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Agenda Document Pack - Audit, Performance and Risk Committee - 30/03/2023

Moray Council · 30 March 2023
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Audit, Performance and Risk Committee 
Thursday, 30 March 2023 
Council Chambers 
NOTICE IS HEREBY GIVEN that a Meeting of the Audit, Performance and Risk
Committee, Council Chambers, Council Office, High Street, Elgin, IV30 1BX on
Thursday, 30 March 2023 at 14:00 to consider the business noted below. 
AGENDA 
1. Sederunt 
2. Declaration of Member's Interests 
3. Minutes 
3a. Minutes of Meeting of 24 November 2022 5 - 6
3b. Minutes of Special Meeting of 26 January 2023 7 - 8
4. Action Log of Meeting of 24 November 2022 9 - 10
5. Quarter 3 Performance Report 11 - 48
6. Internal Audit Plan Report 49 - 52
7. Strategic Risk Register 53 - 82
8. External Audit Plan for the Year Ending 2022-23 83 - 146
9. Internal Audit Section Completed Projects Report 147 - 166
10 Civil Contingencies -  Resilience Standards Progress 167 - 176
11. External Review of Commissioned Services Update
Report
177 - 212
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MORAY INTEGRATION JOINT BOARD 
SEDERUNT 
Councillor Scott Lawrence  (Chair)  
Mr Derick Murray  (Voting Member)
Mr Sandy Riddell  (Voting Member)
Councillor John Divers  (Voting Member)
Mr Sean Coady  (Member)
Mr Graham Hilditch  (Member)
Mr Simon Bokor-Ingram  (Member)
Ms Sonya Duncan  (Member)
Ms Deborah O'Shea  (Member)  
Mr Stuart Falconer  (Non-Voting Member) 
Clerk Name: Tracey Sutherland
Clerk Telephone: 07971 879268
Clerk Email: committee.services@moray.gov.uk 
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MINUTE OF MEETING OF THE AUDIT, PERFORMANCE AND RISK COMMITTEE 
Thursday, 24 November 2022 
Council Chambers, Council Office, High Street, Elgin, IV30 1BX 
PRESENT 
Mr Simon Bokor-Ingram, Mr Sean Coady, Councillor John Divers, Ms Sonya
Duncan, Mr Stuart Falconer, Mr Graham Hilditch, Councillor Scott Lawrence, Mr
Derick Murray, Ms Deborah O'Shea, Mr Sandy Riddell 
APOLOGIES 
Mr Neil Strachan 
IN ATTENDANCE 
Also in attendance at the above meeting were the Chief Internal Auditor and
Tracey Sutherland, Committee Services Officer.   
1.         Declaration of Member's Interests 
Mr Riddell declared that he is Chair of the Mental Welfare Commission.  There were
no other declarations of Members' interests in respect of any items on the agenda.   
2.         Minutes of meeting of 25 August 2022 
The minute of the meeting of 25 August 2022 were submitted and approved.  
3.         Action Log of Meeting of 25 August 2022 
The Action Log of the meeting of 25 August 2022 was considered and updated
accordingly.  
4.         Quarter 2 Performance Report 
A report by the Corporate Manager updated the Audit, Performance and Risk
Committee on performance as at Quarter 2 (July to September 2022).  
Item 3a.
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Following consideration the Committee agreed to note the performance of local
indicators for Quarter 2 (July - September 2022).  
5.         Internal Audit Section - Update Report 
A report by the Chief Internal Auditor provided the Committee with an Internal Audit
update.  
Following consideration the Committee agreed to note the audit update.  
6.         Strategic Risk Register Report 
A report by the Chief Officer provided  an overview of the current strategic risks,
along with a summary of actions which are in place to mitigate those risks, updated
on November 2022.  
Following consideration the Committee agreed to:  
i) note the updated Strategic Risk Register included as Appendix 1; and    
ii) note the Strategic Risk Register will be further refined to align with the
transformation and re-design plans as they evolve.    
7.         Internal Audit Section Completed Projects Report 
A report by the Chief Internal Auditor provided an update for the Committee on audit
work completed since the last meeting of the Committee.  
Following consideration the Committee agreed to note the audit update.  
8.         Directions Monitoring Report 
The Interim Chief Financial Officer joined the meeting for the consideration of this
item.  
A report by the interim Chief Financial Officer informed the Committee of the issued
Directions of the Moray Integration Joint Board for the period 1 April to 30 September
2022.  
Following consideration the Committee agreed to note the Directions issued in the
first six months of 2022/23.   
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MINUTE OF MEETING OF THE AUDIT, PERFORMANCE AND RISK COMMITTEE 
Thursday, 26 January 2023 
Council Chambers, Council Office, High Street, Elgin, IV30 1BX 
PRESENT 
Mr Simon Bokor-Ingram, Councillor John Divers, Ms Sonya Duncan, Mr Stuart
Falconer, Mr Graham Hilditch, Councillor Scott Lawrence, Mr Derick Murray, Ms
Deborah O'Shea, Mr Sandy Riddell 
APOLOGIES 
Mr Sean Coady 
IN ATTENDANCE 
Also in attendance at the above meeting were Brian Howarth, Audit Scotland and
Tracey Sutherland, Committee Services Officer.   
1.         Chair 
The meeting was chaired by Councillor Scott Lawrence.  
2.         Declaration of Member's Interests 
There were no declarations of Members' interests in respect of any items on the
agenda.  
3.         External Auditors Report to Those Charged with Governance Report 
A report by the Interim Chief Financial Officer requested the Committee to consider
the reports to those charged with governance from the Board's External Auditor for
the year ended 31 March 2022.  
The External Auditor advised the Committee that amendments had been made to
Note 3 - Events after the Reporting Period and it now read:
The unaudited accounts were issued by Deborah O’Shea, Interim Chief Financial
Officer on 30 June 2022 and the audited accounts were authorised for issue on 26
Item 3b.
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January 2023.  Events taking place after this date are not reflected in the financial
statements or notes.   
The Scottish Government on the 16 January 2023 advised the IJBs of the intention to
request that unspent monies in the earmarked Covid reserves are to be returned as
they were for  specific purposes and are not to be used to fund day to day
expenditure. The amount for Moray IJB is £6.2 million.  The accounts have not been
adjusted for this amount, as the technical advice provided by CIPFA confirms that this
is not an adjusting event but a disclosure in the 2021/22 accounts.   
In December 2022 the IJB was notified of costs relating to two out of area
placements. Following receipt of the Scottish Government decision on ordinary
residence for the first placement, the IJB is due to pay £0.7 million covering the
period from October 2018 to 31 March 2022.  The surplus on provision of services
and reserves are overstated by this amount but the annual accounts have not been
adjusted as this amount is not considered material. The IJB has not accepted
responsibility for the second placement and this is considered to be a contingent
liability until the individual’s ordinary residence is agreed or determined by the
Scottish Government.  
Following consideration the Committee noted the reports from the External Auditor
within Appendices 1 and 2.  
4.         Audited Annual Accounts 2021-22 
A report by the Interim Chief Financial Officer submitted the Audited Annual Accounts
for the year ended 31 March 2022.  
Following consideration the Committee agreed to recommend to the Moray
Integration Joint Board the Audited Accounts for the financial year 2021/22.   
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MEETING OF MORAY INTEGRATION JOINT BOARD 
AUDIT, PERFORMANCE AND RISK COMMITTEE 
THURSDAY 24 NOVEMBER 2022 
ACTION LOG 
Item
No.
Title of Report Action Required Due Date Action By Update for 
30 March 2023
1.  Action Log of
Meeting dated 27
August 2020
Payment Verification Assurance Update –
once through appropriate NHSG Governance
route. 
June 2022 Sean Coady Payment verification
has resumed for
dentistry, optometry
and pharmacy. 
Payment verification
for general medical
services is expected
to recommence in
2023. 
As the reports are
received they will be
presented to
Committee 
2.  Civil
Contingencies
Annual Assurance Report from HSCM Civil
Contingencies Group
March 2023 Corporate
Manager
On today’s agenda
Item 4.
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Item
No.
Title of Report Action Required Due Date Action By Update for 
30 March 2023
Resilience
Standards Report
3.  External Review
of Commissioned
Services
External Review to be commissioned. August 2022 Chief Officer On today’s agenda
4.  Quarter 1
Performance
Update report from the Psychological Service
to be presented following email sent in July
March 2023 Corporate
Manager
Scheduled – included
as part of
Performance report 
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REPORT TO: MORAY INTEGRATION JOINT BOARD AUDIT, PERFORMANCE
AND RISK COMMITTEE ON 30 MARCH 2023 
SUBJECT: QUARTER 3 (OCTOBER TO DECEMBER 2022) PERFORMANCE
REPORT 
BY:  CORPORATE MANAGER 
1. REASON FOR REPORT 
1.1 To update the Audit, Performance and Risk (APR) Committee on performance
as at Quarter 3 (October to December 2022). 
2. RECOMMENDATION 
2.1 It is recommended that Committee consider and note: 
i) the performance of local indicators for Quarter 3 (October -
December 2022) as presented in the Performance Report at
APPENDIX 1; and 
ii) the analysis of the local indicators that have been highlighted and
actions being undertaken to address performance that is outside
of acceptable target ranges as detailed in APPENDIX 1; 
3. BACKGROUND 
3.1   The purpose of this report is to ensure the Moray Integration Joint Board
(MIJB) fulfils its ongoing responsibility to ensure effective monitoring and
reporting on the delivery of services and on the programme of work as set out
in its Strategic Plan. 
3.2   APPENDIX 1 identifies local indicators for the MIJB and the functions
delegated by NHS Grampian and Moray Council, to allow wider scrutiny by
the Board. 
4. KEY MATTERS RELEVANT TO RECOMMENDATION 
4.1 Local Indicators are assessed on their performance via a common
performance monitoring Red, Amber, and Green (RAG) traffic light rating
system. 
Item 5.
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RAG scoring based on the following criteria:
GREEN If Moray is performing better than target.
AMBER If Moray is performing worse than target but within agreed
tolerance.
RED If Moray is performing worse than target by more than agreed
tolerance. 
4.2 The detailed performance report for quarter 1 is attached in APPENDIX 1.   
Summary
4.3 Performance within Health and Social Care Moray (HSCM) as demonstrated
by the agreed indicators up to the end of quarter 3 of the financial year
2022/23 is showing as variable. Four of the indicators are presenting as
green, one is amber and six are red. This represents a similar performance
compared to quarters 1 and 2 of 2022/23. This is a reflection of the continued
pressure being placed on the service. 
4.4 Figure 1 provides a summary and the historical trend by indicator since
quarter 3 of year 2021/2022. A summary of performance for each of the 6
reporting categories is provided below. One area is presenting as green, while
two are amber and the other three are red. 
EMERGENCY DEPARTMENT - AMBER
4.5 There was a decrease in the attendance rate per 1,000 this quarter from 24 to
22.6, just above the target of 21.7. The trend over the past 5 months has been
generally downwards, but above the target. However, the longer-term trend
over 2 and ½ years is a gradual increase in the attendance rate This increase
in demand will not only put pressure on ED but will undoubtedly have an
impact on other services. 
DELAYED DISCHARGES – RED   
4.6 The number of delays at the December census snapshot was 29, down
considerably from 47 at the end of quarter 2 but remaining well above the
revised target of 10. Although the number of bed days lost due to delayed
discharges reduced from 1,197 last quarter to 1,063 this is still over 3 times
the target. 
EMERGENCY ADMISSIONS – AMBER  
4.7 The steady monthly increase in the rate of emergency occupied bed days for
over 65s, noted in previous reports, continued this quarter. Since the end of
quarter 2 the rate has increased from 2,469 to 2,547, exceeding the target of
2,107 per 1,000 population. The emergency admission rate per 1000
population for over 65s has increased slightly this quarter from 172.4 to 173.3. 
While the long-term trend for the number of people over 65 admitted to
hospital in an emergency in the previous 12 months reduced from 118.6 to
117.4 over the same period. Both indicators are now GREEN but given the
continuing increase in the emergency occupied bed-days for over 65s the
overall status for the three indicators combined is AMBER. 
HOSPITAL RE-ADMISSIONS - GREEN
4.8 The 28-day re-admissions remain on target at 8.0%, as do the 7-day re-
admissions 3.8%.
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MENTAL HEALTH – RED  
4.9 The service has been unable to meet the 18 week LDP1 target since
September 2021.  This has declined steadily and in the first quarter of 2022
the % of people who were referred into the service and treated within 18
weeks had fallen to 27%, but in quarter 3 there have been signs of a recovery
at and the proportion of people being treated within 18 weeks is 79%. 
STAFF MANAGEMENT – RED   
4.10 NHS employed staff sickness levels (to the end of November 2022) have
increased from 5.0% to 5.5%, while Council employed staff sickness was
8.3% last quarter, more than double the 4% target. 
Figure 1 - Performance Summary – Date to Nov 2022           
5. AREAS NOT MEETING TARGETS 
Emergency Department
5.1 The rate per 1,000 population presenting at ED is 22.6, closer to the required
performance level of 21.7. However, the proportion of patients seen within the
4-hour target time continued to reduce during 2021 and 2022 (Figure 2). Prior
to March 2020 over 95% of attendees at ED were seen within 4 hours,
generally reducing to 90% in the winter months. Since May 2021 this rate has 
1 Local Delivery Plan Standards; priorities set and agreed between the Scottish Government and NHS
Boards. Previously known as HEAT Targets and Standards. 
Q3 2122 Q4 2122 Q1 2223 Q2 2223 Q3 2223 New Target Previous Target
Oct-Dec Jan-Mar Apr-Jun Jul-Sep Oct-Dec (from Q1 2122) (from Q1 2021 or earlier)
AE Accident and Emergency
AE-01 A&E Attendance rate per 1000 population (All Ages) 20.0 20.0 24.3 24.0 22.6 no change 21.7 A
DD Delayed Discharges
DD-01* Number of delayed discharges (including code 9) at census point 39 46 46 47 29 no change 10 R
DD-02
Number of bed days occupied by delayed discharges (including code 9) at census
point 1142 1294 1207 1197 1063 no change 304 R
EA Emergency Admissions
EA-01 Rate of emergency occupied bed days for over 65s per 1000 population 2045 2140 2320 2469 2547 2037 2107 R
EA-02 Emergency admission rate per 1000 population for over 65s 187.2 183 177.5 172.4 173.3 179.9 179.8 G‚
EA-03
Number of people over 65 years admitted as an emergency in the previous 12
months per 1000 population 126.3 125.2 122 118.6 117.4 123.4 124.6 G‚
HR Hospital Readmissions
HR-01 % Emergency readmissions to hospital within 7 days of discharge 3.5% 3.4% 4.3% 3.0% 3.8% no change 4.2% G‚
HR-02 % Emergency readmissions to hospital within 28 days of discharge 8.4% 8.0% 8.3% 6.7% 8.0% no change 8.4% G‚
MH Mental Health
MH-01
% of patients commencing Psychological Therapy Treatment within 18 weeks of
referral 67% 33% 27% 33% 79.0% no change 90% R
SM Staff Management
SM-01 NHS Sickness Absence (% of hours lost) 5.5% 4.7% 4.2% 5.0% 5.5% no change 4% R Data to Nov 22
SM-02 Moray Council Sickness Absence (% of days lost) 8.1% 8.9% 8.8% 5.2% 8.3% no change 4% R                                                             
Health and Social Care Moray Performance Report                                          
Code Barometer (Indicator) RAG
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dropped and at the end of quarter 3 was 64.7%. Performance is below target,
but in January there was a 10% improvement to 74.8%, which may indicate
improved performance for 2023. 
Figure 2 – Percentage of patients seen within 4 hours (all ages) – (PHS data) 
5.2 Following the launch of the Medical Ambulatory Emergency Care (AEC)
service at Dr Gray's hospital on 09 January 2023, we have seen an
improvement in ED performance. These figures are in correlation with a 10%
fall in specialty admissions to hospital (surgical and medical) from ED,
compared to December 2022. 
Delayed Discharge
5.3 The number of people who are clinically safe waiting to be discharged from
hospital remains high, and there are no indications that the target of 10 people
is going to be met soon. The Delayed Discharge indicators (DD-01 and DD-
02) continue to be red and remain 3 times higher than the new targets set at
the end of quarter 3 of 2020/21. For the past 11 months the average number
of people waiting to be discharged each week has fluctuated around 40,
although at the end of the last week of 2022 this had reduced to 21. At the
start of 2023 numbers rose back to 41, but have since slowly reduced week-
by-week. The most recent data recorded 35 people waiting in hospital. 
5.4 There are various pressures on the system that are preventing medically fit
people from being able to leave hospital, most of which have been reported
extensively in previous reports. The number of staff available to work has
been an issue throughout the pandemic and continues to be an issue and is
discussed in more detail below. Council staff absences due to sickness have
fluctuated between 6-8%, while the NHS staff absences during quarters 1 and
2 this year returned closer to 4%. However, NHS absences are increasing
once more and ended the year at 5.5%. 
5.5 High numbers of people facing delays in leaving hospital indicate problems
elsewhere in the system. Apart from the few cases where power of attorney,
or other legal matters, require time to be resolved, the majority of the delays
are either due to a suitable package of care not being available, or lack of
beds in a residential home. Figure 3 shows the number of care homes that
have been available each week since January 2022 (those in the ‘Red’
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category have not been able to admit new residents). Apart from the
occasional week there has typically been at least one care home unable to
accept new residents. 
Figure 3: Moray Care Home RAG Status (Number at Red, Amber or Green) 
5.6 There are few empty beds in residential homes in Moray (Figure 4). At the
start of November 2022 bed occupancy was 99.3%, with just 3 beds available
(this figure excludes the 6 interim beds that Health and Social Care Moray pay
for in addition, to support short-term needs). Consequently, between care
homes not being able to take in new residents and a shortage of care home
beds, which might not always be located where the person wants to live, there
are only limited places for a person waiting in hospital to go. 
5.7 More care home beds have become available recently. Cathay was closed
while a large-scale investigation was underway, but since re-opening has
enabled 8 empty beds to become instantly available. Spynie was closed for
some time due to Covid but has since re-opened. Care Home operators have
also been requested that they offer places to residents from Moray first rather
than offer them to people from outside Moray. 
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Figure 4: Moray Care Home Bed Occupancy Rate (%) 
5.8 The average number of people waiting to be discharged have reduced from
50 in July 2022 to 29 for the most recent week. The measures that have been
put in place to manage the flow of patients from hospital to home (or care
home) include the following: 
• People who have been waiting a while have sourced care under Option 22 as
there has been availability through that option. 
• Daily portfolio meetings have helped expedite the outcomes for people.
• The new Planned Discharge Date system changed the criterion from
‘medically fit’ to ‘clinically fit’. When we declare a person is clinically fit it
allows time for occupational therapy, physio-therapy and social work to carry
out their assessments before the person is categorised as a delay, and this
measure has reduced delays slightly.
5.9 In addition, more people have been recruited into the Care at Home team
enabling more rotas to be opened, and there are fewer people requiring
double-up care than in recent months. It appears that people with more
complex needs are choosing to move into residential homes rather than
requiring Care at Home services. Both these changes have allowed more
people to be given care packages, helping to reduce the backlog (see section
6 for more details of unmet need). 
5.10 Care at Home assessors are now able to complete assessments in a timely
manner and there is no backlog of assessments waiting to be completed.
Third, there is a close liaison between the assessors and area managers and
their Allied counterparts, ensuring that any spare capacity is able to be utilised
promptly to provide care packages for people waiting. The demands and
capacity are discussed twice weekly at the Care-at-home hub meetings. 
2 As part of Self-directed support (SDS), there are several options for managing your care. Option 2 is
one of these options. You choose how the budget is used but the money is managed by someone
else.
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5.11 Finally, and sadly, some people die waiting to be discharged. The numbers
aren’t large, but in 2022 there were 7 such deaths and in 2023 so far there
have been 2. Since the start of 2023 the most common reason for a
residential or nursing agreement to be closed is due to the person’s death
(71%, see Figure 5), but then allows the next person waiting for a residential
or nursing agreement to be offered the care they require. These figures will be
monitored in future reports to identify trends from year to year.
Figure 5: Reasons for Closed Residential Nursing Agreements (Jan – Feb 2023) 
5.12 For Care at Home packages most are closed due to a change in service
(63%), but the second largest cause is death, responsible for the closure
approximately 1 in 5 agreements (Figure 6). Again, these deaths allow
packages to be made available to the next person on the waiting list.
Reason Percentage
Change In Service
Client Deceased
Service Not Required
Hospital Admission
Re-ablement Completed
Transferred To Another Home 
63.28%
18.75%
8.59%
7.81%
0.78%
0.78%  
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Figure 6: Care at Home (CAH) Packages Closed by Category (January to February 2023) 
5.13 Figure 5 displays the weekly average number of people, who are clinically
safe, experiencing delayed discharge, by hospital, and illustrates how many
more people are being affected than before the COVID-19 pandemic. This
continues to represent a significant loss of bed–capacity for other medical
procedures, for example, and an additional unplanned burden on hospital and
social care staff. Approximately half the delays are for people admitted to one
of Moray’s community hospitals. 
Figure 7: Average Number of Delayed Discharge Patients in Moray per Week 
5.14 To put the Moray experience into context, at the end of quarter 3 the average
across Scotland was 55, similar to the figure of 56 at the end of quarter 2. The
Moray average during 2022 has consistently been below the Scottish level,
and apart from being more spiky, has tended to follow a similar trend (Figure
8).
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Figure 8: Hospital Delayed Discharges over time - Comparison of Scotland and Moray
(Scottish Government data) 
Emergency Admissions 
5.15 Emergency Admission rates for the over 65s (EA-02) have reduced
significantly over the past 15 months, although there was a small increase in
December 2022. Note that the rate of 173.3 per 1,000 population is below the
target based on the 2021 average of 179.8 per 1,000 population. Similarly, the
number of people in this category admitted during the past 12 months (EA-03)
has followed a similar trend. At the end of quarter 3 the rate had reduced to
117.4 per 1,000 population, below the target of 124.6 per 1,000 population. 
5.16 However, the reduction in admissions may be due to the lack of available
beds, in part caused by delays in discharging people. Furthermore, the over
65s admitted for an emergency are continuing to stay in hospital longer as
evidenced by the Emergency Occupied Bed Days for over 65s (EA-01)
indicator. This has been increasing steadily since the start of 2021 and
continued to increase each month during quarter 3 reaching a rate of 2,547
bed-days per 1,000 population, exceeding the target of 2,037 per 1,000
population, and the highest recorded rate since this indicator was first
measured. 
Mental Health 
5.17 Approximately 1 in 5 patients requiring psychological therapy treatment are
having to wait more than 18 weeks for their treatment to begin. While this
figure remains below the target it is a significant improvement on the previous
2 quarters when almost 4 out of 5 patients had to wait more than 18 weeks.
Improvement is attributed to close monitoring of the service and
implementation of a series of actions aimed at reducing variation, maximizing
capacity and efficiency within the department. 
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5.18 Long term absence of the psychology service lead and psychology resource
being diverted elsewhere in the wider system impacts on ability to achieve
90% target. Recruitment processes are currently underway for an NHS
Grampian wide Band 8D adult mental health psychology lead post. Meanwhile
existing Moray psychological services staff will continue to be supported to
identify and implement any actions that assist further towards meeting the
required standard. Progress continues to be monitored within NHS Grampian
Psychological Service Improvement Board.
5.19 Moray service is working with Grampian colleagues as part of the NHS
Grampian Psychological Therapies Improvement Plan which has been
submitted to the Scottish Government and will be monitored.  Part of this work
has been to look at capacity and demand within the service, offering a set
number of sessions dependant on clinical need and contracting patients in line
with these recommendations.
5.20 Staff working within the service have been triaging patients on the waiting list
and offering group work, when appropriate, to increase the number of people
they can see.  However, some people will not be suitable for this and will
require individual appointments.
5.21 The team has been affected by ongoing sickness absence which impacts on
service delivery and there is an upcoming maternity leave.  Discussions are
taking place about cover for the latter. 
Staff Management
5.22 The average absence due to sickness for all Moray Council staff since May
2020 was 6.8% at the end of quarter 3.  This is just above the Scottish
average of 6.1% for the same period and above the pre-pandemic levels.
Sickness absence for Moray Council employed HSCM staff remains high at
8.3%, and NHS staff absences due to sickness have increased from 4.2% at
the end of quarter 1 to 5.5% in quarter 3 (data to November 2022). 
5.23 The locally collected data for Provider Services provides an illustration of the
magnitude of the difficulties that faced managers in this front-line delivery
service (Figure 7). The high absence rates of 17% experienced in March 2022
have steadily reduced, but throughout the summer and autumn of 2022 the
absence rate has fluctuated between 13% to 7%, still requiring close
management.
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Figure 9: Provider Services staff absence rate from 26 January 2022 to September 2022 (latest
available service collated data) 
5.24 Moray Council has recently reinstated face-to-face Health and Work training
for all managers who have staff attendance responsibility.  The Moray
Council’s Health and Work policy is a supportive policy, and the training
sessions provide vital skills to those managing absence. 
6. UNMET NEED 
6.1 The continuing staff shortages for care at home is impacting on the service’s
ability to meet the demand from people who require support. Since July last
year there have been approximately 150 to 165 people waiting to receive a
social care assessment. However, since the start of December 2022 the
number of people waiting has steadily reduced to 119. Still high, but the trend
is in the right direction (Figure 8). Over the same period the number of hours
of care not being delivered has remained well above the pre-pandemic levels,
but has gradually and steadily been reducing from 1,500 hours in March 2022
down to 1,058 hours for the most recent week (Figure 9).
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Figure 10 
Figure 11 
6.2 The impact of this lack of capacity to deliver care is predominantly on people
living in the community. The number of people in hospital who have been
assessed and are waiting for a package of care to be put in place has
reduced from 41 last August to just 12. However, there are 106 people in the
community waiting for their care packages to begin (Figure 10). Overall the
numbers of people in this category have reduced from over 170 to about 120
in the past 12 months, so the trend is heading in the right direction and the
rate at which the numbers are reducing is speeding-up, albeit after a slow
start.
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Figure 12: 
6.3 The shortfall in provision of care is also monitored by measuring the number
of hours of care not provided each week. The data are measured for those in
hospital and those in the community who are waiting for care packages to
commence, and also for those with a care package in place but who aren’t
receiving the full allocation of hours of care assessed as needed. The
number of hours not being provided has been high for most of 2022, but
there are signs the situation may be improving, albeit still at higher levels
than is acceptable.
6.4 The following 3 figures (Figures 11, 12 &13) illustrate the difficulties faced by
the Social Care team in providing the required numbers of hours of care
during the COVID-19 pandemic. 
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Figure 13: Hours of Care yet to be Provided for Individuals in Hospital 
Figure 14: Hours of Care yet to be Provided for Individuals in the Community 
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Figure 15: Hours of Care Assessed as Needed and not Provided for those in Receipt of a Care
Package 
6.5 Although the levels of unmet need may have peaked and are starting to
reduce the average time that people have to wait for an assessment
continues to increase. The average number of days has doubled from 152 in
September 2021 to over 300, while the number of people waiting has
reduced back to the September 2021 figure. The increased waiting time may
suggest that care packages are becoming more complex and assessments
are taking longer so that fewer are able to be completed each week, or that
there are insufficient staff to undertake the number of assessments required.
