Item 5 - External Auditor Annual Audit Report
North Lanarkshire Council · 30 November 2022
Back to Health and Social Care Integration Joint Board — 30 November 2022 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
REPORT Item No: 5 1. PURPOSE OF REPORT 1.1 This paper is coming to the Integration Joint Board (IJB): For approval For endorsement For noting 1.2 This report:- (1) Outlines the outcome of the audit by the North Lanarkshire Integration Joint Board’s External Auditor, Audit Scotland: (2) Advises that the External Auditor has submitted an Annual Audit Report setting out their key findings for the consideration of the members of the Integration Joint Board (IJB); and (3) Provides details of the proposed management response to the action points detailed in the External Auditor’s Annual Audit Report. 2. ROUTE TO THE PERFORMANCE, FINANCE AND AUDIT COMMITTEE 2.1 This paper has been: Prepared By; Chief Financial Officer Reviewed By; Chief Officer 3. RECOMMENDATIONS 3.1 The IJB is asked to agree the following recommendations: (1) Consider the External Auditor’s Annual Audit Report, attached at appendix 2, in advance of the approval of the IJB Annual Accounts 2021/2022; (2) Note that an unqualified audit certificate has been received in respect of the North Lanarkshire IJB Annual Accounts 2021/2022; and (3) Approve the management response to the action points which is highlighted at pages 20 to 21 of the External Auditor’s Annual Audit Report, attached at appendix 2. 4. VARIATIONS TO DIRECTIONS 5. BACKGROUND/SUMMARY OF KEY ISSUES 5.1 Following the publication of the Local Authority Accounts (Scotland) Regulations 2014, the members of the IJB must meet to consider whether to approve the unsigned audited North Lanarkshire IJB Annual Accounts 2021/2022 for signature. The members therefore require to have regard to any report made or advice provided by the External Auditor. SUBJECT: External Auditor’s Annual Audit Report 2021/2022 TO: Integration Joint Board Lead Officer for Report: Ross McGuffie, Chief Officer North HSCP Author(s) of Report Amanda Kilburn, Chief Finance Officer North HSCP DATE: 30th November 2022 Yes No N/A 1
Page 2
5.2 The IJB’s appointed External Auditor, Audit Scotland, is required to supply an audit certificate outlining the findings of the audit process undertaken in relation to the IJB Annual Accounts 2021/2022. A letter setting out their responsibilities is attached at appendix 1 together with a letter of representation from the Chief Finance Officer (appendix 2). The findings are detailed in the External Auditor’s Annual Audit Report for the financial year 2021/2022 which is attached at appendix 2. 6. CONCLUSIONS 6.1 The External Auditor’s Annual Audit Report on the IJB Annual Accounts extends across several subjects, as follows: IJB Annual Accounts 2021/2022; Financial management and sustainability; and Governance, transparency, and best value. 6.2 The External Auditor has concluded that the financial statements of the North Lanarkshire IJB for 2021/2022 give a true and fair view of the net expenditure for the year and have therefore issued an unqualified independent report. 6.3 This report, attached at appendix 2 includes the key messages at page 3 and an action plan on pages 20 to 21 which have been agreed by both the Chief Officer and the Chief Finance Officer. 6.4 The External Auditor highlighted that there are no significant findings to report on the North Lanarkshire IJB Annual Accounts 2021/2022 and no misstatements were identified. 6.5 The IJB Chief Finance Officer would like to acknowledge the support of the NLC and NHSL finance teams throughout the year and particularly in respect of the preparation of the IJB Annual Accounts. 7. IMPLICATIONS 7.1 NATIONAL OUTCOMES This relates to all national outcomes. 7.2 ASSOCIATED MEASURE(S) The IJB, the Performance, Finance and Audit Committee and both partners are required to ensure effective governance arrangements are in place. 7.3 FINANCIAL This paper has been reviewed by Finance: Yes No N/A 7.4 RISK ASSESSMENT/RISK MANAGEMENT The main risk associated with the IJB Annual Accounts is a qualified audit report. The risk has been assessed as low due to the detailed preparation in relation to the year-end process and technical training undertaken by key finance staff. The finance staff across the partners supported the achievement of key deadlines. 7.5 PEOPLE None 2
Page 3
7.6 INEQUALITIES & FAIRER SCOTLAND DUTY Equality and Diversity Impact Assessment Completed & Fairer Scotland Impact Assessment Form Completed: Yes No N/A 7.7 CARBON MANAGEMENT IMPLICATIONS Yes No N/A 8. BACKGROUND PAPERS IJB 22nd June 2022 Unaudited IJB Annual Accounts 2021/2022 9. APPENDICES External Auditor’s Letter to the IJB 2021/2022 Appendix 1 External Auditor’s Annual Audit Report 2021/2022 Appendix 2 ........................................... Chief Finance Officer Members seeking further information about any aspect of this report, please contact Amanda Kilburn on telephone number 07816 126362. 3
Page 4
102 West Port Edinburgh EH3 9DN T: 0131 625 1500 E: info@audit-scotland.gov.uk www.audit-scotland.gov.uk North Lanarkshire Integration Joint Board Audit of 2021/22 annual report and accounts 30 November 2022 Independent auditor’s report 1. Our audit work on the 2021/22 annual accounts is now substantially complete. Subject to receipt of a revised set of accounts for final review, we anticipate being able to issue unqualified audit opinions in the independent auditor’s report on 30 November 2022 (the proposed report is attached at Appendix A). Annual audit report 2. Under International Standards on Auditing in the UK, we report specific matters arising from the audit of the financial statements to those charged with governance of a body in sufficient time to enable appropriate action. We present for the Integration Joint Board’s consideration our draft annual report on the 2021/22 audit. The section headed “Significant findings from the audit in accordance with ISA 260” sets out the issues identified in respect of the annual report and accounts. 3. The report also sets out conclusions from our consideration of the four audit dimensions that frame the wider scope of public audit as set out in the Code of Audit Practice. 4. This report will be issued in final form after the annual accounts have been certified. Unadjusted misstatements 5. We also report to those charged with governance all unadjusted misstatements which we have identified during our audit, other than those of a trivial nature and request that these misstatements be corrected. 6. We have no unadjusted misstatements to be corrected. Fraud, subsequent events and compliance with laws and regulations 7. In presenting this report to the Integration Joint Board we seek confirmation from those charged with governance of any instances of any actual, suspected or alleged fraud; any subsequent events that have occurred since the date of the financial statements; or material non-compliance with laws and regulations affecting the entity that should be brought to our attention. 4
Page 5
Representations from the Section 95 Officer 8. As part of the completion of our audit, we are seeking written representations from the Section 95 Officer on aspects of the annual accounts, including the judgements and estimates made. 9. A draft letter of representation is attached at Appendix B. This should be signed and returned to us by the Section 95 Officer with the signed annual accounts prior to the independent auditor’s report being certified. 5
Page 6
