Democracy Spraffa

7e 2024_25_InternalAudit_ExternalPlacements_ReportFinal

Argyll and Bute Council · 12 June 2025
Back to Audit and Scrutiny Committee — 12 June 2025 and its agenda

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

Original council PDF · Download plain text

Page 1

Argyll and Bute Council
Internal Audit Report
May 2025
FINAL 
High Medium Low VFM
Number of
Findings
0 7 0 0 
External Placements
Audit Opinion: Reasonable

Page 2

2 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 5
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 7
Appendix 1 – Action Plan ..................................................................................................................... 11
Appendix 2 – Audit Opinion ................................................................................................................. 15 
Contact Details 
Internal Auditor: Moira Weatherstone 
Telephone:  01546 604146 
e-mail:   moira.weatherstone@argyll-bute.gov.uk 
www.argyll-bute.gov.uk

Page 3

3 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
1. Executive Summary
Introduction
1. As part of the 2024/25 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2024, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to External Placements.
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with council officers and the information available at
the time the fieldwork was performed. The findings outlined in this report are only those which
have come to our attention during the course of our normal audit work and are not necessarily
all the issues which may exist. Appendix 1 to this report includes agreed actions to strengthen
internal control however it is the responsibility of management to determine the extent of the
internal control system appropriate to the Council.
3. The contents of this report have been agreed with the appropriate council officers to confirm
factual accuracy and appreciation is due for the cooperation and assistance received from all
officers over the course of the audit.
Background
4. The Children (Scotland) Act 1995 is centred on the needs of children and their families and
defines both parental responsibilities and rights in relation to children.  Councils have a duty to
provide social care for those who need it, whether they provide these services themselves,
contract with the voluntary or private sector to provide them or give clients a budget to arrange
their own care.  This includes placements which are out with the authority area. 
5. Argyll & Bute Council (the Council) Children & Families provide a range of services to protect and
support vulnerable children to enable them to continue to live safely in their own communities
and to meet the Council’s statutory responsibilities. The Council also provides, where
appropriate, to meet the needs of the young person, out of authority placements in Scotland.
Out of authority placements require effective planning, engagement, and information sharing
with the services likely to be responsible for meeting the needs of children.   
6. In 2023/24 the annual budget for external placement services was £2.961m, with Social Work
providing £1,697m of this and Education providing £1.264m.  The actual spend in 2023/24
amounted to £3.411m (Social Work £1.744m and Education £1.667m). The number of young
people requiring an external placement has been increasing in recent years, the current number
of external placements is 16.  The increase in the number of placements and the increase in
rates imposed by external providers (one provider increased rates by 19%) has resulted in
budget overspends on an annual basis. 
7. In addition, with demand for external placements increasing and a large number of authorities
throughout the UK requiring placements, the availability to meet those demands is becoming
challenging.

Page 4

4 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
Scope 
8. The scope of the audit was to determine if clear measures and goals of external placements,
including the actual interventions offered meets the expected long term outcomes and
represents Best Value as outlined in the Terms of Reference agreed with the Head of Children &
Families & Criminal Justice, in addition to Head of Education-Wellbeing, Inclusion and
Achievement on the 10 February 2025.
Key Dates
9. The Terms of Reference provided provisional timescales for the review to take place, the actual
dates are noted below. 
Exhibit 1 – Key Dates
Stage Actual
Date
Terms of Reference agreed 10/02/2025
Fieldwork Commencement 24/02/2025
Draft Report issued 19/05/2025
Management Comments received 23/05/2025
Final Report issued 23/05/2025
Audit and Scrutiny Committee 12/06/2025 
Risks
10.  The risks considered throughout the audit were:
• SRR07:  Health and Social Care Partnership: Failure of the HSCP to deliver on its Strategic
Priorities results in deteriorating health and wellbeing outcomes for the population and /or
reduced access to appropriate health and social care services. This could also result in
financial and reputational risk to the Council
• Audit Risk 1: failure to have policies and procedures in place for external placements
• Audit Risk 2: failure to have robust care plans with detailed outcomes in place for external
placements
• Audit Risk 3: Failure to review and monitor young people’s progress in external placements
in terms of agreed outcomes 
• Audit Risk 4: Failure to set and monitor budgets to ensure value for money
Audit Opinion
11. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion is provided in Appendix 2 to this report. 
12. Our overall audit opinion for this audit is that we can take a reasonable level of assurance.  This
means that internal control, governance and the management of risk are broadly reliable.
However, whilst not displaying a general trend, there are areas of concern which have been

