearly define and communicate to CCS what constitutes a proper invoice and
establish a process wherein only proper invoices are accepted and processed.

6.

Establish at FCC Coleman the practice of returning improper invoices to the
contractor within 7 days as required in accordance with the Prompt Payment
Act.

7.

Review the proposed QCP for adequacy as required by the CCS contract and
ensure CCS timely submits the QCP reports as required.

8.

Establish a government contract quality assurance surveillance plan to use as
the basis for monitoring performance and to determine if the services CCS
provided meet the contract requirements.

9.

Implement a formal process for documenting requests for required onsite
clinics to ensure the contractor is informed of the changing needs of the FCC
Coleman Complex.

18

10.

Clearly define responsibility for entering contractor performance information
into CPARS and ensure information is entered in a timely and accurate
manner.

11.

Further assess opportunities to utilize a secure hospital unit and telehealth at
FCC Coleman.

12.

Complete the modification to the CCS contract to prorate reimbursement for
session-based services.

13.

Modify the contract to state the terms under which compensation would or
would not be made for cancellations.

19

STATEMENT ON INTERNAL CONTROLS
As required by the Government Auditing Standards, we tested, as
appropriate, internal controls significant within the context of our audit objectives.
A deficiency in an internal control exists when the design or operation of a control
does not allow management or employees, in the normal course of performing their
assigned functions, to timely prevent or detect: (1) impairments to the
effectiveness and efficiency of operations, (2) misstatements in financial or
performance information, or (3) violations of laws and regulations. Our evaluation
of the Federal Bureau of Prisons’ (BOP) internal controls in the administration of
contract number DJBP030200000070 awarded to Correct Care Solutions, LLC (CCS)
for comprehensive medical services at FCC Coleman was not made for the purpose
of providing assurance on the BOP and CCS internal control structures as a whole.
BOP and CCS management are responsible for the establishment and maintenance
of their respective internal controls.
As noted in the Audit Results section of this report, we identified deficiencies
in the BOP’s internal controls that are significant within the context of the audit
objectives and based upon the audit work performed that we believe adversely
affect the BOP’s ability to detect whether contractor invoices were properly priced.
Specifically, the BOP must ensure that proper review and verification of contractor
invoices and be accomplished by providing the billing clerks with complete and
current pricing schedules that clearly define the pricing methodology and the
effective dates of changes to the pricing schedule.
Because we are not expressing an opinion on the BOP’s or CCS’s internal
control structure as a whole, this statement is intended solely for the information
and use of the BOP and CCS. This restriction is not intended to limit the
distribution of this report, which is a matter of public record.

20

STATEMENT ON COMPLIANCE
WITH LAWS AND REGULATIONS
As required by the Government Auditing Standards we tested, as appropriate
given our audit scope and objectives, selected transactions, records, procedures,
and practices, to obtain reasonable assurance that the BOP and CCS management
complied with federal laws and regulations for which noncompliance, in our
judgment, could have a material effect on the results of our audit. The BOP’s and
CCS’s management are responsible for ensuring compliance with applicable federal
laws and regulations. In planning our audit, we identified the following laws and
regulations that concerned the operations of the auditee and that were significant
within the context of the audit objectives:
•

FAR Subsection 1.602-2, Responsibilities;

•

FAR Subpart 15.402, Pricing Policy;

•

FAR Subpart 32.9, Prompt Payment;

•

FAR Subpart 37.603, Performance Standards;

•

FAR Subpart 42.15, Contractor Performance Information; and

•

FAR Subpart 46.4, Government Contract Quality Assurance.

Our audit included examining, on a test basis, BOP’s and CCS’s compliance
with the aforementioned laws and regulations that could have a material effect on
BOP’s and CCS’s operations through interviews of BOP And CCS personnel and
inspection of billing records and monitoring reports. As noted in the Audit Results
section of this report, we found that the BOP did not comply with the FAR 32.9,
46.4, and 1.602-2 as required by the records and contract actions we reviewed.

