Finding 573812 (2024-001)

-
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-08-19
Audit: 364476
Organization: Franciscan Alliance, Inc. (IN)

AI Summary

  • Core Issue: Sole source transactions totaling $60,192 were made without timely justification, violating procurement policies.
  • Impacted Requirements: Non-compliance with 2 CFR 200.320(c) and internal policies regarding competitive bidding and documentation.
  • Recommended Follow-Up: Improve internal controls to ensure timely documentation and adherence to procurement processes to avoid management bias.

Finding Text

Cluster: Not applicable Federal Granting Agency: Department of Treasury Pass Through Entity: Indiana Department of Health Award Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Year: 2024 Assistance Listing #: 21.027 Federal Award Identification Number: Contract#0000000000000000000065435 Criteria In accordance with 2 CFR 200.320(c) and Franciscan's policy, vendors above a micro-purchase threshold ($10,000 based on Franciscan’s policy) require a competitive process that includes soliciting multiple bids/quotes to justify best value, unless a sole sourcing method is justified. The Uniform Guidance requires purchasing decisions to be documented, including sole source justification, as applicable. Condition We identified one vendor with sole source transactions totaling $60,192 for which a purchase order was dated in March 2024. Sole source justification documentation was not prepared at the time of procurement in March 2024, but rather was prepared in April 2025. Cause Management did not timely prepare sole source justification related to one vendor prior to procurement of services. Effect The lack of a competitive procurement process, or a sole sourcing justification, could lead to Franciscan experiencing management bias in vendor selection or to miss out on better prospective vendors to do business with. Questioned Costs None noted. Recommendation We recommend that Franciscan enhance its internal control around the adherence to procurement methods established within the Uniform Guidance, and within Franciscan’s procurement policies, including the performance, and documentation of, the required justification for performing a sole sourcing procurement ensuring timeliness of procurement procedures and documentation. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.

Corrective Action Plan

Management of Franciscan Alliance, Inc. and Affiliates (“Franciscan”) considers the implementation and monitoring of effective internal controls to be one of its most important responsibilities, especially as they relate to the funds received from the Federal government. Management has continued to promote sound business practices and effective internal controls across the organization through communication, training, and consistent enforcement of the Franciscan’s policies. The following are the Views and Corrective Action Plans of Management regarding the Schedule of Findings and Questioned Costs for the year ended December 31, 2024 for Franciscan. AUDIT FINDING 2024-001 – Compliance with Reporting Requirements MANAGEMENT’S RESPONSE: Management concurs that the sole source justification was not formally documented prior to the time of procurement. Franciscan’s procurement policy already includes clear criteria for sole source contracting, including the requirement that such procurements be supported by documented justification and approved by the Vice President Supply Chain. The policy outlines specific conditions under which sole source justification is permitted and requires Supply Chain to verify price reasonableness using benchmarking tools or known pricing data. CORRECTIVE ACTION PLAN: Franciscan implemented a new procurement software in the fourth quarter of 2024. The software has a required field for users to select if the procurement is sole-source and if it is, another required field activates for the user to provide a reason for sole-source. Once a procurement request is submitted by the user, the sourcing team reviews the request and verifies it has the appropriate approval if it is sole-sourced. RESPONSIBLE PERSONS: Sarah Burdick, Administrative Director Strategic Sourcing, Franciscan Alliance, Inc. COMPLETION DATE: December 2024

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $752,303
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $615,072
84.063 Federal Pell Grant Program $502,250
93.493 Congressional Directives $425,191
84.268 Federal Direct Student Loans $218,966
93.268 Immunization Cooperative Agreements $211,392
16.575 Crime Victim Assistance $159,517
93.994 Maternal and Child Health Services Block Grant to the States $143,800
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $122,966
93.107 Area Health Education Centers $95,177
93.110 Maternal and Child Health Federal Consolidated Programs $92,863
84.425 Covid-19 - American Rescue Plan - Elementary and Secondary Schools Emergency Relief Fund $64,291
93.211 Telehealth Programs $40,000
84.007 Federal Supplemental Educational Opportunity Grants $25,000
12.420 Military Medical Research and Development $11,692
93.165 Grants to States for Loan Repayment $5,000
84.033 Federal Work-Study Program $3,359