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~epublic of tbe ~lJilippin e~

COMMISSION ON AUDIT

MEMORANDUM
No.: :lod!- OIS
Date~ 1 U JUN 2021

TO All Assistant Commissioners, Directors, Supervising Auditors,

Division Chiefs, Audit Team Leaders, Audit Team Members,
and All Other Concerned Personnel

SUBJECT: Audit Guidelines on the COVID-19 Vaccination Program of the

Government

1. Rationale

Republic Act (RA) No. 11525, the COVTD-1 9 Vaccination Program Act of 2021, was
approved on February 26, 202 1 to implement the State policy of adopting an integrated
approach to health development; and make essential soc ial services available to all people at
an affordable cost. The COVID-1 9 Vaccination Program includes provision of ancillary
supplies and services necessa1y for the storage, transport, deployment, and administration of
the COVID-19 vaccines. The objectives of the COVID-19 Vaccination Program are as follows:

a. Address the adverse impact of COVID-1 9 through the procurement and

administration of safe and effective COVID-19 vaccines by the national
government through the Department of Health (DOH) and the National Task
Force (NTF), and other duly constituted authorities and instrumentalities;

b. Source and procure safe and effective COVTD- 19 vaccines through the DOH
and the NTF, either through themselves jointly or in cooperation with any
national government agency (NGA) or instrumental ity, or local government
unit (LGU);

c. Recognize the experimental nature of COVID-19 vaccines available in the

market and compensate the serious adverse effects (SAEs) arising from the use
of COVID-19 vaccine, experienced by people inoculated through the COVID-
19 Vaccination Program; and

d. Create a COVID-19 National Vaccine Indemnity Fund to be admin istered by

the Philippine Health Insurance Corporation (Ph iiHealth) to compensate
persons encountering SAE.

For its part, the Government Procurement Policy Board (GPPB) approved on March 25,
2021 GPPB Circular No. 02-2021 , the Guidelines for Emergency Procurement under RA No.
11525 or the COVID-19 Vaccination Program Act of202 1. The Guidelines cover the mode of~

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procurement, documentary requirements, and advance payment under Sections 3 and 4 of RA
No. 11525.

Alongside the GPPB Guidelines, this Commission provides these audit guidelines fo r
the uniform guidance of the audit teams tasked to audit the COVID-19 Vaccination Program.
These audit guidelines include the implementing guidelines issued by government agencies
related to the COVID-1 9 Vaccination Program, such as the training of health care workers.

2. Coverage

The audit guidelines cover the COVID-19 Vaccination Program on the following:

1. COVID-19 vaccines, procured through the Department of Health (DOH) and the
Nationa l Task Force Against COVID-19 (NTF);

2. Ancillary supplies and services or other goods and services procured for the storage,
transport, deployment, and administration of COVID-1 9 vaccines as defined by the
DOH; and

3. Completeness and accuracy of the accounting and documentation of the distribution

of vaccines, and the accuracy of the reporting therefor, as well as the existence of
the listed vaccine-recipients.

3. General Audit Guidelines

1. The Supervising Auditor, Department of Budget and Ma nagement (DBM), shall

obtain the list and copies of the COVID-19 vaccination-re lated Special Allotment
Release Orders (SAROs) and Notices of Cash Allocations (NCAs) generated from
the electronic budget (eBudget) System of the DBM. The Supervising Auditor o f
DBM sha ll provide the list and copies of SAROs and NCAs to the Supervising
Auditors of the agencies, through their respective C luster Directors. Funding sources
for COVID-19 vaccine deployment program per Philippine National Deployment
and Vaccination Plan for COVID-1 9 Vaccines are as follows:

Amount
Objective of Procurement Source
(in Php)

Unprogrammed Funds in 2021 GAA

Vaccines (Foreign multilateral and bilateral loans; 70 billion
domestic loans)

Logistics and other supplies 2021 GAA (DOH) 2.5 billion

Bayanihan II in relation to RA No. 11520

10 billion
on Continuing Appropriations

TOTAL AVAILABLE FUNDS 82.5 billion

2. The Audit Teams sha ll obtain an understanding of the laws and regulations relating
to the COVID-19 Vaccina tion Program, including RA No. 11 525 and its
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 Implementing Rules and Regulations (IRRs) as well as the applicable accounting
and auditing rules and regulations. The Audit Teams shall evaluate how these laws
and rules may impact on the auditees' oversight processes and controls. Further, the
Audit Teams shall identify and assess risks of material misstatements relating to
increased risks of fraud and legal exposure due to:

a. new or amended and relaxed regulatory requirements;

b. incentives/pressures on management which may result in management bias on
valuation and accounting estimates particularly on donated vaccines and
supplies; and
c. ineffective execution of vaccination strategies and activities, among others, in
order to determine the appropriate audit response.

3. The audit shall be conducted in accordance with International Standards of Supreme

Audit Institutions (ISSAis) issued by the International Organization of Supreme
Audit Institutions (INTOSAI) to which the Commission on Audit is an active
member.

4. Copies of COVTD-19 vaccine program references and related issuances shall be

maintai ned by the Audit Teams for ready information and reference. A partial list of
References is attached as Annex C hereof.

5. The audit of the COVID-19 Vaccination Program covering the procurement of

COVID-19 vaccines and ancillary supplies and services or other goods and services,
shall be guided by RA No. 11 525; GPPB Circular No. 02-2021; and DOH and NTF
Joint Administrative Order (JAO) 2021-0001 , the IRR ofRA No. 11525. The Audit
Teams shall take notice of the date of effectivity, coverage, conditions, and
requirements of the law, especially on the retroactive application under Sections 3
and 4 ofRA No. 11525 from January 1, 2021 ; and Section 5 from November 1, 2020.

