Posts Tagged ‘armchair auditors’
The Health and Social Care Bill provides only a few clues on the detail of audit arrangements for the new GP consortia. Ensuring the scope of the audit of these new organisations includes value for money is welcome news for armchair auditors. The mechanism for appointing auditors after the abolition of the Audit Commission is yet to be announced. It should include an independent appointment process to prevent threats to auditor independence. The reforms will demand more of auditors during their implementation and this is likely to increase costs at least until the new organisations find their feet. That’s likely to be unwelcome news to everyone.
The publication of the gargantuan Health and Social Care Bill (360 odd pages, 12 Parts, 281 clauses and 20 schedules) will spark all sorts of debates about NHS privatisation, costs of reform and alleged broken election promises. What it almost certainly will not do is to generate heated debate about audit arrangements.
Luckily I see that as part of the remit of the Reluctant Armchair Auditor.
It is only right to pen a gargantuan post in response to such a large document.
I am going to focus though on the audit arrangements for the GP commissioning consortia. Around £80 billion of public money will be spent by these organisations so audit is an important issue for every English taxpayer – the devolved governments are of course considering their own reforms.
So what does the Bill say about how these new bodies will be audited? Well you need to rummage through to page 230 (that’s part 2 of schedule 2) to find the following –
Accounts and audits
12 (1) A commissioning consortium must keep proper accounts and proper records in relation to the accounts.
(2) A commissioning consortium must prepare annual accounts in respect of each financial year.
(3) The Board may, with the approval of the Secretary of State, direct a commissioning consortium to prepare accounts in respect of such period or periods as may be specified in the direction.
(4) The Board may, with the approval of the Secretary of State, give directions to a commissioning consortium as to—
(a) the methods and principles according to which its annual or other accounts must be prepared, and
(b) the form and content of such accounts.
(5) The annual accounts and, if the Board so directs, accounts prepared by virtue of sub-paragraph (3) must be audited in accordance with the Audit Commission Act 1998 by an auditor or auditors appointed in accordance with arrangements made by the Board for the purposes of this paragraph.
(6) The Comptroller and Auditor General may examine—
(a) the annual accounts and any records relating to them, and
(b) any report on them by the auditor or auditors.
(7) A commissioning consortium must send its audited annual accounts, and any audited accounts prepared by it by virtue of sub-paragraph (3), to the Board by no later than the date specified in a direction by the Board.
(8) The Board may direct a commissioning consortium to send its unaudited annual accounts, and any unaudited accounts prepared by it by virtue of sub-paragraph (3), to the Board by no later than the date specified in a direction by the Board.
(9) Nothing in this paragraph requires a commissioning consortium to keep accounts or records, or to prepare annual accounts, in respect of anything done by it as trustee.
(10) For the purposes of this paragraph “financial year” includes the period which begins on the day the consortium is established and ends on the following 31 March.
There’s much to interest armchair auditors here particularly the appointment of auditors.
Currently the Audit Commission appoints auditors to PCTs. The words,
‘ … auditor or auditors appointed in accordance with arrangements made by the Board …’
do not clarify whether the Board will arrange to have this done centrally or if consortia will get the freedom to appoint auditors themselves. As I have written before having audit appointments managed at arm’s length from the organisation being audited has been an important principle of the public audit framework here for some time. It’s also a direction being explored by the EU for business in the wake of the crisis in the financial system.
The National Audit Office has published what it calls a Landscape Review of the NHS which clarifies slightly what is planned. This is what its says about audit arrangements for local NHS organisations.
2.37 On 13 August 2010, the Secretary of State for Communities and Local Government announced plans to disband the Audit Commission. This is significant for NHS bodies as many have auditors appointed by the Audit Commission or, in the case of Foundation Trusts who appoint their own auditors, choose to use the Audit Commission’s audit practice. The intention is to have new arrangements in place for auditing England’s local public bodies by 2012-13.
2.38 The Audit Commission’s responsibilities for overseeing and delivering local audit and inspections will stop, as will their research activities. The audit work will move to the private sector. The Audit Commission is responsible for the 2011-12 audit of local public bodies and is expected to close in December 2012. This timetable has yet to be confirmed and depends on the necessary legislation being passed. To help the National Audit Office provide assurance to Parliament on NHS bodies’ use of public money, the Department of Health and the Department for Communities and Local Government are working together with the National Audit Office to develop effective arrangements for independent external audit. These arrangements will need to address both financial and value for money audit within the planned new health structures. (My emphasis)
So the invocation of the Audit Commission Act 1998 in the Bill really does signal that the scope of the audit of GP consortia is to be wider than simply sticking an opinion on the financial statements.