APPENDIX A: Proposed Independent Auditor’s Report Independent auditor’s report to the members of North Lanarkshire Integration Joint Board and the Accounts Commission Reporting on the audit of the financial statements Opinion on financial statements I certify that I have audited the financial statements in the annual accounts of North Lanarkshire Integration Joint Board for the year ended 31 March 2022 under Part VII of the Local Government (Scotland) Act 1973. The financial statements comprise the Comprehensive Income and Expenditure Statement, Movement in Reserves Statement, Balance Sheet and notes to the financial statements, including significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and UK adopted international accounting standards, as interpreted and adapted by the Code of Practice on Local Authority Accounting in the United Kingdom 2021/22 (the 2021/22 Code). In my opinion the accompanying financial statements: • give a true and fair view in accordance with applicable law and the 2021/22 Code of the state of affairs of the body as at 31 March 2022 and of its income and expenditure for the year then ended; • have been properly prepared in accordance with UK adopted international accounting standards, as interpreted and adapted by the 2021/22 Code; and • have been prepared in accordance with the requirements of the Local Government (Scotland) Act 1973, The Local Authority Accounts (Scotland) Regulations 2014, and the Local Government in Scotland Act 2003. Basis for opinion I conducted my audit in accordance with applicable law and International Standards on Auditing (UK) (ISAs (UK)), as required by the Code of Audit Practice approved by the Accounts Commission for Scotland. My responsibilities under those standards are further described in the auditor’s responsibilities for the audit of the financial statements section of my report. I was appointed by the Accounts Commission on 10 April 2017. The period of total uninterrupted appointment is 6 years. I am independent of the body in accordance with the ethical requirements that are relevant to my audit of the financial statements in the UK including the Financial Reporting Council’s Ethical Standard, and I have fulfilled my other ethical responsibilities in accordance with these requirements. Non-audit services prohibited by the Ethical Standard were not provided to the body. I believe that the audit evidence I have obtained is sufficient and appropriate to provide a basis for my opinion. Conclusions relating to going concern basis of accounting I have concluded that the use of the going concern basis of accounting in the preparation of the financial statements is appropriate. 6
Page 7
Based on the work I have performed, I have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the body’s ability to continue to adopt the going concern basis of accounting for a period of at least twelve months from when the financial statements are authorised for issue. These conclusions are not intended to, nor do they, provide assurance on the body’s current or future financial sustainability. However, I report on the body’s arrangements for financial sustainability in a separate Annual Audit Report available from the Audit Scotland website. Risks of material misstatement I report in my Annual Audit Report the most significant assessed risks of material misstatement that I identified and my judgements thereon. Responsibilities of the Chief Financial Officer and the Integrated Joint Board for the financial statements As explained more fully in the Statement of Responsibilities, the Chief Financial Officer is responsible for the preparation of financial statements that give a true and fair view in accordance with the financial reporting framework, and for such internal control as the Integrated Joint Board determines is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error. In preparing the financial statements, the Chief Financial Officer is responsible for assessing the body’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless there is an intention to discontinue the body’s operations. The Integrated Joint Board is responsible for overseeing the financial reporting process. Auditor’s responsibilities for the audit of the financial statements My objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes my opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the decisions of users taken on the basis of these financial statements. Irregularities, including fraud, are instances of non-compliance with laws and regulations. I design procedures in line with my responsibilities outlined above to detect material misstatements in respect of irregularities, including fraud. Procedures include: • obtaining an understanding of the applicable legal and regulatory framework and how the body is complying with that framework; • identifying which laws and regulations are significant in the context of the body; 7
Page 8
• assessing the susceptibility of the financial statements to material misstatement, including how fraud might occur; and • considering whether the audit team collectively has the appropriate competence and capabilities to identify or recognise non-compliance with laws and regulations. The extent to which my procedures are capable of detecting irregularities, including fraud, is affected by the inherent difficulty in detecting irregularities, the effectiveness of the body’s controls, and the nature, timing and extent of the audit procedures performed. Irregularities that result from fraud are inherently more difficult to detect than irregularities that result from error as fraud may involve collusion, intentional omissions, misrepresentations, or the override of internal control. The capability of the audit to detect fraud and other irregularities depends on factors such as the skilfulness of the perpetrator, the frequency and extent of manipulation, the degree of collusion involved, the relative size of individual amounts manipulated, and the seniority of those individuals involved. A further description of the auditor’s responsibilities for the audit of the financial statements is located on the Financial Reporting Council's website www.frc.org.uk/auditorsresponsibilities. This description forms part of my auditor’s report. Reporting on other requirements Opinion prescribed by the Accounts Commission on the audited part of the Remuneration Report I have audited the part of the Remuneration Report described as audited. In my opinion, the audited part of the Remuneration Report has been properly prepared in accordance with The Local Authority Accounts (Scotland) Regulations 2014. Other information The Chief Financial Officer is responsible for other information in the annual accounts. The other information comprises the Management Commentary, Annual Governance Statement, Statement of Responsibilities and the unaudited part of the Remuneration Report. My responsibility is to read all the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or my knowledge obtained in the course of the audit or otherwise appears to be materially misstated. If I identify such material inconsistencies or apparent material misstatements, I am required to determine whether this gives rise to a material misstatement in the financial statements themselves. If, based on the work I have performed, I conclude that there is a material misstatement of this other information, I am required to report that fact. I have nothing to report in this regard. My opinion on the financial statements does not cover the other information and I do not express any form of assurance conclusion thereon except on the Management Commentary and Annual Governance Statement to the extent 8
Page 9
