Gavi Programme Audit Papua New Guinea
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Document content
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Audit and Investigations Gavi Programme Audit
PAPUA NEW GUINEA
GAVI Secretariat, Geneva, Switzerland
Final Audit Report –December 2016
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Audit and Investigations Gavi Programme Audit
Table of Contents
1. Executive Summary 41.1 Audit rating 4
1.2 Key issues 5
2. Objectives and Scope of the Audit 72.1. Objectives 7
2.2. Scope 7
2.3. Methodology & coverage 7
2.4. Applicable rules and regulations 7
2.5. Exchange rates applied in this report 8
3. Background 93.1. Introduction 9
3.2. Good Practices 9
3.3. Key challenges 10
4. Vaccine Supply Management 114.1. Stock Recording and forecasting 12
4.2. Cold chain equipment 15
4.3. Vaccine stock management 17
4.4. Vaccine wastage due to human error 19
4.5. Vaccine stock management in Eastern Highlands 21
5. Budgeting and Financial Management 225.1. HSS workplan and progress reporting 22
5.2. Reporting inconsistencies and delays 24
5.3. External audit requirements 25
6. Expenditure and Disbursements 276.1. Ineligible expenditure 27
6.2. Outstanding travel advance 29
6.3. Incomplete and untimely Provincial acquittals 30
6.4. Payment of per diems in Eastern Highlands Province 32
6.4.1 Lack of justification for payment 32
6.4.2 Payment of allowances without proof of receipt 33Programme Audit – Papua New Guinea February 2016 Page 2 of 68
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7. Procurement 34
7.1. Non-compliance with the applicable procurement regulations 35
7.1.1 Procurements were unplanned 35
7.1.2 Consideration was not given to existing “Whole of Government” contracts 37
7.1.3 No evidence of requests for quotation from tendering vendors 38
7.1.4 Quotation register not maintained 39
7.1.5 Procurement without Minor Contract Agreements 40
7.1.6 Fixed assets registers were not maintained 417.2. Weak internal controls over the EPI unit’s procurement activities 42
7.2.1 Procurement undertaken outside of the designated procurement unit 42
7.2.2 Budget overrun and unbudgeted procurement 437.3. Inadequacies in procurement documentation and other irregularities 44
7.3.1 Unsupported procurement 45
7.3.2 Contracts awarded without demonstrating competition 46
7.3.3 Inadequately supported delivery 47
7.3.4 Payments not supported by a valid invoice and timing inconsistency 48Annex 1 – Expenditure related to non-Gavi activities but paid out of Gavi grants 49
Annex 2 – Definitions of Ratings and Recommendation Priorities 56
Annex 3 – Classification of expenditure 57
Annex 4 – Audit Procedures and Reporting 58
Annex 5 – Acronyms 59
Annex 6 – Management comments and action plan 60Programme Audit – Papua New Guinea February 2016 Page 3 of 68
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1. Executive Summary
In February 2016, the Audit and Investigations team (the Audit Team) conducted a programme audit
of Gavi funding that contributed towards the Government of the Independent State of Papua New
Guinea’s (GoPNG) Expanded Programme of Immunisation (EPI).
The audit covered the National Department of Health (NDoH) management of Health Systems
Strengthening (HSS), Measles Rubella (MR) and Vaccine Introduction Grants (VIG) funds from 1
January 2013 to 31 December 2015. During this period, the overall Gavi-related expenditure reported
by the country totalled PGK 7,213,963 (USD 2,696,482).
Table 1 below compares total expenditure reported by programme with expenditure reviewed by the
Audit Team. The Programme Audit achieved a total overall coverage of 30% of the expenditure
reported, as follows:
Table 1: Summary of expenditure reviewed during the auditProgramme Disbursed Actual Expenditure Actual Expenditure
from Gavi expenditure Reviewed Expenditure Reviewed
(USD) (USD) (USD) (PGK) (PGK)Health Systems Strengthening 1,103,854 441,472 393,919 1,072,488 981,000
Measles Rubella 1,953,000 2,069,585 319,314 5,661,501 819,812
Vaccine Introduction Grants 735,000 185,425 139,545 479,974 361,892
Total 3,791,854 2,696,482 852,778 7,213,963 2,162,704
1.1 Audit rating
The Audit Team assessed the NDoH management of Gavi funds as unsatisfactory, which means that
“Internal controls and risk management practices were either not established or not functioning well.
The majority of issues identified were critical risk. Hence, the overall entity’s immunisation
programme objectives are not likely to be achieved and risks were not appropriately mitigated or
managed.” Table 2 below summarises ratings for each of the categories reviewed.
Table 2: Summary of audit rating by programme audit classification:Category Audit Rating
Vaccine Supply Management Unsatisfactory
Budgeting and Financial Management Unsatisfactory
Expenditure and disbursements Unsatisfactory
Procurement Unsatisfactory
Overall rating Unsatisfactory
Programme Audit – Papua New Guinea February 2016 Page 4 of 68
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1.2 Key issues
The Audit Team raised 25 issues, which were mainly caused by non-compliance with the GoPNG’s
own guidelines as well as Gavi’s Transparency and Accountability Policy. The rating for the various
issues is summarised in Annex 2.
To address these issues, the Audit Team made 25 recommendations, of which 12 (or 48%) were rated
as being critical in priority, which means that “action is required to ensure that the programme is not
exposed to significant or material incidents. Failure to take action could potentially result in major
consequences, affecting the programme’s overall activities and output.” In particular, the Audit Team
determined that reliance could not be placed upon the controls and systems in place administering
procurement.
Among the high priority issues noted in this report, the most significant are presented below:Vaccine Supply Stock records at the central vaccine warehouse were not timely updated, with
Management the last entry being done in Oct 2015, four months prior to the audit. These
records were adjusted without supporting documentation and unexplained
differences were not investigated. Stock issuance at all stores visited did not
follow “Early-Expiry-First-Out” principle, and vaccine records did not track expiry
dates and batch numbers. Vaccine management errors and misunderstandings
led to the expiry of closed-vial antigens (Refer to issues 4.1 through 4.5).Budgeting and Insufficient detail in the annual workplans directly resulted in significant
Financial overspending on some budget lines. Management and financial reporting within
Management the NDoH and to Gavi, respectively, was incomplete, inaccurate and untimely.
Delays in the implementation of some programmes were not clearly reflected in
revised workplans, and the balance of funds reported as being available for
reprogramming was not correct. (Refer to issues 5.1 through 5.3).Expenditure The National EPI unit’s primary accounting records were not consistently
and maintained in accordance with National financial guidelines and procedures.
disbursements Provincial acquittals sent to the EPI unit were not transparent, with reports being
on a pooled-fund basis. Examples of Gavi monies being utilised to fund activities
unrelated to the programme were identified. (Refer to issues 6.1 through 6.4).Procurement Procurement did not comply with the applicable National regulations. Systemic
internal control weaknesses in the procurement process were identified.
Procurement was conducted outside of the NDoH’s Commercial Support Services
Branch, which was responsible for procurement. Spending on printing and
stationary materials by the EPI unit for the period 2013-2015 exceeded the
approved budget. As a result, it was not possible to determine that good value
was obtained on the use of Gavi’s funds for procurement. (Refer to issues 7.1
through 7.3).Programme Audit – Papua New Guinea February 2016 Page 5 of 68
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It was jointly determined by NDoH and the Audit Team that issues raised by the Programme Audit
relating to procurement and expenditures required further work. As a result a subsequent review
was undertaken by Gavi’s Investigation unit in May 2016. Findings from this additional assessment,
including the determination of misuse, if any, will be reported upon separately.
The following table summarises amounts questioned by the Audit Team because of inadequate
documentation or the ineligibility of expenditures:
Table 3: Summary of questioned amountsReport Amount Amount
Description
section (PGK) (US$)
Expenditure related to non-Gavi activities but paid
6.1 680,788 274,572
out of Gavi grants
6.2 Outstanding travel advances (2013 through 2015) 67,539 27,413
6.4.1 Lack of justification for payment of per diems 5,200 1,880
Unsupported Procurement
7.3.1 (Excluding all other irregularities identified by the audit which 24,540 9,463
will be investigated and reported separately)Total 778,068 313,326
Determined in a separate
Procurement and expenditure irregularities
subsequent reviewThe following table is a non-exhaustive summary of vaccines that had or were due to shelf or
temperature expire at the time audit fieldwork was completed:
Table 4: Summary of vaccines that had or were due to shelf or temperature expireReport
Description Doses
section
Pneumococcal Conjugate Vaccine (PCV) scheduled to shelf-expire
4.3 175,550
in June-July 2016 at the national Area Medical Store
Pentavalent vaccines temperature expired in consignment with the
4.4 13,500
national logistics and forwarding company
Measles Rubella vaccines temperature expired pending collection
4.4 29,000
from Western Province’s airport cargo zone
IPV vaccines temperature expired pending collection from Western
4.4 280
Province’s airport cargo zone
VVM expiry of MR vaccines stored at room temperature in Eastern
4.5 40,800
Highlands’s provincial warehouseProgramme Audit – Papua New Guinea February 2016 Page 6 of 68
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2. Objectives and Scope of the Audit
2.1. Objectives
In line with the Programme legal agreements and Gavi’s Transparency and Accountability Policy, the
main objective of a Programme Audit is to ensure that the funds are spent in accordance with the
agreed terms and conditions and that resources are used for the intended purposes.
In addition, the Audit Team also assessed the adequacy of the control processes regarding the
reliability and integrity of financial, managerial and operational information, the effectiveness of
operations, the safeguard of assets, and compliance with respective National policies and procedures.2.2. Scope
The Programme Audit scope of review was from 1 January 2013 until 31 December 2015, and covered
income, expenditure, procurement as well as elements of vaccine management at National and sub-
National levels. However, the Audit Team identified expenditure in 2012 that was unrelated to Gavi
programmes but nonetheless paid out of Gavi grants. As a result the Programme Audit scope was
extended to 2012 exclusively in relation to this finding.
The review was performed at central level and included visits to the Eastern Highlands and Madang
Provinces.
Table 5: Gavi cash grant disbursements to NDoHGavi cash disbursements to the NDoH in USD
Grant type: 2006-2012 2013 2014 2015 Total
Health systems support – – 565,747 538,107 1,103,854
Immunisation Services Support 434,000 – – – 434,000
Measles Rubella operational costs – – 1,953,000 – 1,953,000
Vaccine implementation grants – 200,000 188,000 375,000 172,000 935,000
PCV and Injectable Polio Vaccine
(IPV)
Total disbursed 634,000 188,000 2,893,747 710,107 4,425,8542.3. Methodology & coverage
Audit evidence was gathered through interviews, review of relevant documents and substantive
testing. Interviews were conducted with personnel from NDoH including the EPI unit, the
Procurement Office, the Australian Government Department of Foreign Affairs and Trade’s HHISP
unit, UNICEF, WHO at National and regional levels, The World Bank, and the national logistics and
forwarding company, among others.2.4. Applicable rules and regulations
The Partnership Framework Agreement (PFA) signed between Gavi and the GoPNG on 29 November
2013 required minimum criteria for procurement, accounting and reporting. Amongst these, the PFA
stipulated that goods and services were to be procured in compliance with the Public Finances
(Management) Act 1995. The Financial Management Manual, issued by Department of Finance in
May 2013, also stated applicable thresholds and required review and approval procedures for
procurement.Programme Audit – Papua New Guinea February 2016 Page 7 of 68
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Other relevant policies and procedures including the Central Supply and Tender Board’s Good
Procurement Manual, Public Services (Management) Act 1995 and the Health Sector Improvement
Program (HSIP) Manual which provides guidance on the HSIP Trust Fund were reviewed.2.5. Exchange rates applied in this report
Gavi funds were expended and accounted for in PNG Kina (PGK). For the purposes of this report,
expenditure has been translated into US dollars (USD) according to the year in which it occurred using
the rate of exchange prevailing at the time that Gavi disbursements in USD were converted into PGK,
as follows:
Year USD 1.00 = PGK2013 2.59336
2014 2.41533
2015 2.76625
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3. Background
3.1. Introduction
The constitution of PNG established the overall political and administrative structure, consisting of
four regions made up of 22 Provinces as well as the National Capital District. Political power and
governance is devolved to these Provincial electorates under which 89 local-level government
electorates are sited. Separate Provincial legislature and executives are established, but with respect
to health at the Provincial-level, this is currently undergoing a progressive restructuring with the
creation of Provincial health authorities.