Figure 16: Average Waiting Time for Assessments 
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7. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP)) and Moray Integration Joint Board Strategic Plan
“Partners in Care 2022 – 2032”
Performance management reporting is a legislative requirement under
section 42 of the Public Bodies (Joint Working) (Scotland) Act 2014.   
In addition to publishing an Annual Performance Report, the Moray
Integration Scheme requires that the MIJB will “monitor the performance
of the delivery of integrated services using the Strategic Plan on an
ongoing basis” (para 5.2.2 of the Moray Integration Scheme refers). 
(b) Policy and Legal
None directly associated with this report. 
(c) Financial implications
None directly associated with this report. 
(d) Risk Implications and Mitigation
There are no risk issues arising directly from this report. The long-term
impact of the COVID-19 on the Health and Social Care system are still
unknown and performance measurement will remain flexible to enable
the service to be prepared and react to any future developments. 
(e) Staffing Implications  
None directly associated with this report. 
(f) Property
None directly associated with this report. 
(g) Equalities/Socio Economic Impact
An Equality Impact Assessment is not required for the Performance
Framework because there will be no impact, as a result of the report, on
people with protected characteristics. 
(h) Climate Change and Biodiversity Impacts
No climate change or biodiversity implications have been determined for
this policy/activity. It should be noted that extreme weather events, such
as the recent storms, are expected to occur more frequently and with
greater ferocity in future years. In the longer-term there are likely to be
issues with the reduction in availability and increases in costs of fossil
fuels that will pose challenges for the delivery of care services to people
living in rural areas. 
(i) Directions
There are no directions arising from this report. 
(j) Consultations
For Health and Social Care Moray the Chief Officer, Corporate Officer
and Service Managers in relation to respective areas have been
consulted as has Tracey Sutherland, Committee Services Officer, Moray
Council and their comments are incorporated in the report.
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8. CONCLUSION 
8.1 This report provides the MIJB with an overview of the performance of
specified Local and National indicators and outlines actions to be
undertaken to improve performance in Section 4 and expanded on in
APPENDIX 1.  As this is my final report before I retire, may I take the
opportunity to wish the MIJB all the best for the future. 
Authors of Report: Sonya Duncan, Corporate Manager
Carl Bennett, Senior Performance Officer
Background Papers: Available on request
Ref: 
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Appendix 1
PERFORMANCE REPORT
- SUPPORTING CHARTS
QUARTER 3
2022/23
(1 OCTOBER 2022 – 31 DECEMBER 2022)
Item 5.
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Table of Contents  
Health and Social Care Moray - 1 - 2022-23 Quarter 3 Performance Report
1. TABLE OF CONTENTS
1. Table of Contents ............................................................................................................................. 1
1. Performance Summary .................................................................................................................... 2
Barometer Overview ........................................................................................................................... 2
2. Delayed Discharge - RED .................................................................................................................. 3
DD-01: Number of delayed discharges (including code 9, Census snapshot, at end of quarter) ....... 3
DD-02: Number of Bed Days Occupied by Delayed Discharges per quarter (inc code 9) per 1000 18+
population ........................................................................................................................................... 3
3. Emergency Admissions - AMBER ..................................................................................................... 5
EA-01: Rate of emergency occupied bed days for over 65s per 1000 population .............................. 5
EA-02: Emergency Admissions rate per 1000 population for over 65s .............................................. 6
EA-03: Number of people over 65 years admitted as an emergency in the previous 12 months per
1000 population .................................................................................................................................. 7
4. Emergency Department – AMBER ................................................................................................... 8
AE-01: ED Attendance rates per 1,000 population (All Ages) ............................................................. 8
5. Hospital Re-admissions - GREEN ...................................................................................................... 9
HR-01: Percentage of Emergency Re-admissions to hospital within 28 days - Moray Patients ......... 9
HR-02: Percentage of Emergency Re-admissions to hospital within 7 days - Moray Patients ......... 10
6. Mental Health – RED ...................................................................................................................... 11
MH-01: Percentage of patients commencing Psychological Therapy Treatment within 18 weeks of
referral ............................................................................................................................................... 11
7. Staff Management - RED ............................................................................................................... 12
SM-01: NHS Sickness Absence % of Hours Lost ................................................................................ 12
SM-02: Council Sickness Absence (% of Calendar Days Lost) ............................................................ 13
Council STAFF Absence OVER TIME – SCOTLAND COMPARISON...................................................... 14
Appendix 1: Key and Data Definitions .................................................................................................. 15
RAG Scoring Criteria .......................................................................................................................... 15
Peer Group Definition ....................................................................................................................... 15
Appendix 2: Strategic Priorities............................................................................................................. 16
Appendix 3: National Health and Wellbeing Outcomes ....................................................................... 18 
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Performance Summary  
Health and Social Care Moray - 2 - 2022-23 Quarter 3 Performance Report
1. PERFORMANCE SUMMARY
BAROMETER OVERVIEW 
Moray currently has 11 local indicators. Of these 4 are Green, 1 is Amber and 6 are Red. 
Figure 1 - Performance Summary         
Q3 2122 Q4 2122 Q1 2223 Q2 2223 Q3 2223 New Target Previous Target
Oct-Dec Jan-Mar Apr-Jun Jul-Sep Oct-Dec (from Q1 2122) (from Q1 2021 or earlier)
AE Accident and Emergency
AE-01 A&E Attendance rate per 1000 population (All Ages) 20.0 20.0 24.3 24.0 22.6 no change 21.7 A
DD Delayed Discharges
DD-01* Number of delayed discharges (including code 9) at census point 39 46 46 47 29 no change 10 R
DD-02
Number of bed days occupied by delayed discharges (including code 9) at census
point 1142 1294 1207 1197 1063 no change 304 R
EA Emergency Admissions
EA-01 Rate of emergency occupied bed days for over 65s per 1000 population 2045 2140 2320 2469 2547 2037 2107 R
EA-02 Emergency admission rate per 1000 population for over 65s 187.2 183 177.5 172.4 173.3 179.9 179.8 G‚
EA-03
Number of people over 65 years admitted as an emergency in the previous 12
months per 1000 population 126.3 125.2 122 118.6 117.4 123.4 124.6 G‚
HR Hospital Readmissions
HR-01 % Emergency readmissions to hospital within 7 days of discharge 3.5% 3.4% 4.3% 3.0% 3.8% no change 4.2% G‚
HR-02 % Emergency readmissions to hospital within 28 days of discharge 8.4% 8.0% 8.3% 6.7% 8.0% no change 8.4% G‚
MH Mental Health
MH-01
% of patients commencing Psychological Therapy Treatment within 18 weeks of
referral 67% 33% 27% 33% 79.0% no change 90% R
SM Staff Management
SM-01 NHS Sickness Absence (% of hours lost) 5.5% 4.7% 4.2% 5.0% 5.5% no change 4% R Data to Nov 22
SM-02 Moray Council Sickness Absence (% of days lost) 8.1% 8.9% 8.8% 5.2% 8.3% no change 4% R                                                             
Health and Social Care Moray Performance Report                                          
Code Barometer (Indicator) RAG
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Delayed Discharge - RED  
Health and Social Care Moray - 3 - 2022-23 Quarter 3 Performance Report
2. DELAYED DISCHARGE - RED
Trend Analysis 
The number of delays at snapshot (29) was just one lower than at the end of quarter 3 2021/22. The
number of bed days lost due to delayed discharges reduced from 1,197 to 1,063. Both indicators
remain around 3 times above target. 
DD-01: NUMBER OF DELAYED DISCHARGES (INCLUDING CODE 9, CENSUS SNAPSHOT,
AT END OF QUARTER)
Purpose 
Reliably achieving timely discharge from hospital is an important indicator of
quality and is a marker for person centred, effective, integrated, and harm
free care.
Strategic Priority  2: HOME FIRST Linked Indicator(s) DD-02
National Health & Wellbeing Outcomes 2, 3, 5, 7 
Figure 2 – Delayed Discharges 
Indicator Trend – Reducing
Despite some volatility in numbers from month to month the underlying trend for the number of
people experiencing Delayed Discharge had been steadily increasing since the end of Quarter 4
2020/21 until May 2022. Since the trend has shown a gradual reduction, but still 3 times the
target level.
Source Public Health Scotland 
DD-02: NUMBER OF BED DAYS OCCUPIED BY DELAYED DISCHARGES PER QUARTER (INC
CODE 9) PER 1000 18+ POPULATION 
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Delayed Discharge - RED  
Health and Social Care Moray - 4 - 2022-23 Quarter 3 Performance Report
Purpose  This monitors the number of people delayed in hospital once medically fit
for discharge. Longer stays in hospital are associated with increased risk of
infection, low mood, and reduced motivation.
Strategic Priority  2: HOME FIRST Linked Indicator(s) DD-01
National Health & Wellbeing Outcomes 2, 3, 5, 7 
Figure 3 – Delayed Discharge Bed-days 
Indicator Trend – Reducing
The number of bed-days are over 3 times the target number of days and after averaging around
1200 for the past three quarters has now reduced to closer to 1,000.
Source Public Health Scotland
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Emergency Admissions - AMBER  
Health and Social Care Moray - 5 - 2022-23 Quarter 3 Performance Report
3. EMERGENCY ADMISSIONS - AMBER
Trend Analysis
Since March 2021 there has been a steady increase each month in the rate of emergency occupied
bed days for over 65s and the rate increased during quarter 3 from 2,469 to 2,547 in December 2022.
However, the emergency admission rate per 1000 population for over 65s has increased from 173.3
to 172.4 over the same period, while the number of people over 65 admitted to hospital in an
emergency reduced from 118.6 to 117.4. 
EA-01: RATE OF EMERGENCY OCCUPIED BED DAYS FOR OVER 65S PER 1000
POPULATION
Purpose  EA-01, EA-02, and EA-03 are all interconnected and provide a narrative
when viewed together of whether emergency admissions and bed days are
within tolerance and indicate where potential risks could arise.
Strategic Priority  1: BUILDING RESILIENCE  Linked Indicator(s) EA-02, EA-03
National Health & Wellbeing Outcomes 1, 2, 3, 5 
Figure 4 – Emergency Occupied Bed-days (Over 65s) 
Indicator Trend – Increasing
This indicator was on a downward trend for most of 2020, but since the start of 2021 has been
increasing and exceeded the reduced target throughout 2022.
Source Health Intelligence  
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Emergency Admissions - AMBER  
Health and Social Care Moray - 6 - 2022-23 Quarter 3 Performance Report
EA-02: EMERGENCY ADMISSIONS RATE PER 1000 POPULATION FOR OVER 65S
Purpose  EA-01, EA-02, and EA-03 are all interconnected and provide a story when
viewed together of whether emergency admissions and bed days are within
tolerance and indicate where potential risks could arise.
Strategic Priority  1: BUILDING RESILIENCE  Linked Indicator(s) EA-01, EA-03 
National Health & Wellbeing Outcomes  1, 2, 3, 5 
Figure 5 – Emergency Admissions (Over 65s) 
Indicator Trend – Increasing
At the start of 2021 the trend had been rapidly increasing, but since August 2021 there has been
a steady and sustained reduction. However, there was a small increase in December 2022, but
the rate remains below the target.
Source Health Intelligence  
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Emergency Admissions - AMBER  
Health and Social Care Moray - 7 - 2022-23 Quarter 3 Performance Report
EA-03: NUMBER OF PEOPLE OVER 65 YEARS ADMITTED AS AN EMERGENCY IN THE
PREVIOUS 12 MONTHS PER 1000 POPULATION
Purpose  EA-01, EA-02, and EA-03 are all interconnected and provide a story when
viewed together of whether emergency admissions and bed days are
within tolerance and indicate where potential risks could arise.
Strategic Priority  1: BUILDING
RESILIENCE  Linked Indicator(s) EA-01, EA-02
National Health & Wellbeing Outcomes 1, 2, 3, 5 
Figure 6 – Number of Over 65 People Emergency Admissions 
Indicator Trend – Increasing
This indicator was showing a consistent downward trend until February 2021, since when the
trend reversed and increased rapidly. As with Figure 4 the rate levelled off in August 21 and then
reduced to be below the target, although there was a slight increase in December 2022.
Source Health Intelligence  
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Emergency Department – AMBER  
Health and Social Care Moray - 8 - 2022-23 Quarter 3 Performance Report
4. EMERGENCY DEPARTMENT – AMBER
Trend Analysis 
There has been an reduction in the rate per 1,000 this quarter from 24 to 22.6, remaining above target and
double the number presenting in April 2020. 
AE-01: ED ATTENDANCE RATES PER 1,000 POPULATION (ALL AGES)
Purpose  A greater system-wide understanding of how people access emergency
care, and why certain choices are made, will allow local health systems to
develop intelligence about avoidable attendances at emergency
departments and target their responses. 
Strategic Priority  3: PARTNERS IN CARE Linked Indicator(s) HR-01, HR-02
National Health & Wellbeing Outcomes  1, 2, 3, 5 
Figure 7 – ED Attendance Rate 
Indicator Trend – Stable
During quarter 3 the attendance rate per 1,000 population has remained reasonably stable, just
above the target level. However, the attendance rate is almost double the rate experienced at
the end of April 2020.
Source Health Intelligence  
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Hospital Re-admissions - GREEN  
Health and Social Care Moray - 9 - 2022-23 Quarter 3 Performance Report
5. HOSPITAL RE-ADMISSIONS - GREEN
Trend Analysis 
28-day re-admissions remain GREEN at 8.0%, and 7-day Re-admissions remain GREEN at 3.8%. 
HR-01: PERCENTAGE OF EMERGENCY RE-ADMISSIONS TO HOSPITAL WITHIN 28 DAYS
- MORAY PATIENTS
Purpose  Re-admissions are often undesirable for patients and have also been shown
to be associated with the quality of care provided to patients at several
stages along the clinical pathway, including during initial hospital stays,
transitional care services and post-discharge support. (This measure lags by
a month due to the time required for a potential 28 day discharge to occur)
Strategic Priority  1: BUILDING
RESILIENCE  Linked Indicator(s) HR-02, AE-01
National Health & Wellbeing Outcome  1, 2, 3, 5 
Figure 8 – 28-dayEmergency Readmissions 
Indicator Trend – Stable
28-day Hospital Re-admissions have remained around the target of 8% for this quarter.
Source Health Intelligence  
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Hospital Re-admissions - GREEN  
Health and Social Care Moray - 10 - 2022-23 Quarter 3 Performance Report
HR-02: PERCENTAGE OF EMERGENCY RE-ADMISSIONS TO HOSPITAL WITHIN 7 DAYS -
MORAY PATIENTS
Purpose  Re-admissions are often undesirable for patients and have also been shown
to be associated with the quality of care provided to patients at several
stages along the clinical pathway, including during initial hospital stays,
transitional care services and post-discharge support.
Strategic Priority  1: BUILDING RESILIENCE  Linked Indicator(s) HR-01, AE-01
National Health & Wellbeing Outcome  1, 2, 3, 5 
Figure 9 – 7-day Emergency Readmissions 
Indicator Trend – Stable
7-day Hospital Re-admissions have generally remained below the target of 4.2% since July 2021,
apart from 2 occasions.
Source Health Intelligence
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Mental Health – RED  
Health and Social Care Moray - 11 - 2022-23 Quarter 3 Performance Report
6. MENTAL HEALTH – RED 
Trend Analysis 
After 24 months below target and a year at around 20% this measure was at 100% for the 6 months
from December 2020 through to June 2021. However, since quarter 3 there has been a rapid
reduction with 27% of patients being referred within 18 weeks during June 2022. 
MH-01: PERCENTAGE OF PATIENTS COMMENCING PSYCHOLOGICAL THERAPY
TREATMENT WITHIN 18 WEEKS OF REFERRAL
Purpose  Timely access to healthcare is a key measure of quality and that applies
equally in respect of access to mental health services.
Strategic Priority  3: PARTNERS IN CARE Linked Indicator(s) 
National Health & Wellbeing Outcome  1, 2, 3, 5 
Figure 10 – Psychological Therapy Treatment within 18 Weeks 
Indicator Trend – Improving
After being around 30% for most of 2022 there has been a marked improvement in performance,
which had achieved 79% by the end of quarter 3 2022/23, albeit still below the target of 90%. 
Source Health Intelligence  
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Staff Management - RED  
Health and Social Care Moray - 12 - 2022-23 Quarter 3 Performance Report
7. STAFF MANAGEMENT - RED
Trend Analysis 
Sickness absence for NHS employed staff remains above target reaching 5.5% at the end of quarter 3.
Council employed staff sickness has remained high with a minimal reduction from 8.98% to 8.87%,
which is above the figure for the same period in the previous 2 years.   
SM-01: NHS SICKNESS ABSENCE % OF HOURS LOST
Purpose  Attendance at work of all employees is essential in the interests of the
effective and efficient operation of services.
Strategic Priority  1: BUILDING
RESILIENCE  Linked Indicator(s) SM-02
National Health & Wellbeing Outcome  8 
Target (+10%) Q2 21/22 Q3 21/22 Q4 21/22 Q1 22/23 Q2 22/23 Q3 22/23
4% 6.0% 5.5% 4.7% 4.2% 5.0% 5.5%* 
Figure 11 – NHS Sickness Absence 
Indicator Trend – Increasing
This indicator has increased steadily throughout 2022/23 although it remained unchanged in
November and December 2022 at 5.5%.
*Data to November 2022
Source Health Intelligence 
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Staff Management - RED  
Health and Social Care Moray - 13 - 2022-23 Quarter 3 Performance Report 
SM-02: COUNCIL SICKNESS ABSENCE (% OF CALENDAR DAYS LOST)
Purpose  Attendance at work of all employees is essential in the interests of the
effective and efficient operation of services.
Strategic Priority  1: BUILDING
RESILIENCE  Linked Indicator(s) SM-01
National Health & Wellbeing Outcome  1, 2, 3, 5
Target Q2 21/22 Q3 21/22 Q4 21/22 Q1 22/23 Q2 22/23 Q3 22/23
4% 7.8% 8.05% 8.98% 8.87% 5.22% 8.34% 
Figure 12 – Moray Council Sickness Absence 
Indicator Trend – Increasing
After a 3% reduction during quarter 2 this indicator rose during quarter 3 to double the target
and close to the peak of 9% recorded in quarter 4 2019/20.
Source Council HR 
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Staff Management - RED  
Health and Social Care Moray - 14 - 2022-23 Quarter 3 Performance Report
COUNCIL STAFF ABSENCE OVER TIME – SCOTLAND COMPARISON 
Chart provided by the Improvement Service using data from the from weekly SOLACE council
returns. This update captures data from the week ending 13 January 2023. Moray remains above the
Scottish average and there was a marked increase in absence towards the end of quarter 3. 
Figure 13 – Moray Council Sickness Absence Compared to National Average   
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Staff Management - RED  
Health and Social Care Moray - 15 - 2022-23 Quarter 3 Performance Report
APPENDIX 1: KEY AND DATA DEFINITIONS
RAG SCORING CRITERIA
GREEN If Moray is performing better than target.
AMBER If Moray is performing worse than target but within specified tolerance.
RED If Moray is performing worse than target but outside of specified
tolerance. 
PEER GROUP DEFINITION
Moray is defined as being in Peer Group 2 in the Local Government Benchmarking Framework 
Family Group 1 Family Group 2 Family Group 3 Family Group 4
East Renfrewshire
East Dunbartonshire
Aberdeenshire
Edinburgh, City of
Perth & Kinross
Aberdeen City
Shetland Islands
Orkney Islands
Moray
Stirling
East Lothian
Angus
Scottish Borders
Highland
Argyll & Bute
Midlothian
Falkirk
Dumfries & Galloway
Fife
South Ayrshire
West Lothian
South Lanarkshire
Renfrewshire
Clackmannanshire
Eilean Siar
Dundee City
East Ayrshire
North Ayrshire
North Lanarkshire
Inverclyde
West Dunbartonshire
Glasgow City 
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Staff Management - RED  
Health and Social Care Moray - 16 - 2022-23 Quarter 3 Performance Report
APPENDIX 2: STRATEGIC PRIORITIES 
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Staff Management - RED  
Health and Social Care Moray - 17 - 2022-23 Quarter 3 Performance Report 
•EA-01: RATE OF EMERGENCY OCCUPIED BED DAYS FOR OVER
65S PER 1000 POPULATION
•EA-02: EMERGENCY ADMISSIONS RATE PER 1000 POPULATION
FOR OVER 65S
•EA-03: NUMBER OF PEOPLE OVER 65 YEARS ADMITTED AS AN
EMERGENCY IN THE PREVIOUS 12 MONTHS PER 1000
POPULATION
•HR-01: PERCENTAGE OF EMERGENCY RE-ADMISSIONS TO
HOSPITAL WITHIN 28 DAYS -MORAY PATIENTS
•HR-02: PERCENTAGE OF EMERGENCY RE-ADMISSIONS TO
HOSPITAL WITHIN 7 DAYS -MORAY PATIENTS
•SM-01: NHS SICKNESS ABSENCE % OF HOURS LOST
•SM-02: COUNCIL SICKNESS ABSENCE (% OF CALENDAR DAYS
LOST)
BUILDING
RESILIENCE
•DD-01: NUMBER OF DELAYED DISCHARGES (INCLUDING CODE 9,
CENSUS SNAPSHOT, AT END OF QUARTER)
•DD-02: NUMBER OF BED DAYS OCCUPIED BY DELAYED
DISCHARGES PER QUARTER (INC CODE 9) PER 1000 18+
POPULATION
•UN-01: NUMBER OF LONG-TERM HOME CARE HOURS UNMET
AT WEEKLY SNAPSHOT
•UN-02: NUMBER OF PEOPLE WITH LONG-TERM CARE HOURS
UNMET AT WEEKLY SNAPSHOT
HOME
FIRST
•OA-01: NUMBER OF REVIEWS OUTSTANDING AT END OF
QUARTER SNAPSHOT
•MH-01: PERCENTAGE OF PATIENTS COMMENCING
PSYCHOLOGICAL THERAPY TREATMENT WITHIN 18 WEEKS OF
REFERRAL
•AE-01: A&E ATTENDANCE RATES PER 1000 POPULATION (ALL
AGES)
PARTNERS
IN CARE
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Staff Management - RED  
Health and Social Care Moray - 18 - 2022-23 Quarter 3 Performance Report
APPENDIX 3: NATIONAL HEALTH AND WELLBEING OUTCOMES
1 - PEOPLE ARE ABLE TO LOOK AFTER AND IMPROVE THEIR OWN HEALTH AND WELLBEING AND
LIVE IN GOOD HEALTH FOR LONGER. 
2 - PEOPLE, INCLUDING THOSE WITH DISABILITIES OR LONG-TERM CONDITIONS, OR WHO ARE
FRAIL; ARE ABLE TO LIVE, AS FAR AS REASONABLY PRACTICABLE, INDEPENDENTLY AT HOME,
OR IN A HOMELY SETTING IN THEIR COMMUNITY. 
3 - PEOPLE WHO USE HEALTH AND SOCIAL CARE SERVICES HAVE POSITIVE EXPERIENCES OF
THOSE SERVICES, AND HAVE THEIR DIGNITY RESPECTED. 
4 - HEALTH AND SOCIAL CARE SERVICES ARE CENTRED ON HELPING TO MAINTAIN OR IMPROVE
THE QUALITY OF LIFE OF PEOPLE WHO USE THOSE SERVICES. 
5 - HEALTH AND SOCIAL CARE SERVICES CONTRIBUTE TO REDUCING HEALTH INEQUALITIES. 
6 - PEOPLE WHO PROVIDE UNPAID CARE ARE SUPPORTED TO LOOK AFTER THEIR OWN HEALTH
AND WELLBEING, INCLUDING TO REDUCE ANY NEGATIVE IMPACT OF THEIR CARING ROLE ON
THEIR OWN HEALTH AND WELLBEING. 
7 - PEOPLE USING HEALTH AND SOCIAL CARE SERVICES ARE SAFE FROM HARM. 
8 - PEOPLE WHO WORK IN HEALTH AND SOCIAL CARE SERVICES FEEL ENGAGED WITH THE WORK
THEY DO AND ARE SUPPORTED TO CONTINUOUSLY IMPROVE THE INFORMATION, SUPPORT,
CARE, AND TREATMENT THEY PROVIDE. 
9 - RESOURCES ARE USED EFFECTIVELY AND EFFICIENTLY IN THE PROVISION OF HEALTH AND
SOCIAL CARE SERVICES.
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REPORT TO: MORAY INTEGRATION JOINT BOARD AUDIT, PERFORMANCE
AND RISK COMMITTEE ON 30 MARCH 2023 
SUBJECT: INTERNAL AUDIT PLAN 2023/24  
BY: CHIEF INTERNAL AUDITOR 
1. REASON FOR REPORT 
1.1 To provide the Audit, Performance and Risk Committee with information on the
proposed internal audit coverage for the 2023/24 financial year. 
2. RECOMMENDATION 
2.1 It is recommended that the Committee considers and notes this report
and agrees   the proposed audit coverage. 
3. BACKGROUND 
3.1 Scottish Government Integrated Resources Advisory Group (IRAG)
guidance requires each IJB to establish adequate and proportionate internal
audit arrangements to review risk management, governance and control of
delegated resources. 
3.2 The guidance recommends that a risk-based audit plan should be developed
by the Chief Internal Auditor of the IJB and be approved by the IJB or other
Committee (in Moray, the Audit, Performance and Risk Committee).
Importantly it also notes that the operational delivery of services within the
Health Board and Local Authority on behalf of the IJB will be covered by their
respective internal audit arrangements. 
3.3 In recent years, discussions have been held with the internal audit providers for
NHS Grampian, Aberdeen City and Aberdeenshire Councils. The intention has
been to develop closer working relationships to better coordinate the audit
planning process. An audit of Information Management was agreed as the first
step to be undertaken by all internal audit providers. It is therefore pleasing to
report that the audit review was completed and a report issued with
Item 6.
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recommendations agreed by the Service. It is hoped moving forward that closer
working relationships can continue to ensure a greater coordinated audit
approach. 
3.4 Moray Council’s Audit and Scrutiny Committee, at its meeting on 15 of February
2023, approved an audit plan which provided 80 days of input for audit work
relating to the MIJB (para 5 of the minute refers). 
4.       KEY MATTERS RELEVANT TO RECOMMENDATION 
4.1 In selecting audit topics, a full evaluation of the council’s resource inputs to the
activities directed by the MIJB has been undertaken, with consideration given
to: 
• materiality (based on expenditure or income)
• consultation with senior management for areas of work where it was
considered internal audit could make a contribution through its work
programme
• time elapsed since an area was last subject to a review
• overall audit assessment of the control environment 
4.2  The following areas are considered for inclusion within the 2023/24 Audit Plan:- 
• Commissioning Services - Review the arrangements for the
commissioning of services for children to ensure these are designed and
delivered to meet the specified needs and demonstrate best value. 
• Disabled Parking System - Review the system for administering the
disabled parking permits, also known as Blue Badges. 