6. The Audit Teams shall be cogni zant that the DOH and the NTF are authorized under
Section 3 ofRA No. 11525, either jointly through themselves or in cooperation with
any National Government Agency (NGA) or instrumentality or Local Government
Unit (LGU), to procure COVID-1 9 vaccines, including ancillary supplies and
services necessary for their storage, transpmt, deployment, and administration.

7. The Audit Teams shall take note that the mode of procurement of COVID-19
vaccines and ancillary supplies and services or other goods and services necessary
for the storage, transportation, deployment and administration of COVID-19
vaccines shall be through the Negotiated Procurement under Emergency Cases
modality pursuant to Section 53(b) ofRA No. 9184 or the "Governm ent Procurement
Reform Act" and Section 53.2 of the 2016 Revised IRR of RA No . 9184, GPPB
Circul ar No. 02-2021 and other relevant vaccine procurement guidelines of the
GPPB, DOH-NTF JAO No. 2021-0001 , and other issuances that may be issued
relating thereto.

8. In view of the pressing need to facilitate the immediate procurement of COVID-19

vaccines, the Audit Teams shall take note that th e documenta1y requirements under
the Negotiated Procurement (Emergency Cases) pursuant to Section 53(b) of RA
No. 9 184 may be dispensed with to apply the requirements identified by DOH and
the NTF during negotiations, and those mentioned in GPPB Circular No. 02-202 1

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 and other relevant vaccine procurement guidelines of the GPPB, and DOH and NTF
J AO No. 2021-0001 and other issuances of these agencies relating thereto.

9. The Audit Teams shall not consider as "splitting of contract" the procurement from
several sources by the Procuring Entity (PE) if one supplier is not able to provide the
required quantity.

10. For procurement ofCOVID-19 vaccines by the LGUs, the Audit Teams shall verify
compliance with the following limitations provided under Section 4 of RA No.
11525:

10.1 Provinces, cities and municipalities may procure only in cooperation with the
DOH and the NTF through a multiparty agreement which shall include the
DOH, NTF and the relevant suppliers of COVID-19 vaccines;

10.2 The LGU s shall procure vaccines to a maximum of seventy-five percent (7 5%)
of their target population, subject to adjustment by the Inter-Agency Task
Force for the Management of Emerging Infectious Diseases (IATF -EID)
when there is sufficient supply of vaccines as determined by the DOH and the
NTF; and

10.3 The request of the LGUs to procure vaccines has been reviewed and approved
by the DOH and the NTF.

11. The Audit Teams shall be aware that issuance of the Notice of Award (NOA) and
Notice to Proceed (NTP) after the award and/or the signing of contract or any similar
agreements are not required for the procurement of COVID-19 vaccines and
ancillary supplies and services.

12. The Audit Teams shall verify if all documents relating to the award of contract for
the procurement of COVID-19 vaccines and ancillary suppl ies and services are
immediately submitted to the Head of Procuring Entity (HoPE), through the Bids
and Awards Committee (BAC).

13. The Audit Teams shall check if the multi-party agreement:

13. 1 was signed by the DOH and the NTF by themselves jointly or in cooperation
with any NGA or instrumentality or LGU or private entity authorized to
procure COVID-19 vaccines;
13.2 contained the roles and responsibilities of all parties involved; and
13 .3 had terms and conditions that are not disadvantageous to the government.

14. The Audit Teams shall take note that the procurement, importation, donation,
storage, transport, dep loyment and administration of COVID-1 9 vaccines are
exempt from custom duties, value-added tax, excise tax, donor's tax, and other fees,
pursuant to Section 11 ofRA No. 11525, beginning January 1, 2021, and pertinent
rules and regulations that were and/or may be issued by the Bureau of Internal
Revenue (BIR) and/or the Bureau of Customs (BOC).

15. The Audit Teams shall verify if payments for procured COVID-1 9 vaccines and
ancillary supplies and services were:

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 a. charged to the funds appropriated therefor;
b. approved by the authorized officials;
c. supported with complete documentation;
d. compliant with applicable laws, rules and regulations; and
e. recognized properly in the books of accounts.

16. The Audit Teams shall conduct a holistic audit to cover procurement, assessment of
the completeness of the accounting and documentation of the distribution, accuracy
of reports of implementing agencies (lAs), and existence of the listed vaccine-
recipients. The list of vaccine-recipients submitted by the lAs must be sex-
disaggregated showing gender statistics (i.e. women, children, senior citizens,
persons with disabilities, indigenous peoples, and other vulnerable sectors).

17. The Audit Teams shall also examine the list of sex-disaggregated vaccine-recipients
submitted by the lAs as to classification of COVID-19 vaccination priority
population groups. The Audit Teams shall take into consideration the LGUs '
prerogative to formulate their own vaccine recipient list and implement their own
operational procedures, in accordance with the national policies and procedures
issued by the DOH, to expedite and enhance the efficiency of the inoculation process
and prevent the spoilage of vaccines.

18. The Supervising Auditor, House of Representatives (HOR), shall request an

electronic copy of the monthly reports submitted by the Vaccine Czar, the DOH and
the IATF-EID to Congress on the implementation of the COVID-19 Vacc ination
Program, which shall include:
a. agreements made by PEs pursuant to RA No. 11525 and its IRRs;
b. date of the delivery;
c. storage and deployment of vaccines;
d. number of persons inoculated; and
e. other relevant information as may be required by Congress.

The Supervising Auditor, HOR, shall provide the Audit Teams, through their Cluster
Directors, a copy of the monthly reports.

19. The Audit Teams shall issue an Audit Observation Memorandum (AOM) for any
deficiencies noted and subsequently, a Notice of Suspension (NS) or Notice of
Disallowance (ND) or Notice of Charge (NC), if warranted.

20. The results of the audit of the COVID-19 Vaccination Program shall be incorporated
in the Annual Audit Report of the agency and/or in a separate Complian ce Audit
Report.

