OMB Circular A-133 Immunization Compliance Supplement

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

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

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

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

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

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. 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.govkel9@cdc.gov • Immunization Compliance Supplement Victor Negron Program Operations Branch, Immunization Services Division (404) 639-6221 vmn1@cdc.gov