Democracy Spraffa

Agenda Document Pack - Risk and Audit Scrutiny Committee - 27/09/2022

South Lanarkshire Council · 27 September 2022
Back to Risk and Audit Scrutiny Committee — 27 September 2022 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

Original council PDF · Download plain text

Page 1

Council Offices, Almada Street        
Hamilton, ML3 0AA 
Friday, 16 September 2022 
Dear Councillor 
Risk and Audit Scrutiny Committee 
The Members listed below are requested to attend a meeting of the Committee to be held as
follows:- 
Date:  Tuesday, 27 September 2022
Time:  10:00
Venue: Hybrid - Council Chamber, Council Offices, Almada Street, Hamilton, ML3
0AA 
The business to be considered at the meeting is listed overleaf. 
Yours sincerely 
Cleland Sneddon
Chief Executive 
Members 
Elaine McDougall (Chair), Mary Donnelly (Depute Chair), Mathew Buchanan, Alistair Fulton,
Ross Gowland, Celine Handibode, Cal Johnston-Dempsey, Susan Kerr, Richard Lockhart 
Substitutes
Colin Dewar, Gavin Keatt, Monique McAdams, Helen Toner
1

Page 2

BUSINESS 
1 Declaration of Interests 
2 Minutes of Previous Meeting
Minutes of the previous meeting of the Risk and Audit Scrutiny Committee
held on 22 June 2022 submitted for approval as a correct record.  (Copy
attached) 
3 - 10 
Item(s) for Decision 
3 2022/2023 Internal Audit Plan
Report dated 9 September 2022 by the Executive Director (Finance and
Corporate Resources).  (Copy attached) 
11 - 20 
Item(s) for Noting 
4 Internal Audit Activity as at 9 September 2022
Report dated 9 September 2022 by the Executive Director (Finance and
Corporate Resources).  (Copy attached) 
21 - 30 
5 Year End Insured Risks Report – 2021/2022
Report dated 13 September 2022 by the Executive Director (Finance and
Corporate Resources).  (Copy attached) 
31 - 40 
6 Fraud Statistics Annual Report 2021/2022
Report dated 8 September 2022 by the Executive Director (Finance and
Corporate Resources).  (Copy attached) 
41 - 46 
7 2020 National Fraud Initiative Exercise
Report dated 8 September 2022 by the Executive Director (Finance and
Corporate Resources).  (Copy attached) 
47 - 56 
8 Forward Programme for Future Meetings
Report dated 13 September 2022 by the Executive Director (Finance and
Corporate Resources).  (Copy attached) 
57 - 60 
Urgent Business 
9 Urgent Business
Any other items of business which the Chair decides are urgent. 
Clerk Name: Elizabeth-Anne McGonigle
Clerk Telephone: 07385403101
Clerk Email: elizabeth-anne.mcgonigle@southlanarkshire.gov.uk 
2

Page 3

RISK AND AUDIT SCRUTINY COMMITTEE 
Minutes of meeting held via Microsoft Teams and in the Banqueting Hall on 22 June 2022 
Chair:
Councillor Elaine McDougall 
Councillors Present:
Councillor Cal Dempsey, Councillor Mary Donnelly (Depute), Councillor Alistair Fulton, Councillor Gavin
Keatt (substitute for Councillor Mathew Buchanan), Councillor Ross Gowland, Councillor Susan Kerr,
Councillor Richard Lockhart 
Councillors' Apologies:
Councillor Mathew Buchanan, Councillor Celine Handibode 
Councillor Also Present:
Councillor Joe Fagan (for items 3 and 4) 
Attending:
Chief Executive’s Service
C Sneddon, Chief Executive (for items 3 and 4)
Finance and Corporate Resources
P Manning, Executive Director; Y Douglas, Audit and Compliance Manager; G McCann, Head of
Administration and Legal Services; E-A McGonigle, Administration Officer; F Morrison, Revenues
and Benefits Manager; A Norris, Administration Assistant; J Taylor, Head of Finance (Strategy) 
Also Attending:
Audit Scotland
A Kerr and G McNally, External Auditors 
1 Declaration of Interests 
No interests were declared. 
2 Internal Audit Annual Assurance Report 2021/2022 
A report dated 7 June 2022 by the Audit and Compliance Manager (Finance and Corporate
Resources) was submitted providing:- 
 a summary of progress and performance of Internal Audit for the financial year 2021/2022
 an opinion on the adequacy and effectiveness of the Council’s framework of governance,
risk management and control systems based on audit work undertaken in 2021/2022 
Details were given on:- 
 Internal Audit performance
 Council-wide performance in relation to the delivery of audit actions
 workload analysis
 links to the Council’s objectives and top risks
 management of fraud risks
 areas of assurance
 areas of external reliance
2
3

Page 4

Many of the pressures which had impacted on the Council’s systems and controls due to
COVID-19 had continued into 2021/2022.  The UK Public Sector Internal Audit Standards
Advisory Board had issued guidance around conformance with the Public Sector Standards
which had shaped the Council’s internal audit approach in 2021/2022 which aimed to:- 
 help protect the organisation’s operations by assisting management to find new ways of
working
 provide real-time advice and insight in the development of new systems and controls
 ensure that core internal audit work remained risk-based and relevant and continued to
inform longer term planning around risks
 allow the regular reporting of activity to this Committee 
The overall opinion expressed on the Council’s control environment was that a reasonable level
of assurance could be placed on the adequacy and effectiveness of the Council’s framework of
governance, risk management and control arrangements for the year ended 31 March 2022. 
The Internal Audit findings would inform the Council’s 2021/2022 Annual Governance
Statement. 
The Committee decided: 
(1) that the performance of Internal Audit during 2021/2022 be noted; 
(2) that the level of assurance on the Council’s control environment be noted; and 
(3) that it be noted that the overall findings from Internal Audit work would inform the Council’s
2021/2022 Annual Governance Statement. 
[Reference:  Minutes of 22 June 2021 (Paragraph 3)] 
3 Annual Governance Statement for 2021/2022 and Significant Governance Areas
Quarter 4 Progress Report 
A report dated 8 June 2022 by the Executive Director (Finance and Corporate Resources) was
submitted on the Annual Governance Statement for 2021/2022 and progress against significant
governance areas identified within the 2020/2021 Annual Governance Statement at Quarter 4. 
Each year, the Council undertook a review of the governance arrangements required to support
its financial and operational controls.  This review provided the basis for the Annual Governance
Statement which was included in the Council’s Annual Report and Statement of Accounts. 
The Council’s governance assurance framework was detailed in Appendix 1 to the report.  The
resulting Annual Governance Statement for 2021/2022, attached as Appendix 2 to the report,
provided information on the Council’s compliance during 2021/2022.  The annual review of
governance arrangements across the Council demonstrated sufficient evidence that the
principles of delivering good governance in local government, contained in the Local Code of
Corporate Governance, operated effectively and that the Council complied with its Code. 
Progress on the significant governance areas highlighted within the Annual Governance
Statement 2020/2021 was attached as Appendix 3 to the report. 
The Committee decided: 
(1) that the Annual Governance Statement, attached as Appendix 2 to the report, which would
be included in the 2021/2022 Annual Report and Statement of Accounts, be approved; and
4

Page 5

(2) that the progress on the Good Governance Statement Action Plan at Quarter 4 2020/2021,
detailed in Appendix 3 to the report, be noted. 
[Reference:  Minutes of 22 June 2021 (Paragraph 4)] 
4 Unaudited Annual Accounts 2021/2022 
A report dated 7 June 2022 by the Executive Director (Finance and Corporate Resources) was
submitted on the requirement for members to consider the Unaudited Annual Accounts of the
Council and related Charitable Trusts, attached as appendices 1 and 3 to the report, by 30 June
2022. 
The Council’s Unaudited Annual Accounts detailed key information on the Council’s expenditure
and income for the financial year ended 31 March 2022.  The accounts also covered 3
Charitable Trusts managed by the Council, namely South Lanarkshire Council Educational
Trust, South Lanarkshire Council Charitable Trust and the East Kilbride Information Technology
Trust.   
Due to the ongoing impact of COVID-19, the Scottish Government had extended the normal
audit deadline from 30 September to 30 November 2022.  The Council’s External Auditors would
be working to a deadline of 31 October 2022.  The full Unaudited Annual Accounts would be
circulated to members following their submission to the auditor on 30 June 2022 and would be
advertised as being available for public inspection on the Council’s website from that date.   
The information contained in the Unaudited Accounts took into account the final outturn position,
as detailed in Appendix 2 to the report, which would be submitted to the Executive Committee
on 29 June 2022 for approval.  Appendix 2 also provided an Expenditure and Funding Analysis
as required by the Chartered Institute of Public Finance and Accountancy (CIPFA) Code of
Accounting Practice. 
The Chair and Depute, on behalf of the Committee members, expressed appreciation of the
work undertaken to prepare the Unaudited Accounts. 
The Committee decided: that the Unaudited Annual Accounts of the Council and
related Charitable Trusts, to be submitted to Audit Scotland
by the deadline of 30 June 2022, be noted. 
5 Internal Audit Activity as at 3 June 2022 
A report dated 7 June 2022 by the Executive Director (Finance and Corporate Resources) was
submitted on work completed by Internal Audit during the period 8 January to 3 June 2022. 
Findings from internal audit assignments were reported to this Committee throughout the year
and the last progress report was considered by this Committee on 26 January 2022.  Key
performance indicators, which reflected quality, on time and within budget for the period to 31
March 2022, were summarised in Appendix 1 to the report.  100% of draft reports were issued
on time and 87% within budget against targets of 80% respectively.  Quality continued to be
monitored through internal quality control procedures.  As at 30 April 2022, 92% of the
2021/2022 Audit Plan was complete. 
Client contributions to the delivery of the audit plan took the form of responding to draft reports,
agreeing to close meetings and signing reports timeously once agreed.  95% of audit
assignments were concluded to a signed action plan within 4 weeks of the issue of a draft report
against a target of 80%.
5

Page 6

An update on progress with the delivery of the Audit Plan for 2022/2023 was provided in
Appendix 2 to the report.  Further information around the allocation of the remaining Audit Plan
time would be presented to the Committee for approval on 27 September 2022.  In the interim,
Internal Audit would focus on the delivery of corporate tasks and the continuation and
finalisation of audit assignments from the 2021/2022 Plan. 
The findings from assignments completed in the period 8 January to 3 June 2022 were detailed
in Appendix 3 to the report.   
The Council formed part of the Glasgow City Region City Deal which funded a range of capital
projects within South Lanarkshire.  Similar to the Council’s own governance arrangements, there
was an Internal Audit Plan of work within the Glasgow City Region City Deal programme which
was delivered by Glasgow City Council. Audit recommendations were followed up by Glasgow
City Council as part of the annual audit plan and, where relevant, those actions would be added
to South Lanarkshire Council’s audit action database to ensure those were implemented in full
and on time.  Delivery on those actions would be reported within the Key Performance Indicators
included in the routine activity reports to the Committee. 
An update report would be submitted to a future meeting of this Committee as appropriate.   
Information on the Chief Internal Auditor’s Group activities during 2021 was attached as
Appendix 5 to the report. 
The Committee decided: that the report be noted. 
[Reference:  Minutes of 26 January 2022 (Paragraph 5)] 
6 Audit Scotland – Financial Overview 2020/2021 
A report dated 25 May 2022 by the Executive Director (Finance and Corporate Resources) was
submitted on the Audit Scotland report entitled ‘Financial Overview 2020/2021’ which had been
published in March 2022. 
The report had been structured as follows:- 
 Part 1 - Councils’ Income in 2020/2021
 Part 2 - Financial Position
 Part 3 - Financial Outlook 
The key messages from the Audit Scotland report were detailed, together with an assessment of
the position in South Lanarkshire Council. 
The Committee decided: 
(1) that the key messages and recommendations contained in the Audit Scotland report
entitled 'Financial Overview 2020/2021', as detailed in sections 4 to 6 of the report, be
noted; and 
(2) that the Council’s position on those key messages and recommendations, as detailed in
section 7 of the report, be noted. 
[Reference:  Minutes of 15 September 2021 (Paragraph 9)] 
6