Health including Immunisation service delivery is a devolved function with the NDoH procuring
vaccines and providing oversight for standards and quality through policy development. The EPI unit
is currently supported technically and financially by several donors including the Australian
Government Department of Foreign Affairs and Trade, World Bank, WHO, UNICEF, Rotary
International as well as Gavi.
The majority of routine immunisation services are provided by government as well as some church
run facilities, which are primarily publicly funded. In addition a small number of private sector and
non-governmental organisation providers exist.
The National Health Plan 2011-2020 identifies improvement in vaccination of children and women as
priority programs in Key Result Area #4 “Improve Child Survival” and Key Result Area #5 “Improve
Maternal Health”. A country Multi Year Plan was developed for 2011-2015 which was fully costed and
clearly outlined activities for that period. As at 10 February 2016, the subsequent country Multi Year
Plan for 2016-2020 was being finalised.
The GoPNG provides the majority of all traditional routine vaccinations, while Gavi assists with the
procurement of Pentavalent and PCV as well as providing financial grants for HSS and ISS activities.
Between 2006 and 2015, PNG received Gavi cash grants totalling USD 4,425,854 (see Table 5) to
support nationwide health systems strengthening, operational costs for MR, and the introduction of
new vaccines, namely PCV and IPV.
A pilot programme to introduce the Human Papilloma Vaccine was recently funded by Rotary
International.3.2. Good Practices
A number of good practices were noted with regards to the EPI unit and its operating environment:The EPI unit was an established programme of the NDoH since 1977. The GoPNG considers the
EPI unit as an important, cost effective intervention for reducing the morbidity and mortality of
children from communicable diseases;
Gavi Alliance partners focused on supporting immunisation and are proactive in this section. For
example:
o A dedicated WHO staff member was assigned to NDoH to advise on vaccine campaigns and
country-wide implementation;
o Similarly, UNICEF provided support in outreach and vaccine distribution, both strategically
and operationally;Programme Audit – Papua New Guinea February 2016 Page 9 of 68
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o The Australian Government Department of Foreign Affairs and Trade provided NDoH with
its Health & HIV Implementation Services Provider (HHISP) services including a Finance and
Accounting team, overseen by a Financial Controller, and a Finance and Audit Advisory
unit.
Established National PNG regulations were in place including the Public Finances Management Act
(1995) (PFMA); and
The HSIP Manual published by HHISP in November 2012 provided specific operational guidance in
complement to the PFMA requirements. The HISP manual is currently under revision and will be
updated during 2016.3.3. Key challenges
Since early 2015, declining tax revenues following the fall of oil and natural gas market prices have
had repercussions on government spending on public services. Recent articles in Australian and
Guinean newspapers report of some health workers being forced to take pay reductions while others
were laid off, notably in rural areas.
These budgetary constraints have also impacted the government’s provision on National health
services, while the 2017 health budget is potentially set to be reduced further. As a consequence, the
country may have to rely further on non-governmental support for public healthcare and health
infrastructure.
The country’s diverse geography mean that the delivery of immunisation services is logistically
challenging. 85% of the nation’s population is rural-based. A range of different transportation modes
for vaccines and immunisation supplies applies along the supply chain, while the country’s tropical
climate results in some vaccines being exposed to relatively elevated temperatures during the warmer
seasons.
For example, the poor management and maintenance of cold chain equipment at the Area Medical
Stores (AMS), situated in Port Moresby’s Badili District, resulted in occasional heat-expired vaccines.
Delays in distribution of vaccines also occurred due to constraints in cold chain facility capacity. The
2011-2015 Comprehensive Multi-Year Plan for National Immunisation Programme includes a budget
of USD 9.4 million to purchase and upgrade existing cold chain equipment
A Joint International Review of the EPI unit which was carried out in September 2013 by immunisation
partners including NDoH, WHO, UNICEF, CDC, Gavi and Oil Search Health Foundation. It concluded
that “A lack of clarity around programme management roles and responsibilities at the Province,
District and health centre level, as well as a lack of leadership at all levels, appears to be preventing
(the achievement) of effective programme outcomes.”
PNG is currently expected to transition out of Gavi financial support, forecast to be complete in 2021.
Given implementation delays and poor absorption of the HSS grant, the Joint Appraisal carried out in
March 2015 recommended that the country seek approval from Gavi’s Independent Review
Committee to reprogram the near USD 2.5 million balance of its existing HSS grant, and proposed a
transition grant of up to USD 6 million be considered.Programme Audit – Papua New Guinea February 2016 Page 10 of 68
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4. Vaccine Supply Management
Audit RatingPoor record-keeping, inadequate and infrequent verification procedures and
weak oversight resulted in significant errors between the physical stock
count and immunisation supply records at the National level. This was
compounded by two successive inaccurate annual forecasts and the
resultant over-ordering of supplies without due regard to requirements.
Unsatisfactory
“Earliest-Expired-First-Out” was not applied, and effective systems were not
in place to comply with this principle.
A significant surplus of 753,000 doses of short-life PCV was on-hand – some
of which was excessive to requirements. Potentially a significant portion of
this PCV is as risk of shelf-expiry by July 2016.Country Context
The country has experienced recurring operational challenges in maintaining adequate supplies across
the supply chain, due in part to a reported lack of clarity between the EPI unit at National level and
the Provincial Health Authorities as to who was responsible for determining vaccine needs. These
were further compounded by inadequate and inaccurate nationwide information on stock levels, as
well as precarious cold storage facilities due to their age and neglect.
In February 2016, the acting EPI National manager identified the following logistic and operational
challenges as having considerably burdened programme resources and their ability to maintain an
effective cold chain supply:There was not currently enough vaccine storage capacity at the National, Provincial, District and
Health Facility Level for the volume of vaccine required to maintain the schedule of National
routine immunisation;
The Provinces and Districts ordered fewer vaccines and supplies than planned in their annual
forecast due to limited storage capacity while handling the additional vaccines required for the
MR National-wide campaign;
Several incidents of communication breakdown between the National, Provincial and District
levels affected the timeliness and reception of vaccine delivery handled by the freight forwarder;
Vaccines were occasionally heat-damaged due to improper storage conditions or due to
insufficient storage capacity; and
Funding constraints for the immunisation programme resulting in protracted stock-outs of BCG
vaccines across the country, requiring an urgent order to be placed with the Medical Supply and
Procurement Branch to secure additional supplies.
Most of the above difficulties were similarly reported in past annual EPI reviews (e.g. 2013, 2014 and
2015).Programme Audit – Papua New Guinea February 2016 Page 11 of 68
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Further, the September 2013 joint “International Review of the Expanded Programme on
Immunisation in Papua New Guinea” identified the following main areas of concern: poor
maintenance of cold chain equipment, lack of understanding of temperature monitoring processes, a
lack of qualified maintenance personnel, and deficiencies in knowledge on vaccine management at
Provincial, District and health centre level.
In addition, the Audit Team noted that the overall resilience and sustainability of the vaccine
distribution system was dependent upon commercial freight forwarding services to transport the
vaccines and immunisation supplies by air. This forwarder currently supplies vaccines to 19 out of the
country’s 22 Provinces.Effective Vaccine Management Assessment (EVM)
EVMs constitute an integral and important element to strengthen the country’s vaccine supply chain
management. An updated EVM is overdue as the last EVM for PNG was undertaken in June 2011, i.e.
five years ago. An EVM was originally scheduled to take place in 2015, but has not yet been
undertaken as at March 2016.This corroborates with the 2015 Joint Appraisal’s finding, which recommended to the NDoH that an
EVM should be expedited and completed in Q1 2016 or Q2 2016.4.1. Stock Recording and forecasting
The National Operational Guidelines for Special Integrated Routine Strengthening Program (SIREP) on
the “recording of incoming and outgoing vaccines and ancillary products” states that the following
procedures must be undertaken at points of reception:Always record all incoming and outgoing quantities of vaccines and ancillary items in a register
(stock management record);
Store all vaccines after Reception and Inspection (R&I) in the cold chain facility; and
Regularly do physical stock counts and compare against findings against vaccine and ancillary
products records.
In addition the guidelines clarify the importance adequate operational and logistical planning to
ensure that adequate resources are available for each level of the supply chain, and that the supply
chain is efficient by bundling the distribution of vaccines and immunisation supplies where possible.
However, from a review of the AMS, significant errors were noted in the stock management records.
Per the February 2016 National records, stock balances on at least four items were significantly
understated, with considerably more stock being on hand than the records identified:PCV was understated by at least 180,000 doses;
Pentavalent was understated by approximately 300,000 doses;
Auto-disabled syringes were understated by at least 700,000 units; and
Safety boxes were equally understated.Programme Audit – Papua New Guinea February 2016 Page 12 of 68
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Further examination of these records for the above four items identified recording errors, as follows:
(a) Multiple large receipts (e.g. 100,000 units) of vaccines doses and supplies received into the
country were never recorded in the stock register (including PCV, Pentavalent, safety boxes and
syringes);
(b) Formula errors were presented in the manual stock records resulting in errors in balances, overall
leading these to be understated;
(c) No stock movements were recorded for PCV for at least 6 weeks at the end of 2015;
(d) Stock records were not routinely kept up to date (at least weekly) as stated;
(e) Stock held under consignment with the national logistics and forwarding company were not
adequately tracked, recorded and accounted for.
Also, physical stock counts were not performed correctly. Although inventory counts were routinely
carried out, the results of these counts were neither reconciled with nor reflected in the stock
records. Dry goods such as syringes and supply boxes had never been physically counted.
Further, there was evidence of tracking and recording batch numbers for any of the vaccines, apart
from noting the batch number on initial receipt. As a result, neither the stock register, nor any of the
medical stores issued vouchers recorded the vaccine batch number issued.
At both National level and in the two Provinces visited, the store managers’ stock registers were
neither reviewed nor checked by another staff member, and there was no segregation of duties
between the National store manager receiving, managing and issuing vaccines and supplies
In addition, the records of all orders placed by Provinces and Districts at the National level were not
all kept on file, with the quality of documentation being sporadic and incomplete, and the date the
order was received not always recorded. On fulfilling these orders, the weight and number of parcels
despatched was similarly not consistently recorded.
Approximately 18 months ago, the National medical supplies store introduced a stock management
system – M-SUPPLY – to track and record both medical supplies, as well as immunisation vaccines and
supplies. As validated by the warehouse staff, it was confirmed that although immunisation data was
entered, all such data in the M-SUPPLY system was not accurate and was unreliable. This had no
impact on the Audit Team’s observations.
Finally, the EPI unit’s National supplies forecasts for PNG for both 2015 and 2016 sent to UNICEF
Supply Division were incorrect and significantly under-reported the number of doses of PCV,
Pentavalent and 0.5ml syringes in stock. This contributed to compounding the problem of the country
overstocking on its vaccines and immunisation supplies by accelerating orders fulfilled by UNICEF. For
example, at the time of Audit in February 2016, it was noted that more than 12 months of PCV was
currently held in stock at National level. In practice, guidelines recommend that between six and nine
months of a vaccine should be held throughout the supply chain pipeline.
The Audit Team’s visits to two Provinces indicated that stock records at the sub-National levels were
similarly incomplete and inadequate. For example, in one Province, there was an unexplained gap of
6.5 months in 2015 when no vaccine records were maintained. Similarly, the same Province
experienced a forced stock-out of all of its vaccines, due to its order submitted on 16 January 2016
still not having been fulfilled by the National stores more than four weeks later.Programme Audit – Papua New Guinea February 2016 Page 13 of 68
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The Audit Team’s observations highlighted the following weaknesses:
Inadequate procedures for stock reporting, inadequate oversight, supervision and a general lack
of awareness of existing procedure to be followed;
Human error –staff do not display sufficient discipline and technical knowledge in record keeping;
and
Staffing in stores is limited.Risks / Effect
A failure to comply with existing procedures for recording and keeping track of movements of
vaccines and immunisation supplies resulted in the inability to accurately forecast future
requirements. Vaccine oversupply potentially stress the country’s limited logistical ability and cold-
storage capacity.