• Occupational Therapy Services – Stores - A review of the Occupational
Services Stores Systems to ensure appropriate accounting systems are
followed. 
4.3 The impact of the pandemic has resulted in changes in the working practices of
services with officers working from home. The Internal Audit Section has
adapted, and greater use has been made of electronic methods of
communication. However, sometimes this has proved challenging and has
slowed the pace of audits. Committee should therefore be aware of possible
delays in progressing and completing audit reviews. 
4.4   The Public Sector Internal Audit Standards require the Chief Internal Auditor to
consider whether or not the audit staffing resources are sufficient to meet the
audit needs of the organisation and where it is believed that the level of
resources may impact adversely on the provision of the annual internal audit
opinion draw this to the attention of the Committee. In recent years there have
been increased demands on the Internal Audit Section to ensure we meet the
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requirements of the service by attendance on various working groups,
consultation on specific issues of concern, and ensuring sufficient coverage to
provide an annual audit opinion. As the Chief Internal Auditor of the MIJB, I am
of the opinion these demands will increase, and I am therefore concerned that
the available resource will be sufficient to meet these needs. 
4.5      In considering the audit coverage, the Audit, Performance and Risk Committee
should be aware that the responsibility for developing and maintaining a sound
control environment rests with management and not with Internal Audit.
Similarly, it will be recognised that Internal Audit is not the only scrutiny activity
within the MIJB, with services challenged through other mechanisms, including
external audit and inspection and separate reporting on clinical and care
governance. 
5. SUMMARY OF IMPLICATIONS    
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan
(LOIP)) and Moray Integration Joint Board Strategic Plan “Partners in
Care 2022-2032” 
Internal audit work supports good governance and assists in securing
appropriate systems of internal control. 
(b)  Policy and Legal 
The internal audit service is provided in terms of paragraph 7:1 of the Local
Authority Accounts (Scotland) Regulations 2014, and there is a requirement
to provide a service in accordance with published Public Sector Internal
Audit Standards. 
(c) Financial Implications 
No implications directly arising from this report. 
(d)  Risk Implications and Mitigation 
Audit reports highlight risk implications and contain recommendations for
management to address as a means of mitigating.   
(e) Staffing Implications 
No implications directly arising from this report 
(f)   Property 
No implications. 
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(g)  Equalities/ Socio Economic Impacts 
Not required as there is no change to policy. 
(h) Climate Change and Biodiversity Impacts 
None directly arising from this report. 
(i) Directions 
None arising directly from this report. 
(j) Consultations 
There have been no direct consultations during the preparation of this report. 
6.        CONCLUSION 
6.1 The Committee is asked to consider and agree the planned audit   coverage
for the MIJB for 2023/24. 
Author of Report: Dafydd Lewis, Chief Internal Auditor
Background Papers: Audit working papers 
Ref: MIJB/APRC/300323
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REPORT TO: MORAY INTEGRATION JOINT BOARD AUDIT, PERFORMANCE
AND RISK COMMITTEE ON 30 MARCH 2023 
SUBJECT: STRATEGIC RISK REGISTER – MARCH 2023 
BY:  CHIEF OFFICER 
1. REASON FOR REPORT 
1.1 To provide an overview of the current strategic risks, along with a summary of
actions which are in place to mitigate those risks, updated March 2023. 
2. RECOMMENDATION 
2.1 It is recommended that the Audit, Performance and Risk Committee
agree to: 
i) consider and note the updated Strategic Risk Register included in
APPENDIX 1; and 
ii) note the Strategic Risk Register will be further refined to align with
the transformation and redesign plans as they evolve 
3. BACKGROUND  
3.1 The strategic risk register is reviewed regularly by the Senior Management
Team as part of a robust risk monitoring framework, to identify, assess and
prioritise risks related to the delivery of services in relation to delegated
functions, particularly any which are likely to affect the delivery of the Strategic
Plan. 
3.2 The Moray Integration Joint Board (MIJB) Strategic Risk Register is attached
to this report at APPENDIX 1 and sets out the inherent risks being faced by
the MIJB, together with a current assessment on the level of the risks and
mitigating actions being taken to reduce the impact of the risks.  This report is
presented to Audit, Performance and Risk Committee for their oversight and
comment. 
3.3 Risk scores are weighted, based on assessment according to their likelihood
and corresponding impact, as per Section 5 of the MIJB Risk Policy.   
Item 7.
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3.4 The Strategic Risks received an initial review to ensure they align to the
Partners in Care 2022-2032 strategic plan which was agreed at MIJB on 24
November 2022 (para 14 of the minute refers). 
4. KEY MATTERS RELEVANT TO RECOMMENDATION 
4.1 The Risk Management Framework review was completed and outcome was
approved by the Board on 25 June 2020 (para 9 of the minute refers). The
approved Risk Appetite Statements have been included in APPENDIX 1. 
4.2 The return to ‘business as usual’ from the Covid-19 pandemic continues.
However, there has not been any relief in the system, and it continues to
challenge an already pressured system. 
4.3 The senior leadership teams continually consider the appetite for risk whilst
planning and effecting transformational change and redesign, despite
operating within a very finite budget. 
4.4 Work continues across teams to ensure the Risk Register is updated in the
timescales dictated by the criteria. Work continues to support teams with this. 
4.5 Governance, adverse events and risk will be covered as part of a Clinical
Governance workstream in upcoming workshops, commenced January 2023. 
4.6 The continued safe delivery of services is a priority and as such, dedicated
management time is being directed to support oversight of operational risks. 
The Grampian Operational Escalation System (GOPES) continues to be
utilised to assist in the identification of pressure points across the whole
system so that they can be addressed and prioritised appropriately. These
principals continue to be revisited across the system in Grampian. 
4.7 Recruitment and retention continues to provide challenges across all
disciplines. The Moray Health and Social Care Workforce Plan was approved
by MIJB on 29 Sep 2022 (para 12 of the minute refers). Over the next three
years, the workforce plan will focus on the five key areas known as ‘pillars’;
they include, Plan, Attract, Train, Employ and Nurture staff. A report
discussing the challenges and plans of Recruitment and Retention was
presented to MIJB on 26 January 2023 (para 13 of the minute refers). 
4.8 As part of the ongoing work to ensure all patients are treated in ‘the right
place, at the right time’, HSCM Senior Clinical Leads led two days of audit
across Moray. The findings will be used to further develop plans across
HSCM. 
4.9 The possibility of planned power outages were raised by SSEN. Civil
contingency groups are discussing options and reviewing Business Continuity
Plans to ensure planning is underway. Additional support has also been
funded by HSCM to assist Primary Care Contractors with planning. 
4.10 There continues to be significant financial risk in the system.  The 2021-22
audited financial accounts were signed off by MIJB 26 January 2023 (para 7
of the minute refers). It was noted that the full impact of the clawback of the
Covid reserve is not yet quantifiable. A full update is scheduled to be
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presented in the Interim Chief Financial Officer’s report to MIJB in March
2023. 
4.11 There continues a significant number of hours per week of unmet need for
care at home, with little change in these figures this year. There is an urgent
need to increase supply to support the Health and Social Care system.
Regular meetings and action plans continue to take place to support teams. 
4.12 As plans evolve, the Strategic Risk Register will continue to be updated to
ensure that it reflects any potential risks to realise the vision set out in our
Strategic Plan. 
5. SUMMARY OF IMPLICATIONS
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP)) and Moray Integration Joint Board Strategic Plan
“Partners in Care 2022-2032”
The MIJB requires effective governance arrangements for those services
and functions delegated to it and Risk Management systems are integral
to this. 
(b) Policy and Legal
As set out in the terms of reference, the Board has responsibility to
provide assurance of the adequacy of the risk management framework. 
There are no legal implications arising from this report.  
(c) Financial implications
There are no direct financial implications arising from this report however
the Board should note the failure to manage risks effectively could have
a financial impact for the MIJB. 
(d) Risk Implications and Mitigation
This report forms part of the governance arrangements for identifying
and managing strategic risks of the MIJB.  The risks are outlined in the
body of the report in section 4. 
(e) Staffing Implications
There are no additional staffing implications arising from this report.   
(f) Property
There are no property implications arising from this report. 
(g) Equalities/Socio Economic Impact
An Equalities Impact Assessment is not required because there are no
service, policy or organisational changes being proposed. 
(h) Climate Change and Biodiversity Impacts
There are no impacts arising from this report. 
(i) Directions
None arising from this report. 
(j) Consultations
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Consultation on this report has taken place with the Senior Management
Team and presented to Clinical and Care Governance Group. 
6. CONCLUSION 
6.1 This report and appendices contains proposed risk appetite statements
that, when approved, will underpin the MIJB approach to strategic
decision making.   
6.2 The report outlines the current position and recommends the Committee
note the revised and updated version of the Strategic Risk Register. 
Author of Report:  Sonya Duncan, Corporate Manager
Background Papers:   held by HSCM
Ref: 
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Appendix 1 
HEALTH AND SOCIAL CARE MORAY STRATEGIC RISK REGISTER 
AS AT MARCH 2023 
Item 7.
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Appendix 1 
RISK SUMMARY 
1. The Moray Integration Joint Board (MIJB) does not function as set out within the Integration Scheme, Strategic Plan and in-line
with Standing Orders and fails to deliver its objectives or expected outcomes.  
2. There is a risk of MIJB financial failure in that the demand for services outstripping available financial resources.  Financial
pressures being experienced by the funding Partners will directly impact on decision making and prioritisation of MIJB.
3. Inability to recruit and retain qualified and experienced staff to provide safe care whilst ensuring staff are fully able to manage
changes resulting from integration.
4. Inability to demonstrate effective governance and effective communication and engagement with stakeholders.
5. Inability to cope with unforeseen external emergencies or incidents as a result of inadequate emergency and resilience planning.
6. Risk to MIJB decisions resulting in litigation/judicial review.  Expectations from external inspections are not met.
7. Inability to achieve progress in relation to national Health and Wellbeing Outcomes.  Performance falls below acceptable level.
8. Inability to progress with delivery of Strategic Objectives and Transformation projects as a result of inability to resolve data sharing
and data security requirements.
9. Requirements for support services are not prioritised by NHS Grampian and Moray Council. 
RISK RATING LOW  MEDIUM HIGH  VERY HIGH
RISK MOVEMENT  DECREASE NO CHANGE INCREASE 
The process for managing risk is documented out with the MIJB Risk Policy. 
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Appendix 1 
Description of
Risk: 
Regulatory
The Integration Joint Board (IJB) does not function as set out within the Integration Scheme, Strategic Plan and
Scheme of Administration and fails to deliver its objectives or expected outcomes.  
Lead: Chief Officer
Risk Rating:  Low/ medium/ high/ very high  MEDIUM
Risk Movement:  Increase/ decrease/ no change  NO CHANGE
Rationale for Risk
Rating: 
The strategic plan “Partners in Care 2019-2029” was revised and presented as “Partners in Care 2022 to 2032”, this was
approved by MIJB in November 2022.  
Membership of IJB committees recently changed due to the elections in May.  An amendment to the Scheme to increase
membership by one from each of the partner organisations was ratified in March 2022 by the Scottish Government
following due process and approval by Moray Council and NHS Grampian Board.
During the initial Covid 19 response, normal business was suspended and emergency arrangements were implemented. 
IJB, CCG and APR meetings restarted during August 2020.  Weekly meetings were instigated with Chair/Vice Chair and
Chief Officer and these continue.  A delivery plan for the new Strategic Plan “Partners in Care” 2022-32 will be presented
Spring 2023.
Rationale for Risk
Appetite: 
The Board, staff and providers across Moray are all committed to ensuring high standards of clinical care & governance
through operational policies.  Innovation and new ways of working may mean traditional regulations do not exist, or are
contradictory. 
We will only take regulatory risks knowingly, following consultation with the relevant regulatory body and where we have
clear risk mitigation in place. 
Controls: • Integration Scheme.
• Strategic Plan “Partners in Care” 2022-32
• Governance arrangements formally documented and approved by MIJB January 2021.
• Agreed risk appetite statement.
• Performance reporting mechanisms.
• Consultation with legal representative for all reports to committees and attendance at committee for key reports.
• Standing orders have been reissued to all members
Mitigating
Actions: 
Induction sessions were held for new IJB members after May elections. Further sessions will be arranged for recent
appointees.
IJB member briefings are held regularly as development sessions. 
1
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Appendix 1 
Conduct and Standards training held for IJB Members in June 2022 provided by Legal Services.
SMT regular meetings and directing managers and teams to focus on priorities. 
Regular development sessions held with IJB and System Leadership Group
Strategic Plan and locality management structure is in place. The work that has been progressed through the Covid19
response has escalated developments in some areas as a matter of priority.  This has been achieved through
collaborative working with partner organisations and the third sector. 
Assurances: • Audit, Performance and Risk Committee oversight and scrutiny.
• Internal Audit function and Reporting
• Reporting to Board.
• The Moray Transformation Board has recently recommenced and will support an oversight of planned business
across HSCM.
Gaps in
assurance:
The new strategic delivery plan and will incorporate the work being taken forward for Self-Directed support, Hospital at
Home and  Locality Planning. 
Current
performance:
The Scheme of Administration is reported when any changes are required.  
Legal advisors are currently working on the requirements to the integration scheme in relation to the proposed The
integrated scheme of delegation of Children’s and Families and Justice Services was presented and accepted by MIJB
on 26th January 2023.
The Governance Framework was approved by IJB 28 January 2021. Re-appointment of Standards Officer agreed by
IJB 31 March 2022.
Members Handbook has been updated and circulated to all members in June 2022.
Comments: Strategic Planning and Commissioning Group approved the generic Terms of Reference and Chairs of the
transformation boards at the meeting on 19 December 2019. These groups have now recently recommenced following
the pause during the Covid19 response. The Interim Strategy and Planning Lead is now taking this forward and
prioritising and focusing on strategic planning and priorities over the short and longer term. 
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Appendix 1 
2
Description of
Risk: 
Financial
There is a risk of MIJB financial failure in that the demand for services outstrips available financial resources.  Financial
pressures being experienced both by the funding Partners and Community Planning Partners will directly impact on
decision making and prioritisation of MIJB.
Lead: Chief Officer/Chief Financial Officer
Risk Rating:  Low/ medium/ high/ very high VERY HIGH
Risk Movement:  Increase/ decrease/ no change INCREASING
Rationale for Risk
Rating: 
Whilst the 2020/21 to 2022/23 settlement saw additional investment for health and social care that was passed through
to the MIJB, there remains a significant pressure due to the recurring core overspend, since most of the new investment
related to new commitments. 
Financial settlements are set to continue on a one year only basis, which does not support sound financial planning.  
In addition, many uncertainties have arisen relating to the carried forward ear marked reserves with the clawback of the
Covid reserve and reduction of the PSIF funding in 2022/23 as well as other funding being looked at.  The full impact is
not yet quantifiable. 
The Revenue Budget 2022/23 was approved by MIJB on 31 March 2022 as a balanced budget.  A small savings plan of
£0.11 million was approved and achieved.  Additional Scottish Government investment was provided again for 2022/23,
this is to meet additional policy commitments in respect of adult social care pay uplift for externally provided services and
seeks to ensure that capacity can be maximised and ensuring system flow.  
The update medium Term Financial Framework was presented as part of the budget papers on the 31st March 2022
however, it is imperative that this is further reviewed during the 2022/23 year to ensure alignment with the upcoming
revisions to the Strategic Plan and is planned to be presented to MIJB on 30 March 2023.
Rationale for Risk
Appetite: 
The Board recognises the financial constraints all partners are working within. While we are cautious and open about
accepting financial risks this will be done: 
• Where a clear business case or rationale exists for exposing ourselves to the financial risk 
• Where we can protect the long term sustainability of health & social care in Moray   
The Covid-19 recovery continues to place risk on the MIJB finances as we continue through the, recover and transform
stages. Whilst we are now officially in the recovery phase there has been no change in the pressures felt by the
system..
Controls: There is an interim arrangement for CFO cover from Moray Council. Permanent recruitment efforts have not been
successful. The Chief Officer is working with both the Council and NHS Finance Leads to secure a longer term interim
arrangement. 
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Appendix 1 
The CFO and Senior Management Team have worked together to address further savings which will be presented to
the Board for approval as part of the budget setting procedures for 2022/23.  This should be a focus of continuous
review to ensure any investment is made taking cognisance of existing budget pressures.  A revised Financial
Framework was presented to the MIJB on 31 March 2022, and a further review will take place once the current
strategic plan has been reviewed to assure alignment. The Senior Management Team met in February 2023 to
consider and plan for the financial challenges for 2023/24.
Mitigating
Actions: 
Risk remains of the challenge that the MIJB can deliver transformation and efficiencies at the pace required whilst dealing
with the pressures that are emerging as a result of the pandemic.    
Financial information is reported regularly to both the MIJB, Senior Management Team and System Leadership Group. 
The Chief Officer and Chief Financial Officer (CFO) continue to engage in finance discussions with key personnel of both
NHS Grampian and Moray Council.  These conversations have continued throughout the pandemic phase. 
Chief Officer and CFO will continue to engage with the partner organisations in respect of the financial position throughout
the year. Cross partnership performance meetings are in with partner CEOs, Finance Directors and the Chair/Vice Chair
of the MIJB. 
Assurances: MIJB oversight and scrutiny of budget.  Reporting through MIJB, NHS Grampian Board and Moray Council.
Gaps in
assurance:
None known
Current
performance:
An overspend of £1,454,162 was reported to the IJB at 30 Sept 2022.
The Scottish Government have announced their intention to reclaim surplus Covid reserves, £6,239,000 is due to be
clawed back in 2023.
Comments: Senior managers continue to work with Chief Officer and Chief Financial Officer to address the continuing financial
challenge, continuing to seek efficiencies and opportunities for real transformation as we look to make efficient and
effective investment in services that are truly transformational. There are additional pressures from the cost of living
crisis, increasing energy bills, inflation and the potential for staff industrial action. 
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Appendix 1 
3
Description of
Risk: 
Human Resources
(People):
Inability to recruit and retain qualified and experienced staff to provide and maintain sustainable, safe care, whilst
ensuring staff are fully able to manage change resulting from response to external factors such as the impact of Covid
and the actions that arose from the recommendations from the Independent Review of Adult Social Care 2021.
Lead: Chief Officer
Risk Rating:  Low/ medium/ high/ very high HIGH
Risk Movement:  Increase/ decrease/ no change NO CHANGE
Rationale for Risk
Rating: 
There continues to be issues with recruitment to front line services that require specific skills and experience.  This has
been the case for some time now and continues to place pressure on existing staff.  Allied Health Professions, Social
Work and Nursing are some of the particular areas experiencing difficulties with obtaining people with the appropriate
skills and training. Care at Home staffing levels are pressured for Internal services and externally with local providers all
experiencing the same difficulties. 
There are also impacts on recruitment of Dentists and other graduates arising from Covid as the number graduating has
reduced during the period.
The various impacts of Covid-19 has  placed a significant strain on the Partnerships resources across frontline and
support functions and this has resulted in delays for the progress of projects relating to the achievement of strategic
objectives.  HSCM is currently has approximately 70 fixed term or seconded posts which can create long term instability
for teams. This is being reviewed by the Senior Management Team.
The Care Homes in Moray also face difficulties with recruitment and retention of staff to care at home roles in particular
is still being experienced.  Efforts are being made to provide support but the situation remains challenging. 
The transition from EU membership has not presented any specific concerns for workforce and this will continue to be
monitored. 
The impact of forthcoming budget allocations and the withdrawal of all Covid funding will also mean that HSCM will face
some challenging decisions in 2023.
The impact of budgetary decisions by the Council in relation to reducing staffing levels has reduced levels of support
provided in some key areas for Health and Social Care Moray (HSCM), such as ICT, HR, Legal and design.  
The lack of suitable housing for Health and Social Care staff has resulted in people not being able to take up posts in
Moray. 
Rationale for Risk
Appetite:
Safety risks that could result in harm to service users, staff or the public are inherent in Health & Social Care services.
The safety of individuals is paramount therefore standards of safety management and clinical care have to be high, and
the Board will continue to seek assurances this is the case. 
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Appendix 1 
The Board’s ambition is for health & social care to be people centred. This means supporting people in decision making
about their own health & care, which may expose individuals to higher risk where they make an informed decision. 
The Board will also seek to balance individual safety risks with collective safety risks to the community. 
Controls: Management structure in place with updates reported to the MIJB. 
Organisational Development plan in place and Workforce Plans are being updated to align to the new strategic plan. 
Continued activity to address specific recruitment and retention issues.   
Management competencies continue to be developed through Kings Fund training although this was suspended due to
Covid19.
Communications & Engagement Strategy was approved in November 2019 and continues.
Council and NHS performance systems in operation with HSCM reporting being further developed and information
relating to vacancies, turnover and staff absences is integral to this.  
Managers are highlighting any areas of concern and where appropriate this is identified in operational risk registers.
HSCM services have commenced weekly reporting of workforce sit reps for Senior Management Team oversight
highlighting vacancies, annual leave, sickness absence and Covid impacts so that issues can be identified and
assessed quickly.  
Moray Council are carrying out a study of accommodation needs, including people working in the Health and Care
sector.
Mitigating
Actions: 
System re-design and transformation.  
Organisational Development Plan and Workforce plan were updated and approved by MIJB in November 2019. The
updated Workforce plan has been submitted to Scottish Government and comments were received by the HSCP in
October 2022. These are currently being worked through.  These plans are core documents for the Workforce Forum
which has recently re-commenced following a temporary suspension during the first quarter of this year due to Covid
impact. 
Staff Wellbeing is a key focus and there are many initiatives being made available to all staff including training, support,
information and access to activities. 
Locality Managers are developing the Multi-disciplinary teams in their areas and some project officer support has been
provided to develop the locality planning model across Moray.
Lead Managers are involved in regional and national initiatives to ensure all learning is adopted to improve this position.
Lead Managers and Professional Leads are linked to University Planning for intakes and programmes for future
workforce development. 
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Appendix 1 
Assurances: Operational oversight by Moray Workforce Forum has resumed and will report to MIJB in accordance with the agreed
Governance framework.
The HSCM Response Group was in place over the whole period of the Covid19 pandemic providing focussed
leadership around emerging issues and resolving them.  This group stood up again in April and is meeting daily whilst
the system is pressured, this will be reviewed as the situation evolves.  The Heads of Service are co-ordinating and
escalate to SMT where necessary. These meetings have been increased as service needs dictate.
Gaps in
assurance:
Further work required to develop workforce plans to reflect strategic plan implementation programmes..
Current
performance: 
The IMatter survey results for 2022 were received by managers for review and action plans.  Preparatory work is
commencing on the action plans for iMatter 2023. 
Discussions are underway with HR in both Council and NHS to develop access to appropriate HR information at a
summarised level to facilitate the necessary workforce planning and subsequent monitoring of plans. 
There continues to be a need for more streamlining in recruitment processes as the delay in approval to recruit to having
a member of staff available is in excess of 8 weeks. 
There is also a lack of suitable applicants for various posts which is impacting on ability to appoint for some roles. 
Comments: Staffing issues are owned by the Systems Leadership Group who will work collaboratively across the system to seek
opportunities to make jobs more attractive where it has proved difficult to recruit in the past.   
For some professions there is a potential risk that staff move from one position to a new position within HSCM will just
move the vacancy to elsewhere in the system, so Senior Management Team are aware of this risk and taking it into
account in considerations for vacancies. This needs to be considered when fixed term contracts and secondments are
planned, consideration needs to be given to the whole of HSCM and not services in isolation. Many of our staff may have
transferrable skills and experience. 
The continuing system issues and lack of available beds may mean operations cannot be scheduled to reduce the backlog
and key staff may not have the necessary time in surgery to maintain essential skills.  This in turn may add to the staff
retention issues within certain specialties. 
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Appendix 1 
4
Description of
Risk: 
Reputation:
Inability to demonstrate effective governance and effective communication and engagement with stakeholders. 
Lead: Chief Officer
Risk Rating:  low/medium/high/very high MEDIUM
Risk Movement:  increase/decrease/no change NO CHANGE
Rationale for Risk
Rating: 
Locality planning assessed as medium in relation to ability to work at the pace required and current workforce capacity. 
Performance framework to be further developed from a planning perspective to show the links through operational
service delivery to strategic objectives. 
Recent engagement with individuals representing their communities or third sector organisations in a variety of forums
is highlighting that problems with their capacity to fulfil our needs so more co-ordination and clearer focus is required to
ensure that the communication, engagement and outcomes are meeting identified needs.
Rationale for Risk
Appetite:
The Board is cautious but open about risks that could damage relationships with different stakeholders. It recognises
many of our aspirations depend on effective collaboration, coproduction and partnership working with a range of
stakeholders. The appetite also recognises that while the aspiration is to be a co-operative partner, some partners will
not be able to move at the same pace as us all the time. 
We will seek to protect relationships in the long term and will not set out to antagonise stakeholders deliberately. For
example, we must not be seen to exclude or prevent participation in the design of services where there is an appetite to
do this.   
We must be mindful that repairing relationships is easier when there is already a well of goodwill to draw on, and that
further damage to an already damaged relationship will not be conducive to good long term outcomes. 
Controls: Governance Framework approved by IJB January 2021
Communication and Engagement Strategy approved November 2019
Annual Governance statement produced as part of the Annual Accounts 2021/22 and submitted to External Audit. 
Annual Performance Report for 2021/22 was published in November 2022.
Performance reporting mechanisms in place and being further developed through performance support team, home first
group and system leadership team.
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Appendix 1 
Community engagement in place for key projects areas such as Forres, Keith and Lossiemouth with information being
made available to stakeholders and the wider public via HSCM website.
Participation of stakeholders in a variety of meetings such as Home First project, carer strategy, Strategic, Planning and
Commissioning groups.
Mitigating
Actions: 
Schedule of Committee meetings and development days in place and implemented. 
Good working relationship established with Audit Scotland, the MIJB’s appointed external auditors since 2016/17.
Discussions at leadership meetings to ensure all standards are being met around Public Sector Equality Duty and
published where appropriate. There is a new programme of training to ensure all policies are Equalities Impact Assessed
and the findings are published. 
Annual Performance Report for 2022/23 will be published in July 2023 after being presented to the IJB in June 2023.
Social media is actively used as a method of engaging with the public, with short videos focussing on particular
services being trialled. 
SMT have considered the existing arrangements for engagement with stakeholders and work is being undertaken to
align our framework with the Scottish Government “Planning with people guidance” and ensure that mechanisms are in
place across services to evidence and evaluate their impact.
Assurances: Oversight and scrutiny by Clinical and Care Governance Committee, Audit Performance and Risk Committee and
MIJB.  
Summary reports of minutes of MIJB meetings are submitted to Council committee and NHS Board.
Gaps in
assurance:
Progress on implementation of the Communication and Engagement Strategy has been impacted by the Covid 19. 
Due to the impact of COVID and requirement for social distancing the normal mechanism for engagement were not all
available.  More use is being made of social media and Microsoft teams and other options and methods for
engagement with staff are being used via NHSG such as videos on YouTube and one question surveys. 
