Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Organization's special reports submitted to the Department of Health and Human Services were not reviewed and approved by a separate individual outside of the preparer. Context: Key line items were tested on the Period 4 special reports submitted to the Department of Health and Human Services. 2 reports were tested, which both lacked appropriate approval. Response: Copa Health, Inc will continue to monitor and review internal control systems and implement new policies and/or procedures when necessary or applicable