4. Specific Audit Guidelines

1. Procurement ofCOVID-19 Vaccines

The Audit Teams shall verify if:

1.1 There was coordination prior to the conduct of negotiations among the DOH, /
NTF, and the PE, which funded the procurement; ~

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 1.2 There were funds available in the budget of the PE to cover the procurement of
COVID-19 vaccines, as certified by the appropriate official of the PE;

1.3 The procurement of the COVID-19 vaccines is included in the Annual

Procurement Plan (APP) or in any of its revisions or Supplemental APPs duly
approved by the HoPE or his/her authorized official;

1.4 The approved APP and/or Supplemental APP were posted in the PE's website
or at a conspicuous place in the premises of the PE and the GPPB online portal
within 30 days after its approval ;

1.5 When the procurement of COVID-19 vaccines was not included in the approved
APP or any of its revisions or Supplemental APPs, the Audit Teams shall check
if:
1.5.1 The appropriate office in the PE validated that there were funds in its
budget to cover the procurement; and
1.5.2 The Supplemental APP adding/covering the vaccine procurement was
approved before the processing of payment.

1.6 The preparatory documents and requirements for the negotiatiOn s in the
procurement of COVID-19 vaccines, as detennined by the DOH and NTF, were
based on market research of available suppliers, manufacturers or distributors;

1.7 The suppliers, manufacturers and distributors submitted all eligibility

documents, formal offer or bid documents and other negotiation documents
which were identified and deemed necessary by the DOH and the NTF; and
compliant with the rules of the Food and Drugs Administration (FDA) pursuant
to Section 6 ofRA No. 11 525;

1. 8 Th e DOH and/or the NTF had informed the PE of the results of the negotiations,
including submission of any additional documents required prior to the
execution of contract or any similar agreements. This is to ensure the timely,
effective and effici ent execution of the contract, which may be in the form of a
tripartite agreement, supply agreement, advance market commitment, purchase
order or any similar arrangements as may be prescribed by the DOH and the
NTF;

1.9 The authmized official of the HoPE who directly participated in the negotiations
or signed the contract or any similar agreements for the procurement ofCOVID-
19 vaccines had no conflict of interest; and

1.10 The vaccines procured have valid Emergency Use Authorization (EUA) issued
by the FDA pursuant to FDA Circular No. 2020-036 and have positive
recommendation from the Health Technology Assessment Council (HTAC), if
the FDA-issued Certificate of Product Registration (CPR) is not available.

2. Procurement of Ancillary Supplies and Services or Other Goods and Services

Necessary for the Storage, Transport, Deployment, and Administration of
COVID-19 Vaccines ~
The Audit T earns shall:

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2. 1 Verify if the PE, in conducting negotiated procurement for anc illary supplies
and services or other goods and services necessary for the storage, transport,
deployment, and administration of COVID-1 9 vaccines, complied with the
procedures provided under GPPB Circular No. 02-2021.

2.2 Be guided by the definition or determination by the PE on what constitutes

ancillary supplies and services or other goods and services necessary for the
storage, transport, deployment, and administration of COVID-1 9 vaccines, in
accordance with the definition provided by the DOH.

2.3 Take note that the PEs are encouraged to delegate the following matters to
ensure the efficient and timely procurement of ancillary supplies and services
under RA No. 11 525:

2.3. 1 The awarding and/or signing of contract or any simi lar agreements for the
procurement of anc illary supplies and services, except to those where
conflict of interest exists, such as the BAC Chairperson, members or
person authorized to negotiate the bidding;

2.3.2 The authority to directly negotiate and procure ancill ary supplies and
services with a legally, technically and financiall y capable supplier,
manufacturer, distributor, or service provider to the end-user unit or any
appropriate bur eau, committee, support or procuring unit; and

2.3.3 Direct negotiation by the BAC with a legally, technically and financi ally
capable supp lier, manufacturer, distributor or service provider, when such
delegation is not made.

2.4 Veri fy compliance by the PE with the following procedural guidelines

prescribed under GPPB C ircular No. 02-202 1:

2.4.1 Preparation of project requirements:

a. The end-user or implementing unit of the PE prepared the project

requirements, with the fo llowing details:

• Approved Budget for the Contract (ABC);

• Name and Detai ls of the Ancillary Supplies and Services;
• Name of the supplier, manufacturer, distributor or service provider;
and
• Other relevant information that may be required by the National
Vaccination Program and other related issu ances issued by the
DOH and the NTF.

b. The proj ect requ irements and contract packaging were based on the
PE 's needs as well as the capabi lity of the supp lier, manufacturer,
distributor or service provider as determined through initial market
scanning or scoping accompanied by appropriate supporting documents j1
identifying the ancillary suppli es and services (e.g., Technical L--\..
Specifications) to be procured.

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 c. Specifications for the procurement of ancillaty supplies and services
were based on relevant characteristics, functionality, and/or
performance requirements.

d. There was no required form used in the preparation of the project

requirements.

e. The project requirements were submitted to the BAC or duly authorized

bureau, committee, support or procuring unit for the conduct of
procurement.

2.4.2 Updating of the APP:

a. The BAC or end-user unit or any other appropriate bureau, committee,

suppmt or procuring unit has recommended to the HoPE or his/her duly
authorized official the updating of the APP to cover the procurement of
ancillary supplies and services. The appropriate office of the PE
validated if there were funds in its budget to cover the procurement;

b. In view of the urgent necessity to procure Ancillary Supplies and

Services, the PE has commenced with the procurement even without an
approved APP and the appropriate office in the PE validated that there
were funds in its budget to cover for the same;

c. The APP was approved before the processing of payment and the
approved APP was posted on the PE's website or at a conspicuous place
reserved for the purpose in the premises of the PE and the GPPB online
portal within thirty days (30) from its approval; and

d. The approval of the APP by the HoPE or by his/her duly authorized

official covering the procurement using Negotiated Procurement
(Emergency Cases) pursuant to GPPB Circular No. 02-2021 and the
DOH-NTF JAO No. 202 1-0001, effectively confirms the existence and
veracity of the ground(s) relied upon in resorting thereto.

