The Guam Office of Public Accountability (OPA) released a flash report reviewing 19 healthcare employment contracts executed by the Guam Memorial Hospital Authority (GMHA) from January 2022 through December 2023, identifying what it called deficiencies in contract processing and policy compliance. The review found that none of the contracts appeared to have been routed to the Office of the Attorney General or the Office of the Governor for required review and approval under then-existing policy, and several agreements lacked clear funding certifications and effective dates.
The report stated that GMHA’s Human Resources department handled the contracts under Policy No. A-LD700, which in its July 2021 version required legal and gubernatorial clearance before contracts could become enforceable. The OPA also noted changes in GMHA policies that took effect in mid-2025, after initial audit inquiries began, including the adoption of Policy No. A-HR900 in June 2025 and revisions to Policy No. A-LD700 in August 2025 to remove outside signature requirements.
GMHA strongly rejected the OPA’s conclusions in two management responses dated September 19 and October 2, 2025. The hospital asserted that the OPA relied on outdated policies and misinterpreted internal procedures, arguing that not all signatures cited by the OPA were required for every type of contract. GMHA further stated that its updated policies supersede prior versions, rendering the OPA’s findings “moot” and disputing what it called a lack of deference toward the hospital’s interpretation of its own regulations.
The OPA maintained that policy revisions made in 2025 do not apply retroactively to contracts executed in 2022 and 2023 and said further auditing of physician compensation agreements is ongoing. The report emphasized that no audit procedures were used to verify compensation totals, and a more extensive review will follow. Full copies of GMHA’s responses and the OPA report are available at opaguam.org.