explicitly stated in the following opinions prescribed by the Accounts Commission. Opinions prescribed by the Accounts Commission on the Management Commentary and Annual Governance Statement In my opinion, based on the work undertaken in the course of the audit: • the information given in the Management Commentary for the financial year for which the financial statements are prepared is consistent with the financial statements and that report has been prepared in accordance with statutory guidance issued under the Local Government in Scotland Act 2003; and • the information given in the Annual Governance Statement for the financial year for which the financial statements are prepared is consistent with the financial statements and that report has been prepared in accordance with the Delivering Good Governance in Local Government: Framework (2016). Matters on which I am required to report by exception I am required by the Accounts Commission to report to you if, in my opinion: • adequate accounting records have not been kept; or • the financial statements and the audited part of the Remuneration Report are not in agreement with the accounting records; or • I have not received all the information and explanations I require for my audit; • there has been a failure to achieve a prescribed financial objective. I have nothing to report in respect of these matters. Conclusions on wider scope responsibilities In addition to my responsibilities for the annual accounts, my conclusions on the wider scope responsibilities specified in the Code of Audit Practice, including those in respect of Best Value, are set out in my Annual Audit Report. Use of my report This report is made solely to the parties to whom it is addressed in accordance with Part VII of the Local Government (Scotland) Act 1973 and for no other purpose. In accordance with paragraph 120 of the Code of Audit Practice, I do not undertake to have responsibilities to members or officers, in their individual capacities, or to third parties. Brian Howarth ACMA CGMA Audit Scotland 8 Nelson Mandela Place Glasgow G2 1BT 9
Page 10
APPENDIX B Letter of Representation (ISA 580) Brian Howarth Audit Scotland 8 Nelson Mandela Place Glasgow G2 1BT Dear Mr Howarth North Lanarkshire IJB Annual report and accounts 2021/22 1. This representation letter is provided about your audit of the annual accounts of North Lanarkshire IJB for the year ended 31 March 2022 for the purpose of expressing an opinion as to whether the financial statements give a true and fair view in accordance with the financial reporting framework, and for expressing other opinions on the remuneration report, management commentary and annual governance statement. 2. I confirm to the best of my knowledge and belief and having made appropriate enquiries the following representations given to you in connection with your audit of North Lanarkshire IJB’s annual accounts for the year ended 31 March 2022. General 3. North Lanarkshire IJB and I have fulfilled our statutory responsibilities for the preparation of the 2021/22 annual accounts. All the accounting records, documentation and other matters which I am aware are relevant to the preparation of the annual accounts have been made available to you for the purposes of your audit. All transactions undertaken by North Lanarkshire IJB have been recorded in the accounting records and are properly reflected in the financial statements. 4. I confirm that I am not aware of any uncorrected misstatements. Financial Reporting Framework 5. The annual accounts have been prepared in accordance with the Code of Practice on Local Authority Accounting in the United Kingdom 2021/22 (2021/22 accounting code), and in accordance with the requirements of the Local Government (Scotland) Act 1973, the Local Government in Scotland Act 2003 and The Local Authority Accounts (Scotland) Regulations 2014. 6. In accordance with the 2014 regulations, I have ensured that the financial statements give a true and fair view of the financial position of the North Lanarkshire IJB at 31 March 2022 and the transactions for 2021/22. Accounting Policies & Estimates 7. All significant accounting policies applied are as shown in the notes to the financial statements. The accounting policies are determined by the 2021/22 accounting code where applicable. Where the code does not specifically apply, I have used judgement in developing and applying an accounting policy that results in information that is relevant and reliable. All 10
Page 11
accounting policies applied are appropriate to North Lanarkshire IJB’s circumstances and have been consistently applied. 8. The significant assumptions used in making accounting estimates are reasonable and properly reflected in the financial statements. Judgements used in making estimates have been based on the latest available, reliable information. Estimates have been revised where there are changes in the circumstances on which the original estimate was based or as a result of new information or experience. Going Concern Basis of Accounting 9. I have assessed North Lanarkshire IJB’s ability to continue to use the going concern basis of accounting and have concluded that it is appropriate. I am not aware of any material uncertainties that may cast significant doubt on North Lanarkshire IJB’s ability to continue as a going concern. Fraud 10. I have provided you with all information in relation to: • my assessment of the risk that the financial statements may be materially misstated as a result of fraud • any allegations of fraud or suspected fraud affecting the financial statements • fraud or suspected fraud that I am aware of involving management, employees who have a significant role in internal control, or others that could have a material effect on the financial statements. Laws and Regulations 11. I have disclosed to you all known instances of non-compliance or suspected non- compliance with laws and regulations whose effects should be considered when preparing financial statements. Related Party Transactions 12. All material transactions with related parties have been appropriately accounted for and disclosed in the financial statements in accordance with the 2021/22 accounting code. I have made available to you the identity of all the North Lanarkshire IJB’s related parties and all the related party relationships and transactions of which I am aware. Remuneration Report 13. The Remuneration Report has been prepared in accordance with the Local Authority Accounts (Scotland) Amendment Regulations 2014, and all required information of which I am aware has been provided to you. Management commentary 14. I confirm that the Management Commentary has been prepared in accordance with the statutory guidance and the information is consistent with the financial statements. Corporate Governance 15. I confirm that the North Lanarkshire IJB has undertaken a review of the system of internal control during 2021/22 to establish the extent to which it complies with proper practices set out in the Delivering Good Governance in Local Government: Framework 2016. I have 11
Page 12
disclosed to you all deficiencies in internal control identified from this review or of which I am otherwise aware. 16. I confirm that the Annual Governance Statement has been prepared in accordance with the Delivering Good Governance in Local Government: Framework 2016 and the information is consistent with the financial statements. There have been no changes in the corporate governance arrangements or issues identified, since 31 March 2022, which require to be reflected. Events Subsequent to the Date of the Balance Sheet 17. All events subsequent to 31 March 2022 for which the 2021/22 accounting code requires adjustment or disclosure have been adjusted or disclosed. Yours sincerely, Amanda Kilburn Chief Financial Officer 12
Page 13
Prepared for North Lanarkshire Integration Joint Board and the Controller of Audit November 2022 North Lanarkshire Integration Joint Board 2021/22 Annual Audit Report DRAFT Appendix 2 13
Page 14