Going forward there may be more opportunity for face to face meetings to take place again but it should be considered
that this will not be beneficial for all. It is anticipated that once a Communication and Engagement Officer and
supporting role are recruited.that this work stream will rapidly restart as a priority.
Current
performance:
Communications Strategy was reviewed approved by IJB November 2019.
Annual Performance Report 2021/22 published November 2022.  Audited Accounts for 2021/22 were audited and
approved in January 2023 and will be published in February 2023. 
Due to Covid19 there have been increased levels of briefings to staff, the public and Chair/Vice Chair of MIJB with a
focus on the key elements of the response.  
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Appendix 1 
Comments: A communication cell was established as part of the Local Resilience Partnership Covid and storms response with
representation from Councils, HSCP and NHSG.  This was led by Aberdeen City Council and was an example of the
collaborative working that took place.  This forum provides assurance that messages to all stakeholders are consistent.   
There has been representation from the Home first project at the Wellbeing forum to facilitate sharing of information
and seeking views. 
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Appendix 1 
5
Description of
Risk: 
Environmental:
Inability to cope with unforeseen external emergencies or incidents as a result of inadequate emergency and resilience
planning. 
Lead: Chief Officer
Risk Rating:  low/medium/high/very high HIGH
Risk Movement:  increase/decrease/no change NO CHANGE
Rationale for Risk
Rating: 
Due to the response requirements for Covid 19 progress has been made in a number of areas.  SMOC information is
updated, control room guidance updated and expanded, control centre protocols were implemented and remain in place
and management teams have responded in an agile, responsive and collaborative way under very challenging conditions. 
Teams continue to do their best but there are areas where they still feeling overwhelmed and service delivery is
challenging. 
With effect from March 2021 MIJB is defined as a Category 1 responder under the Civil Contingencies (Scotland) Act
and there are additional requirements for preparedness that is being taken forward in partnership with NHSG and Moray
Council emergency planners.
Rationale for Risk
Appetite:
The MIJB understand the requirement to meet the statutory obligations set out within the Civil Contingencies Act and
the Category 1 status applied in March 2021, and work with partner organisations to meet these obligations.
Controls: Winter Preparedness Plan was updated (but not tested as in previous years) alongside NHSG plans as NHSG
implemented their crisis management framework which required participation of partners at Daily connect meetings to
discuss and prioritise resource to address issues with system flow.
HSCM Civil Contingencies group established and meeting regularly to address priority subjects.
NHS Grampian Resilience Standards Action Plan approved (3 year).
Business Continuity Plans in place for some services although overdue a review in some areas.
Knowledge of critical functions and ability to respond quickly and effectively has been in evidence during incidents such
as Gas outages in Keith (January and February 2021) and Covid response, Storms (Arwen, Malik and Corrie) – debriefs
carried out and learning identified.
A Resilience Newsletter started in December 2022 to ensure all staff receive some personal resilience information
together with resources for teams to plan.
Regular updates to SMT and SLG regarding potential power outages across the country. Additional sessions delivered
to Primary Care Contractors to assist with their Business Continuity Planning around power outages.
Regular system wide meetings to discuss potential Industrial Action implications and service planning. 
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Appendix 1 
A review of the Festive season arrangements has commenced and will conclude in March 2023. 
Mitigating
Actions: 
Information from the updated BIA/BCP informed elements of the Winter Preparedness Plan 
A Friday huddle is in place which gathers the status of services across the whole system to provide information and
contact details to the Senior Manager on Call (SMOC) over the weekend. If any potential issues are highlighted the
relevant Persons at Risk Data is compiled and if appropriate, shared with relevant personnel. 
NHSG have introduced system wide daily huddles to manage the flow and allocation of resources which require
attendance from Dr Grays and HSCM. 
Practitioner group established for Moray with representation from HSCM, Dr Grays, Moray Council and NHSG to
discuss matters arising from the Local Resilience Forum and within our respective organisations.  In addition it will
provide a forum for discussion of the linkages between organisational response plans to ensure there are no gaps or
over reliance on particular local resources. 
HSCM continues to monitor the local situation regarding impacts on staffing and is engaged with NHSG emergency
planning arrangements and Council Response and Recovery management team to be ready to escalate response if
required. Work was undertaken within NHSG, Aberdeenshire HSCP and Aberdeen City HSCP to look at Surge flows
and establish a mechanism that will provide easy identification of “hot spots” across the whole system in Grampian, to
facilitate a collaborative approach to addressing the issues through the use of a common Operational Pressure
Escalation approach.  This work could underpin surge responses in winter and at other times of pressure and having a
standard approach across Grampian could aid communication and understanding. 
Assurances: Audit, Performance and Risk Committee and NHS Grampian Civil Contingencies Group oversight and scrutiny.
HSCM Civil Contingencies group review specific risks and action plans to mitigate, developing plans and testing
arrangements in partnership with NHSG and Council
Gaps in
assurance:
Moray Integrated Joint Board (MIJB) was designated as a Category 1 responder under the Civil Contingencies Act 2004
from March 18th 2021. That designation imposed a number of statutory duties in terms of the Act and the associated
Scottish Regulations1.  MIJB has no dedicated, specialist in post and is reliant on the Corporate Manager covering this
increasingly demanding role in addition to other duties without the necessary background, knowledge, skills and
experience. This presents a potential organisational risk in terms of compliance, and our ability to provide assurance on
discharging our civil contingency arrangements. This has been highlighted to the Chief Officer and IJB. 
1 Civil Contingencies Act 2004 (Contingency Planning) (Scotland) Regulations 2005
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Appendix 1 
The debriefs from the storms in 2021/22 have identified lessons learnt for Grampian Local Resilience Partnership and
more locally for the response co-ordination within Moray.    Action plans are being developed in collaboration with Moray
Council’s emergency planning officer to address the issues identified.  The main issues related to developing wider
awareness of roles and responsibilities,   and improving general awareness of response structures and meeting protocols. 
This will be incorporated into training schedules going forward.  It has also highlighted the need for a robust arrangement
for out of hours contact and clarity of roles and responsibilities across the system which is being discussed at SMT.
Option Appraisal discussions have commenced. 
Progress has been made however further work is required to address the targets in the implementation plan that have
not been met and the Resilience standards as identified by the NHSG Civil Contingencies Group. 
Due on ongoing system pressures and staff vacancies the draft strategy document ‘Care for People’ document has been
presented to HSCM SMT for comment and will also be presented to CMT and  then MIJB. It is anticipated this will be
completed by end March 2023. A draft operational response plan has been drawn up and will also be presented for
approval shortly after. 
The intention is to hold a table top exercise with managers from HSCM and Moray Council to test the invocation
arrangements to ensure common understanding of roles and responsibilities.
Table top style exercises are currently being arranged with some of those services who have submitted their finalised
Business Continuity plans for February 2023.
Current
performance:
The Senior Management Team participated in Strategic Leadership in a Crisis training in 2020 and a programme of
further training for the wider management team is scheduled. A follow up session was held in September 2022. 
Many services have business continuity arrangements and some are overdue for an update.  Work has progressed in
identification of a critical functions list for agreement by System Leadership Group that will inform planning
arrangements going forward.  There will need to be changes made to business continuity plans following the
implementation of additional ICT resources in services which have provided a greater deal of resilience for some
services and functions – albeit reliant on electricity supply.  A schedule of review and exercising of business impact
assessments and plans has been scheduled for this year across services. All services have been requested to prioritise
their Business Continuity planning with a particular lens on power outages. 
Annual report on progress against NHS resilience standards will be presented to the APR committee on 30 March
2023. 
Report on the implications of the designation as a Category 1 responder was presented to MIJB 25 November 2021.
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Appendix 1 
Work is currently underway to plan for possible National Power Outages across the UK. This is being co-ordinated
across Grampian to ensure all Partners are involved. It is also planned to provide additional resource to ensure our
Primary Care partners are informed and engaged in the process. 
Comments: The requirements of a Category 1 Responder continue to increase in demand placing increased pressures across
already overstretched services and managers. MIJB does not have a subject matter expert leading on these topics.  
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Appendix 1 
6
Description of
Risk: 
Regulatory
Risk to MIJB decisions resulting in litigation/judicial review.  Expectations from external inspections are not met.
Lead: Chief Officer
Risk Rating:  low/medium/high/very high MEDIUM
Risk Movement:  increase/decrease/no change NO CHANGE
Rationale for Risk
Rating: 
Considered medium risk due to the impact of Covid-19 and resultant efforts required to remobilise services and/or the
increase in workloads stretching a workforce that has been under sustained pressure for a considerable time. 
The ongoing impact of the Covid 19 pandemic is stretching resources to deliver care in the community across all
providers (internal and external) so there is a potential increased risk of expected standards not being achieved despite
the best efforts of all concerned.     
Rationale for Risk
Appetite: 
The Board, staff and providers across Moray are all committed to ensuring high standards of clinical care & governance
through operational policies.  Innovation and new ways of working may mean traditional regulations do not exist and
require to be developed, no longer apply, or are contradictory. 
We will only take regulatory risks knowingly, following consultation with the relevant regulatory body and where we have
clear risk mitigation in place. 
Controls: Clinical and Care Governance (CCG) Committee established and future reporting requirements identified
Clinical Risk Management and Practice Governance group has oversight of their respective professional standards and
feed into Clinical and Care Governance Group, which then escalates to CCG Committee as necessary.
High and Very High operational risks are reviewed by System Leadership Group monthly and a review of all risks will be
undertaken as part of the risk management framework.
Workshops took place in January and February 2023, ‘A conversation about Clinical Governance’. This will be followed
by 2 more workshops in 2023. 
Complaints and compliments procedures in place and monitored.   
Clinical incidents and risks are being reviewed on a weekly basis to ensure processes are followed appropriately and
consistently and responses are recorded in a timely manner.
Adverse events and duty of candour procedures in place and being actioned where appropriate and summary reports
submitted to CCG committee.
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Appendix 1 
Reports from external inspections reported to appropriate operational groups and by exception to SMT for subsequent
reporting to CCG or Audit Performance and Risk Committee as appropriate, albeit there has been a reduction in some
areas of external inspection reporting during the Covid period due to social distancing restrictions 
Care Home Oversight Group meets to oversee and manage risks in care homes.
Children and Adult Protection services are being delivered and reported to their respective committee on a regular basis.
Mitigating
Actions: 
This risk is discussed regularly by the three North East Chief Officers. 
Additional resource has been allocated to support the analysis of information for presentation to CCG committee
All High and Very High risks are now brought before the senior management team in Moray. 
Process for sign off and monitoring actions arising from Internal and External audits has been agreed
Assurances: Audit, Performance and Risk and Clinical and Care Governance Sub-Committees oversight and scrutiny.
Governance Framework in place and operational. 
Gaps in
assurance:
Process for highlighting recurring themes or strategic expectations from external inspections requires further development
to ensure Committee has sight of significant issues. 
Current
performance:
External inspection reports are reviewed and actions arising are allocated to officers for taking forward. 
Two Days of Audit took place across Moray on 25th and 26th January, 2023 respectively. These were led by the Clinical
Service Leads. An update on this will be provided to MIJB on 30th March 2023, with a report going to the Clinical and
Care Governance Group in due course. 
A summary of inspections is included in the Annual Performance report.   
The level is marked as an increasing risk on the basis that services are under pressure with the issues with staffing
capacity and the need to focus on delivery of critical functions which may mean external inspection are not the priority
at this moment in time. 
The Adult Support Protection inspection took place in April/May and an action plan has been developed and is now in
place. 
Comments: No major concerns have been identified for HSCM services in any audits or inspections during 2021/22. 
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Appendix 1 
7
Description of
Risk: 
Operational
Continuity and
Performance:
Inability to achieve progress in relation to national Health and Wellbeing Outcomes.   
Performance of services falls below acceptable level.
Lead: Chief Officer
Risk Rating:  low/medium/high/very high HIGH
Risk Movement:  increase/decrease/no change NO CHANGE
Rationale for Risk
Rating: 
Potential impacts to the wide range of services in NHS Grampian and Moray Council commissioned by the MIJB arising
from reductions in available staff resources as budgetary constraints impact. 
Unplanned admissions and delayed discharges place additional cost and capacity burdens on the service.   
The level of delayed discharges has remained high, reflecting the sustained pressure in the system following the  Covid
-19 pandemic impact and the lack of availability of care in the community.  There are sustained focussed and collective
efforts by all those working in the pathway.  However this is a complex area and will require continued effort to realise
reductions and maintain them.   
Rationale for Risk
Appetite: 
The Board is cautious but open about risks that could affect outcomes that are priorities for people in Moray. There is a
slightly higher appetite to risks that may mean nationally set outcomes – that by design are not given a high priority in
Moray - are not met. There is new focus on addressing positive risk taking to ensure the most appropriate and timely
measure of care for the population of Moray, this is being supported through various work streams across the system. 
This will only be accepted where there is a clear rationale, and preferably also a way of demonstrating what the IJB is
doing to meet the aspiration the outcome was created for. 
Controls: Performance Management reporting framework. 
2022 to 2032 “Partners in Care” Strategic Plan was approved and development of delivery plan is underway.
Performance is regularly reported to MIJB. Revised Scorecard being developed to align to the new strategic priorities.
Best practice elements from each body brought together to mitigate risks to MIJB’s objectives and outcomes.
Chief Officer and SMT managing workload pressures as part of budget process.
A daily Huddle and write up circulates the picture on performance across community and acute services for the
Portfolio and  service managers have a shared understanding of the pressures in the system and mitigations taking
place.  Work continues on  refinement of G-OPES (Grampian Operating Pressures and Escalation System) led by
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Appendix 1 
NHSG but being developed locally to identify the triggers and resultant actions required in services to respond to
pressure points.
Mitigating
Actions: 
Service managers monitor performance regularly with their teams and escalate any issues to the System Leadership
Group (SLG) for further discussion to provide wider support, developing shared ownership and a greater understanding
across the whole system.   
Key operational performance data is collated and circulated daily to all managers.  A  Daily dashboard is held on
illuminate for managers to access to ensure any potential issues are identified quickly so action can be taken.  This
dashboard is being reviewed and will be further developed with the intention of further dashboards to provide a whole
system overview.  This has been discussed at SLG and agreed. 
Performance information is presented to the Performance sub group of Practice Governance Group to inform Social
Care managers of the trends in service demands so that resources can be allocated appropriately. 
Assurances: Audit, Performance and Risk Committee oversight. 
Operationally managed by service managers, summary reports to Practice Governance and clinical and care
governance group and to System Leadership Group.  Strategic direction provided by Senior Management Team. 
HSCM Response Group continues to meet and reviews the key performance information and actions that are required
to deliver the priority services.
Gaps in
assurance:
Development work in performance to establish clear links to describe the changes proposed by actions identified in the
Strategic Plan has recommenced but is at an early stage.  This will be progressed as the revised outcomes are
determined and associated KPI are identified.  Progress will be reported to future Board meetings.
Review of systems and processes will commence across HSCM to ensure they are fit for purpose and ensure that
there are no indirect consequences of structure changes resulting in any gaps in assurance processes. 
Current
performance:
The Covid19 pandemic impacted on all areas of the service and work is underway to take the learning and experience
gained during the response to collate performance information in dashboards to support mangers interpret the impact
of Covid19 on their services, now and going forward.
There are likely to be changes to ways of working and this may also have impact on the performance information
required. 
Comments: Locality profile information has been provided to Locality Steering Group/Locality Manager to inform potential priorities
for consideration in Localities and work will be taken forward regarding development of performance monitoring and
reporting of key performance indicators in relation to Localities once it has been determined what the intended
outcomes are.  Locality plans will be presented to the IJB in March 2023. 
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Appendix 1 
The delayed discharge group has produced an action plan for implementation and progress is being made.  
Practice Governance have reviewed their operational performance requirements and have a comprehensive data set
used to inform operational priorities.
The Home First priorities are being taken forward and updates are reported to this committee or MIJB on a regular
basis. 
Progress in this area has been hampered due to the increased demand for urgent or critical services requiring staff
resource to be prioritised to frontline service delivery. 
The Council has procured new modules for their performance reporting system Pentana and HSCM performance team
have been developing its use for reporting. 
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Appendix 1 
8
Description of
Risk: 
Transformation
Inability to progress with delivery of Strategic Objectives and Transformation projects. 
Lead: Chief Officer
Risk Rating:  low/medium/high/very high HIGH
Risk Movement:  increase/decrease/no change NO CHANGE
Rationale for Risk
Rating: 
There are many issues that will impact on the ability to progress to deliver Strategic Objectives. 
The Strategic Planning & Commissioning group has been refreshed and re-launched and key work is being progressed. 
There was an initial meeting held on 22 September 2021 to consider terms of reference and the proposed structure for
oversight, prioritisation and assurance in relation to key developments, their fit with IJB strategy and enabling elements. 
The interim appointment of the Strategic and Planning Lead provides capacity to take this forward and to align the
priorities arising nationally, Grampian-wide and locally. 
The remobilisation plan for HSCM services that were suspended or reduced is progressing with Providers services and
social work implementing the IJB decision to return to delivery of both substantial and critical eligibility criteria.  Work has
progressed risk assessments are completed and assessments have been or are in the process of being reviewed to
ensure equality.   
The impact of Covid 19 on the population of Moray is still not fully realised.  It is therefore not possible to predict the
extent of the impact on the ability to progress with delivery of Strategic Objectives.  There are some aspects that have
progressed very well such as introduction of Near Me consultations but there are others that are more difficult to progress. 
There is concern that due to the workloads and challenges over the last year that teams are weary and/or do not have
capacity at this moment in time, to progress with delivery of development plans at this moment in time.  In addition the
pandemic is still present in the community so services are still responding to the impacts it has for the population of
Moray.  Managers are working with teams to establish “readiness” and their capacity and sense of wellbeing and the
collated output will inform plans going forward. 
One key aspect to facilitate transformation is the need for progress in relation to ICT infrastructure, data sharing and data
security across the whole system.   Work was undertaken by NHS Grampian and partners to address the needs for ICT
kit and information during the response to Covid. 
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Appendix 1 
Rationale for Risk
Appetite:
The Board has a high appetite for risks associated with delivery of transformational redesign. The following should be
considered when accepting these risks:
• We understand and can mitigate other risk types that may arise, e.g. safety or financial within appetite 
• Service users are consulted and informed of changes in an open & transparent way 
• We will monitor the outcome and change course if necessary   
Controls: It is recognised that there will be significant changes taking place in Social Work practice with the implementation of the
Self Directed Support standards and the move to outcomes based services, so governance arrangements are being set
up to facilitate the same type of oversight and communication that is in place for the Home First programme. 
Mitigating
Actions: 
Integrated Infrastructure Group previously established, with ICT representation from NHSG and Moray Council, to
consider and provide solutions to data sharing issues and ICT infrastructure matters which is an area that will be taken
forward alongside the Moray Growth Deal projects.  The Moray Transformation Board has recently restarted and will
link to all relevant groups. 
Assurances: Strict ICT and data sharing policies and protocols in place with NHS Grampian and Moray Council. 
Gaps in
assurance:
Transformation/implementation planning is in development and will inform outcomes and performance reporting on the
delivery of the strategic plan.
Protocol for access to systems by employees of partner bodies are in place.
Information Management arrangements to be developed and endorsed by MIJB.
Process of identification of issue and submission to data sharing group requires to be reinforced to ensure matters are
progressed.
The strict information sharing protocols can cause issues when trying to work across system in an open and
transparent way.
Smarter Working programmes are being progressed in partnership with Council and NHSG.
Current
performance:
Training programme to be developed on records management, data protection and related issues for staff working
across and between partners.   
Comments: Where national systems are involved it may not be possible to identify a solution however the issues will be able to be
raised at the appropriate level via the Grampian Data Sharing Group where all three partnerships are represented. 
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Appendix 1 
9
Description of
Risk: 
Infrastructure
Requirements for support services are not prioritised by NHS Grampian and Moray Council.
Lead: Chief Officer
Risk Rating:  low/medium/high/very high HIGH
Risk Movement:  increase/decrease/no change NO CHANGE
Rationale for Risk
Rating: 
Changes to processes and necessary stakeholder buy-in still bedding in. 
Moray Council is undertaking a Property review of office and depot accommodation and the potential impact for HSCM
services requires consideration.  The output was anticipated in October 2019 however due to changes with roles and
responsibilities within the Council however the paper has been out for consultation. NHSG have advised that staff should
continue to work from home at present whilst policies and protocols are developed.  Moray Council have a dedicated MC
officer leading on a hybrid working plan with input from HSCM on their requirements. It is anticipated that this will  conclude
end 2023. 
ICT infrastructure service plans in NHS Grampian and Moray Council are not yet visible to HSCM and development of
communication and engagement process is required. 
The impact of Covid has resulted in a change in ICT strategy for Moray Council.  Council employed staff requiring mobile
technology have now been provided with it and some staff are still working from home.
Rationale for Risk
Appetite: 
Low tolerance in relation to not meeting requirements.
Controls: Chief Officer has regular meetings with partners
Computer Use Policies and HR policies in place for NHS and Moray Council and staff. 
PSN accreditation secured by Moray Council 
Infrastructure Programme Board was established with Chief Officer as Senior Responsible Officer/Chief Officer
member of CMT. Process for submission of projects to the infrastructure board approved and implemented to ensure
appropriate oversight of all projects underway in HSCM.  The Board has only recently restarted, so in the interim,
project requests are being processed via Senior Management Team. The interim Strategy and Planning Lead will
support the Infrastructure Programme Board for Moray portfolio. 
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Appendix 1 
Mitigating
Actions: 
Membership of the Board was reviewed and revised to ensure representation of all existing infrastructure processes and
funding opportunities.
Process for ensuring infrastructure change/investment requests developed
Dr Gray’s strategy (vision for the future) is being produced collaboratively with input from NHSG and HSCM
management. 
Assurances: Infrastructure Programme Board functions to provide robust governance and assurance that proposed projects have a
robust business case and meets requirements of the respective partner organisations.  This board reports to Strategic
Planning and Commissioning Group.  Both of these groups have been recently  refreshed and remobilised. 
Workforce Forum meeting regularly with representation of HR and unions from both partner organisations 
Gaps in
assurance:
Further work is required on developing the process for approval for projects so that they are progressed timeously.
Need to review all existing processes in relation to infrastructure changes/projects/investments and streamline to avoid
duplication of effort. 
Infrastructure Board is in development and priority issues are being addressed in relation to infrastructure and premises
risk. Due to staff changes this work will now be incorporated into other roles. This will likely mean that this work will
complete with other priorities of already busy roles. 
Legal services have reduced capacity to provide support due to budget cuts and vacancies so any requests may take
longer. 
Recruitment for vacancies takes considerable time due to various factors and is presenting a strain on services to maintain
normal service whilst covering vacancies.  There have been several posts that have had to go out to advert more than
once extending the time other staff are covering gaps. 
Current
performance:
No update.
Comments: Existing projects will be reviewed as part of the development of the transformation plans for the Strategic Plan to
ensure resources are being dedicated appropriately and aligned to the emerging Strategic priorities.  Our requirements
for support will be communicated via appropriate channels 
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REPORT TO: MORAY INTEGRATION JOINT BOARD AUDIT, PERFORMANCE
AND RISK COMMITTEE ON 30 MARCH 2023 
SUBJECT: EXTERNAL AUDIT PLAN FOR THE YEAR ENDING 2022/23 
BY:  CHIEF FINANCIAL OFFICER 
1. REASON FOR REPORT 
1.1. To inform the Committee of the Auditor’s Annual Plan for 2022/23. 
2. RECOMMENDATION 
2.1 It is recommended that the Audit, Performance and Risk Committee
considers and notes the contents of the External Auditor’s Annual Plan
for 2022/23. 
3. BACKGROUND 
3.1. In September 2022, Grant Thornton was confirmed as the external auditor of
the Moray Integration Joint Board (MIJB).  The appointment was for financial
years 2022/23 to 2026/27 inclusive.    
3.2. Grant Thornton were appointed by the Accounts Commission to deliver the
public audit for Moray, they will provide independent assurance to the people of
Scotland that public money is spent appropriately and provides value.  Audit
work is carried out in accordance with International Standards on Auditing, the
Code of Audit Practice https://www.audit-scotland.gov.uk/publications/code-of-
audit-practice-2021 and any other relevant guidance. 
4. KEY MATTERS RELEVANT TO RECOMMENDATION 
4.1. An Annual Audit Plan for 2022/23 has been received from Grant Thornton and
is attached at APPENDIX 1 to this report. The Plan sets out the scope of the
audit work and the auditors approach to the audit. The Plan details the initial
risks identified by Grant Thornton and planned work to be undertaken for the
audit of the financial statements for the year ending 2022/23.  Grant Thornton
also aim to add value to the MIJB through its work.
Item 8.
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4.2. The Audit Plan identifies the main risks for the MIJB which will be the focus of
audit testing and are outlined in page 9 of the Plan. In order to assist with the
assessment of risk, an Informing the Audit Risk Assessment was completed by
senior managers and is attached at APPENDIX 2. 
4.3. On page 5 of the Audit Plan, Grant Thornton has shown the External Audit fee
for 2022/23 as being £31,470 and represents a 15% increase on the previous
year. 
4.4. The annual accounts timetable, including key deadlines are shown on page 7 of
the audit plan and requires the MIJB to submit the Unaudited Annual Accounts
along with supporting working papers to Grant Thornton by 30 June 2023
following consideration by those charged with governance at the meeting of the
MIJB on 29 June 2023.  The MIJB will be asked to approve the audited annual
accounts and to consider the Annual Audit Report at its meeting of 28
September 2023. 
5. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP)) and MIJB Strategic Commissioning Plan ‘Partners in
Care’ 2022 – 2032 
The work undertaken by External Audit seeks to provide assurance to
the MIJB on the financial governance and resource management.  It will
express a view on the key risks to be managed in order to secure
operational efficiency in line with the Strategic Plan 2019 - 29. 
(b) Policy and Legal 
The external audit is conducted in terms of statutory powers afforded to
the appointed External Auditor and in accordance with Grant Thorntons
Code of Practice. 
(c) Financial implications 
The annual audit fee set for 2022/23 by Grant Thornton and paid by the
MIJB is £31,470. 
(d) Risk Implications and Mitigation 
The risks associated with the Audit Plan have been identified and
categorised within the Plan on page 9. 
(e) Staffing Implications 
Preparation of the MIJB’s financial statements will require input and
coordination from the MIJB Chief Financial Officer and the finance teams
of both Moray Council and NHS Grampian which forms part of the
scheduled work. 
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(f) Property 
None arising directly from this report. 
(g) Equalities/Socio Economic Impact 
None arising directly from this report as there has been no change to
policy. 
(h) Climate Change and Biodiversity Impacts 
None arising directly from this report. 
(i) Directions 
None arising directly from this report. 
(j) Consultations 
The content of the Plan has been discussed with the Chief Officer, Chief
Internal Auditor and Senior Managers prior to production and their
comments have been incorporated where appropriate. 
6. CONCLUSION 
6.1. The Annual Audit Plan informs the MIJB, its Committees and officers of
the work to be undertaken by External Audit (Grant Thornton) in the
year ahead. 
