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‘1G Fe Nome aoe Sreoots eth Deparment & Phi CITY OF PHILADELPHIA OFFICE OF THE INSPECTOR GENERAL Public Report Philly Fighting COVID, Inc. “DE Case No STIS rai Figg COWID. as INTRODUCTION ‘The Office ofthe Inspector General (OIG) presents the following narrative in rough chronological erder to disclose the City of Philadelphia's relationship with Philly Fighting COVID, ine, Vax Popul, fs and ‘Andrei Doroshi ~the principal ofthese organizations. This report is sourced ffom 47 investigative imerviews,' fielded complains, email communications, open source material and documents as dessbed ‘The OIG investigation is ongoing, and some questions remain. Inthe interes of transparency, howve, this report presents the foundational facts that are available a thst. Issues in dispute are noted within the text, and the OIG offers no dispositive factual of legal conclusions. The report concludes with brief OIG analysis of he five central operational decisions thatthe Heaés Deparment made with respect othe idemifid emites: (the decison o award a testing contract (i) the decision fo mclude Ansret Doroshin on the Vaccine Advisory Commie; 1) the decision 10 Mold ‘vaccination eines; the decision to provide vaccine; and 1) the decision to terminate the relationship. Policy questions sbout the Department of Pubic Health’ overall approach to vacine distribution end ministration are beyond the scope ofthis investigation ‘TABLE OF CONTENTS 1. BACKGROUND & INITIAL CONTACT I, TESTING CONTRACT AWARD. 3 Il, TESTING CONTRACT PERFORMANCE & PAYMENT. 4 IV. VACCINE ADVISORY COMMITTEE APPOINTMENT. 6 \V. AGREEMENT TO PARTNER FOR CLINICS. oe VL INTERNAL DISCORD AT PFC. r 9 VI CDC APPLICATION FOR VACCINE sn : 10 VIIL, CLINIC REGISTRATION, SIGN-UP & DATA COLLECTION. u IX. VACCINE CLINICS... = 12 X. TERMINATION OF THE RELATIONSHIP a XL ANALYSIS. 4 APPENDIX. 16 "he majority of ierviews wert of City employees and embeded contactors excep where noe inthe text. sau some sbjets were eraeued multiple uines, Andrei Dorosin has ot yt povided testinon the OG. PUBLIC REPORT 0 21000157 Ply Fighing COVID Tas 1. BACKGROUND & INITIAL CONTACT. ‘On Apail 15,2020, Philly Fighting COVID, In. (PFC) was fit incorporated.? Andrei Doroshin (Doroshin), graduate student at Drexel University, founded the group as a non-profit oxanization for ctuanitable purposes under 15 PaCS. § 5306: In public statements, Doroshin noted that he first organized PRC 1 respond othe die ned for personal protective equipment (PPE) atthe time. And, using privat funds and donations, PFC intaly focused on ‘manufacturing fae-shields for local hospitals and healthcare workers” Most of the orgarization’s crginal staff were contemporaries of Dorothin's, including some local nurses, medial stidents and engineering students* {At some point in June 2020, Doroshin oriented PFC’s operation away from the manufacturing of face Shields and turned 1 Focus on COVID-19 testing.” After obtaining et kts fom Quest agnosis, PFC ‘opened and operate an independent esting stein Fishtown atthe Fillmore Theater. There, PFC worked With medical volunteers o offer COVID-19 testing fr the local community ‘The Health Department's Chief Testing and Surveillance Office, a resident of Fshiown, became aware ofthe Fillmore Theatr testing operation through word-of-mouth and social media, and she saw the site at some point in June. The Health Department employee later reached cut to Deroshn to inquire about PFC's operation and capacity.” Doroshin provided some basic context about PFCs estirg site and asked the Chief Testing Officer about potential funding opportunities. Atte time, there was an open and public RFP for COVID-19 testing contracts, administered via the Philadelphia Mental Health Care Corporation (PMHCC).° The Health Department's Chief Testing Officer informed Dorcshin about the ‘opportunity and noted thst PFC could apply n July 8, 2020, PFC submitted a formal bid to PMHCC, requesting public funding to sypport COVID- 19 esting in Philadelphia." 