North Lanarkshire Integration Joint Board 2021/22 Annual Audit Report DRAFT | 2 Contents Key messages 3 Introduction 4 1. Audit of 2021/22 annual accounts 6 2. Financial management and sustainability 10 3. Governance, transparency and Best Value 17 Appendix 1. Action plan 2021/22 20 Appendix 2. National performance reports and briefings 23 14
Page 15
Key messages | 3 Key messages 2021/22 annual accounts 1 Our audit opinions on the annual accounts of the North Lanarkshire Integration Joint Board are unmodified and there were no significant issues. Financial management and sustainability 2 The IJB returned an underspend of £66 million in 2021/22. There were significant underspends in health and social care services due to staff vacancies. 3 £32 million of Covid-19 funding in 2021/22 remains unspent and total reserves are £119 million. 4 The medium to long term financial plan has not been updated to reflect the expected impact of Covid-19. Governance, Transparency and Best Value 5 Finance capacity is being increased with the appointment of a new Chief Financial Officer for the IJB. 6 Performance has been affected by Covid-19, but the IJB has identified the steps required to address this. 15
Page 16
Introduction | 4 Introduction 1. This report summarises the findings arising from the 2021/22 audit of North Lanarkshire Integration Joint Board (the IJB). 2. The scope of the audit was set out in our 2021/22 Annual Audit Plan which was presented to the Board on 22 June 2022. 3. This report comprises the findings from the audit of the North Lanarkshire IJB’s annual accounts; consideration of the four audit dimensions that frame the wider scope of public audit set out in the Code of Audit Practice 2016; and a review of the arrangements put in place by the IJB to secure Best Value. 4. The global coronavirus pandemic has had a continued impact on the IJB during 2021/22. We did not identify any significant audit risks for 2021/22. Adding value through the audit 5. We add value to the IJB, through the audit by: • identifying and providing insight on significant risks, and making clear and relevant recommendations • sharing intelligence and good practice through our national reports (Appendix 2) and good practice guides • providing clear and focused conclusions on the appropriateness, effectiveness and impact of corporate governance, performance management arrangements and financial sustainability. Responsibilities and reporting 6. The IJB has primary responsibility for ensuring the proper financial stewardship of public funds. This includes preparing annual accounts that are in accordance with proper accounting practices. The IJB is also responsible for compliance with legislation and for putting arrangements in place for governance and propriety that enable it to successfully deliver its objectives. 7. Our responsibilities as independent auditor appointed by the Accounts Commission are established by the Local Government in Scotland Act 1973, the Code of Audit Practice 2016 and supplementary guidance, and International Standards on Auditing in the UK. 8. As public sector auditors we give independent opinions on the annual accounts. Additionally, we conclude on: • the effectiveness of the IJB’s performance management arrangements, 16
Page 17
Introduction | 5 • the suitability and effectiveness of corporate governance arrangements, • the financial position and arrangements for securing financial sustainability, and • Best Value arrangements. 9. Further details of the respective responsibilities of management and the auditor can be found in the Code of Audit Practice 2016. and supplementary guidance. 10. This report raises matters from our audit. Weaknesses or risks identified are only those which have come to our attention during our normal audit work and may not be all that exist. Communicating these does not absolve management from its responsibility to address the issues we raise and to maintain adequate systems of control. 11. Our annual audit report contains an agreed action plan at Appendix 1 setting out specific recommendations, responsible officers and dates for implementation. It also includes outstanding actions from last year and progress against these. Auditor Independence 12. Auditors appointed by the Accounts Commission or Auditor General must comply with the Code of Audit Practice and relevant supporting guidance. When auditing the financial statements auditors must comply with professional standards issued by the Financial Reporting Council and those of the professional accountancy bodies. 13. We can confirm that we comply with the Financial Reporting Council’s Ethical Standard. We can also confirm that we have not undertaken any non- audit related services and therefore the 2021/22 audit fee of £27,960 as set out in our 2021/22 Annual Audit Plan remains unchanged. We are not aware of any relationships that could compromise our objectivity and independence. 14. This report is addressed to both the IJB and the Controller of Audit and will be published on Audit Scotland's website www.audit-scotland.gov.uk. Audit appointment from 2022/23 15. The Accounts Commission is responsible for the appointment of external auditors to local government bodies. External auditors are usually appointed for a five-year term either from Audit Scotland’s Audit Services Group or a private firm of accountants. The current appointment round was due to end in 2020/21 but this was extended for a year. The procurement process for the new round of audit appointments was completed in May 2022. From financial year 2022/23, Audit Scotland will continue to be the appointed auditor for North Lanarkshire Integration Joint Board, although the team undertaking the audit will change. 16. We would like to thank members and staff, particularly those in finance for their co-operation and assistance over the last six years. 17
Page 18
1. Audit of 2021/22 annual accounts | 6 1. Audit of 2021/22 annual accounts The principal means of accounting for the stewardship of resources and performance Main judgements Our audit opinions on the annual accounts of the North Lanarkshire Integration Joint Board are unmodified and there were no significant issues. Our audit opinions on the annual accounts are unmodified 17. The IJB’s annual accounts for the year ended 31 March 2022 were approved by the Performance, Finance and Audit Committee on 30 November 2022. As reported in the independent auditor’s report: • the financial statements give a true and fair view and were properly prepared in accordance with the financial reporting framework • the audited part of the Remuneration Report, Management Commentary and the Annual Governance Statement were all consistent with the financial statements and properly prepared in accordance with the relevant regulations and guidance. The annual accounts were submitted for audit by the statutory date 18. The unaudited annual accounts were received in line with our agreed audit timetable on 30 June 2022. 19. The working papers provided with the unaudited accounts were of a good standard and finance staff provided support to the audit team during the audit. There were no objections raised to the annual accounts 20. The Local Authority Accounts (Scotland) Regulations 2014 require local government bodies to publish a public notice on its website that includes details of the period for inspecting and objecting to the accounts. This must remain on the website throughout the inspection period. There were no objections to the 2021/22 annual accounts. 18
Page 19