There has been a long-standing convention in policy making around public audit that the taxpayers’ interest requires a wider focus for audit of the spending of taxpayers’ money. Not just that the books are right but that public money has been well spent. That’s a more burdensome form of audit but it’s one familiar to the UK’s public sector. Armchair auditors should welcome the retention of this principle amongst the change.
A wider scope of audit requires auditors to consider the effectiveness of arrangements in key areas such as procurement and commissioning. Private sector organisations working on behalf of consortia may well be subject to scrutiny by auditors at a level they may not have experienced before.
Independent appointment of auditors given all the other change in the system would provide an additional safeguard to taxpayer interests. Those of us who remember GP Fundholding though will recall the tensions created when independent business men and women (GPs) found themselves the object of attention from auditors. This is bound to happen again. Some clinicians may find the burden of public audit unwelcome. Their smart new private sector partners may find it even harder to bear.
The final issue here is around numbers. Any audit requires a minimum amount of time to complete the tasks needed in accordance with professional standards. It’s true there are variations in audit fees and there always will be but there is an irreducible minimum amount of work that needs to be done. Clearly the number of audits will depend on the number of consortia. There is still no news on that front.
The amount of audit work in an engagement is also a function of the auditor’s understanding of the entity being audited and the risks he or she identifies. New organisations working in a new operating environment will almost certainly be viewed as inherently high risk and will need more audit work. That should reduce when the consortia have a track record of good governance and internal control.
So just making the changes raises audit costs that are then compounded by any increase in the number of organisations being audited.
Providing assurance to taxpayers will require significant audit work and that is not work that we armchair pundits can undertake. We simply are not equipped to or resourced to make sound judgements about the value for money of healthcare services. We need suitably qualified and independently minded people to do that on our behalf.
In case you doubt that have a look at this Public Interest Report from an independently appointed auditor about the financial failings of an NHS Trust in the current regime. Would an auditor solely reliant on his or her appointment by the Trust Board and management have written such a report?
Jury’s out on that one I think.
It’s probably an age thing but increasingly these days I seem to living in a state of perpetual deja vu. Suddenly it’s the early 90s or 80s again as fear and pestilence stalk public sector land. So much so that I am considering looking out my Don Johnson pastel jackets, raybans and ditching my pringle socks. Loafers don’t need socks.
In many ways it’s a great shame that our national predilection for dressing up in ‘historic’ costumes for ‘living history’ weekends does not extend to reenacting public policy screw-ups. Nope. Each generation of political leaders can re-heat whatever garbage they think the electorate has forgotten about before serving it up fresh.
No one out there is going to get all grumpy because they’ve suddenly remembered that the Big Society sounds eerily similar to the good old days of … well the good old days. Yes, I do mean Back to Basics and the spinster on her blessed bike still cycling to evensong. Although in the Big Society presumably she would have had to deliver some home care support, done a shift at the nearest community asset and filled in some pot holes before getting to church.
Of course ‘no more boom and bust’ has had more outings than an Australian XI. This is even-handed grumpiness on my part. I’ve worked with and for politicians of all views (and none so far as I could tell). What unites almost all of them though is an inability to see the perfectly forseeable consequences of a given policy decision. Or, if they do own that skill, to be pathologically unable to utter in public what they must know to be true.
My first day back post-Christmas with my abacus has found me trying to help clients deal with the impact of CSR2010. My attention was drawn to a highly – unintentionally so – amusing set of comments by a minister from CLG. I’ll not name names because I’ve come to the conclusion that it only encourages them and the SPADs with whom they spend too much time.
Apparently it is only ‘lazy councils’ that will go looking for frontline blood to let to implement the cuts in council spending that CLG was in such a hurry to agree with the Treasury. Here’s the quote from the Sunday Times:
If local authorities cut out excessive chief executive pay, share back offices, join forces to procure, and root out wild overspends, they can safeguard key frontline services. Only lazy councils will attempt to use residents to boost their bank balances.