Recommendation 1 (Critical)The EPI unit should:
Undertake a 100% physical inventory of all vaccines and immunisation supplies so as to amend
and correct current stock records. Vaccine stock records should be reconstituted for 2014 and
2015. Any differences should be fully investigated and justified;
Improve the quality and timeliness of stock recording, including recording batch numbers details
for all receipts, issuances and when undertaking stock counts;
Improve the accuracy and completeness of how National order fulfilments are documented,
including placing all orders in a single consolidated folder, and recording both the date the order
was received and shipped, as well as all details on the shipment including the total weight, for
reconciliation with the freight-forwarder’s subsequent invoice;
Conduct and document routine physical inventories and ensure that any differences identified
from the count are investigated and promptly adjusted, as necessary;
Ensure that appropriately qualified staff are put in place at the AMS;
Assure that all staff handling vaccines and supplies are provided with sufficiently detailed
Standard Operating Procedures with clear roles and responsibility;
Re-evaluable the suitability of the M-SUPPLY system for managing immunisation inventory; and
Ensure that adequate stock records are maintained for all stock held externally or under
consignment, and ensure that regular physical inventories are also conducted and reported to the
National/ Provincial stores manager(s).Management comments
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4.2. Cold chain equipment
The National Operational Guidelines for SIREP emphasise that good management of stocks is
necessary to maintain the quality of the immunisation programme. Elements which are to be
respected include that there be:Adequate storage facility (including cold storage and cold chain equipment) with sufficient
capacity, secure storage and location, and free from humidity, pests, direct sunlight, etc.; and
Quality storage facilities (including cold storage and cold chain equipment) with all cold chain
equipment functioning.
Various programmatic and cold chain reviews undertaken over the past three years identified the
need to upgrade and update components of the National cold chain due to the difficulties in
maintenance, a lack of equipment standardization, a lack of qualified maintenance personnel and
difficulties in obtaining spare parts. Similarly, NDoH’s assessment of lessons learnt from SIREP
acknowledged the insufficient and unreliable cold chain capacity in place at the Province and District
level, as well as the impact this had on the inconsistency in demand for vaccines from Provinces and
Districts.
During 2015, the receipt of significant amounts of MR vaccine and some PCV in May 2015, followed
by further receipts of PCV and Penta in July and August 2015, became a significant burden to the
supply chain. The EPI unit commented that in October 2015, seven of its twelve walk-in cold rooms
were no longer working. This resulted in emergency repairs having to be conducted, with the cold
rooms being fixed in approximately five days.
However, the Audit Team also noted that at least two reefers (refrigerated containers) had been hired
on the premises of a nearby commercial company, using Gavi funds, at approximately the same time
period so as to supplement cold chain capacity at the AMS. A third reefer, manufactured in 1994 and
situated in direct sunlight in the AMS courtyard, had been procured around the same time, but
neither the AMS nor EPI could provide an invoice or delivery note. The assistant store keeper
commented that the reefer had never functioned properly and was not suitable for storage of
vaccines due to a faulty thermostat that froze the reefer contents. The Audit Team questions
whether value for money was obtained on the purchase of this equipment.
Further, at the time of the audit, it was noted that there was not a proper fixed asset register in place
at the National level to track and demonstrate the overall age, condition, status, and location of all of
the National cold supply across PNG.
Finally, no insurance was in place at the AMS, even though at the time of the Gavi audit in February
2016, approximately $4.5 million worth of vaccines was held in stock.
Cold chain capacity was deemed insufficient by the EPI unit at both National and sub-National levels in
order to meet additional needs following the introduction of new antigens (IPV, PCV and MR).
However, beyond the introduction of PCV in 2013, no formal assessment of cold chain capacity was
done to date. In addition, it was not clear whether the purchase of additional refrigeration units was
adequately planned in consideration of overall longer term requirements.Programme Audit – Papua New Guinea February 2016 Page 15 of 68
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Risks / Effect
Failure to ensure that sufficient and reliable storage capacity is available at every level of the cold
chain in the country raises the risk of wastage due to improper storage, and requires additional
operational resources to carry out extra incremental deliveries to compensate for insufficient capacity
at subsidiary levels. In the absence of suitable insurance being in place, accidents – such as fire –
could result in significant financial loss to immunisation products.
Recommendation 2 (Essential)The Gavi Secretariat and Alliance partners should ensure that an adequate implementation plan, is
promptly put in place following the imminent Q1/2016 Effective Vaccine Management (EVM)
assessment, to strengthen the National cold chain system, while designing a supply chain which
maximises sustainability, is technology appropriate and fit for purpose considering existing resource
constraints (and overall maintenance capacity).
The government should fulfil its commitment to ensuring that cold chain equipment is routinely
maintained by qualified persons with a view to prolonging their lifespan.
The EPI unit should ensure that National Operational Guidelines for SIREP are being adhered to.
In accordance with section 10 of the PFA, the government is required to insure programme assets,
including vaccines and vaccine-related supplies.Management comments
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4.3. Vaccine stock management
The National Operational Guidelines for SIREP on the storage of vaccines states that:All vaccines must be clearly identifiable and accessible, and must be easily located and stored in
Earliest-Expired-First-Out order, specifically vaccine vials with the closer expiry date must be
distributed and administered first, however Vaccine Vial Monitoring (VVM) indicating greater heat
exposure must be labelled for priority use;
Temperatures must be monitored two times a day on a monitoring sheet.
The Audit Team observed various non-compliance with these guidelines.
The EEFO order principle was not systematically applied at National or Provincial levels (two Provincial
stores were visited by the Audit Team). A stock count on 3 February 2016 at the AMS revealed that
there were 175,550 doses of PCV which were due to expire by July 2016, i.e. in less than six months.
The use of this PCV is a concern, given the country’s logistical challenges, the significant lead time in
the cold chain and that only approximately half of the country had introduced PCV into its routine
immunisation. There remains a risk that significant amounts of this soon-to-expire PCV will shelf-
expire.
The store manager confirmed that he had issued PCV not in compliance with the EEFO order principle,
and from a review of the stock records it was demonstrated that at least 92,000 doses of PCV expiring
2017 had been incorrectly issued from the National stores prior to using the PCV vaccine which was
expiring in 2016.
Furthermore, the necessary processes to issue vaccines according to EEFO were not in place, since
there was no system in place to record, track and document the batch number for vaccine
movements issued from the AMS. As such existing records did not indicate which Provinces had
received PCV vaccine imminently expiring in 2016, undermining the EPI unit’s ability to determine
how best to allocate and distribute the remaining short-lived PCV.
In addition, although the AMS cold room temperature charts were up to date on 3 February 2016, on
our subsequent visit on 8 February, the Audit Team noted that no entries had been made on the
temperature charts for 5 consecutive days for all seven of the cold rooms. The team’s third visit on 10
February revealed that temperature charts had been retroactively updated. It was explained that in
the absence of the store manager, there was no additional individual to cover for the AMS
temperature checks.
Finally, from discussion and from the Audit Team’s observations at Provincial and health facilities, it
was noted that the EPI unit had not distributed any thermometers or fridge tags to the sub-National
levels since at least 2013. As a result, no temperature chart readings occurred at multiple points in
the cold chain beneath National level, except where thermometers supplied prior to 2013 were still
available. The acting EPI manager indicated that WHO purchased 2,600 vaccine thermometers in
2015. Although these were insufficient in number for the entire cold chain system, the thermometers
would begin to be distributed from March 2016.Programme Audit – Papua New Guinea February 2016 Page 17 of 68
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Risks / Effect
Unless measures are put in place to prioritise the despatch and usage of the PCV imminently expiring
in July 2016, there is a risk that some of the vaccine will shelf-expire.
A failure to adhere to good practices in storing and managing vaccine raises the risk of wastage due to
expiration or improper storage.
Recommendation 3 (Critical)
The EPI unit needs to substantially and urgently improve the management of its vaccines:
The EEFO principle should be systematically applied at all levels through the supply chain; andVaccines should be properly stored, and records maintained so as to facilitate the tracking and
identification of the various expiry dates of product, as well as the temperature in situ
throughout the various points in the cold chain.Fridge tags or thermometers need to be made available at all levels in the vaccine supply
chain, and temperature records maintained such that vaccine exposure to temperature
variations may be tracked. Additionally, temperature monitoring provides information on
faulty cold chain equipment.Every effort should be made to minimise the loss of PCV vaccine due to expire in July 2016.
Management comments
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4.4. Vaccine wastage due to human error
The National Operational Guidelines for SIREP prescribes that in order to reduce the wastage of
vaccines:Assure adequate transport means and adequate transport boxes;
Always keep the vaccines at the correct temperature;
Never expose freeze sensitive vaccines to freezing; and
Never expose heat sensitive vaccines to more than the accepted temperature limit.
In addition, the guidelines discuss issues on how to minimise vaccine wastage and to plan supplies in
consideration of the vaccine wastage factor. Practical suggestions promote to “use as much as
possible all vaccine in a vial before opening a new vial.”
The Audit Team were informed of the following recent cases of vaccine wastage due to human error:The national logistics and forwarding company held significant amounts of stock on consignment
in response to cold storage capacity concerns at the AMS. During October 2015, 13,500 doses of
Pentavalent, with an approximate value of USD 44’500, VVM expired. While the Audit Team was
unable to obtain an exact recount of the cause for these expiries, the EPI stores manager at the
AMS expressed concern over the national logistics and forwarding company’s standards which
required only a single cold room temperature check per day;
Due to a breakdown in communication between NDoH and the national logistics and forwarding
company, 280 doses of IPV and 29,000 doses of MR were heat exposed at Western (South Fly)
Province’s airport cargo zone between delivery by the said logistics company on 17 August 2015
and collection seven days later by the local EPI logistician on 25 August 2015; and
In at least two Provinces, an unquantified amount of IPV vaccines had been accidentally frozen
due to the receiving store confusing handling requirements with those pertaining to OPV vaccines.
Further, from discussions with the acting EPI manager and from the Audit Team’s visits to two
Provinces, it was noted that there was no information system in place through all levels of the cold
chain system to track and report vaccine loss.Risks / Effect
Poor practice or inappropriate storage of vaccine raises the risk of vaccine wastage.
Individuals handling vaccines may not have the necessary technical knowledge or discipline to ensure
that vaccines are handled and stored appropriately.
An absence of complete and reliable data on closed and open vial loss makes it impossible for the
NDoH to take appropriate, targeted corrective action.Programme Audit – Papua New Guinea February 2016 Page 19 of 68
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Recommendation 4 (Critical)
The EPI unit should:
Review and update its vaccine management guidelines and standard operating procedures in
conjunction with the follow up resulting from the Q1/2016 EVM assessment, and suitable training
should be shared and discussed with all individuals responsible for storing and handling the
vaccine;
Review and discuss its contractual arrangements with its national logistics and forwarding
company to incorporate consignment services, including defining INCOTERMS and liability in the
event of vaccine damage or loss. Compensation should be sought for the loss of 13,500 doses of
Pentavalent while under the responsibility of the national logistics and forwarding company;
Undertake an open vial wastage rate assessment to evaluate whether actual open vial wastage
rates are in line with WHO benchmarked rates; and
Adopt suitable procedures to ensure that open and closed-vial wastage are routinely recorded by
District, Provincial and National levels and reported to the EPI unit, and that targeted corrective
action is initiated by the EPI.Management comments
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4.5. Vaccine stock management in Eastern Highlands
The Audit Team identified various weaknesses in the vaccine management at the provincial
warehouse of Eastern Highlands and concluded that there was scope for significant improvement in
the Province’s vaccine management processes.
In 2015, a total of 40,800 doses of MR vaccine valued at approximately USD 23’00 shelf or VVM
expired due to inadvertent storage at room temperature.
Furthermore, the Audit Team’s physical observation of vaccine storage identified a handful of vials of
MR vaccine being stored at -20°C in lieu of -2 to -8°C. Thus the antigen had frozen, rendering the
vaccine useless.
Temperature monitoring practices were found to be insufficient. Temperature monitoring charts
were not always completed; there was no thermometer for one of the freezers; another freezer’s
thermometer was broken; vaccines were stored randomly in cold chain equipment irrespective of
expiry dates; and vaccines were not grouped by product type when this would have been possible and
logical from a storage capacity perspective.
The Audit Team also noted that National guidelines defined to prevent exposing freeze-sensitive
vaccines to freezing were not being followed at the Provincial warehouse. In particular, vaccines were
placed directly into isothermal boxes and surrounded by up to 16 frozen ice packs, rather than using
liquefied ice packs as stipulated in the guidelines.
The Cold Chain Logistic Officer did not maintain any stock records and made no entries in the
available stock movements ledgers. No credible information on the current stock levels was available.Risks / Effect
Inappropriate storage of vaccine has led to wastage due to expiration.