Page 7

7 Financial Resources Scrutiny Forum Activity 
A report dated 24 May 2022 by the Executive Director (Finance and Corporate Resources) was
submitted on reports considered by the Financial Resources Scrutiny Forum in the period from
July 2021 to March 2022. 
A report on the business considered by the Financial Resources Scrutiny Forum would continue
to be submitted to the Risk and Audit Scrutiny Committee on an annual basis. 
The Committee decided: that the report be noted. 
[Reference:  Minutes of 22 June 2021 (Paragraph 8)] 
8 Annual Audit Plan 2021/2022 
The Committee considered the South Lanarkshire Council Audit Plan for 2020/2021 submitted
by Audit Scotland, the Council’s External Auditor. 
The Plan set out the audit work necessary to allow Audit Scotland to provide an independent
auditor’s report and meet the wider scope requirements of public sector audit which included
assessing arrangements for:- 
 financial sustainability
 financial management
 governance and transparency
 value for money
 best value 
The Plan was structured around the following areas:- 
 annual accounts audit planning
 audit dimensions and best value
 reporting arrangements, timetable and audit fee
 other matters 
Details were given on key aspects of those areas. 
The Auditor General for Scotland, the Accounts Commission and Audit Scotland continued to
assess the risks to public services and finances from COVID-19 across the full range of their
audit work, including annual audits and the programme of performance audits. 
A Kerr, Senior Audit Manager, informed the Committee that following the audit appointment
exercise, Audit Scotland would remain as the appointed External Auditor for the Council for the
next 5 years, however, there would likely be changes to the audit team.  The current team would
remain in place until the 2021/2022 annual accounts had been signed off. 
The Committee decided: that the report be noted. 
[Reference:  Minutes of 3 March 2021 (Paragraph 5)] 
7

Page 8

9 Audit Scotland Report: The impact of COVID-19 on Scottish Councils’ Benefit
Services – A Thematic Study 
A report dated 17 May 2022 by the Executive Director (Finance and Corporate Resources) was
submitted providing a summary of the Audit Scotland Report ‘The impact of COVID-19 on
Scottish Councils’ benefit services – A Thematic Study’ released in October 2021. 
In March 2020, in response to the COVID-19 pandemic and in line with UK and Scottish
Government advice, Council buildings were closed to the public and, where possible, staff were
required to work from home.  As a key Council service, this presented a significant challenge for
benefit services.  Additionally, the Scottish Government’s response to the pandemic led to the
creation of local and national hardship schemes and many councils’ benefit services had
responsibility for administering and processing applications for support grants offered by those
schemes. 
Audit Scotland had issued a questionnaire to all 32 Scottish councils to measure the impact of
the pandemic on benefit services in terms of:- 
 Housing Benefit (HB) resources
 Information Technology
 Claims processing
 Accuracy 
The data and analysis in the Audit Scotland report was based on the questionnaire responses
and had not been independently validated, with the exception of claims processing performance,
which was validated against Department for Work and Pensions (DWP) published data. 
Information was provided on Audit Scotland’s recommendations, together with an assessment of
the position in South Lanarkshire Council. 
The Chair and Depute, on behalf of the Committee members, welcomed the report and
expressed appreciation of the work undertaken by staff throughout the COVID-19 pandemic to
keep services operational. 
The Committee decided: that the key messages and recommendations in the Audit
Scotland report ‘The impact of COVID-19 on Scottish
Councils’ benefit services – A Thematic Study’ be noted. 
10 Forward Programme for Future Meetings 
A report dated 6 June 2022 by the Executive Director (Finance and Corporate Resources) was
submitted on the outline forward programme for the meeting of the Risk and Audit Scrutiny
Committee to 6 December 2022. 
As part of future arrangements, members were invited to suggest topics for inclusion in the
Committee’s forward programme. 
In response to a member’s question in relation to the Scottish Government’s recent
announcement on a National Care Service,  the Executive Director (Finance and Corporate
Resources) advised that the implications of this proposal would be considered by the Council in
terms of its review of top risks and their impact on service delivery.  An update report of top risks
would be presented to a future meeting of this Committee.
8

Page 9

The Committee decided: 
(1) that the outline forward programme for the meetings of the Risk and Audit Scrutiny
Committee to 6 December 2022 be noted; and 
(2) that an update report of top risks be presented to the 25 October 2022 meeting of this
Committee. 
11 Urgent Business 
There were no items of urgent business. 
9

Page 10

10

Page 11

Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee 
Date of Meeting: 27 September 2022
Report by: Executive Director (Finance and Corporate Resources)  
Subject: 2022/2023 Internal Audit Plan 
1. Purpose of Report
1.1. The purpose of the report is to:- 
 seek approval of the proposed Internal Audit Plan for 2022/2023 
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendation(s):- 
(1) that the proposed Internal Audit Plan for 2022/2023 be approved. 
3. Background
3.1. Public Sector Internal Auditing Standards (PSIAS) require a specific risk-based
approach to be taken when preparing audit plans. All requirements have been followed
in preparation of the 2022/2023 Internal Audit Plan.  The Internal Audit function’s
compliance with PSIAS is due to be externally assessed by East Lothian Council in
2022/2023.  The outcome of this assessment will be presented to the Risk and Audit
Scrutiny Committee (RASC) in March 2023. 
3.2. The first phase of the annual 2022/2023 Internal Audit Plan was presented to the
Committee in January 2022 and attached at Appendix 1 is an update on progress with
completing this programme of work.   
3.3. The content of audit plans is determined by the requirement to deliver a programme
of work that informs the annual audit opinion on the overall adequacy and
effectiveness of an organisation’s framework of governance, risk management and
control arrangements.  The Internal Audit Plans for South Lanarkshire Council in
2022/2023 support this objective by:- 
 linking to the Council’s objectives and priorities
 providing assurance (as part of a rolling programme of work) in relation to top
risks that have been identified by the Council
 delivering a balanced plan in compliance with PSIAS that maximise resources
available
 committing resources to support corporate activity
 prioritising assignments to ensure key areas of work are completed in year. 
4. Internal Audit Plan 2022/2023
4.1. The earlier presentation of the first phase of the 2022/2023 Internal Audit Plan to
RASC (in January 2022) recognised some time was needed to fully assess the extent
3
11

Page 12

of the function’s role in the implementation of Oracle Fusion within South Lanarkshire
Council, a significant new human resources and financial accounting system. 
4.2. Two full-time posts within Internal Audit have been deployed to date in this financial
year with arrangements now being put in place to release one of these posts back to
the Service to deliver core internal audit assignments.  An additional auditor is now
being recruited for the remaining duration of the project.  In year capacity has been
impacted by the requirement to assist with the implementation of Oracle Fusion as
well as other temporary resourcing pressures in 2022/2023.  A further review of overall
capacity has been undertaken ahead of drafting this final phase of the Audit Plan. 
Assumptions that underpinned earlier assessments have been reviewed and the
number of days available to deliver the 2022/2023 Internal Audit Plan revised. 
4.3. Once capacity had been determined, the content of the Plan was developed.  This
considered the assessed top risks of the Council.  These risks are revised on an
annual basis and, in 2022/2023, the review was ongoing at the date of this report. 
Discussions with Risk Management have identified some potential changes to the top
risk register in relation to ‘cost of living’ (the risk the Council fails to support households
significantly impacted by this crisis) and ‘Community Wealth Building’ (the risk that the
Council fails to maximise the benefits of the Strategy).  Over-arching all of this is the
risk that the Council fails to achieve the outcomes of the Council Plan.  Previous,
identified risks remain valid with only ‘the impact of the UK leaving the EU’ deemed to
be an area of lessening risk.   
4.4.  The proposed final Internal Audit Plan for 2022/2023 is attached at Appendix 2.  This
represents the Plan for the full year and incorporates the work included in Phase 1 of
the 2022/2023 Internal Audit Plan along with a further programme of work for the
remainder of the year.  The Plan reflects time required to deliver a range of
assignments that seek to align to corporate objectives as well as providing assurance
around the general control environment of the Council.  Each audit is conducted in
accordance with the revised PSIAS and within the context of the Internal Audit Charter. 
A summary of how each assignment links to the three key assurance areas is included
at Appendix 3. 
4.5.  The Plan sets out the name of the proposed assignment, the lead Resource and a
brief outline scope for each proposed assignment. Objectives and scopes will be
refined by auditors prior to the commencement of work and once a full risk analysis
has been completed and key controls identified.  Clients will be involved in this initial
risk and control assessment and will be consulted prior to the preparation of the audit
remit for each assignment. 
4.6. Progress against the audit strategy will be monitored and reported to the RASC as
part of regular monitoring reports that are presented at each meeting.  Delivery of the
strategy will be evidenced by the completion of the 2022/2023 Internal Audit Plan. The
risk of significant subsequent changes to the Plan, arising from a change in the
Council’s priorities or risks, are reduced given the approach in 2022/2023 that has
allowed capacity to be reassessed mid-year.  A level of contingency time continues to
be built in to provide some flexibility throughout the remainder of the year.  Key
performance indicators will be reported to the RASC within routine activity reports and
the annual assurance report. 
4.7. The Committee is asked to approve the final phase of the 2022/2023 Internal Audit
Plan attached at Appendix 2. 
12

Page 13

5. Employee Implications
5.1. A full employee capacity plan was prepared at commencement of the audit planning
process and has now been revised. This has determined that 1,109 audit days can be
delivered in 2022/2023 (inclusive of days to deliver an internal audit service to external
clients).  This is broadly similar to the number of days that were available in previous
years albeit recent years have not been directly comparable given resources deployed
by the Service to respond to the pandemic and in year capacity in 2022/2023 being
impacted by a period of planned leave and secondments.    
6. Financial Implications
6.1. Capacity planning has been based on available budget.  This is considered to provide
sufficient resources to deliver the Audit Plan. 
7. Climate Change, Sustainability and Environmental Implications
7.1. There are no implications for climate change, sustainability or the environment in terms
of the information contained in this report. 
8. Other Implications
8.1. To mitigate against the risk of non-delivery of the Plan, the progress of every
assignment is monitored using the Council’s risk management software, Figtree.   
9. Equality Impact Assessment and Consultation Arrangements
9.1. There is no requirement to conduct an equality impact assessment on the proposed
Audit Plan.  Evidence is available of a level of consultation during preparation of the
Plan commensurate with the capacity to deliver in 2022/2023. 
Paul Manning
Executive Director (Finance and Corporate Resources) 
9 September 2022 
Link(s) to Council Values/Priorities/Outcomes
 Accountable, effective, efficient and transparent 
Previous References
 2022/2023 Internal Audit Plan, Risk and Audit Scrutiny Committee - 26 January 2022 
List of Background Papers
 Internal Audit planning documentation
 Internal Audit Charter 
Contact for Further Information
If you would like to inspect the background papers or want further information, please
contact:- 
Yvonne Douglas
Audit and Compliance Manager 
Ext:  2618  (Tel:  01698 45(2618))
E-mail:  yvonne.douglas@southlanarkshire.gov.uk
13

Page 14

Update on progress - 2022/2023 Internal Audit Plan   Appendix 1 
Lead Resource Audit
assignment Outline Scope Status    
Key year end tasks
FCR1 External
Audit 
Provide 2021/2022 general ledger data
to External Audit for the audit of the
financial accounts for the year ended 31
March 2022.
Complete
All
2021/2022
Annual
Report 
Prepare annual statement of assurance
for 2021/2022.  Present to RASC. Complete
All Governance
Statement 
Undertake review of evidence that
supports SLC’s Annual Governance
Statement and provide 2021/2022
annual assurance statement for Glasgow
City Region – City Deal.
Complete
Corporate tasks
All
Attend
internal and
external
working
groups 
Attend, respond to requests, participate
in consultations and provide updates. Ongoing
All Committee
reporting 
Prepare reports to present to RASC and
to External Client Committees and
Boards.
Ongoing
FCR Fusion Support implementation of project. Ongoing
All 2023/2024
Audit Plan 
Undertake consultation, risk assessment,
Resource and Section planning, set
scopes and objectives and seek approval
through preparation of reports.
Commence
Q3 
All
National
Fraud
Initiative
(NFI)
Coordinate data uploads for new NFI
exercise in 2022/2023.  Develop and
communicate plan for investigation of
matches in 2023/2024.
Commence
Q2
All Advice and
guidance 
Provision of advice and guidance on
online banking for school funds and on
the revision of duplicate invoice checks.
Online
banking –
complete
Duplicate
invoice
checks –
included as
part of
Fusion
Core programme of audit work
All Informal
Follow Up
Prompt Resources on a quarterly and
monthly basis of actions due within that
period.  Collate responses for reporting.
Ongoing
All Follow Up For all Council Resources, identify audit
recommendations due in the period April Ongoing 
1 Finance and Corporate Resources  14