Let’s run an armchair auditor’s rule over those frontline service savers in some more detail.
‘ … cut out excessive chief executive pay … ‘
A great ministerial favourite this one. Let’s examine the premise. Reducing all Chief Executive pay to let’s say £120,000 – that’s a good £22,ooo less than the garbage comparison of the PM’s pay – would stop 9% reductions in council spending hitting the frontline? Really? A client of mine is looking for around £3 million of savings in 2011/12. Deleting every post in the corporate management team would barely yield 10% of the savings figure needed.
‘ … share back offices … ‘
Procurement takes time. Good procurement takes even more time. Merging back office functions sounds easy doesn’t it? I’m not sure any businessman or woman who has tried it would agree. Getting the Morrisons/Safeways issues sorted took years. Few, if any, of the organisations I am familiar with have not already got various partnering arrangements underway. In any event there’s a perfectly respectable stream of thought that argues that maintaining integrated back and front line functions serves customers better and at less cost too.
‘ … join forces to procure … ‘
There’s always more that can be done on procurement as lots of reviews have shown over the years. So I would cede some ground on this one. But I would offer just one thought. Great procurement depends on clarity about knowing what you want as a customer and having outstanding service providers working with you to achieve just that. At the minute everyone is so focused on putting out the fire in their part of the public service woodland that it’s getting near impossible to see the forest as a whole.
Frontloading cuts to encourage councils to be super innovative sounds pretty clever in a sixth form debating society in the real world in defies believe. In the few weeks now available to sort the 2011/12 budgets scope for innovative procurement approaches will be pretty narrow.
‘ … root out wild overspends … ‘
No evidence was offered here for the sort of overspend the minister had in mind. The thinking behind the quote is the most interesting thing though because it does the thing that upsets Mr Redwood so much. It confuses a structural problem – CSR2010 – with a current account issue. Sorting out an overspend means you return to the spending level of the agreed budget. Of course what CSR2010 does is to lower the budget ceiling. So just sorting out the overspend is not enough.
There comes a time in the life of almost all political administrations when the contest between hope and reality gets too obvious to avoid. Administrations at the end of their lives tend to the fantastical to avoid facing inconvenient truths. The deeper the problems the wilder the statements. It’s unusual for a relatively young administration to be reaching for the hyperbolic but I suppose it shows the depth of the problems it thinks it’s got.
The trouble is that the ‘trouble’ has barely begun yet.
I boggled on Sunday while watching the PM on the Andrew Marr programme. He said that sorting out the public finances was last year’s problem. This year’s was all about growth. That’s an unusually stark illustration of the gap in experience of almost everyone in our national political life. Announcements, interviews, news releases and leaks do not deliver anything except sentiment.
The problem is that the public finances have not yet been sorted. Doing that depends on the work of ‘lazy’ organisations at the sharp end. It’s going to be bloody.
Many public sector professionals will, like me, have sighed and shrugged a resigned shoulder this morning in reading today’s report of the Public Administration Select Committee Shrinking the Quango State.
Those unfamiliar with the formulation of public policy and its implementation probably still find the flaws PASC found in the government’s review of Quangos shocking. Sadly. I don’t. Here’s a sample of what the committee found.
This review was poorly managed.
There was no meaningful consultation.
The tests the review used were not clearly defined.
The Cabinet Office failed to establish a proper procedure for departments to follow.
The Bill giving the Government the power to bring about these changes was … badly drafted.
The Government has failed to recognise the realities of the modern world.
Much will be written about the report today. What is striking to me is the no-holds-barred language used by PASC. The Committee was deeply unimpressed by what it found. The findings themselves leave me, as an armchair auditor, deeply pessimistic about the government’s stewardship of public funds.
Let’s start at the beginning. Any change process in any business usually has some rationale for being started: the business case. PASC found the business case for the changes proposed by government had shifted around. It was about saving money. Then it was about improving accountability. No, wait a minute it’s about both. With such a muddled start no wonder MPs found such a mess when they looked at the decisions the review had given rise to.
The early confusion led to a set of criteria used in the review that were unclear and a dearth of guidance to individual government departments. So Quangos with broadly similar terms of reference, albeit in different fields, have ended up being treated entirely differently. It’s a dogs’ breakfast and contrasts hugely with the diligence applied by local public sector organisations to their own decision-making. What is also striking is the lack of meaningful consultation and engagement between the reviewers and the reviewed (and their stakeholders).
