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.
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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.
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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
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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
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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
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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).
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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.