Page 15

Lead Resource Audit
assignment Outline Scope Status
2021 to March 2022.  Risk assess and
follow-up to ensure implementation of all
high risk actions.
CER2/HTR3/FCR Follow Up
Undertake follow up of procurement
audits within Roads and Property
Services and debtors review within
Benefits and Revenue Services.
Commence
Q3 
All Anti-fraud
checks  
Rolling programme of anti-fraud checks –
including procurement, petty cash and
purchase cards. 
Commence
Q3
All
Continuous
Controls
Monitoring
(CCM)
Continue to download data in current
CCM areas.  Use data for analysis and to
inform internal and external audit testing.
Ongoing
EDR4 Optimisation
software
Review of optimisation software to
establish benefit of using within other
Council Services.
Added to
scope of
ASN audit
FCR/CER Investigative
contingency 
Undertake investigations as required
(including COVID-19 grants). Ongoing
All General
contingency
Conclude all 2021/2022 audits and
responded to requests for unplanned
work 2022/2023.
Ongoing
All Resource
audits 
Deliver a programme of risk-based audits
across Council Resources (to be
presented June 2022)
Included in
Audit Plan
(see
Appendix
2)
N/A Audit Plan Deliver internal audit service to External
Clients Ongoing 
2 Community and Enterprise Resources
3 Housing and Technical Resources
4 Education Resources 15

Page 16

Proposed 2022/2023 Internal Audit Plan       Appendix 2 
Lead
Resource
Audit
assignment Outline Scope Days
Key year end tasks
FCR5 External Audit 
Provide 2021/2022 general ledger data to
External Audit for the audit of the financial
accounts for the year ended 31 March
2022.
11
All 2021/2022
Annual Report 
Prepare annual statement of assurance for
2021/2022.  Present to RASC. 10
All Governance
Statement 
Undertake review of evidence that supports
SLC’s Annual Governance Statement and
provide 2021/2022 annual assurance
statement for Glasgow City Region – City
Deal.
5
Corporate tasks
All
Attend internal
and external
working groups 
Attend, respond to requests, participate in
consultations and provide updates. 39
All Committee
reporting 
Prepare reports to present to RASC and to
External Client Committees and Boards. 10
FCR Fusion Support implementation of project. 3746
All 2023/2024
Audit Plan 
Undertake consultation, risk assessment,
Resource and Section planning, set scopes
and objectives and seek approval through
preparation of reports.
10
All National Fraud
Initiative (NFI)
Coordinate data uploads for new NFI
exercise in 2022/2023.  Develop and
communicate plan for investigation of
matches in 2023/2024. 
30
All Advice and
guidance  Provision of advice and guidance. 10
Core programme of audit work
All Informal Follow
Up
Prompt Resources on a quarterly and
monthly basis of actions due within that
period.  Collate responses for reporting.
6
All Follow Up
For all Council Resources, identify audit
recommendations due in the period April
2021 to March 2022.  Risk assess and
follow-up to ensure implementation of all
high risk actions.
15
CER7/HTR8 Follow Up Undertake follow up of procurement audits
within Roads and Property Services. 60 
5 Finance and Corporate Resources
6 This includes 25 days for external clients.
7 Community and Enterprise Resources
8 Housing and Technical Resources 16

Page 17

Lead
Resource
Audit
assignment Outline Scope Days
All Anti-fraud
checks  
Rolling programme of anti-fraud checks –
including procurement, petty cash, COVID-
19 grants and purchase cards. Re-brief
Conflict of Interest policy and develop
annual process for briefing within
Resources.  Review and update Fraud
Policies and present to Committee for
approval.
123
All
Continuous
Controls
Monitoring
(CCM)
Continue to download data in current CCM
areas.  Use data for analysis and to inform
internal and external audit testing.
25
EDR9 Equity Strategy
Provide assurance of good governance
around spend and tracking of benefits
deriving from spend.
25
EDR
Education
Maintenance
Allowance
Test systems and processes to ensure
compliance with all relevant legislation and
Scottish Government requirements.
10
CER Sustainability
Provide assurance that plans are practically
deliverable in the short, medium and long
term and that in-year progress against
targets is monitored and reported.
25
SWR10 Self-Directed
Support 
Assess compliance with assessment and
review timescales.  Review evidence to 
ensure that this demonstrates that the 
assessed needs of users are being met.
20
FCR
Community
Wealth Building
Strategy
Test controls in place to mitigate the risk to
the Council of the Strategy not being fully
delivered.
30
EDR
Additional
Support Needs
Transport 
Test effectiveness of new systems and
procedures and implementation of agreed
actions.
30
FCR Cyber Security
Assess the Council’s level of resilience and
ability to use technology securely and to
respond and prevent cyber crime.
30
FCR Purchase
Cards
Provision of advice and guidance regarding
key controls attached to extending the use
of Purchase Cards across the Council. 
10
All Investigative
contingency  Undertake investigations as required. 55
All General
contingency Respond to requests for unplanned work. 34
N/A Audit Plan Deliver internal audit service to External
Clients.
112
TOTAL DAYS 1,109 
9 Education Resources
10 Social Work Resources 17

Page 18

Full Year Plan - Assurance Mapping       Appendix 3 
Resource Audit Assignment Scope of Work Area of
Assurance
FCR  External Audit 
Provide 2021/2022 general ledger
data to External Audit for the audit of
the financial accounts for the year
ended 31 March 2022.
Other tasks
All 2021/2022 Annual
Report 
Prepare annual statement of
assurance for 2021/2022.  Present to
RASC.
Governance
All Governance
Statement 
Undertake review of evidence that
supports SLC’s Annual Governance
Statement and provide 2021/2022
annual assurance statement for
Glasgow City Region – City Deal.
Governance
All
Attend internal and
external working
groups 
Attend, respond to requests,
participate in consultations and
provide updates.
Other tasks
All Committee
reporting 
Prepare reports to present to RASC
and to External Client Committees
and Boards.
Governance
FCR Fusion Support implementation of project. Internal
Controls
All 2023/2024 Audit
Plan 
Undertake consultation, risk
assessment, Resource and Section
planning, set scopes and objectives
and seek approval through
preparation of reports.
Other tasks
All National Fraud
Initiative (NFI)
Coordinate data uploads for new NFI
exercise in 2022/2023.  Develop and
communicate plan for investigation of
matches in 2023/2024. 
Internal
Controls
All Advice and
guidance  Provision of advice and guidance. Internal
Controls
All Informal Follow Up
Prompt Resources on a quarterly
and monthly basis of actions due
within that period.  Collate responses
for reporting.
Governance
All Follow Up
For all Council Resources, identify
audit recommendations due in the
period April 2021 to March 2022. 
Risk assess and follow-up to ensure
implementation of all high risk
actions.
Internal
Controls
CER /HTR  Follow Up
Undertake follow up of procurement
audits within Roads and Property
Services.
Internal
Controls
All Anti-fraud checks  
Rolling programme of anti-fraud
checks – including procurement,
petty cash, COVID-19 grants and
purchase cards.  Re-brief Conflict of
Interest policy and develop annual
process for briefing within
Resources.
Internal
Controls
18

Page 19

Review and update Fraud Policies
and present to Committee for
approval.
All
Continuous
Controls Monitoring
(CCM)
Continue to download data in current
CCM areas.  Use data for analysis
and to inform internal and external
audit testing.
Internal
Controls
EDR  Equity Strategy
Provide assurance of good
governance around spend and
tracking of benefits deriving from
spend.
Internal
Controls
EDR
Education
Maintenance
Allowance
Test systems and processes to
ensure compliance with all relevant
legislation and Scottish Government
requirements.
Internal
Controls
CER Sustainability
Provide assurance that plans are
practically deliverable in the short,
medium and long term and that in-
year progress with the achieving of
targets is monitored and reported.
Risk
Management 
SWR  Self-Directed
Support 
Assess compliance with assessment
and review timescales.  Review
evidence to ensure that this
demonstrates that the assessed
needs of users are being met.
Internal
Controls
FCR Community Wealth
Building Strategy
Test controls in place to mitigate the
risk to the Council of the Strategy not
being fully delivered.
Risk
Management
EDR Additional Support
Needs Transport 
Test effectiveness of new systems
and procedures and implementation
of agreed actions.
Internal
Controls
FCR Cyber Security
Assess the Council’s level of
resilience and ability to use
technology securely and to respond
and prevent cyber crime.
Internal
Controls
FCR Purchase Cards
Provision of advice and guidance
regarding key controls attached to
extending the use of Purchase Cards
across the Council. 
Internal
Controls
All Investigative
contingency  Undertake investigations as required. Internal
Controls
All General
contingency
Respond to requests for unplanned
work.
Internal
Controls
N/A Audit Plan Deliver internal audit service to
External Clients. N/A 
19

Page 20

20

Page 21

Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee
Date of Meeting: 27 September 2022
Report by: Executive Director (Finance and Corporate Resources) 
Subject: Internal Audit Activity as at 9 September 2022     
1. Purpose of Report
1.1. The purpose of the report is to:- 
 update the Risk and Audit Scrutiny Committee (RASC) on progress by, and
performance of, the Internal Audit service in the period 4 June to 9 September
2022 
 provide a summary of audit reports presented to Glasgow City Region City Deal
Cabinet (the Cabinet) during the same period
 advise of the planned external assessment of the Council’s internal audit
function’s level of compliance with the Public Sector Internal Audit Standards
(PSAIS) 
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendation(s):- 
(1) that progress and performance be noted;
(2) that findings from the audit reports presented to the Cabinet be noted; and
(3) that the planned external assessment of the Council’s internal audit service 
level of compliance with PSIAS be noted. 
3. Background 
3.1. Findings from internal audit assignments are reported to the Committee throughout
the year. The last progress report to the Committee was in June 2022 and reported
on work completed in the period 8 January to 3 June 2022. This report covers all
work completed in the period 4 June to 9 September 2022.  Performance information
is also included. 
4. Delivery of the Internal Audit Plan: Progress and Performance
4.1. In January 2022, the Committee approved the first phase of the Audit Plan for
2022/2023. An update on progress with the delivery of this Plan is set out in
Appendix 1. The proposed Audit Plan for the remainder of the year is set out in a
separate item on the agenda of today’s meeting.  As at 9 September 2022, 20% of
the first phase of the 2022/2023 Audit Plan was complete. 
4.2. Key performance indicators reflecting quality, on time and within budget as at 31 July
2022 are summarised in Appendix 2 together with explanations. 100% of draft
reports have been issued on time and 100% within budget against targets of 80%
respectively.  Quality continues to be monitored through internal quality control
procedures.
4
21