Author of Report: Deborah O’Shea
Background Papers:  with author
Ref: 
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APPENDIX 1
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Informing the audit risk assessment
for Moray IJB
2022/23
Angela Pieri
Director
T 0161 214 6337
E Angela.L.Pieri@uk.gt.com
Hannah McKellar
Manager
T 0131 659 8569
E Hannah.L.McKellar@uk.gt.com
APPENDIX 2
Item 8.
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© 2023 Grant Thornton UK LLP | Moray IJB 2022/23
Commercial in confidence
The contents of this report relate only to the matters which have come to our attention, which
we believe need to be reported to you as part of our audit process.  It is not a comprehensive
record of all the relevant matters, which may be subject to change, and in particular we cannot
be held responsible to you for reporting all of the risks which may affect your business or any
weaknesses in your internal controls.  This report has been prepared solely for your benefit and
should not be quoted in whole or in part without our prior written consent. We do not accept any
responsibility for any loss occasioned to any third party acting, or refraining from acting on the
basis of the content of this report, as this report was not prepared for, nor intended for, any
other purpose.
2
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© 2023 Grant Thornton UK LLP | Moray IJB 2022/23
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Table of Contents
Section Page
Purpose 4
General Enquiries of Management 6
Fraud 9
Fraud Risk Assessment 10
Laws and Regulations 15
Impact of Laws and Regulations 16
Related Parties 18
Going Concern 20
Accounting Estimates                                                                                            22
Accounting Estimates - General Enquiries of Management 23
Appendix A – Accounting Estimates 26
3
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© 2023 Grant Thornton UK LLP | Moray IJB 2022/23
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Purpose
The purpose of this report is to contribute towards the effective two-way communication between Moray IJB’s external auditors and Moray IJB’s
Audit, Performance and Risk Committee, as 'those charged with governance'. The report covers some important areas of the auditor risk
assessment where we are required to make inquiries of the Audit, Performance and Risk Committee under auditing standards.  
Background
Under International Standards on Auditing (UK), (ISA(UK)) auditors have specific responsibilities to communicate with the Audit, Risk and Assurance
Committee. ISA(UK) emphasise the importance of two-way communication between the auditor and the Audit, Performance and Risk Committee
and also specify matters that should be communicated.
This two-way communication assists both the auditor and the Audit, Performance and Risk Committee in understanding matters relating to the audit
and developing a constructive working relationship. It also enables the auditor to obtain information relevant to the audit from the Audit, Performance
and Risk Committee and supports Audit, Performance and Risk Committee in fulfilling its responsibilities in relation to the financial reporting process.
Communication
As part of our risk assessment procedures we are required to obtain an understanding of management processes and the Authority’s oversight of the
following areas:
• General Enquiries of Management
• Fraud,
• Laws and Regulations,
• Related Parties,
• Going Concern, and
• Accounting Estimates.
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Purpose
This report includes a series of questions on each of these areas and the response we have received from Moray IJB’s management. The Audit,
Performance and Risk Committee should consider whether these responses are consistent with its understanding and whether there are any further
comments it wishes to make.
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General Enquiries of Management
Question Management response
1. What do you regard as the key events or issues that
will have a significant impact on the financial statements
for 2022/23? 
Clawback/ repayment of ear marked reserves brought forward by Scottish Government
2. Have you considered the appropriateness of the
accounting policies adopted by Moray IJB?
Have there been any events or transactions that may
cause you to change or adopt new accounting policies?
If so, what are they?
Accounting Policies are reviewed each year as the Accounts are prepared and changes incorporated where
deemed necessary.
No changes to accounting policies are anticipated for the 2022/23 accounts
3. Is there any use of financial instruments, including
derivatives? If so, please explain No
4. Are you aware of any significant transactions outside
the normal course of business? If so, what are they? Not aware of any significant transactions
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General Enquiries of Management
Question Management response
5. Are you aware of any changes in circumstances that
would lead to impairment of non-current assets? If so,
what are they?
N/A
6. Are you aware of any guarantee contracts? If so,
please provide further details N/A
7. Are you aware of the existence of loss contingencies
and/or un-asserted claims that may affect the financial
statements? If so, please provide further details
N/A
8. Other than in house solicitors, can you provide details
of those solicitors utilised by Moray IJB during the year.
Please indicate where they are working on open
litigation or contingencies from prior years?
Brodies solicitors for the scheme of integration update
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General Enquiries of Management
Question Management response
9. Have any of the Moray IJB’s service providers
reported any items of fraud, non-compliance with laws
and regulations or uncorrected misstatements which
would affect the financial statements? If so, please
provide further details
Not aware of any instances of fraud
10. Can you provide details of other advisors consulted
during the year and the issue on which they were
consulted?
KPMG for audit on Commissioning service
11. Have you considered and identified assets for which
expected credit loss provisions may be required under
IFRS 9, such as debtors (including loans) and
investments? If so, please provide further details
N/A
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Fraud
Matters in relation to fraud
ISA (UK) 240 covers auditors responsibilities relating to fraud in an audit of financial statements.
The primary responsibility to prevent and detect fraud rests with both the Audit, Performance and Risk Committee and management.
Management, with the oversight of the Audit, Performance and Risk Committee, needs to ensure a strong emphasis on fraud prevention
and deterrence and encourage a culture of honest and ethical behaviour. As part of its oversight, the Audit, Performance and Risk
Committee should consider the potential for override of controls and inappropriate influence over the financial reporting process.
As Moray IJB’s external auditor, we are responsible for obtaining reasonable assurance that the financial statements are free from material
misstatement due to fraud or error. We are required to maintain professional scepticism throughout the audit, considering the potential for
management override of controls.
As part of our audit risk assessment procedures we are required to consider risks of fraud. This includes considering the arrangements
management has put in place with regard to fraud risks including:
• assessment that the financial statements could be materially misstated due to fraud,
• process for identifying and responding to risks of fraud, including any identified specific risks,
• communication with the Audit, Performance and Risk Committee regarding its processes for identifying and responding to risks of fraud,
and
• communication to employees regarding business practices and ethical behaviour.
We need to understand how the Audit, Performance and Risk Committee oversees the above processes. We are also required to make
inquiries of both management and the Audit, Performance and Risk Committee as to their knowledge of any actual, suspected or alleged
fraud. These areas have been set out in the fraud risk assessment questions below together with responses from Moray IJB’s management.
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Fraud risk assessment
Question Management response
1. Has Moray IJB assessed the risk of material
misstatement in the financial statements due to fraud?
How has the process of identifying and responding to
the risk of fraud been undertaken and what are the
results of this process?
How do Moray IJB’s risk management processes link to
financial reporting?
The MIJB has established risk management, governance and operating procedures to mitigate the risk
of material misstatement in the financial statements.
Agreed arrangements within the NHS for the investigation of fraud. In regard to the Council,  Financial
Regulations detail that all staff irregularities should be reported to the Audit and Risk Manager.(MIJB
Chief Internal Auditor). This is supported by the Policy to Combat Fraud, Theft, Bribery and Corruption
and the Whistleblowing Policy. In addition, the Council participates in the National Fraud Initiative data
matching exercise and also publicises a point of contact to report fraud or irregularities involving the
misuse of council resources. All irregularities and system reviews will be reported to the Audit,
Performance and Risk Committee.
The corporate risk register detailing the MIJB’s principal risks are regularly reviewed by SMT, with an
annual report provided to MIJB Board. Services are also required to maintain risk registers detailing
identifiable risks and mitigating actions/controls. In addition, the Chief Internal Auditor (MIJB) also
prepares a risk-based audit plan that considers the IJB’s strategic objectives, associated risks and
senior management's view.
2. What have you determined to be the classes of
accounts, transactions and disclosures most at risk to
fraud?
Risk registers are also maintained by the parent organisations. Internal Audit will also review and test
transactions to ensure compliance with Council Regulations and  Procedures. The use of IDEA, a
computer assisted software system is used to analyse and select a sample for testing.
3. Are you aware of any instances of actual, suspected
or alleged fraud, errors or other irregularities either
within Moray IJB as a whole, or within specific
departments since 1 April 2022? If so, please provide
No irregularity known below the £5000 reporting threshold10
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Fraud risk assessment
Question Management response
4. As a management team, how do you communicate
risk issues (including fraud) to those charged with
governance?                                                                                        
Both the NHS and the Council have their own regulations regarding fraud. The NHS Counter Fraud
Authority (NHSCFA) is a health authority charged with identifying, investigating and preventing fraud and
other economic crimes within the NHS and the wider health group. The Council’s Financial Regulations
require that all irregularities be reported to the Audit and Risk Manager. The Audit and Risk Manager is also
responsible for supporting the Council’s risk management arrangements which includes regularly reviewing
the principal risks facing the Council.
Principal risks facing the MIJB are reviewed regularly by SMT and the corporate risk register is the
accordingly updated
5. Have you identified any specific fraud risks? If so,
please provide details
Do you have any concerns there are areas that are at
risk of fraud?
Are there particular locations within Moray IJB where
fraud is more likely to  occur?
Yes. Specific concerns have been raised regarding the threat of a successful cyber attack, resulting in a
report to the Audit, Risk and Performance Committee with recommendations to improve existing controls. As
part of the risk-based approach to preparing the Annual Audit Plan the Chief Internal Auditor of the MIJB will
consider fraud risks in determining the reviews to be undertaken. However, this only relates to Council
funded services.
6. What processes do Moray IJB have in place to
identify and respond to risks of fraud? The NHS Counter Fraud Authority (NHSCFA) is responsible for identifying, investigating and preventing
fraud within the NHS.
The Council Financial Regulations detail that irregularities should be reported to the Audit and Risk
Manager. This is supported by the Policy to Combat Fraud, Theft, Bribery and Corruption and the
Whistleblowing Policy. In addition, the Council participates in the National Fraud Initiative data matching
exercise and also publicises a point of contact to report fraud or irregularities involving the misuse of council
resources.
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Fraud risk assessment
Question Management response
7. How do you assess the overall control environment for Moray
IJB, including:
• the existence of internal controls, including segregation of
duties; and
• the process for reviewing the effectiveness the system of
internal control? 
If internal controls are not in place or not effective where are the
risk areas and what mitigating actions have been taken?
What other controls are in place to help prevent, deter or detect
fraud?
Are there any areas where there is a potential for override of
controls or inappropriate influence over the financial reporting
process (for example because of undue pressure to achieve
financial targets)? If so, please provide details
The responsibility for developing and maintaining sound control environment rests with
management. However, internal audit prepares a risk based audit plan which considers
the MIJB’s strategic objectives and associated risks. While the prevention of fraud and
error rests with management through the design and operation of suitable systems of
control, reviews undertaken by Internal Audit will make recommendations to improve the
control environment.
All officers are required to adhere to agreed policies and regulations.
8. Are there any areas where there is potential for misreporting? If
so, please provide details None noted
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Fraud risk assessment
Question Management response
9. How does Moray IJB communicate and
encourage ethical behaviours and business
processes of it’s staff and contractors?
How do you encourage staff to report their concerns
about fraud?
What concerns are staff expected to report about
fraud? Have any significant issues been reported? If
so, please provide details
Established arrangements exist to communicate and encourage ethical behaviours and business
processes of its staff and contractors. Managers have an ongoing responsibility for implementing
effective systems of control which secure the legitimacy of expenditure, the safeguarding of assets and
income, the reliability of management information, the accuracy of record keeping and compliance with
statutory guidance. They are also responsible for communicating this policy to their staff and ensuring
established systems are followed.
As detailed, the NHS Counter Fraud Authority (NHSCFA) is responsible for identifying, investigating and
preventing fraud and other economic crimes within the NHS and the wider health group. The Council has
a Policy to Combat Fraud, Theft, Bribery and Corruption. This policy is built around a counter fraud
culture supported by practices to deter and detect fraudulent and corrupt activities. It takes account of
the Council’s statutory obligations, including, and in particular, the provisions of the Bribery Act 2010.
Council Financial Regulations detail that all irregularities should be reported to the Audit and Risk
Manager. In addition, a Confidential ‘whistle blowing’ policy and procedure is in place, enabling
employees to raise any concerns about any aspect of the Council’s work without fear of victimisation,
subsequent discrimination or disadvantage, and in the knowledge that such concerns will be properly
investigated
10. From a fraud and corruption perspective, what
are considered to be high-risk posts?
How are the risks relating to these posts identified,
assessed and managed?
There is an expectation that all staff and elected board members will act within the law and with honesty
and integrity at all times. In particular, all staff and elected board members are expected to refrain from
engaging in fraudulent or corrupt activity of any kind and shall refrain from offering, making or accepting
bribes, whether financial or otherwise.
Governance standards promote values and behaviours for the MIJB that demonstrate how it will uphold
good practice and high standards of conduct. These include codes of conduct for both elected board
members and employees and reflect the principles of public life identified by the Nolan Committee,
including selflessness, honesty and integrity. This also takes in the Duty (Public Service) and Respect
principles added by the Scottish Government.
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Fraud risk assessment
Question Management response
12. What arrangements are in place to report fraud
issues and risks to the Audit, Performance and Risk
Committee?
How does the Audit, Performance and Risk
Committee exercise oversight over management's
processes for identifying and responding to risks of
fraud and breaches of internal control?
What has been the outcome of these arrangements
so far this year?
The Public Sector Internal Audit Standards (PSIAS) applicable to Local Government in Scotland
requires Internal Audit to report functionally to the Audit, Performance and Risk Committee on various
issues relative to the work of the Internal Audit Service, including special investigations.
The Audit, Performance and Risk Committee has a remit which includes ensuring that the highest
standards of probity and public accountability are demonstrated. This involves oversight of internal
control processes as a contribution to good governance and generally supporting an anti-fraud, theft,
corruption, and bribery culture. This Committee considers reports produced by Internal and External
Audit on the IJB’s systems; reports which include recommendations to strengthen internal controls and in
turn reduce the risk of fraud and related behaviours going undetected.
13. Are you aware of any whistle blowing potential
or complaints by potential whistle blowers? If so,
what has been your response?
None noted
14. Have any reports been made under the Bribery
Act? If so, please provide details
None noted
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Law and regulations
Matters in relation to laws and regulations
ISA (UK) 250 requires us to consider the impact of laws and regulations in an audit of the financial statements.
Management, with the oversight of the Audit, Performance and Risk Committee, is responsible for ensuring that Moray IJB’s operations are
conducted in accordance with laws and regulations, including those that determine amounts in the financial statements.
As auditor, we are responsible for obtaining reasonable assurance that the financial statements are free from material misstatement due to fraud or
error, taking into account the appropriate legal and regulatory framework. As part of our risk assessment procedures we are required to make
inquiries of management and the Audit, Performance and Risk Committee as to whether the body is in compliance with laws and regulations.
Where we become aware of non-compliance or suspected non-compliance we need to gain an understanding of the non-compliance and the
possible effect on the financial statements.
Risk assessment questions have been set out below together with responses from management.
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Impact of laws and regulations
Question Management response
1. How does management gain assurance that all relevant laws
and regulations have been complied with?
What arrangements does Moray IJB have in place to prevent
and detect non-compliance with laws and regulations?
Are you aware of any changes to the Authority’s regulatory
environment that may have a significant impact on the
Authority’s financial statements?
Generally speaking each service area are familiar with the statutory regime in which they
operate and will keep up to speed with developments through their professional associations
such as CIPFA or SOLAR.
Changes to legislation, consultations and guidance are notified to the IJB by the Scottish
Government and are distributed to the relevant departmental area.
The legal section has teams which specialise in different areas of Council activity and will be
involved (at the request of client departments) in the implementation of more complex
changes (such as formation of the IJB) and in any areas where legislation is unclear.
Legal compliance will often be subject to external regulation (for example data protection).
The IJB’s Integration Scheme (detailing the powers given to officers to implement services
under specified legislation) is reviewed annually in line with revised legislative powers, in
consultation with client departments.
2. How is the Audit, Performance and Risk Committee provided
with assurance that all relevant laws and regulations have been
complied with?
Overview of committee reports undertaken by Legal Services
3. Have there been any instances of non-compliance or
suspected non-compliance with laws and regulation since 1
April 2022 with an on-going impact on the 2022/23 financial
statements? If so, please provide details
Not aware of any instances
4. Are there any actual or potential litigation or claims that
would affect the financial statements? If so, please provide
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Impact of laws and regulations
Question Management response
5. What arrangements does Moray IJB have in
place to identify, evaluate and account for litigation
or claims?
The legal section has teams which specialise in different areas of activity and will be involved (at the
request of client departments) in the implementation of more complex changes (such as formation of the
MIJB) and in any areas where legislation is unclear.
Where necessary external advice will be sought
6. Have there been any reports from other regulatory       
bodies, such as HM Revenues and Customs, which
indicate non-compliance? If so, please provide
details
None known
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Related Parties
Matters in relation to Related Parties
Moray IJB are required to disclose transactions with bodies/individuals that would be classed as related parties.  These may include:
■ bodies that directly, or indirectly through one or more intermediaries, control, or are controlled by Moray IJB;
■ associates;
■ joint ventures;
■ a body that has an interest in the authority that gives it significant influence over the Authority;
■ key management personnel, and close members of the family of key management personnel, and
■ post-employment benefit plans (pension fund) for the benefit of employees of the Authority, or of any body that is a related party of the
Authority.
A disclosure is required if a transaction (or series of transactions) is material on either side, i.e. if a transaction is immaterial from the Authority’s
perspective but material from a related party viewpoint then the Authority must disclose it.
ISA (UK) 550 requires us to review your procedures for identifying related party transactions and obtain an understanding of the controls that you
have established to identify such transactions. We will also carry out testing to ensure the related party transaction disclosures you make in the
financial statements are complete and accurate.
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Related Parties
Question Management response
1. Have there been any changes in the related
parties including those disclosed in Moray IJB’s
2021/22 financial statements?
If so please summarise:
• the nature of the relationship between these
related parties and Moray IJB
• whether Moray IJB has entered into or plans to
enter into any transactions with these related
parties
• the type and purpose of these transactions
No changes
2. What controls does Moray IJB have in place to
identify, account for and disclose related party
transactions and relationships?
Senior Officers and Elected Board Members make annual returns and members interests are regularly
updated on the website, any significant factors that arise as part of this process would be factored into
the Related Parties Note in the Annual Accounts.
3. What controls are in place to authorise and
approve significant transactions and arrangements
with related parties?
Normal procedures following the parties authorisation policies would apply – transactions over agreed
limits are checked by Chief Financial Officer or Director of finance
4. What controls are in place to authorise and
approve significant transactions outside of the
normal course of business?
For significant transactions that are new and outside the normal course of business IJB Board approval
is required.
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Going Concern
Matters in relation to Going Concern
The audit approach for going concern is based on the requirements of ISA (UK) 570, as interpreted by Practice Note 10: Audit of financial
statements and regularity of public sector bodies in the United Kingdom (Revised 2020). It also takes into account the National Audit Office's
Supplementary Guidance Note (SGN) 01: Going Concern – Auditors’ responsibilities for local public bodies.
Practice Note 10 confirms that in many (but not all) public sector bodies, the use of the going concern basis of accounting is not a matter of
significant focus of the auditor’s time and resources because the applicable financial reporting frameworks envisage that the going concern basis
for accounting will apply where the body’s services will continue to be delivered by the public sector. In such cases, a material uncertainty related
to going concern is unlikely to exist.
For this reason, a straightforward and standardised approach to compliance with ISA (UK) 570 will often be appropriate for public sector bodies.
This will be a proportionate approach to going concern based on the body’s circumstances and the applicable financial reporting framework. In
line with Practice Note 10, the auditor’s assessment of going concern should take account of the statutory nature of the body and the fact that the
financial reporting framework for central government bodies presume going concern in the event of anticipated continuation of provision of the
services provided by the body. Therefore, the public sector auditor applies a ‘continued provision of service approach’, unless there is clear
evidence to the contrary. This would also apply even where those services are planned to transfer to another body, as in such circumstances, the
underlying services will continue.
For many public sector bodies, the financial sustainability of the body and the services it provides are more likely to be of significant public
interest than the application of the going concern basis of accounting. Financial sustainability is a key component of wider scope and best value
work and it is through such work that it will be considered.
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Going Concern
Question Management response
1. What processes and controls does management have
in place to identify events and / or conditions which may
indicate that the statutory services being provided by
Moray IJB will no longer continue?
Regular reporting on the IJB’s Finances would highlight any conditions which may mean the MIJB is
no longer to deliver statutory duties. Regular performance reports would also highlight this
2. Are management aware of any factors which may
mean for Moray IJB that either statutory services will no
longer be provided or that funding for statutory services
will be discontinued? If so, what are they?
Not aware of any
3. With regard to the statutory services currently
provided by Moray IJB, does Moray IJB expect to
continue to deliver them for the foreseeable future, or will
they be delivered by related public authorities if there are
any plans for Moray IJB to cease to exist?
The MIJB would expect to continue to deliver statutory services
4. Are management satisfied that the financial reporting
framework permits Moray IJB to prepare its financial
statements on a going concern basis? Are management
satisfied that preparing financial statements on a going
concern basis will provide a faithful representation of the
items in the financial statements?
The annual accounts are prepared on a going concern basis and this will provide a faithful
representation of the items included in the financial statements
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Accounting estimates
Matters in relation to accounting estimates
ISA (UK) 540 (Revised December 2018)  requires auditors to understand and assess a body’s internal controls over accounting estimates,
including:
• The nature and extent of oversight and governance over management’s financial reporting process relevant to accounting estimates;
• How management identifies the need for and applies specialised skills or knowledge related to accounting estimates;
• How the body’s risk management process identifies and addresses risks relating to accounting estimates;
• The body’s information system as it relates to accounting estimates;
• The body’s control activities in relation to accounting estimates; and
• How management reviews the outcomes of previous accounting estimates.
As part of this process auditors also need to obtain an understanding of the role of those charged with governance, which is particularly important
where the estimates have high estimation uncertainty, or require significant judgement.
Specifically do Audit, Performance and Risk Committee members:
• Understand the characteristics of the methods and models used to make the accounting estimates and the risks related to them;
• Oversee management’s process for making accounting estimates, including the use of models, and the monitoring activities undertaken by
management; and
• Evaluate how management made the accounting estimates?
We would ask the Audit, Performance and Risk Committee to satisfy itself that the arrangements for accounting estimates are adequate.
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Accounting Estimates - General Enquiries of Management
Question Management response
1. What are the classes of transactions, events and
conditions, that are significant to the financial
statements that give rise to the need for, or changes in,
accounting estimate and related disclosures?
None directly but the value of the pension liability from partner organisations would have implications
2. How does the Authority’s risk management process
identify and address risks relating to accounting
estimates?
Managed by the partner organisations
3. How does management identify the methods,
assumptions or source data, and the need for changes
in them, in relation to key accounting estimates?
The results of prior year audits are looked at to see whether there was any material concerns raised or
amendments made
4. How do management review the outcomes of
previous accounting estimates? As above
5. Were any changes made to the estimation processes
in 2022/23 and, if so, what was the reason for these? No changes
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Accounting Estimates - General Enquiries of Management
Question Management response
6. How does management identify the need for and
apply specialised skills or knowledge related to
accounting estimates?
Each area is looked at in isolation and the relevant skills/knowledge/capacity considered
7. How does the Authority determine what control
activities are needed for significant accounting
estimates, including the controls at any service
providers or management experts?
Ensuring that relevant information is provided on time and accurately to ensure that the information received
can be relied upon.
8. How does management monitor the operation of
control activities related to accounting estimates,
including the key controls at any service providers or
management experts?
Regular updates provided by preparers of the Accounts on any issues that arise
9. What is the nature and extent of oversight and
governance over management’s financial reporting
process relevant to accounting estimates, including:
- Management’s process for making significant
accounting estimates
- The methods and models used
- The resultant accounting estimates included in the
financial statements.
The unaudited accounts are reported to Committee and then again upon completion of the audit. External
Audit reporting also helps to inform on estimates.
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Accounting Estimates - General Enquiries of Management
Question Management response
10. Are management aware of any transactions,
events, conditions (or changes in these) that may
give rise to recognition or disclosure of significant
accounting estimates that require significant
judgement (other than those in Appendix A)? If so,
what are they?
Not aware of any
11. Why are management satisfied that their
arrangements for the accounting estimates, as
detailed in Appendix A, are reasonable?
No major changes required to annual accounts in previous years
12. How is the Audit, Performance and Risk
Committee provided with assurance that the
arrangements for accounting estimates are
adequate?
Annual accounts are reported
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Appendix A Accounting Estimates
Estimate Method / model used to
make the estimate
Controls used to
identify estimates
Whether
management
have used an
expert
Underlying assumptions:
- Assessment of degree of uncertainty
- Consideration of alternative
estimates
Has there
been a
change in
accounting
method in
year?
Valuation of
defined benefit
net pension fund
liabilities
Based on information from
actuaries
Information provided to
actuaries based on year
end position reducing
the need for use of
estimates.
Yes Disclosure in accounts regarding the
changes that could happen and the
impact it would have on the figues
included in the accounts
No
Accruals Based on actual entries in the
ledger, or on information
received from departments
No In most cases based on actual ledger
entries so no estimation . Where
estimates are provided we know it will be
based on professional judgement and we
would query it it was materially different
from estimates provided
No
Accrued income Based on actual entries in the
ledger, or on information
received from departments
No In most cases based on actual ledger
entries so no estimation . Where
estimates are provided we know it will be
based on professional judgement and we
would query it it was materially different
from estimates provided
No
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REPORT TO: MORAY INTEGRATION JOINT BOARD AUDIT, PERFORMANCE
AND RISK COMMITTEE ON 30 MARCH 2023 
SUBJECT: INTERNAL AUDIT SECTION COMPLETED PROJECTS REPORT 
BY:  CHIEF INTERNAL AUDITOR 
1. REASON FOR REPORT 
1.1 To provide an update on audit work completed since the last meeting of the
Committee.   
2. RECOMMENDATION 
2.1 The Audit, Performance and Risk Committee is asked to consider and
note this audit update. 
3.  BACKGROUND   
3.1 Public Sector Internal Audit Standards (PSIAS) require the Chief Internal
Auditor to prepare and present reports to the committee on internal audit’s
activity relative to the audit plan and any other relevant matters. 
4. KEY MATTERS RELEVANT TO RECOMMENDATION 
4.1     In line with the approved internal audit plan, the following reviews were
completed: 
General Data Protection Regulation    
4.2 A review has been undertaken of Council systems to ensure compliance with
the United Kingdom's General Data Protection Regulation (GDPR). The
General Data Protection Regulation is a 2016 European Union Regulation that
was incorporated into the United Kingdom Data Protection Act 2018. The
audit reviewed systems and controls to ensure the Council is fulfilling the
requirements of GDPR. The review sought to confirm the required policies,
procedures and guidance are in place; there is awareness throughout the
Council with comprehensive training programmes and effective oversight and
governance arrangements to monitor ongoing compliance with GDPR. The
executive summary and recommendations for this project are given
in Appendix 1.
Item 9.
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Information Management
4.3 An audit has been undertaken to review that an appropriate system exists in
the management, security and transfer of data between the Council and care
providers, including NHS Grampian. The decision to review information
management was undertaken after discussions were held with the internal
audit providers for NHS Grampian, Aberdeen City and Aberdeenshire
Councils. The intention was to develop closer working relationships to better
coordinate the audit planning process and provide a more comprehensive
audit opinion of the control environment within Health and Social Care. 