Page 5

5 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
identified where elements of residual risk or weakness may put some of the system objectives at
risk. 
Recommendations
13. We have highlighted 7 medium priority recommendations where we believe there is scope to
strengthen the control and governance environment. These are summarised below:
• Procedures should be put in place that outline the various steps to be taken when
placing young people in external placements, this should include details of the review
processes
• Consideration should be given to inviting education to participate in the weekly resource
panel meetings and/or minutes shared
• Consideration should be given to requesting regular reports from providers detailing
achievements and progress towards outcomes
• Visits to providers should resume 
• Procedures should be put in place for young people leaving care to ensure that they
have a clear pathway towards a positive destination and destinations are being recorded
• There is increased risks associated with the current model of care and increased demand
on Social Work and Education budgets resulting in significant overspends. Budgets could
be reviewed in conjunction to considering alternate models of care which could be
delivered internally, where that is deemed appropriate
• the costs of care and education must be fully transparent and broken down into each
element with reports provided to both services for each individual package
14. Full details of the audit findings, recommendations and management responses can be found in
Section 3 of this report and in the action plan at Appendix 1.
2. Objectives and Summary Assessment
15. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.  
Exhibit 1 – Summary Assessment of Control Objectives 
Control Objective Link to Risk Assessment Summary Conclusion
1 Policies and
procedures are in
place for the
assessment and care
planning  of young
people
SRR07
Audit Risk 1
Audit Risk 2
Reasonable An Option Appraisal Meeting Practice
Guidance Document (the Document)
dated 2021, was made available for
review.  This document outlines the
agreed approach between Argyll and
Bute Education services and HSCP
children’s services when considering
possible care options for any looked
after and accommodated young
person. Roles and responsibilities are
detailed in the document, however this
has not been updated to reflect the
role of the Care Assessment Reviewing
Officers (CARO) in the process.  The

Page 6

6 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
document outlines who is authorised
to approve admissions to care,
including if this is an emergency
placement.  There was no process
document which outlined, for
practitioners, the various stages of the
process from referral (or emergency
placement) stage to the actual
placement of the young person. 
Procedures are understood by those
undertaking the tasks.
2 All young people in
external placements
have care plans in
place with clear
goals and
intervention which
meet the needs of
the young person
Audit Risk 2 Reasonable Care plans are kept up to date and
amended following any interventions
or reviews.  In addition, as detailed
above weekly internal reviews are
undertaken looking at each placement. 
However, it is noted that Care Plans
and case notes were not always
updated timeously on Eclipse.  Care
providers do not routinely provide
regular updates to Social Work or
Education on progress being made or
whether outcomes are being achieved.  
3 Reviews are
undertaken with
progress to
achieving goals
discussed
Audit Risk 3 Reasonable Formal case reviews are held within 72
hours of placement, 6 weeks and then
3 months.  Visits to the providers were
undertaken by the Virtual Head
Teacher and the Residential and
Aftercare Manager, this allowed more
informal discussions to take place
around whether outcomes were being
achieved and discuss any amendments
to the care plan in place.  Due to staff
changes these have not been taking
place.  
4 Long term outcomes
are assessed and
destinations
recorded at the end
of the external
placement
Audit Risk 3 Reasonable It was unclear whether there were
robust procedures and monitoring in
place for young people leaving care
with many returning to their previous
locations.  This became more
challenging when the young person left
education, although it was noted that
the Virtual Head Teacher ensured that
all efforts were made to secure a
positive destination for that young
person.
5 Budgets are aligned
to ensure costs
reflect the cost of
care and education
elements of the
Audit Risk 4 Reasonable Like other authorities, the Council has
very little control over the cost of
external placements, with providers
setting the cost against a background
of competing demands from