1. Audit of 2021/22 annual accounts | 7 21. The notice of inspection did not state the objection end date (which is one working day after the inspection period). The notice was posted on the North Lanarkshire Council’s website and not the IJB website. Recommendation 1 The notice of inspection should state the objection end date and the advert should be posted on the IJB website as well as the North Lanarkshire Council website. Overall materiality is £6.5 million 22. We apply the concept of materiality in both planning and performing the audit and in evaluating the effect of identified misstatements on the audit and of uncorrected misstatements, if any, on the financial statements and in forming the opinion in the auditor’s report. We identify a benchmark on which to base overall materiality, such as gross expenditure, and apply what we judge to be the most appropriate percentage level for calculating materiality values. We also determine a lower performance materiality threshold. 23. The determination of materiality is based on professional judgement and is informed by our understanding of the entity and what users are likely to be most concerned about in the annual accounts. In assessing performance materiality, we have considered factors such as our findings from previous audits, any changes in business processes and the entity’s control environment including fraud risks. 24. Our initial assessment of materiality for the annual accounts was carried out during the planning phase of the audit. This was reviewed on receipt of the unaudited annual accounts and remains unchanged. This is summarised in Exhibit 1. Exhibit 1 Materiality values Materiality level Amount Overall materiality £6.5 million Performance materiality £4.8 million Reporting threshold £200 thousand Source: Audit Scotland 19
Page 20
1. Audit of 2021/22 annual accounts | 8 We have no significant findings to report on the audited annual accounts 25. International Standard on Auditing (UK) 260 requires us to communicate significant findings from the audit to those charged with governance, including our view about the qualitative aspects of the body’s accounting practices. We have no issues to report from the audit. We have obtained assurance over the significant risks identified in our Annual Audit Plan 26. Exhibit 2 sets out the significant risks of material misstatement to the financial statements we identified in our 2021/22 Annual Audit Plan. It summarises the further audit procedures we performed during the year to obtain assurances over these risks and the conclusions from the work completed. Exhibit 2 Significant risks of material misstatement in the financial statements Audit risk Assurance procedure Results and conclusions 1. Risk of management override of controls International Auditing Standards require that audits are planned to consider the risk of fraud, which is presumed to be a significant risk in any audit. This includes the risk of fraud due to the management override of controls. • Agreement of balances and transactions to North Lanarkshire Council and NHS Lanarkshire financial reports / ledger / correspondence. • Assurances will be obtained from the auditors of NHS Lanarkshire and North Lanarkshire Council over the completeness, accuracy and allocation of income and expenditure. • Review of significant adjustments at year-end. • Review of financial monitoring reports during the year. Results & Significant Judgements: We obtained relevant assurances from the auditors of North Lanarkshire Council and NHS Lanarkshire. We identified the process for preparing the accounts based on financial reports from the partner organisations We undertook detailed testing of year-end adjustments. We reviewed financial reports prepared during 2021/22 Conclusion: We did not identify any incidents of management override of controls. There were no identified misstatements in the audited annual accounts 27. It is our responsibility to request that all misstatements, other than those below the reporting threshold, are corrected. However, the final decision on making the correction lies with those charged with governance considering 20
Page 21
1. Audit of 2021/22 annual accounts | 9 advice from senior officers and materiality. There were no misstatements identified that exceeded our reporting threshold. Limited progress was made on prior year recommendations 28. The IJB has made limited progress in implementing our prior year audit recommendations. Only two of the four prior year recommendations have been complete. For actions not yet implemented, revised responses and timescales have been agreed with management, and are set out in Appendix 1. 21
Page 22
2. Financial management and sustainability | 10 2. Financial management and sustainability Financial management is about financial capacity, sound budgetary processes and whether the control environment and internal controls are operating effectively. Financial sustainability looks forward to the medium and long term to consider whether the council is planning effectively to continue to deliver its services or the way in which they should be delivered. Main judgements The IJB returned an underspend of £66 million in 2021/22. There were significant underspends in health and social care services due to staff vacancies. £32 million of Covid-19 funding in 2021/22 remains unspent and total reserves are £119 million. The medium to long term financial plan has not been updated to reflect the expected impact of Covid-19. The 2021/22 budgeted gap of £2.5 million was to be met by planned savings and from reserves 29. The IJB approved its 2021/22 budget on 23 March 2021. The budget had a funding gap of £2.5 million. Plans to address the gap included savings of £1.7 million and a transfer of £0.8 million from reserves. 30. All funding and expenditure for the IJB is incurred by partner bodies (North Lanarkshire Council and NHS Lanarkshire) and processed in their accounting records. North Lanarkshire Council progressed the previously agreed savings plans for year 2 of the 3-year Efficiency Programme, approved in March 2020, which aimed to meet £1.5 million out of the total £1.7 million planned savings. In NHS Lanarkshire, part of the funding gap was due to the net increase in prescribing costs of £0.3 million. This was addressed by a Prescribing Quality and Efficiency Programme target totalling £1.6 million. The IJB underspent by £66 million in 2021/22 31. The Covid-19 pandemic had a significant impact on the IJB’s 2021/22 budget. Costs remained uncertain throughout the year, and it was not clear 22
Page 23
2. Financial management and sustainability | 11 whether Covid-19 costs and undelivered savings would be fully funded going forward. 32. The IJB returned a total underspend of £74 million which reflects an underspend on services of £66 million and an £8 million draw down on the IJB reserves (Exhibit 3). The outturn was a result of significant year-end additional allocations from the Scottish Government, including Covid-19 funding and because of underspends, caused by ongoing vacancies across many services. Exhibit 3 Performance against budget IJB budget summary Budget £m Actual £m Variance £m Gross Core Expenditure 751.7 685.2 66.5 Total Income (751.7) (759.9) 8.2 In-year expenditure met from Reserves 0 8.3 8.3 Surplus of Income over Expenditure 0.0 (66.4) 66.4 Source: North Lanarkshire IJB Annual Accounts 2021/22 There were significant underspends in health services due to vacancies 33. The most significant variances within the NHS Lanarkshire underspend are within Hosted Services of £16.6 million which includes underspends of £10.3 million in Mental Health & Learning Disability Services and £5.3 million in Children and Adolescents Mental Health Services. Both underspends were mainly due to vacancies in nursing, psychology and administration posts. 34. There was also an underspend in Locality and Other services of £4.5 million. This is mainly due to vacancies across Nursing Services and Administration and Clerical staff within the localities totalling 66.06 WTE. There were incremental pay increases and unfunded enhancements across many services however these cost pressures were offset in-year by the vacancies. 35. There were also underspends in Addiction Services of £2.3 million, Prescribing of £1.5 million and Primary Care and Mental Health Transformation Fund and the Primary Care Improvement Fund of £9.8 million. There were significant underspends in social care services due to additional funding and vacancies 36. From the North Lanarkshire Council underspend, £6.4 million is in relation to the Scottish Government Funding for winter planning and £0.8 million from 23