Page 22

4.3. Client contributions to the delivery of the Audit Plan take the form of responding to
draft reports, agreeing to closing meetings and signing reports quickly once agreed.
100% of audit assignments were concluded to a signed action plan, where this was
required, within 4 weeks of the issue of a draft report against a target set of 80%.     
4.4. Appendix 3 lists all assignments completed in the period 4 June to 9 September
2022 together with a summary of overall assurances from each area of work.   
4.5. Members are asked to note progress and performance. 
5. Glasgow City Region City Deal 
5.1. At the June 2022 Cabinet meeting of the Glasgow City Region City Deal, audit
reports were presented on; change control and contract management; equality
impact assessment and anti-bribery, corruption and fraud measures.  In addition, the
Internal Audit Annual Report and Draft Governance Statement for 2021/2022 was
presented to Cabinet.  A link to these reports can be found here. 
5.2. The first audit included South Lanarkshire’s Hamilton Community Growth Area in the
sample selected.  Audit work confirmed that a reasonable level of assurance could
be placed on the control environment. The audit did identify some scope for
improvement in the existing arrangements and an action plan set out three
recommendations across all sampled areas which management should address. 
Implementation of actions, relevant to South Lanarkshire Council, will be followed up
to ensure that these are delivered in full and on time. 
5.3. The second audit was in relation to equality impact assessments.  The report
presented concluded that there was assurance that the control environment around
such assessments was satisfactory. 
5.4.  The final audit was in relation to anti-bribery, corruption and fraud measures within
City Deal authorities which concluded that a reasonable level of assurance could be
placed on the control environment. The audit, again, identified some scope for
improvement in existing arrangements and an action plan set out two
recommendations which management should address across City Deal authorities.
Implementation of actions, relevant to South Lanarkshire Council, will be followed up
to ensure that these are delivered in full and on time. 
5.5.  In a similar manner to South Lanarkshire Council, an Annual Internal Audit Report is
presented to Cabinet following the end of each financial year that expresses an
overall audit opinion. The Annual Report included the following opinion by the Head
of Audit and Inspection, Glasgow City Council “based on the audit work undertaken
and the assurances provided by the member authorities, it is my opinion that
reasonable assurance can be placed upon the adequacy and effectiveness of the
governance and control environment which operated during 2021/0222”. 
5.6. As detailed above, actions, where relevant to South Lanarkshire Council, will be
logged and followed up.  Findings will be reported within activity reports to the
Committee. 
5.7. Members are asked to note audit findings and opinion for the year 2021/2022.
22

Page 23

6. Public Sector Internal Audit Standards – External Review
6.1. The internal audit service is delivered within South Lanarkshire Council (SLC) within
the context of the Public Sector Internal Audit Standards (PSIAS) (revised 1 April
2017), compliance with which is mandatory under Section 95 of the Local
Government (Scotland Act) 1973.  This sets out a series of standards to ensure a
professional, independent and objective internal audit service is delivered that
supports good governance within an organisation.     
6.2. Each year, a self-assessment exercise is undertaken to assess the ongoing level of
compliance with these Standards.  Once, every 5 years, this assessment is required
to be undertaken by an external assessor.  To deliver this requirement, a group of
Local Authorities undertake these assessments on a reciprocal, no-fee basis.  The
allocation of the reviews is undertaken by the Chief Internal Auditor’s Group and care
is taken the ensure that reviews rotate and are not undertaken by neighbouring
Authorities.  In 2017/2018, South Lanarkshire Council’s review was undertaken by
Stirling Council and the report on the assessment can be found here . 
6.3. The requirement for an external assessment next falls in 2022/2023 and East
Lothian Council will undertake this review.  Arrangements are being developed with
the intention to commence the review around October 2022 and for the report on the
outcome to be presented to the Committee in March 2023.  Periodic updates will be
provided in activity reports to the Committee in the interim. 
6.4. Members are asked to note the process for the external assessment of compliance
with PSIAS and that findings will be reported to RASC in March 2023. 
7. Progress against Strategy
7.1. The Public Sector Internal Audit Standards (PSIAS) require progress against the
audit strategy to be monitored and reported to the Committee as part of regular
monitoring reports that are presented at each meeting. 
7.2. Delivery of the strategy in 2022/2023 will be evidenced by the completion of the
Internal Audit Plan in-year and will be monitored through the performance indicators
regularly reported to the Committee. 
8. Employee Implications 
8.1. There are no employee issues. 
9. Financial Implications
9.1. A breakeven position for 2022/2023 is forecast at the end of the financial year for the
Internal Audit section.   
10. Climate Change, Sustainability and Environmental Implications 
10.1.  There are no implications for climate change, sustainability or the environment in
terms of the information contained in this report. 
11. Other Implications
11.1. The main risks to the delivery of the Audit Plan are, generally, vacancies and team
up-skilling requirements, unforeseen service demands and delays with client sign-off. 
These are mitigated by coaching and training, regular meetings and escalation
processes as well as inclusion of contingency time within the annual plan.  The risk
of significant, subsequent amendments to the Plan, arising from a change in the
Council’s priorities or risks, are reduced given the approach in 2022/2023 that has
allowed capacity and content to be reassessed mid-year.    
23

Page 24

12. Equality Impact Assessment and Consultation Arrangements
12.1 There is no requirement to equality assess the contents of this report. 
11.2. Heads of Service are consulted on each and every audit assignment. 
Paul Manning
Executive Director (Finance and Corporate Resources) 
9 September 2022 
Links to Council Values/Priorities/Outcomes
 Accountable, Effective, Efficient and Transparent 
Previous References
 Risk and Audit Scrutiny Committee - 2022/2023 Internal Audit Plan - 26 January 2022
 Risk and Audit Scrutiny Committee - Internal Audit Activity as at 3 June 2022 - 22 June
2022 
List of Background Papers
 Figtree extracts of Action Plans 
Contact for Further Information
If you would like to inspect the background papers or want further information, please
contact:- 
Yvonne Douglas, Audit and Compliance Manager
Ext:  2618
(Tel:  01698 452618)
E-mail:  yvonne.douglas@southlanarkshire.gov.uk
24

Page 25

2022/2023 Internal Audit Plan                Appendix 1 
Lead Resource Audit assignment Outline Scope Progress    
Key year end tasks
FCR External Audit 
Provide 2021/2022 general ledger data to
External Audit for the audit of the financial
accounts for the year ended 31 March 2022.
Complete
All 2021/2022 Annual
Report 
Prepare annual statement of assurance for
2021/2022.  Present to RASC. Complete
All Governance
Statement 
Undertake review of evidence that supports
SLC’s Annual Governance Statement and
provide 2021/2022 annual assurance statement
for Glasgow City Region – City Deal.
Complete
Corporate tasks
All
Attend internal and
external working
groups 
Attend, respond to requests, participate in
consultations and providing updates. Ongoing throughout year.
All Committee reporting  Prepare reports to present to RASC and to
External Client Committees and Boards. Ongoing throughout year.
FCR Fusion Support implementation of project. Ongoing throughout year.
All 2023/2024 Audit Plan 
Undertake consultation, risk assessment,
Resource and Section planning, set scopes and
objectives and seek approval through
preparation of reports.
Commenced Quarter 3.
All National Fraud
Initiative (NFI)
Coordinate data uploads for new NFI exercise in
2022/2023.  Develop and communicate plan for
investigation of matches in 2023/2024.
Commenced Quarter 3.
All Advice and guidance 
Provision of advice and guidance on online
banking for school funds and on the revision of
duplicate invoice checks.
Online banking – complete
Duplicate invoice checks – included
as part of Fusion.
25

Page 26

Lead Resource Audit assignment Outline Scope Progress
Core programme of audit work
All Informal Follow Up
Prompt Resources on a quarterly and monthly
basis of actions due within that period.  Collate
responses for reporting.
Ongoing throughout year.
All Follow Up
For all Council Resources, identify audit
recommendations due in the period April 2021
to March 2022.  Risk assess and follow-up to
ensure implementation of all high risk actions.
Ongoing throughout year.
CER/HTR/FCR Follow Up
Undertake follow up of procurements audits
within Roads and Property Services and debtors
review within Benefits and Revenue Services.
Some initial work undertaken but the
majority of audit testing commence
Q3.
All Anti-fraud checks  
Rolling programme of anti-fraud checks –
including procurement, petty cash and purchase
cards. 
Most significant anti-fraud work in
2022/2023 to date has been in
relation to COVID-19 grants.  Rolling
programme of anti-fraud checks
commence Q3
All Continuous Controls
Monitoring (CCM)
Continue to download data in current CCM
areas.  Use data for analysis and to inform
internal and external audit testing.
Ongoing throughout year.
EDR Optimisation software Review of optimisation software to establish
benefit of using within other Council Services.
Added to scope of Additional Support
Needs (ASN) audit.
FCR/CER Investigative
contingency 
Undertake investigations as required (including
COVID-19 grants). Ongoing throughout year.
All General contingency Conclude all 2021/2022 audits and responded to
requests for unplanned work 2022/2023. Ongoing throughout year.
All Resource audits  Deliver a programme of risk-based audits across
Council Resources.
Included in Audit Plan (see separate
item on Agenda).
26

Page 27

Lead Resource Audit assignment Outline Scope Progress
N/A Audit Plan Deliver internal audit service to External Clients Ongoing throughout year. 
27

Page 28

Key audit performance indicators as at 31 July 2022          Appendix 2 
Indicator Numbers Percentage Target Comment
Assignments
delivered within
budget
4/4 100% 80% 
Draft reports
delivered within 6
weeks of file
review 
3/3 100% 80% 
2022/2023 Audit
Plan completed
to draft by 31
March 2023
4/15 20% 100%
This relates to first phase of the 2022/2023 Audit Plan.  Many of the
assignments remain ongoing throughout the year or have a planned start
date of Quarter 3.
Internal Audit
recommendations
delivered on time
4/4 100% 90% 
Client to agree
findings and
actions within 4
weeks of draft
issue
3/3 100% 80% 
28

Page 29

Assignments completed 4 June to 9 September 2022   Appendix 3 
Job Number Assignment name
Draft
Issue
Final
Issue Assurance Info 
Previous Years
I710067 Ordering Process 13/06/2022 13/06/2022 Provision of advice and
guidance re process. 
Current Year 
I350100 Governance
Statement - City Deal
23/05/2022 27/05/2022 Provision of Statement
of Assurance for City
Deal 2021/2022.
I350099 Governance
Statement - Resource
Peer Reviews
31/05/2022 31/05/2022 Review of 2021/2022
Resource Directors’
Statements of
Assurance.  
I821035 2021/2022 Annual
Report
09/06/2022 22/06/2022 Provision of annual
statement of
assurance.
I222113 LEADER Grant
Closure
01/08/2022 08/08/2022 Provision of LEADER
audit certificate for the
period to closure. 
External Clients 
I924185 Lanarkshire Valuation
Joint Board (LVJB)
Follow Up 
06/06/2022 17/06/2022 Reported to LVJB.
I929188 LVJB New houses
process / recording
06/06/2022 17/06/2022 Reported to LVJB.
I929189 LVJB Conflict of
Interest
06/06/2022 17/06/2022 Reported to LVJB.
I914173 South Lanarkshire
Leisure and Culture
(SLLC) Follow Up 
07/09/2022 15/09/2022 Reported to SLLC.
I919174 SLLC Booking
System 
07/09/2022 15/09/2022 Reported to SLLC.
I919175 SLLC Data Protection 07/09/2022 15/09/2022 Reported to SLLC.
I913190 SLLC Governance
Plan
07/09/2022 15/09/2022 Reported to SLLC. 
29

Page 30

30

Page 31

Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee
Date of Meeting: 27 September 2022
Report by: Executive Director (Finance and Corporate Resources) 
Subject: Year End Insured Risks Report – 2021/2022 
1. Purpose of Report
1.1. The purpose of the report is to:-
[purpose}
 highlight trends on an annual basis, for insurance claims against the Council
[1purpose]
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendation(s):-
[recs]
(1) that the Insured Risks Report for year ended 31 March 2022 be noted; and
(2) that proposed work to mitigate insurance hotspots, as detailed in section 13,
be noted.
[1recs]
3. Background
3.1. The Council has in place insurance policies for combined liability, motor, property
and other miscellaneous risks. 
3.2. The combined liability policy covers both public liability (PL) and employer’s liability
(EL) claims. The PL section of the policy provides indemnity for the council’s legal
liability to pay claims for death, injury and disease to third parties, as well as third
party property damage, where the Council is found to be responsible for such losses. 
The EL section of the policy covers employee injury, disease, and death, where the
council is deemed to be negligent. The self-insured excess for this policy was
increased at renewal on 1 April 2022 from £0.250 million to £0.500 million to achieve
a premium saving. 
3.3. Motor insurance provides comprehensive cover for all council vehicles and injuries
resulting from motor incidents. The current self-insured excess for this policy is
£0.150 million. 
3.4. The property insurance policy covers damage/loss to council buildings and assets. 
The current self-insured excess for this policy is £0.100 million for all claims, other
than storm, flood and escape of water, where a £0.500 million excess applies. 
4. Overview and analysis of data
4.1. Claims which fall under the main policies are handled by the Council’s Risk
Management section and external claims handlers, Gallagher Bassett for combined
liability claims, and TopMark for motor claims.  The number and cost of these claims
form the basis of this report and includes comparisons with previous years. 
5
31