4.4 A start date for the information management audit was agreed, but I was then
informed by the NHS Internal Audit Provider they could no longer complete
the audit as a review by the Information Commissioner was taking
precedence. As the audit within the Council was already well progressed, the
review was completed in accordance with the Audit Plan. The executive
summary and recommendations for this project are given in Appendix 2. 
Payroll System 
4.5 A review has been undertaken of the payroll system. The payroll system is
one of the core financial systems of the Council in administering
approximately £80 million of annual expenditure. The audit reviewed the key
controls in the management of the payroll service. This involved an
assessment of the operational effectiveness of these controls. Audit testing
included the random selection of a sample of salary payments and deductions
to ensure the correct calculation of remuneration and statutory/ voluntary
deductions are processed timeously and accurately. The Chartered Institute
of Public Finance and Accountancy Control Matrices were used to develop an
audit programme. Further to an incident regarding the unauthorised access to
an officer’s Employee Self-Service account, additional testing was also
undertaken regarding access controls to the Employee Self Service System,
where officers can amend their personal information, including bank
details. The executive summary and recommendations for this project are
given in Appendix 3.   
5.  SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan
(LOIP)) and Moray Integration Joint Board Strategic Plan “Partners in
Care 2022-2032” 
Internal audit work supports good governance and assists in securing
appropriate systems of internal control. 
(b)  Policy and Legal 
The internal audit service is provided in terms of paragraph 7:1 of the
Local Authority Accounts (Scotland) Regulations 2014, and there is a
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requirement to provide a service in accordance with published Public
Sector Internal Audit Standards. 
(c) Financial Implications 
No implications directly arising from this report. 
(d)  Risk Implications and Mitigation 
Audit reports highlight risk implications and contain recommendations for
management to address as a means of mitigating.   
(e) Staffing Implications 
No implications directly arising from this report 
(f)   Property 
No implications. 
(g)  Equalities/ Socio Economic Impacts 
Not required as no change to policy. 
(h) Climate Change and Biodiversity Impacts 
None directly arising from this report. 
(i) Directions 
None arising directly from this report. 
(j) Consultations 
There have been no direct consultations during the preparation of this
report. 
6. CONCLUSION 
6.1 This report provides Committee with a summary of findings arising from
audit projects completed during the review period. 
Author of Report:  Dafydd Lewis, Chief Internal Auditor 
Background Papers: Internal Audit Files
Ref:    mijb/ap&rc/30032023 
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APPENDIX 1
AUDIT REPORT 23’015 
UK GENERAL DATA PROTECTION REGULATION 
Executive Summary   
The annual internal audit plan for 2022/23 provides for a review to be undertaken of
the Council systems to ensure compliance with United Kingdom's (UK) General Data
Protection Regulation. The General Data Protection Regulation (GDPR) was a 2016
European Union regulation that came into force in May 2018, at the same time as
the UK's updated Data Protection Act 2018 (DPA). Since the UK's departure from
the European Union, GDPR has been adopted into UK regulation and sits alongside
DPA 2018; together they introduce stronger legislation on the handling of personal
data. 
The Council processes an individual's personal data in order to plan, run and
improve its services, perform its statutory duties, carry out its regulatory, licensing
and enforcement roles, make payments, administer benefits and identify fraud and
improve the health of the population it serves. The UK General Data Protection
Regulation regulates and protects the processing of personal data about individuals
by using the law to protect data and the way it is used by Local Authorities. 
The scope of the audit reviewed systems and controls to ensure the Council is
fulfilling the requirements of UK GDPR. The review sought to confirm the required
policies, procedures and guidance are in place, there is awareness throughout the
Council with comprehensive training programmes and effective oversight and
governance arrangements to monitor ongoing compliance with UK GDPR. Failures
that result in a breach of an individual's personal data may result in the Information
Commissioner's Office issuing a fine to the Council.   
The audit was carried out in accordance with Public Sector Internal Audit Standards
(PSIAS). 
Difficulties were experienced during the audit in the provision of information required
for this review. This resulted in a delay in the completion of the audit; consideration
will therefore be required to undertake further audit testing regarding the Council's
compliance with data protection regulations in a future Audit Plan. Findings from the
audit undertaken noted the following areas for consideration:- 
• UK GDPR requires the Council to undertake regular monitoring of policy
compliance to ensure data handling and security controls are operating
effectively in practice. This is not being undertaken. Further monitoring
arrangements should be introduced to evidence compliance with UK GDPR
and the Council's Data Protection Policy.   
Item 9.
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APPENDIX 1
• It was noted that the Council does not maintain an Information Asset Register
or a formal Record of Processing Activities. A requirement of UK GDPR is a
need to record data flows and document a register of personal data. This
should also assist in facilitating a risk assessment of information areas where
further controls may be required. 
• It was pleasing to note that officers need to complete Council online training
modules on data protection. However, no monitoring of participation has been
undertaken. A review should be done to highlight officers that have not
completed this training module. Any officer identified should be reminded to
undertake their data protection training requirement. 
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APPENDIX 1
Recommendations 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control: The Council has the appropriate procedures and controls in place to protect information, fulfilling the requirements of
GDPR. 
5.01 The Data Protection Policy and
guidance should be reviewed to
ensure the detailed information
remains current and appropriate.
Thereafter, a timetable for
continued review should be set. 
Medium Yes Task already
identified and
awaiting
workload
capacity. 
Records &
Heritage
Manager and
Data
Protection
Officer
31/01/2023
5.02 In compliance with UK GDPR, a
Record of Processing Activities
(ROPA) should be compiled by
the Authority based on a data
mapping exercise. 
High Yes A Data
Protection
Review is
already
underway with
the Information
Governance
Officer post now
in place.
Information
collected from
the 2018 GDPR
introduction
work will form
the basis of this
review. A
finalised ROPA
and Information
Records &
Heritage
Manager and
Data
Protection
Officer
31/12/2023
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APPENDIX 1
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Asset Register
will be produced,
and retentions,
privacy notices
and training all
highlighted too. 
5.03 In compliance with UK GDPR,
an Information Asset Register
should also be compiled and
maintained on an ongoing basis. 
High Yes  Records &
Heritage
Manager and
Data
Protection
Officer
31/08/2023
5.04 A review of Privacy Notices held
within Council services should
be progressed and the
documents made available on
the Council website for public
inspection. 
Medium Yes Privacy notices
(PNs) are
covered in the
current DP
Review, as the
current PNs are
updated or new
PNs created
they are made
available on the
Council's
website. After
the review this
will be an
ongoing process
whenever a
change in the
data process
Records &
Heritage
Manager and
Data
Protection
Officer
31/08/2023
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APPENDIX 1
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
occurs. 
5.05 Consideration should be given to
undertaking reviews within
Services to audit compliance
with the Data Protection Policy
and Guidance. This should
provide assurance that the
Authority is effectively handling
personal data in line with
regulations. 
High Yes Current DP
Review will
assist this. Due
to workload
pressures,
reviews will only
be undertaken
when
investigating
data breaches. 
Records &
Heritage
Manager and
Data
Protection
Officer
31/08/2023
5.06 A review of the guidance
documents and forms held within
the Information Management
section of the Interchange
should be undertaken and
updated accordingly.   
Low Yes When workload
capacity allows,
these guides are
reviewed,
updated and
promoted. 
Records &
Heritage
Manager and
Data
Protection
Officer
30/09/2023
5.07 A review should be undertaken
of the officers that have not
undertaken the data protection
training on the LearnPro training
system. Any officer identified
should be reminded to undertake
their data protection training
requirement. 
High Yes Staff are
reminded to do
training via
interchange
news items and
in response to
data breaches.
However,
policing the
completion of
Records &
Heritage
Manager and
Data
Protection
Officer
30/04/2023
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APPENDIX 1
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
mandatory
modules could
be given a
higher priority. 
5.08 Consideration should be given to
providing elected members with
an update of actions undertaken
to ensure the Council's
compliance with data protection
requirements. 
High Yes Agreed this
should become
a regular annual
report. 
Records &
Heritage
Manager and
Data
Protection
Officer
31/12/2023 
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Appendix 2
AUDIT REPORT 23'009 
INFORMATION MANAGEMENT 
Executive Summary 
The annual audit plan for 2022/23 provides for an audit review of the systems
and procedures in the management and security of adult social care
information, including the transfer of information between the Council to NHS
Grampian and other care providers. This review should also complement the
recent audit undertaken regarding the Council’s compliance with the UK
General Data Protection Regulation.  
Effective information controls within adult social care are particularly important
due to the sensitive nature of information held concerning service users. In
addition, the Council has duties under data protection regulations, and
breaches of these regulations can result in substantial financial penalties
being levied by the Information Commissioner’s Office.    
In recent years, discussions have been held with the internal audit providers
for NHS Grampian, Aberdeen City and Aberdeenshire Councils. The intention
has been to develop closer working relationships to better coordinate the audit
planning process within social care. An audit of Information Management was
agreed as the first step within this process. This has progressed well with a
joint approach undertaken, especially within the Internal Audit Services of
Aberdeen City, Aberdeenshire and Moray Councils. However, further to a
recent communication, it has not proved possible for the NHS Grampian
Internal Audit Provider to participate as a review by the Information
Commissioner has taken precedence.  
The audit was carried out in accordance with Public Sector Internal Audit
Standards (PSIAS).  
The review has highlighted the following areas for consideration:- 
• The Information Commissioner considers it is good practice to have a
data sharing agreement when information is shared between two
organisations. Data sharing agreements set out the purpose of the data
sharing, cover what happens to the data at each stage, set standards,
and help organisations involved in sharing to be clear about their roles
and responsibilities. It was found that the data sharing arrangements
for patient/ service user information between the Council and NHS
Grampian are still based on a Memorandum of Understanding from
2011. Consideration should be given to agreeing on a Data Sharing
Agreement between the Council and NHS Grampian to reflect the
updated Data Protection Legislation.   
Item 9.
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Appendix 2 
• A Data Protection Impact Assessment (DPIA) is an essential part of the
Council's accountability obligations under the UK General Data
Protection Regulation (GDPR). A DPIA is a process to help identify and
minimise data protection risks. Information regarding adult social care
service users are shared with approximately 80 care providers.
However, it was found that only one DPIA had been completed
regarding these data sharing arrangements.     
• The Council uses a software application to schedule visits for care
workers to service users. Details held within this software include
personal information concerning individuals receiving care. The
software application is administered through desktop computers but
with a facility to download information to a mobile device used by
carers. Access controls were found to have been installed within the
mobile devices; however no individual user login or password was
required to access the desktop computers used for administering the
software application. 
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Appendix 2
Recommendations 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control: Arrangements are in place for secure handling of personal data.
5.01 Data Protection Impact
Assessments (DPIAs) should be
undertaken to determine
whether additional safeguards
need to be implemented where
information concerning service
users is shared with care
providers. 
High Yes DPIAs are to
be carried out
on all
processes,
including for
new contracts
where data
sharing is
required with
partners.
Records and
Heritage
Manager, and,
Data Protection
Officer/
Commissioning
Manager
31/12/2023
5.02 Assurances should be obtained
that appropriate data protection
training has been undertaken by
NHS Grampian employed
officers requiring access to
Council administered databases.
Medium Yes Arrangements
to be put in
place to
confirm that
Data
Protection
training has
been received
by NHS staff
prior to being
given access
Information
Systems Officer
31/03/2023
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Appendix 2
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
to Council
systems.
5.03 Access to the Staffplan Software
Application used to schedule
visits by Care Workers to service
users should require individual
user login and password
controls.    
Medium Yes Password
Protection
facility to be
utilised for
Staffplan office
based access.
Provider
Services
Manager
31/03/2023
5.04 Regular reviews should be
undertaken to confirm the
access requirement to the
Occupational Therapy Stores
Management System by NHS
Grampian employed officers. 
Medium Yes Develop
procedure for
confirming
current NHS
staff access
requirements
to Council
systems.
Information
Systems
Officer
31/03/2023
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Appendix 2
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control: Appropriate security controls operate within Information sharing arrangements
5.05 The Council and NHS Grampian
should agree on an updated
Data Sharing Agreement (DSA)
for operational information
concerning service users that
includes the requirements of the
current data protection
regulations. 
Medium Yes Overarching
Information
Sharing
Protocol with
NHS Grampian
to be updated
and signed.
Dedicated
DSAs then to
be completed
for individual
processes.
Records and
Heritage
Manager, and,
Data Protection
Officer/
Commissioning
Manager
31/06/2023
5.06 Contract compliance visits to
care providers should include a
review that appropriate systems
are being followed to manage
and ensure the security of
service user information. 
Medium Yes Contract
Monitoring
checklist for
external
providers
updated to
include
Information
Management.
Commissioning
Manager
Implemented 
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Appendix 3 
AUDIT REPORT 23’018 
PAYROLL SYSTEM 
Executive Summary
A payroll software application called iTrent is used to administer the payroll service.
It was noted that approximately 5000 officer payslips are processed every month.
The iTrent system has a dual function of meeting the requirements of two main
service areas, i.e., payroll and human resources. This allows segregation of duties
control to ensure a separation between the management process concerning officer
appointments, terminations, grading and the processing of salary payments.   
The scope of the audit involved a review of the key controls in the management of
the payroll service. As verification of the operational effectiveness of these controls,
the audit reviewed systems and procedures and tested a random sample of salary
payments and deductions. The Chartered Institute of Public Finance and
Accountancy Control Matrices were used in the development of an audit programme.
Further testing was also undertaken regarding access controls to the Employee Self
Service System, where officers can amend their personal information, including bank
details.    
The audit was carried out in accordance with the Public Sector Internal Audit
Standards (PSIAS).  
The areas identified for management attention include the following:- 
• It is pleasing to note that an establishment listing exercise was undertaken in
March 2022. This involved an email from the Human Resources Section to
every budget manager to request confirmation or changes required to the
names, grades, locations and salary details of officers recorded within their
services. This exercise is an important control to confirm the accuracy of the
payroll system. However, it was found where the budget manager had not
replied, no further action was undertaken, or the issue escalated to a Head of
Service.  
• It was noted that the Human Resources Section provides an occupancy end
date report to budget managers of employees due to terminate their contract
of employment the following month. This report reminds budget managers of
the need to complete a “Termination of Employment” Form or update the
employee's employment status. Analysis undertaken of the iTrent system
found 252 individuals still recorded as officers of the Council, but where
records indicate a termination in their employment status. Audit testing found
the issue to be an administrative requirement to update officers’ employment
status rather than a salary overpayment. The occupancy end date report
provided to budget managers should be expanded to include employees
recorded as officers of the Council but where records indicate a termination in
their employment contracts. 
Item 9.
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Appendix 3 
Recommendations 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control: Review internal controls as detailed within the CIPFA Control Matrices to ensure effective delivery of a payroll service. 
5.01 Email requests to the Payroll
Section to reset an officer’s
access to their Employee Self
Service Account should only be
accepted from a Moray Council
email address or a prior
registered personal email
account. 
High       Yes  In place  Assistant
Payroll Officer 
Completed 
5.02 Officers should be reminded to
record memorable information
within their Employee Self-
Service accounts. This will allow
an additional level of system
security to confirm identity
before an officer can reset their
password. 
Medium Yes Reminders to
go into staff
comms. via
interchange
and Connect
Assistant
Payroll Officer
/ Acting Senior
Comms.
Officer
28/02/2023
5.03 The Human Resources Section
should undertake an annual
exercise with budget managers
to confirm the names, grades,
locations and salary details of
officers within their Service.
High Yes Procedure has
been updated
re previous
schedule (3
times per year)
for issue,
HR & Business
Resources
Team Leader
Completed
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Appendix 3 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
process for
non-
responders
and timeframe
to action
changes.
5.04  All budget managers should be
reminded of the importance of
confirming or advising Human
Resources of any changes
required to the establishment list
reports of officers recorded
within their services. If the
budget manager does not
respond, the issue should be
referred to the appropriate Head
of Service. 
Consideration should be given
by Human Resources to allocate
resource to ensure that any
amendments highlighted by
Budget Managers can be
actioned as quickly as possibly
following notification from the
service. 
High Yes Covering email
content updated
to emphasise
importance of
completion,
procedure
updated to
include
indicative
timescales to
allow for planned
allocation of
resources to
action any non-
responses,
escalation
procedure for
non-responses
amended and
escalation to
Head of Service
level if required.
HR & Business
Resources
Team Leader
31/03/23
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Appendix 3 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation 
5.05  Occupancy end date reports
issued to budget managers of
employees due to end their
employment with the Council the
following month should be
expanded to include all officers
whose records indicate their
employment contract has ended.
The budget manager should
advise the Human Resources
Section of any changes required
to the employment status of
officers within their services.   
High    Yes  Report
amended as
recommended
and
procedures
updated to
escalate non
responses to
head of
service. 
HR & Business
Resources
Team Leader 
Changes to report
made.  Updated
procedures live
from February
2023 
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REPORT TO: MORAY INTEGRATION JOINT BOARD AUDIT, PERFORMANCE
AND RISK COMMITTEE ON 30 MARCH 2023 
SUBJECT: CIVIL CONTINGENCIES - RESILIENCE STANDARDS PROGRESS 
BY:  CORPORATE MANAGER 
1. REASON FOR REPORT 
1.1. To inform the Audit, Performance and Risk Committee of Health and Social Care
Moray’s (HSCM) progress against NHS Grampian’s Resilience Improvement Plan
2019-21, and provide an overview of the work of HSCM Civil Contingencies Group. 
2. RECOMMENDATION 
2.1. It is recommended that the Committee: 
i) consider and note the contents of this report alongside the HSCM Civil
Contingencies Group Action Plan (APPENDIX 1); 
ii) request an annual assurance report to this Committee from the HSCM
Civil Contingencies Group; 
3. BACKGROUND 
3.1. Integration Joint Boards are categorised as Category One responders under the
Civil Contingencies Act 2004 (Scotland), as per an amendment to the act in
Scottish Parliament on 18 January 2021.  This places requirements for the MIJB
and HSCM to have mechanisms and plans in place to respond to incidents.   
3.2. In May 2016, Scottish Government Health Resilience Unit (SGHRU) published the
NHS Scotland Standards for Organisational Resilience (the Standards): this was
subsequently updated, revised and a second edition published in May 2018. 
3.3. The stated purpose of the 41 Standards is to “support NHS Boards to enhance
their resilience and have a shared purpose in relation to health and care services
preparedness in the context of duties under the Civil Contingencies Act 2004”. 
3.4. Each Standard, of which there are 41, sets out:
Item 10
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• A statement of an expected level of resilience practice
• A rationale/basis for the Standard (set within the context of statutory duties
under the Civil Contingencies Act 2004 and other key legislation and
guidance
• A series of indicators/measures of what should be in place, or achieved,
within/by the Health Board. 
3.5. An assurance report was submitted to this committee on 31 March 2022 providing
an update on progress against NHS Grampian’s Resilience Improvement Plan and
provided an overview of the work of the HSCM Civil Contingencies Group, para 10
of the minute refers. 
4. KEY MATTERS RELEVANT TO RECOMMENDATION 
4.1. The impact of the Covid-19 pandemic on civil contingencies and partnership
working across Health and Social Care Moray, Moray Council and NHS Grampian
has been unprecedented. The HSCM Civil Contingencies Group continued to meet
quarterly during the Covid-19 response to focus on key issues, identify training
needs, monitor and manage risks and progress key actions. 
4.2. Close working relationships with NHS Grampian and Moray Council continues with
a focus on shared learning and disruptive event planning.  The Corporate Manager
represents HSCM on all Grampian wide emergency planning groups. 
4.3. The HSCM Control room was established in March 2020 and has continued to
operate for the purposes of emergency planning and response, providing a central
point for receipt and distribution of essential communication and intelligence
information. 
4.4. The use of technology and in particular, the use of Microsoft Teams has allowed
staff to fully engage with colleagues and participate in meetings with cross
Grampian implications. It has also enabled incident response teams and control
rooms to respond and stand up virtually. However, the use of technology on a daily
basis also has implications for events that may result in loss of power or
communications and this is being included in Business Continuity and Emergency
planning. 
4.5. Debriefs and lessons learned from Storm Arwen during November 2021 and Storm
Malik and Corrie January 2022, continue to be discussed and implemented across
all partners in Grampian. The recommendations from the Scottish Government
report, published 28 October 2022, are being incorporated into resilience planning,
where appropriate, across the health and social care partnership. 
4.6. Much of this shared learning is co-ordinated through the Grampian Local
Resilience Partnership (GLRP). The relationships with the other Health and Social
Care Partnerships resilience teams and NHSG Civil Contingencies Unit, allows
sharing of ideas, plans and support for debriefs. 
4.7. The action plan (Appendix 1) is in place to support NHS Grampian’s Resilience
Improvement Plan, to close the gaps and address areas of improvement in Moray,
with assurance processes around these.  The plan, overseen by HSCM Civil
Contingencies group on behalf of the Chief Officer, is linked to each Standard and
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self-assessment level against each Standard is detailed.  (Please see Appendix 2
for criteria for scoring the self-assessment). This plan will be updated in 2023
against the revised Standards. 
4.8. The following actions have been identified for 2023: these are predicated on the
ongoing maintenance of actions already achieved, identified risks and continuance
of the supporting resilience processes and practice in place across the health and
social care system:
• Care for People (CfP) – Strategic document in final draft 
• Planning has commenced for a CfP Operational Plan. 
• Clarify roles and responsibilities for staff within HSCM and invocation of
plans, both in hours and out of hours. 
• Review existing service Business Impact Analysis (BIA) and Business
Continuity plans to ensure they reflect new ways of working.  A programme
for supporting service managers to review and exercise plans is in place. 
• Training gaps identified and action to address the gaps.
• Continue to work closely with partners to share information and learning
with other responders to enhance coordination and efficiency in responses,
with any gaps in preparedness identified and incorporate into the action
plan.
• Persons at Risk Database (PARD) – data continues to be accessed via the
Care First system to identify vulnerable people within social care. There is
ongoing work across the 3 HSCP’s in Grampian to consider other available
data, reporting back via the GLRP.   
4.9. The Partnership are signed up to Page One, which is run by Police Scotland. It is
the method of activating the GLRP. This was used during the storms of 2021/22. 
4.10. NHS Grampian have been contacted by Audit Scotland to advise of their intention
to carry out an audit of NHS Grampian’s Business Continuity arrangements. 
Whilst responding to the pandemic HSCM had to suspend testing and exercising of
plans, however it is planned that a revised schedule will be agreed. 
4.11. The Partnership’s Senior Managers on Call (SMOCs) continue with a 24/7 rota
throughout the year. They are responsible for emergency response across HSCM.
Review of these arrangements and training is under discussion. 
4.12. Prior to March 2021, IJB’s were reliant on NHS Board and Council specialist
advisors for support. Currently HSCM is represented by the Corporate Manager on
all matters involving Civil Contingencies. Unlike other partnerships, HSCM does
not employ a subject matter expert on this topic and this has been highlighted and
placed on the Strategic Risk Register, with a High rating. 
4.13. Persons at Risk Database (PARD) - a letter has been submitted to the Scottish
Government on behalf of the three H&SC Partnerships in Grampian, highlighting
the information governance issues that prevent the sharing of health data to
identify vulnerable people in the event of an incident. It is important to note that
there is no actual database as the name suggests. All three partnerships have to
accept that there is risk meantime, that we are not sighted on all data. It is
understood that this situation is a common theme in many of the H&SC
Partnerships across Scotland. 
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5. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes
Improvement Plan (LOIP)) and Moray Integration Joint Board
Strategic Plan “Partners in Care 2022-2032” 
This report forms part of the governance arrangements of Moray Integration Joint
Board; good governance arrangements will support the Board to fulfil its
objectives. 
(b) Policy and Legal 
The Civil Contingencies Act 2004 outlines a single framework for civil protection
in the UK.  Part 1 of the Act established a clear set of roles and responsibilities for
specified organisations involved in emergency preparedness and response at
local level (known as Category 1 responders).  Moray Council and NHS
Grampian are also Category 1 responders. 
Sector resilience and preparedness is the responsibility of the Chief Officer.  The
Corporate Manager is responsible for acting as the point of contact for Moray and
for driving forward all matters relating to civil contingencies and resilience within
Moray, supported by HSCM Civil Contingencies Group and Moray Resilience
Group. 
(c) Financial implications 
There are no financial implications associated with this report. 
(d) Risk Implications and Mitigation 
HSCM Civil Contingencies Risk Register is routinely monitored by the HSCM Civil
Contingencies Group with actions and risks escalated to the system leadership
group and senior management team as appropriate.   
(e) Staffing Implications 
There are no implications directly arising from this report.   
(f) Property 
There are no property implications arising from this report. 
(g) Equalities/Socio Economic Impact 
An Equality Impact Assessment is not needed as there is no change to policy or
procedure. 
(h) Climate Change and Biodiversity Impacts 
None arising directly from this report. 
(i) Directions 
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None arising directly from this report. 
(j) Consultations 
Consultation on this report has taken place with the Chief Officer, Chief Financial
Officer, Ross Ferguson, Emergency Planning officer, Moray Council, Isla Whyte,
Interim Support Manager and Lindsey Robinson, Committee Services Officer,
Moray Council, who are in agreement with the content of this report as regards
their responsibilities. 
6. CONCLUSION 
6.1. This report summarises the actions that are being progressed to ensure that
HSCM meets the appropriate standards and establishes robust contingency
arrangements to ensure critical functions can be maintained during
disruptive incidents. Progress is being made but there are some areas that
require attention and these are being prioritised by senior management.
Without dedicated resource, there is a risk to MIJB that it may not fulfil all of
its statutory duties as a Category 1 responder under the Civil Contingencies
Act 2004. 
Author of Report: Sonya Duncan, Corporate Manager, March 2023
Background Papers:  with author 
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Moray Civil Contingencies Improvement Action Plan APPENDIX 1
Last Updated: 01/03/2023 To support the national standards
ID Description Linked to
Self Assess
Level (see
criteria on
next page)
Requirement RAG
Status Action Required Evidence Owner
Expected
Completion
Date
Completion
Date Progress update
Proposed
revised
completion date
2 Governance Standard 2 2 Work plan in place to include training,
review of plans, sector based
exercising and participation in NHSG
programme of exercising
A Rolling programme of work to be
reviewed and updated following
COVID.  SBAR sent to Chief
Officer October 2022 and added
to Risk Register
Annual work plan agreed and
in place.
Interim Support
Manager
31/10/2020
31/3/2021
1/3/23 Teams channel for Senior Managers on Call
with emergency plans/details. All managers sent
emergency response training. All online material
circulated. Presentation to all managers regards
power outages with supporting resources. Offer
to exercise BC plans sent to all managers.
31/03/2023
3 Business Continuity Standard 7,8 2 a)  HSCM to have up-to-date,
effective Business Continuity (BC) /
contingency plans for all prioritised
services and functions. 
b) HSCM to have an overarching BC
Plan with agreed list of critical
functions/services.
A Critical functions list agreed
during COVID response. 