Page 24
2. Financial management and sustainability | 12 carers budgets. These will both be carried forward to ring-fenced reserves to be incurred in 2022/23. There was also an £8 million underspend within the care at home sector predominantly relating to staff shortages. £32 million of Covid-19 funding in 2021/22 remains unspent 37. Covid-19 funding totalling £45 million was received from the Scottish Government in 2021/22 of which £13.4 million was incurred in 2021/2022 and £31.7 million will be transferred to a ring-fenced reserve to meet ongoing Covid- 19 costs in 2022/2023. 38. The Scottish Government provided the following additional allocations which were unspent at the year-end and have been added to IJB reserves for use in future years: • Adult & Drug Partnership (ADP): £1.931 million • Child and Adolescent Mental Health Services (CAMHS): £9.109 million • Multi-Disciplinary teams: £1.160 million • Additional healthcare support workers: £0.634 million • Mental Health Action 15: £3.016 million • Distress brief Interventions: £1.444 million • Mental Health Recovery – Facilities: £1.840 million The budget monitoring arrangements are appropriate and clear information was provided to IJB Board members 39. Detailed budget monitoring reports were submitted to the IJB Board and the Performance, Finance and Audit Committee. The outturn to date and projected year-end outturn position were clearly stated in these reports while the actual year-end outturn position was in line with expectations. 40. The content of the budget monitoring reports was updated to reflect the financial impact of Covid-19 and an additional section was included that highlighted additional income received and expenditure incurred because of Covid-19. This ensured the IJB were aware of how Covid-19 impacted on the overall financial position and outturn. 41. We observed that senior management and members receive accurate financial information on the IJB’s financial position. However, the first quarterly financial monitoring report was not presented to the Performance, Finance & Audit Committee until 5 months into the 2021/22 financial year on 24 August 2021. A prior-year audit recommendation regarding the timeliness of budgetary information being presented to members is included in Appendix 1. 24
Page 25
2. Financial management and sustainability | 13 The medium to long term financial plan has not been updated to reflect the expected impact of Covid-19 42. Financial sustainability looks forward to the medium and longer term to consider whether the body is planning effectively to continue to deliver its services or the way in which they should be delivered. 43. The IJB has a medium to long term financial plan in place spanning the period 2020/21 to 2029/30 which is aligned to the Strategic Commissioning Plan. However, the financial plan has not been updated since it was initially presented to the Board on 24 March 2020, and specifically has not been updated to reflect the impact of Covid-19. Financial planning has focussed primarily on the annual budget setting exercise. 44. Reports are presented to the Board as national funding allocations are announced. The medium to long term financial plan is to be updated to reflect these financial assumptions. 45. This was a recommendation that was included in our 2020/21 Annual Audit Report and has been carried-forward in Appendix 1. Total reserves are £119 million, with the majority of this either earmarked or ring-fenced for specific purposes 46. With the £66 million surplus achieved in 2021/22, the balance on the General Fund was £119 million at 31 March 2022. The IJB’s reserves position for 2021/22 is summarised at Exhibit 4. Exhibit 4 Composition of IJB reserves as at 31 March 2022 38% 59% 3% Ring Fenced Reserves (£45.718m) Earmarked Reserves (£70.050m) Contingency Reserves (£3.684m) 25
Page 26
2. Financial management and sustainability | 14 Source: 2021/22 North Lanarkshire IJB Annual Accounts 47. Ring-fenced reserves are those where funding has been provided by the Scottish Government for specific purposes, such as funding to address Covid- 19 costs. Earmarked reserves are those where the IJB has approved the use of reserve balances for specific purposes. 48. The substantial increase in 2021/22 is primarily due to an underspend with Covid-19 funding received at the year-end by the Scottish Government, to be spent in future years. The non-recurring nature of these funds, and the reserves, presents a significant challenge to IJBs. Exhibit 5 below sets out the reserve balances of the IJB between 2016/17 to 2021/22. Exhibit 5 Reserves 2016/17 to 2021/22 2016/17 £m 2017/18 £m 2018/19 £m 2019/20 £m 2020/21 £m 2021/22 £m Ring-Fenced Reserves 0.000 0.000 2.4 2.3 20.7 45.7 Earmarked Reserves 3.2 13.8 13.5 10.4 28.7 70 Contingency Reserves 4.3 4.4 0.1 3.7 3.7 3.7 Total Reserves 7.5 18.2 16 16.4 53.1 119.4 Source: North Lanarkshire Integration Joint Board 2016/17 to 2021/22 Annual Accounts 49. The IJB Reserves Strategy for 2022/23 is still to be finalised and presented to Committee. Recommendation 2 The IJB should develop a reserves strategy for 2022/23 which sets out how and when reserves will be spent. 95 per cent of planned savings were achieved, however savings targets in 2022/23 have increased 50. The IJB is required to make efficiency savings to maintain financial balance. The total savings target in 2021/22 was £2.7 million. The IJB achieved £2.6 million (95%) of planned savings. It is important to note that some of the funding 26
Page 27
2. Financial management and sustainability | 15 solutions in 2021/22 were non-recurring and therefore some cost pressures are expected to recur in 2022/23. 51. The 2022/23 Financial Plan was approved on 23 March 2022. Including the cost of the approved North Lanarkshire Winter Planning and Enhanced Supports Business Case, costs are projected to increase by a total of £56.9 million in 2022/23 and funding is projected to increase by £51.4 million. The 2022/23 funding gap of £5.5 million is to be addressed by budget realignments (£3.3 million), a projected recurring prescribing budget underspend (£1.5 million), prescribing efficiency savings (£0.4 million) and reliance on reserves (£0.4 million). There remain significant workforce pressures within both partner organisations 52. There are significant workforce pressures in the NHS and social care systems. In its February 2022 NHS in Scotland 2021 report, Audit Scotland noted the risk of workforce issues in the NHS. This included concerns about staff wellbeing, sustainability because of retirals, recruitment challenges, and the need to ensure the appropriate skills mix. In social care, Audit Scotland’s 2022 Social Care briefing highlighted that the social care workforce has high vacancy rates, with many services facing recruitment problems. Together with the increasing demand for social care, this presents a risk to the capacity and quality of social care services. The national workforce issues are replicated within both partner organisations of the North Lanarkshire IJB. These issues have the potential to impact on the IJB’s performance. 