Page 32

4.2. Claims will continue to be intimated beyond the financial year end, with numbers
increasing by approximately ten per cent due to those incidents that have taken
place, but claims have not yet been reported to the Council.  Up to date annual
comparisons for the last 5 years are included at Appendix 1. The comparison shows
an overall downward trend in claims numbers from 2017/2018 to 2021/2022. Claims
costs have fluctuated over the last 5 years. On average, over that period, the self-
insured cost of claims per annum is £2.056 million, with 2021/2022 costs above
average at £2.242 million. 
4.3. In addition, to allow comparison of the position as at the year end for the last 2 years,
Appendix 2 compares the claim numbers and costs for incidents reported in
2020/2021 as at 31 March 2021 against incidents reported in 2021/2022, as at
31 March 2022. In effect, this compares the equivalent position and removes the
impact of late claims notification for both years. 
5. Insurance – total losses reported as at 31 March each year
5.1. Based on the comparisons in Appendix 2, the overall number of claims for all classes
received to date for incidents occurring during 2021/2022 is 822. This is an increase
of 54 claims (seven per cent) on the numbers reported last year for 2020/2021.  It
should, however, be noted that an extraordinary low number of claims were
intimated during 2020/2021, as a result of reduced council operations in the early
stages of the pandemic. 
5.2. The number of claims received for 2021/2022 is still substantially below the average
for the last 5 years (974). This reflects the reduction in council operations as
recovery was made from the pandemic.   
5.3. The total self-insured estimated cost of claims for 2021/2022 is £2.242 million.  At
the same time last year estimated claims costs for 2020/2021 was £2.010 million. 
This is an increase of £0.232 million (12 per cent), which is a result of the estimated
cost of property and motor claims increasing, with the position being offset slightly by
reduced estimated costs for combined liability claims.   
5.4. Based upon Appendix 2, sections 6 to 10 details some of the key findings from the
analysis of 2021/2022 claims. 
6. Combined liability claims
6.1. The combined liability policy covers for both public liability (PL) and employer’s
liability (EL) claims. The PL section of the policy provides indemnity for the council’s
legal liability to pay claims for death, injury and disease to third parties, as well as
third party property damage, where the Council is found to be responsible for such
losses.  The EL section of the policy covers employee injury, disease, and death,
where the council is deemed to be negligent. The following sections detail the
current position for 2021/2022 and makes comparisons against the position reported
for 2020/2021 as at 31 March 2021.   
6.2. 362 claims have been received for 2021/2022, with an estimated value of £0.821
million. 
6.3. The number of claims received for 2020/2021 was 388, and the estimated settlement
value of these claims was £1.094 million.  The 2021/2022 figures represent a seven
per cent decrease in claims numbers and a 25 per cent decrease in claims costs. 
32

Page 33

6.4. The main area where a decrease in claim numbers has been seen is in Community
and Enterprise Resources where 22 fewer claims have been received and Housing
and Technical Resources saw a reduction of 10 claims.  There has been an increase
of 11 claims for Education Resources related incidents, which is to be expected as
schools start to return to normal following lockdown. 
6.5. The most significant reduction in estimated claims costs is in Community and
Enterprise Resources, with a fall of £0.169 million. Housing and Technical
Resources has seen a reduction of £0.066 million and Social Work Resources a
reduction of £0.041 million in estimated claim costs. 
6.6. Education Resources have seen an increase in estimated costs of £0.011 million,
which reflects the increased claims intimated. 
6.7. It is anticipated that overall value of outstanding claims will reduce as further claims
are repudiated and closed off. 
7. Motor claims
7.1. The council’s motor insurance policy provides comprehensive cover for all council
vehicles and injuries resulting from motor incidents.  The following sections detail the
current position for 2021/2022 and makes comparisons against the position reported
for 2020/2021 as at 31 March 2022.   
7.2. 391 claims have been received for 2021/2022, with an estimated value of £0.591
million. 
7.3. At the same time last year, 303 motor claims had been received for incidents during
2020/2021, with an estimated settlement value of £0.525 million.  This equates to a
29 per cent increase in numbers and a 12 per cent increase in costs, this reflects a
return to normal service provision, following the pandemic. 
7.4. “At fault” incidents continue to be monitored. Table One compares the number and
cost of “at fault” incidents for the last five years. 
Table One – Comparison of “at fault” incidents 
7.5. The number of “at fault” incidents has worsened, with 62 more incidents during
2021/2022, when compared to the previous year. This increase is at least in part due
to driving operations returning to pre-pandemic levels. 
7.6. Despite an increase from the previous year, with 0.10 “at fault” incidents per vehicle
for 2021/2022, this is on a par with the average for the 4 previous years.  
Number
of
vehicles
on fleet
Number of
incidents
Cost of
incidents
Number of
Accidents
per
vehicle
Average
cost per
incident
2017/2018 1,697 183 £341,220 0.11 £1,865
2018/2019 1,556 180 £347,275 0.12 £1,929
2019/2020 1,588 145 £367,909 0.09 £2,537
2020/2021 1,808 127 £328,250 0.07 £2,585
2021/2022 1,834 189 £432,672 0.10 £2,289
33

Page 34

7.7. A Changing Driver Behaviour training programme for Managers has now been rolled
out via a Management Bulletin. A further course aimed at council drivers will be
developed once the content has been agreed.   
8. Property claims
8.1. The property insurance policy covers damage/loss to council buildings and assets. 
This section of the report details the current claim position for 2021/2022 and makes
comparisons against the status reported for 2020/2021 as at 31 March 2021.   
8.2. 69 claims have been received for 2021/2022, with an estimated value of £0.830
million. 
8.3. The overall number of claims intimated for 2021/2022 has reduced by 8 from the
previous year. This equates to a 10 per cent reduction. However, the value of
estimated claims intimated during 2021/2022 is £0.830 million compared to
estimated losses of £0.391 million for 2020/2021. Therefore, claim costs have more
than doubled. The reason for the increase value is twofold; a significant storm
damage loss was intimated during 2021/2021 and there has been an increase in the
estimated cost of house fires claims, despite the number of fires remaining broadly
the same. 
8.4. The main cause of property claims during 2020/2021 continues to be fires, with 31
claims reported with an estimated cost of £0.510 million.  The next most common
causes of claims were accidental damage, 13 claims reported with an estimate value
of £0.004 million, (mainly due to damaged laptops); water ingress/flooding, eight
claims reported with an estimated value of £0.020 million; and storm, 6 claims
reported with an estimated value of £0.190 million (this includes storm damage at
Lanark Lifestyles valued at £0.180 million) 
8.5. Overall the number of house fires resulting in insurance claims has increased by
one, from 30 incidents in 2020/2021 to 31 in 2021/2022.  Costs over this period have
increased by £0.283 million, from £0.228 million in 2020/2021 to £0.511 million in
2021/2022. 
9. Insurance hotspots
9.1. Following the completion of a claims leakage analysis report by insurers, the areas
of work noted below have been identified to mitigate insured losses. 
Property
 A property insurer survey programme to be agreed and implemented.
 Continued awareness raising and advice for tenants in respect of council house
fires, via the Housing News and social media. 
 Work to address functionality and reliability of CCTV systems across South
Lanarkshire. 
Motor
 Following the development and launch of a ‘Challenging Driver Behaviour’ learn
online course for managers this year, a review to undertaken on the uptake and
steps taken to ensure that all managers with responsibilities for driving at work
complete the course.
 Development and roll of the same ‘Challenging Driver Behaviour’ learn online
course for all drivers. 
34

Page 35

 Following the update and roll out of motor insurance procedures this year,
managers have been asked, through a more detailed post incident interview
process, to establish the root cause of motor accidents and identification of
support/corrective action, where required. Continued support and monitoring of
this process via the Drivers Safety Group.
 Continued factfinding investigations into accidents, as per guidance which
forms part of the Council’s driving at work procedures. 
Combined Liability 
 Health and Safety/training review to be undertaken by the Council’s claims
handlers, Gallagher Bassett.
 Roads and Transportation Services to trial technology associated with road
safety inspections and network condition surveys. 
9.2. Progress with implementation and effectiveness of actions will be reported back to
the Committee, via future insured risks reports. 
10. Employee Implications
10.1. Time and effort will continue to be required by Resource personnel to implement
initiatives to mitigate insurance hotspots. 
11. Financial Implications
11.1. Claims received to date, for incidents which occurred during 2021/2022 have an
estimated self-insured cost of £2.242 million.  It is reasonable to expect this value to
increase due to incidents that have taken place but claims have not yet been
received.   
11.2. There are currently no 2021/2022 claims that have estimated reserves which are
likely to breach the Council’s uninsured excess limits.  Therefore, based on claims
intimated to date for incidents which occurred during 2020/2021, it is forecast that
the current estimated cost of claims of £2.242 million will require to be met fully from
the council’s self-insurance fund. 
11.3. During 2021/2022, a total of £2.716 million was paid out by the Council on all claims,
irrespective of their incident date.  For claims which occurred between 1 April 2021
and 31 March 2021, £0.254 million was paid out by the Council.  These costs include
claims payments and other associated costs. 
11.4. The total cost of loss for 2021/2022 was £4.396 million.  This covers claims costs,
insurance premiums, and other costs for contracted insurance services. For
2020/2021 the total cost of loss was £3.888 million. 
11.5. The balance in the insurance fund is reducing year on year and will require to be
closely monitored to ensure adequate funds are available to meet known liabilities.
This will be particularly important, with the increased level of self-insured risk taken
on for combined liability claims this year (£500,000 uninsured excess). 
12. Climate Change, Sustainability and Environmental Implications 
12.1.  There are no implications for climate change, sustainability or the environment in
terms of the information contained in this report. 
35

Page 36

13. Other Implications
13.1. The cost of insurance claims and premiums is linked to the Council top risk
‘Reduction in external funding and fees/income received by the Council, as well as
increased financial pressures/demand for services; results in savings difficulties. 
13.2. Failure to adequately manage insurance hotspots is likely to lead to increased claims
numbers, self-insurance costs and insurance premiums.  This risk is mitigated
through the insurance hotspots review and associated action plans and other risk
management initiatives implemented by Resources. 
14. Equality Impact Assessment and Consultation Arrangements
14.1. There is no requirement to carry out an impact assessment in terms of the proposals
contained within this report. 
14.2. Consultation has taken place with Resource risk representatives. 
Paul Manning
Executive Director (Finance and Corporate Resources) 
13 September 2022 
Links to Council Values/Priorities/Outcomes
 Accountable, Effective, Efficient and Transparent 
Previous References
 Risk and Audit Scrutiny Committee – 2020/2021 Year End Insured Risks – 15
September 2021 
List of Background Papers
 None 
Contact for Further Information
If you would like to inspect the background papers or want further information, please
contact:-
Craig Fergusson, Head of Finance (Transactions)
Ext:  4951 (Tel: 01698 454951)
E-mail:  craig.fergusson@southlanarkshire.gov.uk
36