2 Appendi 2 up wv. pila con/news!20219126 who e-pilh-igh + Although PEC i erated as no-pofit corporaoa under Commonweal a tt company isnot keeps March 2 2021 hips i rm * BEC slo orgenize Sond drives and administered ifluone veces a some pol, * Andes Dorin, Philly Fighting COVID,” interview, BEN Around Ply, BEN FM, Sepember 12,2020, the IRS Pub, 78 databace stows ding cm puns/2S7benin.com/pissxnly-filag-svad + the Cy mnintined map ofl texting lection o help drct residents, andthe Heal Department al EC's Filmore site ota is. pw lla govieovid estates ""PMECC ia nor profit organization at bods a conraet ‘wit the Health Deparment o assist an suppor is opzrans. The Health Department fequstly izes PMHCC to aminiter pane and contract opportune ‘hough aubstave decision-making remain with he Health Department. The Heath Deparment ws of PNICC is long-standing and primary driven by te need o keep wansaction costs low. All partes noted tht PME can conform a contact much fair and comet payments are more eal disbursed to payees, which were (he Heals Departments primary considerations when responding fo the eatly sages of he COVID pandemic append PUBLIC REPORT "OIG Case 30001 COV M1, 'TESTING CONTRACT AWARD ‘Although the contract was formally administered by PMHCC, the submissions were evaluated and scored bya team of five Health Department employees,” including the Chief Testing Officer who initiated contact with PFC. Neither Commissioner Thomas Farley (Farley) nor Deputy Commissione- Caroline Johnson (Johnson) was onthe seleti pane, sthough Dr. Farley reviewed the panel's scoesheet and ‘authorized the final awards. “The selection panel reviewed and scored the applications onthe basis of nine substantive criteria." Those: on the selection panel generally noted that cot (per test and testing capacity/volume were the primary drivers ofthese initial contact decisions; atthe time, the department soup o increase Citywide testing to roughly 5,000 per day." For the mast par, the selection pane conducted very litle independent research on the applications ~ they 4d not perform checks for thing lik insurance coverage. Mos ofthe research was limitedto simple Google searches for background on the organizations’ current operations, and many of the fems were already knovtn tothe Health Department through rio work in and around Philadelphia With respect to PFC, the panel noted that there ws significant weight given tothe fact that they already hed an upand-running testing operation, unlike some other applicants, PFC had a lab agreement in place with Quest Diagnostics, an existing location and an identified Nurse Practitioner as the organization's preseribng agent. Based primarily on these considerations, the panel approved PFC’s application and Dr. Farley later agreed. (n July 20,2020, the Health Commissioner notified Doroshin via eter that PFC was approved fo upto '5194,234 in availabe funding to conduct COVID-19 testing, and PMHCC executed a formal six-month contract shortly thereafter Although the contract did not specify the precise testing ste lorations in Philadelphia, PFC represented thatthe organization would focus on underserved communities and frontline healtheare workers. PEC was approved for up o 59 testing eventsites, with input rom the Heath Deparment sbout dates, times and specific locations. After the testing events, PPC was to submit invoices with supporting documentation, ike cost receipts and staff timesheets, in order o receive payment. A specific Health Deparment employee, who reported to the Chief Testing Office, was PEC’s primary point of contact and was tasked with reviewing/approvig ll ofthe fren invoices for payment. "The sledon pal was racially and organizational diverse According to the dpartnent’s organizational tire whe time, COVID texting waste responsiblity ofthe ‘ComuinnattGrnsy, edby the Bucci of Publ Containment Vacsne admnsstston was he maps of ‘he Division of Disease Conv led by Dr. Joon. Both ns reprisal o Dr. Fay. "*Seleton crea were: volume, target population pro, infection prevention, emunantyouesch billing sysem, safety mesures, cost per tet ably to meet RFP equrement nding infstrcture & sty or ‘pid implementation, 1 the pane! member sko noted hat they sought mos lea organization that were fair with he Pili ‘ommuniy. append PUBLIC REPORT iG Case No 96H ing COT UL, TESTING CONTRACT PERFORMANCE & PAYMENT. ‘Health Department and PMHCC employees who worked with Doroshin and other PFC representatives uring the testing period consistently described the relationship as challenging, especially early inthe process. PFC was new to City contract procedure and reportedly struggled to submit imely and complete {nvoices. Health Department aff frequently had to ite follow-up requests for supporting documents — Primarily timesheets” Deroshin, specifically, was described as unprofessional and rather aggressive with Fespect to payment tumaround, and some City staff suspected this o be indicative of a lack of finan Stability within the PPC business organization, Notably, the Health Deparment contact managers approved an initial payment to PFC of $18,000 in administrative fees. Othe esting contactors prorated tis administrative fe across the life ofthe six- ‘month tem, a8 was the Health Department's general practice. Doroshia, however, pressed the ‘department fo thie early payment to cover vome of he more immediate aff cose. 