Why We Did This Inspection
On October 7, 2023, Hamas—a U.S.-designated terrorist organization—invaded southwest Israel, killing more than 1,200 people and seizing 253 hostages. Following Hamas’ cross-border attack, Israel declared war on the group. Israeli strikes have since killed over 65,000 Palestinians in Gaza. Critical shortages in available medical stock and treatment needs have made procurement of pharmaceuticals and other medical commodities a priority need for Gaza’s health system.
USAID’s Bureau for Humanitarian Assistance (BHA) activated its Gaza response in October 2023, working with International Medical Corps (IMC) to provide health sector programming in Gaza. IMC, which by June 2025 had received more than $72 million for health sector programming, was USAID’s primary implementer for the procurement and distribution of pharmaceuticals and other medical commodities in the Gaza Strip.
We conducted this inspection to determine the extent to which USAID (1) ensured pre-award requirements related to the supply chain of pharmaceuticals and other medical commodities for Gaza were fulfilled; and (2) monitored award implementation related to the supply chain of pharmaceuticals and other medical commodities for Gaza.
What We Found
USAID ensured IMC fulfilled pre-award requirements for pharmaceuticals and other medical commodities. USAID’s Automated Directives System and BHA’s Emergency Application Guidelines and supplemental guidance contained pre-award requirements for pharmaceuticals and other medical commodities funded by the Agency. These included quality checks for pharmaceuticals vendors and details about proposed health supply chains. BHA used these requirements in concert with its application review process to ensure the quality of pharmaceuticals at the point of manufacture.
USAID monitored IMC activities in Gaza but relied on IMC to monitor components of its health supply chain in Jordan, Egypt, and other locations. Due to the war, BHA did not have any staff in Gaza to conduct direct monitoring of IMC’s activities. As such, BHA was kept informed about the implementation of activities related to pharmaceuticals and other medical commodities through required programmatic reporting included in IMC’s award terms. In addition, BHA used implementer meetings and a third party to monitor the implementation of IMC’s activities inside Gaza. However, BHA relied on IMC to self-monitor the procurement, storage, and transportation of pharmaceuticals and other medical commodities as they moved through the supply chain on the way to Gaza. This occurred because USAID’s guidance on the roles and responsibilities for overseeing implementer-managed supply chains was unclear. Absent clear roles and responsibilities for staff overseeing implementer-managed humanitarian supply chains, including the procurement, transportation, storage, and distribution of assistance, BHA did not have a full understanding of all components of IMC’s health supply chain for its Gaza response.
What We Recommend
As the administration determines the future of foreign assistance, we suggest decision makers consider developing clear roles and responsibilities for staff overseeing implementer-managed humanitarian supply chains, including the procurement, transportation, storage, and distribution of U.S.-government funded humanitarian assistance.