What is deeply troubling is that all the flaws PASC identify could have been addressed if anyone had paid any attention to the findings of one of the many reviews of governmental lash-ups over the years produced either by the NAO or, indeed, the Audit Commission. Institutional memory seems to be in short supply now the government has declared Year Zero.
For us armchair auditors the PASC report raises ominous question marks over the quality of decision-making in other key areas such as the NHS reforms where similar rumblings about decision-making are already growing. The government has embarked on a radical reform agenda which it has often clothed in the threads of spending reduction. As PASC says,
… the Government faces the much larger challenge of successfully implementing these reforms; any organisation would struggle with changes on this scale.
It’s not at all clear that the machinery of government is up to the task particularly as ministers chop capacity out of their ‘back offices’ i.e exactly the people you need to deliver change if you want the frontline to really focus on the frontline. It’s a recipe for confusion that management consultants everywhere will be looking on and smacking their lips with anticipation.
We risk ending up where other reform programmes have found themselves: vast amounts of money spent with no noticeable improvement in public services or their accountability. Bad enough in economic good times surely indefensible given the problems we face right now.
I spent Christmas on retreat with a large parcel of reading to catch up with. Anyone who thought coalition government would strangle the volume of paper flowing from the initiative engine room down by the Thames was clearly barking up the wrong tree. Each department seems to have decided it’s Year Zero.
In my experience there’s an absolute correlation between the quality and quantum of the capacity available to deliver change and its success. Public sector careers are littered with experiences of sweeping up after disastrous change programmes whose benefits were sketchy to start with and never got close to being realised.
For the first time in the experience of almost anyone but the hardiest veterans of public service we face rapidly reducing public expenditure coupled with enormous and complex reform of public services. Less money and fewer people to do more work. All the ingredients of a perfect public policy storm.
A certain amount of change is inevitable with any new government but my clients have now suffered a severe sense of humour failure. But, although the lights are on in Whitehall, there’s no evidence that there’s anyone home listening.
Instead what local public service organisations get for raising queries about the direction and pace of change is the chance to get publicly rubbished by an administration which seems fixated on rubbish collections.
I listened to a minister from CLG yesterday on my way home, interviewed alongside the Leader of Exeter. The minister had written to all councils to admonish them for failing to collect household rubbish over the Christmas holidays. The Leader at Exeter – a council in the ministerial sights – made two not unreasonable points: it had been a tad snowy; and, even if his troops had worked throughout Christmas the Council would have had nowhere to stick the waste collected because it’s not the waste disposal authority (WDA). The WDA’s dumps were, of course, closed on the public holidays over the break.
Few things seem to galvanise the CLG ministerial team more than the question of rubbish collection. Yesterday the minister repeated the old canard on the radio that the move by councils to alternative weekly collections of waste and recyclables was forced on them by a government/Audit Commission plot. Local politicians will tell you this isn’t true. The Audit Commission has also made it plain that this simply is not true. Perhaps if it gets repeated often enough it might become true in some magical and unexpected way. (Sorry, I happened to see Peter Pan over the holidays and yes, I believe in fairies.) You can read the Audit Commission correspondence here.
Changing these arrangements made economic sense and was good for the environment too. In many cases local elections have been fought and won with the issue of changes to local refuse collection arrangements as a hot topic. In any event surely this is a prime example of a local issue where local politicians should be held accountable through the ballot box rather than to ministers’ letters? Perhaps I have misunderstood what this localism malarkey is all about.
I had just about recovered some sort of mental equilibrium when up popped a transport minister to talk about potholes. He said it was up to local councils to sort it out and the government shouldn’t get involved in prescribing what happens locally. But surely, I thought to myself, that’s just what CLG have just been doing over its fixation over bin emptying. The minister boasted that councils had got £3 billions in the spending review to spend on roads and said poorer performing councils should learn from the good practice of the good ones. Quite how that is going to happen was left unexplained.
However, a whacking thump from the suspension as I hit yet another pothole brought me back to the issue at hand. On the final miles home I mused about the £3 billion figure. Here’s the fruit of that musing.