21

APPENDIX 1
OBJECTIVES, SCOPE, AND METHODOLOGY
Objective
The audit objective was to assess the Federal Bureau of Prisons’ (BOP) award
and administration of the contract, and Correct Care Solutions, LLC (CCS)
compliance with the terms, conditions, laws, and regulations applicable to contract
DJBP030200000070 in the areas of: (1) contractor performance, (2) billings and
payments, and (3) contract management, oversight, and monitoring.
Scope and Methodology
We conducted this performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objective. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions
based on our audit objective.
This was an audit of the BOP contract DJBP030200000070 with CCS. The
scope of this audit, unless otherwise indicated, is contract performance from
January 2016 through January 2018, and included activities of both the BOP and
CCS.
To determine whether during the contract award and administration
processes, the BOP adhered with Federal Acquisition Regulation (FAR) requirements
that we tested, we reviewed the FAR, pre-award documents, contract files, and
BOP’s procurement files and monitoring reports. We also held interviews with key
personnel from the BOP to understand the BOP’s contract award and administration
processes.
To assess whether CCS complied with the terms and conditions of the
contract, we evaluated CCS provision of medical care and tested CCS’ billing
records and invoices submitted to the BOP. We also evaluated the BOP’s review of
billings and the BOP’s records of medical care provided by subcontracted providers.
Analysis of Invoices for Onsite Services
CCS had submitted a total of 261 invoices for onsite services to the BOP for
medical services provided during the months of January 2016 through January
2018. We judgmentally selected a non-statistical sample of 75 invoices for onsite
service claims. We found that 9 of the 75 invoices for onsite service claims were
not paid as of July 2018, reducing our sample size to 66 invoices. We reviewed the
pricing for each paid invoice to confirm they were based on the agreed rates. We
found that the optometry and general physician onsite service invoices were
frequently not based on the agreed rates. Therefore, we expanded the
non-statistical sample to include all of the optometry and general physician onsite
22

service invoices which increased our sample of invoices from 66 to 180 invoices.
The non-statistical sample design did not allow projection of the test results to the
universe from which the samples were selected. We reviewed the additional invoice
pricing to confirm they were based on the agreed rates.
During our audit, we obtained information from the Financial Management
Information System and the Electronic Record Management Application. We did not
test the reliability of those systems as a whole, and did not rely on any processing
of the data performed by these systems. Any findings identified involving
information from those systems were verified with documentation from other
sources.
Analysis of Invoices submitted after 90 days
CCS had summited a total of 24,683 claims to the BOP for medical services
provided during the months January 2016 through January 2018. We calculated
the number of days between the date the service was rendered and the invoice
date to determine that 7,286, approximately 30 percent, were submitted past the
90 day requirement. We also determined that 1,937, approximately 8 percent,
were submitted after 180 days, and 252, approximately 1 percent, were submitted
after 365 days.
Analysis of Contract Requirements and Proposals Evaluations
To determine the potential cost savings from a secure unit at the local
hospital, we relied on the estimates of FCC Coleman officials regarding the average
number of inmates hospitalized each day and the average number of staff members
needed to provide security for those inmates from January 2014 to July 2018.
Using this information, we established an average baseline salary for security staff
for a year and calculated the annual cost for the security staff required for the
hospitalized inmates. We also relied on estimates from FCC Coleman officials
regarding the number of staff members needed to staff a secure unit. Using the
same methodology as above, we determined the annual cost for security coverage
for a secure unit at a local hospital for a year. We then compared the estimated
cost of security for hospitalized inmates and the estimated cost for security of a
secure hospital unit and determined the potential cost savings of $3,849,780.
Analysis of Pricing Schedule
We reviewed 94 of 131 invoices for onsite service claims that CCS submitted
to FCC Coleman for optometry services provided during the months of
January 2016 through January 2018. We selected all of the invoices for that period
that had been paid as of July 2018. We verified invoice amounts and service hours
delivered by CCS’ subcontracted providers, and the contract pricing schedule rate
for each claim. We compared the invoice amounts to the support and determined
the amount of overpayments. We also determined whether CCS reimbursed the
BOP for any of the overpayments.