Page 7

7 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
placement, with
value for money
being monitored
authorities throughout Scotland.  In
addition, the need for external
placements is increasing each year.  In
many cases there are no internal
resources available to meet the needs
of the young person.  Clear costings are
given from the providers, they are
available to see in advance of
contacting them to discuss any
prospective placement, and these are
available through the Scotland Excel
procurement service website. The
breakdown of all cost of care and
education placements is 38%
education and 62% care with the
placements agreed jointly by Heads of
Service for both care and education. 
16. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
Policies and procedures are in place for the assessment and care planning of young people 
17. An Option Appraisal Meeting Practice Guidance Document (the Document) dated 2021, was
made available for review.  This document outlines the agreed approach between Argyll and
Bute Education services and HSCP children’s services when considering possible care options for
any Looked after and accommodated young person.   
18. Roles and responsibilities are detailed in the document, however, it has not been updated to
reflect the role of the Care Assessment Reviewing Officers (CARO) in the process.  The document
outlines who is authorised to approve admissions to care, including if this is an emergency
placement, however, it does not outline the complete process or responsibilities in terms of
identifying placement information, contracting, sharing information with providers and the
review follow up processes.                                                                                                                                                               
Action Plan 1
19. The option appraisal process clearly seeks to consider all options open to meet the needs of the
young person and where a child requires care, and where there are no kinship options, the
options appraisal process aims to match the child to the most appropriate available care option.
It is stated that consideration should only be given to an external care option where other
options have been exhausted.  At this point, the Senior Manger Children’s Resources may
request an external care screening panel and authorise initial approaches to potential providers
where urgent. 
20. The processes for consideration being given to an external placement are robust with a Multi-
agency Options Appraisal Panel being convened. The options appraisal meeting will consider all
provider’s proposals to meet the child’s needs, along with; cost, previous experience of the

Page 8

8 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
provider and any registration or inspection issues, to identify a recommended preferred option.
The panel has 2 purposes: 
• To consider whether an options appraisal of external care providers should be
undertaken 
• To approve a preferred external option – where required 
21. Significant scrutiny and oversight is also given to external placements. A Joint Resource Group
(JRG) Terms of Reference was provided. The JRG is the interagency management group with
operational responsibility for promoting and overseeing effective joint working between
Education, Health and Social Work, and for ensuring the effective prioritisation and deployment
of interagency resources in respect of individual children, in line with the principles and values of
GIRFEC (Getting it Right for Every Child) and best value. The remit of the JRG group includes: 
• Consideration of requests for funding of complex interagency packages of support,
including Social Work packages over £30,000
• Consideration of requests for external placements including residential school and day
education placements and CAMHS tier 4 commissioned services 
• Monitor the progress of care planning for high profile cases including children at risk,
secure placements and children in the community 
• Consider any issues of concern around meeting the needs of looked after and
accommodated children as identified by the CAROs
• Monitor receptions into care, transfers and discharges
• Consider variations in contracts in respect of children in external placements 
22. Weekly Children’s Resource Panel meetings are chaired by the Senior Manager for Resources
and are attended by the Senior Managers for Resources and Justice and the two operational
Service Managers.  This is an internal meeting where each external placement is reviewed, in
addition to discussion on any potential placements coming forward.  Minutes of this meeting are
recorded, however are not shared with education.  The details of individual children’s plans are
shared with education at review meetings, however, we understand that such meetings may not
always be taking place within expected timescales or are being postponed.            
Action Plan 2
All young people in external placements have care plans in place with clear goals and
intervention which meet the needs of the young person 
23. Care plans are kept up to date and amended following any interventions or reviews.  In addition,
as detailed above, weekly internal reviews are undertaken looking at each placement.  It is noted
that Care Plans and case notes were not always updated timeously on Eclipse, however, regular
supervision by the Line Manager ensured that case records were discussed and where necessary
highlighted if care plans are not updated. 
24. Care providers do not routinely provide regular updates to Social Work or Education on progress
being made or whether outcomes are being achieved.  The lack of regular updates makes it
challenging to monitor and adapt care plans where goals and interventions are not meeting the
needs of the young person.                                                                                                                                              
Action Plan 3