There was a Ministerial statement in the Commons on 13 December. This did indeed announce the £3 billion mentioned. But it’s £3 billion over 4 years. I had a look then at the length of the road network maintained by councils in England. You can have a look at the details here on the Department for Transport website.
Highways experts may correct me but it looks like councils have to look after around 182,000 miles of road. So councils have just over £4,100 a mile to work with each year. That does not seem like an awful lot of money to me. Just think how much it costs to get a drive skimmed with a new layer of blacktop. Of course it looks even less generous when you realise that this money will not be evenly distributed across the road network. Some roads will clearly see not a penny of this £3 billion.
In the interview the minister made the point again that some councils have ‘lots’ of money in reserves. If they do then, as I have said before, this is for genuine un-budgeted for emergencies. If money is needed for planned highways schemes then it is almost certainly already earmarked.
My overall point is that while the government may be intellectually committed to localism it seems pathologically unable to deal with its consequences. This makes for poor relations between Whitehall and local decision-makers who I know are becoming fed up with the constant second guessing that flows from this aggressive authoritarian localism. The ever excellent Local Government Chronicle is reporting today on the local government response to all this noise from the Whitehall machine.
As I pick up the traces from December and clamber back into harness I sense this growing disconnect will increasingly dominate the debate over public service ‘reform’. I haven’t even mentioned what my NHS contacts are saying about what’s going on in that service. That is a whole new post.
There’s certain to be a lot of work for us armchair auditors in the year ahead.
By the way, Happy New Year.
By all accounts the Secretary of State for Transport is a good minister – at least that’s what I hear from people I respect who should know. He is learning a hard lesson at the moment about how the blame game works when public services don’t work as well as the great British public expect they should.
Here he is yesterday on ITN talking about keeping the roads running.
As a (reluctant) armchair auditor I’m finding what’s happening with ‘The Snow’ interesting. The government is very big on localism. It – apparently – believes in shunting decision-making to the nearest possible point to the action. It believes too that local communities should decide on their own priorities and be free from Whitehall interference in how they are chosen and pursued. Coalition politicians are gambling on there being a host of willing participants in priority-setting, decision-making and service delivery. Years of public service experience leads me to doubt that this belief is well founded but the government is entitled to hold it.
What I think peoples’ growing fury about the impact of the current freakishly cold weather on their lives tell us is this: ministers should beware.
Scotland’s Transport Minister lost his job because the roads couldn’t be kept clear. It makes no difference there were plenty of severe weather warnings that people could have acted on. Like every other day of their working lives they got on a bus or in their car and expected to be able to drive home. When they couldn’t, they got cross and politicians took the heat. There’s always a price to be paid for wanting to lead.
Let’s fast forward a bit to autumn 2011. The cuts I’m now helping to design are really beginning to bite.
The children’s centre your children used to attend has scaled back it’s activities. Your kids no longer get the range of activities they did. The leisure centre has scaled back its hours too so you’ve had to re-arrange your life to keep up your classes. They also cost more so you’ve knocked some on the head. At your kids’ school you notice that the planned building work and upgrading of the IT facilities hasn’t yet happened. A bit of a ruck is developing over whether the school should pursue a change in status. Would there be some more money on the table if it did?
You notice how bad the roads still are after the winter of 2010/11 the surfaces of many make your car rumble and vibrate. There’s a couple of impressive potholes that you know now to slow and swerve for. Experience gained at the cost of a new tyre and alloy wheel.
You’re worried about your parents as they now have to pay quite a bit more for the care package they have. They are seeing a succession of care workers now after the service was outsourced. They’re bit worried about the rent now as well as they think it’s going to be going up. Their utility bills, and yours, have gone up too.
Quite a few of your friends have been laid off either from the council or from jobs that depended on the council. You’re worried about your own business. The high street has been getting quieter and there’s been a bit more anti-social behaviour in the precinct. The local policing team has been reorganised, there was a story about it in the local paper.
You’ve also heard something about some reorganisation in the NHS. But no-one you speak to is very clear about what it’s all about. The campaign to save the local community hospital has started up again. A friend of your wife who works as a finance assistant in the medical centre said that they are working on a ‘big deal’ with a private company and that’s taking up more of the GPs’ time. They’re all really excited by it.
Your oldest child who was thinking about going on to university after sixth form has decided instead to get a job and will stay on at home.