53. The IJB’s management team are already planning to undertake a review of workforce planning, as this has been a recurring theme in the risk register, particularly the availability of the workforce in certain areas. Challenges faced by the IJB need to be addressed regardless of medium-term proposals for a new National Care Service 54. Following the publication of the Independent Review of Adult Social Care in February 2021, work is currently under way nationally to develop and implement a new National Care Service (NCS). The Scottish Government expects the new NCS to be operational by 2026. 55. In its January 2022 Social Care briefing, Audit Scotland noted stakeholders concerns about the extent of the proposals for reform and the time it will take to implement them. Many of the current issues experienced by the social care sector, for example the workforce pressures, cannot wait for the Scottish Government to implement a new NCS. In its formal response to the national consultation on the new NCS proposals, the IJB highlighted similar points to those identified in the Audit Scotland national report. Whilst supportive of the opportunity to discuss improvements to users experience of social care services, the IJB emphasised the importance of ongoing discussions on the short, medium, and long-term challenges relating to funding, staffing, and service redesign. 27
Page 28
2. Financial management and sustainability | 16 Financial systems of internal control operated effectively 56. The IJB does not have its own financial systems and instead relies on partner bodies’ financial systems. All financial transactions are therefore processed under the partner bodies’ internal controls. 57. As part of our audit approach, we sought assurances from the external auditor of NHS Lanarkshire and North Lanarkshire Council and confirmed there were no significant weaknesses in the systems of internal controls for either the health board or the council. 58. As auditors, we need to consider whether audited bodies have established adequate financial management arrangements. While the Joint Board has comprehensive financial regulations in place, these have not been reviewed since approval on 8 March 2016. They require to be updated to reflect the budget disaggregation of Children, Families and Justice Services and to also note the arrangements for the management of financial resources for hosted services. The IJB should ensure all governance documents are reviewed periodically to ensure they remain up-to-date and fit for purpose. Recommendation 3 The financial regulations were approved on 8 March 2016. These should be updated to reflect the budget disaggregation of Children, Families and Justice Services and to note the arrangements for the management of financial resources for hosted services. Standards of conduct and arrangements for the prevention and detection of fraud and error were appropriate 59. The IJB does not maintain its own policies relating to the prevention and detection of fraud and error but instead depends on those in place at its partner bodies. We reviewed the arrangements in place at North Lanarkshire Council and NHS Lanarkshire and found them to be adequate. The IJB has a Code of Conduct in place and members are required to complete a Register of Interest on an annual basis. We are not aware of any specific issues we require to bring to your attention. 28
Page 29
3. Governance, transparency and Best Value | 17 3. Governance, transparency and Best Value The effectiveness of scrutiny and oversight and transparent reporting of information Main Judgements Finance capacity is being increased with the appointment of a new Chief Financial Officer for the IJB. Performance has been affected by Covid-19, but the IJB has identified the steps required to address this. Governance arrangements are appropriate and operate effectively 60. Our observations at committee meetings throughout the year has found that these are conducted in a professional manner and there is a good degree of scrutiny and challenge by members. We consider that governance arrangements are appropriate and support effective scrutiny, challenge and decision making. 61. Our audit work in 2020/21 identified areas of the IJB website which are out of date and have not been revisited following changes to the partnership’s structure and operations. Children, families and justice social work services were transferred to the council in 2020/21 but are still identified as a devolved service to the IJB on the website. The website was not updated and therefore this remains as a recommendation brought forward form last year in Appendix 1. Finance capacity is being increased with the appointment of a new Chief Financial Officer for the IJB 62. At its meeting in December 2021, the IJB approved a new management structure to accommodate additional capacity in the finance function. The previous Chief Financial Officer (CFO) had responsibility for North and South Lanarkshire IJBs. 63. Following an options appraisal exercise, it was decided to create a full-time CFO position for each of the North and South Lanarkshire IJBs. A full-time CFO has been appointed to the North Lanarkshire IJB and the new structure is now established. 29
Page 30
3. Governance, transparency and Best Value | 18 Appropriate arrangements are in place to secure Best Value 64. Integration Joint Boards have a statutory duty to have arrangements to secure Best Value. To achieve this, IJBs should have effective processes for scrutinising performance, monitoring progress towards their strategic objectives and holding partners to account. 65. The IJB undertook a self-evaluation exercise in 2021, with the results reported to the Board on 31 August 2022. This self-evaluation exercise took the form of a checklist developed by the Improvement Service to allow IJBs to assess their own performance at board level against the expectations of the Public Bodies (Joint Working) (Scotland) Act 2014. It focuses primarily upon the effectiveness of current arrangements and how well the Board meets its intended outcomes. 66. Three areas were considered good practice, as 100% of the assessment team strongly agreed or agreed with each of the statements. This included: • The IJB can evidence examples of how it worked well together in response to Covid-19 • The IJB can demonstrate effective partnership working through local NHS mobilisation plans and local authority recovery and renewal planning • The IJB should look to permanently retain new ways of working developed during the response to Covid-19. 67. The IJB identified three areas for improvement which are set out below: • Evidencing how health and social care spending contributes to prevention and early intervention • Embedding learning and new ways of working in the IJB from the response to the pandemic to ensure plans and governance are fit for purpose • Review how performance information is used by the IJB to ensure it is timely, relevant, and provides a good measure of progress. 68. An improvement plan was developed for each of these three areas for improvement. There will be ongoing monitoring of progress against this improvement plan, and consideration of the need for a future follow up self- evaluation exercise. Performance has been affected by Covid-19, but the IJB has identified the steps required to address this 69. The pandemic is expected to have had a substantial impact on performance measures, particularly for services which have been temporarily suspended, are operating at a reduced level or have had to adapt to new ways of working. 30
Page 31
