AUDIT REPORT Vendor Management Office Contract Administration Audit Opinion: Satisfactory June 10, 2015 Report Number: 2015-AUD-05 Vendor Management Office Contract Administration Table of Contents: Page Executive Summary Background Audit Objectives and Scope Individual Section Ratings Audit Opinion 1 1 1 2 Appendix Definitions Issue Classifications Distribution Audit Performed By Report Number: 2015-AUD-05 Vendor Management Office Contract Administration 3 4 6 6 Executive Summary Background The Contract and Vendor Administration work unit was transferred from the Purchasing department on February 2, 2015 to the Vendor Management Office (VMO). This organizational change occurred to align vendor and contract management with the Citizens corporate strategy to improve scalability, cost structure alignment, maximize efficiencies of core systems and balance staffing resources. To achieve Citizens vendor management strategy, the VMO was created to provide centralized governance and oversight of the contract and vendor life cycle. The VMO is responsible for developing and maintaining a standardized vendor management approach and process across all business units, ensuring due diligence is conducted, and developing reporting mechanisms to facilitate executive oversight. As of February 28, 2015 Citizens has 599 contracts and 381 purchase orders with an approximate value of $976 million during the life of the contracts. As a result of the organizational alignment, the VMO is responsible for coordinating and enabling the execution of all contracts and maintaining/administering any documentation related to the Contract Administration function. Audit Objectives and Scope With this audit the OIA assessed the effectiveness of the Contract Administration function within the VMO and verified that the roles and responsibilities align with Statute 287.057 and 287.058. The audit scope included: Verification that the Contract Administration function is compliant with the State of Florida Statute 287.057 and 287.058. Verification that all segments of the revised Contract Administration function are assigned; business areas are aware and accountable for assigned responsibilities. Review and evaluation of the effectiveness of the Contract Administration process currently implemented under the new vendor management strategy. Review of all segments of the Contract Administration function which have not been implemented under the new vendor management strategy in relation to the project objectives and timeline. Assessment of the Contract Administration function and its alignment with Citizens corporate vendor management strategy. Individual Section Ratings Section Contract Administration compliance with Florida Statutes Contact Administration process ownership and accountability VMO process implementation as of May 15, 2015 VMO project implementation plan and strategy Contract Administration alignment with VMO Strategy Rating Satisfactory Needs Improvement Satisfactory Satisfactory Satisfactory Report Number: 2015-AUD-05 Vendor Management Office Contract Administration P age |1 Executive Summary Audit Opinion The overall effectiveness of the processes and controls evaluated during the audit is rated as Satisfactory. The VMO is in the process of implementing the Vendor Management Strategy and OIA has reviewed the objective and components of the Vendor Management Strategy and we are of the opinion that identified governance and controls are consistent with industry contract administration best practices. Recent VMO achievements include refreshed contract terms and conditions, the implementation of a vendor classification model, a procedure to address vendors who are not complying with contracts, the development of a vendor risk tool and the establishment of Contract and Vendor Management Guidelines. In addition, our work has identified specific areas for control enhancements and potential improvement opportunities that should be considered while the VMO continues to implement the Vendor Management Strategy. There is no process to actively monitor Contract Managers and to ensure ongoing post award contract management functions are adequately performed. The implementation of the Vendor Management Strategy by the VMO has focused on managing vendors to gain efficiencies, improve vendor compliance and enhance vendor communications. Business areas are responsible to ensure that vendors adhere to contractual obligations which will require ongoing monitoring, assessing and communicating. These responsibilities are not a business area’s primary function, as such process oversight and coordination is needed to realize benefits of the VMO Vendor Management Strategy. The VMO agreed to create a process to ensure business areas perform post award contract administration responsibilities in an adequate or reliable manner. The need to ensure roles and responsibilities between the VMO, Purchasing and Contract Managers are formalized. Roles and responsibilities must be clearly defined and coordinated across the VMO, Purchasing and Contract Managers. Through discussion and review of documentation, we noted process responsibilities and ownership gaps between the VMO, Purchasing and Contract Managers. Misalignment of process responsibilities or ownership may impede or delay expected benefits from the Vendor Management Program. The VMO will ensure that roles and responsibilities are formally communicated and acknowledged by all departments to ensure gap and overlaps are corrected. The need to update and enhance the Purchasing Desk Reference Manual to reflect VMO and Purchasing structure and applicable statutes. The Purchasing Desk Reference Manual is the single point of reference utilized by all business areas to guide end user procurement and contract administration process. The Purchasing Desk Reference Manual should provide specific guidance to direct contract management, contract administration, and vendor administration process and procedure questions. In collaboration with the Purchasing department, the VMO will revise the Purchasing Desk Reference Manual and re-issue the document as the Purchasing and Vendor Management Playbook (the “Playbook”). We would like to thank management and staff for their cooperation and professional courtesy throughout the course of this audit. Report Number: 2015-AUD-05 Vendor Management Office Contract Administration P age |2 Appendix 1 Definitions Audit Ratings Satisfactory: Critical internal control systems are functioning in an acceptable manner. There may be no or very few minor issues, but their number and severity