'To avoid wnnccersry interruptions in testing services the Chef Testing Officer agreed ater consukng with her supervisors. In August 2020," PEC began its work under the esting conirac although, operationally the ‘organization was sil focused onthe already-estalished Fillmore Theater stein Fshiown. Health Department representatives encouraged PFC to expand to ther locations so the organization could meet the needs of cenain underserved communities, as PEC previously agreed Inlate August, epresentatives fom th South Street Headhouse District (SSHD) leared about PEC through sacial media and reached ou via Facebook to inquire about the prospect of a testing event in Society Hill. Dealing primarily wth PFC's Chief Operating Ofier atthe ime, SSHD and PEC agred to hold walk-up and drive-up testing on September! and 3, 2020 atthe openair “Shambles” on Street south of Pine Sree. FC suecessflly held the testing evens, as scheduled, and performed roughly 200-250 tests over the vo days, SSHD, however, later Fielded a number of complaints from community members who expressed concer about PFC’s proximity (oa outdoor children's event that also took place on September 3. 'SSHD contacted the Health Department for direction about the conic, ad the Director of COVID Containment instructed the group to immediately cease testing operations at that location, The Direstr also contacted Doroshin and explained that he City of Philadelphia had not authorized testing at that Jocetion and would not reimburse PFC for any cost ascocated with those events. The Director explained ‘hat City-funded testing was tobe prioritized in undeserved areas, not Society Hill Doroshin was reportedly frustrated with his decision. PFC later posted a numberof statements on its Facebook page, riliciing the decision to cease the Headhouse Square testing even® According to hat © Some PEC invoice were reueed mil times fo clrisction. M Although he contact was frst conformed in Avge, PMC Iaer executed cone amendment — wih he Heath Department approval slow for embarement of costs incured ato he date ofthe Heal ‘Deparanen'savard lee, uly 2, 2020 Although PFC and SSHD di noi execu a formal contact PFC principals signed bility release and fished. sm insurance ceric to SSHD pie to the testing evens. OIG investigaors contcied the named insurance Cmpary ho sated that he dtd PEC policy was oot intended o cover COVID veting. Rather, secording 0 the surance company eepresenutive he poly in question Was limited isbily asi withthe manufecure te datbuton of PPE, B appendix C PUBLIC REPORT iG Case Wo. aBOIS Fr Figing COV Ts Facebook page, Councilmember Squilla mediated this dispute, and on September 15, PFC isued a sHatement together withthe Councilmember and SSHD. The joint statement noted that PFC would no Tonger operate the Headhouse Square ste but would continue to seek testing opportunities in South Philadelphia” ‘By November 2020, PPC expanded fo other testing sites across the Cy, and in late Novernber the ‘organization held» scree of mass esting events athe intersection of 6 iret and Exie Avenue in Nowth Philadelphis, in collaboration with The Latino Connection, Health Deparment emplayees credited PFC With stepping to conduct this event on shor notice, andthe testing clinic was well-received ‘Asa matter of quality conto, and consistent with Health Department practice, the department assigned sn undercover “secret shopper” to engage with PFC and sigarup fora test atone of the organization's location. This evaluation yielded mixed reviews ~the “seeret shopper” reported significant ificulty ‘wth the PFC sigr-p and registration proceses, although te actual tet was conducted without nove” A last wo other citizens reported troubling esting experiences with PFC in November?” One ‘complainant stated that PEC failed to notify her of «postive test result, which reportedly caused significant COVID exposure at her workplace and necessitated an immediate shutdown by her employer Another complainant reported that PFC never communicated the results of his test, despite ‘numerous follow-up requests and inquiries. And, although the majority of tests were conducied without complaint, there were also some public reports of intemal