2.4.3 Submission of documentary requirements:

Procurement/rom domestic suppliers/manufacturers/service providers

a. PEs already maintaining a bidder's updated file, whether through the

Philippine Government Electronic Procurement System (PhilGEPS)
Certificate ofRegistration and Membership or its own records, shall not
require its resubmission.

b. Otherwise, PEs shall require one copy of the following documentary

requirements:

• Mayor's or Business Permit;

• Omnibus Sworn Statement (OSS), which shall be an original copy
("Appendix 1" ofGPPB Circular No. 02-2021); and
• Income Tax Returns (Annual Income Tax Return of the preceding
tax year) or Busines~ Tax Returns (Value Added Tax or Percentage ?.
 Tax Return covering the previous six months), for projects with an
ABC above PhP 500,000.00.

c. Bid security is not required for this procurement. PEs have the option to
require or dispense with the submission of p erfmmance and/or wan·anty
securities depending on the nature of the procurement project.

d. Suppliers, manufacturers, distributors or service providers may submit

their documentary requirements in printed copies or by electronic mail
or facsimile.

e. The use of digital signature or similar means may be used m all

procurement-related documents.

f. PEs are allowed to accept a copy of the recently expired Mayor's or

Business Permit and other documents showing proof of application for
renewal, such as the Official Receipt and payment for the renewal will
suffice, subject to submission of the Mayor's Permi t after award of
contract but before payment.

g. As a general rule, the OSS shall be submitted at any time before award
of contract However, an unnotarized OSS may be accepted subject to
submission of notarized copy after award but before payment.

Procurement from foreign suppliers/manufacturers/service providers

h. For foreign suppliers, manufacturers, distributors, or service providers,

the equivalent documents in their jurisdiction, for the documents
required herein, would suffice consistent with Section 23.2 of the 2016
Revised IRR ofRA No. 9184.

2.5 Verify if the PE, through the BAC or duly authorized end-user unit or any other
appropriate bureau, committee, support or procuring unit, conducted direct
negotiation with a legally, technically and financially capable supplier,
manufacturer, distributor or service provider after the project requirements were
completed and the APP had been updated or the budget had been confitmed, as
the case may be.

2.6 Verify if the BAC or the duly authorized end-user unit or any other appropriate
bureau, committee, support or procuring unit, recommended to the HoPE or
his/her duly authorized official the award of the contract to th e supplier,
manufacturer, di stributor or service provider, after validation of the requi red
documents in 2.4 above.

2. 7 Check if the HoPE or his/her duly authorized official immediately entered into
contract with the supplier, manufacturer, distributor, or service provider, subject
to Section 41 of RA No. 91 84 or the Reservation Clause.

3. Posting Requirements

3.1 The Audit Teams shall check if the fo llowing information were posted on the
PE's website or at a conspi cuous place in the PE's premises and on the GPPB
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 Online Portal, within thirty (30) days after award or execution of a contract or
any similar agreements. For procurements covered by the retroactive provision
under Sections 3 and 4 ofRA No. 11525, the posting shall be made within thirty
(30) days after the effectivity of GPPB Circular 02-2021.

a. ABC or company budget;

b. Name and details of the ordered or procured COVID -19 vaccrnes or
Ancillary Suppl ies or Services;
c. Name of the supplier, manufacturer, distributor or service provider;
d. Amount of advance payment made and the reasons given by the supplier,
manufacturer, distributor, or service provider; and
e. Amount of contract as awarded or agreed upon.

3.2 The Audit Teams shall note that the PEs shall nominate their authorized
principal and alternative representatives who shall be provided access for
posting the requ ired procurement information on the GPPB Online Portal. A
copy of the agency or company identification number (ID) showing the name
and position, as well as the email address of the said authorized representatives
shall be endorsed by the BAC C hairperson or appropriate officer to the GPPB,
through GPPBonl ineregistration@gppb.gov.ph.

3.3 The foregoing posting requirements shall be in addition to the posting

requirements specified in Section IV.1.4 and Section IV.2.4.2.c.

4. Fund Transfers

4.1. The audit at the Source Agency (SA) shall focus on the validity or propriety of
fund transfers made, as well as efficiency of submission of liquidation reports.
The utilization of the funds received by Implementing Agencies (lAs) shall be
audited by the Audit Teams assigned thereat as to validity, propriety and
completeness of documents. The results of the audit made by the Audit Teams
ofiAs shall be submitted to the Audit Teams assigned to the SA

4.2. The Audit Teams of both the SA and IA shall coordinate in the reconciliation of
the accounts in the books of these agencies.

4.3. The Audit Teams shall verify whether the fol lowing guidelines were observed
by the agencies in fund transfers:

4.3.1. A Memorandum of Agreement (MOA) shall be entered into by the SA

and the IA for the undertaking by the latter of the project of the former.
The MOA shall provide the requirements for project implementation and
reponing.
4.3.2. The check shall be issued in the name of the lA for deposit to the tmst
account in its authorized government depository bank. The lA shall issue
an official receipt to acknowledge the fund transfer.
4.3 .3. Recording of fund transfer: (a) If the MOA provides a condition that the
fund transfer shall be spent for a specific purpose and any excess shall be
returned to the SA, the IA shall recognize the receipt of the fund as asset
at its fa ir value with a corresponding liabi li ty, while the SA shall
recognize a receivable corresponding to the fund transfer; or (b) If the
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 MOA does not provide condition, the IA shall recognize the receipt of
the fund as asset at its fair value with a corresponding revenue, while the
SA shall recognize an expense corresponding to the fund transfer.
4.3.4. The lA shall maintain a separate subsidiary record and bank account that
is opened; and shall return to the SA any unused balance upon completion
ofthe project, if stipulated in the MOA.
4.3.5. The SA shall draw a Journal Entry Voucher (JEV) to take up the
liquidation reports of the IA. The amount to be taken up in the liquidation
in the RCI shall be net of the cash advances granted by the IA to its
accountable officers.

