Finding 1241635 (2021-008)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2021
Accepted
2026-11-04

AI Summary

  • Core Issue: CHCC failed to provide required documentation for monthly inventory reconciliations and annual site visits, indicating poor record-keeping practices.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303(a) and VFC Policies, which mandate effective internal controls and regular monitoring of vaccine handling and eligibility screening.
  • Recommended Follow-Up: CHCC should enhance its document management and retention processes, possibly by adopting a centralized electronic system for better oversight and compliance.

Finding Text

Finding No. 2021-008 - Special Tests and Provisions - Control, Accountability and Safeguarding of Vaccine Identification of the federal program: Federal Agency: Department of Health and Human Services AL Program: 93.268 Immunization Cooperative Agreement Award Number: 5 NH23IP922587-03, 6 NH23IP922587-03, 6 NH23IP922587-02 Criteria or specific requirement (including statutory, regulatory or other citation): In accordance with 2 CFR 200.303(a), the recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Vaccine for Children Program (VFC) Policies and Procedures at the State/Local Immunization Program section 5.2.7 states that CHCC is required to conduct monthly reconciliation of the vaccination records which includes the vaccine inventory, patient screening forms, vaccine administered log sheet and the temperature log sheet. Additionally, VFC Policies and Procedures at the State/Local Immunization Program section 4.1 states that visits must be conducted on an annual or as per need basis which evaluates the program’s adherence to VFC program requirements, including appropriate vaccine handling, storage, and ordering procedures. CHCC is required to perform sampling of patient records to verify eligibility screening and the administration of VFC vaccine only to eligible children. Condition: 1. CHCC did not provide all sampled monthly inventory reconciliations. 2. CHCC did not provide all sampled annual site visit reports. Cause: CHCC’s current document maintenance and retention control and procedure is not designed effectively. Effect or potential effect: CHCC is in noncompliance with the applicable Special Tests and Provisions - Control, Accountability and Safeguarding of Vaccine. Questioned Costs: There are no questioned costs as the finding is non-monetary. Context: 1. For ten (or 71%) of fourteen monthly provider inventory reconciliations selected for testing, CHCC did not provide the supporting documentation. 2. For six (or 86%) of seven providers selected for testing, CHCC did not provide the annual site visit reports and the related supporting documentation that evidences that CHCC is monitoring the provider’s proper storage of vaccines and reviewing provider medical records for eligibility screening. Identification as a repeat finding, if applicable: Finding No. 2020-010. Recommendation: CHCC should improve its records management and document retention controls to ensure that documentation is available for oversight and audit purposes. Management may consider implementing centralized electronic storage and system-based retention procedures (such as the database functionality of its new financial management system). Views of Responsible Officials: CHCC concurs with the finding. To address this finding, the Immunization Program conducts the following reconciliation of vaccination records as follows: Vaccination records: daily entries of vaccination records are captured through the patient encounter form for all providers administering vaccinations. Data Entry Assistants and Program Assistants are responsible for entering the vaccinations based on the form. The Immunization Information Systems (IIS) team are responsible for ensuring data quality elements are complete on the form and reflected on the WebIZ system. Patient screening forms: also known as the patient encounter form is the paper-based document in which patient demographics and vaccination data elements are recorded upon visit for all providers. Data Entry Assistant and Program Assistant capture demographic and input vaccines an individual is to receive for the visit. The vaccinator then inputs vaccination data elements (lot number, manufacturer, site, route, etc.) to be inputted into the registry, WebIZ. Temperature log: utilized to document the vaccine storage unit temperature based on the thermometer reading and logged at the start and end of each workday, as well as after hours and weekends/holidays. The VFC Coordinator and Security team logs the temperatures on a daily, routine basis. Vaccine inventory: monitored weekly by the Logistics Technician via spreadsheet and tracked using the registry WebIZ for overall vaccine inventory management. Inventory is reported to CDC by the Program Manager every 14 days. Vaccine wastage from all providers is submitted to the program at the first week of each month for the previous month reporting period. Overall wastage reporting is done monthly to CDC. A summary report of FY2021 vaccine transactions on the CNMI Immunization Registry, WebIZ was submitted via spreadsheet format under, “Vaccine Inventory Reports” Views of Responsible Officials, continued: Additionally, the CHCC has conducted the following steps to strengthen that annual site visits for VFC providers are completed and documented appropriately to evaluate adherence to the VFC program requirements: - Provided training to the staff member assigned/responsible (VFC Coordinator) for conducting site visits - Worked with CDC Subject Matter Experts to ensure that data systems for site visit findings/reporting were accessible to the VFC Coordinator. Training on the system was also provided to the VFC Coordinator. This system is cloud based and accessible to anyone provided access. Therefore, should staff turnover occur, access to prior reports and the system for submitting new site visit reports will continue to be accessible to the organization and to team members who will take on the responsibility. - Ensure that Position Description for the VFC Coordinator clearly specify responsibilities for implementing the VFC Program in accordance with VFC Operations Guide, which outlines the requirements for annual provider compliance site visits, including the sampling of patient records to verify eligibility screening and administration of VFC vaccine only to eligible children. - Entries of vaccine reconciliation documentation such as vaccine inventory (orders, transfers, and wastages) are accessible on the registry, CNMI WebIZ, as well as routine reporting to CDC VtrckS Site visits were suspended per the CDC Project Officer during that time period due to the COVID-19 response. E-mail communication from the CDC Project Officer is attached. The Program continued to continuously monitor VFC Providers were maintaining proper storage of vaccines and reviewing medical records for eligibility screening despite not conducting a formal site visit.