Overarching plan to be
completed
A) Services have up to date
plans in place
b) Critical functions approved
and overarching BC plan in
place and agreed by Systems
Leadership Group (SLG)
a)  Service
Managers
b) Corporate
Manager
11-Nov-22
07-Nov-22
a) 1/3/23 ongoing review of BC plans and some
tabletop talk through of plans. Additional
resources provided to teams for Power Outages.
Workshops provided for Primary Care Contractors
to support BC planning for power resilience.
b)  no longer required , agreed to follow NHS
Grampian Business Continuity Management as
per discussion with NHSG CCA (7/11/22)
30/03/23
30/09/23
4 Specific needs of
Children in MI & BC
planning
Standard 10 2 The specific needs of children and
young people to be addressed in all
relevant Major Incident and Business
Continuity plans, and ensure that its
responses / interventions are
sensitive to their needs
A Sectors to develop model for
engagement of Children's social
work services in Resilience
Groups
Engagement of Children's
social work services in
resilience planning
Systems
Leadership
Group
31-Dec-22 31-Mar-23 1/3/23 Childrens and Families will formally
integrate in April 2023. During the shadow period
C+F have been included in all resilience planning
including Care for People. The Strategic document
is now being presented to both Moray Council and
HSCM for approval. Discussions have taken place
with Childrens services regards their PARD data.
31/03/2024
7 Pandemic Influenza Standard 16 2 NHS Board shall develop and review
its Pandemic Influenza Plan jointly
with local partnerships and RRP, and
seek their endorsement.  A joint multi-
agency plan shall be developed, if one
does not already exist.
A Review of documents and
updating where necessary. 
Completion and sign off
MID/Pandemic Flu response
plan detailing integrated
health system response to
MID/Pan Flu, and setting out
links to RP response
HSCM Civil
Contingencies
Group
31-Mar-23 To be taken forward with NHSG and LRP Health
liaison group.  Date to be advised. 7/11/22
currently waiting for pandemic enquiry response, 
other policies/documents likely to follow to
inform the new proposed documents - discussed
with NHSG CCU Lead.
annual
8 Pandemic Influenza Standard 17 2 Link with NHSG Board in exercising
Pandemic Flu plan every 3 years
A Grampian wide health and social
care system pandemic table top
exercise.
Exercise documentation and
records of attendees.  Post
exercise report with lessons
learned.
HSCM Civil
Contingencies
Group
30-Sep-22 31-Mar-23 Linked to number 7 above. 7/11/22 Pandemic
response supersedes all exercise plans and will be
reviewed by NHSG and all partnership agencies.
Local lessons learned have been identified and
30/09/2023
10 Information
Security and ICT
Resilience
Standard 31 3 BIA/Recovery plans reviewed for IT
and Communications
G Review and update list of critical
ICT requirements following
changes to working practices as a
result of COVID and advise NHSG
EHealth and Moray Council
accordingly.
BIAs updated and held
centrally.  Critical functions
list agreed.  NHS eHealth and
Moray Council informed of
requirements.
HSCM Civil
Contingencies
Group
31-Jan-23 1/3/23 NHSG and MC monitor IT security systems
and potential risks. NHSG introducing 2 factor
security. NHSG to audit supplier systems also to
reduce risk.
ongoing
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11 Supply Chain
Resilience
Standard 39 2 BIA/Recovery plans reviewed for
suppliers
A Define list of critical suppliers and
ensure risk assessment
mitigation measures are in place. 
NHSG Board to be informed.
BIAs updated and held
centrally.  Critical functions
list agreed.  Risk assessment
completed with actions to
mitigate detailed.
NHSG and
Moray Council
31-Dec-22 1/3/23 NHSG eHealth to start incorporating BC as
part of supplier commissioning. Fuel planning
considered as part of power outage work.
ongoing
12 (Surge) Winter Plan Standard 18 4 Sectors shall have robust Winter Plans
and implement a range of actions to
enhance resilience during winter
period.
G Review and update plan - short
term working group to be
established.
Winter plan in place and
action plan in place.  Part of
Grampian's year-round
planning cycle and
participation in joint
planning, table top exercises
and debrief exercises.
Systems
Leadership
Group
31-Mar-23 30-Nov-22 1/3/23 Additional support provided for power
outages. Following each storm event plans are
revisited.
31-Mar-23
13 Major Incident
/Resilience Plans
Standard 9 2 NHS Board shall have Major Incident
or resilience plans that reflect its
emergency preparedness.  Sectors to
sign off plan.  Through HSCP, GP /
Primary Care made aware of their role
in the Major Incident Plan and
expectations of them.
A Take final NHS Board plan to SLG
and HSCM CC Group for
discussion and sign off.
Grampian plan signed off and
partnership working with
primary care in place.
Systems
Leadership
Group
31-Mar-23 1/3/23 NHS G plan currently being updated. 30/09/2023
14 Training Standard 12 1 Training gaps identified:                                                             
- who needs to be trained and in what
course / session
A A locally delivered Civil
Contingencies programme of
training courses for HSCM
managers and staff to be
identified and implemented
NHSG Civil Contingencies
Unit (CCU) training
programme in place and
dates communicated to SLG
Interim Support
Manager
31-Mar-23 1/3/23 Loggist and Chair training provided by
NHSG CCU. Support provided by HSCM Corporate
team around BC.
ongoing
15 Care for People Standard 38 1 Establishment of the care for people
plan and supporting framework for
implementation, including
clarification of roles and
responsibilities for partner agencies
G Using revised C for P plan from
Aberdeen City as basis update for
Moray, communicate widely
across partnership.
Resurrect regular Care for People
meetings
Strategic Care for People
document submitted for
approval. Draft delivery plan
in place. PARD /mechanism
for identification of
vulnerable people at risk in
place. Care for people and
PARD  meetings taking place
regularly and plans exercised
Corporate
Manager/Head
of Service /
CSWO/
31-Mar-23 1/3/23 Strategic document submitted to HSCM
SMT for approval. Plan to do exercise for delivery
plan.
30-Jun-23
16 Category 1
Responder /
Organisational
Resilience
Standard 5, 13 2 Civil Contingencies- Report to
Discharge duties of Cat 1 Responder
to CO
Actively participate in Local and
Regional Resilience Partnerships.
Programme in place to assess,
mitigate or manage resilience risks.
A IJBs included within the Civil
Contingencies Act 2004 as
Category 1 responders, effective
18 March 2021.                        
Report to IJB 24/11/22 to
highlight the risk to the IJB not
delivering its full responsibility
without subject matter expert.
Managers are participating in
the appropriate forums and 
working closely with
colleagues in the LRP, Moray
Council and NHS Grampian to
ensure that necessary
communication channels and
protocols are in place for
response action and that
plans are in place, and
exercised collaboratively. 
Where any gaps in
preparedness are identified
they will be incorporated into
the action plan.
Moray
Integrated Joint
Board
ongoing 1/3/23 Report to MIJB (24/11)  highlighting risk to
IJB not employing Civil Contingencies subject
matter expert to discharge Cat 1 duties. Also on
Strategic Risk Register as High Risk.
31/10/2023
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Appendix 2 
Self-assessment level 
The table below explains the self-assessment levels used against each NHS Scotland
Standards for Organisational Resilience (the Standards).
The assessment level determined for each action is shown in Appendix 1 
Level 1 – Planning
• Benchmarking against ‘Action’
undertaken and analysed
• Planning arrangements have been
initiated
• Local improvement plan to meet
standard developed and forms integral
part of Health Board’s Resilience
Committee’s work plan.  
Level 2 – Implementing
• Resilience Committee / Resilience Exec
Lead tasked to progress ‘Action’ 
• Implementation plan and methodology
agreed
• Collating appropriate information to
monitor delivery of ‘Action’ 
• Some evidence of ‘Action’ being
delivered.
Level 3 – Monitoring
• ‘Action’ implemented consistently and
geographically across Health Board
• Agreed process in place and being
reviewed over time 
• Associated learning and improvement
planning in place to ensure delivery of
standard.
Level 4 – Reviewing
• ‘Action’ has been mainstreamed into
existing services
• Quality assurance and performance
management established to review
‘Action’ on an on-going basis. 
Item 10
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REPORT TO: MORAY INTEGRATION JOINT BOARD AUDIT, PERFORMANCE
AND RISK COMMITTEE ON 30 MARCH 2023 
SUBJECT: EXTERNAL REVIEW OF COMMISSIONED SERVICES UPDATE 
BY:  TRACY STEPHEN, CHIEF SOCIAL WORK OFFICER 
1. REASON FOR REPORT 
1.1. To inform the Committee of the findings and action plan relating to the external
review of the adult Commissioning Service. 
2. RECOMMENDATION 
2.1. It is recommended that the Audit, Performance and Risk Committee: 
i) consider and note the findings of the external review included in
APPENDIX 1; and 
ii) agree the improvement actions included in APPENDIX 1. 
3. BACKGROUND 
3.1. A peer review exercise was completed by Aberdeen City and Aberdeenshire
Councils Shared Services (Commissioning) in December 2021 on behalf of
Health & Social Care Moray (HSCM) to provide evidence and assurance that
the commissioning of adult services by the Commissioning Service were
robust, appropriate, equitable, efficient and provided value for money for the
population of Moray. 
3.2. The report findings were not accepted by the CSWO (Chief Social Work
Officer) and Head of Service in post at that time and an external review was
agreed as a way forward by Audit, Performance and Risk Committee on 31
March 2022 to gain a definitive perspective on the challenges experienced by
the service and how improvements could then be made (para 11 of the minute
refers). 
3.3. KPMG were appointed to complete the external review and they completed that
process in February 2023. 
Item 11.
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4. KEY MATTERS RELEVANT TO RECOMMENDATION 
4.1. The report has been shared with the Commissioning Team and appropriate
conversations have happened between the team and KPMG to reach a final
agreed position which is reflected in the report. 
4.2. An action plan has now been created to achieve the agreed outcomes and
monitor progress, with support from the CSWO and Head of Service now in
post. The team are committed to achieving the outcomes set out in the report
and steps have already started towards achieving improvements. 
4.3. There are some risks to achieving the set timescales due to staffing
implications and related restructuring that has taken place following the external
review. The CSWO is looking at the capacity issue and how that risk can be
mitigated using interim support. There is also a significant amount of remedial
work needed to update contracts and ensure that best value is being achieved. 
4.4. Progress on the actions will be reported back to Audit, Performance and Risk
Committee on a quarterly basis. 
5. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes
Improvement Plan (LOIP)) and Moray Integration Joint
Board Strategic Plan “Partners in Care 2022 – 2032”
In order to fulfil the MIJB strategic aims, it is essential that services are
operating with optimum efficiency to ensure the needs of the Moray
population can be met, that services are fit for purpose and that
processes and accountability is clear. 
(b) Policy and Legal
The CSWO/Head of Service must ensure that services delegated by her
work within the legal and policy framework related to commissioning and
delivery of services. 
(c) Financial implications
There are no financial implications arising from this report. 
(d) Risk Implications and Mitigation
There is a risk that timescales and outcomes may not be reached due to
the current resource and restructure of the team, although, efforts will be
made to minimise this risk. 
(e) Staffing Implications
There are no staffing implications 
(f) Property
There are no property implications 
(g) Equalities/Socio Economic Impact
This report does not require an EIA. 
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(h) Climate Change and Biodiversity Impacts
None 
(i) Directions
None 
(j) Consultations
Not required 
6. CONCLUSION 
6.1. The committee is requested to agree the improvement plan at APPENDIX
1. 
Author of Report: Tracy Stephen, CSWO and Head of Service
Background Papers:  
Ref: 
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Social Care Commissioning
The Moray Council: The Moray Health and Social Care Partnership
KPMG Governance, Risk & Compliance Services
February 2023
APPENDIX 1
Item 11.
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Content
Distribution list
For action:
Simon Bokor-Ingram, Chief Officer of
Health and Social Care Moray
Tracy Stephen, Chief Social Work Officer
and Head of Service
For information:
Audit & Scrutiny Committee
Report status
Closing meeting: 27 October 2022
Draft report issued: 10 November 2022
Updated draft report issued: 14 February
2023
Final report issued: 23 February 2023
01 Executive summary 3
02 Findings and management actions 6
03 Appendices 19
Sample testing
Analysis of commissioning database
Scope extract
Acknowledgments
Rating definitions
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3
Acknowledgements
We would like to thank the following individuals for their
contribution during this internal audit:
— Key individuals involved in our work are acknowledged at
Appendix D.
01
Executive summary
Conclusion
We have performed a review of social care commissioning within Health and Social Care Moray
(‘HSCM’). Our review assessed the design of controls in place, as well as their operating
effectiveness in order to determine the suitability of internal procedures, the application of these
procedures and whether the approach taken to commissioning aligns with best practice. In order to
make this determination our work included, but was not limited to, sample testing of contracts with
providers, invoices and governance meeting minutes.
The delivery of social care is led by the commissioning team, but is supported by other functions
across the Council including finance and procurement. Our review included meetings with staff from
across these areas.
We have raised 11 key findings relating to governance, roles and responsibilities, strategy/processes
and contract management. We have rated six of these findings as high-level (red), four as mid-level
(orange) and one as low-level (green).
Governance
There is not a clear structure for the escalation and oversight of commissioning issues. We
specifically note that Commissioning Manager meetings have not been held since February 2022.
Such meetings should act as a forum to monitor commissioning activity and provide oversight on the
efficient resolution of issues. Our review of the governance arrangements in place can be found in
Finding 2.1 and Appendix A .
Roles and responsibilities
The overarching role of the Council’s Commissioning provision should be to provide services that
meet the needs of users. This means that commissioning activity must evolve to meet needs and
new contracts may need to be procured. Therefore, commissioning encapsulates a number of
Council areas (e.g. Commissioning Team, Procurement, etc), so it is important that staff understand
the gaps for which they are responsible to ensure functional working relationships (Finding 2.2) . As
per Finding 2.3 , we identified a need for staff training which would assist in communicating job
Priority rating: Control design Operating effectiveness
2 4
3 1
1 0
High
Medium
Low
Summary
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Contract management
We applied data analytics to the contracts database and found it to be only 78.71%
complete due to a number of fields being left blank. We found out of date contracts
within the database dating back as far as 2004. We have included details of this
analysis in Finding 2.8 and Appendix B. Failure to keep the central contracts
database up to date creates a risk to monitoring activities as contracts may be
omitted from monitoring plans and/or incorrectly included.
The Council has a Senior Performance Officer responsible for rolling out performance
management frameworks across the Council. However, Commissioning is yet to
benefit from such a framework and we were not able to obtain information relating to
timelines for implementation. Delays pose a risk that there is inadequate oversight
of performance at a team level. When rolled out, the framework should include
suitable KPIs to measure performance (Finding 2.9) .
The contract review process (Finding 2.10) is not capable of sufficiently monitoring
contract compliance as it is currently only conducted periodically. Providers should be
subject to more frequent, in -depth reviews that evaluate compliance with legal and
regulatory standards as well as other contractual terms. This will ensure that the
Council has working relationships only with compliant organisations, upholding the
Council’s overall credibility and reputation.
Block contracts are currently being used, however we understand that a transition
away from such arrangements is in progress. The operation of block contracts require
detailed tracking and monitoring in order to be managed well, however we have not
found this to be the case. The Council should endeavour to complete the transition as
soon as possible (Finding 2.11) .
Executive summary
descriptions to staff and signposting sources of guidance and escalation should the
need arise. Training would also reinforce the Council’s standard operating procedures
and improve adherence to such procedures
Strategy & processes
There is no documentation setting out the commissioning and decommissioning
process, including the lack of a policy document relating to how services should be
procured and managed under the Self-Directed Support (‘SDS’) framework (Finding
2.4). Our testing of a sample of 13 contracts with providers and 25 invoices
demonstrated further shortcomings in contract documentation.
For example, we were unable to obtain four of the sampled contracts and 15 of the
sampled invoices due to insufficient audit trails which will have further implications in
terms of future planning. Without complete documentation, there is a risk that staff
are not following formal Council policies and procedures. The findings from our
sample testing are further detailed in Finding 2.5 and Appendix A .
The ‘Moray Partners in Care’ strategy, formulated by Moray Council, is a strategic
plan covering the next 10 years. Although we identified a clear direction within the
strategy, there are no clear targets, KPIs or milestones against which the Council can
hold itself accountable. A delivery plan for the strategy is currently being developed
and should be implemented as a priority to ensure the strategy is being followed
(Finding 2.6) .
Robust controls in invoicing ensure that expenditure is incurred appropriately,
however we observed that controls are not applied consistently as they are not
formally documented. For example, the 15 minute variance for billed care time and
expected care time set by the Finance team has not been formalised. Furthermore, if
the invoices cannot be agreed to the underlying contract, queries are raised without
retaining any evidence, leading to undocumented decision making (Finding 2.7) .
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Executive summary
Summary of key findings
Governance
structure
2.1 The Council should prioritise having senior oversight to close the
gap between the organisation and those charged with governance,
as there is currently an insufficient grip on governance.
Team structure
and roles
2.2 There is a lack of clarity around roles and responsibilities, and poor
cross-organisational relationships.
Strategy 2.6 The Council does not have a clear strategy for the Health and Social
Care Commissioning Division, supported by KPIs and milestones.
Process
documentation
2.4 The Council has not documented the processes around
commissioning and de-commissioning.
Invoicing 2.7 Financial controls around the invoicing processes are inconsistently
applied.
Contracts
register
2.8 The Council should develop a centralised contracts register to
ensure there is adequate oversight over contracts held, including
their value and date.
Performance
management
system
2.9 The Council should prioritise the development of a performance
management system in commissioning.
Sample testing 2.5 Our sample testing identified a number of issues relating to missing
documentation and inadequate audit trails.
Contract
review
2.10 Contracts are currently subject to an annual review but there
should be more regular review.
Block contracts 2.11 The Council should ensure there is adequate monitoring of block
contracts to ensure greater accuracy of billing.
Training 2.3 A lack of training for staff has contributed to confusion as to what is
expected of different teams.
Contract management:
Roles and responsibilities:
Strategy & processes:
Governance:
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6
02
Findings and management actions
Governance
2.1 Governance structure
The Council should prioritise having senior oversight to close the gap between the organisation and those charged with governance, as there is
currently an insufficient grip on governance.
The provision, management and oversight of health and social care delivered in Moray is governed by the Integration Joint Board (‘IJB’). This forms
part of the wider governance structure, which is presented in more detail in Appendix A.
Our review identified that currently, there is no clear structure for the escalation and oversight of issues relating to Social Care Commissioning.
As part of our review, we also reviewed minutes for a number of meetings:
Systems Leadership Group Meetings (leadership)
– Commissioning was not discussed at leadership level as it was not on the agenda, nor was there commissioning representation.
Senior Management Team Meetings (management)
– There was a standing agenda item in each of these meetings labelled ‘Gaps in Social Care Provision’ where those with oversight of commissioning
provided an update.
– However, we noted three meetings where social care was insufficiently addressed, as discussion lacked depth and detail. On a further three
occasions, the standing item was not discussed. This means that the opportunity to extract constructive actions from these meetings relating to
commissioning is not utilised.
Commissioning Group Meetings (operational)
– Commissioning Manager Meetings are held on a roughly quarterly basis. It was agreed that action plans for each Commissioning Manager Meeting
would be created, however this has not yet been done.
Continued…
High
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2.1 Governance (contd.)
Risk:
There is inadequate central oversight of billing and budgeting in relation to
contracts. Expenditure related to contracts is not appropriately authorised,
in line with Standing Financial Instructions.
The Council has insufficient governance in place to successfully plan,
commission and manage contracts with the highest complexity, cost and
risk.
Agreed management action:
1. As per guidance issued by the Sottish Government, the IJB Terms of
Reference should be revised to include clear roles and responsibilities
in relation to the management and oversight of all social care
commissioning activities.
2. The Council should clarify the expectation around attendance at
meetings and attendance should be reported at least part-publicly.
Deputies attending should have the delegation to make decisions on
behalf of their superior.
3. The Council should prioritise the production of action plans for each
Managers Commissioning meeting. These should clearly set out the
action, responsible individual and due date for completion. Progress
against the action log should be monitored at each meeting.
Evidence to confirm implementation:
Reviewed Terms of Reference.
Communications to senior management regarding manager meeting
intentions.
Proposed template action logs.
Responsible person/title:
Service Manager
Target date:
1. 31st August 2023
2. 29th February 2024
3. 31st May 2023
Findings and management actions
High
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Roles and Responsibilities
2.2 Team structure and roles
There is a lack of clarity around roles and responsibilities, and poor cross-organisational relationships.
The overarching role of the Commissioning function is to provide services that meet the needs of end users. To achieve this, services must
evolve according to the changing needs of service users, which is not currently possible due to blurred lines of responsibility acting as a barrier to
collaborative working. Adapting alongside changing user demands may include the procurement of new contracts. This therefore incorporates a
number of teams into the overall commissioning process, such as Procurement and Finance.
Through our discussions with staff from across the different areas of the Council, we found that there was a lack of clarity around which teams
are responsible for which parts of the commissioning process. The absence of guidance around the commissioning and de-commissioning
process also exacerbates the confusion around roles and responsibilities (see Finding 2.4 ), as staff are not assigned specific responsibilities.
This lack of clarity, combined with a lack of communication has exposed the Council to risks where core tasks relating to the commissioning
process have not been completed as expected, because the responsible staff member did not complete the task in time. We found that teams
do not work together, and fractured relationships pose a direct challenge to the effective and efficient completion of tasks.
Determining roles and responsibilities requires the council to first review its commissioning structure, including the aims of the commissioning
division and how these will be met, and how other teams across the council engage with the commissioning process (if required). Once an
effective framework has been established, the council can then use this to re-communicate the roles and responsibilities of the different teams
and individuals which sit within and alongside the commissioning function. This process will ensure that the goals are clear and are aligned on
both an individual and a higher level.
Risk:
Roles and responsibilities are not clearly set out and allocated, resulting in inadequate completion of tasks.
Continued…
Findings and management actions
High
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2.2 Team structure and roles (contd.)
Agreed management action:
1. The Council will develop clear job descriptions for each role, which set out
the responsibilities of the individual. These job descriptions will be shared
with staff on commencement of a role, and will be made available for future
reference.
2. The opportunity and scope for collaboration across the various Council
teams will be explored so that the Council can benefit from shared learning
and increased efficiency.
3. As part of the wider performance management process, staff will be held
accountable for their roles. If tasks are not completed as expected, the
reasoning behind this should be explored and appropriate action taken to
avoid the chance of a recurrence.
Evidence to confirm implementation:
Clearly defined job descriptions.
Revised approach to collaborative working.
Clearly defined controls to link performance management and
accountability for job roles.
Responsible person/title:
Service Manager
Target date:
1. 31st May 2023
2. 31st August 2023
3. In place
Findings and management actions
High
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2.3 Training
A lack of training for staff has contributed to confusion as to
what is expected of different teams.
Finding 2.2 notes that there is a lack of clarity around the
roles and responsibilities of different teams, meaning
expectations of each of the teams involved in the wider
delivery of social care are not sufficiently understood.
As part of the move towards a new single service under
‘The National Care Service’, the training that HSCM provides
should include an ‘awareness raising’ arm. This will set out
exactly what the service is aiming to achieve, what is
required of different teams and job roles, as well as how this
should be performed in accordance with the Council’s
policies and standard operating procedures. Training would
also provide an opportunity to signpost sources of guidance
and escalation where staff feel it necessary. Ideally, training
would be followed up by a series of guidance documents to
be referred to should instances of uncertainty later arise.
Risks:
Council staff involved in commissioning are not
consistently complying with the Council’s
policies and procedures.
Roles and responsibilities are not clearly set out
and allocated, resulting in inadequate
completion of tasks.
Agreed management action:
1. Implement a clearly defined staff training
plan, supported by a series of readily-
available guidance documents.
Evidence to confirm implementation:
Staff training plan.
Responsible person/title:
Team Manager
Target date:
31st August 2023
Findings and management actions
Medium
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Strategy / Processes
2.4 Process documentation
The Council has not documented the processes around
commissioning and de-commissioning.
Our review identified that there is no documented
process in place which clearly sets out the
commissioning and de-commissioning process.
Self-Directed Support (‘SDS’)
A number of contracts are procured under the SDS
framework, which has its own set of rules and
regulations. The Council does not have a policy /
document in place which sets out how services should
be procured and managed under the SDS framework.
Currently, invoices received under SDS option 2 are sent
to the commissioning manager for approval. This is in the
process of changing as the invoices should be signed off
by the budget holder to be in line with the Council's
financial regs. The Council should prioritise this alignment
to financial regulations.
Risk:
Staff are unaware of what is required of them.
Steps in the commissioning and
decommissioning process may be omitted,
exposing the Council to risk around incomplete
contract terms.
Agreed management action:
1. The Council will develop and document a
clear end-to-end process, which sets out
each of the steps of both the
commissioning and decommissioning
process.
2. All staff involved in commissioning will
be provided with training around this
process, and details of the process will
be made available to staff for future
reference.
3. Prioritise alignment with SDS financial
regulations.
Evidence to confirm implementation:
End-to-end process document for
commissioning and decommissioning.
Training programme.
Progress report as to the alignment with SDS
financial regulations.
Responsible person/title:
Service Manager
Target date:
31st August 2023
Findings and management actions
High
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Findings and management actions (cont.)
High
2.5 Sample testing
Our sample testing identified a number of issues relating to missing documentation and inadequate audit trails.
We have presented the detailed results of our sample testing in Appendix A.
Contracts
We took a sample of 13 contracts under social care commissioning arrangements and reviewed whether each contract was in date, sufficiently approved and
agrees to the contracts database. We identified the following issues:
– We were unable to obtain documentation for four contracts in our sample, suggesting an insufficient audit trail has been maintained, and we confirmed that
there was no contract in place for a further one.
– There were five instances where contracts signed by the contracting party were not retained on file, these were only signed by the Council.
– We were unable to confirm that five contracts were still in date, due to either no end date information or conflicting contract clauses.
– We were unable to reconcile any of the contract values to the value as per the contract database as different costing information was used (e.g. per resident
per week, total value, etc).
– It was only possible to reconcile end dates to the database for one contract as variations to contract end dates were not accounted for in the database.
– There were four contracts where the respective contract numbers were not reflected in the contracts database.
Invoices
We selected a sample of 25 invoices from a listing of all transactions which had been incurred by the Council. For each item in our sample, we attempted to
verify the invoice and underlying approvals of the transaction. We identified the following issues:
– For 15/25 items in our sample we were unable to view the invoice. This was because management was unable to tie back the transactions in our listing to
individual invoices.
– We were unable to confirm that any invoices in our sample had been sufficiently approved prior to payment. This was due to the Council not retaining any
evidence relating to this approval.
Continued…
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2.5 Sample testing (contd.)
From the results of our sample testing, we identified
three key areas for improvement:
– Audit trails: as per our findings, we were unable to
obtain documentation relating to both contracting
and invoicing. This indicates that thorough audit
trails are not maintained. Documentation should
always be obtainable so that expenditure can be
easily identified and monitored.