Page 9

9 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
Reviews are undertaken with progress to achieving goals discussed 
25. Formal case reviews should be held within 72 hours of placement, after 6 weeks and also after 3
months.  Visits to the providers were previously undertaken by the Virtual Head Teacher and the
Residential and Aftercare Manager, this allowed more informal discussions to take place around
whether outcomes were being achieved and discuss any amendments to the care plan in place. 
Due to staff changes these have not been taking place.                                                                                                                                                               
Action Plan 4
Long term outcomes are assessed and destinations recorded at the end of the external
placement 
26. It was unclear whether there were robust procedures and monitoring in place for young people
leaving care with many returning to their previous locations.  This became more challenging
when the young person left education, although it was noted that the Virtual Head Teacher
ensured that all efforts were made to secure a positive destination for that young person. 
Action Point 5                                                                                                                                              
Budgets are aligned to ensure costs reflect the cost of care and education elements of the
placement, with value for money being monitored 
27. Like other authorities, the Council has very little control over the cost of external placements,
with providers setting the cost against a background of competing demands from authorities
throughout Scotland.  In addition, the need for external placements is increasing each year.  In
many cases there are no internal resources available to meet the needs of the young person,
leaving the only option open to the Authority to place externally.  The increasing demands
within the Council is resulting in significant budget overspends, the demand for such services are
projected to increase in the coming years. 
Action Point 6             
28. Clear costings are given from the providers, they are available to see in advance of making
contact to discuss any prospective placement, and these are available through the Scotland Excel
procurement service website. The breakdown of all care and education placements is 38%
education and 62% care with the placements agreed jointly by Heads of Service for both Care
and Education. In addition to the breakdown of Care and Education, providers detail their
costing for any specialist resources that may be necessary to meet the individual needs of the
young person.  It is unclear whether education are provided with a copy of the costs of the
provision of the education in order that they can review best value for the service provided. 
Action Point 7 
29. The costings for the placements are reviewed in line with the Individual Placement Agreement
(IPA) contracts that are generated through Scotland Excel, contained within these contracts are
the parameters of any increments planned for coming years. Working alongside Financial
Services, Social Work are alert to any deviation from agreed costs signed for with IPA and no
additional funds will ever be released unless an updated and jointly signed IPA is in place. Both

Page 10

10 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
Care and Education Financial Services work jointly to ensure that invoices are accurate and
reflect only what has been confirmed within the IPA. 
30. The cost of individual care packages is significant and can cost up to £10k per week, the demand
is projected to rise in line with the profile of the last few years.  It is difficult to assess whether
the Council is receiving value for money for each individual placement, particularly if outcomes
are not achieved or the placement does not result in a positive destination, however, it is
recognised that against this backdrop, young people are provided with a safe environment. 
Without alternate internal solutions regarding the mode of care, the Council will require to
continue placing young people externally.  Greater monitoring of outcomes, achievements and
destinations, including regular reporting on progress from providers will ensure that value for
money in each placement is achieved.

Page 11

Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Medium
1
Options Appraisal Meeting Practice Guidance
The Options Appraisal Meeting Practice Guidance
document does not outline the complete process or
responsibilities in terms of identifying placement
information, contracting, sharing information with
providers and the review follow up processes.
Inconsistencies in practice and
a lack of shared understanding
of processes
A simplified pathway schematic
will be drawn.
Head of Children Families
and Justice 
31 March 2026
Medium
2
Sharing of Information
Children’s Resource Panel meetings take place weekly. 
This is an internal meeting where each external placement
is reviewed, in addition to discussing any potential
placements coming forward.  Minutes of this meeting are
recorded, however, are not shared with Education.
Important updates regarding
education may not be shared
A member of the senior education
team will attend the weekly
meeting, where possible. 
Minutes of meetings will be
shared with Education Service-
directly to Principal Educational
Psychologist, Ed Mgr Inclusion and
ASN and Virtual Headteacher. 
Head of Children Families
and Justice/Head of
Education-Wellbeing,
Inclusion and
Achievement 
31 March 2026
Medium
3
Reports from providers
The lack of regular updates from providers makes it
challenging to monitor and adapt care plans where goals
and interventions are not meeting the needs of the young
person.
Failure to achieve early
interventions and adapt Care
Plans to meet the changing
needs of young people
Termly updates from providers
will be requested and shared with
Social Work and Education staff as
appropriate, and discussed at
relevant multi-agency review
meetings.
Head of Children Families
and Justice/Head of
Education-Wellbeing,
Inclusion and
Achievement 
31 March 2026
Medium
4
Provider Monitoring Visits 
Visits to the providers were previously undertaken by the
Virtual Head Teacher and the Residential and Aftercare
Manager, this allowed more informal discussions to take
place around whether outcomes were being achieved and
discuss any amendments to the care plan in place.  Due to
staff changes these have not been taking place.  
Lack of monitoring of care
providers 
Virtual Headteacher will work
with relevant staff in SW C&F
team to undertake a programme
of visits to all care settings over
the course of a rolling 12 month
period. 
These will be of a commissioning
nature rather than care planning
and feedback shared via the
placement review process.
Head of Education-
Wellbeing, Inclusion and
Achievement/Head of
Children Families and
Justice 
31 March 2026