discord, disorganization and so-called “concierge” testing outside ofthe scheduled community events. Incarly January 2021, Health Department contract managers noted that PFC had not submited ny invoices for testing site November, and they reached out te Doroshin o inquire. Shortly thereafter, oroshin submited final invoices, noting that December 23 was the last day of any PFC testing. Upon review, Health Deparment employess idemified @ numberof discrepancies, ineluding the lack of| appropriate signatures on several timesheets and at least one PFC staff member who was reportedly in ‘wo locations at once. Based on these issues, the Health Deparment refused to pay. Doreshin protested, ane the matter itll unesolved, PFC then abruply topped COVID testing and focused instead on the distribution of vaccine. On January 10,2021, PFC posted = Facebook message to inform the public that the company decided to cease all testing in order otranstion o vaccinations. At the time, the company had fourten different ypeoming testing events alrendy scheduled forfour different locations the following week. The Health Department never received formal notice of PRC's withdrawal, and the ins testing contrac ultimately expired atthe «end of January 2021 without father activity The September 15 join statement lo sates, “PFC hs begun tas with he City of Pilsdephi o dsebuing the bighly anticipated SARS-COV-2 vaccine" Appendix C. 2 aAppendisD 2 These complains didnot surfice uni 2021, when PEC became the mubjet of sigan medi coverage > According the complainat, PEC representatives nly od her hat she had teed negative. Laer, however, ‘hey infarmed ber hatte negative rest was an ero and that she was, in fat, positive fer COVID-18. By iat, {ie the complainant had aeadreumed o work. relying on PFCs nial communication farilesvhy-d-hil he ateexpetene! hps/ wn onuanslesphilsihingecovi-povidedatchome-esingsi- bobby: fae Append PUBLIC REPORT CIS Cas Ne TOOTS Pay Figiiag COVID. Te ‘To date, PFC performed atotl of 15,968 tests and received $111,405 intotal compensation under the MECC testing contrac.” ‘With regard to data tracking al testing contractors were required to report centain demographics about the testing population served, o include identifies like race, age and geader. PFC was significantly deficient in this area, furishing demographic data for approximately 32% ofthe toa ests the company’ performed, on average.” Although other contractors were also less than 100% compliant, PFC had the lowest reporting percentage by a significant margin. IV. VACCINE ADVISORY COMMITTEE APPOINTMENT Stating in August 2020, very shorty after PFC was formally warded the testing contrac, Doroshin began soliciting meetings with Heath Department officials, including Dr. Farley, to discus the City's vaccine distribution plans and how PFC might get involved.” Although the Commissioner never met with Doroshin during this time, some members of the Health Depatmert’s testing tam (who worked with PFC as described above) connected Doroshin withthe vacine tear within the Division of Disease Control, led by Deputy Commissioner Johnson atthe time.” ‘The Health Departments vaccine team, which included several other employees who reported to Dr. Johnson, was then working o establish a Vaccine Advisory Committee (VAC). The use of sucha ‘omaitte reflected best practice inthe field and was similar tothe HHS National Vaceine Advisory Commitee the VAC was to engage various stakeholders dialogue bout the vacsine distribution plan, considering factors like timing, equity and prioritization irs” Dr. Johnson chaired the VAC and PFC was sleced to participate" around September, along with approximately 30 oer organizations and individuals throughout Philadphi.” The decision to include PFC was reporedly based on Doroshin's persistent interest inthe City's vaccine effort and the company's As noted above, some PFC testing invoices esl pening 3 dppendicF > Dovoshin ted ifficuly withthe lab, Quest Diagnostics, when Heals Deparment conact managers questioned im about th deficen. flea Lepatmen ployee who wee in comnusicton with Docshi tthe ime deserbed hn avery peste Ie Faley ted that he delegated day-to-day administration ofthe vaccine efor wo Dr. Johnson, based on ber ‘bckgrund ss an epidemiologist an experience inthe fl, unerstaning hat she aso keep hi wl informed Dr. Farley andthe vaecine lea met weekly mt i, then becky, as Dr. Farley continued 19 be more diecly ‘gvolved in esting and contact wacing efor 3 yap won as go vanes ines im 2 The Health Deparment