relative to the size and scope of the operation, entity, or process audited indicate minimal concern. Corrective action to address the issues identified, although not serious, remains an area of focus. Needs Improvement: Internal control systems are not functioning in an acceptable manner and the control environment will require some enhancement before it can be considered as fully effective. The number and severity of issues relative to the size and scope of the operation, entity, or process being audited indicate some significant areas of weakness. Overall exposure (existing or potential) requires corrective action plan with priority. Unsatisfactory: One or more critical control deficiencies exist which would have a significant adverse effect on loss potential, customer satisfaction or management information. Or the number and severity of issues relative to the size and scope of the operation, entity, or process being audited indicate pervasive, systemic, or individually serious weaknesses. As a result the control environment is not considered to be appropriate, or the management of risks reviewed falls outside acceptable parameters, or both. Overall exposure (existing or potential) is unacceptable and requires immediate corrective action plan with highest priority. Report Number: 2015-AUD-05 Vendor Management Office Contract Administration P age |3 Appendix 2 Issue Classifications Control Category Financial Controls (Reliability of financial reporting) Operational Controls (Effectiveness and efficiency of operations) High Actual or potential financial statement misstatements >USD 5 million Control issue that could have a pervasive impact on control effectiveness in business or financial processes at the business unit level A control issue relating to any fraud committed by any member of senior management or any manager who plays a significant role in the financial reporting process Actual or potential losses >USD 2.5 million Achievement of principal business objectives in jeopardy Customer service failure (e.g., excessive processing backlogs, unit pricing errors, call center non responsiveness for more than a day) impacting 10,000 policyholders or more or negatively impacting a number of key corporate accounts Actual or potential prolonged IT service failure impacts one or more applications and/or one or more business units Actual or potential negative publicity related to an operational control issue An operational control issue relating to any fraud committed by any member of senior management or any manager who plays a significant role in operations Medium Actual or potential financial statement misstatements between USD 2.5 million to 5 million Control issue that could have an important impact on control effectiveness in business or financial processes at the business unit level Low Actual or potential financial statement misstatements below USD 2.5 million Actual or potential losses between USD 0.5 to 2.5 million Achievement of principal business objectives may be affected Customer service failure (e.g., processing backlogs, unit pricing errors, call center non responsiveness) impacting 1,000 policyholders to 10,000 or negatively impacting a key corporate account Actual or potential IT service failure impacts more than one application for a short period of time Actual or potential losses below USD 0.5 million Achievement of principal business objectives not in doubt Customer service failure (e.g., processing backlogs, unit pricing errors, call center non responsiveness) impacting less than 1,000 policyholders Control issue that does not impact on control effectiveness in business or financial processes at the business unit level Actual or potential IT service failure impacts one application for a short period of time Report Number: 2015-AUD-05 Vendor Management Office Contract Administration P age |4 Appendix 2 Control Category High Any operational issue leading to death of an employee or customer Medium Any operational issue leading to injury of an employee or customer Low Compliance Controls (Compliance with applicable laws and regulations) Actual or potential for public censure, fines or enforcement action (including requirement to take corrective actions) by any regulatory body which could have a significant financial and/or reputational impact on the Group Any risk of loss of license or regulatory approval to do business Areas of non-compliance identified which could ultimately lead to the above outcomes A control issue relating to any fraud committed by any member of senior management which could have an important compliance or regulatory impact Such an issue would be expected to receive immediate attention from senior management, but must not exceed 60 days to remedy. Actual or potential for public censure, fines or enforcement action (including requirement to take corrective action) by any regulatory body Actual or potential for non-public action (including routine fines) by any regulatory body Areas of noncompliance identified which could ultimately lead to the above outcomes Areas of noncompliance identified which could ultimately lead the above outcome Remediation timeline Such an issue would be expected to receive corrective action from senior management within 1 month, but must be completed within 90 days of final Audit Report date. Such an issue does not warrant immediate attention but there should be an agreed program for resolution. This would be expected to complete within 3 months, but in every case must not exceed 120 days. Report Number: 2015-AUD-05 Vendor Management Office Contract Administration P age |5 Appendix 3 Distribution Addressees Stephen Guth, VP Vendor Management Spencer Kraemer, Director Purchasing Copies Juan Cocuy, Citizens Audit Committee Chairman Bette Brown, Citizens Audit Committee Member Jim Henderson, Citizens Audit Committee Member Barry Gilway, President/CEO/Executive Director Kelly Booten, Chief Systems & Operations Dan Sumner, Chief Legal Officer & General Counsel Bruce Meeks Inspector General Following Audit Committee Distribution The Honorable Rick Scott, Governor The Honorable Jeff Atwater, Chief Financial Officer The Honorable Pam Bondi, Attorney General The Honorable Adam Putnam, Commissioner of Agriculture The Honorable Don Gaetz, President of the Senate The Honorable Will Weatherford, Speaker of the House of Representatives Audit Performed By Auditor in Charge Anthony Huebner Audit Director John Fox Under the Direction of Joe Martins Chief of Internal Audit Report Number: 2015-AUD-05 Vendor Management Office Contract Administration P age |6