– Contracts database: the database is not subject to
ongoing updates to reflect contract expirations or
extensions. It is also not possible to reconcile
contract values with the database due to an
inconsistent approach. We have expanded on this
in Finding 2.8 and Appendix B .
– Approvals:the Council should have a robust
approvals process in place, which can be
documented and applied consistently. However, for
the samples we tested we were unable to confirm
that approvals were sufficient and were not capable
of being construed as approvals, often not even
containing the word 'approved'. To be in line with
best practice, the approvals process should ensure
there is segregation of duties. For example, we
noted that one invoice was received and 'approved'
by the same member of staff.
Risk:
Inefficiencies in commissioning may lead to delays in the
overall procurement process, thereby increasing costs to
the Council and delaying commencement of the services.
Insufficient internal checks are performed at the Council,
which fail to identify deficiencies or gaps within the
processes around commissioning.
Council staff involved in commissioning are not consistently
complying with the Council’s policies and procedures.
Agreed management action:
1. All contracts will be signed, and copies of these
signed contracts stored for future reference.
2. The Council will explore the possibility of
adjusting the reporting system such that
expenditure listings can easily be tied back to the
underlying invoice.
3. Invoices will not be processed without adequate
approval.
4. The Council will consider introducing spot-checks
and/or audits of documentation, to ensure that
processes are consistently being followed across
the organisation.
Evidence to confirm
implementation:
Updated and approved process
documentation that clearly sets out
the requirements.
Signed, dated and approved contracts.
Consideration of changes to system.
Spot checking process.
Responsible person/title:
Service Manager
Target date:
28th February 2025
Findings and management actions (cont.)
High
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2.6 Strategy
The Council does not have a clear strategy specifically for the Health
and Social Care Commissioning Division, supported by KPIs and
milestones.
Moray Council has a ‘Moray Partners in Care’ strategy, which was
approved and issued in 2019. This strategy sets out the strategic plan
for Health and Care for the next 10 years, across Moray.
The strategy covers three broad themes:
1. Building Resilience
2. Home First
3. Partners in Care
While the strategy provides a good over-arching understanding of the
Council direction, the strategy does not provide sufficient detail on
how the Health and Social Care Commissioning department can
achieve the transformation required. This means that the strategic
intent has been articulated, but this has not been operationalised. For
example, the outcomes noted are not supported by clear targets,
supporting KPIs and milestones for the division to hold themselves
against, and this strategy is not underpinned by a delivery plan.
We note that the Council is currently in the process of developing a
delivery plan for this strategy, which should clearly set out guidelines
for how staff at the Council can deliver on the requirements of the
strategy.
Risk:
The Council’s Health and Social Care
Commissioning Division lacks direction,
and is unable to support the wider
Council in achieving its aims.
Agreed management action:
1. The Council will develop an
implementation plan which
supports the wider strategy. This
implementation plan will clearly set
out the goals for the Council, how
these will be achieved and the
method for monitoring the success
of this strategy.
Evidence to confirm implementation:
Implementation plan incorporating the
considerations in our recommendation.
Responsible person/title:
Head of Service
Target date:
29th February 2024
Findings and management actions (cont.)
Medium
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2.7 Invoicing
Financial controls around the invoicing processes are
inconsistently applied.
Robust financial controls in the invoicing process are vital
to ensuring that expenditure is incurred appropriately, in
line with the Council’s Standing Financial Instructions
(‘SFIs’). The responsibility for complying with financial
controls lies with the finance team as opposed to the
commissioning team.
Financial control processes are not documented, and
therefore controls are not applied consistently.
Our review identified the following issues:
Variances
There is no set limit at which any variances on invoices
received are subject to further investigation. Although the
finance team has informally set an acceptable limit of 15
minutes for billed care time and expected care time, there
is no formal documentation to support this as a limit.
Queries
When the invoicing team are unable to agree invoices
received to underlying contracts, queries are raised with
the social commissioning team if it relates to a contract or
with the social worker who raised the invoice if it relates to
a one-off payment. Although an explanation is sought for
the variance, the team does not retain any evidence.
Risk:
The Council could be incurring additional cost by
paying invoices for inappropriately raised bills.
Without an adequate audit trail, invoices could be
processed which do no meet the Council’s needs.
Agreed management action:
1. The Council will formalise and document its
approach to variances.
2. Staff will ensure that all evidence is retained
throughout the invoicing process, to ensure
that there is an adequate audit trail for all
decisions made.
Evidence to confirm implementation:
Revised approach to variance analysis.
Document retention guidance.
Responsible person/title:
Head of Service
Target date:
29th February 2024
Findings and management actions (cont.)
Medium
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Findings and management actions (cont.)
High
Contract Management
2.8 Contracts register
The Council should develop a centralised contracts register to ensure there is adequate oversight over contracts held, including their value and date.
The Council holds contracts with different providers who are responsible for the delivery of social care to the residents of Moray.
We requested copies of a contracts register in order to complete our testing, however the majority of staff we interviewed were unfamiliar with the
contracts register and did not believe one was in place. For the purpose of sample selection, we therefore relied on a listing of all 175 suppliers with whom
transactions had been raised by the Council, provided by the Procurement department, and a listing of 59 contracts provided by Commissioning.
Through further investigations, we found that the Council holds a Commissioning Database, which acts as the Contracts Register. This database includes
key details related to each contract, including dates, values and responsible individual for each contract. We performed data and analytics routines (see
Appendix B ) over this database and identified a number of issues.
Procurement maintain its own contracts register, encompassing all Council contracts and not just commissioning. However, the extent to which
commissioning information is accurately presented in this register depends on the effectiveness of communication between teams. This is something we
have touched on in Finding 2.2.
Incomplete Fields
Overall, we identified 575 blank entries out of a possible 2,701, suggesting that the database is, at most, 78.71% complete. 49.49% of budget details and
12.33% of contracting party details were incomplete.
The database contained 73 contracts in total, while the listing of contracts provided by Commissioning which we used to select our sample contained 59
contracts.
Through our discussions with management, we were informed that commissioning officers are not always aware of all the details relating to their contracts,
as these have not been formally recorded. This results in reputational risk if commissioning officers reach out to contracting parties to ask them to confirm
the details, as well as exposing the Council to the risk that they will be held to terms which they have not agreed, and are not in line with regulations.
Continued…
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2.8 Contracts register (cont.)
Out of date contracts
Our data and analytics routines identified that
21.92% of contracts on the database had start
dates prior to August 2012, so related to contracts
more than 10 years old.
43 contracts included on the database had expired,
with 38 of these having expired prior to August
2020.
Through discussions with management, we were
informed that contracts often reach their expiry
date, and the Council is forced to roll contracts
over, or continue their operation.
Data Quality
Our review of the contracts database found that
information entered was of varying quality. For
example, information was not consistently
formatted and additional comments were included
for some categories.
Risk:
There is no central oversight of contracts held. Contracts are
omitted from the register and therefore not subject to the
appropriate level of monitoring and review.
Without a central contracts register, there is the risk that
contracts expire without the Council being aware, or irregular
monitoring results in the Council failing to re-tender for contracts
in time, increasing use of single tender waivers and contract
extensions. Budgeting or monitoring spend cannot be achieved
effectively, if there is insufficient grasp of current contracts.
Agreed management action:
1. Health and Social Care Moray should prioritise the development
of an expenditure contracts database, which clearly sets out
their expenditure and details of the agreements they hold.
2. Once established, this database should be monitored, reviewed
and routinely updated to ensure that all data is accurate and of a
high quality. There will be clear ownership of the contracts
register, and as part of the review process these registers
should be scrutinised by senior management.
3. The Contracts database will be shared and made available to all
staff involved in the commissioning process, such as the
procurement team.
Evidence to confirm
implementation:
Updated contracts database
reflecting the true state of
commissioning within the Council.
Responsible person/title:
Service Manager
Target date:
31st August 2024
Findings and management actions (cont.)
High
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2.9 Performance management system
The Council should prioritise the development of a performance
management system in commissioning.
Contracts should be subject to regular performance review to ensure
the quality of work needed is delivered to end service-users. Without a
sufficient performance management system, there is a risk that the
quality of services is compromised.
Currently, performance management is done solely on a contract basis
by the senior commissioning officers. The Council has a Senior
Performance Officer, in post since November 2021 whose role includes
rolling out a performance management framework and system across
the Council. This has not yet been done for Commissioning, and there is
no timeline in place for when this will be implemented.
Risk:
Without a performance management system,
there is inadequate oversight of performance
at a team level.
Agreed management action:
1. The Council will prioritise rolling out a
performance management system. This
framework, when rolled out, will look at
performance management on a team-wide
level, including looking at what performance
management KPIs should be.
Evidence to confirm
implementation:
Performance management
system incorporating the
considerations in our
recommendation.
Responsible person/title:
Service Manager
Target date:
29th February 2024
2.10 Contract review
Contracts are currently subject to an annual review but there should be
more regular review.
Although contracts are reviewed periodically, this should be conducted
more often. The review should be aligned with strategic objectives, and
ensure providers are held to legal and regulatory standards to ensure
relationships with only compliant organisations. This should be subject
to pro-active review as opposed to just informal feedback. The Council
should determine the standards to be reviewed against (i.e. Council or
Integration Joint Board-level objectives) that providers are expected to
meet.
Risk:
Contracts are awarded to substandard and/or
unapproved suppliers that do not meet the needs
of the Council including timeliness, quality and
competence. This will impact on the quality of
services and best value for the Council.
Agreed management action:
1. The Council will implement a regular contract
review procedure that assesses the
suitability of providers.
Evidence to confirm
implementation:
Contract review procedure.
Responsible person/title:
Service Manager
Target date:
31st August 2023
Findings and management actions (cont.)
High
Medium
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2.11 Block contracts
The Council should ensure there is adequate monitoring of
block contracts to ensure greater accuracy of billing.
We understand that the Council is already undergoing the
process of moving away from block contract arrangements.
This transition should be prioritised as the operation of block
contracts required detailed tracking and monitoring in order
to be managed well, however we have not found this to be
the case.
Block contracting is not monitored sufficiently enough to
effectively track activity, meaning the billing which arises
from this type of contracting does not align with the
Council’s current position. This concerns the operation of
block contracts as opposed to the use of block contracts
themselves.
Risk:
There is insufficient tracking and monitoring of
financial incentives available to the Council,
resulting in the Council not obtaining optimum
value for money.
Agreed management action:
1. Ensure that any block contracts are
appropriately monitored to ensure that
best value is obtained.
Evidence to confirm implementation:
Active, high-quality monitoring of block
contracts.
Responsible person/title:
Service Manager
Target date:
31st August 2023
Findings and management actions (cont.)
Low
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Sample testing –contracts
We took a sample of 13 contracts under social care commissioning arrangements, using two different listings – ten from one, and three from the other. We
reviewed whether each contract was in date, sufficiently approved and agrees to the contracts database. A summary of the results from our testing is as follows:
Appendix A
# Contract in place Contract signed Contract in date Agrees to database
(value)
Agrees to database
(date)
Agrees to database
(contract no.)
1    (Note 4)  (Note 5)  (Note 6) 
2   (Note 3)    
3  (Note 1)     
4      
5      
6       (Note 7)
7      
8      
9  (Note 2)     
10      
11      
12      
13      
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Sample testing –contracts (cont.)
Appendix A
Note 1 – we were unable to obtain documentation relating to four contracts (highlighted grey), suggesting that the Council should focus on maintaining audit trails (Finding 2.5) .
We have excluded these contracts from our charts to more accurately display our results, and the following notes are all in addition to these four contracts.
Note 2 – there was one arrangement for which we confirmed with the Council that there was no contract in place, leaving no formal document to govern this working
relationship. This is in addition to the four contracts identified in Note 1. (Finding 2.5)
Note 3 – there were five contracts where signatures were incomplete. Three of these were signed by the Council but not the contracting party, one was signed by neither
party, and the final one related to the arrangement in Note 2 above. (Finding 2.5)
Note 4 – there were five contracts that had expired, two of which had extensions that expired March 2022 and March 2020, one of which contained no end dates meaning we
were unable to confirm whether it was in date, and a further one relating to the arrangement in Note 2 above. The final one contained a clause stating the duration as four years
with a further conflicting clause stating it ends when no longer required. (Finding 2.5)
Note 5 – we were unable to reconcile contract amounts to the contracts database for all of the contracts because contracts and the database used different pricing calculations
(e.g. total / per resident per week). (Finding 2.8)
Note 6 – we were unable to reconcile end dates with the contracts database for eight contracts.
(Finding 2.8)
Note 7 – we were unable to reconcile contracts numbers with the contracts database for four
contracts. (Finding 2.8)
Contract in
place
Contract
signed
Contract in
date
Agrees to
database
(value)
Agrees to
database
(date)
Agrees to
database
(contract
no.)
Yes
No
Fig 1. Summary of Sample Testing
We have presented a summary of our contract sample testing findings in graphical form, in
Figure 1.
Additional comments
In addition to these findings from our sample testing, we were unable to locate any
document that stipulates who has sufficient power to sign and approve contracts. We would
expect to see this is a scheme of delegation, or similar. Therefore, it cannot be confirmed
whether the member of staff signing on behalf of the Council had the power to do so.
(Finding 2.5)
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Sample testing –invoices
We obtained a list of AP transactions for HSCM in 2022 and selected a sample of 25 invoices from this listing. We then reviewed whether the amount as per the invoice agreed
with the listing, whether the supplier details as per the invoice agreed with the listing, and whether the invoice had been sufficiently approved. A summary of the results from
our testing is as follows:
Appendix A
# Amount agrees
to invoice
Supplier details
agree to invoice Approval
1  (Note 1)  
2   
3    (Note 2)
4   
5   
6   
7   
8   
9   
10   
11   
12   
13   
# Amount agrees
to invoice
Supplier details
agree to invoice Approval
14   
15   
16   (Note 3) 
17   
18   
19   
20   
21   
22   
23   
24   
25   
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Sample testing –invoices (cont.)
Appendix A
Note 1 – we received confirmation from the Council that it was not possible for 15 invoices in our to match expenditure with individual invoices due to the volume of payments.
As a result we were unable to test these samples. The Council should ensure that sufficient documentation is retained which acts as an audit trail for expenditure in order to
reduce the risk of duplicate or missing payments. (Finding 2.5)
Note 2 – for the ten invoices we were able to obtain documentation for, we were not able to confirm that approvals were satisfactory. Although we were able to acknowledge
that some type of confirmation had been received for the payment of invoices, we noted a number of issues with this. For example, for one invoice the person who received it
was also the person who approved it, meaning there was no segregation of duties. Other invoices had been approved in batches, meaning individual invoices may not have
been sufficiently checked. Furthermore, as we have not been able to locate a document setting out a scheme of delegation (i.e. who has the authority to approve payments), it
was also not possible to confirm that those confirming approval had the power to do so. (Finding 2.5)
Note 3 – for all but one of the invoices in our sample we obtained documentation for, we were able to reconcile the supplier details and value as per the invoice with the list of
AP transactions. For the exception, the invoice value could be reconciled but the supplier name did not match that contained within the list of AP transactions. This poses a risk
that payments are sent to the incorrect person or entity. (Finding 2.5)
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Sample testing –governance
Appendix A
We examined meeting minutes from three governance forums on an operational level, management level and leadership level and noted our findings in the boxes below.
(Finding 2.1)
Commissioning Group
Meetings
(operational level)
We could only obtain documentation for one operational meeting. Staff feel this meeting is always effective, but it
is not held consistently enough. The meeting we reviewed was well attended and contained a number of useful
actions. The risk register, however we found to be empty, unlike the ‘operational issues’ register which appeared
comprehensive.
Senior Management
Team Meetings
(management level)
We sampled ten of these meetings, for which documentation was readily available. Each meeting had space for a
standing agenda item termed ‘Gaps in Social Care Provision’ where those with oversight of commissioning are to
give an update of Moray’s current position. However, on three occasions this standing item referred to other parts
of the meeting where social care was discussed briefly, and lacked depth and detail. On a further three occasions,
this item was not discussed at all.
Systems Leadership
Group Meetings
(leadership level)
We sampled three of these meetings, all being generally well attended. But, we did note that commissioning was
not discussed in any of the three meetings sampled and there was no commissioning representative in one of
them. As a result, no constructive actions were drawn from the meetings we reviewed.
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Analysis of commissioning database
We obtained the commissioning database used to record contracts entered into with care providers, which showed a total of 73 contracts. We then performed data analysis on
the database and have noted two key areas of risk – (i) completeness; and (ii) contract start/end dates. We have set out below our approach to analysing this information and our
observations, as well as a number of other key findings to be considered. For all of the below comments, we used a cut off of August 2022.
Area of analysis – completeness
Approach:
— We initially recognised a large number of blank fields within the database and grouped columns into the five categories reflected in Table 1 & Chart 1 below . We then noted
how many blank fields each category had and tested for completeness across the database.
Findings:
 The database contains budgets ranging from 2017/18 to 2023/24, however fields relating to budgets were the least complete, with 49.49% of entries being incomplete. This
suggests budgets are not being monitored sufficiently. (Finding 2.8)
 The most complete category was information relating to contracts such as dates (however, see next page) and contract numbers, as 9.93% of fields were incomplete.
(Finding 2.8)
 Overall, we identified 575 blank entries out of a possible 2,701, suggesting that the database is, at most, 78.71% complete. (Finding 2.8)
Appendix B
Category of information Total fields
in category
No. of
blank fields
Incomplete
%
Risk
rating
Contracting party details 730 90 12.33%
Contract information 584 58 9.93%
Budgets 584 289 49.49%
Monitoring 438 63 14.38%
Other (e.g. H&SC standards, contract
request requirements, etc). 365 75 20.55%
Table 1
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Other Contract
information
Contracting
party details
Budgets MonitoringChart 1
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Analysis of commissioning database (cont.)
Area of analysis – contract start/end dates
Approach:
— We condensed the database using four identifiers – name of the contracting organisation, contract numbers, start date, and end date. From this, we were able to analyse
start and end dates in order to reach the following conclusions.
Findings:
 The earliest contract start year was 2004, with 16 contracts commencing more than ten years ago (before August 2012). This equates to 21.92% of contracts in the
database. (Finding 2.8)
 A further 27 contracts commenced more than five but less than ten years ago (August 2012 – August 2017), equating to 36.99% of contracts in the database. In Chart 2
below we have summarised the position regarding contract start dates in. (Finding 2.8)
 The earliest contract expiry year was 2017 and we identified a total of 43 expired contracts, equating to 58.90% of contracts in the database. This suggests that expired
contracts have either not been removed from the database or renewals have not been processed correctly. (Finding 2.8)
 Of those 43 expired contracts, 21 had expired more than two years ago (before August 2020), equating to 28.77% of contracts in the database. (Finding 2.8)
Appendix B
21.92%
36.99%
27.40%
13.70% Start date more than
10 years ago
Start date 5-10 years
ago
Start date less than 5
years ago
No information
Other key findings
 We noted two contracts that were not assigned a commissioning officer, which showed in the
database as ‘unallocated’. This presents a risk that there will be insufficient monitoring activity and
limits accountability should problems arise with these contracts in particular as there is no one
assigned to hold accountable.
 We found three instances where the database stated that there was no contract in place. This
suggests that either work begins before contracts are signed or the database is not updated
regularly enough.
Chart 2
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Scope extract
Background of the internal audit
Moray Council has identified the processes that support the commissioning of
services provided externally as an area of focus to ensure continuous improvement
within services.
The Commissioning Service is managed within the Moray Health and Social Care
Partnership, and is primarily concerned with social care commissioning.
The Chief Officer and Head of Service, who is also the Chief Social Work Officer, have
requested a review of the Commissioning Service as part of a continuous
improvement programme, and for the assurance required by the Integrated Joint
Board’s Audit, Performance and Risk Committee. The Chief Officer has been given a
specific instruction from the Committee to seek this review.
The review will look at the work undertaken by the Commissioning Service and
provide a report to the Integration Joint Board on how social work contracts are
awarded and managed. Our report will provide detail findings and improvement
recommendations for the Council’s Management and Commissioning Service to
implement through an action plan.
Our review will assess the design of controls over the Council’s commissioning
process against the national background, local priorities and best practice. We will also
review the operating effectiveness of the commissioning process and the extent to
which these reflect the current Standing Orders, Standing Financial Instructions and
the Scheme of Delegation in place and the Council’s level of compliance with these.
Specifically, roles and responsibilities for the commissioning process need to be
clearly defined and adhered to.
For any contract management to be successful the Council must ensure that contracts
are known and understood by all those who will be involved in their management and
there are clear lines of responsibility, roles and accountability. Contracts represent an
area of risk for many Councils where relationships often rely heavily on providers to bill
accurately for the services provided. Our review will also therefore assess the
processes and controls in place over the monitoring of contracts, management of
contractual relationships and consequences of KPI and/or contract breaches.
Our approach
Our work will involve the following activities:
— Meetings with the key staff involved in the commissioning and management of
contracts;
— Walkthroughs of the processes for commissioning and monitoring contracts;
— Desktop review of documentation supporting the internal controls;
— Sample testing of ten contracts; and
— Benchmarking of the commissioning and contract management processes and
policies against good practice.
Appendix C
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Scope extract –risks identified
Appendix C
Key risks identified
Objective One: Commissioning Controls
1 The Council does not have an accurate internal needs analysis process in place. This
results in the potential under and/or overstatement of business needs and unrealistic
budgets and timescales impacting on the subsequent procurement decisions and
best value considerations.
2 Contracts are awarded to substandard and/or unapproved suppliers that do not meet
the needs of the Council including timeliness, quality and competence. This will
impact on the quality of services and best value for the Council.
3 Contracts are awarded outside of the formal procurement procedures, preventing a
fair tender process. This may also lead to the absence of appropriate authorisation.
4 Inefficiencies in commissioning may lead to delays in the overall procurement
process, thereby increasing costs to the Council and delaying commencement of the
services.
5 The Council have insufficient organisational capability and capacity with regard to the
commissioning skills and resources required to deliver best value.
6 The Council have insufficient governance processes in place to successfully plan,
commission and manage contracts with the highest complexity, cost and risk.
7 Insufficient internal checks are performed at the Council, which fail to identify
deficiencies or gaps within the processes around commissioning.
8 Council staff involved in commissioning are not consistently complying with the
Council’s policies and procedures.
Objective Two: Contract Management Governance
9 The Council does not have robust procedures in place, applied consistently across the
Council for agreeing, monitoring and reporting on contracts.
10 The Council does not have example documentation and contracts in place, which
provide the wording for key clauses to help ensure that Council contracts are worded
in line with legal expectations and Council requirements.
11 Roles and responsibilities are not clearly set out and allocated, resulting in inadequate
completion of tasks.
12 Invoices raised are incomplete, inaccurate or not raised in a timely manner.
13 There is inadequate central oversight of billing and budgeting in relation to contracts.
Expenditure related to contracts is not appropriately authorised, in line with Standing
Financial Instructions.
14 There is insufficient tracking and monitoring of financial incentives available to the
Council, resulting in the Council not obtaining optimum value for money.
15 The Council does not have effective KPI’s in place, to support monitoring and
measuring of performance against contract terms.
16 The Council does not effectively share and report on data relating to contract
performance throughout the Council, limiting the Council’s ability to improve contract
performance.
17 Contract obligations, including non-financial obligations, are not clear opening up the
Council to the risk of regulatory or legal non-compliance.
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Acknowledgements
Appendix D
We would like to thank the following individuals for their contribution during this internal audit:
Stakeholder Title
Simon Bokor-Ingram Chief Officer of Health and Social Care Moray
Jane Mackie Chief Social Worker
Roddy Huggan Commissioning Manager
Aimee Borzoni Senior Commissioning Officer
Diane Beattie Head of Procurement
Carl Bennet Senior Performance Manager
Fiona McPherson Public Involvement Officer
Charles McKerron Integrated Services Manager
Laurie Anne Davidson Development Worker
Michelle Fleming SDS/Carers Officer
Stakeholder Title
Catherine Quinn Interim Community Care Finance Officer
Carmen Gillies Interim Strategy Lead
Tracie Wills Senior Commissioning Manager
Pauline Knox Senior Commissioning Manager
Tracey Peden Development Officer
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Ratings definitions
We have set out below the overall report grading criteria and priority ratings used to assess each individual finding.
Appendix E
Low
Medium
High
Issues arising that would, if corrected, improve internal control in general but
are not management actions which could improve the efficiency and / or
effectiveness of the system or process but which are not vital to achieving
your strategic aims and objectives. These are generally issues of good
practice that the auditors consider would achieve better outcomes.
A potentially significant or medium level weakness in the system or process
which could put you at risk of not achieving its strategic aims and objectives.
In particular, having the potential for adverse impact on your reputation or for
raising the likelihood of your strategic risks occurring.
A significant weakness in the system or process which is putting you at
serious risk of not achieving its strategic aims and objectives. In particular:
significant adverse impact on reputation; non-compliance with key statutory
requirements; or substantially raising the likelihood that any of your strategic
risks will occur. Any management action in this category would require
immediate attention.
Finding
priority rating Definition
Significant
assurance
Significant
assurance with
minor
improvement
opportunities
Partial assurance
with
improvements
required
The system is well designed and only minor low priority management actions
have been identified related to its operation. Might be indicated by priority three
only, or no management actions (i.e. any weaknesses identified relate only to
issues of good practice which could improve the efficiency and effectiveness of
the system or process).
The systems is generally well designed however minor improvements could be
made and some exceptions in its operation have been identified. Might be
indicated by one or more priority two management actions. (i.e. there are
weaknesses requiring improvement but these are not vital to the achievement of
strategic aims and objectives - however, if not addressed the weaknesses could
increase the likelihood of strategic risks occurring).
Both the design of the system and its effective operation need to be addressed
by management. Might be indicated by one or more priority one, or a high
number of priority two management actions that taken cumulatively suggest a
weak control environment. (i.e. the weakness or weaknesses identified have a
significant impact preventing achievement of strategic aims and/or objectives; or
result in an unacceptable exposure to reputation or other strategic risks).
Overall
report rating Definition
No assurance
The system has not been designed effectively and is not operating effectively.
Audit work has been limited by ineffective system design and significant
attention is needed to address the controls. Might be indicated by one or more
priority one management actions and fundamental design or operational
weaknesses in the area under review. (i.e. the weakness or weaknesses
identified have a fundamental and immediate impact preventing achievement of
strategic aims and/or objectives; or result in an unacceptable exposure to
reputation or other strategic risks).
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This report has been prepared solely for MHSCP in accordance with the terms and conditions set out in our engagement
letter. We do not accept or assume any liability or duty of care for any other purpose or to any other party. This report
should not be disclosed to any third party, quoted or referred to without our prior written consent.
© 2023 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG global organisation of independent
member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights
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This report is provided pursuant to the terms of our engagement letter. Nothing in this report constitutes a valuation or leg al advice. We have not verified the reliability or accuracy of any information
obtained in the course of our work, other than in the limited circumstances set out in our engagement letter. This report is for the sole benefit of The Moray Council: The Moray Health and Social Care
Partnership (‘MHSCP’). In preparing this report we have not taken into account the interests, needs or circumstances of anyon e apart from MHSCP, even though we may have been aware that others might
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