3. Governance, transparency and Best Value | 19 70. The Public Bodies (Joint Working) (Scotland) Act 2014 requires the IJB to produce an annual performance report covering areas such as assessing performance in relation to national health and wellbeing outcomes, financial performance and best value, reporting on localities, and the inspection of services. 71. The Board has continued to monitor key performance targets throughout the year. The IJB has a corporate performance dashboard which is monitored and reported on a quarterly basis. However, the 2021/22 Annual Performance Report has not yet been finalised. It is due to be presented to the IJB Board meeting on 7 December 2022. 72. The 2020/21 annual performance report was presented to the IJB in December 2021. The report acknowledges that there is a data gap nationally for a number of performance indicators and calendar year data for 2020 has been used in some instances. Performance levels are measured against a suite of 23 key performance indicators covering areas such as emergency admissions rates and patient satisfaction with GP services. 73. Delayed discharges, A&E attendances and unscheduled bed days remain key focusses for the IJB. 74. The annual performance report sets out the next steps for the IJB in improving performance across the statutory indicators. This is supported by the Strategic Commissioning Plan 2020-2023 and Programme of Work 2021-2022 which outline the approach to transformational change required to meet the IJB’s commissioning objectives. National performance audit reports 75. Audit Scotland carries out a national performance audit programme on behalf of the Accounts Commission and the Auditor General for Scotland. During 2021/22 we published some reports which may be of direct interest to the IJB as outlined in Appendix 2. 76. We noted that reference to relevant national reports were made by IJB Board members throughout the year. 31
Page 32
Appendix 1. Action plan 2021/22 | 20 Appendix 1. Action plan 2021/22 2021/22 recommendations Issue/risk Recommendation Agreed management action/timing 1. Accounts inspection advert The notice of inspection should state the objection end date and the advert should be posted on the IJB website in addition to the North Lanarkshire Council website. The IJB should ensure it has procedures in place to ensure the accounts inspection advert is published in line with criteria set out in the Local Authority Accounts (Scotland) Regulations 2014. Paragraph 21. The IJB will ensure future adverts are posted on the IJB website in addition to the North Lanarkshire Council website. Responsible officer: IJB Chief Financial Officer Agreed date: June 2023 2. 2022/23 Reserves Strategy There are significant reserves held at 31 March 2022. A reserves strategy for 2022/23 which sets out how and when monies will be spent, has not yet been developed. The IJB should develop a reserves strategy for 2022/23 which sets out how and when monies will be spent. Paragraph 47. The IJB 2022/23 Reserves Strategy will be presented to the PFA Committee on 16th November and to the IJB on 30th November 2022. The reserves strategy will continue to be updated in line with the new Strategic Commissioning Plan 2023- 2026 and the new Medium Term Financial Plan 2023- 2026. Responsible officer: IJB Chief Financial Officer Agreed date: November 2022 3. Review of Financial Regulations The financial regulations were approved on 8 March 2016. They require to be updated to reflect the budget disaggregation of Children, The financial regulations should be reviewed to ensure they remain up-to-date and fit for purpose. Paragraph 58. Agreed. The services currently delegated by each partner to the IJB will be specified in the IJB Financial Regulations. The principal method of accounting for 32
Page 33
Appendix 1. Action plan 2021/22 | 21 Issue/risk Recommendation Agreed management action/timing Families and Justice Services and to also note the arrangements for the management of financial resources for hosted services. Hosted Services will also be included. Responsible officer: IJB Chief Financial Officer Agreed date: 31 March 2023 Follow-up of prior year recommendations Issue/risk Recommendation Agreed management action/timing b/f 4. Website refresh It should be clear who has ownership of the IJB website and responsibility for maintaining it. The website should be refreshed to reflect the IJB’s current operating model. Ongoing HSCP working group is currently completing the development of the website. Responsible officer: IJB Chief Officer Revised date: 31 March 2023 b/f 5. Financial Management The CFO should continue to work with partners to improve the timing of financial reports being presented to Committee. The first quarterly financial monitoring report was not presented until 5 months into the financial year on 24 August 2021. Complete The current reporting arrangements are in line with the North Lanarkshire IJB Financial Regulations which state that a quarterly financial management report will be presented to the IJB by 31 August, or the nearest meeting of the Board or nearest complete accounting period. This is to enable the implementation of the financial strategy to be monitored. The IJB requires to wait until the first financial reports for the financial year from each partner are available. Presenting the first financial report is also dependent on when the first meeting of the IJB or PFA is scheduled for. 33
Page 34
Appendix 1. Action plan 2021/22 | 22 Issue/risk Recommendation Agreed management action/timing Opportunities will continue to be identified to develop financial monitoring arrangements. b/f 6. Hosted Services The IJB should set out the arrangements that exist in practice for the management of financial risk for hosted services on a permanent basis. Complete The 2022/23 Financial Plan for North Lanarkshire IJB has been prepared on the basis of the “principal” method of accounting for hosted services and on the understanding that the lead partner for the hosted services will continue to retain underspends and will manage overspends. b/f 7. Medium to long term financial plan The IJB’s medium to long term financial plan should be reviewed due to the impact of Covid-19 and EU withdrawal. Ongoing The new Medium Term Financial Plan 2023-2026 reflects the impact of recovering from Covid-19 and other challenging factors facing the IJB. It has been condensed to a three-year plan rather than the original ten-year plan due to the pending formation of the National Care Service (NCS) and the continuing uncertainty around future funding. The MTFP will align to the Strategic Commissioning Plan 2023- 2026 and the current IJB Reserves Strategy Responsible officer: IJB Chief Financial Officer Revised date: 31 March 2023 34
Page 35
Appendix 2. National performance reports and briefings | 23 Appendix 2. National performance reports and briefings May Local government in Scotland Overview 2021 June Covid 19: Personal protective equipment July Community justice: Sustainable alternatives to custody September Covid 19: Vaccination programme January Planning for skills Social care briefing February NHS in Scotland 2021 March Local government in Scotland: Financial Overview 20/21 Drug and alcohol: An update Scotland’s economy: Supporting businesses through the Covid 19 pandemic 35
Page 36
Appendix 2. National performance reports and briefings | 24 North Lanarkshire Integration Joint Board Draft 2021/22 Annual Audit Report Audit Scotland’s published material is available for download on the website in a number of formats. For information on our accessibility principles, please visit: www.audit-scotland.gov.uk/accessibility For the latest news follow us on social media or subscribe to our email alerts. Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN Phone: 0131 625 1500 Email: info@audit-scotland.gov.uk www.audit-scotland.gov.uk AS.4.0 36