The roles of certain key federal officials initially involved in the advisory board’s review of the dose reconstructions may not have been sufficiently independent and actions were taken to replace these officials. Nonetheless, continued diligence by HHS is required to prevent such problems from recurring as new candidates are considered for these roles. Initially, the project officer assigned responsibility for reviewing the monthly progress reports and monitoring the technical performance of the contractor was also a manager of the NIOSH dose reconstruction program being reviewed. In addition, the designated federal officer for the advisory board, who is responsible for scheduling and attending board meetings, was the director of the dose reconstruction program being reviewed. In response to concerns about the appearance of conflicting roles, the director of NIOSH replaced both of these officials in December 2004 with a senior NIOSH official not involved in the NIOSH program under review. The contractor and members of the board told us that implementation of the contract improved after these replacements were made. With regard to structural independence, we found it appropriate that the contracting officers, who are responsible for managing the contract on behalf of the advisory board, have been federal officials with the Centers for Disease Control and Prevention (CDC), NIOSH’s parent agency. The contracting officers do not have responsibilities for the NIOSH program under review and are not accountable to its managers. Members of the advisory board helped facilitate the independence of the contractor’s work by playing the leading role in developing and approving the initial statement of work for the contractor and the independent cost estimate for the contract. The progress of the contracted review of NIOSH’s site profiles and dose reconstructions has been hindered by the complexity of the work. Specifically, in the first 2 years, the contractor spent almost 90 percent of the $3 million that had been allocated to the contract for a 5-year undertaking. Various adjustments have been made in the review approach in light of the identified complexities, which were not initially understood. However, further improvements could be made in the oversight and planning of the review process. First, the contractor’s expenditure levels were not adequately monitored by the agency in the initial months and the contractor’s monthly progress reports did not provide sufficient details on the level of work completed compared to funds expended. The monthly report for each individual task order was subsequently revised to provide more details but developing more integrated data across the various tasks could further improve the board’s ability to track the progress of the overall review. Second, while the advisory board has made mid-course adjustments to the contractor’s task orders and review procedures, the board has not comprehensively reexamined its long-term plan for the overall project. The board revised the task orders for the contractor several times, in part to reflect adjustments made as the board gained a deeper understanding of the needs of the project. Nonetheless, the board has not reexamined its original plan for the total number of site profile and dose reconstruction reviews needed, and the time frames and funding levels for completing them. Third, there is still a gap with regard to management controls for the resolution of the findings and recommendations that emerge from SC&A’s review. The advisory board developed a six-step resolution process to help resolve technical issues between the contractor and NIOSH, and this process uses matrices to track the findings and recommendations of the contractor and advisory board. However, NIOSH currently lacks a system for documenting that changes it agrees to make as part of this resolution process are implemented. With regard to reviewing special exposure cohort petitions, the advisory board has asked for and received the contractor’s assistance, expanded its charge, and acknowledged the need for the board to review the petitions in a timely manner. The board has reviewed eight petitions as of October 2005, and the contractor assisted with six of these by reviewing the site profiles associated with the facilities. The contractor will play an expanded role by reviewing some of the other submitted petitions and NIOSH’s evaluation of those petitions and recommending to the advisory board whether the petitioning group should be added to the special exposure cohort. The contractor will also develop procedures for the advisory board to use when reviewing petitions. While NIOSH is generally required by law to complete its review of a petition within 180 days of determining that the petition has met certain initial qualification requirements, the advisory board has no specified deadline for its review of petitions. However, the board has discussed the fact that special exposure cohort petition reviews have required more time and effort than originally estimated and that the advisory board needs to manage its workload in order to reach timely decisions. Credibility is essential to the work of the advisory board and the contractor, and actions were taken in response to initial concerns about the independence of federal officials in certain key roles. Nonetheless, it is important for HHS to continue to be diligent in avoiding actual or perceived conflicts of roles as new candidates are considered for these roles over the life of the advisory board. The advisory board’s review of site profiles and dose