Page 37

Appendix 1 
Full year claims numbers and values by Resource as at 31 March 2022. 
All claim types     
Number of claims 2017/2018 2018/2019 2019/2020 2020/2021 2021/2022
Community and Enterprise 769 585 630 516 466
Education 35 40 32 23 22
Finance and Corporate 4 0 2 2 0
Housing and Technical 472 405 392 257 239
Social Work 70 81 67 84 95
Total 1,350 1,111 1,123 882 822
Reported at individual year
end 1,252 1,032 996 768        
Cost of claims 2017/2018 2018/2019 2019/2020 2020/2021 2021/2022
Community and Enterprise £1,209,090 £847,097 £803,951 £913,737 £1,153,874
Education £121,382 £133,731 £72,108 £112,101 £60,329
Finance and Corporate £5,298 £0 £50 £0 £0
Housing and Technical £628,664 £592,225 £1,098,494 £615,628 £944,938
Social Work £158,521 £339,100 £276,013 £110,770 £82,480
Total £2,122,954 £1,912,153 £2,250,617 £1,752,236 £2,241,620
Reported at individual year
end £1,962,638 £2,113,302 £1,946,633 £2,009,739  
* Reported to CMT at the respective year ends and excludes claims intimated beyond 31 March 
Combined Liability 
Number of claims 2017/2018 2018/2019 2019/2020 2020/2021 2021/2022
Community and Enterprise 487 323 396 304 232
Education 21 23 17 12 18
Finance and Corporate 3 0 1 2 0
Housing and Technical 249 226 226 162 110
Social Work 12 15 11 11 2
Total 772 587 651 491 362      
Cost of claims 2017/2018 2018/2019 2019/2020 2020/2021 2021/2022
Community and Enterprise £812,807 £522,914 £497,100 £487,021 £528,971
Education £105,365 £113,988 £68,400 £82,919 £55,027
Finance and Corporate £5,298 £0 £50 £0 £0
Housing and Technical £243,980 £140,465 £429,270 £266,743 £236,695
Social Work £83,151 £119,825 £244,685 £51,558 £545
Total £1,250,600 £897,192 £1,239,505 £888,241 £821,237      
37

Page 38

Motor     
Number of claims 2017/2018 2018/2019 2019/2020 2020/2021 2021/2022
Community and Enterprise 239 225 202 189 211
Education 5 6 6 1 2
Finance and Corporate 1 0 1 0 0
Housing and Technical 167 138 121 56 94
Social Work 56 65 54 63 84
Total 468 434 384 309 391      
Cost of claims 2017/2018 2018/2019 2019/2020 2020/2021 2021/2022
Community and Enterprise £358,940 £299,014 £270,646 £344,168 £413,196
Education £2,716 £7,364 £365 £1,163 £1,297
Finance and Corporate £0 £0 £0 £0 £0
Housing and Technical £164,201 £95,496 £189,901 £85,481 £101,838
Social Work £73,189 £216,214 £31,328 £58,152 £74,557
Total £599,046 £618,088 £492,240 £488,964 £590,888      
Property     
Number of claims 2017/2018 2018/2019 2019/2020 2020/2021 2021/2022
Community and Enterprise 43 37 32 23 23
Education 9 11 9 10 2
Finance and Corporate 0 0 0 0 0
Housing and Technical 56 41 45 39 35
Social Work 2 1 2 10 9
Total 110 90 88 82 69      
Cost of claims 2017/2018 2018/2019 2019/2020 2020/2021 2021/2022
Community and Enterprise £37,343 £25,169 £36,205 £82,548 £211,707
Education £13,301 £12,379 £3,343 £28,019 £4,005
Finance and Corporate £0 £0 £0 £0 £0
Housing and Technical £220,483 £356,264 £479,323 £263,404 £606,405
Social Work £2,181 £3,061 £0 £1,060 £7,378
Total £273,308 £396,873 £518,871 £375,031 £829,495   
38

Page 39

Appendix 2
Comparison of claims costs and numbers for claims occurring during the last 2 years as at
their respective year ends 
All claim types    
Number of claims 2020/2021 as at
31 March 2021
2021/2022 as at
31 March 2022
Difference Difference
Percentage
Community and Enterprise 461 466 5  1%
Education 17 22 5  29%
Finance and Corporate 1 0 -1  -100%
Housing and Technical 213 239 26  12%
Social Work 76 95 19  25%
Total 768 822 54  7%     
Cost of claims 2020/2021 as at
31 March 2021
2021/2022 as at
31 March 2022
Difference Difference
Percentage
Community and Enterprise £1,151,144 £1,153,874 £2,730 0%
Education £83,529 £60,329 -£23,201 -28%
Finance and Corporate £7,750 £0 -£7,750 -100%
Housing and Technical £647,504 £944,938 £297,433 46%
Social Work £119,812 £82,480 -£37,332 -31%
Total £2,009,739 £2,241,620 £231,881 12%     
Combined liability    
Number of claims 2020/2021 as at
31 March 2021
2021/2022 as at
31 March 2022
Difference Difference
Percentage
Community and Enterprise 254 232 -22  -9%
Education 7 18 11  157%
Finance and Corporate 1 0 -1  -100%
Housing and Technical 120 110 -10  -8%
Social Work 6 2 -4  -67%
Total 388 362 -26  -7%     
Cost of claims 2020/2021 as at
31 March 2021
2021/2022 as at
31 March 2022
Difference Difference
Percentage
Community and Enterprise £698,876 £528,971 -£169,905 -24%
Education £43,589 £55,027 £11,437 26%
Finance and Corporate £7,750 £0 -£7,750 -100%
Housing and Technical £302,250 £236,695 -£65,556 -22%
Social Work £41,228 £545 -£40,683 135%
Total £1,093,693 £821,237 -£272,455 -25%     
Motor    
Number of claims 2020/2021 as at
31 March 2021
2021/2022 as at
31 March 2022
Difference Difference
Percentage
Community and Enterprise 185 211 26  14%
Education 1 2 1  100%
Finance and Corporate 0 0 0  0%
Housing and Technical 54 94 40  74%
Social Work 63 84 21  33%
Total 303 391 88  29%     
39

Page 40

Cost of claims 2020/2021 as at
31 March 2021
2021/2022 as at
31 March 2022
Difference Difference
Percentage
Community and Enterprise £369,557 £413,196 £43,639 12%
Education £750 £1,297 £547 73%
Finance and Corporate £0 £0 £0 0%
Housing and Technical £80,481 £101,838 £21,357 27%
Social Work £74,704 £74,557 -£147 0%
Total £525,492 £590,888 £65,396 12%     
Property    
Number of claims 2020/2021 as at
31 March 2021
2021/2022 as at
31 March 2022
Difference Difference
Percentage
Community and Enterprise 22 23 1  5%
Education 9 2 -7  -78%
Finance and Corporate 0 0 0  0%
Housing and Technical 39 35 -4  -10%
Social Work 7 9 2  29%
Total 77 69 -8  -10%     
Cost of claims 2020/2021 as at
31 March 2021
2021/2022 as at
31 March 2022
Difference Difference
Percentage
Community and Enterprise £82,711 £211,707 £128,996 156%
Education £39,190 £4,005 -£35,185 -90%
Finance and Corporate £0 £0 £0 0%
Housing and Technical £264,773 £606,405 £341,632 129%
Social Work £3,880 £7,378 £3,498 0%
Total £390,554 £829,495 £438,941 112% 
40

Page 41

Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee  
Date of Meeting: 27 September 2022
Report by: Executive Director (Finance and Corporate Resources) 
Subject: Fraud Statistics Annual Report 2021/2022 
1. Purpose of Report
1.1. The purpose of the report is to:- 
 provide a summary of the fraud statistics for the year to 31 March 2022 and a
comparison to the same period in 2021 
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendation(s):- 
(1) that the contents of the report be noted. 
3. Background
3.1. Collating and reporting fraud statistics and setting targets for improvement are
considered best practice by the Chartered Institute of Public Finance and
Accountancy (CIPFA) and the Association of Local Authority Risk Managers
(ALARM).   
3.2. This report provides information on the number, types and outcomes of fraud
investigations within South Lanarkshire Council for the year to 31 March 2022
together with a comparison to the statistics for the same period in 2021.  It includes
all frauds reported to Internal Audit, benefit frauds during this period investigated by
the Department for Work and Pensions (DWP) and insurance losses resulting from a
failure in internal controls or which have been investigated by Internal Audit. 
3.3. Although the responsibility for housing benefit fraud investigations has transferred to
the DWP Fraud and Error Service (FES), South Lanarkshire Council retains
responsibility for the recovery of fraud overpayments from their own Housing Benefit
claimants.  Housing Benefit fraud data will, therefore, continue to be included within
the fraud statistics reported as information is provided by FES.     
3.4. Revenues and Benefits continue to deliver an annual programme of rolling reviews
on Housing Benefit claimants based on risk-profiling to establish the most likely
areas of benefit fraud or overpayment. Information is also obtained from HMRC
through Real Time Information (RTI) and DWP through the Housing Benefit
Matching Service (HBMS).  Where fraud is suspected, the case will be passed to
FES for investigation and, if proven, returned to South Lanarkshire Council to pursue
recovery.  Irrespective of whether a fraud is proven or not, the Council takes steps
immediately to recover any overpayment.   
6
41

Page 42

3.5. Progress with all types of fraud investigations during 2021/2022 has continued to be
impacted by the pandemic in terms of both the reporting of new cases and
concluding investigations. Despite these delays, the processes have not been
altered. All suspected, significant fraud cases continue to be investigated with
timescales extended for concluding work.  Steps are being taken to progress existing
cases to a conclusion and to re-establish reasonable timescales in 2022/2023.   
4. Results
4.1. All concerns reported to Internal Audit are risk assessed with high risk areas
investigated by Internal Audit, medium risks investigated by Resources and low risks
registered for monitoring of trends. Internal Audit may also undertake joint
investigations with Resources and the Fact-Finding team within Personnel Services
depending on the nature of the fraud and the operational knowledge required. 
4.2. Areas within the Council that have an inherently higher risk of fraud are considered
for inclusion in the annual Audit Plan.  There have been no specific patterns or
trends identified in 2021/2022 in addition to those already known. 
4.3. An analysis of the fraud caseload for the year to 31 March 2022 and the comparative
period in 2021 is detailed in Table 1. 
Table 1 - Fraud Caseload
Status
Year to  
31/03/22
Year to 
31/03/21 
Nos. £000 Nos. £000
Cases open as at 1 April  133 150 145 139
Concerns reported to 31 March   48 12 26 45
Caseload at 31 March    181 162 171 184
Cases closed in period (see Table 2) (33) (42) (38) (34)
Work in progress at 31 March    148 120 133 150 
4.4. Although cases reported in the year remain relatively low, a pattern of these coming
primarily from suspected benefit fraud and theft has started to emerge again. 
4.5. An analysis of closed cases in the year is detailed in Table 2:- 
Table 2 - Analysis of Closed Cases 
Source of fraud
Year to  
31/03/22
Year to 
31/03/21 
Nos. £000 Nos. £000
Founded allegation (see Table 3) 15 30 24 27
Insufficient information 3 0 5 3
Unfounded allegations 11 2 9 4
Time Delay 4 10 0 0
Total 33 42 38 34 
4.6. 45% of cases closed in the period were founded.  None of these cases involved a
South Lanarkshire Council employee.  In 2021/2022, some potential benefit fraud
cases were closed by FES, with no action taken, given the considerable time delay
in investigating as a result of the pandemic.   
4.7. An analysis of founded allegations is detailed in Table 3:-
42