23

Analysis of Scheduled Visit Cancellations
We evaluated cancellation payments made by FCC Coleman to CCS from
January 2016 to February 2018. We found a total of 21 instances of canceled
appointments for which FCC Coleman paid CCS a total of $4,125.00.

24

APPENDIX 2
THE FEDERAL BUREAU OF PRISONS’
RESPONSE TO THE DRAFT AUDIT REPORT
U.S. Department of Justice

Federal Bureau of Prisons

Of/ice of the D1re,·1or

\Vm1H11gto11. D.C. 2053-J.

August 21, 2019

MEMORANDUM FOR JASON R. MALMSTROM
ASSISTANT I NSPECTOR GENERAL

&AUDIT

FROM:

1L~

SUBJECT:
Response to the Office of Inspector General's (OIG) Draft
Audit Report : Audit of The Federal Bureau of Prisons ' Contract
Awarded to Correct Care Solutions, LLC, for the Federal
Correctional Complex in Coleman, Florida

The Bureau of Prisons (BOP) appreciates the opportunity to prov ide
a response to the Office of the Inspector General's abovereferenced report. Therefore, please find the BOP's responses to
the recommendations below :
OIG recommends the BOP:
Recommendation 1 : Establish procedures to specifically address
how pricing should be established for out-of -network services
and services required during the performance of the contract but
not covered by Medicare pricing.
Initial Response:
The BOP agrees with this recommendation. The
BOP will establish procedures to specifically address how pricing
should be established for out-of-network services and services
required during the performance of the contract but not covered
by Medicare pricing.

25

Recommendation 2 : Revi ew all of the optometrist and general
physician onsite service invoices paid after July 2018, to
identify any additional overpayments and request a reimbursement
for any additional overpayments identified .
I nitial Response : The BOP agrees with this recommendation . The
BOP will review all of the optome t rist and general physician
onsite service invoices paid after July 2018, to identify any
additional overpayments and request a reimbursement for any
additional overpayments identified.
Recommendation 3 : Revi se its billing review process to ensure
billing c lerks a r e provided comple te and curren t pricing
schedules that clearly define the duration of a session for
pricing purposes and notes the effective dates of changes to the
pricing schedule.
Initi al Response : The BOP agrees with this recommendation. The
BOP will revise its billing review process to ensure billing
clerks are provided complete and current pricing schedules that
clearly define the duration of a session for pricing purposes
and notes the effective dates of changes to the pricing
schedule.
Recommendation 4: Consider the timeliness of invoice submissions
by CCS in its evaluation of CCS' contract performance and report
deficiencies appropriately in the Contractor Performance
Assessment Reporting System .
I nitial Re spo nse: The BOP agrees with this recommendation. The
BOP will consider the timeliness of invoice submissions by CCS in
its evaluation of CCS' contract performance and report
deficiencies appropriately in the Contractor Performance
Assessment Reporting System.
Re c ommendat ion 5 : Clearly define and communicate to CCS what
constitutes a proper invoice and establish a process wherein
only proper invoices are accepted and processed.
Initial Response:
The BOP agrees with this recommendation . The
BOP will clearly define and communicate to CCS what constitutes a
proper invoice and establish a process wherein only proper
invoices are accepted and processed.