Weak stock records may result in stock outs and/or excessive stock levels.Recommendation 5 (Critical)
The EPI unit should ensure that:Individuals managing vaccines at Provincial levels are trained on vaccine management;
An up-to-date standard operating procedure for vaccine management is made available and
enforced at all levels of vaccine management;
Stock records are adequately maintained and can be relied upon for vaccine forecasting and
reordering purposes;
Individuals handling the vaccines are sufficiently trained on temperature monitoring;
Routine temperature monitoring is carried out and recorded; and
Thermometers are verified to be accurate, in working condition and replaced where necessary.Management comments
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5. Budgeting and Financial Management
Audit RatingReporting inconsistencies and inaccuracies in the financial data collected on
Gavi monies were identified which significantly undermined the reliance that
could be placed on information provided by the NDoH on the activities and Unsatisfactory
outcomes of EPI programmes. This also weakened the ability of budget owners
to make accurate financial decisions thereon.Gavi’s financial support to the NDoH is made through the HSIP Trust Account, a government
instrument governed by PNG law which forms part of the overall National public accounts, created in
1996 by the Asia Development Bank. The financial statements of the HSIP Trust Account, into which
multiple donors contribute financial support, were not disaggregated by funding source.Gavi’s relative financial contribution represented less than 1% of total receipts to the HSIP Trust
Account in 2013, but increased in 2014 as a result of significant Gavi funds disbursed for the MR
campaign.The GoPNG’s 2011-2020 National Health Plan was split into a country Multi Year Plan for 2011-2015
and one for 2016-2020. The 2011-2015 country Multi Year Plan stated that the “majority of [the
estimated total EPI] costs will be funded by Government of PNG through its PGK 14.17 billion budget
allocation for health services in the country. And the overall funding gap of USD $18,492,028 (PGK
52,175,529) is expected to be met by donor partners.” Gavi’s HSS grant for a total of USD 3,072,923
helped fund part of this gap, however most of the activities set out in the GoPNG’s Detailed Workplan
and Budget did not correspond to those in country Multi Year Plan.5.1. HSS workplan and progress reporting
In April 2013, Gavi’s Independent Review Committee approved an HSS grant to the GoPNG totalling
USD 3,072,923. As at the end of December 2015, USD 1,103,854 had been disbursed by Gavi, of
which PGK 1,072,488 (USD 393,919) (see Table 1) had been spent. Based on the grant’s operational
timetable, it was expected that the grant would fund immunisation activities through until mid-2018.
However as at the end of 2015, and following the first disbursement, 87% of the HSS grant remained
unspent.
The EPI unit presented the Audit Team with a draft revised 5-year HSS workplan running from 2015 to
2019. The amended timeline was not satisfactorily explained. Furthermore, the revised plan was a
crude approximation, as it assumed that the entire grant balance was still available rather than
deducting any expenditure incurred to date.The EPI unit was unable to demonstrate that it proactively reviewed and managed its programme
budgets or that reference was made to the initial approved and current budgets as budgetary tools
for the purpose of guiding and administering the programme against the approved activities and key
milestones. In addition, there was no overall clarity on the remaining balance of Gavi funds.The Audit Team concluded that the EPI unit’s capacity and ability to proactively review and manage its
budgetary and financial management commitments was inadequate.Programme Audit – Papua New Guinea February 2016 Page 22 of 68
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Risks / Effect
Lack of budgetary control over the periodicity and prioritisation of HSS activities.
Sub-optimal management of the balance of HSS funds available for reprogramming.
Recommendation 6 (Essential)Given the budgetary necessity to reprogram the balance of HSS funds, and to reprioritise unfulfilled
workplan activities, the NDoH is requested to:Verify the relevance and accuracy of the 2014 Annual Progress Report and, if necessary, resubmit
a corrected version to Gavi ;
Timely complete and submit 2015 reports as per Gavi’s Financial management and audit
requirements; and
Submit a formal request to reprogram its remaining HSS grant funds in time for consideration by
the next Independent Review Committee session.Management comments
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5.2. Reporting inconsistencies and delays
In February 2016 and prior to submission to Gavi of the 2015 Annual Progress Report, the EPI unit
shared its 2014 and 2015 Annual Reports. These Annual Reports are not part of the standard
reporting to Gavi but were shared with the Audit Team as an overview of the unit’s performance. The
2014 report contained select references to activities and events which did not occur in 2014.Similarly, the 2015 Annual Report was an exact copy of the 2014 Annual Report except in title and
footer which had been relabelled 2015. The substantive reporting on pages 14 through 17 and
recommendations on page 18 clearly related to 2014 and not 2015. The Audit Team concluded that
the 2015 Annual Report was not updated to reflect actual 2015 activities and recommendations, and
could not be relied upon.Annual Progress Report
The EPI unit’s 2014 Annual Progress Report submitted to Gavi on 15 May 2015 reported no HSS
activity. However, this was contradicted by the 2014 accounting records which indicated that 48% of
the immunisation expenditure in 2014 related to HSS. No satisfactory explanation was provided for
this discrepancy.The above inconsistencies were attributable to the preparation of financial reporting without
involving finance personnel, and without review by personnel not involved in report preparation.
Many financial reports from 2014 and 2015 had been prepared by an unaided, unsupervised EPI
employee.Risks / Effect
Reporting errors and inconsistencies occurred and went undetected.Unless reports are relevant, accurate and complete, decision making will be sub-optimal.
Recommendation 7 (Essential)
The EPI unit needs to strengthen its reporting processes by putting in place:
A process which ensures a greater level of scrutiny and involvement of persons who are familiar
with both the financial and non-financial programme performance; and
A formal review and authorisation procedure. This should be done by persons not involved in the
report preparation.
All financial reporting which is relied upon for decision-making is to be submitted to HHISP Finance
and Accounting team assigned to the NDoH for a due review and approval process.Management comments
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5.3. External audit requirements
The PFA stipulates the requirement of an annual external audit, specifically: “38. The external audit
shall cover all aspects of HSIP Trust Account activities implemented by the Government at central and
Provincial and District levels. The audit shall include verification of expenditure eligibility,
procurement files, programme performance and physical inspection of goods, works and services
acquired at central and peripheral levels by all implementing entities. […]”The PFA goes on to stipulate: “39. The audit report and the Management Letter for each audited
period shall be submitted to the Inter agency Coordinating Committee, Health Sector Finances
Committee and the Gavi Secretariat not later than six months after the end of the Government fiscal
year.”The latest HSIP Trust Account external audit report covered the 2013 fiscal year, and was belatedly
issued in June 2015.Furthermore, the financial statements presented the total funds disbursed to Provinces but without
indicating when or whether these funds had been spent at Provincial level. As such, the accounting
treatment was to fully expense these disbursements, rather than to treat the amounts as advances
yet to be justified. As a result, the annual financial reporting to Gavi did not present an accurate
position of the actual substance for how funds disbursed to the Provinces were spent.As a consequence, the Annual Progress Reports for 2013 and 2014 presented a National level position
only and did not reflect the actual substance of expenditure and activities implemented by the
Provincial and District level public health instances. In effect, this was the same accounting treatment
as presented in the 2013 HSIP Trust Account audited financial statements.On 08 February 2016, the Audit Team met and confirmed with the Auditor General’s Office that they
were currently finalizing the selection of an HSIP Trust Account external auditor for 2014, 2015 and
2016 financial statements. They also acknowledged that the 2014 HSIP Trust Account financial
statement audit is overdue.Furthermore, the Auditor General’s Office acknowledged that the past 2013 external audit of the HSIP
Trust Account had not addressed Gavi’s financial management requirements, but they indicated that
it would be able to accommodate these requirements by including a donor-specific statement
covering Gavi funds as an annex to the HSIP Trust Account financial statements. As such, this
statement would present the actual expenditure on the activities implemented by the central,
Provincial and District level public health instances – in substance the actual spending linked to the
programme’s performance – and would be independently audited.Finally, the National accounting system did not track the actual expenditure by Provinces against
respective donor funding sources. As a result, past financial reports – including the HSIP Trust
Account financial statements – were unable to provide any donor specific reporting, or any Provincial
level information other than the level disbursements from the National accounts.Programme Audit – Papua New Guinea February 2016 Page 25 of 68
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Risks / Effect
Inaccurate financial reporting to Gavi (by over-reporting expenditure) due to the basis and treatment
of Provincial allotments.
Financial numbers not reflective of programmatic progress enumerated in Annual Progress reports.
The preparation basis of the HSIP Trust Account financial statements failed to meet Gavi’s financial
management requirements.Recommendation 8 (Essential)
In order to comply with Gavi’s financial management requirements it is recommended that the NDoH:Beginning 2014, the HSIP Trust Account audited financial statements should include an additional
Gavi specific certificate of income and expenditure which identifies in substance the income,
expenditure and closing balances for each Provincial advance. This certificate may be included as
an additional annexed disclosure to the overall financial statements;Strengthen its Provinces’ capacity to continue to maintain donor-specific sub-ledgers and to
monthly produce the “HSIP Trust Account funding source report” as required;Record all transfers of funds to Provinces as advances rather than as expenditure in accordance
with paragraph 18 of the Financial Management Requirements of the PFA; andComplete external financial statement audits within six months of the GoPNG fiscal year-end in
accordance with paragraph 39 of the Financial Management Requirements of the PFA.Management comments
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6. Expenditure and Disbursements
Audit RatingReporting by Provinces on acquittals fell short of adequately substantiating
programmatic expenditure. Absence of budgetary control over the Gavi grants
Unsatisfactory
resulted in USD 411,233 of ineligible expenditure at National level which did not
relate to Gavi supported programmes.This section elaborates on the:
Use of Gavi funds for non-eligible activities by way of Gavi monies being loaned to cover other
programme costs;
Untimely retirement and justification of travel advances issued to NDoH staff; and
Procedures and reporting relating to financial support for EPI programmes at Provincial level.6.1. Ineligible expenditure
The Audit Team identified PGK 1,010,872 (USD 411,233) of expenditure that did not relate to Gavi
supported programmes. According to the EPI unit and the HHISP Finance and Accounting team
assigned to the NDoH, Gavi funds were used to implement non-Gavi activities pending receipt of
funds from other EPI donors. This amounted to 32% (by value) of total EPI expenditure. When funds
were received from the respective donors, they were insufficient to fully cover the costs incurred to
date.
Prior to commencement of the audit, PGK 330,083 (USD 136,662) had been reimbursed to the Gavi
programme. As of 10 February 2016, PGK 680,788 (USD 274,572) was yet to be refunded.
Table 6: Non-Gavi activities paid out of Gavi grants and status of refunds and balances (c.f. Annex 1)Activity Expenditure Refunded Balance Balance Audit Comment
PGK PGK PGK USD
Gas Supplies 247,244 – 247,244 97,363 Related to procurement of gas cylinders
from 2012/2013, funded by other donor
Gardasil Project 2012 3,792 – 3,792 1,462 Non-Gavi funded project. Gavi had not
provided support for HPV in PNG
Data Collection & 38,259 – 38,259 15,609 Non-Gavi activity, funded by GoPNG
assessment1
National EPI Surveillance 253,053 152,388 100,665 41,678 Non-Gavi activity, funded by other
Meeting donor. Partially refunded.
Hepatitis B Birth dose 151,124 151,124 – – Non-Gavi funded activity, fully refunded
survey
Measles Outbreak 87,069 – 87,069 34,099 Funded by GoPNGNewborn Care 40,335 26,571 13,764 5,699 Non-Gavi activity, partly refunded
1
Including Sentinel Site Surveillance
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Table 6: Non-Gavi activities paid out of Gavi grants and status of refunds and balances (c.f. Annex 1):
Activity Expenditure Refunded Balance Balance Audit Comment
PGK PGK PGK USD
Vaccine Management 189,995 – 189,995 78,662 Annual Implementation Plan of NDoH,
forms & Frequently Asked indicated GoPNG as funding source for
Questions (FAQ) booklets these activities. The expenses were paid
for Routine Immunisation from the HSS grant but this did not
Activities2 include an allocation for these activities.
The total HSS budget for printing
materials (posters) was USD 9,523 over
five years. The FAQs were for Measles,
Vitamin A, Tetanus Toxoid and Japanese
Encephalitis, these programmes were
not supported by Gavi in PNG.
Total Balance not yet refunded 680,788 274,572Risks / Effect
Use of Gavi grants for unapproved activities contradicts the PFA and relevant grant terms and
conditions.
Immunisation programme objectives funded by Gavi may be delayed due to lack of cash flow/
liquidity.Recommendation 9 (Essential)
NDoH should:Review the accounting records, from the inception of Gavi grants to date, identify and quantify all
instances of ineligible expenditures, and promptly refund all outstanding balances to Gavi; and
Adhere to the terms and conditions of PFA and relevant grant agreements in regards to its ability
to use Gavi funds for unplanned activities, including emergency situations.Management comments
See Annex 6 – Management comments and action plan as at 17 October 20162
Transactions related to use of Gavi grants for non-Gavi activities, in routine immunization, may be subject to further
review in any separate Gavi investigation.