Page 12

12 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
No Finding Risk Agreed Action Responsibility / Due Date
Medium
5
Destinations
It was unclear whether there were robust procedures and
monitoring in place for young people leaving care with
many returning to their previous locations and no clear
pathway for the future.  
No positive destination for
young person leaving care
There requires to be a
fundamental review of the models
of care within A&B encompassing
the use of external placements. 
The child’s journey within
placement and discharge planning
requires as much focus as
admission. 
Head of Children Families
and Justice 
31 March 2026
Medium
6
Model of Care and Costs
The increasing demands within the Council is resulting in
significant budget overspends and the demand for services
is projected to increase in the coming years. In many cases
there are no internal resources available to meet the
needs of the young person, resulting in the only option
being looking for external placements.
Budgets not aligned to
demand increasing risks of
budget overspends
Continue to explore options to
develop internal resources for the
education and care of Argyll and
Bute’s children within its existing
asset base- specifically in line with
Education’s work on the
development of Secondary
Wellbeing Hubs and the
development of the work of
Children’s Houses. 
As in finding 5 there is a need for
a fundamental review of the
models of care. 
Head of Children Families
and Justice/Head of
Education-Wellbeing,
Inclusion and
Achievement 
31 March 2026
Medium
7
Sharing of Costs 
It is clear that need is currently outstripping the budget
available to accommodate this cohort of children. The
breakdown of all care and education placements is 38%
education and 62% care with the placements agreed
jointly by Heads of Service for both care and education. It
is unclear if a detailed breakdown of cost in regards the
care and education service of each placement is provided.
The value of what is provided
by external placements is not
clear. This is particularly the
case where costs move
beyond the baseline and extra
is provided. 
If the current numbers of
young people in external
Providers are expected to provide
a more detailed breakdown of
costs, particularly extra costs to
inform consideration and decision
making at service level. 
There will need to be a focus on
data trends.
Head of Children Families
and Justice/Head of
Education-Wellbeing,
Inclusion and
Achievement 
31 March 2026

Page 13

13 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
No Finding Risk Agreed Action Responsibility / Due Date
placements is in fact a longer
term trend the current budget
will result in an inherent
deficit

Page 14

14 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained.  The definitions
of each classification are as follows: 
Grading    Definition
High  A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the
objectives of the system.  The weakness may therefore give rise to loss or error. 
Medium 
Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting
the objectives of the system.  The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective
action was taken.  
Low  Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected.  The weakness does
not appear to significantly affect the ability of the system to meet its objectives. 
VFM  An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve
better value for money (VFM).

Page 15

15 
Argyll and Bute Council – Internal Audit Report – External Placements, May 2025 
Appendix 2 – Audit Opinion 
Level of Assurance  Definition 
High  Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have
been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system
objectives is in place and being applied consistently. 
Substantial  Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be
addressed within a reasonable timescale. 
Reasonable 
Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend,
there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system
objectives at risk. 
Limited  Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an
acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with
management allocating appropriate resources to the issues raised. 
No Assurance  Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with
basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with
management allocating appropriate resources to the issues.