4.4. The Audit Teams shall check the following documentary requirements for fund
transfers to lAs:

4.4.1. Transfer from Source Agency

a. Obligation Request and Status (ORS), Budget Utilization Request

and Status (BURS), or any equivalent document signed by the budget
officer showing that there is available or approved and obligated
budget for the purpose, and a Certificate of Availabi lity of Funds
(CAF) signed by the accounting official showing that funds have been
appropriated;
b. Copy ofMOA;
c. Approved Project Expenditures or estimated expenses indicating the
project objective and expected output;
d. For Government-Owned and Controlled Corporations (GOCCs),
Board Resolution ratifying the MOA in case of fund transfers not
incorporated in the Corporate Operating Budget (COB) and/or
beyond the signing authority of the Agency Head;
e. For LGUs, authorization by local Sanggunian for the Local Chief
Executive to enter into contract;
f. Certification by the Accountant that funds previously transferred to
the IA has been liquidated, and accounted for in the books; and
g. Copy of the OR issued by the IA to the SA acknowledging receipt of
funds transferred

4.4.2. The IA utilized the funds received from the SA in accordance with the
MOA and fully supported by the following documents:

a. Copy ofMOA;
b. Copy of OR upon receipt of funds transferred
c. Expenditure/transaction documents; and
d. Copy of OR issued by the SA evidencing refund by the IA of the
unexpended/ unutilized balance of the fund transfer

4.4.3. Recording by the SA of the liquidation by the IA shall be based on the

following:

a. RCis certified correct by the Accountant and duly approved by the

Head of the lA; and

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 b. Copy of the OR issued by the SA for the refund by the IA of the
unexpended/unutilized balance of the fund transfer duly recorded in
the Cash Receipt Journal

5. Payment

5.1. Common Documentary Requirements for Advance and Final/Full Payments

a. Authenticated photocopy of the APP or Supplemental APP thereto approved

by the HoPE or his/her authorized representative;
b. Original copy of the duly approved contract/tripartite agreement/supply
agreement/purchase order;
c. Proof of Payment (Invoice, Official Receipts, or Letters of Credit);
d. ORS, BURS, or any equivalent document signed by the budget officer
showing that there is avai lable or approved and obligated budget for the
purpose, and CAF signed by the accounting official showing that funds have
been appropriated for the contract;
e. CPR or, if unavailable, EUA from FDA; and
f. Proof of posting of the required documents specified in Section TV.3

5.2. Advance Payment

5.2.1 Pursuant to Sections 3 and 4 ofRA No. 11 525, the Audit Teams shall allow
advance payments up to the full cost of the contract price notwithstanding
Section 338 ofRA No. 7160 (Local Government Code of 1991), Section
88 of Presidential Decree (PD) No. 1445 (Government Auditing Code of
the Philippines), and other applicable laws, subject to the following
conditions:

a. to cover the procurement of vaccines and ancillary supplies and

services or other goods and services necessary for the storage,
transport, deployment, and adm inistration of COVID-19 vaccines as
defmed by the DOH; and
b. when such advance payment is required by the suppliers,
manufacturer, or distributor.

5.2.2 The Audit Teams shall check that in making advance payment, the DOH
and the NTF, as well as all PEs have ensured that such payment did not
constitute illegal, irregular, unnecessary, excessive, extravagant, or
unconscionable expenditures; or uses of government funds and
properties, as defined under existing accounting and auditing rules.

5.2.3 The Audit Teams shal l verify if the amount of advance payment made by
the PE was agreed upon and the reasons therefor were posted in
accordance with paragraph 3.1.d, and supported b y the following
documents:

a. Copy of the approved contract which allows advance payment; and

b. Proof of Payment (Invoice, Official Receipts or Letters of Credit)

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5.3. Final/Full Payment

For Vaccines

5.3.1 The Audit Teams shall validate if payments or disbursements for vaccines
are in accordance with the price and payment terms and conditions agreed
upon in the contract or any similar agreements, and if these are supported
by the fo llowing documents:

a. Original copy of Manufacturer' s/Supplier's Delivery Receipt and

Invoice Receipt/Commercial Invoice or equivalent showing the item
description, quantity, batch/lot number, manufacturing and expiry
date, unit and total value, contract/purchase order (PO) number, duly
signed by the supplier or his/her authorized representative, and
indicating receipt of items delivered by the authorized official of the
PE;
b. Inspection and Acceptance Report (JAR) sign ed by the authorized
DOH Inspection and Acceptance Committee;
c. Other documents as required under DOH DM No. 2021 -0053 (Interim
Guidelines on the Shipment and Acceptance of the COVID-19
Vacc ines and Ancillary Immunization Commodities) dated January
28, 2021 , such as:

• Bill of Lading or Airway Bill, Packing List, and Batch Release

Certificate;
• Authorization letter to DOH-accredited Broker for the processing
and release of shipment;
• Undertaking documents for duties and taxes, exemption
documents, and BOC documents such as Single Administrative
Document and Revised Declaration on Valuation;
• Approved Request Schedule of Deli very (RSD) and supporting
requirements as per checklist required by the FDA; and
• If vaccines are delivered to RTTM: PO, Certificate of Delivery,
Certificate of Analysis, CPR, Lot Release Certificate, and Safety
Data Sheet

For anci llaty supplies and services or other goods and services for the storage,
transport, deployment, and administration of COVID- 19 Vaccines

The Audit Teams shall validate/verify/examine:

5.3.2 If payments or disbursements for ancillary suppli es and services or other

goods and services necessary for the storage, transport, deployment and
administration of COVID-19 vaccines are in accordance with the price
and payment terms and conditions agreed upon in the contract or any
similar agreements. They shall check if such payments or disbursements
are supp01ted by the following documents:

13
 a. For LGUs, authority from DOH and NTF to directly procure ancillary
supplies and services necessary for the storage, transport, deployment
and administration of COVID-1 9 vaccines through negotiated
procurement under emergency cases;
b. Original copy of Manufacturer's or Supplier's Delivery Receipt and
Invoice Receipt/Commercial Invoice or equivalent as described under
Section IV.5.3.l.a;
c. lAR signed by the authorized personnel of the PE;
d. Property Acknowledgement Receipt for equipment and Inventory
Custodian Slip for semi-expendable supplies and equipment;
e. Warranty Certificates;
f. For medical devices and equipment in vaccination sites or posts:
• Certificate of good manufacturing practice from FDA; and
• Batch Release Certificate from FDA;
g. Certificate of Exclusive Distributorship, if applicable;
h. Brochures/samples/photographs of articles/items, if applicable; and
1. Other documents as required under DOH DM No. 2021 -0053 (Interim
Guidelines on the Shipment and Acceptance ofthe COVID-19 Vaccines
and Ancillary Immunization Commodities).

5.3.3 If payments to cold chain storage facilities and third party logistics
management providers were based on services rendered subject to the
agreements between the contracting parties, such as brokerage, storage,
handling, and distribution.

5.3.4 If the following documentary requirements were submitted for warehouses

or hubs rented for the storage of the vaccines:

a. Lease agreement duly signed by the HoPE or his/her authorized

representative and the lessor, and notari zed;
b. Documents evidencing selection and negotiation for the leased real
property;
c. Request for payment from the lessor;
d. Bill or Statement of Account issued by the lessor; and
e. Pictures, plans and other documents relevant to the leased property.

5.3.5 The following documents for the payments or disbursements relative to

the training of Health Care workers in the storage and/or administration of
the vaccines:

a. Budget estimates approved by the Head of Agency;

b. Schedule of training approved by the Head of Agency; and
c. Documents evidencing the training expenses incurred.

5.3 .6 The propriety and validity of expenses incurred and payments made for
the trainings on vaccine administration and adverse effects following
immunization (AEFI) management by the DOH through its Center for
Health Development (CHD) and partner agencies, as fo llows:

a. Specialist clinical training for vaccinator staff including medical and

allied medical staff, such as licensed pharmacists and midwives, who
14
 complement or supplement the current health workforce in
administering the vaccines, and ski lled medical technologists and other
skilled laboratory technicians who conduct the preliminary diagnostics
prior to vaccine administration; and
b. Induction and orientation training for a ll staff working in vaccination
sites.

5.3.7 The propriety and necessity of the payments made relative to the design,
development, deployment, monitoring, and evaluation of the Vaccine
Infotmation Management System (VIMS); as we ll as the supporting
documentaty requirements prescribed under COA Circular No. 2012-00 1
dated June 14,201 2, as applicable.

5.3.8 The payments relating to information and educational campaign (IEC)

activities conducted by the DOH, Presidential Communications
Operations Office, Philippine Information Agency, and LGUs for social
mobilization and community engagement, including the production of
IEC materials (pamphlets with frequently asked questions [FAQs], video
explainers, etc.) are in accordance with the NDVP and DTLG
Memorandum Circular (MC) No. 2021 -019 dated February 17, 2021; and
are supported with the documentary requirements prescribed in COA
Circular No. 2012-001 dated June 14, 20 12.

5.3.9 The completeness and authenticity of documentary support for the

payments for services relating to waste management and disposal wh ich
include waste transport, waste storage and destruction, healthcare waste
treatment, and final disposal facility, including but not limited to:

a. Construction of concrete vault to serve as final disposal for syringes

and vials (The vault must be constructed with concrete walls and slabs
with a minimum size of lm x l m x 1.8m.); and
b. Hiring of service of a DENR-accredited waste transporter, to transport
all the hazardous waste generated during the vaccination to the final
treatment and disposal facil ity.

5.3.1 0 The compliance of disbursements for waste disposal with the following
regulati ons on healthcare waste management:

a. DOH Hea lthcare Waste Management Manual 4th edition (Ap:ril2020)

Annex A. Infection Prevention and Control Practices of DOH DM No.
2020-0072, otherwise known as the "Interim Gui delines for 20 19
Novel Coronavirus Acute Respiratory Di sease (20 19-nCoV ARD)
Response in Hospitals and Other Health Facilities."
b. DOH DM No. 202 1-0031, enti tled "Interim Guidelines on the
Management of Health Care Wastes Generated from COVID-1 9
Vacci nation."

15
6. Audit of the Completeness of Accounting and Reporting of the Receipt and
Distribution of Vaccines Acquired through Procurement and Donations

The Audit Teams shall:

6.1. Verify if all vaccines procured and received as donations are properly and
completely accounted for, and that control mechanisms against spoilage,
wastage, or expiration are implemented.

6.2. Require from the DOH/LGUs/PEs all information/documentation necessary to

monitor and evidence the receipt and distribution of vaccines procured and
received as donation as well as of ancillary supplies procured. These documents
include the following:

a. Contracts or POs or any similar agreements;

b. Deed of donation;
c. Inspection and Acceptance Reports which should indicate the expiration
dates of the supplies received;
d. Distribution reports for the vaccines or supplies/goods procured or received
as donations with the schedule of inoculations;
e. Master list of the names and profiles of the residents to be vaccinated under
the COVID-19 Vaccination Program;
f. Master list of the vaccinated individuals indicating the date of inoculation,
sex, age, category, occupation and other required information.

6.3. Require from the DOH/LGUs/PEs an Inventory Report or its equivalent, which
includes the number of vaccines or supplies/goods procured and/or received as
donation, indicating the following:

a. dates of receipt and expiration dates;

b. quantity and cost of: vaccines or supplies issued or distributed for
inoculation, wastage or spoilage, and remaining balance of vaccines and
supplies;
c. dates of issuance and inoculation.