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6.2. Outstanding travel advance
The Audit Team identified poor controls over the acquittal of advances related to travel. These
advances were either issued to NDoH staff or to hotels and venues where the activities were held. At
the end of January 2016, the total amount yet to be acquitted, for period 2013-2015, was PGK 67,539
(USD 27,413) of which PGK 55,489 (USD 22,974) was outstanding from 2014.
GoPNG’s Financial Management Manual allows for temporary cash advances to Government Officers
for approved purposes. The Manual requires that the “advances must be repaid in full as early as
possible where no repayment date is specified…”
Some of the advances had been issued to individuals who had not yet completed the submission and
acquittal of prior advances. This practice was not in accordance with the Manual which states that no
new advances should be provided while prior advances to the same staff member remained un-
acquitted.
Table 7: Aging of acquittals for the period 2013-2015Advances Un-acquitted Un-acquitted
Year
issued PGK advance PGK advance USD
2013 51,755 3,409 1,315
2014 461,694 55,489 22,974
2015 660,441 8,641 3,124
Total 1,173,890 67,539 27,413Risks / Effect
Loss of Gavi funds due to non-recovery of advance payments or advances being used for a purpose
other than intended.Recommendation 10 (Critical)
NDoH should:Clarify the timeline for submission, review, approval and acquittal of staff advances; and
Ensure the provisions of Financial Management Manual are adhered to, specifically “A new
advance will not be made for any purpose while the previous one to the same person is
unacquitted except where evidence is produced that payment is still continuing and repayment
action on the first advance is not deliberately delayed.”
Management comments
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6.3. Incomplete and untimely Provincial acquittals
Per Financial Management Manual Section 16-4, those responsible for the maintenance of the HSIP
Trust Accounts should ensure that: “a cash account is submitted to the Public Account of the
Department of Finance for each month, not later than seven days after the end of the month (unless a
different period is allowed under the trust instrument). The receipts and payments during the period
and the closing balance should be accompanied by a bank reconciliation statement. This is necessary
for incorporation of the trust transactions in the monthly and quarterly Statement of Public Accounts
by the Department of Finance.”
Per the November 2012 HSIP Manual of Procedures “accurate financial reporting is depending on the
relevant Provincial coding details (in the expense code fields) being entered in the cashbooks. At
issue is that the allocation of costs to programs […] is accurately identified and reported. Separate
vote coding (Chart of Accounts) is necessary to facilitate this requirement.”
The HSIP Manual also states that “Accurate coding of expenditure will allow the NDoH and NDoH
Financial Management Service Branch compliance function to effectively monitor progress against
Medium Term Expenditure Framework priority areas.”
The Audit Team’s review of a sample of HSIP acquittals received from the Provinces for the period
June to November 2015 revealed the following weaknesses:Acquittals were often received late – for example as at 10 February 2016 more than 50% of the
November and more than 75% of the December acquittals had not yet been received by the
National HHISP Finance and Accounting team assigned to the NDoH;
The quality of the acquittals was weak as more than half of the submissions over the six month
period did not adhere to the vote number structure (the Provincial chart of accounts);
Acquittals frequently attributed Gavi funds to other donors or failed to code Gavi-funded activities
correctly to the programme “Family Health Services/ Immunisation”;
There was a lack of transparency as to what Gavi was funding since the Provincial accounts
comingled funds from all three principal immunisation sources under the category “Other donor”;
Acquittals were often incomplete as only 25% of the Provinces submitted the required “HSIP Trust
Account funding source report” and, of those Provinces which did submit a report, at least a third
did not complete this report correctly;
More than half of the Provinces did not maintain a sub-ledger for each funding source as required;
Without these required sub-ledgers, the Provinces’ ability to track the balance of funds was
undermined, and they were not able to accurately prepare a funding source report, as required;
Because there was no overall aggregation of the financial information from each Province, NDoH
management with overall responsibility for the budgets did not have the necessary information
and insights into the rate at which Provincial funds were used; and
The HHISP Finance and Accounting team assigned to the NDoH responsible for visiting Provinces
to validate their underlying supporting documents undertook such visits infrequently. Moreover,
these visits were often only triggered by Provincial requests rather than following a routine
programme. As a result, each Province was being visited on average once every two years.Programme Audit – Papua New Guinea February 2016 Page 30 of 68
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One of the key purposes of the “HSIP Trust Account funding source report” was to ensure that,
whatever HSIP funds were comingled and disbursed to Provinces, these funds could still be tracked by
funding source. Further, the existence of such a report validated that suitable mechanisms were in
place to compute the cumulative year-to-date expenditure for each funding source, as well as
remaining funding source balances.
The current configuration of the Provincial Government Accounting System only contained details on
disbursements made to the Provinces, and was unable to consolidate and provide any donor specific
reporting other than the total funds disbursed from the National to the Provinces.Risks / Effect
Without any aggregate year-to-date information on expenditure against the various HSIP funding
sources, the EPI unit and the Financial Management Service Branch were unable to:
Effectively monitor progress against immunisation priorities areas; andFulfil their fiduciary and oversight responsibilities on the use of EPI funds disbursed to the
Provinces.Furthermore, the level of detail in the budget and workplan undermined EPI management’s ability to
monitor and make decision on the use of Gavi’s funds at Provincial levels.Recommendation 11 (Critical)
HHISP Finance and Accounting team in conjunction with the NDoH should:
Update the funding source segment of its Provincial chart of accounts by creating a Gavi-specific
segment, so as to enable the tracking of Gavi’s funding independent from other sources also
funding immunisation;Ensure that relevant sub-National personnel are knowledgeable with the accounting structure of
Provincial Government to properly classify receipts and payments, with particular focus on
accounts fields Program/Activity (fields #10/#11) and Donor Identification (field #15);Follow up with all Provinces and confirm that they comply with financial regulations and
instructions, maintain funding source specific sub-ledgers, and timely submit complete acquittals
including the “HSIP Trust Account funding source report”;Ensure all relevant personnel are briefed and trained on the above changes; and
Improve the “funding source report” by inserting a balance brought forward column into the
template.Management comments
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6.4. Payment of per diems in Eastern Highlands Province
The Audit Team noted the following inconsistencies in the payment of per diems in Eastern Highlands
Province.6.4.1 Lack of justification for payment
Per diems and allowances may be paid to staff while on duty travel to cover their subsistence and
incidental expenses.
The Audit Team noted that the Eastern Highlands Province was paying incidentals from Gavi funds to
personnel who had not travelled to carry out their work. Specifically, daily payments of PGK 40 were
disbursed to 13 staff over the 10 day period between 7 and 16 September 2015 for the SIREP
campaign which took place in their home town duty station in Goroka. Total expenditure was
PGK 5,200. No justification for these claims was provided.
Risks / Effect
The validity of payments of per diems and incidentals could not be confirmed without adequate
supporting documentation to validate the entitlement.Recommendation 12 (Essential)
Per Diem allowances should only be paid to staff who qualify for the allowance. Such payments
should only be made where there is a valid approval on file; and
The HHISP Finance and Accounting team assigned to the NDoH should follow up on and quantify
any per diem payments paid over the entire grant duration (including a review of the Goroka
hospital case) where entitlement cannot be justified.
Any and all unjustified payments identified over the entire grant duration should be reimbursed to
the grant.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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6.4.2 Payment of allowances without proof of receipt
In both the SIREP campaign and multiple other cases where staff were required to attend training
away from their duty station, allowances for multiple staff members were paid to a single person for
onward distribution to their colleagues. This was described to the Audit Team as common practice
whenever it is not possible to pay personnel individually. In the case of Goroka, no documentation
was on file to evidence the fact that these onward payments were effected, or that the claimants had
received their entitlement.
Risks / Effect
Without evidence of receipt of allowances, it is not possible to confirm that amounts were distributed
appropriately to individual.
Absence of such evidence increases the risk of theft or fraudulent claims going undetected, while also
offering no protection to individuals responsible for redistribution of cash allowances.Recommendation 13 (Essential)
HHISP Finance and Accounting team in concert with the NDoH should ensure that the transfer of
all cash payments, including allowances, are supported by a receipt signed by the recipient,
documenting the amount of funds received, their identity card and their contact details; and
Shortly after campaigns, training and other events resulting in entitlements to allowances, HHISP
Finance and Accounting team should randomly contact staff members and volunteers to confirm
attendance and amounts received.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7. Procurement
Audit RatingProcurement processes did not comply with the requirements of National
regulations or the PFA. Systemic internal control weaknesses were identified
across multiple stages of the procurement process, with errors not being timely
addressed, as a result of ineffective oversight by NDoH management. The
Unsatisfactory
Commercial Support Services Branch of NDoH, designated as responsible for
National-level procurement, was not involved. Instead, procurement was
carried out autonomously by the EPI unit which resulted in inadequate
segregation of duties.Background
Procurement files were examined to provide assurance that procurement was carried out in
compliance with the PFA and National regulations; and included complete documentation to support
budgeting and planning, tendering, contracting, delivery and receipts of goods, payments, and assets
management.
The procuring entity within the Population and Family Health Services Branch of NDoH was the EPI
unit. GoPNG’s Public Finances (Management) Act 1995 (PFMA) specifies that departmental heads are
responsible for ensuring that the provisions of PFMA, including for the procurement, are complied
with.
Total expenditure reported by NDoH during the period 2013-2015 was PGK 7,213,963
(USD 2,696,482), of which procurement related expenditure totalled PGK 2,447,111 (USD 967,106).
Of this, the Audit Team sampled and audited 80% of total procurement expenditure for the period
2013-2015, totalling PGK 1,954,167 (USD 771,067).
Table 8: Coverage of procurement and expenditure for the period 2013-2015Description % Amount PGK Amount USD
Total expenditure, procurement
___ 7,213,963 2,696,482
& non-procurement
34%
Of which total procurement 2,447,111 967,106
of total expenditure 2013-2015
80%
Of which total audited 1,954,167 771,067
of total procurement 2013-2015The Audit Team identified systemic weaknesses across all procurement transactions reviewed
(sections 7.1 & 7.2). In addition, 64% of procurement items audited were inadequately supported
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Table 9: Summary of procurement transactions reviewed by the Audit Team for the period 2013-2015
Description Amount PGK Amount USD
Printing & Stationary 910,019 364,772
Accommodation 416,153 156,491
Supply & Utility 295,232 114,710
Service- Catering/Car hire/Repair 155,436 62,957
Air Fare 114,327 46,054
Equipment 63,000 26,083
Total 1,954,167 771,067
7.1. Non-compliance with the applicable procurement regulations
The Audit Team found that the procurement processes did not comply with the National procurement
regulations. Non-compliance occurred during the various stages of the procurement process, with
key instances being identified as follows:7.1.1 Procurements were unplanned
The PFA requires the NDoH to prepare an Annual Procurement Plan and submit it to the Inter-agency
Coordinating Committee and Central Supply and Tenders Board for their review and approval. Prior
to the implementation of the plan, the NDoH was required to communicate the approved Plan to the
Gavi Secretariat.
In addition, the Financial Management Manual, 2006 issued by the Department of Finance of GoPNG,
and the Good Procurement Manual, January 2008 issued by Central Supply and Tenders Board,
required the procuring entity to develop a procurement plan before commencement of procurement.
The Audit Team found instances of procurement that were carried in an ad-hoc and piecemeal
manner without identifying the programmatic needs. For frequently purchased consumables such as
stationery and printed materials, a costed Annual Procurement Plan would have achieved better
value for money by identifying potential economies of scale, and by enabling the procuring entity to
negotiate more favourable pricing.
An Annual Procurement Plan would have enabled the EPI unit to consider different options such as
entering into a Long Term Agreement for the repeat purchase of consumables.
In addition, Annual Procurement Plans also facilitate the measurement of progress against
procurement targets.Programme Audit – Papua New Guinea February 2016 Page 35 of 68
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Risks / Effect
Opportunities for economies of scale and price negotiations with vendors were potentially foregone
through failing to adequately plan for procurement.
The practice of initiating piecemeal procurement instances carries the risk of procurement being
subdivided to avoid competitive bidding processes.
The EPI unit’s administrative and transaction costs were potentially higher than necessary.
Recommendation 14 (Essential)The EPI unit, in consultation with its technical partners, should prepare a credible Annual
Procurement Plan and submit for approval as defined by the PFA and National regulations. The
Plan should similarly be shared with NDoH’s procurement unit prior to commencement of
programme activities.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.1.2 Consideration was not given to existing “Whole of Government” contracts
The PFA and GoPNG’s procurement regulations required, for procurement up to an aggregate value of
PGK 300,000, that priority should be given to “Whole of Government” (WoG) contracts insofar as they
exist for the goods or services that are being procured.
