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Audit of Indian Health Service's COVID-19 Vaccine Policies and Procedures for COVID-19 Vaccines Distributed to Tribal Health Programs

The COVID-19 pandemic has disproportionately affected American Indian and Alaska Native (AI/AN) populations nationwide. The Centers for Disease Control and Prevention (CDC) reported that the age-adjusted AI/AN population's mortality rate from COVID-19 was 1.8 times higher than that among non-Hispanic whites as of December 2020. The Indian Health Service (IHS) has issued its COVID-19 Pandemic Vaccine Plan detailing how the IHS health care system will distribute, allocate, and administer the COVID-19 vaccine. The CDC recommended that all jurisdictions be prepared to immediately vaccinate identified critical populations as the earliest COVID-19 vaccine doses became available and were granted emergency use authorization. IHS is recognized as a "coordinator," similar to a State or other jurisdiction, for vaccine distribution. Tribal Health Programs and Urban Indian Organizations had the option to receive vaccines through either the IHS or their State. IHS direct facilities receive the vaccine through IHS. Approximately 338 facilities elected to receive vaccines through the IHS (including IHS direct facilities, Tribal Health Programs, and Urban Indian Organizations). We will focus on IHS's coordination of the distribution, allocation, and administration of the vaccine to Tribal Health Programs. The objective of this audit is to determine whether IHS followed the Memorandum of Agreement for the CDC COVID-19 Federal Agency Vaccination Program and the IHS COVID-19 Pandemic Vaccine Plan to coordinate the distribution, allocation, and administration of the vaccines to Tribal Health Programs to protect AI/AN beneficiaries. This objective will allow us to review the OIG priority area of promoting public health and safety with respect to services provided to the vulnerable population served by IHS. It will also allow us to address particularly critical goals that bear directly upon OIG's mission and that are identified in the OIG Strategic Plan: Oversight of COVID-19 Response and Recovery. These goals include protecting the health and safety of the AI/AN population that receives health care services through IHS programs and identifying opportunities to increase the effectiveness of IHS's COVID-19 response. We will review the policies and procedures that IHS had in place during our audit period and evaluate the measures implemented by Tribal Health Programs during Phases 1a and 1b of their vaccination programs—specifically, the measures to distribute, allocate, and administer the COVID-19 vaccines developed by Pfizer-BioNTech and the Moderna—for the period of December 11, 2020, through February 28, 2021. We will select a sample of Tribal Health Programs to review and will identify best practices as well as challenges that Tribal Health Programs have faced when coordinating the distribution, allocation, and administration of COVID-19 vaccinations.

Announced or Revised Agency Title Component Report Number(s) Expected Issue Date (FY)
Completed Indian Health Service Audit of Indian Health Service's COVID-19 Vaccine Policies and Procedures for COVID-19 Vaccines Distributed to Tribal Health Programs Office of Audit Services W-00-21-59455;
A-07-21-04125		 2023