OMB Circular A-133 Immunization Compliance Supplement

1. 1 Program Managers� Meeting New Orleans, Louisiana November 19, 2008 OMB Circular A-133 Immunization Compliance Supplement

2. 2 Discussion Topics OMB Circular A-133 Immunization Compliance Supplement Compliance Supplement Changes Challenges Revisited Links and POCs

3. 3 OMB Circular A-133 Issued pursuant to federal law (P.L. 98-502 and P.L. 104-156) Subtitle: Audits of States, Local Governments, and Non-Profit Organizations Threshold = $500,000 Frequency = annual (in some cases, biennial)

4. 4 OMB Circular A-133 A-133 internal control provisions require auditors to plan and perform �testing of internal control � relevant to compliance requirements for each major program.� Major programs are determined using a four-step approach described in OMB Circular A-133, �.520. Not all major programs need to be audited every year, e.g., low-risk major program.

5. 5 Immunization Compliance Supplement Sets forth internal control audit requirements for major programs as defined in OMB Circular A-133, �.520. Changes reviewed/approved through ISD, PGO, HHS, and OMB. Consists of four sections: I Program Objectives II Program Procedures III Compliance Requirements IV Other Information Minor (non-substantive) changes to sections I and II. Significant changes to section III, sub-section N. Special Test and Provisions; and to section IV.

6. 6 Compliance Supplement Changes(Section III, Sub-Section N. Special Tests and Provision)

7. 7 Compliance Supplement Changes(Section III, Sub-Section N. Special Tests and Provision)

8. 8 Compliance Supplement Changes(Section IV, Other Information)

9. 9 Challenges Revisited Complying with the �old� immunization compliance supplement was difficult under �new� operating procedures for funds management and centralized vaccine distribution. Most issues addressed by updating section IV of the compliance supplement. Some of the resolved issues included: With DA vaccine no longer obligated to grantees, should DA vaccine be included as part of the value of vaccine received? If yes, where would auditors/grantees get value of vaccine received data? Are vaccinating providers (LHDs and private providers) considered subrecipients? If yes, how would the provisions of A-133 apply given centralized vaccine distribution. If no, how would auditors/grantees account for vaccine shipped directly to vaccinating providers? Should the value of DA vaccine shipped directly to vaccinating providers be included as a grant expenditure for purposes of determining audit coverage as a major program? Should the value of DA vaccine shipped directly to vaccinating providers be included in the Schedule of Expenditures of Federal Awards (SEFA)?

10. 10 Links and POCs Links OMB Circular A-133 http://www.whitehouse.gov/omb/circulars/a133/a133.pdf Immunization Compliance Supplement http://www.whitehouse.gov/omb/circulars/a133_compliance/08/hhs.pdf POCs OMB Circular A-133 Gary Koontz Dalton Leonard Procurement and Grants Office Procurement and Grants Office (770) 488-2842 (770) 488-2816 gck0@cdc.gov kel9@cdc.gov Immunization Compliance Supplement Victor Negron Program Operations Branch, Immunization Services Division (404) 639-6221 vmn1@cdc.gov