The Audit Team noted from its sample review of procurement instances above this threshold, that
there was no evidence to demonstrate that WoG contracts had been considered prior to self-
procuring.Risks / Effect
Opportunities for value for money with existing WoG contracts were missed by not considering these
during the procurement process.
The administrative burden on the EPI unit was unnecessarily increased by self-procurement on
occasions when WoG contracts existed.Recommendation 15 (Essential)
NDoH, in compliance with National procurement regulations, should ensure that all instances of
procurement up to an aggregate value of PGK 300,000:Duly incorporate a consultation step of existing WoG contracts;
Formally document that the consultation of WoG contracts has been carried out;
Formally document the respective decision-taking thereon; and
Select WoG contracts whenever these provide better value for money than self-procurement.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.1.3 No evidence of requests for quotation from tendering vendors
The Financial Management Manual, 2006 issued by the GoPNG’s Department of Finance required that
quotations be requested from tendering vendors in writing. This was applicable for all procurement
with an aggregate value of between PGK 5,000 and PGK 300,000.
The procuring entity is to provide the potential vendors with a complete “Description of
Requirement”, including, but not limited to, quantity, description, delivery requirement, timings,
specifications, standards, drawings, and special conditions etc.
The Audit Team noted that there was no evidence of any form of communication with the vendors
prior to submission of the quotations. There was no documentation on how the vendors had been
shortlisted and requests for quotation undertaken. Furthermore, there was no documented evidence
of due process to review and evaluate vendor quotations.Risks / Effect
The absence of documented communication with tendering vendors does not provide assurance that
requests for quotation were public, fair and transparent.
Similarly the undocumented nature of vendor quotation ratings and short-listing tendering vendors
did not demonstrate due process and fair, unbiased decision-taking.Recommendation 16 (Essential)
For procurement between PGK 5,000 and PGK 300,000, NDoH should ensure that the EPI unit
complies with the provisions of the Financial Management Manual, 2006 issued by the Department of
Finance of GoPNG, specifically documenting and placing on file:End-to-end communication with the tendering vendors; and
Short-listing and vendor selection procedures.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.1.4 Quotation register not maintained
The Financial Management Manual, 2006 issued by the Department of Finance of GoPNG required the
procuring entity to maintain a quotation register to capture pertinent information on supplier quotes
including: quote date, description of goods/service, price quoted, bidder name, name of
departmental officer obtaining the quotation, quote selected to supply goods/services, reason for
selection of the successful quote, and all three quotations received. This requirement applies for
cases of procurement up to an aggregate value of PGK 500,000.
A quotation register provides transparency over how supplier quotes are managed, and it helps to
identify cases of direct procurement or single-sourced supplies.
However, the EPI unit did not maintain a quotation register as required during the period 2013-2015.Risks / Effect
The absence of a quotation register undermines assurance that the most competitive quotes were
selected for each procurement incident.Recommendation 17 (Essential)
NDoH should put in place and maintain a quotation register to transparently manage and track all
respective supplier quotes, in compliance with National regulations.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.1.5 Procurement without Minor Contract Agreements
Section 5.2 of Financial Instruction 2-2013, issued by the Department of Finance in May 2013 as an
amendment to the Public Finances (Management) Act to increase the threshold for major
procurement, states that a Minor Contract Agreement should be executed between the procuring
entity and the vendor(s) for procurement between PGK 50,000 and PGK 500,000. Section 5.1 of the
Financial Instruction required that such contracts be “…executed by the Head of the procuring
Agency”.
The Audit Team reviewed a sample of 41 procurement transactions, totalling PGK 2.5 million (USD
0.97 million) carried out by the EPI unit between 2013 and 2015. However, none of the transactions
qualifying for a Minor Contract Agreement, had been executed with a contract.
Such written contracts were necessary for locking into an agreed price, quantity and quality, and for
stipulating terms and conditions for delivery, cancellation, and payment terms.Risks / Effect
In the absence of a suitable contract or credible purchase order, the procuring entity is at substantial
risk of financial loss and/or sub-standard performance without recourse.Recommendation 18 (Critical)
In compliance with National regulations, the NDoH should ensure that the EPI unit puts in place valid
Minor Contract Agreements for all procurement instances which meet the stated thresholds.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.1.6 Fixed assets registers were not maintained
The Financial Management Manual, 2006 issued by the Department of Finance of GoPNG required
entities at all levels to maintain fixed assets registers to duly record acquisitions and disposals. The
Manual also defined the criteria for what constituted a fixed asset and the requirement for annual
physical inspections of these assets.
The Audit Team noted that no fixed assets registers were maintained for assets acquired with Gavi
funds. Similarly, the EPI unit was unable to substantiate that annual physical inspections had been
carried out. Finally there was no documentation on file evidencing the physical existence, location,
working condition, ownership or usage of assets, as required in the PFA between the NDoH and Gavi.
As a consequence, the EPI unit did not plan and budget for maintenance, repairs and replacement of
its fixed assets.Risks / Effect
Failure to track and manage fixed assets may result in the unplanned use, loss or theft of items being
undetected.
Not conducting routine physical inspections could contribute to the lack of maintenance and poor
working state of fixed assets.
No information is readily available for the EPI unit to plan and budget for maintenance, repairs and
replacement of its fixed assets across the country.Recommendation 19 (Critical)
The NDoH should strengthen its management and oversight over fixed assets by:Carrying out a full physical inventory of existing assets, including verifying the working condition of
items, on a regular basis. Where remediation is necessary, it should ensure that necessary
maintenance is performed and documented;
Recording all assets in a suitable fixed assets register that can be consolidated by funding source
at National level.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.2. Weak internal controls over the EPI unit’s procurement activities
The Audit Team identified systematic internal control weaknesses in procurement handled by the EPI
unit. Ineffective oversight by NDoH over the EPI unit’s purchases resulted in significant shortcomings
in how procurement was conducted.
Specific gaps identified in the procurement processes as reviewed by the Audit Team were as follows:7.2.1 Procurement undertaken outside of the designated procurement unit
The Audit Team noted that the EPI unit duly procured immunisation items and services without
engaging Commercial Support Services as required. Commercial Support Services was intended as the
unit responsible for procurement within the NDoH.
There was no segregation of duties in procurement carried out by the EPI unit over the period 2013-
2015. Roles and responsibilities of the individuals involved in procurement were undefined and
unclear. The person receiving and evaluating the quotation was also found to have received the
goods or services, and to have prepared the request for payment. No suitable controls were in place
to compensate for these incompatible duties.
The principle of segregation of duties is necessary to ensure that no one individual maintains
excessive control over an entire procurement process. This principle significantly mitigates the risk of
mismanagement and the inappropriate awarding of contracts.Risks / Effect
Failing to engage with NDoH’s designated procurement unit:Undermined the principle of segregation of duties by failing to separate key responsibilities; and
Burdened the EPI unit with procurement related tasks that could and should have been delegated
to the Commercial Support Services unit.Recommendation 20 (Critical)
Future procurement involving Gavi funds should be carried out with the appropriate involvement
of NDoH’s Commercial Support Services unit;
There should be a clear segregation of duties between procurement, ordering, receiving goods or
services, preparing requests for payment, approving supplier invoices and executing payments to
suppliers; and
This segregation of duties should be reviewed regularly to ensure it remains appropriate and
relevant.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.2.2 Budget overrun and unbudgeted procurement
The absence of planning, budget monitoring and linking of procurement expenses to budgeted
activities resulted in a significant proportion of Gavi funds being spent on activities that were not in
the grant proposal, nor approved in subsequent workplans.
In 2014, expenditure on printing and stationeries totalled PGK 290,995 (USD 112,208). This
contrasted adversely with the respective HSS budget allocation for the 5-year grant which totalled
USD 9,523. As such, in 2014 alone, the EPI unit exceeded the entire 5-year budget by more than
thirty-fold without any formal budget reallocation and without the necessary due approval and
documentation justifying this overspend.Risks / Effect
Overspend on individual budget lines went unchecked, without any due oversight.
Insufficient funds remained for other budgeted activities, potentially taking away from the
achievement of programme outcomes.Recommendation 21 (Critical)
Budgetary amendments, variations and reallocation of funds should be formally justified and
approved according to the provisions of the PFA;
Procurement should be carried out as per the workplan and with appropriate involvement from
NDoH’s Commercial Support Services unit; and
Supplier payments should be released only by the HHISP Financial Controller assigned to the
NDoH after confirming both the appropriateness of the budget line and the availability of funds.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.3. Inadequacies in procurement documentation and other irregularities
The Audit Team selected a sample of 41 procurement transactions and reviewed associated
documentation relating to vendor selection, delivery of goods and services, supplier invoices and
supplier payments.
Of these 41 transactions:11 were not related to the Gavi programme but had been paid out of Gavi grants;
17 were inadequately supported and contained multiple irregularities; and
13 contained major inconsistencies including timing discrepancies (e.g. purchase preceded
requisition), irregular supplier documentation, disproportionate costs, potential duplicate
funding and other matters. The Audit Team was unable to conclude that procurement had
been conducted correctly.
Consequently, the overview summarised in the table below is preliminary, for information purposes
only, and will be subject to change during a further investigation by review. Final details will be
provided in a separate report.
Table 10: Overview of procurement transactions reviewed by the Audit Team (indicative figures only)Number of
Description transactions PGK USD
Procurement transactions audited A 41 1,954,167 771,067
Procurement unrelated to Gavi programme
B 11 699,602 284,649
funded by Gavi grants3
Procurement related to Gavi and funded by
C 30 1,254,564 486,419
Gavi grants (A minus B)
Procurements inadequately supported and with
irregularities 17 638,179 245,944
(see sections 7.3.1, 7.3.2, 7.3.3 & 7.3.4)
Procurement with major inconsistencies, not
13 616,385 240,475
concluded at the time of auditKey observations made by the Audit Team are reported in the following sub-sections.
3
Expenditure relating to non-Gavi activities included both procurement and non-procurement expenditure. Therefore the
overall status of the refunds and balances is reported under budgeting and financial management section of this audit
report (refer to section 6.1).
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7.3.1 Unsupported procurement
No supporting documentation could be provided to the Audit Team for one transaction amounting to
PGK 24,540 (USD 9,463).
Section 20.1, paragraph (c) of the PFA requires that “…all expenses relating to the use or application
of funds are properly evidenced with supporting documentation sufficient to permit Gavi to verify
such expenses.”Risks / Effect
Inadequate assurance on the appropriate use of Gavi’s financial support.
Risk of Gavi’s financial support being utilised for purposes other than those intended.Recommendation 22 (Essential)
NDoH is required to:Ensure that all transactions and contracts entered into are supported with adequate and complete
supporting documentation; and
Put on file all necessary supporting documentation adequately cross-referenced to the relevant
accounting records.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.3.2 Contracts awarded without demonstrating competition
Out of a total of 6 transactions, vendors had been selected without obtaining the necessary three
quotations in 5 instances.
For the remaining transaction, documentation on file demonstrated that three quotations had been
obtained. However, the decision for selecting a more expensive supplier quotation had not been
documented, and no satisfactory explanation could be given to the Audit Team.
The supporting documentation for each instance of procurement must be able to demonstrate that
open, transparent competition was applied and value for money was obtained.Risks / Effect
Where the selection of vendors is not duly documented and justified, there is an increased risk of
contracting with unqualified or non-competitive vendors.Recommendation 23 (Critical)
In conformity with National regulations, NDoH should ensure that:Vendor selection for Gavi-supported activities is competitive and duly documented;
Only quotations from qualifying suppliers are short-listed and selected; and
Vendor selection be made on the principle of considering best value for money, and any exception
should be duly documented and authorised by an executive function independent of the vendor
selection process.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.3.3 Inadequately supported delivery
9 transactions were identified where delivery or receipt of goods were not adequately supported. Key
observations were:Air travel for EPI employees for which hand-written or incoherent quotations were on file.
However, neither supplier invoices nor evidence of travel, such as boarding pass stubs, was placed
on file; and
The delivery of goods to the National NDoH office (Waigani) and to the AMS (Badili) could not be
observed on either site, had not been recorded in any stock or supply registers, and were not
supported by delivery notes or bills of lading. Personnel from EPI and the AMS explained that
most of these goods were destined for nationwide distribution, however there was no record of
such distribution in the AMS dispatch books, and no trace of delivery in either of the two
Provinces visited by the Audit Team.Risks / Effect
Satisfactory delivery of goods and services cannot be demonstrated or reconstituted without
adequate substantiation for performance.