The Audit Teams shall validate from the Inventory Report the remaining
undistributed vaccines as to its valuation and recording.

6.4. Conduct physical inventory periodically to ensure that the remaining vaccines
or supplies are duly secured and maintained in the storage facili ty in accordance
with the standards issued by the DOH; and that the actual quantities as well as
expiration dates tally with the Inventory Report submitted by the LGU/PE. The
Audit Teams shall see to it that this audit activity shall not hamper the
immediate distribution of the vaccines and ancillary supplies.

6.5. Compare the master list of residents for vaccination duly approved by concerned
agency officials with the actual number of vaccine recipients per Inoculation
List to verify the accuracy of the Inventory reports and the completeness of the
accounting of the distribution and utilization by the DOH/LGU/PE of the
vaccines/anci llary supplies and other goods.

16
6.6. Verify delays, if any, in the distribution and scheduled inoculation and the
causes or reasons for wastage or spoilage; and compare the number of
individuals vaccinated with the number of vaccines distributed and reported
used, taking into consideration the number of doses received for each vaccine
brand, to account for vaccine spoilage or losses.

6.7. For vaccines administered by the LGUs, determine the source of funding thereof
whether procured by the National Govemment or by the LGU through tripartite
agreement. For those funded by the National Government, check if the LGUs
complied with the science and evidence-based terms and conditions of
deployment, and prioritized the needs of the following groups: healthcare
workers; senior citizens; adults with comorbidities; frontline personnel in
essential services, including uniformed personnel and teachers; indigent
population; and other priority groups as may be thereafter identified by the
IATF.

6.8. For LGU-funded vaccine procurements, the local health officials shall be
allowed to formulate their own vaccine recipient list and implement their own
operational procedures in accordance with the national po licies and procedures
issued by the DOH, such as the Philippine National Deployment and
Vaccination Plan for COVTD-19 Vaccines and National Vaccine Operations
Center advisories, if it will expedite and enhance the efficiency of the
inoculation process and prevent spoilage of vaccines.

6. 9. Refer to the concemed Audit Director before any action is taken, any perceived
violation of the prioriti zation of vaccine recipients, to ensme consistency of
audit action with the objective of the Vaccination Program which is to "Address
the adverse impact of COV/D-19 through the procurement and administration
of safe and ff(ective COVID-1 9 vaccines". The audit team must bear in mind
that the Vaccination Program is a matter of pub li c health, and actual vaccination
of the popul ace, including non-Fil ipinos in the Philippines, is the primordial
goal; consequently, actual vaccination in violation of any prioritization, as a
rule, should not result in a disallowance of the cost of the vaccine, without
prejudice to any admin istrative li ability for such violati on.

6.10. Determine if in the delivery of COVID-19 vaccines to the facilities of their

choice, the LGUs or PEs contracted the services of a Third-Party Logistics
management provider or provided LGU -owned transportation in line with
existing relevant DOH and other government policies.

6. I 1. Review which vaccination sites were used to determine observance of the DOH
DM No. 2021-0 116 or the "Interim Guidelines on the Identification and
Utilization of COVID-1 9 Vaccination Sites".

6.12. Validate if the DOH or LGUs maintained a database of actual residents

vaccinated for record purposes and future reference upon any possible adverse /
reaction on the recipients. t---1

17
Effectivity

This Memorandum shall have retroactive application pursuant to Sections 3, 4, 5, and 11

of Republic Act No. 11525.

. ~ ·. Commissi<:>n on 1\udit
~ J O Hir e or the Chairperson

111111 11111111111111 1111

21-29~5060~1300

18
 Annex A

Definition of Terms
1. Ancillary supplies- those necessa1y for the administration of the COVID-19 vaccines such
as, but not limited to needles, syringes (auto-disabed, mixing), safety collector boxes,
alcohol prep pads, surgical mask, face shields, gloves, and other personal protective
equipment.

2. Coronavirus Disease 2019 (COVID-19)- refers to a disease caused by the Severe Acute
Respiratory Syndrome Coronavirus 2 (SARS-CoV -2).

3. COVID-19 Vaccination Program- refers to the response of the National Government in

addressing the adverse impact of COVID-19 through the delivery and administration of
both procured and donated COVID-19 vaccines, management of AEFis and
indemnification as covered under Republic Act 11525.

4. Emergency Use Authorization (EVA) - an authorization issued by the Food and Drug
Administration for unregistered drugs and vaccines in a public health emergency. The
EUA is not a CPR or a marketing authorization.

5. Procuring Entity - refers to any branch, constitutional commission, or office, agency,

department, bureau, or instrumentality of the government, including, state universities and
colleges, government owned and/or -controlled corporations, government financial
institutions, and LGUs procuring goods, consulting services and infrastructure projects,
and lease of goods and real estate, including humanitarian organizations and private
entities, among others, authorized to procure COVID-19 vaccines as well as goods and
services necessary for their storage, transport, deployment and administration.

