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1、July 15, 1994Mr. Ronald K. BremerCorporate Director of FinanceSaint Lukes Hospital4400 Wornall RoadKansas City, Missouri 64111Dear Mr. Bremer:We were engaged to perform a review of the purchasing and receiving internal control procedures at Saint Lukes Hospital (Saint Lukes), which includes the area
2、s of purchasing, receiving and accounts payable. Our focus was on current policy and procedures as performed, with identification of areas for improvement in internal controls. Our detailed observations and related recommendations on internal controls are included in the next section of this report.
3、During the course of our review of internal controls, we also identified various opportunities for improvement in the purchasing procedures. We have provided you with our observations and recommendations in this report. We have identified them primarily because we believe that improvement in interna
4、l control is closely linked with, if not dependent on, improvement in the effectiveness and efficiency of the purchasing operations.Project ApproachIn order to gather the necessary information for our review, we performed the following work steps:Reviewed a work plan with Chuck Robb and Gene Meyer b
5、efore field work began which outlined the project approach, timetable and expectations. Developed a listing of key personnel to interview and scheduling timeframe. Held discussions with department heads and other personnel from Purchasing, Receiving, Accounting, Accounts Payable and Materials Manage
6、ment.Held discussions with department personnel in Orthopedics, Surgical Services, Continuing Medical Education, Marketing and Security.Performed job observations in Purchasing, Receiving, Materials Management and user departments.Produced process maps of the general purchasing procedures and compar
7、ed to Global Best Practices knowledge base. Inquired of materials management personnel regarding all receiving points of purchased supplies at Saint Lukes. Inquired of personnel familiar with the materials management system regarding access to data in the system. Reviewed Policy 955 - PurchasingRevi
8、ewed Policy 950 - Conflict of InterestReviewed conflict of interest policies and procedures for adequate coverage, and met with the Conflict of Interest Committee. Overall AssessmentWe believe there is room for improvement in internal controls as well as to the overall process. Overall, the system a
9、ppears to operate in an effective fashion, but there are various opportunities throughout the process where a breakdown could occur. It appears that the “80/20 rule” applies (the majority of dollars spent relate to a relatively small number of larger vendors), especially with the VHA purchasing grou
10、p. It also appears that most of the opportunities for process breakdowns lie with the smaller vendors, not the vendors where the majority of dollars are spent.RecommendationsOur detailed recommendations are included in the following sections. We have split our observations and recommendations in the
11、 following manner:Internal Controls:-Decentralized Procurement-Unauthorized Purchases-Non-Standard Procedures-Receiving-Access to Materials-Inventory Management-Systems Issues-Vendor Management-Conflict of Interest StatementsOperations:-Communication/Education-Administrative Tasks-Exceptions-Automat
12、ion-Process Streamlining-Cost Savings-Purchasing Strategies-Vendor Maintenance-Performance MeasurementSome of our general recommendations are as follows:Educate departments on the necessity of purchasing controls. This will open communication, and cooperation will be enhanced.Formalize the process f
13、or annual review and documentation of the conflict of interest policy.Establish a single purchasing contact person in each department who will be responsible for compliance with purchasing policies and procedures.Receiving reports should not include the quantity ordered. Exclusion will mitigate the
14、risk of orders not being counted or excess items being stolen.Invoices should be sent directly to accounts payable. Departments should not request that invoices side-step payables.Receiving reports should be sent only to the receiving area. These should never be routed through purchasing.Receiving r
15、eports should only be accepted with adequate proof of delivery.Review access points (doors, gates, locks, etc.) for access and security.Provide feedback to appropriate levels of management that identify departments that are circumventing stated purchasing policies and procedures.Develop updated proc
16、edures manuals which are distributed and clearly communicated to user departments.Reemphasize the revised purchasing policies, especially policy 955-11; 955-12 and 95513.Moving ForwardWe understand that the process of implementing change is difficult, especially when there seems to be enormous oppor
17、tunity with limited time and resources. In this report, we have included some specific recommendations for a phased implementation approach for our internal control improvement recommendations.We applaud the effort being made by Saint Lukes to ensure that sufficient controls exist over the procureme
18、nt of goods and services. Additionally, we think Saint Lukes should focus on improvements in the operations, as well. Continuous improvement is important for any organization, and we believe the Saint Lukes has an opportunity to make great strides in improving its procurement controls and procedures
19、. We would be glad to assist Saint Lukes in the process of further clarifying what changes are necessary, prioritizing change initiatives and facilitating the implementation of these initiatives.We look forward to discussing this report with you in the near future. If you have any questions or comme
20、nts, please call Tony Tomandl at (816) 292-7516 or Ross Rydberg at (816) 292-7546.Very truly yours,Internal ControlsThe following observations and recommendations pertain to the area of internal control. The observations are meant to reflect what we consider to be important in understanding the cont
21、rol environment and developing recommendations. The recommendations listed are potential opportunities for improvement. At the end of this section, we have attempted to prioritize these recommendations into a phased implementation plan.We believe emphasis should be placed on changing and improving p
22、rocesses which will enable departments to purchase items efficiently, effectively and economically and remain in compliance with purchasing policies and procedures.A.Decentralized ProcurementObservationsSome departments are ordering on their own in at least some situations. Some departments are purc
23、hasing outside of the standard process. They are selecting, negotiating and placing orders with vendors on their own.There are a large number of people buying and receiving throughout the organization.There is a general feeling in certain departments that standard purchasing policies are in conflict
24、 with the mission of the department.In some cases, departments can call and get a purchase order number over the phone if the vendor is not new.In some cases, the person placing orders is also receiving merchandise in the user departments. Departments have less problems in adhering to standard purch
25、asing procedures when there is one contact person that interfaces with Purchasing.In one case, when the purchasing director explained purchasing policies and reasons to the department, they became better at adhering to policies.Recommendations1.Establish a single purchasing contact person in each de
26、partment. This person would be responsible for compliance with purchasing policies and procedures. This person should be well trained in these areas.2.Establish a mechanism to track and report on orders placed directly to the vendor without contacting Purchasing and orders received directly by the d
27、epartments.3.Educate departments on the necessity of purchasing controls. 4.Reemphasize the revised purchasing policies, especially policy 955-11 (purchasing control); 955-12 (pricing, quotes and negotiations) and 95513 (requests for purchase).Implementation CategoryIIIIIIB.Unauthorized PurchasesObs
28、ervationsEmergency purchases may be made on the weekend without a purchase order. The standard procedure is to call the vendor with the purchase order number the next working day.Accounts payable encounters many problems with invoices being sent without purchase order numbers (approximately 20-30%).