Corrective Action Plan

Finding No.: 2021-008 AL Program: 93.268 Immunization Cooperative Agreement Area: Special Tests and Provision Control, Accountability and Safeguarding of Vaccine Questioned Costs: -0- Contact Person(s): Program Manager Corrective Action Plan: CHCC concurs with the finding. To address this finding, the Immunization Program conducts the following reconciliation of vaccination records as follows: Vaccination records: daily entries of vaccination records are captured through the patient encounter form for all providers administering vaccinations. Data Entry Assistants and Program Assistants are responsible for entering the vaccinations based on the form. The Immunization Information Systems (IIS) team are responsible for ensuring data quality elements are complete on the form and reflected on the WebIZ system. Patient screening forms: also known as the patient encounter form is the paper-based document in which patient demographics and vaccination data elements are recorded upon visit for all providers. Data Entry Assistant and Program Assistant capture demographic and input vaccines an individual is to receive for the visit. The vaccinator then inputs vaccination data elements (lot number, manufacturer, site, route, etc.) to be inputted into the registry, WebIZ. Temperature log: utilized to document the vaccine storage unit temperature based on the thermometer reading and logged at the start and end of each workday, as well as after hours and weekends/holidays. The VFC Coordinator and Security team logs the temperatures on a daily, routine basis. Vaccine inventory: monitored weekly by the Logistics Technician via spreadsheet and tracked using the registry WebIZ for overall vaccine inventory management. Inventory is reported to CDC by the Program Manager every 14 days. Vaccine wastage from all providers is submitted to the program at the first week of each month for the previous month reporting period. Overall wastage reporting is done monthly to CDC. A summary report of FY2021 vaccine transactions on the CNMI Immunization Registry, WebIZ was submitted via spreadsheet format under, “Vaccine Inventory Reports” Additionally, the CHCC has conducted the following steps to strengthen that annual site visits for VFC providers are completed and documented appropriately to evaluate adherence to the VFC program requirements: - Provided training to the staff member assigned/responsible (VFC Coordinator) for conducting site visits - Worked with CDC Subject Matter Experts to ensure that data systems for site visit findings/reporting were accessible to the VFC Coordinator. Training on the system was also provided to the VFC Coordinator. This system is cloud based and accessible to anyone provided access. Therefore, should staff turnover occur, access to prior reports and the system for submitting new site visit reports will continue to be accessible to the organization and to team members who will take on the responsibility. - Ensure that Position Description for the VFC Coordinator clearly specify responsibilities for implementing the VFC Program in accordance with VFC Operations Guide, which outlines the requirements for annual provider compliance site visits, including the sampling of patient records to verify eligibility screening and administration of VFC vaccine only to eligible children. - Entries of vaccine reconciliation documentation such as vaccine inventory (orders, transfers, and wastages) are accessible on the registry, CNMI WebIZ, as well as routine reporting to CDC VtrckS Site visits were suspended per the CDC Project Officer during that time period due to the COVID-19 response. E-mail communication from the CDC Project Officer is attached. The Program continued to continuously monitor VFC Providers were maintaining proper storage of vaccines and reviewing medical records for eligibility screening despite not conducting a formal site visit. Responsible Official: Program Manager, Program Administrator, and Director of Public Health Services Proposed Completion Date: On-going