sought advice from the VAC aboot actne planning and equitable distribation modes ‘The VAC was inept the equally changing Federal guidace and help the eparent apply tothe Cot Philadelphia, hin hls pv programs sronirrdiepe 20 cei easing abousavi19- vacche 5 Teri some dspe shout who spciclly decided wo ive PFC 1 the VAC. Dr Fae, however, confimed thot he was generally aware of he rs election and di ot hae sue wih dhe company’s inital ncn, given theft tht PFC held s etn contact * Append G PUBLIC REPORT “OIG Case Na IST ri ing COVED Te cstablthed involvement in COVID testing. Broadly, those within the Division af Disease Contol ‘envisioned thatthe vaccine administration plan would be structurally analogous tothe testing program — ‘with similar elinies and commanity evens ‘The VAC held biweekly meetings to discuss various topics, set by Dr. Johnson and er staff. Participation was strictly voluntary, and no member ofthe commie received compensation in ‘connection wih this work.” VAC member and employee accounts confirm that Doroshin was an active participant he attended many meetings and was reportedly engaged and vocal throughout. In October 2020, and later updated in November, the department submitted a drat vaccination plan tothe CCDC, which included a strategy to leverage the existing testing partners to operate vaccination sites. The plan Suggested thatthe Health Department would use mass vaccination evens, modeled afer the testing programs, and engage external organizations to focus on traditionally underserved neighborhoods and populations ‘The Commonwealth's vaccination plan, which specifically excluded Piladlphia, included an explicit seaside requirement for unafliated healthcare workers." Thais, emsyvania hospitals ouside of Philadelphi ae required to reserve a portion of any alloted vaceine for heakhcare persone! who may rot be directly affiliated withthe hosptl, Some in the Division of Disease Control thought thatthe Philadelphia ares hospitals would be resistant to his model and would insted prefer to focus on thet ‘own personnel and prionties. Accordingly, the Health Department made the policy decision to target inal vaccination clinics atthe approximately 18,000 unafiliated healthcare workers in Philadelphia, V. AGREEMENT TO PARTNER FOR CLINICS Although it i undisputed that the Health Department sought to facilitate mass clinics for unaffiliated healthcare professionals, there is some lack of larity abou the exten to which the Health Department ‘engaged with providers and medical institutions during the planning phase fortis initiative. And, to futher complicate planning, throughout Novernber and December there were many unanswered questions bout exactly when the City would receive vaccine and in what quantity. Its evident, however, tht ‘these planing discussions were wholly informal ~ mainly vie phone, email nd virwl meetings ~and outside of any structured decision-making process, Representatives fom les! hospitals and the Black Doctors’ COVID Consostium (BDC) could not specifically confirm whether Dr. Johnson or any other Health Department representative proposed or explored the prospect of holding a series of mass vaccination clini in January 2021. In interviews with (1G investigators, however, representatives from these institutions generally confirmed that they would ‘ot have been operationally ready o hold significant public vacinaion evens ofthis type without ‘extended advance notice and planning opporunity. To boot, these institutions were initlly focused on ‘vaccinating their own staff, patients and/or other target populations. The Division of Disease Consol further noe tha the VAC was a good vehicle educate community heatbeare providers about te upcoming diribuon proces, Some Hlth Deparment taf believed that cloding a mei ove ike Deroshin would lp him to eam more about he vaccination ek The VAC is sill active o date, allough PFC is no longer aprtipant. 