26

Recommendation 6: Establish at FCC Coleman the practice of
returning improper invoices to the contractor within 7 days as
required in accordance with the Prompt Payment Act.
Initial Response:
The BOP agrees with this recommendation.
The BOP will establish at FCC Coleman the practice of
returning improper invoices to the contractor within 7 days as
required in accordance with the Prompt Payment Act.
Recommendation 7: Review the proposed QCP for adequacy as
required by the CCS contract and ensure CCS timely submits the
QCP reports as required.
Initial Response:
The BOP agrees with this recommendation. The
BOP will review the proposed QCP for adequacy as required by the
CCS contract and ensure CCS timely submits the QCP reports as
required.
Recommendation 8: Establish a government contract quality
assurance surveillance plan to use as the basis for
monitoring performance and to determine if the servi ces CCS
provided meet the contract requirements.
Initial Response: The BOP agrees with this recommendation.
The
BOP will establish a government contract quality assurance
surveillance plan to use as the basis for monitoring performance
and to determine if the services CCS provided meet the contract
requirements.
Recommendation 9: Implement a formal process for documenting
requests for required onsite clinics to ensure the contractor is
informed of the changing needs of the FCC Coleman Complex.
Initial Response:
The BOP agrees with this recommendation. The
BOP will implement a formal process for documenting requests for
required onsite clinics to ensure the contractor is informed of
the changing needs of the FCC Co leman Complex.
Recommendation 10: Cl early define responsibility for ent ering
contractor performance information into CPARS and ensure
information is entered in a timely and accurate manner.
Initial Response: The BOP agrees with t his recommendation. The
BOP will clearly define responsibility for entering contractor

27

performance information into CPARS and ensure information is
entered in a timely and accurate manner.
Recommendation 11: Further assess opportunities to utilize a
secure hospital unit and telehealth at FCC Coleman.
Initial Response: The BOP agrees with this recommendation. The
BOP will further assess opportunities to utilize a secure
hospital unit and telehealth at FCC Coleman.
Recommendation 12: Complete the modification to the CCS contract
to prorate reimbursement for session based services.
Initial Response:
The BOP agrees with this recommendation. The
BOP will complete the modification to the CCS contract to prorate
reimbursement for session based services.
Recommendation 13: Modify the contract to state the terms under
which compensation would or would not be made for cancellations.
Initial Response:
The BOP agrees with this recommendation. The
BOP will modify the contract to state the terms under which
compensation would or would not be made for cancellations.

If you have any questions regarding this response, please
contact David Shinn, Assistant Director, Program Review
Division, at (202) 307-3198.

28

APPENDIX 3
OFFICE OF THE INSPECTOR GENERAL
ANALYSIS AND SUMMARY OF ACTIONS
NECESSARY TO CLOSE THE REPORT
The OIG provided a draft of this audit report to the Federal Bureau of Prisons
(BOP) and Correct Care Solutions (CCS). The BOP’s response is incorporated in
Appendix 2 of this final report. CCS elected not to provide a written response.
However, we discussed our findings with CCS officials and, based on their technical
comments, we made adjustments as appropriate in the report. In response to our
audit report, the BOP agreed with our recommendations, and the status of the audit
report is resolved. The following provides the OIG analysis of the BOP response
and summary of actions necessary to close the report.
Recommendations for the BOP:
1.

Establish procedures to specifically address how pricing should be
established for out-of-network services and services required during
the performance of the contract but not covered by Medicare pricing.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will establish procedures to specifically address how pricing
should be established for out-of-network services and services required
during the performance of the contract but not covered by Medicare pricing.
This recommendation can be closed when we receive documentation of the
procedures established.

2.

Review all of the optometrist and general physician onsite service
invoices paid after July 2018, to identify any additional
overpayments and request a reimbursement for any additional
overpayments identified.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will review all of the optometrist and general physician onsite
service invoices paid after July 2018, to identify any additional overpayments
and request a reimbursement for any additional overpayments identified.
This recommendation can be closed when we receive documentation showing
the results of the review of optometrist and general physician invoices and
the resolution of any additional overpayments identified.

29

3.

Revise its billing review process to ensure billing clerks are provided
complete and current pricing schedules that clearly define the
duration of a session for pricing purposes and notes the effective
dates of changes to the pricing schedule.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will revise its billing review process to ensure billing clerks
are provided complete and current pricing schedules that clearly define the
duration of a session for pricing purposes and notes the effective dates of
changes to the pricing schedule.
This recommendation can be closed when we receive documentation of the
revised billing review process.

4.

Consider the timeliness of invoice submissions by CCS in its
evaluation of CCS’s contract performance and report deficiencies
appropriately in the Contractor Performance Assessment Reporting
System (CPARS).
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will consider the timeliness of invoice submissions by CCS in
its evaluation of CCS’s contract performance and report deficiencies
appropriately in CPARS.
This recommendation can be closed when we receive documentation of
CPARS reporting demonstrating the consideration of timeliness of invoice
submission.

