The Arizona Partnership for ImmunizationNon-Profit

Condition/Context: Although The Arizona Partnership for Immunization had established processes to ensure immunization costs were charged only to eligible award participants, these processes were not formally documented. The organization used various methods to determine participant eligibility and to verify insured or uninsured status prior to billing for immunization services. However, due to the rapid implementation period and a significant increase in immunization volume, these eligibility and verification procedures were not consistently or formally documented. Criteria or specific requirement: In accordance with the Compliance Supplement, Part 6 – Internal Control, 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. For the HRSA COVID-19 Uninsured Program, the OMB Compliance Supplement requires internal controls to ensure eligibility determinations are reviewed and approved in accordance with program requirements. Funds for reimbursement are for the cost associated with COVID-19 testing and testing-related items for individuals who did not have any health care coverage at the time of service. Cause: The Arizona Partnership for Immunization had established eligibility determination and insurance verification practices; however, these practices were not formally documented as internal controls. In addition, the compressed implementation timeline and significant increase in immunization volume limited management’s ability to timely formalize and document these controls while administering the programs and navigating State of Arizona and Health Resources and Services Administration requirements. Effect: The Organization was not in compliance with the Compliance Supplement related to establishing and maintaining internal controls over federal awards. Questioned Costs: None Repeat Finding: No Recommendation: The Arizona Partnership for Immunization should formally document its eligibility determination and insurance verification processes to ensure consistent application and compliance with award requirements. In addition, the organization should implement documentation standards to evidence eligibility determinations, particularly during periods of increased service volume, to support accurate and allowable program charges. Views of responsible officials: Management concurs with the condition. During the audit period, TAPI had operational eligibility determination and insurance verification practices in place; however, these processes were not fully documented within a consolidated and formalized policy framework. This was primarily due to the rapidly evolving operational environment associated with the State of Arizona’s COVID-19 response. TAPI closely followed eligibility and billing guidance issued by the State during this period but encountered significant operational challenges, including system limitations and intermittent downtime, which affected the ability to formally document procedures contemporaneously.