25 The Ciy of Pilea receives dest edralfndig ad Was Uerefore responsible develop its own ‘vacination stato is! woe halh.w.entinnissascocnasins/PapesGuidnce Phas: Aaa: Pecan No AliselsFact- Sheesh PUBLIC REPORT pray Fighing COVID ne Doroshin, onthe other hand. had been expressing interest in vaccination clinics since August. He continued to solicit partnership with the Fialth Department and represented that PEC would be abe to ‘minister vaceine to the Ciy's target population. Throughout Novermber and December, Doroshin Was {in frequent contact with a umber of Health Department employees onthe vaccine tam, discussing things like dta-ecording and the mechanics of large-scale vaccination evens. Infact, Doresin even presented the Health Department with his own vacznation clic pln, as well asa proposal o conduct a Seris of large-scale events at Lincoln Financial Feld fr exactly ths purpose.” Doroshin widely pursued suppor fortis pla, but Dr. Johnson and her staff dismissed it oul-oFhand, describing it as “grandiose” snd overly ambitious (On December 23,2020, the Health Departments fmmuniztion Program Manager contacted Dorosin to discuss the prospect of holding “pilot” vaccination event. During the ensuing conversation the manager suggested varius locations to hold such an even, and staff the Divisio of Disease Contra performed some research for suitable sites. Shortly therafier, however, Doroshin secured the Conveation Center!" ‘Uhimately, Dr Johnson approved the selection of PFC forthe inital vaccination events, firs scheduled for January 8, 2021 iting the company's oveal readiness, willingness and enthusiasm for the pan" Despite the casual negotiations and representations between PPC and Health Department oficial, the department was siltaneously planning to issue a public RFP for Community COVID-19 Vaccination Clinics, essentially funding the same type of work that PFC and Doroshin sought On December 31, 2020, Dr, Johnzon emailed Doroshin this RFP ~dated December 30 ~ and included a suggested budget mount for PEC to submit” In the December 31 email. Dr. Johnson futher suggested that PFC could ‘receive reimbursement from the City, via this coriact opportaniy, for costs incured in conaecton with the upcoming Convention Center evens, already st for January 8, 2021. As publicly reported, Dr. Johnson also set similar email to atleast one other organization - the BDC.“ Unfortunately, there was an apparent lack of communication between the Health Department's COVID Containment and Disease Control groups. By November, Containment’ testing tam was well aware of DDoroshin’s reputation and there were a mimber of negative issues that were already known; including the Headhouse Square incident, billing discrepancies, questions about the company's financial solvency, data reporting deficiencies, the"secret shopper” review and Doroshn's o-epored lack of professionalism, Some employees described informal and off-the-cuff conversations about these issues, but there was inp (phadechia wtgaton toa). 22 ‘uns out bemapoUsmv we 5 Gr. Janary 7,202, the Convention Center nd Vax Popul (be newly created eoport ny) executed 2 sense agreement for as of space "Dr Frey stated hat he was generally aware of PFC's proposal to se Lincoln Finacial Field noting that Dr Johan Was dismissive of he te. Se, when he ater leamed about he Convention Cees, he was Somewhat surpried and questioned Dr. Jonson, who escent od im hat se lt comforabe with the plan — ‘est ons emporary bass. AL one pit, Dr. ohnson described hentia clincsasa "est" toevahate PFCs Performance, Farley sted ht be used Dr Joe's adgment and moved fwardwatoat arte bition Sapp. © agpendecH. 1 eine comnews chasis iahine- cid sastineaubli-healsineichson-ndes oraain 20210131 nk 4 PUBLIC REPORT TAG Ghee Ng BOOT ig COV Te never structured opportunity forthe two groups to share information bout Dorshin andlor PFC, particularly at a leadership level’? VI INTERNAL DISCORD AT PFC ‘Simultaneous to Doroshin's discussions with the Health Department about the clinics, there was also @ significant amount of organizational change within PFC:* On December 9, 2020, Doroshin incorporated ‘new entity with the Pennsylvania Department of State, "Vax Popul,” which was organized asa for profit corporation unlike PFC.*” Just pric to Thanksgiving, Doroshin approached local medical ‘actor and asked him to serve as PFCs Chief Medical Officer, knowing thatthe company needed to ‘maintain an ative affiliation with a licensed doctor in order to rezeve vaccine and bill insurance cartes. ‘The doctor iitilly agreed to serve in a volunteer capacity, nd he signed PFC's frst CDC application” far vaccine ae the Chief Madieal Officer of the company. But in later sonveratione withthe doctor Doroshin referred to his organization as "Vax Populi” and deserbed it as a for-profit venture. According tothe doctor, when he pressed Dorahin for more information about he legal sirucure ofthe firm and its ‘governing board, Droshin was evasive and unclear.” This gave the doctor pause, and on January 4, 2021, he resigned from the company and informed Doroshin acordingly. On the same day the doctor also called the Health Deparment an