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Santis Memo: 2022 Annual Report from the Office of the Auditor General of Ontario

Wednesday, November 30, 2022 – Ontario’s Auditor General Bonnie Lysyk released her 2022 Annual Report today, covering 15 wide ranging topics, including COVID-19 contracts and procurement, and the COVID-19 vaccination program. Highlights from these audits are summarized below.

COVID-19 Vaccination Rollout and Record Tracking Criticized by Auditor General

The audit of the COVID-19 Vaccination Program found high rates of unused doses and wastage of vaccines across all access points, with Ontario wasting 3.4 million vaccines. The audit also pointed to the inconsistent approaches to high risk areas, with the vaccine distribution strategy missing nine “hotspot” communities across the province, which should have been prioritized according to the Auditor General.

Ontarians were able to book their vaccination appointments through multiple booking systems including the provincial booking system and systems operated by public health units, hospitals and pharmacies. Data from the Ministry of Health found about 227,000 no-show appointments were noted in 2021 from the provincial booking system alone and this resulted in appointments going unfilled.

The audit also highlighted the fact that Ontario does not have a central registry to track vaccination history for all Ontarians. The Auditor General makes it clear that this is a limiting factor for Ontario to track and manage new outbreaks and emerging diseases. In the 2014 audit on immunization carried out by the Auditor General under the previous government, the Ministry of Health signaled its intent to expand Panorama — Ontario’s existing vaccination registry — to cover vaccination records beyond those of school-aged children. The Auditor General indicated today that the registry was still incomplete when COVID-19 emerged.

The Auditor General’s Audit on the COVID-19 Vaccination Program has nine findings with 11 recommendations.

The findings are:

  • Vaccine distribution was not always equitable.
  • Multiple vaccination appointment booking systems contributed to no-show appointments.
  • Vaccinators were compensated differently depending on their profession and work location.
  • The lack of a proper vaccine registry limits the province’s ability to rapidly respond to future disease outbreaks.
  • Responsibilities for vaccine rollout were not always well coordinated. Ontario wasted 3.4 million vaccine doses.
  • Proof of vaccination was not effectively enforced.
  • Vaccine mandate decisions were not evidence-based.
  • There was unclear communication on vaccine safety.

COVID-19 Contracts and Procurement

Ontario contracted for more than $7 billion in procurement related to the COVID-19 pandemic between March 2020 and March 2022, of which approximately half was non-competitive procurement due to the urgent situation.

The Auditor General generally approved of the approach to contract COVID-19 testing and other COVID-19 related procurements, emphasizing the speed of the process was justified in the emergency situation. However, the report argued that cost savings would have been possible if there was better coordination between different parts of government. The audit found $18 million was spent on underutilized mobile testing, with particular criticism of the Ministry of Education’s walk-in clinics, with under 10% utilization even as there were areas with high need and demand.

The Auditor General raised significant concerns with some procurement practices including:

  • The rollout of rapid antigen tests to workplaces with limited checks on whether the quantity of tests was appropriate, and no follow-up to investigate results of tests.
  • Examples of vaccine clinic contracts which were procured through a non-competitive process due to the situation being deemed urgent, even as other areas of government completed competitive procurement processes for clinics in a timely manner.
  • Failing to obtain feedback on vendors’ past performance, even as existing relationships were used to justify sole-source contracts.
  • Failing to monitor performance of vendors, even when performance improvement was included as a term of the contract. 11% of all emergency procurements were not reported in a timely manner to the Treasury Board/Management Board of Cabinet.
  • Failing to collect centralized procurement reporting information during the pandemic.

The personal protective equipment (PPE) situation came under greater criticism, with the audit finding $66 million of PPE went unused as it was expiring, damaged or became obsolete during 2021/22. The Auditor General also called for better planning with $81 million of N95 respirators set to expire unused by 2030 under current and expected usage.

The Auditor General made 12 recommendations including:

  • Regularly update the Procurement Directive, with a specific recommendation to review the Directive in the next year.
  • Semi-annually update PPE usage forecasts, coordinate between government departments to manage usage, and ensure planning is in place to use forecasted excess.
  • Coordinating all COVID-19 testing through the Ministry of Health.
  • Collect and assess data on testing site performance and use that data to inform future testing operations.
  • Allow for shorter minimum bid response times.
  • Require the use of the Vendor Performance Management Framework and develop a method for reporting scorecard performance across ministries.
  • Conduct pricing reviews as part of quarterly review meetings with vendors and develop corrective action plans if performance does not meet expectations across two quarters.
  • Initiate reporting requirements similar to those under the Interim Measures across ministries.
  • Review the Interim Measures and ensure all ministries are aware of how to follow the requirements of the Interim Measures.

Follow-up Audits

The Auditor General also completed two follow-up audits (as per normal practice) on previous health care audits that were initially completed in 2020 – one related to Blood Management and Safety, and the other to Virtual Care. However, these audits have not yet been made publicly available “due to technical difficulties”.

Santis Insights

Overall, the Auditor’s findings were relatively good for the health care system. There were a number of negative findings, but fewer than most years and the Auditor seemed to largely approve of the government’s approach to balance compliance with the need to move quickly during the pandemic.

The lack of progress on a centralized provincial vaccination registry is likely the most significant issue that was identified. This remains a large gap in the province’s digital health efforts and has continued for many years despite past Auditor findings. Beyond that, the health care system appears to have received a mostly positive response from the Auditor this year.