Inadequate assurance on the appropriate use of Gavi’s financial support.Recommendation 24 (Critical)
NDoH should ensure that the EPI unit:Obtains and maintains in its records adequate proof of delivery from all suppliers; and
Develops and maintains a dry goods inventory incorporating a record of delivery and distribution
of any such goods procured with Gavi’s financial support.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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7.3.4 Payments not supported by a valid invoice and timing inconsistency
3 payments had been made to vendors solely on the basis of their quotations rather than original
supplier invoices. In one instance, payment had been made prior to the date of delivery and without
any written instruction or justification.Risks / Effect
Control over incomplete or non-delivery of goods and performance of services is undermined when
advance payment is made.
Non-compliance with the Public Finances (Management) Act 1995.Recommendation 25 (Essential)
Payment for goods and services should only be made on the basis of:Original supplier invoices; and
On credible confirmation of satisfactory delivery of goods or performance of services in
accordance with agreed terms and conditions.Management comments
See Annex 6 – Management comments and action plan as at 17 October 2016
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Annex 1 – Expenditure related to non-Gavi activities but paid out of Gavi grants
Amount Amount
Reference Payee Description of Goods/Services Date
PGK USD
Origin Energy (PNG)
210306 Ltd Gas Cylin SIA SHP 2012:GAVI 21/11/2013 6,693 2,580.67
Origin Energy (PNG)
210306 Ltd Gas Cylin SIA WHP 2012:GAVI 21/11/2013 13,961 5,383.27
Origin Energy (PNG)
210306 Ltd Gas Cylin SIA Enga 2012:GAVI 21/11/2013 24,125 9,302.64
Origin Energy (PNG)
210306 Ltd Gas Cylin SIA ESP 2012:GAVI 21/11/2013 42,483 16,381.49
Origin Energy (PNG)
210306 Ltd Gas Cylin SIA Vanimo 2012:GAVI 21/11/2013 43,828 16,899.90
Origin Energy (PNG)
210306 Ltd Gas Cylin SIA Madang 2012:GAVI 21/11/2013 44,896 17,311.78
Origin Energy (PNG)
212606 Ltd Gas CylindersX4Prov:GAVI 15/08/2014 71,260 29,503.09Gas Supplies BALANCE 247,244 97,363
212718 Air Niugini Gardasil Proj WNBP H/Train:GAVI 30/08/2012 1,283 495
212719 Kimbe Bay Hotel Gardasil Projct WNBP H/Train:GAVI 30/08/2012 1,531 590
212720 Gerard Sui Gardasil Projct WNBP Sch H/Train:GAVI 30/08/2012 978 377
Gardasil Project 2012 BALANCE 3,792 1,462
212645 Air Niugini Data Quality Assess Vst MBP:GAVI 25/08/2014 1,075 445
212647 Masurina Lodge Data Quality Assess Vt Alotau:GAVI 25/08/2014 1,520 629
212649 Vienna Nonwo Data Quality Assess Vt MBP Aug14:GAVI 25/08/2014 1,121 464
212775 Air Niugini Data Quality AssessLaex2Dist:GAVI 19/09/2014 1,882 779
212776 Robin Misiel Data QualityAssessLaex2Districts:GAVI 19/09/2014 1,321 547
212777 Huon Gulf Hotel Data QualityAssess Laex2Distr:GAVI 19/09/2014 4,146 1,716
212828 Paik Tade Data Assess Morobe Oct 2014:GAVI 30/09/2014 921 381
212841 Air Niugini CollectDataSelctSntinalEHP:GAVI 09/10/2014 1,133 469
212846 Edilson Yano CollectDataSelctSentinalSitesGka:GAVI 09/10/2014 1,156 479
212848 AB Lodge Collect Data SelectedSitesEHP:GAVI 09/10/2014 800 331
212970 Air Niugini Collct Data Sentinental Ste:GAVI 28/10/2014 1,107 458
212976 Madang Resort Hotel Collct Data Sentinal Ste Mdg:GAVI 28/10/2014 2,136 885
212978 Edilson Yano Collect Data Sentinal Ste MDG:GAVI 28/10/2014 921 381
213071 Air Niugini CollectData SentinalSitesLae:GAVI 31/10/2014 911 377
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Amount Amount
Reference Payee Description of Goods/Services Date
PGK USD213074 Edilson Yano CollectDataSentinalSiteNov14Lae:GAVI 31/10/2014 921 381
213078 Phils Hotel CollectDataSentinalSitesLae:GAVI 31/10/2014 945 391
213241 Air Niugini Data Collect Nov&Dec14 Hgu:GAVI 25/11/2014 1,125 466
213242 Hotel Kimininga Data Collect Nov14&Dec14 WHP:GAVI 25/11/2014 1,364 565
213247 Edilson Yano Data Collect Nov14&Dec14 WHP:GAVI 25/11/2014 1,156 479
213425 Masurina Lodge Data Collect Dec14 MBP:GAVI 12/12/2014 1,520 629
213430 Edilson Yano Data CollectMeningitis&Survei:GAVI 12/12/2014 1,121 464
213446 Air Niugini Data Collect Dec14 MBP:GAVI 12/12/2014 773 320
213470 Air Niugini CollectData Dec14-Jan15ENBP:GAVI 16/12/2014 1,455 602
213471 Kokopo Village Resort Collect Data Dec2014-2ndJan15:GAVI 16/12/2014 900 373
213473 Edilson Yano Collect Data Dec14-2ndJan15 ENBP:GAVI 16/12/2014 1,156 479
213494 Paik Tade Data Collect Lae Huon Dis Dec14:GAVI 18/12/2014 1,264 523
213734 Edilson Yano Collect Data Sent Site NIP Feb15:GAVI 30/01/2015 1,086 393
213736 Kavieng Guest House Collect Data Sent Site NIP:GAVI 30/01/2015 1,750 633
213738 Air Niugini Collect Data Sent Site NIP:GAVI 30/01/2015 1,575 569
Sentinal Site Data Collection BALANCE 38,259 15,609
213245 JACOB YAKOPO Nat.EPI&Surveil Meet Dec14 NCD:GAVI 25/11/2014 816 338
213252 Julie Liviko Nat EPI&Surveil Meet Dec14 NCD:GAVI 25/11/2014 851 352
213253 Air Niugini NatEPI&SurveilMeet Dec14 NCD:GAVI 26/11/2014 28,113 11,639
213290 Judy Minape Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 1,016 421
213301 Granvile Motel Nat&EPI Surveil Meet Dec14 NCD:GAVI 28/11/2014 46,455 19,233
213345 LINNAH ALE EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 838 347
213347 Ernest Giton EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 851 352
213348 Gekso Dawa EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 838 347
213349 Margaret Malaisa EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 851 352
213350 Reuben Maiwax EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 838 347
213351 Elvis Pyrikah EPI&Survil Meet Dec14 NCD:GAVI 28/11/2014 851 352
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Amount Amount
Reference Payee Description of Goods/Services Date
PGK USD213352 Casper Amin EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 851 352
213353 Narua Kaparu EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 981 406
213354 Alice Honjepari EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 816 338
213355 Ben Bal EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 686 284
213363 Lina Laki EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 838 347
213364 Jack Seimoni EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 851 352
213365 Lucy Morris EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 981 406
213366 Maupua Toraea EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 981 406
213367 Patricia Mitiel EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 816 338
213368 Morfa Aruko Incid EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 258 107
213369 Wenani Bokung EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 838 347
213370 Joshua William EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 816 338
213371 Ridley Mwaisiga EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 816 338
213372 Anthony Mala EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 816 338
213373 Esley Tabagani EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 816 338
213374 Moses Mimat EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 851 352
213375 Dickson Kungkene EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 851 352
213408 Bethseba Peni Nat EPI&Surveil Meet Dec14 NCD:GAVI 10/12/2014 851 352
213431 Conrad Kambi Nat EPI&Surveil Meet Dec14 NCD:GAVI 12/12/2014 838 347
213447 Likas Lakain Nat EPI&Surveil Meet Dec14 NCD:GAVI 12/12/2014 816 338
213448 ALOIS PUKIENEI Nat EPI&Survei Meet Dec14 NCD:GAVI 12/12/2014 981 406
213476 Edwin Benny Nat EPI&Surveil MeetDec14 NCD:GAVI 16/12/2014 816 338
213492 Max Manape Nat EPI&Surveil Meet Dec14 NCD:GAVI 18/12/2014 851 352
213493 Julie Wialu Nat EPI&Surveil Meet Dec14 NCD:GAVI 18/12/2014 816 338
213235 Air Niugini Nat EPI Surveil Meet NCD Dec14:WHO 24/11/2014 53,144 22,003
213243 Philip Wanua Nat EPI&Surveil Meet Dec 14 NCD:GAVI 25/11/2014 851 352
213244 Jackson Appo Nat EPI&Survey Meet Dec14 NCD:GAVI 25/11/2014 851 352
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Amount Amount
Reference Payee Description of Goods/Services Date
PGK USD213248 Albert Paliago Nat.EPI&Surveil Meet Dec14 NCD:GAVI 25/11/2014 816 338
213251 Lina Kua Nat EPI&Survey Meet Dec14 NCD:GAVI 25/11/2014 851 352
213254 Roselyn Gatana Nat EPI&Surveil Meet Dec14 NCD:GAVI 26/11/2014 981 406
213255 Nicholas Larme Nat EPI&Surveil Meet Dec14 NCD:GAVI 26/11/2014 873 361
213256 August Mann Nat EPI&Surveil Meet Dec14 NCD:GAVI 26/11/2014 816 338
213257 Samuel Disin Nat EPI&Surveil Meet Dec14 NCD:GAVI 26/11/2014 981 406
213258 Helen Lale Nat EPI&Surveil Meet Dec14 NCD:GAVI 26/11/2014 816 338
213259 Fred Mondo Nat.EPI&Surviel Meet Dec14 NCD:GAVI 26/11/2014 816 338
213260 Obert Abel Nat EPI&Surveil Meet Dec14 NCD:GAVI 26/11/2014 873 361
213261 Peter Robin Nat EPI&Surveil Dec14 NCD:GAVI 26/11/2014 873 361
213262 Jinga Haine Nat DPI&Surveil Meet Dec14 NCD:GAVI 26/11/2014 851 352
213263 Pana Rim Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 258 107
213264 Copland Ihove Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 686 284
213265 John Pokam Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 816 338
213266 David Lapun Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 816 338
213267 Jerry Kubu Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 851 352
213268 Steven Show Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 851 352
213269 Micah Zilu Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 851 352
213270 Michael Mombu Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 816 338
213271 Mark Dupi Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 851 352
213272 Robin Yakomb Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 851 352
213273 Matilda Soagai Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 981 406
213274 Henry Yapen Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 851 352
213281 Granvile Motel Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 68,765 28,470
213285 Joachim Taulo Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 838 347
213286 Jeffery Langi Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 851 352
213287 Jenny Walete Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 851 352
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Amount Amount
Reference Payee Description of Goods/Services Date
PGK USD213288 Johannes Kundal Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 816 338
213289 Dr Hamiya Hewali Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 1,016 421
213291 Julianne Hayara Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 1,016 421
213292 Norman Vakore Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 851 352
213293 Edward Maika Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 838 347
213294 Gedjolly Aaron Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 838 347
213295 Rebecca Thoridoe Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 851 352
213296 Singut Bieb Nat EPI&Surveil Meet Dec14 NCD:GAVI 27/11/2014 258 107
213346 Micah Yawing EPI&Surveil Meet Dec14 NCD:GAVI 28/11/2014 651 270
213362 Micheal Uaiz Incid Nat EPI&Surveil Dec14 NCD:GAVI 28/11/2014 258 107
– –
75 Chq#213228,245,252,330&443 24/12/2014 1,667 690
– –
53 Hepatitis B Birth Dose 27/10/2015 152,388 63,092National EPI Surveillance Meeting BALANCE 100,665 41,678
– –
22 Hepatitis B Birth EPI 21/05/2015 151,124 62,569213170 Bayviews Apartments Veh HepatitisB Birth DoseM/Bay:GAVI 19/11/2014 8,150 3,374
213171 Air Niugini Hepatitis B Birth Dose Surv:GAVI 19/11/2014 15,111 6,256
213172 Kimbe Bay Hotel Hepatitis B Birth Dose Survey:GAVI 19/11/2014 5,760 2,385
Birdwing Butterfly
213173 Lodge Hepatitis B Birth Dose Survy:GAVI 19/11/2014 5,950 2,463213174 Nortons Rent A Car Veh Hepatitis B BirthDose Surv:GAVI 19/11/2014 10,100 4,182
Westoil Transport
213175 Services VehHepatitis B BirthDoseSurvey:GAVI 19/11/2014 7,700 3,188213176 Bayviews Apartments Hepatitis B Birth Dose Survey:GAVI 19/11/2014 4,650 1,925