reconstructions has presented a steep learning curve for the various parties involved. These experiences have prompted the board to make various adjustments to the contractor’s work that are intended to better meet the needs of the review, such as the establishment of a formal six-step resolution process that increases transparency. Nonetheless, further improvements could be made to the oversight and planning of the contracted review. Even though the advisory board has made numerous midcourse adjustments to the work of the contractor, the board has not comprehensively reexamined its long- term plan for the project to determine whether the plan needs to be modified in light of the knowledge gained over the past few years. In addition, while the contractor’s monthly reports were modified to provide more detailed expenditure data, the lack of integrated and comprehensive data across the various tasks makes it more difficult for the advisory board to track the progress of the overall review or make adjustments to funding or deliverables across tasks. Finally, without a system to track the actions taken by NIOSH in response to the findings and recommendations of the advisory board and contractor, there is no assurance that any needed improvements are being made. We are making three recommendations to the Secretary of HHS. To assist the advisory board meet its statutory responsibilities, we recommend that the Secretary of HHS (1) direct the contracting and project officers to develop and share with the advisory board more integrated and comprehensive data on contractor spending levels compared to work completed and (2) consider the need for providing HHS staff to collect and analyze pertinent information that would help the advisory board comprehensively reexamine its long-term plan for assessing the NIOSH site profiles and dose reconstructions. To ensure that the findings and recommendations of the advisory board and the contractor are promptly resolved, we recommend that the Secretary of HHS direct the Director of NIOSH to establish a system to track the actions taken by the agency in response to these findings and recommendations and update the advisory board periodically on the status of such actions. We provided a draft of this report to HHS, the contractor, and all the members of the advisory board for comment. We received comments from HHS, the contractor, and four individual members of the advisory board. The comments from the four members of the board represent the views of these individuals and not an official position of the advisory board. HHS agreed with GAO’s recommendations to provide more integrated and comprehensive data to the advisory board and said that it will consider the need to provide staff to help the advisory board reexamine its overall plan for assessing NIOSH site profiles and dose reconstructions. With regard to the third recommendation, HHS stated that a system is already in place to track actions taken by the agency in response to advisory board recommendations in letters from the board to the Secretary of HHS. HHS added that matrices used in conjunction with the six-step resolution process outline the contractor’s concerns, NIOSH’s response, and the actions to be taken. However, we believe that these matrices do not provide sufficient closure with regard to tracking the actions NIOSH has actually implemented in response to advisory board and contractor findings and recommendations. For example, in some of the matrices, the advisory board has made numerous recommendations that NIOSH perform certain actions to resolve various issues, but there is no system in place to provide assurance that these actions have in fact been taken. Thus, we continue to see a need for this recommendation. Some individual advisory board members who provided comments expressed concerns about our recommendations, although differing in their reasons. One individual board member expressed concern about the recommendations to provide more integrated and comprehensive data to the advisory board or to provide staff to help in reexamining the overall review plan, suggesting that these changes might not be very helpful. We still believe that these recommendations are necessary to ensure that the advisory board has more complete information to better oversee the review as well as a long-term plan for completing the review; hence we did not revise the recommendation. Another individual board member suggested that a system be established to track the advisory board’s recommendations rather than the contractor’s recommendations since it is these that should be of greater concern. While GAO believes it is important to track the resolution of the board’s recommendations, it also important to track the resolution of the contractor’s recommendations, and we therefore revised the wording of our recommendation to reflect this position. HHS, the contractor, and individual advisory board members took issue with statements in the report about the contractor being over budget and behind schedule. While they agreed with GAO’s assessment that the review process got off to a slow start, they thought that the report did not provide sufficient information about the various factors that complicated or led to an expansion of work for the contractor, the revisions to the contractor’s task orders, and the performance of the contractor with respect to the revised task orders. For example, commenters pointed out that in some instances, the contractor had to review a site profile more than once after NIOSH had revised the site profile to include additional information.