29、 The invoice is then either sent back to the vendor or the department. This especially happens with services. There are no exception reports on the number of invoices sent without purchase order numbers. Accounts Payable follows-up in approximately 30 days, but there is no report of invoices outstan
30、ding.Most vendors request purchase order numbers before they will take an order. Departments are able to purchase items from certain vendors without purchase order numbers because they have established good relationships.Recommendations1.Increased use of blanket purchase orders and pre-arranged cont
31、racts (each including negotiated price discounts) would reduce the need for departments to order on an item-by-item basis without a purchase order.2.Accounts Payable should communicate all instances of invoices received without a purchase order to department management.3.Departments should be requir
32、ed to justify instances where they are purchasing without valid purchase order numbers.4.Categorize purchases into routine, priority and emergency. Clear definitions, along with policies and procedures, should be established for each of these categories. Reports should be produced and which identify
33、 the number and type of priority and emergency purchases by department. Departments should be able to justify each of these purchases, based on the established definition. Departments, along with Purchasing, should take measures to reduce the number of these types of purchases. Implementation Catego
34、ryIIIIIIIIIC.Non-Standard ProceduresObservationsSome departments send receiving reports to purchasing, some to the warehouse.There are different procedures for receiving among departments. Some are filling out receiving reports, some send the receiver in with the purchase order request, etc.Occasion
35、ally vendors are sending invoices to the departments, often at the request of the user department.There is a lack of clear communication to the entire organization regarding acceptable purchasing practices.Recommendations1.Develop an awareness at the department level of what internal control risk is
36、 and the potential effects of system abuse.2.Develop a detailed procedures manual that would handle all exceptions to the current documented purchasing policies. These procedures should be clearly communicated to all user departments and updated regularly.3.All receiving reports should be sent direc
37、tly to the receiving warehouse for entry into the system. Receiving reports should never be sent to Purchasing.4.All invoices should be sent directly to Accounts Payable. Purchase orders should be clearly marked as to where invoices should be sent.Implementation CategoryIIIIID.ReceivingObservationsT
38、he warehouse will not deliver goods or check them in if there is not a purchase order number on the packing list. Goods will sit on the warehouse dock until a purchase order can be found unless it is a medical product that is needed immediately.All packing lists are sent to Purchasing after Receivin
39、g has entered them into the system.When a shipment arrives, the warehouse prints a receiving worksheet which shows the quantity ordered and a description of the merchandise.Departments are required to sign for deliveries that come from the warehouse. These receiving documents come to the Warehouse a
40、nd are filed. There is no reconciliation between what is sent from the warehouse and what is received by the departments.In some cases, departments are sending in receiving documents before they are actually receiving the merchandise or services.Receiving routes all receiving documents to Purchasing
41、 once they are input into the system.In some cases, the same person is both ordering and receiving in the departments.Recommendations1.Eliminate printing the receiving worksheet in the warehouse to check in an order. Receiving personnel should not have access to quantities ordered. Limited purchase
42、order inquiry access should be given, in order to check the validity of a purchase order that is received.2.Consider establishing a policy of returning goods to vendors if a valid purchase order cannot be located in a timely fashion.3.Reports reconciling inventory transfers and receipts should be pr
43、oduced and reviewed by management regularly.4.Generate receiving reports only upon actual receipt of goods and services with adequate proof of delivery. Receiving should only accept receiving reports (P-3) from departments with adequate proof of delivery.5.All receiving reports should be maintained
44、in Receiving, not Purchasing. They should be safeguarded from unauthorized theft, destruction or use.6.Allow for limited space in the receiving area to enforce the efficient distribution of goods away from receiving.7.All persons that are both ordering and receiving in departments should be identifi
45、ed to management. Justification should be given by the department as to the business reason for this. Implementation CategoryIIIIIIIIIIIIIE.Access to MaterialsObservationsAccess to CSR inventory is not completely secure. There are doors that are unlocked and could be accessed.The motion detector sec
46、urity system in the warehouse may not provide full coverage. Someone familiar with the system could circumvent it.Someone does not monitor the hospital dock at all times, because of staffing levels.The dock doors at the warehouse remain open during business hours. Access is not limited. Recommendati
47、ons1.Limit access to storage areas. 2.Clearly define employees that should have access to supply areas.3.Clearly define which doors should be locked and at what times. Set up entry/exit procedures for employees (keys or key cards to employees for all locked doors). Inform all departments of new procedures.4.