Page 43

Table 3 – Analysis of Founded Allegations
Source of fraud
Year to  
31/03/22
Year to 
31/03/21 
Nos. £000 Nos. £000
External  14 11 23 27
Internal  0 0 1 0
Benefits 1 19 0 0
Total 15 30 24 27 
4.8. All of the founded cases relate to Benefit Fraud or fraud committed by a third party. 
4.9. Minimal costs have been incurred by Internal Audit in the year to 31 March 2022
aligning to the continuing re-direction of resources to deliver corporate tasks in the
year.  This requirement is now coming to an end and progress is being made with
concluding all current, open investigations by the end of Quarter 2 in 2022/2023.         
4.10. Time budgets and target completion timescales for investigations are set at the start
of each audit and will vary depending on the nature of the investigation.  These
timescales have been extended to reflect other Service priorities over the last 2
years but are now being re-established to reflect a return to normal service delivery.   
5. Improvements
5.1. On the conclusion of all internal investigations, an assessment is made on whether
any improvement actions are necessary.  If required, an improvement plan will be
issued containing recommended actions.  These improvement plans are agreed with
the relevant Heads of Service and the actions followed up by Internal Audit to ensure
implementation and that gaps in controls have been addressed. Outcomes for
concluded investigations are reported to the Risk and Audit Scrutiny Committee
(RASC) as part of Internal Audit’s annual assurance report. 
6. Employee Implications
6.1. South Lanarkshire Council has a zero tolerance approach to fraud.  All employees
have a role to play in reducing fraud within the Council and should understand the
risk of fraud faced by the Council, that fraud is serious and that it diverts resources
from the delivery of the Council’s primary objectives. A Learn on Line Fraud 
Awareness course is available to all employees with People Connect access.   
7. Financial Implications
7.1. The investigation of fraud, participation in National Fraud Initiative (NFI) exercise and
the collection and reporting of fraud statistics is carried out within existing resources. 
7.2. One Audit Assistant (with overview and management from an Audit Adviser) within
Internal Audit is responsible for co-ordinating the NFI exercise which included, for the
most recent Exercise, facilitating the issue and receipt of information requests from
other public bodies in relation to NFI cases, assisting with the recording of some or
all Creditor, Procurement, Grants and Single Person Discount investigations and
reporting on employee benefit fraud cases as required. A total of 66 days was
allocated in the 2021/2022 Internal Audit Plan to take account of the increased role
of Internal Audit in the current Exercise. 
7.3 In addition, 75 days were allocated in 2021/2022 to undertake fraud investigations
where required.  In practice, most of those time has been used to undertake anti-
fraud work on grants being disbursed by South Lanarkshire Council on behalf of the
Scottish Government.  Further time was allocated to conclude work within areas of
43

Page 44

emerging public sector fraud that had been identified by Audit Scotland in their report
of July 20201.  Testing in these areas in 2021/2022 included Overtime and Paypoint
with further output on testing on Purchase Cards; Invoice Authorisation and
Disclosure Checks planned in quarters one and two of 2022/2023. 
8. Climate Change, Sustainability and Environmental Implications
8.1. There are no implications for climate change, sustainability or the environment in
terms of the information contained in this report. 
9. Other Implications
9.1. Fraud risk is recognised as one of the top risks facing South Lanarkshire Council. 
This risk is significant as it can adversely affect the delivery of Council objectives and
erode valuable resources.  It is, therefore, important that the risk of fraud is soundly
managed.  Fraud Risk Registers are in place within all Resources and are reviewed
and updated in line with standard Risk Management procedures. 
9.2. In order to ensure the Council is fully aware of and prepared for emerging fraud
risks, Internal Audit periodically carry out self-assessment exercises against good
practice guidance in fraud management.  This exercise in 2020/2021 contributed to
the review of fraud policies. Work to promote the revised fraud policy has been
delayed sightly and will now be undertaken by Internal Audit in 2022/2023. 
9.3. The Council’s Serious and Organised Crime (SOC) working group have developed
an action plan to address the impact of COVID-19 on SOC and the challenges that
this has brought to the Council in the short, medium and long term.  The Group
progress delivery of the various actions, revising if any new or emerging threats are
identified through the pan Lanarkshire Multi Agency SOC Group.  Updates on
progress are presented to RASC on a periodic basis. 
9.4. The collection and reporting of fraud statistics assists in the management of fraud by
identifying patterns and trends of fraud and areas of high risk where preventative
controls should be concentrated. However, in order to do this effectively, fraud
statistics must be complete.  Internal Audit will continue to highlight areas where
practice could be improved to ensure that all instances of potential and actual fraud
are reported to Internal Audit.   
10. Equality Impact Assessment and Consultation Arrangements
10.1. There is no requirement to undertake an equality impact assessment. 
10.2. Consultation was not necessary for this report. 
Paul Manning
Executive Director Finance and Corporate Resources 
8 September 2022 
Link(s) to Council Values/Priorities/Outcomes
 Accountable, effective, efficient and transparent 
1 COVID 19 - Emerging Fraud Risks – Audit Scotland, July 2020
44

Page 45

Previous References
 Fraud Statistics 2020/2021 Annual Report, 15 September 2021
 Fraud Statistics Six Monthly Update, 26 January 2022 
List of Background Papers
 None   
Contact for Further Information
If you would like to inspect the background papers or want further information, please
contact:-
Yvonne Douglas, Audit and Compliance Manager
Ext:  2618  (Tel:  01698 452618)
E-mail:  yvonne.douglas@southlanarkshire.gov.uk
45

Page 46

46

Page 47

Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee  
Date of Meeting: 27 September 2022
Report by: Executive Director (Finance and Corporate Resources)    
Subject: 2020 National Fraud Initiative Exercise 
1. Purpose of Report
1.1. The purpose of the report is to:- 
 advise of the outcome of investigations that were completed in 2021/2022 as part
of the 2020 National Fraud Initiative (NFI) exercise 
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendations:- 
(1) that the results of the 2020 NFI Exercise be noted. 
3. Background
3.1. The NFI is a counter fraud exercise, which cross matches data from councils and other
public bodies. These bodies then investigate the matches. The Cabinet Office is
responsible for the delivery of the NFI exercise.  Audit Scotland co-ordinates the
exercise in Scotland. 
3.2. South Lanarkshire Council (SLC) has taken part in NFI exercises since 2004/2005. 
Until 2014, the NFI alternated annually between a limited exercise and a full exercise. 
The limited exercise compared electoral register to council tax to detect where single
person discount (SPD) was claimed despite there being more than one person over
18 in the household.  The full exercise involved Council wide comparisons including
benefits, payroll, creditors and blue badge holders. In addition to being matched to
other benefits and payroll data, records were also matched to DWP deceased persons’
records. 
3.3. The full exercise is undertaken every two years with an option to participate in the SPD
exercise annually.  SLC exercised this option and the 2020 exercise included both the
full data set and SPD matches. 
3.4. Internal Audit co-ordinates the delivery of the NFI exercise within the Council.
However, each Resource is responsible for investigating matches relevant to them. 
Internal Audit reports progress to the Council’s External Auditors throughout the year. 
4. 2020 NFI Exercise Results
4.1. There were 11 match areas covered in the current NFI exercise. These are listed in
Appendix 1. 
7
47

Page 48

4.2. In September 2021, the Risk and Audit Scrutiny Committee was advised that there
were 17,113 matches within the 2020 NFI exercise.  Following data refreshes, a
subsequent release of further matches and the inclusion of an additional area (Small
Business Bonus Scheme - SBBS), the final number of matches for the Council from
the exercise was 25,943 (see Appendix 2). 
4.3. From the list of matches, a target number of investigations is determined on a risk
basis and passed to Resources. There is no obligation to investigate every match but
the decision to restrict investigations must be risk based. The NFI Website provides
risk scoring against matches which allows Resources to prioritise high risk matches
for investigation. Internal Audit also liaised with External Audit to ensure the target
number included the high risk matches that they would expect to be investigated. 
4.4. It was originally intended that the Council would investigate 9,954 matches, however,
as additional matches were received, these targets were revisited, and a further risk
analysis undertaken.  This resulted in revised target matches of 9,446 which were
agreed with External Audit (see Appendix 3). 
4.5. Separate to the NFI data-matching exercise, Benefits and Revenue undertake a rolling
programme of external reviews through Datatank to confirm ongoing eligibility around
SPD. Reliance has previously been placed on the work of Datatank for the
investigation of SPD matches given that there was a significant cross-over with the
matches generated by the NFI exercise.  For the 2020 exercise, however, further
checking was undertaken to establish if the NFI exercise was capturing matches that
were not within Datatank reviews.  The outcome of this more detailed review suggests
that there may be some benefit in participating in the SPD exercise on an annual rather
than a biennial basis. 
4.6. As the Housing Benefit Fraud Section transferred to the DWP Fraud and Error Service
(FES), housing benefit fraud is no longer investigated by the Council.  Initial NFI
investigations are undertaken by the Council, if this indicates a potential fraud, the
case is passed to FES.  On conclusion of the FES investigation, all confirmed fraud
cases are recorded on the NFI website. 
4.7. A total of 184 recoverable fraud and errors have been detected through the current
NFI exercise to date, with an estimated amount to be recovered of £158,004 (176
errors and 8 frauds).  These were in relation to Housing Benefit (10 errors, £18,041);
Council Tax Reduction Scheme (23 errors, £6,382), Creditors (2 errors, £5,676),
Grants (1 fraud, £25,000), SBBS (4 errors and 7 frauds, £72,658) and SPD (137 errors,
£30,247).  A summary of outcomes is included at Appendix 3. 
4.8 Audit Scotland prepare a report on national NFI outcomes at the end of each full
exercise and a separate report will be presented to the Committee in due course.  In
addition to the actual financial outcomes above, this Audit Scotland report also
captures notional outcomes.  For SLC, there have been notional outcomes attached
to the non-timeous cancellation of blue badges held by deceased persons (calculated
at £575 per Blue Badge, £247,250 in total) and an additional £96,207.32 estimated as
being the notional value of errors, that were discovered by the NFI exercise, going
undetected for a further period of time. 
4.9. A comparison of the 2020 Exercise outcomes to that of the previous exercise in 2018
is included at Appendix 4. 
48

Page 49

5. Employee Implications
5.1. One Audit Assistant (with overview and management from an Audit Adviser) within
Internal Audit is responsible for co-ordinating the SLC exercise which includes
facilitating the issue and receipt of information requests from other public bodies in
relation to NFI cases, assisting with the recording of some or all Creditor, Procurement,
Grants and SPD investigations and reporting on employee benefit fraud cases if
required. A total of 66 days was allocated in the 2021/2022 Internal Audit Plan to take
account of the increased role of Internal Audit in the current exercise. 
5.2. In addition to the time allocated by Internal Audit, Resources were also required to
allocate time to the investigations. 
6. Financial Implications
6.1. Other than employee time, there is no cost associated with participating in the NFI
exercise. 
6.2. The NFI exercise is a valuable counter fraud exercise which has continued to identify
fraud and error within the Council.  As well as the financial return from participating in
the exercise, involvement continues to act as a deterrent to fraud. 
7. Climate Change, Sustainability and Environmental Implications
7.1. There are no implications for climate change, sustainability or the environment in terms
of the information contained in this report. 
8. Other Implications
8.1. Fraud Risk is recognised as one of the top risks facing SLC.  This risk is significant as
it can adversely affect the delivery of Council objectives and erode valuable resources. 
It is, therefore, important that the risk of fraud is soundly managed. 
8.2. When a fraud or overpayment occurs, steps will usually be taken to recover the loss.
Services are expected to examine why the loss occurred and demonstrate a change
in their processes and procedures accordingly. Internal Audit will routinely check if
these intended improvements have been implemented. 
9. Equality Impact Assessment and Consultation Arrangements
9.1. As the risks associated with the NFI are carried by the Cabinet Office and the Council
is bound by statute to participate, there is no need to undertake a separate equality
impact assessment. 
9.2. Employees and SLC residents are informed of the commencement of the NFI exercise
through a variety of sources.  There is no requirement to undertake any further
consultation in terms of the content of this report. 
Paul Manning
Executive Director (Finance and Corporate Resources) 
8 September 2022 
Link(s) to Council Values/Priorities/Outcomes
 Accountable, effective, efficient and transparent  
49

Page 50

Previous References
 2020 National Fraud Initiative Exercise , Risk and Audit Scrutiny Committee, 15
September 2021 
List of Background Papers
 None 
Contact for Further Information
If you would like to inspect the background papers or want further information, please
contact:- 
Yvonne Douglas, Audit and Compliance Manager
Ext:  2618 (Tel:  01698 452618)
E-mail:  yvonne.douglas@southlanarkshire.gov.uk 
50