When you get together with your friends you talk about all of this and more, in the way friends do.
I am labouring to reach my point so here it is. Clearly an act of God like snow can drive the public to fury with politicians. So how are they going to react when it’s much clearer the falling quality and availability of public services are directly the result of changes directed from the top. Snowy roads – Philip Hammond; duff council services – Eric Pickles; distracted Health Services – Andrew Lansley; ropey schools – Michael Gove; university fees – Vince Cable; and, so it goes on.
If the fury over the current transport problems is a guide all ministers can expect some troubled times ahead. Localism will not protect any national politician from being the object of fury when people in local communities find their lives harder and less full of flavour.
As I said there is always a price to be paid for wanting to lead. Localism doesn’t do anything to change the essential characteristics of that equation.
For armchair auditors the challenge will be to sort out where responsibility for cuts actually rests. Where’s that abacus?
A slew of cancelled client meetings because of the weather leaves me free to catch up with the news. My eye has been particularly taken by what he has to say about using the Prime Minister’s pay as a benchmark.
You will probably be familiar with the figure of £142,500. It’s been used as a useful cricket bat to thwack evil public servants. Here’s a typical example from Daily Mail. Ministers have enjoyed themselves with this too.
Those of us with a passing understanding of how to work out the total value of a remuneration package have treated the benchmark with the derision, sorry professional scepticism, it deserves. About the only thing it had going for it was simplicity. But in my experience simplicity is often simply an excuse for crass reductionism.
Senior public sector managers with whom I come into contact have been grinding their teeth over the PM salary benchmark for ages. For perfectly sensible reasons none of them broke cover. Trying to defend yourself risks getting the treatment that John Ransford got on BBC’s Newsnight. A week later and Mr Ransford got a haircut of over £140,000 on his base salary.
For people like me who like numbers to be materially accurate Hutton has done us all a profound service. Have a look at Box 2E on page 56 of the Interim Report for the detail of the debunking. Suffice it to say he identifies the two flaws with the benchmark.
First, it nowhere near reflects the total value of the PM’s remuneration package. If you add in the salary the PM has chosen – and been able to forego – with the value of his pension, accommodation and so on by any calculation the package is worth more than £500,000. That’s probably right but it’s a rather different benchmark isn’t it?
The second flaw is, of course, that the PM’s remuneration package is not determined in a labour market but rather in a political stock exchange. PMs take a punt on low income yields during their time in office correctly calculating that simply by holding the office they hugely increase their worth. Capital growth of a sort. If you doubt that look at the before and after shots of Mr Blair’s London homes.
Thank you then Mr Hutton but I do not think we should hold our breath for the thundering headline that says, ‘Almost all public sector workers paid less than the PM.’
Reluctantly back to the armchair I must go.
In October the EU launched a little heralded consultation. Inside the audit profession it grabbed a lot of attention. If anything like the proposals it contains is implemented I would be staggered. It is a sign of the times though that some of them are even being mentioned by our friends in Brussels and Strasbourg.
Headlines from the paper dealing with the governance of audit firms include:
- taking audit appointments out of the hands of the directors and shareholders giving it instead to an independent body;
- requiring audit appointments to be time limited;
- restricting the amount of non-audit work audit firms can undertake;
- capping the amount of fees that an audit firm can earn from a single client;
- asking national public sector audit organisations to audit the accounts of audit firms;
- changing the ownership structures of audit firms; and,
- beefing up the role of auditors of group accounts.
The EU is concerned that audit arrangements are not robust enough to help ensure we avoid future financial meltdowns like the one brought to us by the banking crisis.
These are ‘courageous’ proposals. That’s shorthand for ‘you must be joking’. I imagine that the accountancy big guns have lengthy submissions in the system that boil down to, ‘don’t do it’.
All of this is interesting to us armchair auditors because of the changes to the English audit arrangements for local public bodies. The abolition of the Audit Commission – which does the independent appointment of auditors envisaged by the EU – is meant to herald an era of councils appointing their own auditors.
So as EU policy heads in one direction England’s heads in another. Not something that worries our government too much I suspect. However, I can’t help but think that the sorts of issues that worry the EU are no different in character to ones that will come over the horizon if the changes in English audit arrangements are not properly thought through. Strangely enough some of the accountancy profession may agree with me on that.
Fingers crossed then.