213178 Catholic Guest House Hepatitis B Birth Dose Survey:GAVI 19/11/2014 3,500 1,449
Newton
Pacific&Associates
213179 PNG Veh Hepatitis B BirthDose Surv:GAVI 19/11/2014 8,701 3,602213277 Johnnie Arava Hepatitis B Survey Hela&Enga:GAVI 27/11/2014 1,756 727
213278 Dr Edward Waramin Hepatitis B Survey ARoB Dec14:GAVI 27/11/2014 2,556 1,058
213279 Gerard Sui Hepatitis B Survey WNB Nov-Dec14:GAVI 27/11/2014 2,521 1,044
213282 Magaru Maluo HepatitisB Survey Hela Nov-Dec14:GAVI 27/11/2014 2,521 1,044
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Amount Amount
Reference Payee Description of Goods/Services Date
PGK USD213283 Louis Samiak Hepatitis Survey Oro Prov Dec14:GAVI 27/11/2014 1,143 473
213284 Philip Vagi Hepatitis Survey ENBP Nov-Dec14:GAVI 27/11/2014 2,556 1,058
213299 Kokopo Village Resort HepatitisBBirthDoseSurv11Prov:GAVI 28/11/2014 3,300 1,366
213300 Johnnie Arava Hepatitis BBirthDose Surv11Prov:GAVI 28/11/2014 1,172 485
213304 Martha Pogo Hepatitis BBirthDoseSurvey10Prov:GAVI 28/11/2014 2,172 899
213305 Louis Samiak HepatitisBBirthDoseSurvey10Prov:GAVI 28/11/2014 721 299
213306 Sebastian Robert HepatitisBBirthDoseSurvDec14WNBP:GAVI 28/11/2014 2,486 1,029
213307 Nelson Mek HepatitisBBirthDoseSurv11Prov:GAVI 28/11/2014 2,521 1,044
213308 Joseph Wasam HepatitisBBirthDoseSurvey11Prov:GAVI 28/11/2014 2,556 1,058
213309 Emily John HepatitisBBirthDoseSurvey11Prov:GAVI 28/11/2014 2,743 1,136
213336 Freda Walai Sui AcomHepatitusBBirthDoseSurv:GAVI 28/11/2014 600 248
OnePine Vehicle Hire
213337 Service Veh Hepatitis B BirthDosesCP:GAVI 28/11/2014 9,273 3,839213338 Nortons Rent A Car VhHepatitisBBirthDoseSurveEnga:GAVI 28/11/2014 4,150 1,718
213339 Freda Walai Sui Hepatitis B Birth Dose Survey CP:GAVI 28/11/2014 810 335
OnePine Vehicle Hire
213340 Service VehHepatitisBBirthDoseSurvGulf:GAVI 28/11/2014 9,273 3,839213342 Hani’s Inn HepatitisBBirth Dose SurvARoB:GAVI 28/11/2014 4,318 1,788
Yakam Resort Co-op
213343 Society Ltd Hepatitis B BirtDose SurvEnga:GAVI 28/11/2014 3,864 1,600213344 West Winds Hire Cars VehHepatitisBBirthDoseSurvARoB:GAVI 28/11/2014 10,800 4,471
Island Mobile Hire
213410 Cars Ltd VehHepatitisBBirthDoseSurvOro:GAVI 10/12/2014 7,691 3,184Hepatitis B Birth dose survey BALANCE – –
210240 Maho Media Measles O/Break B/Lets Hosp:GAVI 11/10/2013 11,051 4,261
210241 Maho Media Measles O/Break G/Lin B/Lets:GAVI 11/10/2013 14,300 5,514
210165 Air Niugini Outbreak Measles Nov13 ESP:GAVI 31/10/2013 1,473 568
210166 Sea View Hotel Measles Outbreak Nov13 ESP:GAVI 31/10/2013 1,700 656
210167 Gerard Sui Measles Outbreak Nov13 ESP:GAVI 31/10/2013 1,286 496
210242 Maho Media Measles O/Break G/Line B/Lets:GAVI 11/11/2013 11,051 4,261
210243 Maho Media Measles O/Break G/Line B/Lets:GAVI 11/11/2013 14,300 5,514
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Amount Amount
Reference Payee Description of Goods/Services Date
PGK USD
Stephens Printing &
210262 Stationary Measle O/B Guidlne B/Let Hosp:GAVI 12/11/2013 13,440 5,182211308 Air Niugini O/S TT Rpt&Monitor Measles:GAVI 17/06/2014 1,127 466
211309 Madang Resort Hotel O/S TT Rprt&Monitor Measles:GAVI 17/06/2014 1,591 659
211311 No.1 Hire Car Veh O/S TT Rpt&Monitor Measles:GAVI 17/06/2014 3,546 1,468
211312 Vienna Nonwo O/S TT Rprt&Monitor Measles MDG:GAVI 17/06/2014 1,156 479
212917 Rael Limited Veh Measles O/Break Jul14 NCD:GAVI 22/10/2014 11,050 4,575
Measles Outbreak BALANCE 87,069 34,099
Travel Planners (PNG)
212593 Limited New Born CarePom 18-22/8/14:GAVI 15/08/2014 8,710 3,606212595 Stella Jimmy NewBorn Care TOT 18-22/8/14 Pom:GAVI 15/08/2014 1,346 557
212597 Belinda Yamkeok NewBorn Care TOT 18-22/8/14 Pom:GAVI 15/08/2014 1,346 557
212598 Paul Wari NewBorn Care TOT 18-22/8/14 Pom:GAVI 15/08/2014 1,181 489
212599 Karen Sanga NewBorn Care TOT 18-22/8/14 Pom:GAVI 15/08/2014 1,181 489
– –
44 Chq#211051,600,675,676,680&etc 30/09/2014 1,181 489212594 Hotel Hodava Confer Room&Accom NewBorn Care:GAVI 15/08/2014 25,225 10,444
212596 Angela Seginami NewBorn Care TOT Pom 18-22/8/14:GAVI 15/08/2014 1,346 557
212600 Julie Liviko NewBorn Care TOT 18-22/8/14 Pom:GAVI 15/08/2014 1,181 489
– –
53 Hepatitis B Birth Dose 27/10/2015 26,571 11,001Newborn Care BALANCE 13,764 5,699
Countrywide Business
212708 S&Distrib Vaccine Routine Mgmnt Forms:GAVI 30/08/2014 142,995 59,203212969 MAF & PRINTZ FAQs Routine Immuniz Measles:GAVI 28/10/2014 47,000 19,459
Routine Immunization Activities BALANCE 189,995 78,662
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Annex 2 – Definitions of Ratings and Recommendation Priorities
A. AUDIT RATINGS
The Gavi Programme Audit Team’s assessment is limited to the specific audit areas under the purview
and control of the primary implementing partner administrating and directing the programme of
immunisation. The three audit ratings are as follows:
Satisfactory – Internal controls and risk management practices were adequately established
and functioning well. No high-risk areas were identified. Overall, the entity’s objectives are
likely to be achieved.Partially Satisfactory – Internal controls and risk management practices were generally
established and functioning, but needed improvement. One or more high- and medium-risk
areas were identified that may impact on the achievement of the entity’s objectives.Unsatisfactory – Internal controls and risk management practices were either not established
or not functioning well. The majority of issues identified were high risk. Hence, the overall
entity’s objectives are not likely to be achieved.B. CATEGORIES OF PRIORITISATION RATING
The prioritisation of the recommendations included in this report includes proposed deadlines for
completion as discussed with the National Department of Health, and an indication of how soon the
recommendation should implemented. The urgency and priority for addressing recommendations is
rated using the following three-point scale, as follows: Critical – Essential – Desirable.Programme Audit – Papua New Guinea February 2016 Page 56 of 68
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Annex 3 – Classification of expenditure
Adequately supported – Expenditures validated on the basis of convincing evidence (evidence which is
sufficient, adequate, relevant and reliable) obtained by the auditors during the carrying out of their
mission on the ground.Inadequately supported – This covers two sub-categories of expenditure:
a) Purchases: This is expenditure for which one or more of the essential items of documentary evidence
required by the country’s regulations on procurement are missing such as procurement plan, tender
committee review, request for quotation, invoice, contract, purchase order, delivery note for goods
and equipment, pro-forma invoice, the final invoice, etc.b) Programme activity: This is expenditure where essential documentation justifying the payment is
missing. This includes but is not limited to travel without a travel authorisation, lack of a technical
report or an activity report showing completion of the task, signed list by participants. Lack of the same
documents to support liquidation of advances/floats given for meetings/trainings/workshops etc.Irregular Expenditure – This includes any deliberate or unintentional act of commission or omission
relating to:a) The use or presentation of documents which are inaccurate, incomplete/falsified/inconsistent
resulting in the undue use or payment of Gavi funds for activities, or the undue, withholding of monies
from funds granted by Gavi,b) The embezzlement or misappropriation of funds to purposes other than those for which they were
granted.Ineligible expenditure – Expenditure which does not comply with the country’s programme/grant
proposal approved by Gavi or with the intended purpose and relevant approved work plans and
budgets.Programme Audit – Papua New Guinea February 2016 Page 57 of 68
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Annex 4 – Audit Procedures and Reporting
Audit procedures
Using risk-based audit procedures, the audit included an analysis of reported expenditure (in the
Annual Progress Reports or any other periodical financial reports), inquiry/ discussions, computation,
accuracy checks, reconciliation and inspection of records/ accounting documents and the physical
inspection of assets purchased and works performed using grant funds.
The following procedures were carried out:Review of the Financial Management arrangements for the programmes, focusing on the
control procedures e.g. appropriation and approval, segregation of duties, roles and
responsibilities, reconciliation, verification of delivery of goods and services, invoice
verification, retirement of advances controls and imprest;
Review of the arrangements for managing the bank accounts, including tracing withdrawals
and transfers from the programme and designated accounts to determine that they are for
eligible expenditure for the programmes;
Verification, on a sample basis, of procurement undertaken to ensure that the applicable
policies and procedures are strictly adhered to and that transparency and value for money is
maintained;
Review of the mechanism for channelling cash advances from the NDoH to the various budget
management centres at the various levels (regional and District) to ensure that there are
adequate internal controls in place to timely liquidated such advances;
Undertaking field visits to regions and Districts to review flow of funds and to determine
whether principal activities took place according to the work plan/ schedule of cash advances;
Visit to the central, regional and District stores to ensure that stock management procedures
are being well implemented;
Physical verifications, on a sample basis, to check the actual delivery of goods, works and
services purchased as per the source documents;
Review of expenditure and identifying expenditure which are not eligible for funding from Gavi
programme funds.Reporting
At the end of the audit, key findings were discussed with the senior management team of PNGs NDoH
on 16 February 2016, and to a broader audience of EPI and core partner representatives on
17 February 2016 comprising a presentation summarising these findings.Programme Audit – Papua New Guinea February 2016 Page 58 of 68
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Annex 5 – Acronyms
AMS Area Medical Stores
CDC Centers for Disease Control, Department of Health and Human Services, U.S.A.
DoF Department of Finance
EPI Expanded Programme on Immunisation
EVM Effective Vaccine Management
GoPNG Government of the Independent State of Papua New Guinea
HSS Health Systems Strengthening
HSIP Health Sector Improvement Program
HHISP Health & HIV Implementation Services Provider
IPV Injectable Polio Vaccines
ISS Immunisation Services Support
KRA Key Result Area
MR Measles Rubella
NDoH National Department of Health
NGO Non-governmental organisation
PCV Pneumococcal Conjugate Vaccine
PFA Partnership Framework Agreement
PFMA Public Finances (Management) Act 1995
PGK Papua New Guinean Kina
PNG Independent State of Papua New Guinea
R&I Reception and Inspection
SIREP Special Integrated Routine EPI Strengthening Program
TAP Transparency and Accountability Policy
USD United States dollars
VIG Vaccine Introduction Grant
VVM Vaccine Vial MonitoringProgramme Audit – Papua New Guinea February 2016 Page 59 of 68
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Annex 6 – Management comments and action plan as at 17 October 2016 – Vaccine Supply Management (1/3)
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Audit and Investigations Gavi Programme Audit
Annex 6 – Management comments and action plan as at 17 October 2016 – Procurement (1/2)
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Audit and Investigations Gavi Programme Audit
Annex 6 – Management comments and action plan as at 17 October 2016 – Procurement (2/2)
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