Page 51

List of “matched” areas in the 2020/2021 NFI    Appendix 1 
Match area Match between Purpose of Match/Fraud risk
Housing
Benefits (HB) 
HB to Student Loans  To identify individuals claiming benefits, whose
student loan eligibility results in them being
ineligible for those benefits.
HB to HB (within SLC
and between other
authorities)
To identify an individual that is claiming housing
benefit from one or more local authority at the
same time.
HB to Rents(within
SLC and between
other authorities)
To identify possible tenancy fraud and/or
housing benefit fraud where an individual
appears to be resident at two different
addresses.
HB to taxi drivers
(within SLC and
between bodies) 
To identify where housing benefit claimants
have failed to declare income that may remove
entitlement to benefit or reduce benefit payable.
HB to CTRS To identify anyone claiming housing benefit and
council tax reduction from one or more local
authority at the same time.
HB to DWP Deceased To identify where a claimant has passed away
and who was in receipt of DWP benefits which
would not have stopped.
HB to Waiting List To identify where an individual appears to be
resident at two different addresses as the
address on the waiting list application is
different to the address on the benefit system.
Council Tax
Reduction
Scheme
(CTRS)
CTRS to Payroll
(within SLC and
between other bodies)
To identify where CTRS claimants have failed
to declare income that may remove entitlement
to benefit or reduce benefit payable. 
CTR to Right to Buy To identify individuals in receipt of council tax
reduction that are in the process of or have
completed the purchase of a property under the
Right to Buy (RTB) scheme, which may remove
the entitled to the reduction or reduce the
reduction amount.
CTRS to pensions  To identify where CTRS claimants have failed
to declare pension income that might remove
entitlement to benefit or reduce benefit payable.
CTRS to CTRS (within
SLC and between
other authorities)
To identify an individual claiming CTRS from
one or more local authority.
CTRS to HB (within
SLC and between
other authorities) 
To identify where an individual is in receipt of
council tax reduction and housing benefit from
one or more local authority simultaneously that
may remove or reduce entitlement to the
reduction.
CTRS to Housing
Tenants (within SLC
and between other
authorities)
To identify possible cases of tenancy fraud
and/or CTRS fraud where an individual appears
to be resident at two different addresses.
CTRS to taxi
drivers(within SLC and
between bodies)
To identify where CTRS claimants have failed
to declare income that may remove entitlement
to benefit or reduce benefit payable.
51

Page 52

CTR Scheme to DWP
deceased
To identify where a person has passed away
but may be in receipt of CTR after the date of
death
Payroll Payroll to payroll
(within SLC and
between bodies) 
To identify individuals who may be committing
employment fraud by failing to work their
contracted hours because they are employed
elsewhere or are taking long-term sickness
absence from one employer and working for
another employer at the same time. 
Payroll to Creditors To identify employees who are also creditors
where there may be a conflict of interests or
corruption.
Payroll to Pensions To identify employees who have gone back into
employment after drawing a pension that could
result in an abatement of pension. 
Housing
Tenants (HT)
HT (within SLC and
between bodies) 
To identify where an individual appears to be
resident at two different addresses suggesting
possible cases of subletting or dual tenancies.
HT to Right to Buy To identify possible causes of subletting or
individuals not entitled to a tenancy.
HT to HB To identify possible cases of tenancy fraud
and/or housing benefit fraud, where an
individual appears to be resident at two
different addresses.
HT to CTR Scheme To identify possible causes of tenancy fraud
and/or incorrect claims for CTR where an
individual appears to be resident at two
different addresses.
HT to State Benefits To identify possible cases of tenancy fraud
against the organisation i.e. where an individual
appears to be resident at two different
addresses.
HT to DWP Deceased To Identify where the tenant has died, but the
DWP has not been informed.
Housing Tenants to
Waiting Lists
To identify where an individual appears to be
resident at two different addresses as the
address on the waiting list application is
different to the address on the rents system.
Waiting Lists Housing Waiting Lists
to Housing Tenants
(within SLC and
between bodies)
To identify where an individual appears to have
registered on the waiting list using a different
address to the one on the housing rents system
suggesting possible undisclosed changes in
circumstances or that false information has
been provided.
Housing Waiting List
to Housing Waiting
List (within SLC and
between bodies)
To identify where an individual appears to have
registered on the waiting list using two different
addresses.
Housing Waiting Lists
to Housing Benefit
Claimants (within SLC
and between bodies)
To identify where an individual appears to have
registered on the waiting list using a different
address to the one on the housing benefit
system.
Waiting List to DWP
deceased
To identify an applicant who has died but is still
shown on the waiting list.
52

Page 53

Blue Badges Blue badge to blue
badge 
To identify individuals who hold more than one
Blue Badge.
Blue badge to DWP
deceased person
To identify cases where a permit holder has
died, but the local authority may not have been
notified. 
Procurement Procurement – payroll
to Companies House
(Director)
To identify potential undeclared interests that
have given a pecuniary advantage.
Creditors Duplicate creditors by
Duplicate creditor
payments and details
To identify instances where the same supplier
has been recorded against more than one
reference number on the system thus
increasing the potential for creditors to obscure
fraudulent activity.
To identify possible duplicate payments.
VAT overpaid
Council Tax to
Electoral register
This test identifies instances where VAT may
have been overpaid. 
To identify where Single Persons Discount is
being claimed and there is more than one
person aged 18 or over registered within the
property on the Electoral Register.
Council Tax
Single Person
Discount
Single Person
discount award to
other government
bodies
To identify individuals who have declared they
are living alone but have not declared they are
living with a partner or non- dependant in the
household. 
Council Tax Rising
18s
To identify where the householder is claiming a
Council Tax SPD on the basis that they are the
only occupant over 18 years of age yet the
electoral register suggests that there is
somebody else in the household who is
already, or is approaching, 18 years of age,
which may have already, or be about to, make
the SPD invalid.
SBBS Business Rates to
Business Rates, same
bank account,
company name (within
SLC and between
bodies)
To identify those claiming multiple Small
Business Bonus Scheme grants, those
fraudulently in receipt of SBBS.
Small
Business
Grant Fund
(SBGF) and
Retail,
Hospitality and
Leisure Grant
Fund (RHLG)
SBGF duplicates
(within SLC and
between bodies)
To identify those claiming multiple Small
Business Grant Fund grants or those
fraudulently in receipt of SBRR.
RHLG duplicates
(within authorities)
To identify those claiming multiple Retail,
Hospitality and Leisure Grants within authorities
SBGF and RHLG
duplicates (within SLC
and between bodies)
To identify those claiming both Small Business
Grant Funding and Retail, Hospitality and
Leisure Grants which are mutually exclusive
within and between authorities.
SBGF duplication of
75% or 100%
To identify those claiming Small Business Grant
Funding from multiple Councils for the full
£10,000 or £25,000 grants rather than 100% for
first premises and 75% for others.
RHLG where total
property rateable
value >£500,000
To identify those claiming for grants whilst
having a cumulative total property rateable
value over the limit. 
53

Page 54

Comparison of matches previously reported       Appendix 2 
Area/Matches Matches Reported
to RASC June
2021
Additional
Matches
Final
Number of 
Matches
Housing Benefits 172 0 172
CTRS 2,005 0 2,005
Payroll 134 0 134
Housing Tenants 685 0 685
Waiting List 1,229 0 1,229
Blue Badge 1,114 0 1,114
Creditors 4,981 0 4,981
Procurement 259 0 259
Single Person Discount 6,496 8,630 15,126
Grants (SBGF and RHLG) 38 29 67
SBBS 0 171 171
Overall matches 17,113 8,830 25,943 
54

Page 55

Target Investigations and Outcomes             Appendix 3 
Area Total Original
Target 
Revised Target  Cleared Fraud and Errors Value 
£
Housing Benefits 172 142 126 126 10 18,041
CTRS 2,005 1,715 368 368 23 6,382
Payroll 134 115 38 38 - -
Housing Tenants 685 646 652 652 - -
Waiting List 1,229 1,117 586 586 - -
Blue Badge 1,114 859 926 926 - -
Residents Parking Permit  254 254 - - - -
Creditor 4,981 4,981 401 401 2 5,676
Procurement 259 87 259 259 - -
Single Persons Discount 15,126 - 5,852 5,852 137 30,247
Grants (SBGF and RHLG) 67 38 67 67 1 25,000
SBBS 171 - 171 171 11 72,658
Total 25,943 9,954 9,446 9,446 184 158,004 
55

Page 56

Comparison of outcomes to last NFI Exercise     Appendix 4 
Area Value (2020)
£
Value (2018)
£
Housing Benefits 18,041 22,064
CTRS 6,382 6,268
Creditors 5,676 1,430
Private Care Home Residents - 84
Single Persons Discount 30,247 -
Grants (SBGF and RHLG) 25,000 -
SBBS 72,658 -
Total 158,004 29,846 
Blue Badges (notional loss) 247,250 83,375 
56

Page 57

Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee
Date of Meeting: 27 September 2022 
Report by: Executive Director (Finance and Corporate Resources) 
Subject: Forward Programme for Future Meetings 
1. Purpose of Report
1.1. The purpose of the report is to:-
[purpose]
 advise members of the forward programme for the meetings of the Risk and Audit
Scrutiny Committee to 7 March 2023
 invite members to suggest topics for inclusion in the Committee’s forward
programme
[1purpose]
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendation(s):-
[recs]
(1) that the report and the outline forward programme for the meetings of the Risk
and Audit Scrutiny Committee to 7 March 2023, attached as an Appendix to
the report, be noted.
[1recs]
3. Background
3.1 As part of a range of improvement measures introduced as a result of Audit
Scotland’s report on the Audit of Best Value and Community Planning (2009), an
Action Plan was prepared.  One of the actions was to include, as a standard agenda
item, a list of items proposed for consideration at subsequent meetings of this
Committee to provide an opportunity for members to inform future agendas.  The
outline forward programme to 7 March 2023 is attached, for members’ information,
as an Appendix to the report.  
4. Employee Implications
4.1. There are no employee implications. 
5. Financial Implications
5.1. There are no financial implications. 
6. Climate Change, Sustainability and Environmental Implications
6.1. There are no Climate Change, Sustainability or Environmental implications in terms
of the information contained within this report. 
7. Other Implications 
7.1. There are no risk implications in terms of the information contained within this report.  
8
57

Page 58

8. Equality Impact Assessment and Consultation Arrangements
8.1. The report does not introduce a new policy, function or strategy or recommend a
change to an existing policy, function or strategy and, therefore, no impact
assessment is required. 
8.2. There was no requirement to undertake any consultation in terms of the information
contained in this report. 
Paul Manning
Executive Director (Finance and Corporate Resources) 
13 September 2022 
Link(s) to Council Values/Priorities/Outcomes
 Accountable, Effective, Efficient and Transparent 
Previous References
 Executive Committee 8 July 2009 
List of Background Papers
 Audit Scotland Audit of Best Value and Community Planning 
Contact for Further Information
If you would like to inspect the background papers or want further information, please
contact:-
Elizabeth-Anne McGonigle, Administration Officer
Tel:  0738 5403101
E-mail:-  elizabeth-anne.mcgonigle@southlanarkshire.gov.uk 
58

Page 59

APPENDIX – RASC OUTLINE FORWARD PROGRAMME TO 7 MARCH 2023 
Meeting Date Item Responsibility
25 October 2022 External Auditor’s Annual Report
to South Lanarkshire Council 2021/
2022 
External Audit 
Audited Annual Accounts 2021/2022 Head of Finance (Strategy) 
Internal Audit Activity Report  Audit and Compliance
Manager 
Year End Risk Management Report
2021/2022 and Review of Council’s
Top Risks 2022/2023 
Head of Finance
(Transactions) 
The National Fraud Initiative in
Scotland 2020/2021 
Audit and Compliance
Manager
6 December 2022 Good Governance Update  Head of Administration and
Legal Services 
Internal Audit Activity Report  Audit and Compliance
Manager 
Performance and Review Scrutiny
Forum Annual Update 
Head of Corporate
Communications
7 March 2023 Public Sector Internal Audit
Standards (PSIAS) – External
Assessment 
Audit and Compliance
Manager 
Internal Audit Activity Report  Audit and Compliance
Manager 
Fraud Statistics Six Monthly
Update
Audit and Compliance
Manager 
Internal Audit Plan 2023/2024 Audit and Compliance
Manager 
N.B:-. Audit Scotland national studies and reviews will appear as a recurring item but the
frequency and subject matter will vary according to their programme. 
59

Page 60

60