Sanford
Corrective Action Plan
December 31, 2023
Finding 2023-001 – Suspension and Debarment/Procurement
Information on the federal program:
Federal Agency: United States Department of Health and Human Services, Health Resources
and Services Administration (HRSA)
Assistance Listing: 93.155
Award ...
Sanford
Corrective Action Plan
December 31, 2023
Finding 2023-001 – Suspension and Debarment/Procurement
Information on the federal program:
Federal Agency: United States Department of Health and Human Services, Health Resources
and Services Administration (HRSA)
Assistance Listing: 93.155
Award Year: 2021
Planned corrective actions:
As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third-party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford’s compliance department to ensure that there are no findings that would be of concern to Sanford’s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford.
To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 23,754 vendors in 2023. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds.
Sanford’s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to the vendors that are suspended or debarred. Sanford believes the risk of any material disbursement to suspended and debarred vendor is effectively mitigated through existing preventive and detective internal controls.
In August 2023, Sanford began documenting a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford enhanced its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results generated through the vendor setup process.
Responsible official: Tracy Sattler, Director of Compliance and Melanie Paape, Vice President of Supply Chain Operations
As it relates to the procurement of goods and services, Sanford’s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being utilized for procurement. Sanford believes the risk of any material disbursement subject to procurement is effectively mitigated through existing preventive and detective internal controls.
To provide context on the scale of procurement under the program $2,298,733 in expenditures exceeded the micro purchase threshold and $307,249 were found to have inadequate documents for sole source. Sanford will provide education to applicable departments related to the compliance requirements subject to procurement. Sanford will document the procurement process from the initial approval to potential sale/disposition items.
Responsible official: Kristi Crawford, Director of Office of Grants
Anticipated completion date: June 30, 2024