Categories

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions Eligibility Reporting

Other Findings in this Audit

  • 1241631 2021-004
    Material Weakness Repeat
  • 1241632 2021-005
    Material Weakness Repeat
  • 1241633 2021-006
    Material Weakness Repeat
  • 1241634 2021-007
    Material Weakness Repeat
  • 1241636 2021-009
    Material Weakness Repeat
  • 1241637 2021-010
    Material Weakness Repeat
  • 1241638 2021-011
    Material Weakness Repeat
  • 1241639 2021-012
    Material Weakness Repeat
  • 1241640 2021-013
    Material Weakness Repeat
  • 1241641 2021-014
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.498 PROVIDER RELIEF FUND AND AMERICAN RESCUE PLAN (ARP) RURAL DISTRIBUTION $5.21M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $5.01M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $3.63M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $3.62M
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $3.51M
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $1.92M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $1.02M
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $1.00M
93.870 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $869,181
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $687,143
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $596,181
93.104 COMPREHENSIVE COMMUNITY MENTAL HEALTH SERVICES FOR CHILDREN WITH SERIOUS EMOTIONAL DISTURBANCES (SED) $528,358
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $462,618
93.982 MENTAL HEALTH DISASTER ASSISTANCE AND EMERGENCY MENTAL HEALTH $438,257
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $432,556
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $422,872
93.236 GRANTS TO STATES TO SUPPORT ORAL HEALTH WORKFORCE ACTIVITIES $400,328
93.217 FAMILY PLANNING SERVICES $343,159
97.088 DISASTER ASSISTANCE PROJECTS $341,416
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $337,474
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $328,371
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $290,825
93.251 EARLY HEARING DETECTION AND INTERVENTION $240,262
93.665 EMERGENCY GRANTS TO ADDRESS MENTAL AND SUBSTANCE USE DISORDERS DURING COVID-19 $214,228
93.377 PREVENTION AND CONTROL OF CHRONIC DISEASE AND ASSOCIATED RISK FACTORS IN THE U.S. AFFILIATED PACIFIC ISLANDS, U.S. VIRGIN ISLANDS, AND P. R. $179,144
93.788 OPIOID STR $168,753
93.912 RURAL HEALTHCARE SERVICES PROGRAMS $147,842
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $143,060
93.165 GRANTS TO STATES FOR LOAN REPAYMENT $125,000
93.817 HOSPITAL PREPAREDNESS PROGRAM (HPP) EBOLA PREPAREDNESS AND RESPONSE ACTIVITIES $123,359
10.855 DISTANCE LEARNING AND TELEMEDICINE GRANTS $120,717
93.504 FAMILY TO FAMILY HEALTH INFORMATION CENTERS $119,371
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $69,403
93.103 FOOD AND DRUG ADMINISTRATION RESEARCH $45,076
93.917 HIV CARE FORMULA GRANTS $44,846
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $43,612
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $41,888
93.314 EARLY HEARING DETECTION AND INTERVENTION INFORMATION SYSTEM (EHDI-IS) SURVEILLANCE PROGRAM $26,630
93.946 COOPERATIVE AGREEMENTS TO SUPPORT STATE-BASED SAFE MOTHERHOOD AND INFANT HEALTH INITIATIVE PROGRAMS $5,817
16.575 CRIME VICTIM ASSISTANCE $5,696
93.644 ADULT MEDICAID QUALITY: IMPROVING MATERNAL AND INFANT HEALTH OUTCOMES IN MEDICAID AND CHIP $3,089
93.495 COMMUNITY HEALTH WORKERS FOR PUBLIC HEALTH RESPONSE AND RESILIENT $732