19
 Annex B

Table of Acronyms
ABC Approved Budget for the Contract
AEFI Adverse Events Following Immuni zation
AOM Audit Observation Memorandum
APP Annual Procurement Plan
BAC Bids and Awards Committee
BOC Bureau of Customs
BURS Budget Utilization Request and Status
CAF Certificate of Availability of Funds
CHD Center for Health Development
COB Corporate Operating Budget
COVID-19 Coronavirus Disease 2019
CPR Certificate of Product Registration
DENR Department of Environment and Natural Resources
DILG Department of Interior and Local Government
DOH Department of Health
DBM Department of Budget and Management
EO Executive Order
EUA Emergency Use Authorization
FAQ Frequently Asked Questions
FDA Food and Drugs Administration
GAA General Appropriations Act
GAD Gender and Development
GOCC Government Owned and Controlled Corporation
GPPB Government Procurement Policy Board
HOR House of Representatives
HoPE Head of Procuring Entity
HTAC Health Technology Assessment Counci l
lAs Implementing Agencies
IATF-EID Inter-Agency Task Force for the Management ofEmerging
Infectious Diseases
IAR Inspection and Acceptance Report
ID ldentification Card
IEC Information and Education Campaign
INTOSAI International Organization of Supreme Audit Institutions
IRR Implementing Rules and Regulations
ISSAis International Standards of Supreme Audit Institutions
JAO Joint Administrative Order
JEV Joumal Ent_ry Voucher
LGU Local Government Unit
MOA Memorandum of Agreement
NC Notice of Charge
NCA Notices of Cash Allocation
nCoV ARD Novel Coronavirus Acute Respiratory Disease
ND Notice of Disallowance
NDVP Philippine National Depl o~ent and Vaccination Plan
NGA National Government Agency
20
NOA Notice of Award
NS Notice of Suspe nsion
NTF National Task Force
NTP Notice to Proceed
OR Official Recei pt
ORS Obligation Request and Status
ass Omnibus Sworn Statement
PD Presidential Decree
PE Procuring Entity
PhilGEPS Philippine Government Electronic Procurement System
PO Purchase Order
RA Republi c Act
RCI Report of Checks Issued
RER Reimbursement Expense Receipt
RlTM Research Institute for Tropical Medicine
RSD Request Schedule of Delivery
SA Source Agency
SAEs Serious Adverse Effects
SAROs Special Allotment Release Orders
SARS-CoV-2 Severe Acute Respiratory Syndrome Coronavirus 2
SA Source Agency
VIMS Vaccination Infmmation Management System

21
 Annex C

References
Issuance Date Title/Particulars
COA Circular No. June 14, 20 12 Prescribing the Revised Guidelines and
20 12-001 Documentary Requirements for Common
Government Transactions
COA C ircular No. April 2 1, 202 1 Temporary relaxation in the application of
2020-009 certain provisions of COA Circular No.
2014-002 dated April 15, 2014 and COA
Memorandum No. 2014-009 dated August
28, 20 14 in areas subject to quarantine during
the period of the State of Calamity declared
under Proclamation No. 929, dated March 16,
2020
DILG Memorandum February 17, 2021 Guidelines on the Implementation ofDemand
CircularNo. 2021-019 Generation and Communication Activities in
Support to the National COVID-19 Vaccine
Deployment Plan
DOH Department February 3, 2020 Interim Guidelines for 2019 Novel
Memorandum No. Coronavirus Acute Respiratory D isease
2020-072 Response in Hospitals and Other Health
Faci li ties
DOH Department January 18, 2021 Interim Guidelines on the Management of
Memorandum No. Health Care Wastes Generated from COVTD-
2021 -0031 19 Vaccin ation
DOH Department February 23, 202 1 Department of Health 's Strategic Plan for
Memorandum No. COVID-19 Vaccination (202 1-2023) and
2021-009 National Strategic Policy Framework for
COVID-19 Vaccine Deployment and
Immunization
DOH Department January 28, 2021 Interim Guidelines on the Shipment and
Memorandum No. Acceptance of the COVID-19 Vaccines and
2021-0053 Ancillary Immunization Commodities
DOH Healthcare Apri l 2020
Waste Management
Manual, 4lh Edition
DOF-NTF Joint March 26, 202 1 Implementing Rules and Regulations of
Administrative Order Republic Act No. 11 525 known as" An Act
202 1-0001 Establishing the Coronavirus Disease 2019
(COVID-19) Vaccination Program
Expediting the Vaccine Procurement and
Administration Process Providing Funds
therefor, and for Other Purposes
GPPB Resolution January 20,202 1 Approving the Issuance of a Letter to the
No. 01-2021 Inter-Agency Task Force for the
Management of Emerging Infectious
Diseases and to the Covid-1 9 Vaccine
Cluster Asking Clarifications on the
Procurement ofCovid-19 Vaccines
22
 GPPB Resolution February 3, 202 1 Approving the Issuance of a Resolubon
No. 02-202 1 Seeking Clarifications on the Intended Role
of the Procurement Service-Department of
Budget and Management in the
Implementation of the Philippine National
Deployment and Vaccination Plan for
COVID-1 9 Vaccines in Relation to the
Request of the Department of Health to
Include Covid-19 Vaccines in the List of
Common Use Supp li es and Equipment and
Incorporate Such Clarifications to the Letter
to the Inter-Agency Task Force for the
Management of Emerging Infectious
Diseases and the Covid- 19 Vaccine Cluster
GPPB Resolution March 25, 202 1 Approving the Issuance of a Circular on the
No. 06-2021 Guidelines for Emergency Procurement
Under Republic Act no. 11 525 or the
COVID-1 9 Vaccination Program Act of202 1
GPPB Circular No. March 25, 2021 Guidelines for the Procurement of
02-202 1 Corona virus Disease 20 19 Vaccines and its
Anci llary Supplies and Services or Other
Goods and Services Authorized Under
Repub lic Act 11525 or the COVID- I 9
Vaccinati on Act of2021
The Philippine January 2021
National Deployment
and Vaccination Plan
for COVID -1 9
Vaccines
PD No. 1445 June 11 , 1978 Government Auditing Code of the
Philippines
RA No. 7 160 October I 0, 1991 Local Government Code of 199 1
RA No. 9 184 July 22, 2002 Government Procurement Reform Act
RA No. 1151 8 December 28, General Appropriations Act FY 2021
2020
RA No. 11525 February 26, 2021 An Act Establishing the Coronavirus Disease
2019 (COVID- 19) Vacc in ation Program
Expediting the Vaccine Procurement and
Administration Process, Providing Funds
Therefor, and for Other Purposes

23