5.

Clearly define and communicate to CCS what constitutes a proper
invoice and establish a process wherein only proper invoices are
accepted and processed.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will clearly define and communicate to CCS what constitutes
a proper invoice and establish a process wherein only proper invoices are
accepted and processed.
This recommendation can be closed when we receive documentation of the
clear definition of a proper invoice and the established process for accepting
and processing invoices.

6.

Establish at Federal Correctional Complex (FCC) Coleman the practice
of returning improper invoices to the contractor within 7 days as
required in accordance with the Prompt Payment Act.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will establish at FCC Coleman the practice of returning
improper invoices to the contractor within 7 days as required in accordance
with the Prompt Payment Act.

30

This recommendation can be closed when we receive documentation of the
established practice for returning improper invoices in accordance with the
guidelines established in the Prompt Payment Act.
7.

Review the proposed Quality Control Program (QCP) for adequacy as
required by the CCS contract and ensure CCS timely submits the QCP
reports as required.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will review the proposed QCP for adequacy as required by
the CCS contract and ensure CCS timely submits the QCP reports as
required.
This recommendation can be closed when we receive documentation of the
BOP’s review of the proposed QCP.

8.

Establish a government contract quality assurance surveillance plan
to use as the basis for monitoring performance and to determine if
the services CCS provided meet the contract requirements.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will establish a government contract quality assurance
surveillance plan to use as the basis for monitoring performance and to
determine if the services CCS provided meet the contract requirements.
This recommendation can be closed when we receive documentation of the
government contract quality assurance surveillance plan.

9.

Implement a formal process for documenting requests for required
onsite clinics to ensure the contractor is informed of the changing
needs of the FCC Coleman Complex.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will implement a formal process for documenting requests
for required onsite clinics to ensure the contractor is informed of the
changing needs of the FCC Coleman Complex.
This recommendation can be closed when we receive documentation of the
implemented process for documenting requests for required onsite clinics.

10.

Clearly define responsibility for entering contractor performance
information into CPARS and ensure information is entered in a timely
and accurate manner.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will clearly define responsibility for entering contractor
performance information into CPARS and ensure information is entered in a
timely and accurate manner.

31

This recommendation can be closed when we receive documentation of a
procedure that clearly defines the responsibility for entering contractor
performance information into CPARS and that establishes a monitoring
requirement to ensure the information is entered in a timely and accurate
manner.
11.

Further assess opportunities to utilize a secure hospital unit and
telehealth at FCC Coleman.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will further assess opportunities to utilize a secure hospital
unit and telehealth at FCC Coleman.
This recommendation can be closed when we receive documentation of the
steps taken to further assess opportunities for the use of a secure hospital
unit and telehealth at FCC Coleman.

12.

Complete the modification to the CCS contract to prorate
reimbursement for session-based services.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will complete the modification to the CCS contract to prorate
reimbursement for session-based services.
This recommendation can be closed when we receive documentation of the
finalized modification to the CCS contract to prorate reimbursement for
session-based services.

13.

Modify the contract to state the terms under which compensation
would or would not be made for cancellations.
Resolved. The BOP agreed with our recommendation. The BOP stated in its
response that it will modify the contract to state the terms under which
compensation would or would not be made for cancellations.
This recommendation can be closed when we receive documentation of the
finalized modification identifying the terms under which compensation would
or would not be made for cancellations.

32

The Department of Justice Office of the Inspector General (DOJ OIG) is a
statutorily created independent entity whose mission is to detect and deter
waste, fraud, abuse, and misconduct in the Department of Justice, and to
promote economy and efficiency in the Department’s operations.
To report allegations of waste, fraud, abuse, or misconduct regarding DOJ
programs, employees, contractors, grants, or contracts please visit or call the
DOJ OIG Hotline at oig.justice.gov/hotline or (800) 869-4499.

U.S. DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL
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Washington, DC 20530 0001
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