informed them that he had reigned from his role with PFC and would no longer serve asthe organization's Chief ‘Medical Officer. The doctor also reportedly urged the Health Department to conduct deeper vetting of PFC and Doreshin, expressing concerns abou the firm's stability and leadership. "Notably, the intial Chief Medical Officers resignation eame only four days before the rst scheduled ‘vaccination elinic wast take place atthe Convention Center. Dr Johnson and he staff acknowledged that they were aware ofthe new for-profit entity" as wel asthe doctor's departure, but one day ater Doroshin contacted ther to report that he had found a new doctor to serve as the Chief Medical Officer. ‘The Health Department confirmed tha he new doctor was, in fac, lieensed and in good standing ~ and PFC submited a revised CDC application for vaceine on January 5, identifying the new doctor 2 the ‘esponsie medical diretor* ‘Thee litle evidence to suggest that anyone at the Health Department conducted additional research or reconsidered the relationship with PFC or Doroshin afer these issues initially surfaced during the fst week of January, and the department instead moved forward with the scheduled clinics. “ Onat eat wo oscsons aff members fom the respective groups discussed PFC. But ihe Coatsamen roup feed mised comments and never arse saunchponition on he orgeization ‘en addition othe arte peered ee, there ae also untainted aecornt of cont sang PFC st, ‘eclung unspecified disagreement between the COO and Dooshin that lime led fo the COO's resignation rng theft week of January 202 Sapper “The doctor who provided a statement the OIG, was a vonter al he Filmore esting te ©The CDC application i discuseed in geaer etal in ner sewtons For example, the doco noted that Dovesisiacoasstenly represented tht te company was an IRS.approved 501(213) adr 301 (044 organization 5D Johason tated that she was ot concerned wide new “for-profit” sas, thinking that it had no legal penionl relevance 5 The new doctor deseo provide a sateen coancton with is investgaton, PUBLIC REPORT Cae Oring COT Tre VIL, CDC APPLICATION FOR VACCINE Asa matter of procedure, before any of the clinics could tke place, PPC needed to apply tothe CDC for ‘uthorization to receive nd administer vaccine” And, as noted above, PFC submited two such applications. one naming the original medical desir and a second after replacing him. Neither the Health Department nor the City of Philadelphia were parties to this agreement. Rather, Principals from PFC —namely Doroshin and the new Chief Medical Officer represented directly tothe (CDC that thee organization would safeguard, handle and administer the vaccine according to CDC uidelines and other applicable aw. ‘The CDC agreement was non-negotisble, and on December 1, 2020 the department made it publicly available online for any provide that wished to receive vaccine. A specific Heath Deparment contract, ‘employee administered these agreements between the providers and the CDC. This employee sent clectronie CDC application 1 numberof diferent healthcare provider, ineluding PFC and other VAC ‘members, and facilitated the submission of these applications tothe federal goverment via an electronic document management system, Because these agreements were external to the City, the Health Department performed litle independent vetting ofthe provides" represenations onthe CDC applications. The Health Department employee checked the Chief Medical Officer’ license and standing, and she ensured tha the providers had access tocold storage equipment. As long a those checks yielded accepiable results, which hey di for PEC, the Heath Depariment sent along the application othe CDC.* To date a total of 103 healthcare providers have followed this process and are therefore positioned to receive vaccine from the federal goverment, via the Health Department.” In aditon to PEC, other providers include a numberof lea! hospitals, universities, non-profits, medics! practices and pharmacies ‘As an overay to this administrative proces, however, the Health Department isin unilateral contol of the allocation of specifi amount of vaccine among and between the diferent providers. Thats, the City nly eceves limited quantities from the Federal government ~a small fraction of what may be needed ‘This imbalance leaves the Health Department to assign certain numbers of doses to certain providers By all accounts, there is no documented or established structure by which the Health Deparment

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